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Privacy Policy

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

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 policy of that third party. This privacy policy applies to the information that we collect from you on our digital services. Our privacy policy 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.


What information is collected?

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 example:

Information directly provided by you

  • Information you provide when you link your profile from a third party platform with your account for our digital service
  • Information you provide on public forums
  • Information you provide when you contact us with support or other queries

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
  • 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 here: apacdataprivacy.chaching@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:

  • enter into a survey, promotion or competition;
  • 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 such as WebTrends & Omniture.
  • 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://chaching.cartoonnetworkasia.com/en/cookie-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 content through social media, or other non-Turner, sites or applications, you may allow those sites to share Information with us such as content you have viewed or interacted with and about adverts within the content which you have been shown or clicked on.
  • The privacy policies for these sites and applications will contain more detail about this and how to change your privacy settings on those sites and applications.

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 policy. 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 policy.

Use of information directly provided by you

We use your information that is directly provided by you:

  • to verify your user identity;
  • 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 policy;
  • 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 (https://chaching.cartoonnetworkasia.com/en/terms-of-use) , to check for potential illegal activity and to protect our rights, and

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, personalise, 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:

  • where you direct us to share your personal information with third party platforms such as social media sites or payment systems (for example in connection with a purchase) . Note that in these instances your personal information will be subject to the privacy policy and practices of the operator of that third party platform;
  • with 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;
  • when we are fulfilling a contract or transaction authorised by you (for example a purchase transaction, package delivery, prize delivery, marketing and advertising, and customer service);
  • in connection with the merger, acquisition or sale or other similar transaction involving a Turner Group business;
  • 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:

  • 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 find the tools to make these changes here:

  • You can choose not to receive targeted advertising although currently there is no universally accepted standard. Visit https://digitaladvertisingalliance.org/ for further information on targeted advertising and http://optout.aboutads.info/?c=2&lang=EN to learn more about the settings on your browser that can prevent targeted advertising.
  • Where you have given consent to our using 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 email newsletters and other marketing communications by following the opt-out instructions provided to you in those emails. If you sign up to receive SMS or MMS messages, you can unsubscribe from those messages received by replying "STOP".

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 policy unless a longer retention period is required or permitted by law:

  • If you contact us with support queries, we keep the data for 36 months from the date of query.
  • Where we process personal information for digital service security purposes, we retain it 36 months from the log date.
  • 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.
  • 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 policy, our privacy practices or the personal information we hold about you please contact

Email: apacdataprivacy.chaching@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

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. Our Data Protection Officer can be contacted with any such queries or concerns about our use of our information at the contact details listed below.

E-mail Administration
Turner Broadcasting System Asia Pacific Inc.
Attention: Data Controller
23rd Floor, 41 Heung Yip Road, Wong Chuk Hang, Hong Kong
email: apacdataprivacy.chaching@turner.com


Changes to this policy

We will notify you about material changes to our privacy policy either by sending an email to the last email address you provided us, by prominently posting a notice on our digital service or by any other means consistent with applicable laws.


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.

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.

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.

P

  • 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.

Prudence Foundation is the community investment arm of Prudential Corporation Asia. Prudential Corporation Asia is a business unit of Prudential plc of the United Kingdom. Neither Prudential Corporation Asia nor Prudential plc are affiliated in any manner with Prudential Financial, Inc., a company whose principal place of business is in the United States of America. In Taiwan and Korea, Prudential Corporation Asia trades under the PCA name for its insurance business. Its asset management business in Asia operates under the name Eastspring Investments.

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