Privacy Policy

Last Updated: October 2023

Effective Date: January 2020

Table of Contents

INTRODUCTION

This Privacy Policy is issued on behalf of ZURU Inc. and all of its subsidiaries and affiliates (ZURU). ZURU may also be referred to in this Privacy Policy as “we”, “our” or “us”. Our registered office is at Unit 1201-04, 12th Floor, Energy Plaza, 92 Granville Road, Tsim Sha Tsui East, Kowloon, Hong Kong, China. ZURU is committed to safeguarding your privacy online. It is very important to us that you are able to use and enjoy our websites without having to worry about your privacy. This Privacy Policy is designed to help you understand how your personal information will be treated. Please read this Privacy Policy along with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

This Privacy Policy (“Privacy Policy”) describes the personal information that may be collected and processed by us, what we use your personal information for, when we collect your information, how we might use and disclose your personal information, and the choices you can make about your personal information.

This Privacy Policy applies to zurutoys.com (however accessed or used) whether via personal computers, mobile devices, or other technology (“Device”) and other interactive features, applications or downloads that are operated by us that are available through this website and contain this Privacy Policy produced and maintained by ZURU (collectively “Website”). By using the Website, you acknowledge that you’ve read and understood this Privacy Policy.

We collect information that is directly related to the products and service you choose including information collected automatically and personal information.

Information collected automatically (cookies) is used by ZURU for aggregated statistical analyses or systems administration purposes only. You can know more about our Cookie Policy (https://zurutoys.co/cookies/) here. No attempt will be made to identify users or their browsing activities, except where required by law.

Personal information is information about an identifiable individual, or an individual who is reasonably identifiable whether the information is true or not. The kind of personal information we collect may include:

• identifiers such as a real name, alias, postal address, telephone number, and/or e-mail address, zip code, account name;
• demographic details such as age and/or gender;
• internet or other electronic network activity information, including browsing history, search history (for example – the previous Website you visited), and information regarding a consumer’s interaction with an Internet Web site; and application, or advertisement, products you are interested in;
• device information, and information that helps you access Services (such as login information, Wi-Fi network name, IP (Internet Protocol) address (a number which is unique to the machine through which you are connected to the internet), etc.;
• geolocation information such as country, city and address;
• order information and other proof of purchase when you submit a product issue;
• survey information; and
• other information that is necessary to your enquiry.

• We may collect personal information from you when you:
• visit/browse our website
• fill in an application form, register with a service;
• deal with us over the telephone or through any Device;
• use an interactive activity, enter a sweepstakes or contest;
• e-mail us;
• submit your personal information details through the Website;
• ask us to contact you after visiting the Website; and
• agree to complete an on-line survey.

We will collect personal information when you provide to us, and only to the extent necessary to provide the product or service you requested or to carry out our internal administrative operations.

We may receive information automatically through cookies. When you interact with us on the internet, our system automatically sends you a ‘cookie’. A cookie is a small amount of information sent from a web server to your computer, electronic tablet or smart phone that enables your device to be recognized. It is used to handle your internet sessions on that device and contains a unique identifier. Other information stored by the cookie includes website traffic data. This data is not used to identify individual details. We only collate the data into anonymous results in order to evaluate and improve our internet user ability and services. You may disable cookies using your browser’s preferences, but some features of the Website may not function if you do so. You can know more about our Cookie Policy here.
We also receive information via third party when you visit our page on social media sites or channels (e.g. Facebook, Youtube, Instagram, Linkedin etc.).

We may receive personal data about you from various third parties and public sources. Technical Data from the following parties:

• analytics providers, such as Google Analytics;
• search information providers such as Google and Bing；
• app store providers, such as the Apple App Store and Google Play.

We will collect personal information from you by lawful and fair means and not in an unreasonable way.

We will collect, hold, use and disclose personal information for the purposes of providing or offering goods and services to you, for any purposes that you may reasonably expect, for any other purpose authorized by law, or for any other purposes with your consent. This may include disclosures to organizations that provide us with technical and support services, and professional advice.

We use personal information in the following ways to:

• provide you with news and information about our products and services;
• provide, deliver, source, administer, and improve our products and services;
• provide marketing offers through direct marketing, database compilation, market research, data analysis and segmentation, and the processing or creation of other marketing information;
• communicate with you such as responding to queries and complaints;
• send you marketing and promotional material that we believe you may be interested in;
• seek your feedback for market research purposes；
• Participation in feedback such as online surveys is completely voluntary and anonymous. It will not be used to gather identifying information about any individual;
• protect intellectual property and our legal rights; or
• protect our rights or property and comply with legal processes, which may include disclosures to law enforcement, regulatory or government agencies.

You may at any time request that we discontinue sending you emails or other communications. Requests should be directed to Customer Service – see Contact Us.

Direct marketing

From time to time we may use the personal information we collect from you to identify particular products and services which we believe may be of interest to you. We may then contact you to let you know about these products and services and how they may benefit you. Every directly addressed marketing contact sent or made by ZURU will include a means by which you may unsubscribe (or opt out) of receiving further marketing information. Further, you may instruct us at any time to remove any previous consent you provided to receive marketing communications from us. Requests should be directed to Customer Service – see Contact Us.

Entrants in Competitions, Contests and Sweepstakes

We may offer competitions, sweepstakes and contests through the Website that may require registration. By participating in a competition, contest or sweepstake, you agree to the terms, conditions and official rules that govern that particular promotion. If you choose to enter a competition, sweepstake or contest, we may disclose personal information to third parties or the public in connection with the administration of such competition, contest or sweepstake, including without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the official rules, such as on a winners’ list.

Job Candidates

We collect information from job candidates. This information will contain personal information such as name, address, employment history and reference details.

Generally, we will collect personal information directly from the job candidate but some information may be provided by third parties providing human resource services. Job candidate personal information will be used for recruitment purposes and to evaluate the job candidate’s application. Where we wish to use the information for other purposes we will seek job candidates’ agreement beforehand.

We will share information within the ZURU Company and subsidiaries.

We may share your personal information with service providers that perform services on our behalf and help us run our business, including running our sites and contest, delivering our emails to you, analyzing the data we collect, and sending you the products and services you requested. We only share the personal information needed for these companies to complete the tasks we request. They are required to protect your information in the same way we do and will not share it or use it for any other purpose.

We share information on Social Media. Some of our websites may include social media links such as Facebook. If you click on any of these links, it may collect your IP Address and record which page you were visiting at the time. Social media may also use cookies so that the feature can function properly. Social media are hosted by third parties. When you’re clicking them, your personal data will be processed by that third-party according to their own privacy policies.

We don’t and won’t sell your personal information. We do not share your personal information with third parties except for some necessary business purposes permitted by law or you have given us your consent to do so. These third parties have agreed to maintain the confidentiality and security of the information. We won’t share your personal information outside ZURU except:

• When we need to enforce the Privacy Policy, Terms of Use or Cookie Policy;
• When we need to protect the safety, security, rights and property of our company, our customers or third-party partners;
• When we need to meet legal processes or if disclosure of the data is required by law; or
• If a merger, acquisition or sale of assets ever meant we needed to share information with a third party. In this case, we will email you and post a notice on our website to publish the change of owner and we’d also tell you how your data would be used and give you options regarding your personal data.

ZURU conducts business throughout the world through multiple office locations and the personal information that we collect from you may be transferred to, stored at, or processed in our offices around the world or third parties carrying out such services on our behalf. All information we collect from you may be located in countries with privacy laws that may be different from where you live.

We ensure your personal data is protected by requiring all our companies and service providers to follow the same rules when processing your personal data. By using our Services, the transfer, collection, processing of data will occur as specified in this Privacy Policy, our Terms of Use, and any other terms provided at the time of collection. Whenever your personal information is transferred, stored or processed by us or by third parties carrying out such services on our behalf, we’ll take reasonable steps to safeguard the privacy of your personal information.

ZURU is committed to keeping your trust by protecting and securing your personal information. We have in place reasonable commercial standards of technology and operational security to protect all personal information provided to us from misuse, interference, loss, unauthorized access, modification or disclosure. We limit access to personal information to individuals with a business need consistent with the reason the information was provided.

The Internet is not 100% secure. We cannot promise that your use of our sites and apps will be completely safe. We encourage you to use caution when using the Internet. This includes not sharing your passwords. This Website may include links to third-party websites like Facebook or Walmart. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every Website you visit.

We will notify you and any applicable regulator of a data breach where we are legally required to do so.

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

If you wish to unsubscribe from e.g. newsletters or marketing emails you will be able to do so via the link provided in those emails. If you wish to delete cookies placed, our cookie policy will help show you how to do that. Under certain circumstances, you have rights under data protection laws in relation to your personal data. ZURU complies with the rights given to EU Citizens under the General Data Protection Regulation (GDPR) and Californian Citizens under California Consumer Protection Act (CCPA). These rights are as follows:

Request disclosure of your personal information or access to your personal data (commonly known as a “data subject access request”). This enables you to receive additional details or a copy of the personal data we hold about you and to check that we are lawfully processing it. The file containing your personal information will be kept on our servers and those of our service providers.

This right is subject to certain exceptions (see below) allowed by law.

Exceptions

Your right to access your personal information is not absolute. In some circumstances, the law permits us to refuse your request to provide you with access to your personal information. Such circumstances may include where:

• access would pose a serious threat to the life or health of any individual;
• access would have an unreasonable impact on the privacy of others;
• the request is frivolous;
• the information relates to a commercially-sensitive decision-making process;
• access would be unlawful; or
• access may prejudice enforcement activities, a security function or commercial negotiations.

Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request deletion or erasure of your personal information. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have over-riding legitimate grounds to use it.

Right of data portability. We will provide to you or a third party you have chosen your personal data in a readily useable format or in a structured, commonly used, machine-readable format. Note that this right is to in response to a request for disclosure or only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Do not track right. California law requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Because there currently isn’t an industry or legal standard for recognizing or honoring DNT signals. We don’t respond to them at this time. We await the result of work by the privacy community and industry to determine when such a response is appropriate and what form it should take. If you turn on Do Not Track in your website browser, we will respect your choice.

Besides, we don’t have any automated processing including profiling. If you wish to exercise any of the rights set out above, or you have any complaint about our processing of your personal data, please see Contact Us. To check and confirm you are the right data subject, please provide us with your name and email address when you email us.

We will update this Privacy Policy from time to time by posting it here. We will not change how we handle previously collected information without providing notice. If applicable, we will also obtain your consent. Please check our sites periodically for updates.

To contact us with a query, request, complaint or a privacy question, visit: https://zurutoys.com/contact/

A member of our Customer Service team will try to respond to all legitimate requests within one week. Occasionally it may take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Kids Privacy Assured by PRIVO: COPPA Safe Harbor Certification & GDPRkids™

ZURU is a member of the PRIVO Kids Privacy Assured Program (“the Program”) for COPPA Safe Harbor Certification and GDPRkids™. PRIVO is an independent, third-party organization committed to supporting online services to safeguard children’s personal information collected online.