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Gund Forever Friends Promise™
Privacy Policy

Effective Date: September 1, 2026

This Privacy Notice applies only to your interactions with us through the Gund Forever Friends Promise™ Program (the “Program”) owned or controlled by Spin Master Toys UK Limited (“Spin Master”, “we”, “us”, or “our”), a company registered in England and Wales with registered office at Meridian House, Fieldhouse Lane, SL7 1TB Marlow Buckinghamshire, UK.

Your interactions with our websites and mobile apps outside of the Program are otherwise subject to our main privacy policy, located at https://privacy.spinmaster.com/. The Program does not target and is not intended for users younger than 18. The Program is designed for parents and guardians to register on behalf of their children, and we do not knowingly collect personal data directly from any person younger than the age of 18, including a child’s name or other identifying information relating to a child.

If you are a child or young person (under 18), please read the “Information for Children and Young People” section below first.

Our Data Protection Officer can be contacted at dpo@spinmaster.com. Please also review the Terms of Service which govern your use of the Program.

Personal Data We Collect

Personal Data You Provide to Us Directly

We collect personal data from you directly when you interact with the Program platform, accessible through the QR code located on the tag of the plush friend (“Plush Friend”), either when you are registering the Plush Friend as a parent or guardian (“User”) or you are returning the Plush Friend as a finder (“Finder”). We may process the following categories of personal data about you depending on how you interact with the Program:

  • Personal Details such as first name, last name, email address, and mobile phone number.
  • Age Verification Data we use month and year of birth to verify age at the point of entry. We do not intend to store this information and we configure the service to avoid retaining it (other than transient processing necessary to apply the agegate).
  • Verification Data such as the mobile phone number used for two-factor authentication, one-time verification codes.
  • Technical Data such as internet protocol (IP) address, login data, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Program.
  • Communications Data such as messages you send to our customer care team and your preferences in receiving marketing communications from us.

How We Collect Your Personal Data

Data We Collect From You

We collect personal data from the following sources: directly from you, when you scan the QR code on your Plush Friend’s sewn-in tag and register through the Program, report a Plush Friend as lost or found, contact our customer care team, or opt in to receive marketing communications; and automatically, when you access the Program platform (including via cookies and similar technologies).

Data We Collect Automatically

We and our third-party service providers may use technologies, including cookies, that automatically collect certain information about you and your device whenever you access, use, or otherwise interact with the Program platform. Such cookies are used to allow the Program platform to function properly and are set in response to actions made by you when accessing the Program, such as loading the Program platform, logging in, and filling out form fields. These are “strictly necessary” cookies that do not require your consent. In addition, these technologies may also include analytics or performance cookies, which help us understand how visitors interact with the Program platform by collecting information such as pageviews, traffic sources, user journeys, and site performance metrics. In addition, we and our third-party partners may use targeting or advertising cookies (typically third-party marketing cookies, such as the Facebook/Meta pixel) to deliver relevant advertising and measure the effectiveness of advertising campaigns.

You can find more information about cookies and how they work at https://www.allaboutcookies.org/.

Uses of Personal Data

Purpose for Processing

Categories of Data

Lawful basis

Registration and account management. To register your Plush Friend, set up and manage  your Program account, and provide Program services.

Personal Details
Plush Friend Details
Verification Data

Performance of contract  with Users, including to provide and administer the Program services we have agreed to provide to you.

Reunification. To facilitate the reunification of a lost Plush Friend with its registered User, including processing Finder submissions, coordinating the return through our customer care team, and arranging shipping.

Personal Details
Plush Friend Details
Communications Data

Performance of contract (for Users).

Legitimate interest
(for Finders) in facilitating the return of a registered Plush Friend to its owner.

Age verification. To verify that you meet the minimum age requirement (18) to  access the Program.

Age Verification Data
Communications Data

Legitimate interest in ensuring the platform is accessed only by adults.

Customer support. To respond to your enquiries and provide customer care support, including  managing reports of lost Plush Friends.

Personal Details
Plush Friend Details
Communications Data

Performance of contract (for Users).

Legitimate  interest
(for Finders and visitors) in providing responsive customer support.

Marketing. To send you direct  marketing communications about GUND products and the Spin Master group of companies, where you have opted-in to receive such communications.

Personal Details  
Communications Data

Consent. You may withdraw  your consent at any time without affecting the lawfulness of processing carried out before withdrawal.

Security and fraud prevention. To prevent fraud and ensure the security of the Program,  including detecting and preventing misuse of the QR code system and monitoring for unauthorised access.

Personal Details
Plush Friend Details
Communications Data

Legitimate interest in ensuring the safety and security of the Program and preventing fraud or misuse.

Compliance with legal obligations and safeguarding rights. To comply with our legal and regulatory obligations in the UK, including responding to court orders, regulatory requests, or other legal processes and to respond to court orders,  exercise and/or defend our legal rights and in connection with complaints or legal claims made by, against, or otherwise involving you.

Any of the categories of personal data detailed in this Privacy Notice: specific category will depend upon the specific obligation or request.

Legal obligation.

Only to the extent legal obligation does not apply.

Legitimate interest
in establishing, exercising and/or defending legal claims.

Merger/acquisition. In connection with a sale, transfer of assets, acquisition, or other corporate transition, including during due diligence.

Any of the categories of personal data detailed in this Privacy Notice: specific category will depend upon the context of the transaction.

Legitimate interests in managing and growing the business and making investment decisions.

Disclosures of Personal Data

We may disclose the personal data we collect to the following categories of recipients:

  • OpenScreen – our third-party platform provider that operates the Program platform on our behalf;
  • Shipping and logistics providers – to facilitate the return of a found Plush Friend;
  • Authentication providers – to verify Users through multi-factor authentication;
  • Spin Master group affiliates – meaning entities that control, are controlled by, or are under common control with Spin Master Toys UK Limited, who may use the personal data we share in a manner consistent with this Privacy Notice for business and operational purposes; and
  • Professional advisers and authorities – including legal, regulatory, and tax advisers, and law enforcement or regulatory bodies where required by applicable UK law.

When you (as a User) register a Plush Friend or claim (as a Finder) that you have found a Plush Friend, we will share such information as necessary to reunite the Plush Friend with the applicable User. The Finder will not receive the User’s contact information.

We may also share your personal data where we are required to do so by UK law or to comply with a court order, regulatory requirement, or other legal process applicable in the United Kingdom, or to protect against fraud or illegal activity.

Your personal data may be provided to third parties in connection with a business transaction, including a merger, sale, or corporate reorganisation, or other change in corporate control. In such circumstances, we will inform you of any change in controller identity and the applicable lawful basis for continued processing.

We do not share personal data collected through our SMS text message verification service (such as mobile number and record of consent) with third parties for their own direct marketing purposes.

We may share non-personal information, including de-identified or pseudonymised information and aggregated user statistics, with third parties for analytical purposes. Where any such data constitutes personal data under UK GDPR, we will ensure an appropriate lawful basis and safeguards are in place before sharing.

Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing and against accidental loss, destruction, or damage. These measures include two-factor authentication for account access and data minimisation in the Finder flow (Finders do not receive User contact information). However, no method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.

Data Retention

Your Personal Data will be retained for as long as necessary to fulfil the purpose for which it was processed or to comply with legal, regulatory or internal policy requirements.

Further information about our retention periods can be obtained by contacting us at the contact details specified in this Privacy Notice.

Your Rights

You have certain rights regarding your personal data under applicable data protection laws. A summary of these rights appears below.  Please note that these rights are not absolute and certain exemptions may apply to specific requests that you may submit to us.

To exercise these rights (with the exception of the right to lodge a complaint with a data protection authority), please contact us using the information above in the “Contact us” section.  For your protection, we may need to verify your identity before responding to your request.  In the event that we refuse a request, we will provide you a reason as to why.

  1. Access and to be informed: To request a copy and/or to be informed of the personal data we hold about you.
  2. Rectification: To request correction of inaccurate or incomplete personal data.
  3. Erasure: To request the deletion of personal data, where applicable.
  4. Restriction: To request the restriction of processing, where applicable.
  5. Objection: To object to processing based on our legitimate interests due to grounds relating to your situation and to object to processing for direct marketing purposes.
  6. Data portability: To request a copy of your personal data, which you have provided to us and where the legal basis for the processing is your consent or performance of a contract, in a structured, commonly used, machine-readable format.
  7. Withdraw consent: To withdraw consent at any time with effect for the future, where consent was provided for processing.
  8. To be informed about data transfers: To request more information about the countries where your data is transferred and, where such countries have not been recognised as providing an adequate level of data protection, to request more information about the appropriate safeguards implemented such as standard data protection clauses.
  9. Right to complain to controller (UK only): Should you reside in the UK, you also have a right to complain directly to the relevant Controller about that Controller’s processing of your personal data by writing to legal@spinmaster.com.
  10. Right to complain to supervisory authority. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO). You may contact ICO here.

International Transfers of Your Personal Data

Your personal data may be transferred to, and processed in, countries outside the United Kingdom, including the United States (where our platform provider OpenScreen and certain Spin Master group servers are located). These countries may not provide the same level of data protection as the United Kingdom. Where we transfer personal data outside the UK to a country that has not been deemed to provide an adequate level of protection by the UK Secretary of State, we ensure that appropriate safeguards are in place, including: (a) the UK International Data Transfer Agreement (UK IDTA); or (b) the EU Standard Contractual Clauses supplemented by the UK Addendum, as applicable.

Information for Children and Young People

This section is written for children and young people who may visit or use our Program. We want to explain in a simple way what happens with personal information when someone uses our service.

Who are we? We are Spin Master Toys UK Limited, the company behind Gund plush toys in the UK. We run the Program, which helps reunite lost plush friends with their owners.

Is this service for me? This service is designed for grown-ups (parents and guardians) to use. If you are under 18, please ask your parent or guardian to register your plush friend for you. You should not fill in any forms or give us your name, email, or phone number yourself.

Is this service for me? This service is designed for grown-ups (parents and guardians) to use. If you are under 18, please ask your parent or guardian to register your plush friend for you. You should not fill in any forms or give us your name, email, or phone number yourself.

What information do we collect? When a grown-up registers a plushfriend, we ask them for their name, email address, and phone number. We alsoask what name has been given to the plush friend (for example, “Teddy” or “Snuffles”). We do not ask for your name or any information about you.

Why do we collect it? We collect this information so that if your plush friend ever gets lost, we can help get it back to you. If someone finds your plush friend and scans the special code on the label, we will contact your parent or guardian to arrange for your plush friend to be returned. The person who finds it will not be given your family’s contact details.

Who do we share it with? We only share information with people who help us run the Program, like the company that manages the website and the company that helps return your plush friend to you. We never sell anyone’s information.

How long do we keep it? We keep your parent’s or guardian’s information for as long as needed to run the account / return the plush and then we delete or anonymise it, subject to legal/administrative needs.

What are your rights? Your parent or guardian can ask us at any time to see what information we hold, ask us to correct it if it’s wrong, or ask us to delete it. If your parent or guardian are unhappy about how we use information, they can tell us and we will try to sort it out. They can also complain to the Information Commissioner’s Office (the ICO), which is the organisation that makes sure companies like us follow the rules about personal information.

Found a plush friend? If you have found a lost plush friend and you are under 18, please ask your parent or guardian to scan the code and fill in the form for you. Please do not enter your own details.

Changes to this Notice

We may update this Privacy Notice from time to time. When we make material changes, we will notify you by posting the updated Privacy Notice on the Program website. We will update the effective date at the top of this Privacy Notice.

Contact Us

If you have any questions about this Privacy Notice or our processing of your personal data, please contact us at: Spin Master Toys UK Limited, Meridian House, Fieldhouse Lane, SL7 1TB Marlow Buckinghamshire, UK; Email: dpo@spinmaster.com; Telephone: 0800 206 1191. You may also contact our Data Protection Officer directly at dpo@spinmaster.com.

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