Thank you for your interest in a digital service
owned and/or operated by Turner Broadcasting Asia Pacific, a part of the WarnerMedia Group
will treat information including personal information
, provided or collected on the digital services
is processed in accordance with applicable laws, rests with the WarnerMedia Entity
who owns and/or operates this digital service
– please refer to the Addendum
for the list of data controllers
who own and/or operate the respective digital service
should therefore also be read as references to the entity which is the data controller
in respect of your personal information
for this digital service
. If you provide information to us via a third party (for example on one of our digital services
on a third party platform
will not apply to our use of the information collected by us through our digital services
. Links in our digital services
may take you to third party platforms
and we are not responsible for the privacy practices of those third party platforms
The laws of certain jurisdictions require us to provide you with additional information about our processing activities and we have included separate appendices to deal with this. Please refer to the appendices that apply to you:
2. What information is collected?
We collect some or all of the following personal information
. If you fail to provide the personal information
required by our digital services
for the provision of a specific experience, product or service, we may be unable to deliver such experience, product or service. We collect less personal data on our online services
. Please see the individual privacy notices published on each of our online services
to see what personal information
we collect on those services.
- Personal information such as your name, postal address, telephone number, email address, date of birth or gender, or your photos and other images.
- Information you provide in the course of your use of, or your registration with, our digital services. For example, when you create an account, register for or download a digital service, or when you enter into a survey, promotion or competition on a digital service, you may provide us with information such as service providers’ account identifiers, voucher codes, and/or passwords.
– Information you provide when you make a purchase of a product or service on our digital services. For example, credit/debit card details, billing information, delivery address, information about trial periods, periods without an active subscription etc. and service providers’ account identifiers.
– Information provided about your use, and the use or participation, as applicable, by any person(s) you authorize through your account, of the digital services, device and browser settings, the digital services you use, advertisements you see and interact with, and certain digital service usage information such as advertisements clicked on or viewed, content that you have viewed or posted, games that you have downloaded or played, competitions or surveys that you have participated in and your preferences and interest in and use of various products, programs, services and content available on our digital services. This may also include demographic information including, at a household level, information about your preferences.
- Information you provide when you engage with our digital services on or through third party platforms which include social media sites and applications. When you link to or interact with a digital service via a third party platform, you allow us to receive certain information about you from that third party platform (e.g. social media account name, user ID, email address, profile photo, photos and videos, gender, birthday, your list of friends and their contact details, people you follow and/or who follow you and the posts or the 'likes' you make). We also receive information from your interaction with the digital service (e.g. content viewed, competition entries, game performance, high scores and information about advertisements you have been shown or have clicked on). We do not collect social media information in relation to online services.
- On some of our digital services, we may collect personal information you submit about other people. For example, you might submit personal information to invite a friend to participate in an offering, make recommendations, or share content, or have multiple players sharing the same video game session. Such information may include name, postal address, email address, telephone number, or information about the person’s interest in and use of various products, programs, services, and content. In certain situations, we also allow you to invite your friends to participate in activities by providing their contact details or importing contacts from your address book or from third party platforms.
– Information you provide when you contact us for support or in relation to other queries. For example, when you contact us through one of our customer helpdesks or customer call centres, your calls and other correspondence with us may be recorded, and transcripts of your emails, chats or other social media correspondence may also be stored.
– Information regarding your location such as country code as provided by a mobile or other device interacting with our digital services, or associated with your IP address, where we are permitted by law to process this information.
– Technical and device information provided when you visit our digital services (including via third party platforms), including your type of device, browser and operating system, your Internet service provider or mobile carrier, your unique device identifier, IDFA, IDFV or MAC address, advertisements you see and interact with, and certain digital services usage information such as your viewing history, data consumption related to churn, use of functionalities, title selection, search queries and results (only stored locally within the digital service for certain subscription digital services) [and marketing optimization].
– Technical and commercial business information collected by us when you visit our digital services as may be required to be provided in connection with a third party due diligence request.
– Your employer’s or company name, your name, your email address, your job title/category and your social media handle as may be required to be provided in connection with a business transaction between a WarnerMedia Entity and a company you work for or a service you provide.
3. How is information collected?
Information about you
We collect personal information
from you directly (e.g. when you register for a digital service
account or enter into a competition) or through your use of our digital services
(e.g. your browsing history as you navigate through our digital services
We also collect personal information
about you from other sources, including:
- when you engage with certain of our digital services offered through third party platforms such as social media platforms. These third party platforms will share information described under the heading titled “Social media information” in Section 2 above. These third party platforms will have their own privacy policies governing how they use your personal information, and any privacy settings you set on the third party platform may not extend to our use of your personal information. For example, some third party platforms allow you to push content from our digital services to your contacts or to pull information about your contacts so you can connect with them on or through our digital services. Some third party platforms will facilitate your registration for our digital services or enhance or personalize your experience on our digital services. Your decision to use a third party platform in connection with certain of our digital services is voluntary;
- from other people who provide information on your behalf. For example, users of our digital services can submit information to invite a friend to participate in an offering, make recommendations, share content, or have multiple players sharing the same video game session. Such information may include your name, postal address, email address, telephone number, or information about your interest in and use of various products, programs, services, and content. In certain situations, we also allow our users to invite their friends to participate in activities by providing their contact details or importing contacts from their address books or from third party platforms.
Where permitted by law, by providing personal information
or otherwise interacting with our digital services
through other sources, you consent to our use of personal information
We may combine personal information
we receive from other sources with personal information
Information about others
4. How we use children’s information?
Most of the digital services
are intended for users of all ages.
On some digital services
, for the different types of purposes listed in Section 5, we may ask you to provide age information. If you indicate that you are a child
, as permitted by law we will (i) collect limited personal information
(e.g. persistent identifier and/or email address only), (ii) inform you, that as a child
under applicable laws, a parent's
verifiable consent is required, and/or (iii) collect your email address in addition to your parent’s
We use a parent's
email address to seek the parent's
verifiable consent, or notify the parent
of a child's
online activities, to seek the parent’s
consent for a child
to complete a transaction (for example, entry into a competition on a digital service
), and/or to enable the parent
to unsubscribe a child
from a newsletter, competition or other similar activity. Any information provided by a child
will be held for up to 30 days while we wait to receive parental consent and will be deleted if the relevant consent is not provided.
Once a parent
provides consent, we may use any information from the child
. If a user is a child, we will not condition their participation in an online activity on the disclosure of more personal information
than is reasonably necessary to participate in the activity.
If you are a parent
and would like to review any personal information
that we have collected online from your child
, have this personal information
deleted from our active servers, and/or request that there be no further collection or use of your child's personal information
, or if you have questions about these information practices, you may contact us using our request form
. Please note that to protect children’s
privacy and security, we will take reasonable steps to verify a parent’s
identity before granting access to any personal information
Online Services aimed specifically at children
Some digital services
are aimed specifically at children
. We call these online services
. In relation to our online services
, so that children
can easily understand how we process their personal information
. The child
We reserve the right at all times to verify your age and identity where necessary to comply with age limited legal restrictions on our use, disclosure or deletion of your personal information
5. How do we use information?
We use your personal information
for the following purposes:
– To process your account registration; to respond to a request; to administer your subscription; to process payment; to fulfil a transaction; to allow you to submit a post or other content; to ensure service quality and optimize your experience (for example. game play synchronisation) to be able to send you relevant information in relation to your subscription/account; to provide seamless experience across digital services and devices.
– Where you have consented (as required by law), to receive marketing communications including offers, promotions and newsletters, from us or other WarnerMedia Entities and other third parties with whom we conduct business, which may be personalised based on your visits to and use of the digital services. We may share personal information, anonymised information and aggregated information with third parties for marketing purposes.
– To verify your age, identity, residency and other eligibility requirements; to notify you if you have won; to deliver the prize and respond to any query regarding the activity.
– To conduct analysis to better understand the performance of our digital services and to understand your interests and preferences so that we can improve, refine and personalise your experience on the digital services. For example, we will analyse your search queries, the frequency and length of your viewing, your digital services views and clicks to understand your interests and preferences to provide customized marketing to you and to other target groups which may have similar preferences, and to operate advertising campaigns, where applicable. We may combine the personal information we collect about you from other WarnerMedia Entities or third parties to improve and refine our offerings or personalise our marketing communications to include content that may be of interest to you, including for example, to tailor the advertising that you see where you have consented to receive personalised advertising.
– To communicate with you about a digital service
for which you have registered and/or a related account; to obtain feedback about transactions on our digital services
and/or a related account; to update you about changes to our digital services
; and to enable us and our service providers
to provide customer service to you.
– Including optimisation of the design, functionality and content of the digital services via use of analytics tools; to develop new services; and to improve the safety and security of our digital services particularly to further enhance the protection of your personal information.
– To comply with our legal obligations, which may include disclosing your personal information to third parties, courts, regulators or law enforcement agencies in connection with enquiries, legal proceedings or investigations by such parties anywhere in the world.
(e.g. limitations on number of devices and displaying the right content based on location); to detect, investigate and prevent activities on the digital services
– In the event of change of control, for example, when we are subject to negotiations for the sale of our business to a third party or undergo a re-organisation, we may need to transfer some or all personal information held by us to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analysing any proposed sale or re-organisation.
– As part of any process we undertake to connect and improve our business, including issuing business to business communications about our products and services.
6. Who do we share information with?
We share your personal information
with the parties described below:
– We share personal information with other members of the WarnerMedia Group for the purposes described in Section 5.
– We share personal information with third party service providers engaged by us to perform business-related functions on our behalf including hosting services, cloud storage services, account verification and authentication services, research and analytics, content creation, customer support services, marketing and advertising, payment, packaging, delivery, maintenance and any other services that support our digital services.
– We share personal information with third party platform operators to enable you to engage with our content or offering on or through third party platforms.
7. How do we manage international transfer of information?
We operate globally and your personal information may be transferred to and processed in the United States where many of our central databases operate, or to individual members of the WarnerMedia Group or to third parties located elsewhere around the world. The data protection and privacy regulations in the United States and those other jurisdictions may not offer the same level of protection as the jurisdiction in which you are located.
8. How do we protect information?
We have technical, administrative, and physical security measures that are designed to protect your personal information from unauthorized access, disclosure, use, and modification. Please be aware that, despite our efforts, no security measures are impenetrable.
9. How long do we keep information?
10. What rights and choices do you have?
You have the right (subject to various exceptions and in accordance with data protection legislation in your jurisdiction) to access and correct personal information
we hold about you:
- where you have given consent to our use of your personal information for marketing, you can withdraw your consent at any time. You can also ask us not to carry out profiling for direct marketing purposes. You can opt-out of receiving marketing communications by following the opt-out instructions provided to you in those communications or log into your account (if available) to update your subscription preferences.
- If you sign up to receive SMS or MMS messages, you can unsubscribe from those messages received by replying "STOP".
- Where you subscribe to our digital services on a mobile app, depending on the device you use, you may be able to manage your advertising and location preferences through your device settings and as outlined in our Cookies Policy. You can stop all collection of information by the digital service by uninstalling the mobile app.
- You also have a right to complain to a supervisory authority in charge of data protection in the jurisdiction where you live, where you work, or where you consider that a breach of data protection has occurred, although we hope that we can assist with any queries or concerns you may have about our use of your personal information.
- If you would like to exercise any of the above rights, please contact our Data Protection Officer using the contact details listed below. We may take reasonable steps to verify your identity (for example, authenticating you through your email address) and we may require further documentation such as a password and user ID before proceeding to respond to your request.
You can also exercise other controls and choices regarding our collection, use and sharing of your personal information
via these tools:
- You can choose not to receive targeted advertising although currently there is no universally accepted standard. For more information about interest-based advertising on your desktop or mobile browser, and your ability to opt out of this type of advertising by third parties that participate in self-regulatory programs, please visit the Network Advertising Initiative and/or the DAA Self-Regulatory Program for Online Behavioral Advertising. To learn more about interest-based advertising in mobile apps and to opt out of this type of advertising by third parties that participate in the DAA’s AppChoices tool, please download the version of AppChoices for your device here. Please note that any opt-out choice you exercise through these programs will apply to interest-based advertising by the third parties you select, but will still allow the collection of data for other purposes, including research, analytics, and internal operations. You may continue to receive advertising, but that advertising may be less relevant to your interests.
- You can choose to limit the collection of precise location information from your mobile device through our digital services by accessing your mobile device settings.
- You may have more options depending on your mobile device and operating system to limit or prevent the delivery of tailored in-application advertisements. You may review the support materials and/or the privacy settings for your device’s operating system to learn more about these features.
Some digital services
can only be provided if we have your personal information
, therefore please be aware that deletion of your personal information
(where requested by you) will result in termination of such digital services
The WarnerMedia Group
12. How can you contact us?
we hold about you, please contact the Data Protection Officer here:
Turner Broadcasting System Asia Pacific, Inc.
Nexus One @ One North,
1 Fusionopolis Link
#04-02/03 Singapore 138542
13. How will we make changes to this policy?