Kogan
Retail & Ecommerce
No relevant claims found in policy - no specific provisions for children's data protection, age verification, or parental consent mechanisms. Overall: Good with minor gaps.
10 dimensions · 57 claims · assessed 19 May 2026 · methodology · source policy ↗
Score Breakdown
Transparency
Good with minor gaps
7.67/107.67/10
Transparency
Good with minor gaps
Transparency & Clarity
8/10Comprehensive policy structure with clear definitions, specific contact information including Privacy Officer details, numbered sections for navigation, and current version date. Strong commitment statement and detailed scope coverage.
Purpose Limitation & Use
8/10Comprehensive list of primary purposes with explicit secondary use disclosure, clear marketing and analytics uses, consent requirements for additional purposes, and necessity limitations. Strong coverage of lawful use authority and purpose notification commitments.
Policy Maintenance & Accountability
6/10Clear modification rights and current update date, specific Privacy Officer contact details, and complaint handling timeframes. However, lacks regular review frequency commitments and comprehensive governance framework details.
Data Protection
Good with minor gaps
6.67/106.67/10
Data Protection
Good with minor gaps
Data Collection Disclosure
8/10Detailed enumeration of personal information types including sensitive data, clear collection methods and circumstances, lawful collection commitment, and specific consent mechanisms. Good coverage of cookies and third-party collection with user control options.
Third-Party Sharing & Disclosure
7/10Clear categories of third-party sharing with specific countries named for cross-border disclosure, consent requirements stated, and marketing lead generation arrangements disclosed. Some specificity in partner arrangements but could be more granular on contractual obligations.
Data Security
4/10Generic 'reasonable steps' commitment without specific security measures, encryption details, or certifications. Includes transmission security disclaimer and overseas transfer protections but lacks concrete technical safeguards or breach notification procedures.
Cross-Border Data Flows
7/10Specific countries named (Philippines, Hong Kong, New Zealand) with clear purpose statement and reasonable safeguards commitment to ensure APP compliance. Good notification through policy disclosure but could benefit from more detailed adequacy mechanisms.
Your Rights
Major deficiencies
3.2/103.2/10
Your Rights
Major deficiencies
Consumer Rights & Control
8/10Detailed access and correction rights with clear mechanisms, specific opt-out procedures for marketing with brand-specific email addresses, complaint handling with 5-day response timeframe, and deletion rights when information no longer needed. Strong procedural clarity.
Automated Decision-Making
not assessedNo relevant claims found in policy - no disclosure of automated decision-making, AI use, profiling, or related opt-out rights.
Children's Data
not assessedNo relevant claims found in policy - no specific provisions for children's data protection, age verification, or parental consent mechanisms.
No specific findings.
Sector Comparison
Retail & Ecommerce comparison