Privacy Policy

Thank you for your interest in a digital service owned and/or operated by Turner Broadcasting System Asia Pacific, Inc, a part of the WarnerMedia Group.

1. Scope


This privacy policy explains how WarnerMedia will treat information including personal information, provided or collected on the digital services where this privacy policy is displayed and the choices you can make about the way your personal information is used.

Terms in bold are defined in Section 14 “Definitions” of this privacy policy.

The responsibility for this privacy policy, and ensuring that your personal information 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. References in this privacy policy to WarnerMedia Entity 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), the information you provide may also be collected by the third party and may be subject to the privacy policy of that third party. This privacy policy applies to the information that we collect from you on our digital services and may differ from the privacy policy of that third party. The choices you make on the 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: (open to a new window)

Appendix 1 - Australia
Appendix 3 - Hong Kong
Appendix 4 - India
Appendix 5 - Indonesia
Appendix 6 - Japan
Appendix 7 - Malaysia
Appendix 8 - New Zealand
Appendix 9 - Philippines
Appendix 10 -Singapore
Appendix 11 -South Korea
Appendix 12 - Taiwan
Appendix 14 -Vietnam

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 post or share on public forums or publicly accessible portions of a digital service, such as photos, letters, videos, comments, emojis or ‘canned responses’ while participating in digital services we operate, or when you interact with us through our digital services via third party platforms. Depending on your privacy settings, such information (including your username) can become public on the Internet or within a community of users. We cannot prevent further use of this information once it is made public. For information about how you can customise your privacy settings on third party platforms, and how those third party platforms handle your personal information and content, please refer to their privacy help guides, privacy policies and terms of use. Please be mindful of all personal information that you may wish to post
- 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 informationabout 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 in accordance with this privacy policy.

Information about others
We also collect personal information about others from you, as we have described in Section 2(f) above. If you provide us with personal information about others, you confirm that you have obtained their consent to their personal information being provided to the relevant WarnerMedia Entity for the purposes set out in this privacy policy.

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 email address.

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 consistent with the rest of this privacy policy and/or the terms of the consent provided by the parent. If a user is under 16, 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 here:


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, we provide a child-friendly privacy policy, so that children can easily understand how we process their personal information. We will make it clear which privacy policy applies in relation to each online service. The child-friendly privacy policy is designed to be read together with this privacy policy and its appendices.
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 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, Terms of Use, and/or this privacy policy; to provide technical support (including testing, quality assurance, troubleshooting and security) for 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.
- For legal purposes, such as to enforce our policies and Terms of Use (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 that may violate the Terms of Use, or copyright; could be fraudulent, or otherwise illegal; and to protect our rights and the rights and safety of our users and others.
- 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.
- We share personal information with the relevant third party in connection with the merger, acquisition or sale, or as part of a bankruptcy proceeding, of all or part of a WarnerMedia Group business. We may also share your personal information with that re-organised entity or third party after the sale or reorganisation for them to use for the same purposes as are set out in this privacy policy.
- We share personal information in order to comply with our legal obligations, for example in response to a court order or a subpoena, or in response to a law enforcement body's request. We also share personal information with third parties: (i) in connection with fraud prevention activities, (ii) where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, (iii) in situations that can involve violations of our Terms of Use or other rules, (iv) to protect our rights and the rights and safety of others, and (v) if we believe in good faith that disclosure is required by law.
We share personal information with third parties such as advertising networks and platforms, magazine publishers, analytics providers, database, retailers, participatory databases and non-profit organisations, so they can market and otherwise communicate with you about their own products and services. If we share personal information with third parties for advertising purposes, we provide you with an opportunity to opt-out of such uses either at the point of collection or through the choice mechanisms available in this privacy policy.

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?


In broad terms, we will only retain your personal information for as long as is necessary for the purposes described in this privacy policy. This means that the retention periods will vary according to the type of personal information and the reason that we have received the personal information in the first place. For example, some personal information related to the provision of digital services to you or by you will be kept for a number of years in order to comply with various finance and tax related legal obligations. Other service related personal information may be kept for a different period because it is in our legitimate interests to do so in order to provide or receive appropriate follow up service.


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:

  • Managing your account or updating your password
  • Manage your child’s registration account

  • 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.


11. How do we use cookies?


The WarnerMedia Group uses cookies to enhance your online experience with our digital services. For detailed information on how we use cookies, please see our Cookies Policy


12. How can you contact us?


If you have questions about this privacy policy, our privacy practices or the personal information 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
apacdataprivacy.chaching@turner.com


13. How will we make changes to this policy?


From time to time, we may update this privacy policy. We will notify you about changes to this privacy policy by placing a notice on our digital services or, if required by law, by contacting you to obtain your consent to the changes. We encourage you to review this policy periodically so that you always know our current privacy practices.


14. Definitions

A

  • aggregate information

    is a compilation of statistical information from which from which it is not possible to identify an individual by any reasonable means.

  • anonymous information

    is information that does not allow identification of the individuals to whom it relates and from which it is not possible to identify an individual by any reasonable means.

  • child / children

    the legal meaning of a child differs across jurisdictions. We generally treat users who are less than 16 years old as children for the purpose of this privacy policy, although in some jurisdictions the legal meaning of a child can be lower or higher than 16 years old. Any differences are set out in the relevant Appendix to this privacy policy.

C

  • child / children

    the legal meaning of a child differs across jurisdictions. We generally treat users who are less than 16 years old as children for the purpose of this privacy policy, although in some jurisdictions the legal meaning of a child can be lower or higher than 16 years old. Any differences are set out in the relevant Appendix to this privacy policy.

D

  • data controller

    is the subsidiary or affiliate of the Turner Group that is responsible for directing and instructing the collection, use and means of processing personal information from our digital service in accordance with the scope of this privacy policy

  • data processor

    is the subsidiary or affiliate of the Turner Group or a third party, as applicable, that is responsible for processing personal information on behalf of the data controller(s) and only as directed and instructed by the data controller(s).

  • digital services

    means sites, applications or other online services of Turner, Turner Group or a third party.

O

  • online service

    means a digital service directed at children as set out in the Addendum to this policy

P

  • parent

    means lawful parent or guardian.

  • personal information

    means information relating to an individual who can be identified (directly or indirectly) and includes an individual’s name, email address, postal address, phone number, device identification number, location data, online identifier and may include anonymised information that is capable of being used to identify (directly or indirectly) an individual.

  • public forum

    means those online sites and platforms that are accessible by any member of the public such as message boards, chat rooms, profile pages, social media and other public online forums including those that may be accessible via a link on our digital service.

  • push notifications

    means those notifications on mobile and other devices that are typically associated with downloaded applications, and which can communicate to the device holder even when the application is not open or in use.

S

  • service providers

    means third party service providers engaged by WarnerMedia Group to perform business-related functions on its 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 the digital services.

T

  • third party platform

    means any third party social media platform, third party app store (such as the Apple App Store, Google Play Store), or third party operator of an online site, app or platform

  • Turner

    means Turner Broadcasting System Asia Pacific, Inc. (our, Turner, us or we) a member of the Turner Group. Turner is the Data Controller for the digital service.

  • Turner Group

    means Turner Broadcasting System Asia Pacific, Inc. and its subsidiaries, affiliates and associated companies in the Asia Pacific region.

W

  • WarnerMedia

    means each member of the WarnerMedia Group. Please see the Addendum for the list of data controllers who own and/or operate the respective digital service.

  • WarnerMedia Group

    means WarnerMedia, LLC and its holding companies, subsidiaries, affiliates and associated companies in the Asia Pacific region (each a WarnerMedia Entity)

  • We / us / our

    means the owner and /or operator of the digital services stated in Section 1 of this privacy policy.

Brought to you by:
In partnership with: