隱私政策

Scope

This privacy notice explains how Turner will treat information including personal information, provided or collected on the digital service where this privacy notice is displayed and the choices you can make about the way your personal information is used. A reference to 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.

Turner is the data controller for your information. Turner means Turner Broadcasting System Asia Pacific, Inc. (our, Turner, us or we) a member of the Turner Group. Turner Group means Turner Broadcasting System Asia Pacific, Inc. and its subsidiaries, affiliates and associated companies in the Asia Pacific region.

If you provide information to us via a third-party (for example on one of our mobile game applications on a third party platform), the information you provide may also be collected by the third-party and may be subject to the privacy notice of that third party. 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

This privacy notice applies to the information that we collect from you on our digital services. A reference to digital services means sites, applications or other online services of Turner, Turner Group or a third party.

Our privacy notice may differ from the privacy notice 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.

What information is collected and why?

We collect personal information that is directly provided by you to us and anonymous information that is indirectly provided by you through use of our digital service. We may use personal information and anonymous information to create aggregate information for each of the purposes listed below:

Information directly provided by you

  • Registration information you provide to obtain a digital service account or to access another service (including newsletters, subscriptions to other services provided by the Turner Group)
  • Registration information you provide to enter into a survey or competition
  • Information you provide when you link your profile from a third party platform with your account for our digital service
  • Information you provide when you make a purchase of a product or service through our digital service (eg payment and other information)
  • Information you provide on public forums.
  • Information you provide when you contact us with support or other queries
  • Information you provide in connection with marketing and promotional campaigns run by us. Where we process information for marketing purposes, we process the information while you remain interested in the marketing (for example, where you open and read our offers) and for three years after that point. If you ask us to stop sending you marketing we will keep your personal information for a short period after this (to allow us to implement your requests).

Information indirectly provided by you

  • information from a third party (for example a mobile services provider), about use of our digital services on that third party’s platform or device
  • Information regarding location provided by a mobile or other device interacting with one of our digital services, or associated with your IP address, where we are permitted by law to process this information
  • information about your use, and the use by any person(s) you authorize through your account, of digital services (for example, content viewed or posted, frequency of use and preferences); and
  • technical, and device information when you visit our digital services including via third party platforms, including your browser or device type, unique device identifier, and IP address
  • You can ask us to stop processing this Information by contacting us here: apacdataprivacy.safestepskids@turner.com

How is information collected?

Direct collection of information

We directly collect information you provide when you interact with us via one or more devices to:

  • register for a digital service account or to access another service (including marketing updates, newsletters and subscriptions to other services provided by the Turner Group);
  • enter into a survey, promotion or competition;
  • link your account for our digital service to your profile from a third party platform;
  • purchase a product or service through our digital service;
  • post on a public forum connected to or integrated with our digital service, and
  • contact us with support or other queries.

Indirect collection of information

  • We automatically receive and collect information from your device or browser through use of information tracking technologies (eg. cookies, Flash cookies, pixels, tags, software development kits, application program interfaces, and Web beacons) and analytics tools.
  • We commence collection of information when you visit our digital service or use our digital service on a third party platform using one or more devices and regardless of whether you have logged in or registered.
  • For more details please visit https://www.safestepskids.com/privacy-policy.
  • We acquire information from third parties to update or supplement the information you provided or we collected automatically, such as when we validate postal address information using third party fulfilment services. Applicable law may require that you authorize the third party to share your information with us before we can acquire it.
  • When you engage with our digital services through social media or other third party platform, those third party platforms will share information:
    • about the content you have viewed or interacted with (eg. your game performance and high scores)
    • about adverts within the content on our digital service which you have been shown or clicked on; and
    • in your profile - for example, your name, e-mail address, gender, birthday, location, user ID, photos and videos, your list of friends or connections, people you follow and/or who follow you, or your posts or "likes".
    • The third party platforms will have their own privacy policies. 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.

How do we use children’s information?

  • We do not knowingly collect personal information from children under the age of 13.
  • If we collect and use personal information from children on our digital services for the different types of purposes listed, we will use reasonable efforts to notify parents and obtain appropriate consent prior to such collection and use. A reference to parent means a lawful parent or guardian of the child or children.

How does the Turner Group use information?

Turner is the member of the Turner Group that is the data controller for your information obtained through this digital service in accordance with this privacy notice. Other members of the Turner Group may have access to your information if they provide services as a data processor for Turner or possibly for use on their own behalf, where permitted under applicable laws, for the purposes set out in this notice.

Use of information directly provided by you

We use your information that is directly provided by you:

  • where you have registered for a digital service account or registered for another service (eg newsletter or subscription to another service provided by the Turner Group), process your registration and to communicate with you about the digital service or the other service for which you have registered and/or the related account;
  • to verify your user identity;
  • to obtain feedback about transactions on our digital service or your account;
  • to send you offers and promotions for our products and services or third-party products and services by email or other sites or apps or social media, which may be personalised based on your visits to and use of the digital services and to check if these adverts have been received and if they were of interest to you, where you have registered or consented to receive such communications;
  • to provide you with the experiences, products, and services (including digital services) you request, view, engage with, or purchase;
  • to update you about changes to our digital service, its terms and conditions of use, and/or this privacy notice;
  • where you enter into a survey, promotion or competition, to administer that activity, notify you if you have won, verify your identity, residency and other eligibility requirements, deliver the prize and respond to any query regarding the activity;
  • to allow you to submit a post or other content to our digital service or a public forum;
  • to respond to requests and inquiries regarding the digital service, your account or a related matter;
  • to provide technical support (including testing, quality assurance, troubleshooting and security) for our digital service;
  • to comply with our legal obligations (including responding to requests by government or law enforcement authorities);
  • to analyse how you use the digital services, including which video content you like to watch and to help us develop new services;
  • to enforce our policies and Terms of Use, to check for potential illegal activity and to protect our rights, and
  • to help complete or fulfil a transaction, such as your purchase of a product or service on our digital service.

Use of information indirectly provided by you

We use your information that is indirectly provided by you:

  • to analyse how our digital service is used including search queries, frequency and length of viewing and length of viewing time, page views and clicks to help us manage and improve our digital service and to develop new services;
  • to manage the delivery of advertising (eg. number of times an advertisement is served and viewed on our digital service);
  • operate, optimize or improve our digital services, services, products and operations, including by using analytics tools;
  • to enforce our policies and Terms of Use, to check for potential illegal activity;
  • to improve the safety and security of our digital services to further enhance the protection your information,
  • where you have subscribed for digital services or otherwise consented to receiving communications from us, to check if these have been received and opened

Do we share your information?

We share your personal information outside the Turner Group:

  • with our business partner including Prudence Foundation Limited , service providers engaged by us to perform business-related functions on our behalf including host services, research and analytics, content creation, provision of customer support services, conduct or support marketing, maintain databases and otherwise support our digital services;
  • to enforce our Terms of Use;
  • to ensure the safety and security of digital service and third party platforms;
  • to protect our rights, and property;
  • advertising networks and platforms, magazine publishers, database, retailers, participatory databases and non-profit organisations, and
  • and the rights and property of our guests and third parties, to comply with legal process, or in other cases if we believe in good faith that disclosure is required by law.

Global transfer and processing of information

Turner Group operates globally. Your information will be transferred to and processed in the United States where many of our central databases operate. We transfer personal information to individual members of the Turner Group or to third parties located around the world:

  • to allow our service providers access to your Information to assist us with repairs or maintenance of our digital services
  • if we receive a legal or regulatory request from a foreign law enforcement body

We will take reasonable steps to safeguard the transfer of your personal information:

  • we will only transfer your personal information to countries that are recognised as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights;
  • transfers to our service providers and other third parties will always be protected by contractual commitments and where appropriate further assurances, such as standard data protection clauses and certification schemes, and
  • any requests for information we receive from law enforcement or regulators will be carefully checked before personal information is disclosed.

Access and Choice

You can exercise certain controls and choices regarding our collection, use and sharing of your personal information:

  • Correct, update, and delete your account for our digital service;
  • Select or change your subscriptions, newsletters, and alerts or communication preferences (eg marketing and promotions for our products and services);
  • Requesting removal of your personal information from a public forum on one of our digital services;
  • Requesting access to the personal information we hold about you, and
  • Requesting that we amend or delete personal information we hold about you.

You can contact us here to make these changes here: apacdataprivacy.safestepskids@turner.com

Security and Retention

We have technical, administrative, and physical security measures that are designed to protect your information from unauthorized access, disclosure, use, and modification. Please be aware that, despite our efforts, no security measures are impenetrable.

We will retain your personal information for the length of time needed to fulfil the purposes outlined in this privacy notice unless a longer retention period is required or permitted by law:

  • If you contact us with support queries, we keep the data for between 3 and 18 months, depending on the nature of the query and whether you have registered with us for a digital service.
  • Where we process personal information for digital service security purposes, we retain it for 6 months.
  • Where we process personal information for a competition, poll or survey, we keep the data for between 1 and 3 months from the day the activity is specified to end unless a longer period is required by law.
  • Where we process personal information for a payment transaction related to a purchase, we retain it for 13 months after the date of payment.
  • Where we process personal information in relation to the submission of end user content on our digital services, we will keep the data for as long as necessary in accordance with the specific terms of the activity.
  • Where you register for an account with us, we will keep your personal information for as long as you use the digital service and your user account details for up to 18 months after cancellation of your account. We delete user profile information provided to us for the digital service automatically when the registration for that digital service is cancelled.
  • We also keep a record of the fact that you have asked us not to send you direct marketing or to process your Information indefinitely so that we can respect your request in the future.
  • Our cookies and other tracking technologies expire 13 months from the date after you give or renew consent for us to use these technologies.

Contact Us

If you have questions about this privacy notice, our privacy practices or the personal information we hold about you please contact:

Email: apacdataprivacy.safestepskids@turner.com

Mailing Address: Turner Privacy Officer

Turner Broadcasting System Asia Pacific, Inc.
23rd Floor 41 Heung Yip Road
Wong Chung Hang,
Hong Kong

Telephone: 3128 3333

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