Children's Privacy Policy

HOW WE USE YOUR INFORMATION


Date Updated: [June 2020]

We are a group of companies called WarnerMedia. We provide entertainment services that include "Online Services." These are:

  • our website and website games
  • our mobile phone apps
  • our console apps

When you use some of our Online Services, we collect a small amount of information about you

This is a “Privacy Policy.” It will tell you why we collect your information and what we do with it.

If you need help understanding this document, you should ask the adult who looks after you to read it and talk with you about it.


This children’s privacy policy provides a simplified explanation of how we process personal data on our Online Services directed at children. It is designed to be read together with our general audience WarnerMedia Group policy. If you are an adult and want to understand more about how we collect and use personal data, or how we process personal data on our wider offering of digital services, you should take a look at the WarnerMedia Group policy

WHAT INFORMATION DO WE COLLECT ABOUT YOU?

Information about you
The information we collect about you (and what we do with it) depends on which features of our Online Services you use and how you use them. Click the feature below to find out more.


Generally, you don’t need to provide us with any information about you for you just to visit our Online Services, other than a bit of information about how you use your computer or console called “cookies,” which helps our service run properly and tells us about how people are using our website.

You can find out about cookies here.

Sometimes, certain features on our Online Services will require us to collect more information about you. We have listed these below and you can click on each feature to find out more about how we use your information in relation to it.
Generally, you don’t need to provide us with any information about you for you to use our mobile app, other than a code that helps us identify your phone. This code doesn’t allow us to see who you are. It just lets us know that it is the same phone using the app. This is so the mobile app can remember what you’ve previously done (for example, your progress through a game).
Sometimes, certain features on our mobile apps require us to collect more information about you. We have listed these below and you can click on each feature to find out more about how we use your information in relation to it.
Before buying something, you should always have permission from the adult who looks after you. When you buy something in our Online Service, your adult may have to pay for it with real money. Some of our Online Services allow you to buy things inside the Online Service, pay to join our clubs, and use ‘virtual money’ from our Online Services.
Pretend money (also known as Virtual Money)
Some of our games and features use pretend money, (or currency, gems, etc.) which exist only in the game. Pretend money is earned by the player and can be used to trade for things in the game or upgrading their character. Even though this money isn’t real money you might want to check with an adult about it.
Some of our Online Services will let you ‘chat’ with your friends in a way that shows your conversation with other people on the Online Service. Canned Chat

This is the most common type of chat used on Online Services aimed at children. Canned chat means users can choose from a set menu of allowed phrases or emojis. No personal data can be shared and no one can say anything bad or nasty.
some profiles use a pseudonym, here referred to as a “nickname”.

Some of our features include virtual (pretend) worlds, where you can play games, talk with your friends or get items, such as gems, pretend money, additional costumes or powers, for an “in-game” character that you control. For these Online Services you need to create a character and then choose a “nickname” or “handle” for that character. This is a unique, made-up name used to tell your character apart from other users’ characters and to save your game progress, without you having to share your real name or any other information with us or strangers. Other people will be able to see your nickname, when you are using the feature. We will always tell you if a nickname is needed to use a particular feature.

To help protect your privacy and safety online, we recommend that your nickname does NOT include your real name, your year of birth, your age or any part of your address. Lots of people like to use a pretend name, a name of a famous character or a pet’s name.

You can visit [link] for more information regarding risks of sharing information online.
Some of our Online Services may have alerts that you can choose to receive (sometimes called “notifications”) to tell you about the features you’re using or if a new game is available, a new prize is available within a game you’re playing, one of your friends has just come online or that a new episode of a TV program you watch is now available.

Some alerts only show within the Online Service itself (e.g. if a friend gifts you a special present in a mobile game). As soon as you stop using the Online Service, you will stop getting the alerts.

Other alerts show on your computer, mobile phone or console, whenever they arrive and even when you are not using the Online Service. These are called “push notifications.” You shouldn’t turn push notifications on when you are using a computer, phone or console that isn’t yours. We may need to ask permission from the adult who looks after you to collect the information that we need to send you these push notifications.

If you change your mind about getting alerts, you can always turn them off. If you are receiving alerts within an app or a game there will be a way to switch them off under the “Settings” menu.
If you contact us by email or using an online form, we will ask you for some information. For example, this may include your first name and email address. We will also ask you to tell us why you are contacting us. Once we have helped you, we will delete your information.
Sometimes we offer competitions on our Online Services. In order to enter a competition you will need to provide a bit of information about yourself (including your first name and your email address), so that we are able to let you know if you have won and if you win, make sure you get your prize.

We will also email your parent to let them know you have entered the competition / get their permission for you to enter the competition.
Sometimes, we need to collect information about the adult who looks after you at home. For example, we do this so we can:
  • Let them know about your interest in the Online Services
  • ask them for permission so you can acess parts of our Online Services
  • tell them how to start some of the features for you
When we need to contact the adult who looks after you, we will need to get some information from them, so we may ask for their:
  • full names
  • address
  • email address
  • telephone number

Please get permission from your adult before you provide us with any information relating to them. Find out more about

HOW DO WE USE YOUR INFORMATION?


THE LEGAL BIT

In your country there are some laws to make sure that companies use information about you fairly. These laws protect you from unexpected or unwanted things being done with it. They require us to explain why we think it is fair for us to use information about you (sometimes called “personal data”).

We use your personal data for the following reasons:
We will get permission before:
  • Where we need permission (also known as “consent”) from you and/or the adult who looks after you
    Sometimes we will ask you for permission to use information about you. If you are not old enough to provide permission, we will sometimes ask the adult who looks after you for permission.
    We will get permission before:
    • using some types of cookies(see the cookies policy)
    • entering competitions; or
    • sending you newsletters and other types of marketing, where we need to get permission. We will always ask for your permission first. Marketing can include sponsorships (which may involve another party sponsoring a show). You can change your mind about marketing at any time by following the opt-out instructions provided to you in those communications or on our Online Services to update your subscription preferences. Ask your adult to help you if you need to.
  • Where we have a legitimate interest
    when using your information is:
    Important to us (for example, we can't make the feature work properly without using information about you), and
    Fair to you (it doesn't create a problem for you, annoy you or upset you),
    We have something called a "legitimate interest" in using that information.
    We rely on our legitimate interests:
    • to provide you with access to our Online Services
      • to play games
      • to chat with your friends
      • to post or send us comments
    • learn how we can make our Online Services better
    • make sure your experience can be special and personalized for you
    • keep you and others safe
    • answer your questions and comments when you contact us
    • to send you information about our Online Services (where you're an existing customer. We will stop sending you this information if you ask us to)
    • to let you know if anything about our company or our Online Services changes

  • If the law says we must use your information, then we will do so. For example:
    • if the government, a judge or the police need to investigate something; or
    • we need to keep a record of something, such as where you (or your adult) bought something with real money
    • we need to share your information to help us stop people from doing bad things or committing crimes, or to protect you or other people.

WHO WE SHARE YOUR INFORMATION WITH?



Our helpers (service providers)
Sometimes we have helpers who make sure our Online Services are great. They will help operate the Online Services or help with buying things on our Online Services, like points. They will also help with sending prizes to competition winners. We make sure that our helpers keep your information safe and they will use it in the same way as us.

Our friends (for example, co-sponsors)
Sometimes we ask our friends to help us with our Online Services. If we do, they will have access to information about you. We will always let you know when we ask our friends to help us. Sometimes, they will use information about you in the same way we do. Other times, they will provide a page like this (normally called a “privacy notice”) that tells you how they will use information about you.

Our family (the WarnerMedia group of companies)
Sometimes we may share information about you with members of our WarnerMedia family who will use it in the same way as we do. You can find a list of WarnerMedia group of companies here. We may update this list from time-to-time, so please check back periodically to keep up-to-date.

Links to other people's websites (external links)
Our Online Service will sometimes have links to other people's websites. Those people can treat your information differently from us. You should make sure you understand how they will use your information. They should provide a page like this (normally called a “privacy policy”) that tells you how they will use information about you.

If the law says we must share your information
WarnerMedia, our friends and our helpers will sometimes need to share your information with other people such as the police or the government when the law says so.

If we sell or reorganize our business
If we sell or reorganize our business, we may share your information with the company that buys our business or the company we sell it to.

If you or the adult who looks after you gives us permission
If you or the adult who looks after you gives us permission to share your information for something, then we will share your information in the way we describe at the time.

WHEN WE INVOLVE YOUR ADULT?


When we involve your adult depends on where you live.
Younger children – under 7 years old

We assume that children of this age will be using our Online Services with help from an older child or an adult. All decisions relating to children of this age will be referred to the “responsible adult.”

Children ages 7-16
We will involve your adult where:
  • your data may have been accessed by someone who shouldn't have seen it
  • you have asked us to help you with one of your “data protection rights” and we think you may need help from an adult


Older children 16-18

You can make your own decisions about your personal data. We do not need to involve an adult.
Children aged below 18.

We assume that children of this age will be using our Online Services with help from an older child or an adult. All decisions relating to children of this age will be referred to the “responsible adult.”

For example, we will involve your adult where:
  • you have requested to enable “push notifications
  • your data may have been accessed by someone who shouldn’t have seen it
  • you have asked us to help you with one of your “data protection rights” and we think you may need help from an adult
  • you have entered a competition


User ages 18 or above
You can make your own decisions about your personal data. We do not need to involve an adult.

SENDING YOUR INFORMATION AROUND THE WORLD


We have offices around the world. Sometimes, we will need to send your information to a different country. Usually, this is to the United States where WarnerMedia and our helpers will use your information in the way we have already described in this Privacy Policy.

When we send information about you to a different country, we will ensure that it is treated in the same way as we have explained on this page. If you or your adult wants more information about how do this, you can contact us.

WE WANT TO KEEP YOUR INFORMATION SAFE


  • Keeping your information secure

  • We take reasonable steps to protect your information to stop other people getting to it. This includes making sure that our computers have protection on them to stop bad people from getting access to the information held on them. You can help us by:
    • never telling anyone (other than your adult, if you need to) your password or writing it down
    • not using the same password for lots of different things
    • changing your password periodically
    • if you are using a shared computer, mobile phone or console, make sure you “log out” when you are finished using it

    Very rarely, an accident will happen (like someone accidentally sending an email) or a bad person will get access to information they shouldn’t have access to. If this happens and could possibly cause a problem for you, we will tell you (and your adult). Our message will explain what happened, why this matters to you, and what we are doing to fix it. If we cannot send you this message directly, we may make a public post about it.
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.

  • Not keeping your information for too long.

If we need your information for our own purposes, w will also keep your information for three years after you last contact our customer support team or interact with our Online Services or after you stop being subscribed or registered with us.

Sometimes the law says we have to keep your information for longer than this. We may have to keep your information for longer to protect you and us. When it’s time for us to stop keeping your information, we will burn or shred hard copies (like print-outs) and permanently delete electronic copies.

YOUR RIGHTS


You can ask us to do any of the following things with information we hold about you:

  • Stop sending me marketing
    You can ask us to stop sending marketing and advertising to you.

  • Give me a copy of the information you hold about me
    You can ask us to send you all or some of the information we hold about you. It will generally take us a month to do this (but it can take up to 3 months if it is difficult to gather all the information together).

  • The information you hold about me is wrong. Please correct it
    If the information we have about you is wrong or has changed, you can let us know so we can try to fix it.

  • I don’t want you to have my information any more. Please delete it
    You can ask us to delete information about you. This may mean that you can’t use some features of our Online Services (because some of them only work if we have some information about you). If the information has been made public, we may not be able to delete it.

  • I don’t want you to do something with my personal data any more. Please stop it.
    For example, where:
    • you previously gave us permission (consent) to do something with your information, and you have changed your mind. For example, if you previously consented to marketing or ”extra cookies”. Cookies are described in more detail in our Cookies Policy
    • we are doing something with your information that you do not like and we are relying on our “legitimate interests
    • you want us to stop using your data for now whilst we deal with a question, complaint or problem.
      We will consider your query and let us know whether we can stop using your information or not.
  • Give me a copy of the information I have given you, so that I can share it with another companyHave a copy of the information you have given us sent to a different company in a way that the different company is able to put it on its computers.
  • I want to complain
    You can complain to us by contacting us.
    You’re also able to complain to the person responsible for protecting your privacy rights in your country. You can find out how to contact them [here].
To do this, visit [name of portal]
Depending on where you live, you may be able to ask us to do these things because the law says so – it is a legal right you have. However, we are not always able to do what you’ve asked us. Where we can’t, we will reply to you (or your adult) to say why not.
We want you to feel in control of how we use your personal data as far as possible. If you have any queries relating to your rights or exercise of your rights, please contact us.

CONTACT US


Turner Broadcasting System Asia Pacific, Inc.
Nexus One @ One North,
1 Fusionopolis Link
#04-02/03 Singapore 138542
apacdataprivacy.chaching@turner.com

UPDATES


From time to time, we may update this Privacy Policy.. We will let you know about any big changes to how we use your information by putting a sign on our Online Service or by sending the adult who looks after you an email message. We think it is a good idea for you to come back to this page once in a while to learn about how we protect your information.

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