Moose Privacy Policy

Last updated: 22 February 2019
Effective Date: 22 February 2019

Moose is committed to safeguarding your privacy online. It is very important to us that you should be able to use and enjoy this website without having to worry about your privacy in any way.

Please also view our children’s privacy policy located at Children’s Privacy Policy

Please also view our credit privacy policy located at Credit Privacy Policy

Please read the whole of this policy to understand how your personal information will be treated.

This policy may change from time to time, so please check back regularly. All changes will be posted on our website. The last updated date will be changed at the start of the amendment of the policy.

Privacy Policy

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

This Privacy Policy applies to all websites (including all interactive features, applications or downloads available through these websites) and apps operated by Moose which contain this Privacy Policy (however accessed and/or used), whether via personal computers, mobile devices, or other technology (“Device”) (collectively “Website”). By using the Website, you acknowledge that you’ve read and understood this Privacy Policy.  Moose includes Moose Enterprise Pty Ltd, Moose Creative Pty Ltd, Moose Creative Management Pty Ltd, Moose Enterprise (INT) Pty Ltd, Moose Toys Pty Ltd, Moose Toys LLC and all of their subsidiaries and affiliated companies and are referred to in this policy as “we”, “our” or “us”.

Collection of Personal Information

Personal information is information about an identifiable individual, or an individual who is reasonably identifiable whether the information is true or not.

Customers

We collect information that is directly related to the products and services you choose. The kind of personal information we collect can include: basic contact details (name, postal address, telephone number, or e-mail), demographic details such as age and/or gender, and products you are interested in.

Generally, we will collect personal information directly from you, and only to the extent necessary to provide the product or service you requested or to carry out our internal administrative operations. We may collect personal information from you when you:

  • fill in an application form;
  • deal with us over the telephone or through any Device;
  • purchase a product;
  • e-mail us;
  • submit your personal details through the Website;
  • create an account with us;
  • ask us to contact you after visiting the Website; or
  • agree to complete an on-line survey.

We may also collect solicited personal information indirectly, through some publicly available sources, or through social media sites, like Facebook, Twitter, Google and others, who disclose to their users that the users’ personal information is provided to businesses like Moose.  We will collect personal information from you by lawful and fair means and not in an unreasonable way.

Using Personal Information

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 authorised by law, or for any other purposes with your consent (whether express or implied). This may include disclosures to organisations 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;
  • provide you with functionality on the Website, and customising and improving your online experience with us;
  • personalise your experience with our products and services, for example, via connectivity with social media services;
  • send you marketing and promotional material that we believe you may be interested in; or
  • 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

You may at any time request that we discontinue sending you emails or other communications.

Your personal information may also be used and disclosed to protect our rights or property and that of our users and, where appropriate, to comply with legal processes, which may include disclosures to law enforcement, regulatory or government agencies.

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 Moose will include a means by which you may unsubscribe (or opt out) of receiving further marketing information.

California Civil Code Section 1798.83 permits customers of Moose who are California residents to request certain information regarding its disclosure of their personal information to third parties for their direct marketing purposes. 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 our Data Protection Officer – DPO@moosetoys.com.

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/or 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.

Suppliers

We collect information from suppliers that is directly related to the products and services Moose and its customers purchase and provide. This information may contain personal information such as the name and contact details of the contact people at each supplier.  Generally, we will collect personal information directly from the contact person but some information may be provided by third parties.

We use information from suppliers in the following ways to:

  • provide you with news and information about our products and services;
  • be supplied, products or services;
  • communicate including responding to queries and complaints;
  • maintain quality control and product safety; or
  • produce innovative products.

Job Candidates

We collect information from job candidates.  This information will contain personal information such as name, address, employment history and referee 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 your agreement beforehand.

Disclosure

We do not disclose personal information to third parties unless we are permitted to do so by law or you have given us your consent to do so. Third parties we may disclose personal information to include:

  • our related companies;
  • our service providers including IT service providers, major delivery companies, mail houses and third party fulfilment contractors;
  • our professional advisors including our accountants, auditors and lawyers;
  • payment system operators and financial institutions; or
  • government agencies.

Some of our service providers provide services to us entirely or partly from locations outside your jurisdiction and we may in order to receive those services occasionally transfer personal information to such other jurisdictions (where the information may be available to the government of these other jurisdictions), including where:

  • we use service providers, cloud computing solutions or data storage located in other jurisdictions;
  • we, or our related bodies corporate, have offices in other jurisdictions;
  • we need to comply with foreign legal or regulatory requirements; or
  • an international payment has been made.

Your personal information may be stored or processed outside of the European Economic Area (EEA). These countries may not have the same data protection laws as the EEA. If we transfer your information outside of the EEA, we will take appropriate steps to ensure that your information is adequately protected.

Accessing and checking the personal information we hold about you

You have the right to request access to the personal information we hold about you. This right is subject to certain exceptions (see below) allowed by law. The file containing your personal information will be kept on our servers and those of our service providers

Moose will, upon your request to the Data Protection Officer (see Contact Us), and subject to applicable privacy laws, provide you with access to your personal information that is held by us. However, we ask that you identify, as clearly as possible, the type(s) of information requested. Moose will deal with your request in a reasonable time.  Depending on the breadth of your request, we may recover from you our reasonable costs incurred in supplying you with access to this information.

We rely on the accuracy of the information you provide to us. If you think that we may hold information about you that is incorrect in any way, please contact us and we will correct any errors or inaccuracies where required.

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;
  • access may prejudice enforcement activities, a security function or commercial negotiations.

Security

Moose 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, unauthorised access, modification or disclosure.

We limit access to personal information to individuals with a business need consistent with the reason the information was provided. We keep personal information only for as long as it is required for business purposes or by the law.

Information collected automatically

We may collect information automatically such as browser type, operating system, and web pages visited to help us manage our Website.

We use cookies (see below) and other internet technologies to manage the Website and certain online products and services. Our internet server logs the following information which is provided by your browser for statistical purposes only:

  • the type of browser and operating system you are using;
  • your Internet Service Provider and top level domain name (for example – .com, .gov, .au, .uk etc);
  • the address of any referring website (for example – the previous website you visited); and
  • your computer’s IP (Internet Protocol) address (a number which is unique to the machine through which you are connected to the internet).

This information is used by Moose for aggregated statistical analyses or systems administration purposes only. No attempt will be made to identify users or their browsing activities, except where required by law.

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 recognised. 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.

How long do we keep your personal information

We will keep your personal information as long as your account is active or as long as it is needed to provide a product or service. If you would like to cancel your account or for us to delete your personal information, please contact our Data Protection Officer – DPO@moosetoys.com. We will only keep information that we need for legal reasons, to resolves disputes or to enforce our agreements.

Contact Us

If you have a query or question about this policy, please contact our Data Protection Officer at DPO@moosetoys.com. Or by mail at: Data Protection Officer, 29 Grange Road, Cheltenham, Victoria, 3192, Australia.

If you would like to make a complaint about the way we process your personal data you can contact the relevant Data Protection Authority (DPA). Please contact us to find out more.

Changes to This Policy

We will post changes to the Privacy Policy and publish the effective date when this policy is updated.

Safety on the Internet

Please remember that whenever you voluntarily give personal information publicly online – for example on message boards, through e-mail, or in chat areas – that information can be collected and used by others. If you provide personal information on forums like that – you do so at your own risk.

Assignment

We may change our ownership or corporate organisation or sell some of our assets.  As a result, please be aware that in such event we may transfer some or all of your information to a company acquiring all or part of our assets or to another company with which we have merged.  Under such circumstances we would, to the extent possible, require the acquiring party to follow the practices described in this Privacy Policy, as it may be amended from time to time.  Nevertheless, we cannot promise that an acquiring company or the merged company will have the same privacy practices or treat your information the same as described in this Privacy Policy.

Your California Privacy Rights

California Civil Code Section 1798.83 permits customers of Moose who are California residents to request certain information regarding its disclosure of their personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail toDPO@moosetoys.com. These services will respect your browser’s Do Not Track signals (or other well-established, commercially available mechanisms that provide you with the ability to exercise choice regarding the collection of Personal Information).  If we receive a Do Not Track notice, we will stop using any Personal Information for online behavioral advertising purposes.

For Canadian Residents

We may send you marketing communications by e-mail, text message or other electronic means unless you did not opt-in when required or have opted-out from receiving further messages. You may at any time opt out of the use of your personal information for marketing purposes by contacting our Data Protection Officer – see Contact Us above.

Children’s Privacy Policy

Last updated: 8 February 2019

We welcome children (“Children”) to access all websites (including all interactive features, applications or downloads available through these websites) and apps operated by Moose which contains this Children’s Privacy Policy (collectively “Website“). By using the Website, you acknowledge that you’ve read and understood this children’s privacy policy.  Moose includes Moose Enterprise Pty Ltd, Moose Creative Pty Ltd, Moose Creative Management Pty Ltd, Moose Enterprise (INT) Pty Ltd, Moose Toys Pty Ltd  and all of their subsidiaries and affiliated companies and are referred to in this policy as “we”, “our” or “us”.

Moose complies with the Children’s Online Privacy Protection Act of 1998 (“COPPA“) and the GDPR.  Please read our Children’s Privacy Policy carefully as it explains our information collection practices for Children at our Website, such as the type of information we collect regarding Children and how we may use that information.  It also describes a parent’s or guardian’s (each, a “Parent”) ability to limit the collection and use of data collected from their Children.  Please review our Privacy Policy that applies to our general information collection practices for visitors to our Website.

PRIVO COPPA Seal Information and GDPRkids Privacy Assured Program

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

Moose Toys 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 safeguarding children’s personal information collected online. To learn more about PRIVO’s program standards click here.

COPPA Safe Harbor Certification

The Program certification applies to the digital properties listed on the validation page that is viewable by clicking on the PRIVO COPPA certification seal. The certification seal posted on this page indicates Moose Toys has established COPPA compliant privacy practices and has agreed to submit to PRIVO’s oversight and consumer dispute resolution process. If you have questions or concerns about our privacy practices, please contact us at 9579 7377 or – DPO@moosetoys.com. If you have further concerns after you have contacted us, you can contact PRIVO directly at privacy@privo.com.

GDPRkids Privacy Assured

The Program applies to the digital properties listed on the validation page that is viewable by clicking on the PRIVO GDPRkids™ Verified Shield. The PRIVO GDPRkids Privacy Assured Program supports child directed services known as Information Society Services under the General Data Protection Regulation (GDPR), to comply with the requirements of this legislation. It impacts any child directed service in an EU Member State and any service globally that collects and or processes the personal data of children and minors. There is no safe harbor for the GDPR to date, but to ensure this company’s services meet the program requirements, we conduct regular monitoring and consulting.

A Note to EU Citizens

Moose complies with the rights given to EU Citizens under the General Data Protection Regulation (GDPR). These rights are as follows:

  • Correcting your Information – the right to have your personal information updated to ensure it is up-to-date and accurate.
  • Withdrawing Consent – the right to withdraw your consent to any processing that is currently being done under your consent, e.g. marketing.
  • Obtaining a copy of your Information – the right to receive a copy of the personal information we hold about you.
  • Deleting your information – right to request that we delete personal information in certain circumstances.
  • Data Portability – the right to have us transfer to another controller the personal information that you have provided us with.
  • Restricting Processing – the right to request a restriction on the processing of your data in some limited circumstances.
  • Right to object to processing – right  to request that we stop processing your data for marketing purposes and in other limited circumstances such as asking us not to process your data by wholly automated means or not to analyse your information for targeted content etc. (also known as profiling).

For more information on how to action these rights please contact us at: DPO@moosetoys.com

If you are an EU citizen and would like to make a complaint about the way we process your personal data you can contact the relevant Data Protection Authority (DPA). Please contact us to find out more.

What kind of information does Moose collect?

A.   Information provided by Children

Children may view much of the Website’s content without registering or providing personal information Moose may collect a Child’s e-mail address under the following limited one-time use circumstances:

  1. if your Child sends a request to us, we will keep their e-mail address to respond to them.  We will then delete their e-mail address from our system once we have responded to them; or
  2. if your Child enters a competition, sweepstake or contest, we will ask the Child to give us the Parent’s e-mail address, too, so that we can tell the Parent that the Child has registered for the competition, sweepstake or contest. If we need more than the Child’s e-mail address and first name (or screen name) to enter your Child in the competition, sweepstake or contest, we will notify you, explain what information we need and ask that the Parent provide it. For example, we will ask the Parent for his or her mailing address so that we can send, for your Child, any prizes the Child wins, or for his or her telephone number so that we can tell the Parent when the Child has won. Any information a Parent or the Child gives us in these circumstances will be deleted from our database once the competition, sweepstake or contest is concluded, and after any legally required period for keeping such information has ended.
  3. If the child signs up for our newsletter in the Mighty Kingdom Shopkins apps we collect the parent’s email address and the child’s email address to notify the parent of the child’s wish to participate. the parent must actively optin to their child receiving the newsletter by entering the code provi in the parent email. If the parent fails to opt in we will delete all information collected.
B.   Information collected through the use of our Website

Moose collects information on our Website’s visitors collectively including which sections of the Website are most frequently visited, how often and for how long (collectively, “Usage Information”). This is done through cookies and other technologies. This data is used as aggregated, non-Personal Information.  Cookies do not contain any Personal Information about a specific user. Moose uses Usage Information to improve and enhance our online service. You may disable cookies using your browser’s preferences, but some features of the Website may not function if you do so.  We do not share this information externally.  For more information about our technology practices, please review our general Privacy Policy.

How May Parents Access Children’s Personal Information?

Upon identification, a Parent may review the Personal Information we have collected about the Child, request deletion, or refuse to allow further collection or use of that information. When we delete Personal Information, it will be deleted from our active databases and deleted after any legally required period for keeping such information has ended.

What Does Moose Do With The Information We Collect?

We may use a Child’s Personal Information or Usage Information: (1) to enable a Child to participate in a variety of the Website’s features such as to track collectables or enter competitions, sweepstakes or contests; (2) to process a Child’s registration with the Website; (3) to improve the Website or to serve the Child specific content that is most relevant to the Child; (4) to contact the Child and Parent with regard to the Child’s use of the Website and, in our discretion, changes to the Website and/or Website’s policies; or (5) for purposes disclosed at the time the Child provides their information or as otherwise set out in this Privacy Policy.

Does Moose Share Children’s Information?

Moose discloses information in the following circumstances:

1) in the event we are required to respond to subpoenas or other legal process or if in our good faith opinion such disclosure is required by law; (2) at the request of governmental authorities conducting an investigation; (3) to protect and/or defend the Website’s Terms of Use; or (4) to protect the personal safety or rights of any individual.  We may also use IP address or other device identifiers to identify users, and may do so in cooperation with copyright owners, internet service providers, wireless service providers or law enforcement agencies in our discretion.  Such disclosures may be carried out without notice to you.

In the event Moose goes through a business transition such as a merger, acquisition by another company, or sale of all or a portion of its assets, Personal Information will likely be among the assets transferred. Any acquirer of Children’s Personal Information held by Moose will continue to abide by this Children’s Privacy Policy.

Third Party Service Providers

To help Moose understand the use of our service and improve it we work with a number of third parties. These third parties do not share our user data.

Mighty Kingdom Shopkins apps

Mighty Kingdom Shopkins apps use the following third party service providers, which enables advertising to be temporarily uploaded into the game and replaced whilst you play. The data collected for this purpose may include IP addresses or persistent identifiers, to allow the third party service provider to calculate the number of views, to cap ads and to serve ads in a format that fits your device.   None of the information collected or used by the third party service provider is used to personally identify you, or for behavioural advertising or to build a profile on your online practices. If you do not want to use these advertising serving technologies, do not play the Mighty Kingdom Shopkins apps whilst connected to the internet. Also, in certain areas of the apps, you may be able to turn off advertising from third party service providers via the settings screen. Please see below for the privacy policies of the third party service providers used.

The Fyber Grouphttps://www.fyber.com/legal/gdpr-faqs/

https://www.fyber.com/legal/privacy-policy/

AdColony, Inc.https://www.adcolony.com/gdpr/

https://www.adcolony.com/privacy-policy/

Chartboosthttps://answers.chartboost.com/en-us/articles/115001489623
Unity 3D/Unity Technologies ApShttps://unity3d.com/legal/gdpr

https://unity3d.com/legal/privacy-policy

Vungle, Inc.http://vungle.com/privacy/

https://vungle.com/gdpr-faq/

HyperMX Mobile LLChttps://www.hyprmx.com/pp.html

For more information on these third parties, please contact Moose: DPO@moosetoys.com

Security

We incorporate commercially reasonable safeguards to help protect and secure your Personal Information.  However, no data transmission over the Internet, wireless transmission or electronic storage of information can be guaranteed to be 100% secure.  Please note that we cannot ensure or warrant the security of any information you transmit to us, and you use our Website and provide us with your information at your risk.

Changes to the Children’s Privacy Policy

Moose reserves the right to change this Children’s Privacy Policy at any time.  All changes will be posted on our website. Any changes will be effective immediately upon the posting of the revised Children’s Privacy Policy and updated date.  However, Moose will not use your Child’s Personal Information in a manner materially different than what was stated at the time it was collected without first obtaining a Parent’s consent. If we make a material changes , we will post a notice at the start of this policy. If we have your email address we will notify you of the change before it is made.

Contact Us

If you have a query or question about this policy, please contact our Data Protection Officer at DPO@moosetoys.com. Or by mail at: Data Protection Officer, 29 Grange Road, Cheltenham, Victoria, 3192, Australia.

Credit Privacy Policy

Last updated: 3 January 2020

Purpose

This Credit Privacy Policy explains how Moose deals with certain types of credit-related personal information (Credit Information) which is regulated by Australian privacy law. This Credit Privacy Policy details the types of Credit Information we collect, how we may use that information and who we allow to access it. “Moose” includes Moose Enterprise Pty Ltd, Moose Enterprise (INT) Pty Ltd, Moose Creative Pty Ltd, Moose Creative Management Pty Ltd, Moose Toys LLC, Moose Toys Ltd  and all of their subsidiaries and affiliated companies and are referred to in this policy as “we”, “our” or “us”.

Scope

This Credit Privacy Policy applies to current and former credit customers of Moose, as well as to other relevant individuals we deal with in connection with credit we provide, including guarantors and directors. In addition to this Credit Privacy Policy we will on occasion provide specific statements about how we use the Credit Information that we collect.

This Credit Privacy Policy applies in addition to the Moose Privacy Policy.  We recommend you read this Credit Privacy Policy in conjunction with the Moose Privacy Policy, which is available at moosetoys.com/privacy-policy.

Credit Reporting System

If an individual, or company of which an individual is a director, applies to us for credit terms (Credit Terms) in connection with the supply of goods under our trading terms and conditions (or an individual applies to us to provide a guarantee for Credit Terms) we may obtain a consumer credit report or commercial credit report about the individual from a credit reporting body to the extent the Australian privacy law permits us to do so.

We may also obtain a consumer credit report or commercial credit report about an individual from a credit reporting body to the extent the Australian privacy law permits us to do so, if an individual, or company of which an individual is director, has been provided with Credit Terms, or has provided a guarantee for Credit Terms.

When we request a credit report from a credit reporting body, we will provide information to the credit reporting body that identifies the individual and we may give information about the Credit Terms, including the type and amount of credit.

What Credit Information do we collect and hold?

If you apply for credit, we collect and hold information for the assessment of your credit which includes:

  • identification information, including current and prior names and addresses, any known alias, date of birth, gender,  current or last known employer and driver’s licence number;
  • information contained in credit reports obtained from credit reporting bodies, which includes information about consumer and commercial credit history with other credit providers;
  • credit eligibility information, for example, scores, ratings, summaries, evaluations and other information relating to an individual’s credit worthiness;
  • type of credit, amount of credit provided and terms of credit provided;
  • bank account details and other financial information;
  • personal insolvency information;
  • certain publicly available information; and
  • court proceeding information, such as information about a judgement against an individual that relates to any credit that has been provided to, or applied for, by the individual.

 

How do we collect and hold Credit Information?

We collect Credit Information about individuals as much as possible directly from them, for example:

  • when they contact us by phone, email or otherwise during the course of our relationship with them;
  • when they contact us about any of our products or services;
  • when they take part in promotional activities or events; or
  • when they make an application for credit or complete other forms.

We also collect Credit Information about individuals from third parties, including from:

  • consumer credit reporting bodies;
  • organisations who provide commercial credit reports;
  • trade references provided as part of a credit assessment;
  • other credit providers;
  • government authorities; and
  • publicly available sources.

An individual is not required to provide us with Credit Information if we request it from them, but this may affect our ability to provide them with the products, services or further information they have requested.

We, or our related entities or service providers on our behalf, may hold Credit Information about individuals in computer systems, electronic form, digital records, telephone recordings or in paper files.

 

What we do with Credit Information

We may collect, hold, use and disclose individuals’ Credit Information as reasonably necessary for our business purposes and as permitted by law.  Our purposes include:

  • assessing whether to provide an individual, or an associated entity, with credit
  • accepting an individual as a guarantor for credit applied for by another person;
  • deriving scores, ratings, summaries and evaluations relating to an individual’s credit worthiness (which are used in our decision-making processes and ongoing reviews);
  • managing credit we provide;
  • developing our products and  services and to maintain and develop our systems and infrastructure;
  • enabling us to participate in the credit reporting system and provide information to credit reporting bodies as permitted by the Australian privacy laws;
  • assigning debts and collecting overdue payments;
  • undertaking debt recovery and enforcement activities, including in relation to guarantors;
  • dealing with complaints and meet legal and regulatory requirements;
  • assisting other credit providers; or
  • otherwise in accordance with the consent and authorities provided in a credit application.

Some Credit Information may only be used or disclosed under Australian privacy laws for some of these purposes or in some circumstances. We may also use or disclose Credit Information for any other purposes disclosed at or around the time of collection. We may also collect or disclose Credit Information about individuals from or to any entity where that collection or disclosure is required or authorised by law.

We may also disclose an individual’s Credit Information on a confidential basis to related Moose entities within and outside Australia, our agents, contractors or third party service providers that provide financial, legal, administrative or other services required in connection with the operation of our business or if they consent to the disclosure.

 

Overseas disclosure

For the purposes explained in this policy, Credit Information may be disclosed overseas to our related entities (including service providers operating on their behalf) and other third parties.

We only disclose Credit Information to our related entities and service providers overseas when it is necessary for the services they provide to us.  The third parties to whom we disclose Credit Information will only use that credit information as necessary to provide their services to us.

Disclosure may take place in countries in which Moose has business operations including Hong Kong, UK and the United States of America. From time to time we may need to disclose an individual’s Credit Information to parties in countries other than these. This will be on an ad hoc or case by case basis and for the purposes for which the Credit Information was collected.

Security

We take reasonable steps to protect Credit Information from misuse, loss, unauthorised access, modification or disclosure. Credit Information is stored securely whether in an electronic or physical form.  For example, only staff needing access to the Credit Information are allowed access.  Credit Information is stored in secured premises or in electronic databases requiring logins and passwords.

Access and correction of Credit Information

An individual may request access at any time to Credit Information we hold about them.  We will process their request within a reasonable time.  There is no fee for requesting access to their information, however we may charge them the reasonable cost of processing their request.  An individual may ask us at any time to correct Credit Information held by us about them, which they believe is incorrect or out of date.

We try to ensure that all Credit Information we hold about an individual, which we collect, use or disclose is accurate, complete, up to date and relevant. If at any time an individual believes that the Credit Information we hold is incorrect, incomplete or inaccurate, the individual may request an amendment and we will amend the information, as we see fit.

Complaints

If an individual is concerned that we have not complied with our obligations that apply to dealing with Credit Information under Australian privacy laws, they may bring a complaint internally through our complaints process.

An individual may make a complaint through our internal complaints process by contacting us at the details set out below.  Complaints will be taken seriously and will be assessed by our Data Protection Officer and Legal Counsel with the aim of resolving any issue in a timely and efficient manner.  We will need the individual to cooperate with us during this process and provide us with relevant information we may require.

We expect our procedures will deal fairly and promptly with complaints.  However, if an individual is dissatisfied, they may make a formal complaint to the Office of the Australian Information Commissioner (www.oaic.gov.au) being the regulator responsible for privacy in Australia).

If you are an EU citizen and would like to make a complaint about the way we process your personal data you can contact the relevant Data Protection Authority (DPA). Please contact us to find out more.

Contact

If you have any questions or concerns about our Credit Privacy Statement or practices, please contact our Data Protection Officer at DPO@moosetoys.com or by mail at: Data Protection Officer, 29 Grange Road, Cheltenham, Victoria, 3192, Australia.

 

 

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