1) Scope & who this policy applies to

This Policy applies to personal information we handle in connection with:

• • ・Browsing and interacting with the Website;
  • ・Creating accounts, newsletter sign ups, competitions, support queries, or online purchases (if offered on the Website);
  • ・Cookies, pixels and similar tracking technologies used on the Website. OAIC treats tracking technologies as personal information handling where individuals are reasonably identifiable, which engages APP obligations including notice, consent (where applicable), and opt out tools.

2) The personal information we collect

Depending on how you use the Website, we may collect:

• • ・Identifiers & contact: name, username, email, postal address, phone.
  • ・Transactional & support: purchase details (if e commerce is offered), inquiries, feedback.
  • ・Technical & usage data: IP address, device identifiers, browser/OS, pages viewed, referring URLs, timestamps, and interactions (via cookies, pixels, SDKs). OAIC guidance recognises pixels and cookies can collect personal information that triggers APP requirements.
  • ・Marketing preferences: subscription status, opt in/opt out choices for direct marketing under APP 7.
  • ・Age-related information (where features target children or require age gates): we may collect age or date of birth to provide age appropriate experiences and apply heightened protections consistent with OAIC’s emerging Children’s Online Privacy Code framework.

We will not collect sensitive information (e.g., health, biometric, religious beliefs) unless strictly necessary and permitted by law and, where required, only with consent.

3) How we collect information

• • ・Directly from you: forms, account creation, subscriptions, surveys, support requests.
  • ・Automatically: through cookies, pixels, logs and analytics when you use the Website. OAIC requires clear notice and data minimisation for tracking technologies and recommends configuring pixels to limit personal information collection.
  • ・From service providers: payment, fulfilment, analytics, security/anti fraud, and customer support partners, where permitted. Cross border handling is subject to APP 8 (see Section 7).

4) Why we collect and use personal information (APP 3, 5 & 6)

We use personal information only for purposes that are necessary for our functions and disclosed to you at or before the time of collection (or as soon as practicable thereafter), including:

• • ・Operating the Website & providing requested services (contract/legitimate interests): page delivery, account features, customer support, purchase processing, and security.
  • ・Website performance & analytics (legitimate interests/consent where required): to understand usage, fix issues, and improve content. Configure pixels to minimise data and avoid sending sensitive information.
  • ・Direct marketing: email newsletters, promotions, and personalised content in line with APP 7 (including simple opt out mechanisms).
  • ・Legal & risk: fraud prevention, incident response, and compliance with applicable laws and regulator requirements.

5) Cookies, pixels and similar technologies

We use cookies (including essential, analytics, and marketing cookies) and third party pixels (e.g., for measurement or ad delivery).

• • ・Transparency: We provide a cookie banner/notice and a Preferences Centre so you can manage non essential cookies. OAIC emphasises clear notice and appropriate consent/opt out controls for tracking technologies.
  • ・Data minimisation: We configure tags to limit personal information collection and prevent disclosure of sensitive information to third parties.
  • ・Cross border: If cookie/pixel providers transfer data overseas, we take reasonable steps under APP 8 to ensure comparable protections or rely on permitted exceptions (see Section 7).

You can manage cookies via our Preferences Centre and your browser settings. Some site features may not function without essential cookies.

6) Direct marketing (APP 7)

We may send you updates and promotions about Tamagotchi if you have opted in or if permitted by law. We will provide a simple means to opt out in each message (e.g., unsubscribe link). Targeting and pixel based advertising must comply with APP 7 and OAIC guidance.

7) Overseas disclosures & cross border transfers (APP 8)

We may disclose personal information to overseas service providers (e.g., hosting, analytics, customer support, or group companies) located in countries such as Japan, the United States, or other jurisdictions.
Before disclosing personal information overseas, we take such reasonable steps as are appropriate to ensure the recipient does not breach the APPs (other than APP 1). We may use contractual safeguards, vendor assessments, and technical controls, or rely on APP 8 exceptions (e.g., informed consent or where the recipient is subject to a substantially similar law or binding scheme), as outlined by OAIC.

Note: OAIC has updated APP 8 guidance to reflect Privacy and Other Legislation Amendment Act 2024 changes, including a new exception mechanism, effective from 11 December 2024. We will keep this section current as further OAIC guidance is released.

8) Children’s privacy

Tamagotchi appeals to families and younger audiences. We apply heightened protections when we reasonably believe a user is a child, including minimising personal information collection, avoiding profiling for marketing, and using age appropriate notices. OAIC is developing a Children’s Online Privacy Code due by 10 December 2026, which will specify how online services accessed by children must comply with the APPs, and may impose additional requirements. We will update this Policy and our practices to meet the Code once in force.

9) Anonymity & pseudonymity (APP 2)

Where practicable, you may interact with us without identifying yourself or by using a pseudonym (for example, browsing the Website without logging in). Certain features (purchases, account functions, customer support) may require identification.

10) Data quality & security (APP 10 & 11)

We take reasonable steps to ensure personal information we collect, use or disclose is accurate, up to date and complete. We implement administrative, technical and physical safeguards to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure. OAIC emphasises strong security practices and data minimisation.

11) Retention & deletion

We retain personal information only for as long as necessary for the purposes described above or as required by law, then delete or de identify it in line with our data retention schedule. (OAIC guidance on APP 11 requires protection and appropriate disposal of personal information.)

12) Access & correction (APP 12 & 13)

You may request access to the personal information we hold about you and request corrections if it is inaccurate, out of date, incomplete, irrelevant or misleading. We will respond within a reasonable period and in accordance with the APPs. If we refuse access or correction, we will provide reasons and how you can complain.

13) Notifiable Data Breaches (NDB) scheme

If a data breach is likely to result in serious harm, we will assess, notify affected individuals and notify the OAIC in accordance with the NDB scheme requirements under the Privacy Act. (Industry guidance summarises the need to prepare for prompt breach notification.)

14) How we share personal information

We may share personal information with:

• • ・Service providers: hosting, analytics, marketing (subject to APP 6), payment processing, fulfilment, anti fraud, and customer support. We require them to handle personal information consistently with the APPs and this Policy.
  • ・Affiliates/Group companies: for operational support and legal compliance, subject to APP 8 for cross border disclosures.
  • ・Regulators and legal authorities: where required or authorised by law.

We do not disclose children’s personal information for behavioural advertising and we avoid profiling children except where it is demonstrably in their best interests, consistent with the direction of the forthcoming Children’s Code.

15) Your choices

• • ・Marketing: Unsubscribe at any time using links in our emails. (APP 7 requires a simple means to opt out.)
  • ・Cookies & tracking: Use our Preferences Centre or browser controls to manage non essential cookies and pixels; block third party cookies if desired. OAIC guidance supports transparency and controls for tracking technologies.
  • ・Pseudonymity: Where feasible, interact without providing identifiable information (APP 2).

16) Complaints & contacting us

If you have concerns about how we handle your personal information, please contact us first at:
Privacy Contact: toys@bandainamcoent.com.au | Address: Level 2, 83-87 Kippax Street, Surry Hills, NSw, 2010

Can use contact link on Tamagotchi.com website

We will respond within a reasonable timeframe. If you are not satisfied, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC): www.oaic.gov.au.

17) Changes to this Policy (APP 1)

We may update this Policy to reflect changes in our practices, the law, or OAIC guidance—especially as Australia’s privacy reforms progress and the Children’s Online Privacy Code is finalised (deadline 10 December 2026). We will post updates here and revise the “Last updated” date; material changes may also be communicated via a notice on the Website.

Annex: Additional notes for Tamagotchi context (non policy guidance)

• • ・Some Tamagotchi experiences (e.g., Tamagotchi Uni) are designed to minimise data collection (e.g., device ID, IP, game data), and may rely on servers in Japan. If similar integrations exist on tamagotchi.com, incorporate APP 8 safeguards and vendor contracts for cross border handling.
  • ・Bandai entities publish global privacy notices; ensure the Australia specific site references this Policy and any AU/NZ specific privacy notices where relevant.