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Effective Date: October 1, 2025
This 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”). 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 and we do not knowingly collect personal data directly from any person younger than the age of 18.
Please also review the Terms of Service, located at https://privacy.spinmaster.com/gund-terms-of-service which governs your use of the Program. By accessing or using this Program, or by otherwise providing us with personal data, you consent and agree to the Terms of Service and this Privacy Policy.
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.
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 user or you are returning the Plush Friend asa finder. We use the term “personal data” to mean any data that could be used to identify you, including “personal information” such as your identifying 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 PlushFriend and date of purchase. We will also treat other information, including IP addresses and cookie identifiers, as“personal data” where required by applicable law. Note that we may de-identify or pseudonymize personal data so that it is non-personal, 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 de-identified or pseudonymized data as non-personal to the fullest extent allowed by applicable law. If we combine non-personal data with personal data, then we will treat the combined data as personal data under this Privacy Policy and as required by applicable law.
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, your device, or household, whenever you access, use, or otherwise interact with the Program platform. Such cookies are used to allow the Program platform to function properly which 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.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 this personal data 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 to respond to subpoenas, court orders, or legal processes. We may also use your personal data to prevent fraud or other illegal activity, or otherwise 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 otherwise with your consent.
We maydisclose the personal data we collect with third parties that provide serviceson our behalf, including to assist us in performing certain services andfunctions on our behalf, such as facilitating the shipping of a found orreplacement Plush Friend, providing the Program platform, verifying usersthrough multi-factor authentication, customer support services, and internal analyticsand reporting. When you (as a user) registera Plush Friend or claim (as a finder) that you have found a Plush Friend, wewill share such information as necessary to reunite the Plush Friend with theapplicable user.
We and our service providers may also share your personal data 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 data with our affiliates, meaning an entity that controls, is controlled by, or is under common control. Our affiliates may use the personal data we share in a manner consistent with this Privacy Policy, including for business and operational purposes.
Your personal data 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 relationship.
Notwithstanding anything else in this Privacy Policy, we do not share personal data 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.
Except as expressly prohibited bylaw, we may share non-personal information, including, without limitation, de-identified or pseudonymized information, usage information, aggregated user statistics, and hashed or otherwise de-identified or pseudonymized information(including email addresses), and/or analyses derived from such information with third parties in our discretion, including for marketing and targeted advertising purposes.
We use commercially reasonable security measures to protect against loss, misuse, and alteration of your personal data under our control. We keep personal data as long as it is necessary or relevant for the practices described in this Privacy Policy. 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 data, please be aware of these inherent risks and understand that you do so at your own risk.
Subject to the exceptions set forth below and pursuant to applicable law, you are provided the following rights: (1) Access Your Information – to confirm whether we are processing your personal data and request to access such data; (2) Delete Your Information – to request to delete your personal data; (3) Correct Your Information – to request we correct the personal data we hold about you. You can exercise these rights by using the contact information provided below.
If, for any reason, you would like to appeal our decision relating to your request and you are a resident of a state that allows such right, you have the right to submit an appeal and can do so by emailing us. Please include your full name, the basis for your appeal, and any additional information to consider.
Note that we may retain personal data that you have requested to be updated or deleted in backup systems or for internal, legal, or administrative purposes and for other reasons to the extent allowed by applicable law, such as to resolve disputes and troubleshoot problems.
California residents are provided additional disclosures and rights, please see more in the Additional Notice to California Residents section, below.
Information we maintain may be stored both within and outside of the United States. Where possible, we try to keep the information you supply to us locally. However, aspart of the services offered, the information you provide to us may be transferred to countries outside the United States. By interacting with the Program platform or providing us with any information, you fully understand and unambiguously consent to the transfer to, and processing, usage, sharing, and storage of your information in the United States and other jurisdictions which may not afford the same level of protections as those in your country.
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 we make material changes to this Privacy Policy, we will notify you by posting the updated Privacy Policy, and we will update the effective date at the end of this Privacy Policy. We may also provide notice to you in other ways at our discretion, such as through contact data you have provided.
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 data. Any changes will be effective immediately upon the posting of the revised Privacy Policy unless otherwise specified, and your continued use of after the effective date of the revised Privacy Policy (or such other act as specified in the revised Privacy Policy) will constitute your consent to those changes to the fullest extent allowed by applicable law.
If you have any questions about this Privacy Policy or our processing of data about you, please contact us at dpo@spinmaster.com. Alternatively, our Customer Care line is +1 800-622-8339.
If you are a California resident, we are required to provide additional information to you about how we use and disclose your personal information and set out your rights in connection with how we use your information.
Use and Disclosure of your Information: Consistent with the “Uses of Personal Data” section of this Privacy Policy, we collect certain categories and specific pieces of information about individuals that are considered "personal information" in California.As detailed above, we may collect this personal information from you and other third parties. We collect, share, and disclose personal information for the purposes described in this Privacy Policy. We do not sell or share this personal information.
Your Rights: As a consumer, under California law and subject to its exceptions, you havethe right to request (1) that we disclose to you what personal information wecollect, use, disclose, including the categories and specific pieces of personalinformation we have collected about you (“Right to Know”); (2) that we deletethe personal information we hold about you (“Right to Delete”); and (3) that wecorrect inaccurate personal information we hold about you (“Right to Correct”).California consumers have the right not to be discriminated against for havingexercised their rights under California law.
Exercising Your Rights: To exercise your rights, please email us at dpo@spinmaster.com or call us at 1-800-622-8339. Please ensure the request includes (a) sufficient information to allow us to reasonably verify you are the person about whom the information is collected; and (b) describe your request which allows us to understand and action on your request. We will take reasonable steps to verify your identity based upon the information you provide and the type of request you are making. We may ask that you provide us with information, beyond your full name in order to verify your identity and fulfill your request. If we are unable to verify that the individual submitting the request is the same individual about whom we have collected information (or someone authorized by that individual to act on their behalf), we will not be able to process the request.
If you are an authorized representative submitting a request on a California consumer’s behalf, please provide proof in the form of a written permission signed by the individual who is the subject of the request authorizing you to make the request on their behalf. Please keep in mind that if we do not receive adequate proof that you are authorized to act on the consumer’s behalf, we may deny the request.
Data Retention: We will retain all categories of personal information described in this Privacy Policy for as long as it is necessary for the purposes for which it was collected, to resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, prevent fraud, and comply with applicable laws.
California’s Shine the Light Law: California law permits its residents to request certain information relating to third parties with whom personal information was disclosed for direct marketing purposes. We do not use personal information for such purposes and thus do not provide this right.