Last updated: 12 February 2015
We are committed to providing fun, safe and secure Sites and Apps for people of all ages. We are dedicated to safeguarding all personal information we collect online and to helping our visitors learn how to exercise control over personal information while exploring the Internet.
You do not have to provide us with your personal information. However, if you do not provide us with the information we require, we may not provide you with some of our products or services.
1. The Information We Collect, how we collect it and why
At Turner, we do not collect personally identifiable information on our Sites unless our visitors voluntarily provide it to us when you visit our Sites, including when you participate in activities on our Sites like contests, informational and promotional offers, and when you provide information to our customer service representatives.
(a) Sweepstakes and competitions
For activities such as entering contests and sweepstakes, we may ask visitors to provide a first name and e-mail address. We do not continue to retain or use any personal information we obtain through a contest or sweepstakes after we have successfully selected a winner(s), awarded the prize(s), and administered the contest or sweepstakes, except to the extent it is necessary to keep winner’s details for record keeping purposes.
(b) Customer service and improving our Sites and products
In order to provide appropriate customer service support for some features of our Sites or to improve our Sites or products, we may ask visitors to provide a first name, email address and limited information that is relevant to a customer service inquiry.
(c) Specific one time requests
For specific one-time requests we receive from visitors on Sites, e-mail addresses are collected and used only in connection with the specific one-time request. For example, for sweepstakes and contests, e-mail addresses are collected for the purpose of entering the online sweepstakes or contest on a one-time basis and are used to notify winners of the sweepstakes or contest once by e-mail.
(d) Non-personally identifiable information
When visitors come to our Sites, we also may collect some non-personally identifiable information such as the current Internet protocol address and the type of computer operating system you are using (e.g., Microsoft Windows or Mac OS), the type of browser you are using (e.g., Firefox, Internet Explorer), the domain name of the Internet service provider (e.g., America Online, Earthlink), your activities while visiting our Site, your activities while playing games or utilizing services on our Sites (e.g., which of our Web pages you viewed or which games you played), and the advertisements you have been shown.
Our Apps generally include features, functionality and informational content. We do not knowingly collect personally identifiable information from children under the age of 14 in our Apps. The data collected in an App may vary by App but will include any information a user provides once the user downloads and uses the App. For example, some of our Apps may require you to first register and create an account with us (e.g. user name, password, or email address) before you can use it. Other Apps may require additional information from you, such as transaction-related information (e.g. when you make purchases, respond to any offers). We may also use information you provide us to reach you when you contact us for help. If you interact with third-party social media sites and applications, we may have access to certain information from your social media account such as your user name, profile picture, information about friends and followers, and content posted or viewed through the social media. When you use social media networking platforms and plugins, you share your information with them and their use of your information will be subject to that social media site’s privacy practices. To help improve the design, functionality, performance and content of our Apps, we usually collect certain information when you use the App on your mobile device, such as usage, viewing and technical data including the type of mobile device you use, your unique device ID, your device’s IP address, your mobile operator and operating system, the type of mobile Internet browsers you use, and information about the way you use the App. Our Apps usually do not collect precise information about the location of your mobile device and only would do so if you are specifically prompted to provide your consent to do so. You can always manage your location preferences at any time by adjusting the settings on your device.
2. How we disclose the information we collect
The personal information you provide to use may be shared, if appropriate, with any of our related entities, affiliates, agents and third parties who provide services on our behalf. These include:
Any of the companies within our group and our other subsidiaries, affiliates and associated companies around the world.
Our agents or contractors to provide services on our behalf, such as helping us conduct a sweepstakes, sending prizes to winners, shipping customer orders made on the Sites, processing payments, or providing customer service related to activities on the Sites. In these cases, we require our agents and contractors to keep the personal information we provide to them confidential and to use it only for the specific services they are performing for us.
Our third party information technology, infrastructure and operations service providers (e.g. cloud storage providers), consultants and advisers.
If we or one of our business units are acquired by, sold to, or merged with another entity, to that entity and their advisers.
Any other entities notified to you at the time we collect your personal information.
We will not use or disclose personally identifiable information in ways that are materially different from the ones described above without notifying you and, if required, obtaining your consent.
3. Cookies and Web Beacons
“Web beacons” or clear .gifs or similar technologies are small pieces of code placed on a web page to monitor the behavior and collect data about the visitors viewing a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page. We, our third party service providers and/or our partners may use web beacons on our Sites or Apps from time to time for this and other purposes.
4. Collection of Information by Third-Party Sites, Ad Servers and Sponsors
5. International Transfer
Turner operates globally so it may be necessary to transfer any information provided to these Sites or Apps internationally. In particular, the information provided will likely be disclosed to, processed, stored and maintained by our affiliates or third party partners in Hong Kong, Singapore, the United States and the United Kingdom where many of our central databases and third party partners operate. The data protection and other laws of other countries may not be as comprehensive as those in your country.
We have put in place reasonable physical and electronic security measures and managerial procedures in an effort to safeguard the personal information we hold and help protect your personal information from misuse, interference and loss and from unauthorized access, modification or disclosure.
We are particularly sensitive to visitors’ security concerns regarding the use of credit cards to purchase products over the Internet. For orders placed on our Sites, we use a technology that automatically encrypts credit card data while information is being transmitted over the Internet, provided that the visitor’s browser supports the Secure Socket Layer protocol (SSL).
To verify the security of your connection at our Sites, check the lower left corner of your browser window after accessing the server. If you see an unbroken or a closed lock, then SSL is active and the server is secure. You may also check by looking at the URL line of your browser. When accessing a secure server, the site address will change from http to https.
Despite the steps we have taken, data protection and security measures are never completely secure and we cannot guarantee the security of your personal information. You must take care to protect your personal information (for example, by protecting any usernames and passwords) and notify us as soon as possible if you become aware of any security breaches.
7. Access and Choice
For information collected on our Sites or Apps, visitors can send an email or letter to our Turner Privacy Officer via the contact details provided below to:
access personally identifiable information that a Site or App has collected online from you,
update or correct errors in such information,
request to have this information deleted, or
request that we no longer collect or maintain such information.
Please be sure to include your e-mail address and a telephone number where we can reach you. To protect our visitors’ privacy and security, we will take reasonable steps to verify your identity before granting you access, making corrections or deletions to the personal information that we collect and maintain about you.
For information collected on our Apps, you can stop all collection of information by the App easily by uninstalling it from your device. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. If you would like to opt out and stop receiving marketing communications from us, you may follow the “unsubscribe” instructions provided in any marketing email or for mobile device push notifications, you can manage your preferences either through your device or App settings depending on the type of device. If you’d like us to correct, update your information, or help you opt out from our marketing communications and/or delete user provided data that you have provided via the App, please contact us at the email address below and we will respond in a reasonable time. Please note that some or all of the user-provided data may be required in order for an App to function properly, and we may be required to retain certain information by law.
8. How to make a complaint
We will refer your complaint to our Turner Privacy Officer who will investigate the issue and determine the steps that we will undertake to resolve your complaint. We will contact you if we require any additional information from you and will notify you in writing of the outcome of the investigation. If you are not satisfied with our determination, you can contact us to discuss your concerns or contact to the privacy regulator in your jurisdiction.
9. Contact Us
Mailing Address: Turner Privacy Officer
Turner Broadcasting System Asia Pacific, Inc.
34/F Oxford House, Taikoo Place, 979 King’s Road,
Quarry Bay, Hong Kong
Telephone: 3128 3333
10. Updates and Effective Date