This app is a digital product published and operated by Turner Broadcasting System Asia Pacific, Inc.(“Turner”, “we” or “us”). This privacy policy (“Privacy Policy”) explains our information practices and the choices you can make about the way your information is collected and used by this digital service (the "Service"). We refer to your personal data as "Information".
The Policy is broken down into the following sections.
1. WHO IS RESPONSIBLE FOR YOUR INFORMATION
2. THE INFORMATION WE COLLECT
3. HOW WE USE YOUR INFORMATION
4. INFORMATION SHARING AND DISCLOSURE
5. SDKs AND SIMILARTECHNOLOGIES
6. OTHER IMPORTANT INFORMATION ABOUT YOUR PRIVACY
7. YOUR RIGHTS
8. HOW TO CONTACT US
9. UPDATES & EFFECTIVE DATE
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1. WHO IS RESPONSIBLE FOR YOUR INFORMATION
Turner Broadcasting System Asia Pacific, Inc. is the data
controller with relation to the any Information collected by the Service and
through your interaction with the Service.
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2. THE INFORMATION WE COLLECT
We receive both Information that is directly provided to us, such
as personal information you provide when you participate in an activity on the
Service, and information that is passively or automatically collected from you,
such as usage information collected each time you access the service on a
mobile device.
Information You Provide To Us.
In order to participate in an activity on the Service such as a
competition, game or other similar activity, you may be required to provide
some contact information such as name and email address and other Information
such as a photograph or a video, depending on the specific activity.
Additional details about the collecting and processing will be provided at the
point of collection and by the specific terms for participating in that
activity.
Information That is Passively or Automatically Collected.
We also receive Information when
you visit the Service that is automatically collected from your device such as
the sections you visit, buttons you tap, IP address, device ID (or equivalent),
the name of your Internet service provider, and the type of device and
operating system you are using.
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3. HOW WE USE YOUR INFORMATION
We use your Information for the following purposes:
3.1. To fulfil a contract, or take steps linked to a contract:
(a) to provide the Service and to communicate with you about your account with
us where we offer registration;
(b) to send you information about changes to our terms or policies;
(c) to allow you to take part in any competitions that we run from time to
time, administer the competition, notify you if you have won, verify your
identity, residency and other eligibility requirements, as applicable, deliver
the prize and respond to any query you may have around the competition;
(d) to allow you to submit End User Content (as defined in the Terms of Use),
and allow us to use the End User Content you submit in accordance with the
Terms of Use or other more specific terms which may apply from time to time.
3.2. Where this is necessary for purposes which are in our, or third
parties', legitimate interests:
These interests are:
(a) to fulfil your requests and inquiries regarding the Service;
(b) to provide technical support (including testing, quality assurance,
troubleshooting and security) for the Service;
(c) to analyse how the Service is used including search queries, frequency of
viewing and length of viewing time, app launches, section views and taps to
help us manage and improve the Service and to develop new services;
(d) to manage the delivery of advertising, including the number of times the
same advertisement is served and viewed;
(e) to enforce our policies and terms of use, to check for potential illegal
activity (such as copyright infringement or fraud);
(f) to run occasional surveys or market research on the Service to understand
our audience;
(g) to set reminders for particular activities, subject to preferences set by
the user; and
(h) protecting the safety of our users.
3.3. Where you give us consent:
(a) to send you newsletters about our products and services and third party
products and services and to use technologies to check if these have been
received and opened, in accordance with the additional information provided at
the point of collecting your consent;
(b) if
you are under fourteen and participate in an activity that requires consent, we
will also make reasonable efforts to obtain your parents’ permission to process
your Information. We do not knowingly collect Information from anyone under fourteen
for these types of activities without giving parents the option to consent to
their child’s personal details being included in the applicable database for
that activity.[AMT1]
During the period when parental consent is being requested, the Information
provided will be held on a temporary basis. If we do not receive your parent’s
consent we will delete the information provided by you within a reasonable
period in accordance with the specific terms which will be provided with
relation to that activity. For purposes of this Privacy Policy, any reference
to “parent” shall include legal guardian.
•
Where we do
collect personal information from children under the age of fourteen we take
the following steps:
•
Obtaining
parental consent and disclosing the types of Information we will collect from
children in connection with the specific activity, the use of that Information,
and whether and with whom we will share that Information in connection with the
activity;
•
Deleting
children’s Information after responding to a customer[TA2]
services or support service question or request;
•
Limiting our
collection of Information from children to no more than is required for that
child to participate in the activity; and
•
giving parents
access or the ability to request access to the Information we have collected
from their children and the ability to request[TA3]
that the personal information be changed or deleted.
3.4. For purposes which are required by law;
(a) in response to requests by government or law enforcement authorities
conducting an investigation.
(b) to comply with our legal obligations.
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4. INFORMATION SHARING AND DISCLOSURE
We share your Information:
(a) With service providers we have engaged to perform
business-related functions on our behalf. For example, to: (i) conduct research
and analytics; (ii) create content; (iii) provide customer support services;
(iv) conduct or support marketing; (v) fulfil orders; (vi) host Services; (vii)
provide technical or operational support; (viii) administer competitions or
other user activity; (ix) maintain databases; and (x) otherwise support the
Service;
(b) In response to legal process, for example, in response to a
court order or a subpoena, a law enforcement or government agency's request;
(c) With third parties if this will help us to enforce our
policies and terms of use, to investigate, prevent take action regarding
potential illegal activity (such as copyright infringement or fraud) or to
protect the safety of other users of the Services; or
(d) If we, or one of our business units, undergoes a business
transition, like a merger, acquisition by another company, or sale of all or
part of our assets.
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5. SDKs AND SIMILARTECHNOLOGIES.
We use SDKs (Software Development Kits) developed by third party
companies, and other similar technologies, to help provide the Service and to
analyse how you use our Service and to deliver advertising. We also allow
authorised third parties to use these technologies for similar purposes.
In short, SDKs used on the service provide audience
research/analytics, deliver adverts and measure the delivery of our advertising
campaigns
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6. OTHER IMPORTANT INFORMATION ABOUT YOUR
PRIVACY
6.1. International Transfer
From time to time we may need to allow our service providers or
assistance providers, who may be located outside your country of residence,
access to your Information. We may also make other disclosures of your personal
data overseas, for example if we receive a legal or regulatory request from a
foreign law enforcement body.
We will always take steps to ensure that any international
transfer of information is carefully managed to protect your rights and
interests:
(a) we will only transfer your personal data to countries which
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;
(b) 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.. We have entered
into standard data protection clauses with our US affiliate Turner Broadcasting
System, Inc, which provides support, security, infrastructure, maintenance
services.
(c) any requests for information we receive from law enforcement
or regulators will be carefully checked before personal data is disclosed.
You have the right to ask us for more information about the
safeguards we have put in place as mentioned above. Contact us as set out below
if you would like further information.
6.2. Retention of Your Information
We will retain your personal data for as long as is reasonably
necessary for the purposes listed in Section 3 of this Privacy Policy. In some
circumstances we may retain your personal data for longer periods of time, for
instance where we are required to do so in accordance with legal, regulatory,
tax or accounting requirements.
Where we offer
registration, we keep details of users who have registered with us for as long
as you use the Service and your user account details for up to 18 months
afterwards. We delete user profile information provided to us for the Service
automatically when the registration for the Service is cancelled.[AMT4]
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.[AMT5]
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 marketing we will keep your Information for a short
period after this (to allow us to implement your requests).
Where we process
Information for a competition, we keep the data for 12 months form the day the
competition ends unless a longer period is required by law.[AMT6]
Where we process Information with relation to the submission of
End User Content, we will keep the data for as long as necessary in accordance
with the specific terms of the activity.
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7. YOUR RIGHTS
You have a number of rights in relation to your personal data.
More information about each of these rights is set out below.
You have the right to ask us for a copy of your Information, to
correct or delete your Information.
In the case of free apps that can be exercised by simply by
uninstalling the app from your device and anu data processing will be stopped
automatically. The third party app stores may keep a record that you have
previously installed the app and if you require to clear that data you will
need to address that with app store account provider
These rights to stop the active processing of data may be limited,
for example if fulfilling your request would reveal Information about another
person, or if you ask us to delete Information which we are required by law to
keep or have compelling legitimate interests in keeping.
You can also withdraw your consent in respect of any processing of
personal data which is based upon a consent which you have previously provided.
You can also opt out of receiving email newsletters and other marketing
communications by following the opt-out instructions provided to you in those
emails.
To exercise any of these rights, you can get in touch with our
Privacy Office using the details set out below in Section 9. Please include
your registration information, where we offer registration, such as first name,
last name and e-mail address in the request. We may ask you to provide
additional information for identity verification purposes. You also have a
right to complain to a supervisory authority for data protection in the country
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 Information.
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8. HOW TO CONTACT US
The primary point of contact for all issues arising from this
Privacy Policy, including requests to exercise data subject rights, is our
privacy office. The privacy office can be contacted in the following
ways:
Privacy Office
Turner Broadcasting System Asia Pacific, Inc.
23rd Floor 41 Heung Yip Road
Wong Chuk Hang
Hong Kong
Telephone: +852 3128 3333
Email: privacyasiapac@turner.com
If you have a complaint or concern about how we use your personal
data, please contact us in the first instance and we will attempt to resolve
the issue as soon as possible. You also have a right to lodge a complaint with
your national data protection supervisory authority at any time.
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9. UPDATES & EFFECTIVE DATE
From time to time, we may update this policy. We will notify you
about material changes by either sending an email message to the email address
you most recently provided to us or by prominently posting a notice on our
Service. We encourage you to periodically check back and review this policy so
that you know what Information we collect, how we use it, and with whom we
share it.
The policy posted on this Service was updated on 11th October, 2018.