Last updated 1st February 2021
- What information can we collect?
- How is your/your child’s personal information collected?
- How and why do we use and share your/your child’s personal information?
- For how long do we keep your/your child’s personal information?
- International data transfers
- Your/your child’s rights
- Contact details
2. What information can we collect?
Please note that, unless otherwise explained, we do not knowingly collect personal data about children under the age of 13. We anticipate only collecting data from parents and guardians.
Some of our Websites are designed partly for children. However, if you are under the age of 13, you may only use our Websites and submit personal information if you have the consent of, and are supervised by, a parent or guardian. If we believe a child using one of our Websites is under 13 we will not process any personal information of that child without the verifiable consent of the parent or guardian. If, as a parent or guardian, you believe we have collected personal data about your child, you may contact us to review the data and request that we cease processing data about your child.
3. What personal data do we collect?
What is personal data?
- Basic details like your/your child’s name, date of birth and gender.
- Contact details like your/your child’s e-mail address, phone number, delivery address and shipping address if you are purchasing products or services from us. If you are a business contact, we may collect your name, email address, telephone number, job title and mailing address/place of work.
- Financial data like your payment card details.
- Transaction data like details about payments you have made to us and the products or services you have purchased.
- Usage data about how you/your child use our Websites.
- Marketing and communications data which includes your/your child’s preferences in receiving marketing and newsletters from us and third parties.
- Social media data like posts, comments, photos or videos uploaded onto our social media pages managed by us.
4. How do we collect your/your child’s personal data?
Automated technologies or interactions
We also collect information about you/your child when you/your child visit and interact with our Websites through the use of technologies such as cookies. The following are examples of information we may collect:
- information about your/your child’s device, browser or operating system;
- your/your child’s IP address;
- information about links that you/your child click and pages you/your child view on our Website;
- length of visits to certain pages;
- subjects you/your child viewed or searched for;
- page response times;
- records of download errors and/or broken links;
- page interaction information (such as details of your/your child’s scrolling, clicks, and mouse-overs);
- methods used to browse away from the page; and
- the full Uniform Resource Locators (URL) clickstream to, through and from this Website (including date and time).
Information we collect from other sources
From time to time we may also obtain personal data from other sources, for example your username, location and IP address whenever you/ your children view one of our YouTube videos whilst logged into your YouTube or Google account.
5. How and why do we use and share your/your child’s personal data?
Lawful basis for processing your/your child’s information
We will only use your/your child’s personal data when the law allows us to. Most commonly we will use personal data in the following circumstances:
- Where you/your child have asked us to do so, or consented to us doing so;
- Where we need to do so in order to perform a contract we have entered into with you/your child;
- Where it is necessary for our legitimate interests (or those of a third party) and your/your child’s fundamental rights do not override those interests; and
- Where we need to comply with a legal or regulatory obligation.
Here are some examples about how we may use the information we collect about you/your child and the lawful basis we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your/your child’s personal data for more than one lawful ground depending on the specific purpose for which we are using your/your child’s data.
Where you have given your consent, or where we have an alternative lawful basis,you/your child may receive marketing communications from us.
You can unsubscribe (or ‘opt out’) from marketing emails at any time byclicking on the unsubscribe link at the bottom of any marketing email. You/your child may also contact us directly if you/your child do not wish to receive any marketing materials from us.
Sharing your/your child’s personal data
Depending on how and why you/your child provide us with your/your child’s personal data we may share it in the following ways where appropriate:
- with any company within the Moonbug group of companies including Moonbug Entertainment Limited’s parent company, subsidiaries, affiliates, or joint ventures;
- with selected third parties who we sub-contract to provide various services and/or aspects of our Websites’ functionality;
- with analytics and search engine providers that assist us in the improvement and optimisation of our Website as described above;
- if we were to sell or buy any business or assets, in which case we might disclose your/your child’s personal data to the prospective seller or buyer of such business or assets as part of that sale;
- if Moonbug or substantially all of its assets are acquired by a third party, in which case personal data held by us about you/your child will be one of the transferred assets;
- if we are under a duty to disclose or share your/your child’s personal data in order to comply with any legal obligation, or if we are asked to provide your/your child’s details to a lawful authority in order to aid in a criminal or legal investigation; and
Our service providers provide us with a variety of administrative, statistical, and technical services. We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we endeavour to ensure that they protect this data and do not use it for any other purpose. We take these relationships seriously and aim to ensure that all of our data processors sign contracts with us that clearly set out their commitment to complying with data protection laws and assisting us to help you/your child exercise applicable data subject rights.
Links to third party sites
6. For how long do we keep your/your child’s personal data?
We will hold your/your child’s personal information on our systems only for as long as required to provide you/your child with the services you/your child have requested, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your/your child’s personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you/your child.
In some circumstances you/your child can ask us to delete your/your child’s data: see ‘Your/your child’s rights’ below for further information.
In some circumstances we may anonymise your/your child’s personal data (so that it can no longer be associated with you/your child) for research, demographic, analytical or statistical purposes in which case we may use this information indefinitely.
Moonbug takes the protection of personal data seriously. We have put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed, including use of secure servers and passwords. In circumstances where we have given you/your child a password that enables you/your child to access certain parts of our Website, you/your child are responsible for keeping this password confidential. We ask you/your child not to share a password with anyone.
In addition, we limit access to your/your child’s personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your/your child’s personal data in accordance with our instructions.
Despite these precautions, and although we will do our best to protect your personal data, Moonbug cannot guarantee the security of information transmitted over the Internet or that unauthorised persons will not obtain access to personal data. In the event of an actual or suspected data breach, we have put in place procedures to deal with this and will notify you and any applicable regulator of a breach where required to do so.
8. International data transfers
Please note that as your/your child’s personal data is shared within the Moonbug group of companies, this will involve transferring it outside of the European Economic Area (EEA) and/or the United Kingdom (UK), including between the EEA and the UK. Some of our external service providers may be also based outside of the EEA and/or the UK. These service providers may work for us or for one of our suppliers and may be engaged in, among other things, the fulfilment of your/your child’s request for information and the provision of services.
Where we transfer your/your child’s data to a service provider that is outside of the EEA or the UK (as relevant) we seek to ensure that appropriate safeguards are in place to make sure that your/your child’s personal data is held securely and that your/your child’s rights as a data subject are upheld. Transfers of personal data are made:
- to a country recognised by the appropriate body as providing an adequate level of protection; or
- to a country which does not offer adequate protection but whose transfer has been governed by approved standard contractual clauses or by implementing other appropriate cross-border transfer solutions to provide adequate protection.
9. Your/your child’s rights
As a data subject you/your child have a number of rights in relation to your/your child’s personal data. Below, we have described the various rights that you/your child have, as well as how you/your child can exercise them. These rights can be exercised at any time by contacting us – see the “Contact Details” section below.
Right of Access
You/your child may, at any time, request access to the personal data that we hold which relates to you/your child (you may have heard of this right being described as a “subject access request”).
Please note that this right entitles you/your child to receive a copy of the personal data that we hold about you/your child. It is not a right to request personal data about other people, or a right to request specific documents from us that do not relate to your/your child’s personal data.
Your/your child’s right to rectification and erasure
You/your child may, at any time, request that we correct personal data that we hold about you/your child which you/your child believe is incorrect or inaccurate. You/your child may also ask us to erase personal data if you/your child do not believe that we need to continue retaining it (you may have heard of this right described as the “right to be forgotten”).
Please note that we may ask you/your child to verify any new data that you/your child provide to us and may take our own steps to check that the new data you/your child have supplied us with is right. Further, we are not always obliged to erase personal data when asked to do so; if for any reason we believe that we have a good legal reason to continue processing personal data that you/your child ask us to erase we will tell you/your child what that reason is at the time we respond to the request.
Your/your child’s right to restrict processing
Where we process your/your child’s personal data on the basis of a legitimate interest, you/your child are entitled to ask us to stop processing it if you/your child feel that our continuing to do so impacts on your/your child’s fundamental rights and freedoms or if you/your child feel that those legitimate interests are not valid.
You/your child may also ask us to stop processing your/your child’s personal data: (a) if you/your child dispute the accuracy of that personal data and want us verify that data’s accuracy; (b) where it has been established that our use of the data is unlawful but you/your child do not want us to erase it; (c) where we no longer need to process your/your child’s personal data (and would otherwise dispose of it) but you/your child wish for us to continue storing it in order to enable you/your child to establish, exercise or defend legal claims.
Please note that if for any reason we believe that we have a good legal reason to continue processing personal data that you/your child ask us to stop processing, we will explain that reason, either at the time we first respond to the request or after we have had the opportunity to consider and investigate it.
Your/your child’s right to portability
Under certain circumstances, where you/your child wish to transfer certain personal data that we hold about you/your child, which is processed by automated means, to a third party, you/your child may write to us and ask us to provide it to you/your child in a commonly used machine-readable format.
Your/your child’s right to object to processing
You/your child may object to processing of your/your child’s personal data where we rely on legitimate interest for processing that personal data. We will comply with your/your child’s request unless we have a compelling overriding legitimate interest for processing or we need to continue processing your/your child’s personal data to establish, exercise or defend a legal claim.
Your/your child’s right to withdraw consent
Where our processing of your/your child’s data is on the basis of consent, you can withdraw this consent at any time. This would not affect the lawfulness of the processing based on consent prior to the withdrawal.
Your/your child’s right to object to automated decision making and profiling
You/your child have the right to be informed about the existence of any automated decision making and profiling of your/your child’s personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you/your child.
Right to Opt Out of Sale of Personal Data
A consumer (as defined in the California Consumer Privacy Act 2018 (or “CCPA”)) has the right to request disclosure of personal data about him or her sold by Moonbug and opt out of the sale of that consumer’s personal data by Moonbug by contacting us using the contact details set out below.
Shine the Light
California law provides that you have the right to submit a request to us at our designated email address and receive the following information: (i) the categories of information disclosed to third parties for the third parties’ direct marketing purposes during the preceding calendar year; and (ii) the names and addresses of third parties that received such information, or if the nature of their business cannot be determined from the name, then examples of the products or services marketed. Please put “Shine the Light Request” in the subject line of your email.
Exercising your/your child’s rights
When you/your child write to us making a request to exercise your/your child’s rights, we may ask for copies of relevant ID documents to help us to verify identity.
It will help us to process your/your child’s request if you/your child clearly state which right you/your child wish to exercise, what personal data it is that is of particular concern to you/your child and, where relevant, why it is that you/your child are exercising it. The clearer and more specific the request, the faster and more efficiently we can deal with that request. If insufficient information is provided then there may be a delay in actioning the request until additional information is provided (and where this is the case we will tell you/your child).
Please note that all the rights mentioned in this section are not absolute and we may be entitled to refuse requests, wholly or partly, where exceptions under the applicable law apply. For example, we may refuse to comply with a request if it is manifestly unfounded or excessive.
10. Contact Details
Whilst we would prefer that you direct any complaints or queries you/your child have to us first, you/your child may also lodge a complaint to the supervisory authority applicable in your country about the way we process your/your child’s personal data. In the UK, this is the Information Commissioner’s Office (ICO).