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Effective Date: September 1, 2026
Last Update: September 1, 2026
This Gund Forever Friends Promise™ Program Privacy Policy (Canada) (the “Privacy Policy”) applies only to your interactions with us through the Gund Forever Friends™ Program (the “Program”) owned or controlled by Spin Master Ltd. (“Spin Master”, “we”, “us” or “our”). 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 the age of majority (“Minors”) and we do not knowingly collect personal information from or about Minors. For clarity, Minors are persons under the age of 18 in Alberta, Manitoba, Ontario, Prince Edward Island, Quebec, and Saskatchewan, and persons under the age of 19 in British Columbia, New Brunswick, Newfoundland, Northwest Territories, Nova Scotia, Nunavut, and Yukon.
Please also review the Terms of Service which govern your use of the Program.
If you do not agree with this Privacy Policy and the Terms of Service, do not access or use the Program or provide personal information to us.
PRIVACY POLICY – SUMMARY OF KEY POINTS
We appreciate that your time is valuable. We have summarized some key elements of the Privacy Policy below. Please read the full Privacy Policy for complete details.
Personal Information We Collect & How We Collect It
We collect the following categories of personal information in connection with the Program:
Such information is collected by email, through online forms, and using cookies on the Program platform. You may contact our Data Protection Officer if you have questions about our collection of your personal information.
Purposes for Collection, Use, Communication and Disclosure
We collect, use, communicate and disclose personal information in connection with the Program for the following purposes:
Third Parties With Whom We Share Personal Information
We may share personal information in connection with the Program with the following third parties:
Risks, Consequences & International Transfers
Your personal information may be transferred to and stored in countries outside of Canada (and, if you are located in Quebec, outside of Quebec). When your information is transferred or stored outside of Canada, it may be accessible to courts, law enforcement and national authorities in those countries, which may have different privacy laws than Canada. You may contact our Data Protection Officer if you have questions about our foreign service providers or to obtain written information about our policies and practices with respect to such service providers.
Your Rights
You have certain rights with respect to your personal information, subject to permitted and required limitations under applicable law, including to access and rectify your information or withdraw consent to our use and communication of your information.
Personal Information You Provide to Us Directly
We collect personal information from you directly when you interact with the Program platform, accessible through the QR code located on the tag of an eligible Gund plush friend (“Plush Friend”) either when you are registering the Plush Friend as a user or you are returning the Plush Friend as a finder. We use the term “personal information” to mean any data that could be used to identify you, alone or together with other available information, including contact information (name, address, email address, phone number), messages you send to our customer care team, and specifically for users registering a Plush Friend, the name you have given to the Plush Friend and date of purchase. We will also treat other information, including IP addresses and cookie identifiers, as “personal information” where required by applicable law. Note that we may anonymize or de-identify personal information where permitted by applicable law, such as aggregating or converting it to a code, sometimes using a function commonly known as “hash”. We maintain and use de-identified data without attempting to re-identify it, except where permitted by applicable law, such as to determine whether our de-identification processes satisfy legal requirements. We will treat anonymized data as non-personal to the fullest extent allowed by applicable law. If we combine non-personal information with personal information, then we will treat the combined data as personal information under this Privacy Policy and as required by applicable law. The personal information that you provide to us directly is collected using online forms on the Program platform and by email.
Data We Collect Automatically
We and our third-party business partners (including any third party service providers and analytics providers) may use a variety of technologies, including cookies, that automatically or passively collect certain information about you or your device used to access the Program platform, whenever you access, use, or otherwise interact with the Program platform. Such cookies are used to allow the Program platform to function properly, and they are set in response to actions made by you when accessing the Program platform such as loading the Program platform, logging in, and filling out form fields.
“Cookies” and local storage are pieces of information (data files) transferred to a browser when the user visits the Program platform. Cookies and similar technologies may be used for many purposes by us and our third party providers, such as automatically collecting device information, keeping your use of the Program platform more secure, maintaining the integrity of the Program platform, and enabling essential functionality. 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 page views, 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. Certain browsers or browser add-ons may provide additional local data storage mechanisms that are used in a manner similar to cookies, and some of the content included on our Program platform may make use of this local storage. Most browsers provide you with the ability to disable, decline, or clear cookies and local storage; please check your browser’s settings for further information. You can find more information about cookies and how they work at https://www.allaboutcookies.org/.
We may use the personal information described in this Privacy Policy to provide the Program to you, including the platform, and to fulfill, track, ship, and otherwise facilitate the reunification of a Plush Friend with a user, for other ongoing customer support, internal record keeping, and as otherwise needed to meet our legal and tax obligations, including as needed to respond to subpoenas, court orders, or legal processes.
If you opt-in to receive GUND Forever Friends promotional communications, we will also use your contact information to send such messages by email.
We may also use your personal information to prevent fraud or other illegal activity, or to protect our or third-party rights; in connection with a merger, acquisition, consolidation, bankruptcy, or other corporate transition, including during due diligence; and for other purposes as disclosed at the time of collection or with your consent.
We may share the personal information we collect with third parties to assist us in performing certain services and functions related to the Program. In particular, your contact information may be disclosed to third parties to facilitate the shipping of a found or replacement Plush Friend (e.g., FedEx Canada, Canada Post, etc.), and your personal information may also be shared with Spin Master’s service providers such as those that provide the Program platform, verify users through multi-factor authentication, provide customer support services, and conduct analytics and reporting. 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.
We and our service providers may also share your personal information to the extent we reasonably believe we are required to do so by law or to comply with legal or regulatory requirements, such as a warrant, subpoena, or other court order, or to protect against fraud, illegal activity, or as otherwise required or permitted by applicable domestic or international laws or legal processes.
We may share certain personal information with our affiliates, meaning an entity that controls, is controlled by, or is under common control with Spin Master. Our affiliates may use the personal information we share in a manner consistent with this Privacy Policy, including for business and operational purposes.
Your personal information may be provided to third parties in connection with a business transaction, including a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) or as part of a corporate reorganization, or stock or asset sale, or other change in corporate control, including for the purpose of determining whether to proceed or continue with such transaction or business arrangements.
Notwithstanding anything else in this Privacy Policy, we do not share personal information we collect specific to our SMS/MMS/RCS text message programs (such as mobile number and record of consent) with third parties for their own direct marketing purposes without your specific consent.
To the fullest extent permitted by applicable law, we may share anonymized data with third parties in our discretion, including for marketing purposes.
We keep personal information as long as it is necessary or relevant for the purposes described in this Privacy Policy.
We use commercially reasonable security measures to protect against loss or theft of personal information, as well as unauthorized access, disclosure, communication, copying, use, or modification of personal information, or any other breach of the protection of personal information within our custody or control. However, there is no such thing as 100% security of the networks, servers, and databases we operate or that are operated on our behalf. Before submitting any personal information, please be aware of these inherent risks and understand that you do so at your own risk.
You may access and rectify your personal information, or withdraw your consent to the collection, use, communication or disclosure of your personal information, subject to permitted or required exceptions, limitations and conditions pursuant to applicable laws in the jurisdiction where you are located. You also have the right to submit a challenge or make a complaint about our handling of your personal information or compliance with applicable laws, and you may have additional rights in some jurisdictions.
Please contact us, as described below, for more information or to exercise your rights. We will respond to requests from individuals to exercise their rights with respect to their personal information in accordance with applicable laws.
Information we maintain may be stored both within and outside Canada. As part of the services offered, the information you provide to us may be transferred to countries outside Canada including the United States (and if you are located in Quebec, your information may be communicated outside Quebec). Information that is transferred or stored outside Canada may be accessible to courts, law enforcement and national authorities in other countries.
To the extent allowed by applicable law, we reserve the right to alter, modify, update, add to, subtract from, or otherwise change this Privacy Policy at our discretion at any time. When changes are made, we will post the updated Privacy Policy, and we will update the effective date at the outset of this Privacy Policy. Where required by applicable law, we will notify you of any changes to the Privacy Policy that impact your personal information, and when necessary under such laws we will obtain your consent to changes in how we collect, use and/or share your personal information.
As this Privacy Policy may be modified from time-to-time, we encourage you to periodically review this Privacy Policy to stay informed about how we collect, use, and share personal information.
If you have any questions about this Privacy Policy or our collection and other processing of your personal information, please contact our Data Protection Officer at dpo@spinmaster.com. Alternatively, our Customer Care line is +1 800-622-8339. You may also contact our Data Protection Officer at dpo@spinmaster.com if you have questions about the collection, use, communication, disclosure or storage of personal information in connection with the Program, by our service providers and affiliates outside Canada, or to obtain written information about our policies and practices with respect to such service providers and affiliates.
Roles and Responsibilities of Spin Master Personnel
Personal information collected in connection with the Program will be accessible to our brand team, marketing team, IT team, customer care team and legal team who require such information to perform their job duties. Such personnel are responsible for protecting the confidentiality and security of the personal information they handle in connection with their employment throughout the lifecycle of such information, following SpinMaster’s security measures and its policies and procedures for handling such personal information, and ensuring they only access, use and share personal information for authorized purposes. Our customer care team is also responsible for responding to (or escalating, where appropriate) questions and complaints related to the personal information collected in connection with the Program, and our IT team is responsible for designing and implementing appropriate safeguards to protect such personal information. Spin Master’s Data Protection Officer provides guidance and training to personnel in order to help them fulfil their responsibilities, as described above.
Retention and Destruction
We retain your information for the following periods:
Once the purpose for collecting and using your personal information is achieved and any applicable retention period has expired (as described above), we will destroy the information, unless we are permitted or required to retain the information under applicable law. Personal information printed on paper is destroyed by shredding or incinerating. Personal information stored by electronic means is destroyed by deleting information using methods that resist simple recovery methods, such as overwriting, which can be done using software and hardware products that overwrite the media with non-sensitive data.
Compliant Process
Spin Master’s process for dealing with complaints related to the protection of personal information generally includes:
Communicating the outcome of the investigation to the complainant, including any remediation measures taken by Spin Master (where justified).