PRIVACY, DATA PROTECTION & ONLINE SAFETY POLICY

Effective date: 10 November 2026
Last updated: 10 November 2026
Organisation: The Laughing Otter (TLO) and its applicable affiliated entities, brands and services
Website: https://www.thelaughingotter.com

1. INTRODUCTION

The Laughing Otter ("TLO", "we", "our" or "us") is committed to protecting the privacy, personal information, security and online safety of everyone who interacts with our websites, games, applications, products, services and digital platforms.

Our goal is to create positive, entertaining, educational and engaging experiences in a safe and respectful online environment.

This Privacy, Data Protection and Online Safety Policy establishes the principles and practices that govern how we collect, use, store, protect, disclose and manage personal information.

This policy applies to all TLO-operated and TLO-branded digital environments, including:

• Websites and online platforms.
• Mobile applications and downloadable apps.
• Online, mobile, browser-based and downloadable games.
• Digital entertainment and interactive experiences.
• Memberships, subscriptions and user accounts.
• Competitions, promotions, giveaways and events.
• Digital products, content and educational resources.
• Social media channels and online communities operated by TLO.
• Any future products, services or digital experiences developed, owned, licensed, managed or operated by TLO.

This policy applies whether you access our services through a computer, mobile phone, tablet, gaming device or another supported technology.

Where a particular product or service has additional privacy requirements, a supplementary notice or product-specific policy may also apply.

2. OUR PRIVACY PRINCIPLES

TLO is guided by the following principles:

1. Privacy first: We respect the privacy of individuals and seek to collect only information reasonably necessary for our activities.
2. Transparency: We aim to explain what information we collect, why we collect it and how it is used.
3. Security: We take reasonable measures to protect personal information against unauthorised access, loss, misuse, alteration or disclosure.
4. User control: We provide appropriate opportunities for individuals to access, correct, manage or request deletion of their personal information.
5. Protection of children: We recognise the importance of protecting children and younger users in online environments.
6. Responsible technology: We seek to use technology, artificial intelligence, analytics and advertising responsibly.
7. Accountability: We expect our employees, contractors, suppliers and business partners who handle personal information on our behalf to respect applicable privacy and security obligations.

3. INFORMATION WE MAY COLLECT

Depending on the TLO website, game, application or service you use, we may collect the following categories of information.

3.1 Personal and contact information

This may include:

• Name or username.
• Email address.
• Telephone number.
• Mailing or billing address.
• Account registration information.
• Age or date of birth, where required.
• Parent or guardian contact details, where appropriate.

3.2 Account and profile information

Where accounts or profiles are offered, we may collect:

• Login credentials and account identifiers.
• Profile preferences.
• User-selected avatars and display names.
• Account settings.
• Subscription or membership status.
• User preferences and saved content.

We will not request passwords or other authentication secrets through unsolicited communications.

3.3 Technical and device information

When you access our services, we or our service providers may automatically collect certain technical information, including:

• IP address.
• Device type and operating system.
• Browser type and version.
• Device identifiers.
• Application version.
• Language and regional settings.
• Network information.
• Access dates and times.
• Crash reports, diagnostic information and performance data.

3.4 Usage and gameplay information

Depending on the product, we may collect information about how our services are used, including:

• Game progress and achievements.
• Scores, rankings and gameplay statistics.
• Levels completed and preferences.
• App interactions and feature usage.
• Session duration.
• General engagement and performance information.
• Error reports and technical issues.

3.5 Payment and transaction information

Where purchases, subscriptions, donations or other paid services are offered, payment information may be processed by authorised third-party payment providers.

We may receive transaction details such as:

• Purchase history.
• Payment status.
• Transaction identifiers.
• Subscription details.
• Billing information.
• Refund and transaction records.

TLO does not need to directly store complete payment card details when payment processing is handled by an external payment provider.

3.6 User-generated information

Where supported, we may collect information that users voluntarily submit, including:

• Comments and feedback.
• Messages and support enquiries.
• Competition entries.
• Uploaded images, videos or other content.
• Survey responses.
• Reviews, suggestions and submissions.
• Reports of inappropriate content or behaviour.

Users should not submit sensitive personal information or another person's private information unless specifically requested through an appropriate and secure process.

3.7 Location information

Some services may collect approximate or precise location information where necessary for a particular feature and where permitted by applicable law.

Location information may be obtained through device settings, IP addresses or other authorised technical methods.

Where location information is not necessary, we will seek to avoid collecting it.

3.8 Information from third parties

We may receive information from authorised third parties, including:

• App stores and distribution platforms.
• Payment processors.
• Analytics and advertising providers.
• Authentication services.
• Marketing and referral partners.
• Business and event partners.
• Other services you choose to connect to our platforms.

We will handle such information in accordance with this policy and applicable law.

4. HOW WE USE INFORMATION

We may use personal and technical information for legitimate business and operational purposes, including:

• Providing and operating our websites, applications and games.
• Creating and maintaining user accounts.
• Delivering content, entertainment and digital products.
• Saving gameplay progress and preferences.
• Processing transactions and subscriptions.
• Responding to customer enquiries and support requests.
• Improving product performance and user experience.
• Identifying bugs, errors, suspicious activity and technical problems.
• Protecting users, accounts, systems and infrastructure.
• Detecting and preventing fraud, abuse and unauthorised activity.
• Administering competitions, promotions and events.
• Communicating important service updates.
• Sending marketing communications where permitted.
• Measuring advertising and promotional effectiveness.
• Conducting research and product development.
• Meeting legal, regulatory and contractual obligations.

We will not knowingly use personal information for purposes that are incompatible with the purposes for which it was collected, unless permitted or required by law.

5. CHILDREN, FAMILIES AND YOUNGER USERS

TLO aims to provide family-friendly experiences and recognises that children and younger people may access our websites, games and applications.

We take particular care when designing services that may be accessed by children.

5.1 Children's privacy

Where a service is likely to be accessed by children, we will take reasonable steps to ensure that personal information is handled appropriately and in accordance with applicable children's privacy requirements.

Depending on the service and applicable law, this may include:

• Limiting the information collected from children.
• Avoiding unnecessary personal information requirements.
• Providing age-appropriate privacy information.
• Obtaining parental or guardian consent where legally required.
• Providing appropriate parental or guardian controls.
• Restricting access to unsuitable features or content.
• Limiting the collection and use of location information.
• Applying appropriate controls to user-generated content and communications.
• Restricting personalised advertising where required.
• Providing processes for parents or guardians to raise privacy concerns.

5.2 Children's personal information

TLO does not knowingly seek to collect unnecessary personal information from children.

Where parental or guardian consent is required by law, we will take reasonable steps to obtain and verify that consent before collecting, using or disclosing the relevant information.

If we become aware that personal information has been collected from a child in circumstances that are inconsistent with applicable legal requirements, we will take appropriate steps to address the situation.

5.3 Parental and guardian requests

A parent or legal guardian may contact us to:

• Enquire about information collected from their child.
• Request access to their child's personal information, subject to applicable law.
• Request correction or deletion where appropriate.
• Withdraw consent where legally applicable.
• Raise concerns about a TLO product or service.

We may need to verify the identity and authority of the person making the request.

5.4 Age restrictions

Some TLO products, games, features or services may have minimum age requirements.

Where applicable, these requirements will be communicated through the relevant product, application store or service.

Nothing in this policy overrides age restrictions imposed by law or by the platforms through which our services are distributed.

6. COOKIES, TRACKING AND ANALYTICS

Our websites, applications and digital services may use cookies and similar technologies.

These technologies may include:

• Essential cookies required for functionality.
• Preference and settings cookies.
• Analytics and performance tools.
• Advertising and measurement technologies.
• Session identifiers.
• Device and application analytics.

These technologies may help us:

• Understand how visitors use our websites.
• Improve navigation and performance.
• Remember preferences.
• Identify technical problems.
• Measure the effectiveness of campaigns.
• Understand general usage trends.
• Support security and fraud prevention.

You may be able to manage cookies through your browser or device settings.

Disabling certain cookies may affect the availability or functionality of some services.

Where required by law, we will obtain consent before using non-essential cookies or similar tracking technologies.

7. ADVERTISING AND THIRD-PARTY ADVERTISING SERVICES

TLO may use advertising networks, advertising partners and third-party services to support free or subsidised digital experiences.

These providers may use cookies, device identifiers, advertising identifiers and similar technologies to deliver, measure or improve advertising.

Depending on the service and applicable law, advertising may be contextual, general or personalised.

Where children may access a service, we will apply appropriate advertising restrictions and safeguards required by applicable laws and platform policies.

We do not authorise advertising partners to use children's personal information for purposes that are prohibited by applicable law.

Users may have options to manage advertising preferences through their device, browser or relevant advertising provider.

8. ARTIFICIAL INTELLIGENCE AND AUTOMATED TECHNOLOGIES

TLO may use artificial intelligence (AI), machine learning, automation and other emerging technologies to support the development and operation of its products and services.

These technologies may be used for:

• Content creation and recommendations.
• Game development and functionality.
• Customer support.
• Technical analysis.
• Product improvement.
• Personalisation.
• Moderation and safety processes.
• Operational efficiency.

Where personal information is processed through AI or automated systems, we will take reasonable steps to ensure that such processing is appropriate, secure and consistent with applicable privacy laws.

We will not knowingly submit sensitive personal information or children's personal information to third-party AI systems unless there is an appropriate legal basis, necessary safeguards and a legitimate operational reason.

Where applicable law requires disclosure of significant automated decision-making, we will provide the required information about the relevant processes.

9. DISCLOSURE AND SHARING OF INFORMATION

TLO may disclose or share personal information with authorised third parties where reasonably necessary for the operation of our business and services.

These may include:

• Website hosting and infrastructure providers.
• Cloud storage and database providers.
• Software and application developers.
• Game development and distribution platforms.
• Analytics and performance providers.
• Payment processors.
• App stores and digital marketplaces.
• Advertising and marketing providers.
• Customer support providers.
• Security and fraud prevention providers.
• Professional advisers, including legal and accounting advisers.
• Business partners and event organisers, where relevant.
• Government authorities and regulators where required or permitted by law.

Where practical and appropriate, we seek to ensure that third-party providers are subject to confidentiality, privacy and security obligations.

We do not permit service providers to use personal information for unrelated purposes unless authorised by law or otherwise appropriately disclosed and agreed.

9.1 Business transactions

If TLO undergoes a merger, acquisition, restructuring, sale of assets, investment transaction or transfer of business operations, personal information may be transferred as part of that transaction, subject to applicable privacy requirements.

Any recipient of such information must handle it in accordance with applicable law.

9.2 Sale of personal information

We do not intend to sell personal information as a standalone commercial product.

Where information is disclosed to advertising, analytics or other commercial partners, the disclosure and any associated use will be governed by applicable law, the relevant service arrangements and this policy.

10. INTERNATIONAL DATA TRANSFERS

TLO may use service providers, hosting infrastructure and technology platforms located in Australia or other countries.

As a result, personal information may be stored, processed or accessed outside the country in which it was originally collected.

Where personal information is transferred overseas, we will take reasonable steps to ensure that applicable privacy and data protection requirements are satisfied.

Depending on the circumstances, this may include contractual safeguards, appropriate security arrangements and other measures required by law.

The countries in which information may be processed will depend on the third-party services and infrastructure used by the relevant TLO product or service.

11. DATA STORAGE AND SECURITY

TLO takes reasonable technical, organisational and administrative measures to protect personal information.

Depending on the nature of the information and the services involved, these measures may include:

• Access controls and permission management.
• Password and authentication protections.
• Encryption where appropriate.
• Secure hosting and cloud infrastructure.
• Software updates and security patches.
• Backup and recovery processes.
• Monitoring for suspicious activity.
• Protection against unauthorised access.
• Restricted access to sensitive information.
• Security reviews and testing.
• Appropriate staff and contractor confidentiality obligations.

Access to personal information should be limited to individuals and service providers who reasonably require it to perform their authorised responsibilities.

No internet-based service, electronic storage system or method of transmission can be guaranteed to be completely secure.

Users are responsible for keeping their account credentials confidential and notifying us if they suspect unauthorised access to their account.

12. DATA BREACHES AND SECURITY INCIDENTS

TLO will take appropriate steps to investigate and respond to suspected or confirmed data breaches and security incidents.

Where a breach occurs, we may:

1. Investigate the nature and extent of the incident.
2. Identify affected systems and information.
3. Take reasonable steps to contain and mitigate the incident.
4. Assess potential harm to affected individuals.
5. Restore or secure affected services.
6. Notify affected individuals and relevant authorities where required by law.
7. Take reasonable steps to prevent similar incidents occurring again.

Where applicable, TLO will comply with relevant mandatory data breach notification requirements, including Australia's Notifiable Data Breaches scheme.

Users should report suspected security incidents through our contact details.

13. DATA RETENTION AND DELETION

TLO will retain personal information only for as long as reasonably necessary for the purposes for which it was collected, or as required or permitted by law.

Retention periods may vary depending on:

• The type of information.
• The nature of the service.
• Whether an account remains active.
• Legal and regulatory obligations.
• Financial and transaction record requirements.
• Security and fraud prevention requirements.
• Dispute resolution and contractual obligations.

When information is no longer required, we will take reasonable steps to securely delete, destroy or de-identify it.

Some information may remain in secure backups, archived systems or records for a limited period before being permanently removed.

14. USER RIGHTS AND CONTROL

Subject to applicable law, individuals may have the right to:

• Request access to personal information held about them.
• Request correction of inaccurate or incomplete information.
• Request deletion of personal information.
• Withdraw consent where processing relies on consent.
• Object to certain types of processing.
• Restrict certain uses of personal information.
• Opt out of marketing communications.
• Request information about overseas disclosures.
• Lodge a privacy complaint.

Some requests may be subject to legal exceptions or limitations.

For example, TLO may need to retain certain information to meet legal obligations, resolve disputes, prevent fraud or protect the security of its services.

14.1 Account deletion

Where a TLO product or service offers user accounts, users may request account closure or deletion.

Where applicable, account deletion may result in the loss of saved progress, achievements, preferences, purchases or other account-associated information.

Information that must be retained for legitimate legal or regulatory reasons may be retained for the applicable period.

14.2 Marketing preferences

Users may unsubscribe from marketing emails by using the unsubscribe facility provided in the communication or contacting TLO.

Service-related communications, including security notifications, transaction confirmations and important operational announcements, may continue where necessary.

15. USER-GENERATED CONTENT AND ONLINE INTERACTIONS

Some TLO services may allow users to submit, share or interact with content.

This may include comments, reviews, scores, competition entries, messages, images, videos or other submissions.

Users are responsible for ensuring that content they submit does not:

• Violate another person's privacy.
• Contain personal information shared without permission.
• Include harassment, threats or abuse.
• Contain unlawful, harmful or inappropriate material.
• Infringe intellectual property rights.
• Facilitate fraud, impersonation or other misconduct.

Where a service allows public submissions or interactions, TLO may use moderation systems, reporting facilities and other reasonable safeguards.

We reserve the right, subject to applicable law and the relevant service terms, to remove content, restrict access, suspend accounts or take other appropriate action where we identify inappropriate or harmful conduct.

Users should understand that information deliberately posted in public areas may be visible to other people and may be copied or redistributed.

TLO cannot guarantee the privacy of information voluntarily made public by users.

16. THIRD-PARTY WEBSITES, APPS AND SERVICES

Our websites, games and applications may contain links, integrations or connections to third-party websites, platforms, applications and services.

Examples include:

• App Store and Google Play.
• Social media platforms.
• Video hosting services.
• Payment providers.
• Advertising platforms.
• External games and entertainment services.
• Affiliate and promotional partners.

These third parties operate under their own privacy policies and terms.

TLO is not responsible for the privacy, security or data handling practices of independent third-party services.

Users should review the applicable privacy policies before providing information to external services.

17. SOCIAL MEDIA AND PUBLIC COMMUNICATIONS

When users interact with TLO through social media platforms, their information may also be subject to the privacy policies and settings of those platforms.

Public comments, posts, photographs and other interactions may be visible to other users.

We encourage users to avoid publicly sharing sensitive personal information, private contact details or information about children.

Where TLO operates social media communities, we may moderate content and respond to reports of inappropriate conduct.

18. MARKETING AND COMMUNICATIONS

TLO may communicate with users about:

• New games and applications.
• Products and services.
• Events and competitions.
• Promotions and offers.
• Updates and announcements.
• Newsletters and entertainment content.

Where required by law, we will obtain appropriate consent before sending commercial electronic messages.

Users may unsubscribe or withdraw their marketing consent at any time.

We will continue to send essential communications where reasonably necessary to provide a service or meet legal obligations.

19. INTERNATIONAL PRIVACY RIGHTS

TLO aims to respect applicable privacy and data protection requirements in the countries where our products and services are offered.

Depending on your location, additional rights and protections may apply under legislation such as:

• Australia's Privacy Act 1988 and Australian Privacy Principles.
• The European Union General Data Protection Regulation (GDPR).
• The United Kingdom GDPR and Data Protection Act 2018.
• The California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA).
• Other applicable national, state and regional privacy and data protection laws.

Where a law provides additional rights, protections or obligations, those requirements will apply to the extent relevant.

Nothing in this policy is intended to limit rights that cannot legally be excluded.

20. AUSTRALIAN PRIVACY LAW

For users and activities covered by Australian privacy legislation, TLO will handle personal information in accordance with applicable requirements, including the Australian Privacy Principles where applicable.

These requirements include appropriate practices concerning:

• Collection and notification.
• Use and disclosure.
• Direct marketing.
• Overseas disclosures.
• Information quality.
• Information security.
• Access and correction.
• Privacy complaints.

TLO will also consider applicable online safety and children's privacy requirements when developing and operating services that may be accessed by children.

21. PRIVACY COMPLAINTS AND DISPUTES

If you believe that TLO has mishandled your personal information or breached this policy, you may contact us using the details below.

Please provide:

• Your name and contact details.
• The relevant TLO website, application or service.
• A description of your concern.
• Any relevant supporting information.

We will review privacy complaints and take reasonable steps to investigate and respond.

Where appropriate, we may request further information to verify your identity and understand the issue.

If you are not satisfied with our response, you may have the right to lodge a complaint with the relevant privacy regulator.

In Australia, this may include the Office of the Australian Information Commissioner (OAIC).

Website: https://www.oaic.gov.au

22. CHANGES TO THIS POLICY

TLO may update this policy from time to time to reflect:

• Changes to our business operations.
• New websites, applications and games.
• New technologies and services.
• Changes to data collection and processing practices.
• New security requirements.
• Changes in applicable laws and regulations.

The latest version will be published on the TLO website.

Where material changes are made, we will take reasonable steps to notify affected users where required or appropriate.

Continued use of our services following an update will be subject to applicable law and any consent requirements.

23. CONTACT INFORMATION

For privacy enquiries, requests, complaints, security concerns or questions about this policy, please contact:

The Laughing Otter

Website: https://www.thelaughingotter.com

Privacy contact: [INSERT PRIVACY CONTACT EMAIL]

General enquiries: [INSERT CONTACT EMAIL]

Business location: Australia

When contacting us about personal information, please include sufficient details for us to identify the relevant account or service. Please do not send passwords, payment card details or other sensitive authentication information.

24. GENERAL PROVISIONS

This policy is intended to apply broadly across TLO's business activities, digital products, games, applications and online services.

Where a specific product or service has additional terms, privacy notices, consent requirements or safety rules, those additional provisions will operate alongside this policy.

If any provision of this policy is found to be invalid or unenforceable, the remaining provisions will continue to apply to the extent permitted by law.

Nothing in this policy excludes, restricts or modifies any consumer guarantee, statutory right or legal protection that cannot lawfully be excluded, restricted or modified.

THE LAUGHING OTTER

Creating positive experiences. Protecting privacy. Promoting safer online environments.