Privacy Policy
PLAYDEMIC PRIVACY POLICY
Last updated 1 July 2020
Scope of this Privacy Policy
Please read this Privacy Policy carefully to understand our policies and practices regarding your Information (as defined below) and how we will treat it.
This Privacy Policy explains how your Information is collected, used, and disclosed by Warner Bros. entities as listed in the controllers & contact section ("we" or "us"). It also tells you how you can access and update your Information and make certain choices about how your Information is used.
This Privacy Policy covers both our online and offline data collection activities, including information that we collect through our various channels such as websites, apps, console games, third party social networks, customer care centres, studios, attractions/exhibitions, points of sales and events. Please note that we can combine information that we collect via one method (e.g. a Warner Bros. website) with information that we collect via another method (e.g. a Warner Bros. video game). As part of this, we can combine information that was originally collected by different Warner Bros. entities.
Finally, we note that California law requires us to provide certain information about how we collect and use the personal information of California residents and to grant those California residents certain rights with respect to their data. If you are a California resident, please see the California and CCPA Privacy Rights and Disclosures section of this Policy for these disclosures and a description of your privacy rights, including a right to access, delete, or opt out of the sale of your personal information.
TABLE OF CONTENTS
• THE INFORMATION WE COLLECT
• HOW WE USE THE INFORMATION
• INFORMATION SHARING AND DISCLOSURE
• YOUR CHOICES
• COOKIES AND OTHER TECHNICAL INFORMATION
• DATA RETENTION
• HOW YOU CAN ACCESS OR CORRECT INFORMATION
• INTERNATIONAL TRANSFER
• NOTIFICATION REGARDING UPDATES
• JOINT CONTROLLERS & HOW TO CONTACT US
• CALIFORNIA AND CCPA PRIVACY RIGHTS AND DISCLOSURES (effective 1/1/2020)
INFORMATION WE COLLECT
We collect and combine different types of information together, and collectively refer to all of this information in this Privacy Policy as “Information”. Such Information includes:
Registration, account, and sign-up information. We collect Information in the course of your use of, or registration with, us. For example, when you create an account, register for, or download an application, or sign-up for a product or service, you provide us with certain personal information. This type of personal information can include: name, postal address, telephone number or email address. We can also receive Information about your interest in and use of various products, programs, services, and content available.
Chat conversation. When you use the in-game chat feature, we collect Information relating to your conversations, such as who you message, the time and date of your message and the contents of your message.
Product/service purchase. Where you make a purchase on one of our sites, we will also collect certain payment information (e.g. credit/debit card, billing information and delivery address).
Information about others/inviting friends. In certain situations, we collect Information you submit about other people. For example, you can submit Information to invite a friend to participate in an offering, make recommendations, share content, or you have multiple players sharing the same video game session. By processing these requests, we can receive the other person’s Information, including details such as his/her name, postal address, email address, telephone number, or information about the recipient’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 Social Media Sites (as defined below).
Information from other sources. We, on occasion, combine Information we receive online with other information, including usage information from our other sites and our online advertising and media. We also supplement or combine Information with information from a variety of other sources or outside records, such as demographic, transaction history, or personal information, and we use that combined information in accordance with this Privacy Policy.
Social media. You can engage with some of our content and offerings, such as videos, games, applications, and other offerings on or through third party communities, forums, and social media sites, services, plug-ins, and applications (“Social Media Sites”). When you link to or interact with us or content through Social Media Sites, you allow us to receive certain Information from your social media account (e.g., 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, the posts or the 'likes' you make). We also receive Information from your interaction with our content (e.g., content viewed, game performance, high scores, and information about advertisements you have been shown or have clicked on). Where permitted by law, by providing this Information or otherwise interacting with our Sites through Social Media Sites, you consent to our use of Information from the Social Media Site in accordance with this Privacy Policy.
Public forums. If you post or share Information or content, such as photos, letters, videos, or comments, while participating in online forums we operate, or when you interact with us through Social Media Sites, depending on your privacy settings this Information and 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 Social Media Sites, and how those Social Media Sites handle your personal information and content, please refer to their privacy help guides, privacy policies, and terms of use.
Location information. We have access to certain Information about your location, such as your country or address, when you provide it or via device information (such as an IP address). With your consent (where required by law), we can also collect Information about your device’s precise location (e.g. geolocation via mobile devices).
Technical and usage information. We also collect certain technical and usage information such as the type of device, browser, and operating system you are using, your Internet service provider or mobile carrier, unique device identifier, IDFA or IDFV, MAC address, IP address, device and browser settings, the webpages and apps you use, advertisements you see and interact with, and certain site usage information. See our Cookies and Other Technical Information section for more information on how we may use these technologies to collect this Information.
Customer enquiries. Where you contact us through one of our customer helpdesks or customer call centres, we can have access to the application, or product/service that you have purchased, your purchase history, your previous correspondence with us or your contact details. Calls to customer call centres may be recorded.
HOW WE USE THE INFORMATION
We use Information for the purposes described in this Privacy Policy or disclosed at the time of collection.
Providing and marketing products and services.
We use the Information we collect about you, to fulfill your purchase, or to fulfill your requests for, and otherwise provide or analyse your use of our products, application, services, video games and content, to facilitate sharing and other interactions with Social Media Sites, and to provide, develop, maintain, personalise, protect, and improve your experience and our offerings. For example, we use Information collected on our sites to enable you to do things like (i) watch trailers and video clips, (ii) get entertainment news and updates, (iii) get information about our products, services, and content, (iv) locate and access personalised information, ads or functionality based on your interests and location (e.g., find stores, theaters, or show times), (v) buy digital content, products/services or movie tickets, (vi) play games, (vii) engage with interactive features, activities, and Social Media Sites, (viii) read and post comments, content, and reviews, or (ix) enter promotions, contests, and sweepstakes. We also use Information for your payment of any products/services you purchase, to prevent fraud or to offer, market, and advertise products, programs, and services from us and our affiliates, trusted partners, and select third parties that we believe can be of interest to you.
Our Reasons
• Fulfilling contractual obligations
• Legal obligations
• With your consent (where required)
• Our legitimate interests:
o Improving and developing new products and services
o Being more efficient
o Fighting fraud
o Retaining your shopping history and use details of the products you have previously purchased to make suggestions to you for other products which we believe you will also be interested in
Communicating with you and others.
We use Information about you to communicate with you, such as (i) to notify you when you win one of our contests or sweepstakes, or when we make changes to our policies or user agreements, (ii) to respond to your inquiries, (iii) to communicate with you about your purchases or transactions, (iv) to contact you about your account, or (v) to send you information about promotions, offerings, and our features. You can also choose to receive push notifications from us on your mobile device. If you choose to submit content for publication online or in other forums, we can publish your screen name and other Information you have provided to us, the Internet, or elsewhere. If you choose to contact one of our call centres we can record such calls. We use Information that you provide about others to enable us to send them invitations, promotions, or other content on your behalf or through our sites. From time to time, where permitted by law, we also use this Information to offer, market, or advertise products, programs, or services to them from us and our affiliates, business partners, and select third parties.
Our Reasons
• Fulfilling contractual obligations
• Legal obligations
• With your consent (where required)
• Our legitimate interests:
o Communicating important information
o Improving and developing new products and services
o Being more efficient
o Compiling statistics
Monitoring in-game chat function.
To ensure a safe in-game chat environment, we monitor your in-game chat communications.
Our Reasons
• With your consent
Third party social networks.
We use your Information when you interact with third party social networking features to serve you with advertisements and engage with you on third party social networks. You can learn more about how these features work, the profile data that we obtain about you, and find out how to opt out by reviewing the privacy notices of the relevant third party social networks.
Our Reasons
• With your consent (where required)
• Our legitimate interests:
o Retaining and evaluating information on your recent visits to our mobile apps, and video games, and how you move around for analytics purposes in order to understand how people use our mobile apps, and video games so that we can make them more intuitive
o Defining types of customers for new products or services
o Developing a profile of you and your interactions with us so that we can provide tailored offers, opportunities and services that may be of interest to you
Use of technical and usage information.
We use technical and usage information to improve our design, functionality and content and to enable us to personalise your experience with our content and offerings. We use this Information (i) to provide, develop, maintain, personalise, protect, and improve our products, applications, services and video games, and to operate our business, (ii) to perform analytics, including to analyse and report on usage and performance, (iii) to protect against, identify, and prevent fraud and other unlawful activity, (iv) to create aggregate data about groups or categories of our users, and (iv) for us and our affiliates, business partners, and select third parties to target, offer, market, or advertise products, programs, or services.
Our Reasons
• With your consent (where required)
• Our legitimate interests:
o Retaining and evaluating information on your recent visits to our mobile apps, and video games, and how you move around for analytics purposes in order to understand how people use our mobile apps, and video games so that we can make them more intuitive
o Defining types of customers for new products or services
o Developing a profile of you and your interactions with us so that we can provide tailored offers, opportunities and services that may be of interest to you
Compliance.
We use Information we collect to detect, investigate, and prevent activities that violate our terms of use, could be fraudulent, violate copyright, or other rules or that can be otherwise illegal, to comply with legal requirements, and to protect our rights and the rights and safety of our users and others.
Our Reasons
• Legal obligations
• Our legitimate interests:
o Protecting our business interests and rights, privacy, safety and property, or that of the public
o Sharing your Information with third parties in order to permit us to pursue available remedies or limit damage that we may sustain
Note: We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out later in this Privacy Policy.
INFORMATION SHARING AND DISCLOSURE
We share and disclose Information in the following ways or for any other purpose disclosed at the time of collection:
Joint-controllers. Two Warner Bros. entities jointly control your Information. See the end of this policy for further details.
Law enforcement bodies and courts. We disclose Information in response to legal process, for example in response to a court order or a subpoena, or in response to a law enforcement body's request. We also disclose such Information to 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) as otherwise required by law.
Change of control. We transfer Information in the event of a business transaction, such as if we or one of our business units or our relevant assets are acquired by, sold to, or merged with another company or as part of a bankruptcy proceeding or a business reorganisation.
Service providers. Our agents and contractors have access to Information to help carry out the services they are performing for us, such as, but not limited to, fulfilment, creation, maintenance, hosting, and delivery of products and services, conduct marketing, handle payments, email and order fulfillment, administer contests, conduct research and analytics, or customer service.
Linked sites. Some of our sites contain links to other sites, including Social Media Sites, whose information practices can be different from ours. You should consult the other sites' privacy disclosures and terms before submitting any Information, as we have no control over Information that is submitted to, or collected by, these third parties.
Sponsors and co-promotions. We sometimes offer content or programs (e.g., contests, sweepstakes, promotions, games, applications or Social Media Site integrations) that are sponsored by or co-branded with identified third parties. By virtue of these relationships, the third parties collect or obtain Information from you when participating in the activity. We have no control over these third parties' use of this Information. We encourage you to look at the privacy disclosure of any such third party to learn about their data practices.
Advertising networks. We share certain Information with third parties to provide advertising to you based on your interests. For more information, please see our (i) Cookies and Other Technical Information and (ii) Ad Choices sections below.
YOUR CHOICES
Marketing communications and sharing with third parties. We provide you with an opportunity to express your preferences with respect to receiving certain marketing communications from us, and our sharing of Information with trusted partners for their direct marketing purposes. If you ever decide in the future that you would like to update these preferences, you can submit a request by going to our individual rights request portal. If you previously chose to receive push notifications on your mobile device from us, but no longer wish to receive them, you can manage your preferences through your device or app settings, depending on the type of device.
Ad Choices. We work with reputable third parties to present advertisements, and engage in data collection, reporting, ad delivery and response measurement, and site analytics on our sites and on third party websites across the Internet and applications over time. These third parties use cookies, web beacons, pixels, or similar technologies to perform this activity. They also obtain information about applications you use, websites you visit, and other information from across your devices and browsers in order to help serve advertising that will be more relevant to your interests on and off our sites and across your devices and browsers. This type of advertising is known as interest-based advertising. They also use this information to associate various browsers and devices together for the purpose of interest-based advertising and other purposes like analytics.
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 Your Online Choice and/or the EDAA Self-Regulatory Initiative for Online Behavioral Advertising. 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 can continue to receive advertising, but that advertising will be less relevant to your interests.
You can have more options depending on your mobile device and operating system. For example, most device operating systems (e.g., iOS for Apple phones, Android for Android devices, and Windows for Microsoft devices) provide their own instructions on how to limit or prevent the delivery of tailored in-application advertisements. You can review the support materials and/or the privacy settings for the respective operating systems to learn more about these features and how they apply to tailored in-app advertisements.
Precise location information. To disable the collection of precise location information from your mobile device through our mobile apps, you can access your mobile device settings and choose to limit that collection.
See also our Cookies and Other Technical Information section for more choices about managing other technical and usage information.
COOKIES AND OTHER TECHNICAL INFORMATION
Cookies and other technologies. We, and our affiliates, third party service providers, and trusted partners send "cookies" to your device or use similar technologies to understand and enhance your online experience with us and through our advertising and media across the Internet including Social Media Sites, mobile apps, and video games.
Cookies are small text files placed in your browser. We also use pixels or "web beacons" that monitor your use of our sites. Web beacons are small strings of code that provide a method for delivering a graphic image on a webpage for the purpose of transferring data, such as the IP address of the device that downloaded the page on which the web beacon appears, the URL of the page on which the web beacon appears, the time the page containing the web beacon was viewed, the type of browser that fetched the web beacon, and the identification number of any cookie on the device previously placed by that server. We also integrate “Software Development Kits” (“SDKs”), javascripts or portions of code into our applications/video games to perform similar functions as cookies and web beacons. For example, SDKs collect technical and usage information such as mobile device identifiers and your interactions with our app. Some of our sites use locally stored objects (“LSOs”) to provide certain content, such as video on demand, video clips, or animation, and a better user experience.
We can use cookies and other technologies to help recognise your browser or device, maintain your preferences, provide certain features, and collect Information about your online interactions with us, our content, and our communications. For example, when corresponding with you via HTML capable email, web beacons and other technologies let us know about your activity, including whether you received and opened our email, clicked through a link, or otherwise interacted with our content, and this information can be associated with Information previously collected.
We also use cookies and other technologies (i) to provide, develop, maintain, personalise, protect, and improve our sites, products, apps, services and video games, and to operate our business, (ii) to perform analytics, including to analyse and report on usage and performance of our content and marketing materials, (iii) to protect against, identify, and prevent fraud and other unlawful activity, (iv) to create aggregate data about groups or categories of our users, (v) to synchronise users across devices, affiliates, and trusted partners, and (vi) for us and our affiliates, and trusted partners to target, offer, market, or advertise products, apps, services or video games. Cookies and other technologies also facilitate, manage, and measure the performance of advertisements displayed on or delivered by or through us.
Managing cookies and other technologies.
Websites and mobile applications
Details
Strictly necessary cookies or similar technologies: They are essential in order to enable you to move around our sites or apps and use its features, such as accessing secure areas. Without them, services like enabling appropriate content based on your type of device cannot be provided.
Performance cookies or similar technologies: They collect information about how you use our sites or apps, so that we can analyse traffic and understand users' interactions. We may use third party service providers such as Google Analytics for this purpose who may use their own cookies or similar technologies. The information is used to improve our site or app.
Functionality cookies or similar technologies: They allow our sites or apps to remember choices you make (such as your user name, or the region you are in) and provide enhanced, more personal features. They can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog.
Social media cookies or similar technologies: They are used when you share information using a social media sharing button or “like” button on our sites or apps, or when you link your account or engage with our content on or through a social media site such as Facebook, Twitter or Google+. The social network will record that you have done this. This information may be linked to targeting/advertising activities.
Advertising cookies or similar technologies: Some of our sites or apps may use a third party advertising network, or Time Warner/Warner Bros. affiliates, to deliver targeted advertising. They may also have the capability to track your browsing across sites, apps and Social Media Sites.
We do not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.
See the Your Choices section to learn how to control data collection for certain purposes.
DATA RETENTION
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 the personal information in the first place. For example, some personal information related to the provision of 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.
We have a detailed internal retention policy that sets out varying retention periods for different categories of personal information depending on our legal obligations and whether there is a commercial need. After a retention period has elapsed, the personal information is securely deleted.
HOW YOU CAN ACCESS OR CORRECT INFORMATION
Under conditions, you have the right to ask us for a copy of your Information, to correct it, erase it or restrict its processing, and to obtain the Information you provide in a structured, machine readable format. You also have the right to ask us to transfer some of this Information to other organisations.
You have the right to object to the processing of personal information on the basis of our legitimate interests. Where we have asked for your consent to process Information, you have the right to withdraw this consent at any time.
If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.
We reserve the right not to allow access to your Information or to limit your rights (e.g. if such disclosure is prohibited by law or if the rights of another individual might be violated). In some instances, this may mean that we are able to retain your Information even if you withdraw your consent. To exercise these rights, or to contact our Data Protection Officer, please submit a request by going to our individual rights request portal.
Additionally, California law grants California residents the right to, among other things, access, delete, and opt out of the sale of certain personal information. For a description of these rights, please see the section on California and CCPA Privacy Rights and Disclosures.
INTERNATIONAL TRANSFER
We operate internationally, and many of our systems are currently based in the United States, this means Information we collect will be processed by us in the U.S. where data protection and privacy regulations will not offer the same level of protection as in other parts of the world, such as the European Union.
When we transfer your Information to our United States group members outside the European Economic Area (EEA), we make use of standard contractual clauses which have been approved by the European Commission. We also use these clauses when we transfer your Information to third parties outside the EEA or we may adopt other means to ensure that adequate safeguards are applied to your Information (e.g. approved Standard Contractual Clauses, international data transfer certifications, codes of conduct, BCR, etc). To find out more about how we protect your Information when it is transferred outside the EEA, please submit a request by going to our individual rights request portal.
NOTIFICATION REGARDING UPDATES
From time to time, we can update this Privacy Policy. We will notify you about material changes to this Privacy Policy by placing a notice on our sites. We encourage you to periodically check back and review this policy so that you always know our current privacy practices.
JOINT-CONTROLLERS & HOW TO CONTACT US
Two Warner Bros. entities jointly control your Information, namely:
• Playdemic Limited, Warner House, 98 Theobalds Road, London, WC1X 8WB, United Kingdom
• WB Games Inc., 4000 Warner Blvd., Bldg. 160, Burbank, CA 91522, USA
If you have any questions about this Privacy Policy you can contact us and our Data Protection Officer by going to our individual rights request portal; by writing to us at Warner House, 98 Theobalds Road, London, WC1X 8WB (Attn: General Counsel - Legal & Business Affairs); or at WarnerMedia Privacy Office, 4000 Warner Blvd., Bldg. 160, Burbank, CA 91522.
CALIFORNIA AND CCPA PRIVACY RIGHTS AND DISCLOSURES
This California and CCPA Privacy Rights and Disclosure Section was last updated July 1, 2020 and addresses legal obligations and rights laid out in the California Consumer Privacy Act (“CCPA”) and other laws that apply only to California residents. These obligations and rights apply to businesses doing business in California and to California residents and information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with California consumers or households (“California Information”). It does not apply to information that has been de-identified or aggregated as provided by CCPA.
CALIFORNIA INFORMATION WE COLLECTED AND SHARED
This section provides the information California residents need to exercise their rights over their California Information. Here is information about the California Information we have collected from and shared about consumers in the year before this section was last updated.
California Information We Collected
In the year before this section was last updated, we may have collected the following categories of California Information:
• Address and other identifiers – such as name, phone number, postal address, zip code, email address, account name or number, date of birth, driver’s license number, payment card numbers, or other similar identifiers
• Characteristics of protected classifications – such as race, ethnicity, or sexual orientation
• Unique and other online identifiers – such as IP address, device IDs, or other similar identifiers that relate to your device and its operating system
• Commercial information – such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
• Internet or other electronic network activity information – such as browsing history, search history, and information regarding your interactions with our Sites, and content such as videos, ads, websites, and devices such as smart TVs, streaming media, browsers and apps
• Professional information or educational Information – such as your current occupation
• Biometric information
• Audio, visual, or similar information – such as photos, videos, video footage (CCTV) or recordings you choose to post to our Sites or provide by granting us access to your camera while using Sites or services
• Location information – such as your device’s precise location in connection with certain Sites
• Inferences or audience segmentation – such as individual profiles, preferences, characteristics, and behaviors
• In-Game or online viewing activities – such videos, content, and pages viewed
We may have collected or sold these categories of California Information for the following business or commercial purposes:
• Performing services on behalf of the business – such as customer service, processing or fulfilling orders, providing content recommendations, and processing payments
• Auditing customer transactions
• Fraud and crime prevention
• Debugging errors in systems
• Marketing and advertising
• Internal research, analytics and development – e.g., user-preference analytics
• Developing, maintaining, provisioning or upgrading networks, products, services, or devices
We may have obtained California Information from a variety of sources, including:
• Directly from you – such as technical and usage information when you use our Sites
• Linked sites – such as Social Media Sites and third-party platforms
• Our affiliates
• Our joint ventures and promotional and strategic partners
• Information suppliers
• Distributors and other vendors
• Marketing mailing lists
• Other users submitting information about you – such as to invite you to participate in an offering, make recommendations, or share content
• Publicly available sources
Disclosures of California Information:
In the year before this section was last updated, we may have disclosed the following categories of California Information to third parties:
• Address and other identifiers – such as name, phone number, postal address, zip code, email address, account name or number, date of birth, driver’s license number, payment card numbers, or other similar identifiers
• Characteristics of protected classifications – such as race, ethnicity, or sexual orientation
• Unique and other online identifiers – such as IP address, device IDs, or other similar identifiers that relate to your device and its operating system
• Commercial information – such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
• Internet or other electronic network activity information – such as browsing history, search history, and information regarding your interactions with our Sites, and content such as videos, ads, websites, and devices such as smart TVs, streaming media, browsers and apps
• Professional information or educational Information – such as your current occupation
• Biometric information
• Audio, visual, or similar information – such as photos, videos, video footage (CCTV) or recordings you choose to post to our Sites or provide by granting us access to your camera while using Sites or services
• Location information – such as your device’s precise location in connection with certain Sites
• Inferences or audience segmentation – such as individual profiles, preferences, characteristics, and behaviors
• In-Game or online viewing activities – such videos, content, and pages viewed
We may have disclosed each of these categories of California Information to the following categories of third parties:
• Affiliates – These entities are associated with us through common ownership. To view a list of Affiliates, please visit the affiliates page.
• Service Providers – These entities process information on our behalf for business purposes, helping us provide products or services to you
• Social Media Platforms – These entities maintain networks connecting individuals and organizations – such as Facebook, LinkedIn, or Twitter
• Advertising Partners – These entities help us advertise our products or services, as well as connect us with others who want to place advertisements on some of our products or services
• Analytics Partners – These entities help us collect data on how our products or services are used, so that we can improve them and better understand our consumers
• Promotional Partners – We partner with these entities to jointly promote our products, for example by running contests or other promotional campaigns
• Government Entities – These entities include law enforcement authorities, regulatory agencies, and courts
Categories of California Information sold to third parties
The CCPA defines ‘sale’ very broadly. It includes the sharing of California Information in exchange for anything of value. According to this broad definition, in the year before this section was last updated, we may have sold the following categories of California Information to third parties:
• Address and other identifiers – such as name, phone number, postal address, zip code, email address, account name or number, date of birth, driver’s license number, payment card numbers, or other similar identifiers
• Characteristics of protected classifications – such as race, ethnicity, or sexual orientation
• Unique and other online identifiers – such as IP address, device IDs, or other similar identifiers that relate to your device and its operating system
• Commercial information – such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
• Internet or other electronic network activity information – such as browsing history, search history, and information regarding your interactions with our Sites, and content such as videos, ads, websites, and devices such as smart TVs, streaming media, browsers and apps
• Professional information or educational Information – such as your current occupation
• Biometric information
• Audio, visual, or similar information – such as photos, videos, video footage, video footage (CCTV) or recordings you choose to post to our Sites or provide by granting us access to your camera while using Sites or services
• Location information – such as your device’s precise location in connection with certain Sites
• Inferences or audience segmentation – such as individual profiles, preferences, characteristics, and behaviors
• In-Game or online viewing activities – such videos, content, and pages viewed
We may have sold each of these categories of California Information to the following categories of third parties:
• Affiliates – These entities are associated with us through common ownership. To view a list of affiliates, please visit the affiliates page.
• Social Media Platforms – These entities maintain networks connecting individuals and organizations – such as Facebook, LinkedIn, or Twitter
• Advertising Partners – These entities help us advertise our products or services, as well as connect us with others who want to place advertisements on some of our products or services
• Analytics Partners – These entities help us collect data on how our products or services are used, so that we can improve them and better understand our consumers
• Promotional Partners – We partner with these entities to jointly promote our products, for example by running contests or other promotional campaigns
YOUR CALIFORNIA PRIVACY RIGHTS TO REQUEST DISCLOSURE OF INFORMATION WE COLLECT AND SHARE ABOUT YOU
If you are a California resident, California Civil Code Section 1798.83 permits you to request information about our practices related to the disclosure of your personal information by certain members of the Warner Bros. Family of companies to certain third parties for their direct marketing purposes. You may be able to opt out of our sharing of your personal information with unaffiliated third parties for the third parties’ direct marketing purposes in certain circumstances. Please send your request (along with your full name, email address, postal address, and the subject line labeled “Your California Privacy Rights”) by email at wmprivacy@warnermediagroup.com.
In addition, if you are a California resident, the CCPA grants you the right to request certain information about our practices with respect to California Information. In particular, you can request the following:
• The categories and specific pieces of your California Information that we’ve collected
• The categories of sources from which we collected California Information
• The business or commercial purposes for which we collected or sold California Information
• The categories of third parties with which we shared California Information
You can submit a request to us for the following additional information:
• The categories of third parties to whom we’ve sold California Information, and the category or categories of California Information sold to each
• The categories of third parties to whom we’ve disclosed California Information, and the category or categories of California Information disclosed to each
YOUR RIGHT TO REQUEST THE DELETION OF CALIFORNIA INFORMATION
Upon your request, we will delete the California Information we have collected about you, except for situations when that information is necessary for us to: provide you with a product or service that you requested; perform a contract we entered into with you; maintain the functionality or security of our systems; comply with or exercise rights provided by the law; or use the information internally in ways that are compatible with the context in which you provided the information to us, or that are reasonably aligned with your expectations based on your relationship with us.
YOUR RIGHT TO ASK US NOT TO SELL YOUR CALIFORNIA INFORMATION
You can always tell us not to sell your California Information by visiting our Privacy Center.
HOW TO EXERCISE YOUR CALIFORNIA RIGHTS
You may exercise your rights to request access to your California Information, deletion of your California Information, or to request we not sell your California Information by visiting our Privacy Center. You can also contact us toll free at 833-WB-PRVCY (833-927-7829) or TTY: 833-PRVCY-TT (833-778-2988) and an agent will assist you with submitting a request. These requests are generally free. When you submit a request, we will usually ask you to provide an email address which we will contact to confirm the request was not fraudulently submitted.
In addition, for access and deletion requests, we will use a third-party verification service to confirm that you are who you say you are. Our verification service does this by matching information you provide against information held about you in its records, or, if necessary, by allowing you to submit documents proving your identity.
If you are the parent of a child under 13 years of age, you may also submit a request on behalf of your child. In that event, we will ask you to provide your child’s email address, to verify your identity, and to submit a signed form authorizing us to proceed with the request regarding your child’s California Information.
You may also designate an authorized agent to submit a request on your behalf. To do so, we will require either (1) a valid power of attorney, or (2) signed written permission from you. In the event your authorized agent is relying on signed written permission, we may also need to verify your identity and/or contact you directly to confirm permission to proceed with the request.
Your authorized agent can make a request by contacting us toll free at 833-WB-PRVCY (833-927-7829) or TTY: 833-PRVCY-TT (833-778-2988).
OUR SUPPORT FOR THE EXERCISE YOUR DATA RIGHTS
You have the right not to receive discriminatory treatment if you exercise any of the rights explained in this section of the Privacy Policy. We are committed to providing you control over your California Information, we will not disadvantage you if you choose to exercise your rights.
CALIFORNIA CONSUMERS UNDER 16 YEARS OLD
CCPA has specific rules regarding the use of California Information from consumers under 16 years of age. In particular, consistent with the CCPA, if we knowingly collect the California Information of a consumer under the age of 16, we will not sell the information unless we receive affirmative permission to do so. If the consumer is between the ages of 13 and 16 years of age, the consumer may provide that permission; if the consumer is under the age of 13, the consumer’s parent or guardian must provide the permission. As of the Effective Date of this Privacy Policy, we do not have actual knowledge that we sell California Information of consumers under 16 years of age.
If you would like further information on how we handle California Information from consumers under the age of 16 years of age, or if you have questions about these information practices, you may contact us at wmprivacy@warnermediagroup.com, or at WarnerMedia Privacy Office, 4000 Warner Blvd., Bldg. 160, Burbank, CA 91522.
CALIFORNIA CONSUMERS UNDER 18 YEARS OLD
California consumers who are registered users of the Sites and under 18 years of age may request removal of content or information they posted on the Sites. We will remove such content or information when we are required to do so by law. To request removal of content or information you posted on the Sites, you may contact us at wmprivacy@warnermediagroup.com, or at WarnerMedia Privacy Office, 4000 Warner Blvd., Bldg. 160, Burbank, CA 91522.
However, even if we remove the content or information that you posted, we cannot completely prevent further use or disclosure of that content or information by others once you have shared it in a publicly available forum.
PLAYDEMIC PRIVACY POLICY
Last updated 1 July 2020
Scope of this Privacy Policy
Please read this Privacy Policy carefully to understand our policies and practices regarding your Information (as defined below) and how we will treat it.
This Privacy Policy explains how your Information is collected, used, and disclosed by Warner Bros. entities as listed in the controllers & contact section ("we" or "us"). It also tells you how you can access and update your Information and make certain choices about how your Information is used.
This Privacy Policy covers both our online and offline data collection activities, including information that we collect through our various channels such as websites, apps, console games, third party social networks, customer care centres, studios, attractions/exhibitions, points of sales and events. Please note that we can combine information that we collect via one method (e.g. a Warner Bros. website) with information that we collect via another method (e.g. a Warner Bros. video game). As part of this, we can combine information that was originally collected by different Warner Bros. entities.
Finally, we note that California law requires us to provide certain information about how we collect and use the personal information of California residents and to grant those California residents certain rights with respect to their data. If you are a California resident, please see the California and CCPA Privacy Rights and Disclosures section of this Policy for these disclosures and a description of your privacy rights, including a right to access, delete, or opt out of the sale of your personal information.
TABLE OF CONTENTS
• THE INFORMATION WE COLLECT
• HOW WE USE THE INFORMATION
• INFORMATION SHARING AND DISCLOSURE
• YOUR CHOICES
• COOKIES AND OTHER TECHNICAL INFORMATION
• DATA RETENTION
• HOW YOU CAN ACCESS OR CORRECT INFORMATION
• INTERNATIONAL TRANSFER
• NOTIFICATION REGARDING UPDATES
• JOINT CONTROLLERS & HOW TO CONTACT US
• CALIFORNIA AND CCPA PRIVACY RIGHTS AND DISCLOSURES (effective 1/1/2020)
INFORMATION WE COLLECT
We collect and combine different types of information together, and collectively refer to all of this information in this Privacy Policy as “Information”. Such Information includes:
Registration, account, and sign-up information. We collect Information in the course of your use of, or registration with, us. For example, when you create an account, register for, or download an application, or sign-up for a product or service, you provide us with certain personal information. This type of personal information can include: name, postal address, telephone number or email address. We can also receive Information about your interest in and use of various products, programs, services, and content available.
Chat conversation. When you use the in-game chat feature, we collect Information relating to your conversations, such as who you message, the time and date of your message and the contents of your message.
Product/service purchase. Where you make a purchase on one of our sites, we will also collect certain payment information (e.g. credit/debit card, billing information and delivery address).
Information about others/inviting friends. In certain situations, we collect Information you submit about other people. For example, you can submit Information to invite a friend to participate in an offering, make recommendations, share content, or you have multiple players sharing the same video game session. By processing these requests, we can receive the other person’s Information, including details such as his/her name, postal address, email address, telephone number, or information about the recipient’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 Social Media Sites (as defined below).
Information from other sources. We, on occasion, combine Information we receive online with other information, including usage information from our other sites and our online advertising and media. We also supplement or combine Information with information from a variety of other sources or outside records, such as demographic, transaction history, or personal information, and we use that combined information in accordance with this Privacy Policy.
Social media. You can engage with some of our content and offerings, such as videos, games, applications, and other offerings on or through third party communities, forums, and social media sites, services, plug-ins, and applications (“Social Media Sites”). When you link to or interact with us or content through Social Media Sites, you allow us to receive certain Information from your social media account (e.g., 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, the posts or the 'likes' you make). We also receive Information from your interaction with our content (e.g., content viewed, game performance, high scores, and information about advertisements you have been shown or have clicked on). Where permitted by law, by providing this Information or otherwise interacting with our Sites through Social Media Sites, you consent to our use of Information from the Social Media Site in accordance with this Privacy Policy.
Public forums. If you post or share Information or content, such as photos, letters, videos, or comments, while participating in online forums we operate, or when you interact with us through Social Media Sites, depending on your privacy settings this Information and 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 Social Media Sites, and how those Social Media Sites handle your personal information and content, please refer to their privacy help guides, privacy policies, and terms of use.
Location information. We have access to certain Information about your location, such as your country or address, when you provide it or via device information (such as an IP address). With your consent (where required by law), we can also collect Information about your device’s precise location (e.g. geolocation via mobile devices).
Technical and usage information. We also collect certain technical and usage information such as the type of device, browser, and operating system you are using, your Internet service provider or mobile carrier, unique device identifier, IDFA or IDFV, MAC address, IP address, device and browser settings, the webpages and apps you use, advertisements you see and interact with, and certain site usage information. See our Cookies and Other Technical Information section for more information on how we may use these technologies to collect this Information.
Customer enquiries. Where you contact us through one of our customer helpdesks or customer call centres, we can have access to the application, or product/service that you have purchased, your purchase history, your previous correspondence with us or your contact details. Calls to customer call centres may be recorded.
HOW WE USE THE INFORMATION
We use Information for the purposes described in this Privacy Policy or disclosed at the time of collection.
Providing and marketing products and services.
We use the Information we collect about you, to fulfill your purchase, or to fulfill your requests for, and otherwise provide or analyse your use of our products, application, services, video games and content, to facilitate sharing and other interactions with Social Media Sites, and to provide, develop, maintain, personalise, protect, and improve your experience and our offerings. For example, we use Information collected on our sites to enable you to do things like (i) watch trailers and video clips, (ii) get entertainment news and updates, (iii) get information about our products, services, and content, (iv) locate and access personalised information, ads or functionality based on your interests and location (e.g., find stores, theaters, or show times), (v) buy digital content, products/services or movie tickets, (vi) play games, (vii) engage with interactive features, activities, and Social Media Sites, (viii) read and post comments, content, and reviews, or (ix) enter promotions, contests, and sweepstakes. We also use Information for your payment of any products/services you purchase, to prevent fraud or to offer, market, and advertise products, programs, and services from us and our affiliates, trusted partners, and select third parties that we believe can be of interest to you.
Our Reasons
• Fulfilling contractual obligations
• Legal obligations
• With your consent (where required)
• Our legitimate interests:
o Improving and developing new products and services
o Being more efficient
o Fighting fraud
o Retaining your shopping history and use details of the products you have previously purchased to make suggestions to you for other products which we believe you will also be interested in
Communicating with you and others.
We use Information about you to communicate with you, such as (i) to notify you when you win one of our contests or sweepstakes, or when we make changes to our policies or user agreements, (ii) to respond to your inquiries, (iii) to communicate with you about your purchases or transactions, (iv) to contact you about your account, or (v) to send you information about promotions, offerings, and our features. You can also choose to receive push notifications from us on your mobile device. If you choose to submit content for publication online or in other forums, we can publish your screen name and other Information you have provided to us, the Internet, or elsewhere. If you choose to contact one of our call centres we can record such calls. We use Information that you provide about others to enable us to send them invitations, promotions, or other content on your behalf or through our sites. From time to time, where permitted by law, we also use this Information to offer, market, or advertise products, programs, or services to them from us and our affiliates, business partners, and select third parties.
Our Reasons
• Fulfilling contractual obligations
• Legal obligations
• With your consent (where required)
• Our legitimate interests:
o Communicating important information
o Improving and developing new products and services
o Being more efficient
o Compiling statistics
Monitoring in-game chat function.
To ensure a safe in-game chat environment, we monitor your in-game chat communications.
Our Reasons
• With your consent
Third party social networks.
We use your Information when you interact with third party social networking features to serve you with advertisements and engage with you on third party social networks. You can learn more about how these features work, the profile data that we obtain about you, and find out how to opt out by reviewing the privacy notices of the relevant third party social networks.
Our Reasons
• With your consent (where required)
• Our legitimate interests:
o Retaining and evaluating information on your recent visits to our mobile apps, and video games, and how you move around for analytics purposes in order to understand how people use our mobile apps, and video games so that we can make them more intuitive
o Defining types of customers for new products or services
o Developing a profile of you and your interactions with us so that we can provide tailored offers, opportunities and services that may be of interest to you
Use of technical and usage information.
We use technical and usage information to improve our design, functionality and content and to enable us to personalise your experience with our content and offerings. We use this Information (i) to provide, develop, maintain, personalise, protect, and improve our products, applications, services and video games, and to operate our business, (ii) to perform analytics, including to analyse and report on usage and performance, (iii) to protect against, identify, and prevent fraud and other unlawful activity, (iv) to create aggregate data about groups or categories of our users, and (iv) for us and our affiliates, business partners, and select third parties to target, offer, market, or advertise products, programs, or services.
Our Reasons
• With your consent (where required)
• Our legitimate interests:
o Retaining and evaluating information on your recent visits to our mobile apps, and video games, and how you move around for analytics purposes in order to understand how people use our mobile apps, and video games so that we can make them more intuitive
o Defining types of customers for new products or services
o Developing a profile of you and your interactions with us so that we can provide tailored offers, opportunities and services that may be of interest to you
Compliance.
We use Information we collect to detect, investigate, and prevent activities that violate our terms of use, could be fraudulent, violate copyright, or other rules or that can be otherwise illegal, to comply with legal requirements, and to protect our rights and the rights and safety of our users and others.
Our Reasons
• Legal obligations
• Our legitimate interests:
o Protecting our business interests and rights, privacy, safety and property, or that of the public
o Sharing your Information with third parties in order to permit us to pursue available remedies or limit damage that we may sustain
Note: We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out later in this Privacy Policy.
INFORMATION SHARING AND DISCLOSURE
We share and disclose Information in the following ways or for any other purpose disclosed at the time of collection:
Joint-controllers. Two Warner Bros. entities jointly control your Information. See the end of this policy for further details.
Law enforcement bodies and courts. We disclose Information in response to legal process, for example in response to a court order or a subpoena, or in response to a law enforcement body's request. We also disclose such Information to 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) as otherwise required by law.
Change of control. We transfer Information in the event of a business transaction, such as if we or one of our business units or our relevant assets are acquired by, sold to, or merged with another company or as part of a bankruptcy proceeding or a business reorganisation.
Service providers. Our agents and contractors have access to Information to help carry out the services they are performing for us, such as, but not limited to, fulfilment, creation, maintenance, hosting, and delivery of products and services, conduct marketing, handle payments, email and order fulfillment, administer contests, conduct research and analytics, or customer service.
Linked sites. Some of our sites contain links to other sites, including Social Media Sites, whose information practices can be different from ours. You should consult the other sites' privacy disclosures and terms before submitting any Information, as we have no control over Information that is submitted to, or collected by, these third parties.
Sponsors and co-promotions. We sometimes offer content or programs (e.g., contests, sweepstakes, promotions, games, applications or Social Media Site integrations) that are sponsored by or co-branded with identified third parties. By virtue of these relationships, the third parties collect or obtain Information from you when participating in the activity. We have no control over these third parties' use of this Information. We encourage you to look at the privacy disclosure of any such third party to learn about their data practices.
Advertising networks. We share certain Information with third parties to provide advertising to you based on your interests. For more information, please see our (i) Cookies and Other Technical Information and (ii) Ad Choices sections below.
YOUR CHOICES
Marketing communications and sharing with third parties. We provide you with an opportunity to express your preferences with respect to receiving certain marketing communications from us, and our sharing of Information with trusted partners for their direct marketing purposes. If you ever decide in the future that you would like to update these preferences, you can submit a request by going to our individual rights request portal. If you previously chose to receive push notifications on your mobile device from us, but no longer wish to receive them, you can manage your preferences through your device or app settings, depending on the type of device.
Ad Choices. We work with reputable third parties to present advertisements, and engage in data collection, reporting, ad delivery and response measurement, and site analytics on our sites and on third party websites across the Internet and applications over time. These third parties use cookies, web beacons, pixels, or similar technologies to perform this activity. They also obtain information about applications you use, websites you visit, and other information from across your devices and browsers in order to help serve advertising that will be more relevant to your interests on and off our sites and across your devices and browsers. This type of advertising is known as interest-based advertising. They also use this information to associate various browsers and devices together for the purpose of interest-based advertising and other purposes like analytics.
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 Your Online Choice and/or the EDAA Self-Regulatory Initiative for Online Behavioral Advertising. 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 can continue to receive advertising, but that advertising will be less relevant to your interests.
You can have more options depending on your mobile device and operating system. For example, most device operating systems (e.g., iOS for Apple phones, Android for Android devices, and Windows for Microsoft devices) provide their own instructions on how to limit or prevent the delivery of tailored in-application advertisements. You can review the support materials and/or the privacy settings for the respective operating systems to learn more about these features and how they apply to tailored in-app advertisements.
Precise location information. To disable the collection of precise location information from your mobile device through our mobile apps, you can access your mobile device settings and choose to limit that collection.
See also our Cookies and Other Technical Information section for more choices about managing other technical and usage information.
COOKIES AND OTHER TECHNICAL INFORMATION
Cookies and other technologies. We, and our affiliates, third party service providers, and trusted partners send "cookies" to your device or use similar technologies to understand and enhance your online experience with us and through our advertising and media across the Internet including Social Media Sites, mobile apps, and video games.
Cookies are small text files placed in your browser. We also use pixels or "web beacons" that monitor your use of our sites. Web beacons are small strings of code that provide a method for delivering a graphic image on a webpage for the purpose of transferring data, such as the IP address of the device that downloaded the page on which the web beacon appears, the URL of the page on which the web beacon appears, the time the page containing the web beacon was viewed, the type of browser that fetched the web beacon, and the identification number of any cookie on the device previously placed by that server. We also integrate “Software Development Kits” (“SDKs”), javascripts or portions of code into our applications/video games to perform similar functions as cookies and web beacons. For example, SDKs collect technical and usage information such as mobile device identifiers and your interactions with our app. Some of our sites use locally stored objects (“LSOs”) to provide certain content, such as video on demand, video clips, or animation, and a better user experience.
We can use cookies and other technologies to help recognise your browser or device, maintain your preferences, provide certain features, and collect Information about your online interactions with us, our content, and our communications. For example, when corresponding with you via HTML capable email, web beacons and other technologies let us know about your activity, including whether you received and opened our email, clicked through a link, or otherwise interacted with our content, and this information can be associated with Information previously collected.
We also use cookies and other technologies (i) to provide, develop, maintain, personalise, protect, and improve our sites, products, apps, services and video games, and to operate our business, (ii) to perform analytics, including to analyse and report on usage and performance of our content and marketing materials, (iii) to protect against, identify, and prevent fraud and other unlawful activity, (iv) to create aggregate data about groups or categories of our users, (v) to synchronise users across devices, affiliates, and trusted partners, and (vi) for us and our affiliates, and trusted partners to target, offer, market, or advertise products, apps, services or video games. Cookies and other technologies also facilitate, manage, and measure the performance of advertisements displayed on or delivered by or through us.
Managing cookies and other technologies.
Websites and mobile applications
Details
Strictly necessary cookies or similar technologies: They are essential in order to enable you to move around our sites or apps and use its features, such as accessing secure areas. Without them, services like enabling appropriate content based on your type of device cannot be provided.
Performance cookies or similar technologies: They collect information about how you use our sites or apps, so that we can analyse traffic and understand users' interactions. We may use third party service providers such as Google Analytics for this purpose who may use their own cookies or similar technologies. The information is used to improve our site or app.
Functionality cookies or similar technologies: They allow our sites or apps to remember choices you make (such as your user name, or the region you are in) and provide enhanced, more personal features. They can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog.
Social media cookies or similar technologies: They are used when you share information using a social media sharing button or “like” button on our sites or apps, or when you link your account or engage with our content on or through a social media site such as Facebook, Twitter or Google+. The social network will record that you have done this. This information may be linked to targeting/advertising activities.
Advertising cookies or similar technologies: Some of our sites or apps may use a third party advertising network, or Time Warner/Warner Bros. affiliates, to deliver targeted advertising. They may also have the capability to track your browsing across sites, apps and Social Media Sites.
We do not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.
See the Your Choices section to learn how to control data collection for certain purposes.
DATA RETENTION
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 the personal information in the first place. For example, some personal information related to the provision of 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.
We have a detailed internal retention policy that sets out varying retention periods for different categories of personal information depending on our legal obligations and whether there is a commercial need. After a retention period has elapsed, the personal information is securely deleted.
HOW YOU CAN ACCESS OR CORRECT INFORMATION
Under conditions, you have the right to ask us for a copy of your Information, to correct it, erase it or restrict its processing, and to obtain the Information you provide in a structured, machine readable format. You also have the right to ask us to transfer some of this Information to other organisations.
You have the right to object to the processing of personal information on the basis of our legitimate interests. Where we have asked for your consent to process Information, you have the right to withdraw this consent at any time.
If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.
We reserve the right not to allow access to your Information or to limit your rights (e.g. if such disclosure is prohibited by law or if the rights of another individual might be violated). In some instances, this may mean that we are able to retain your Information even if you withdraw your consent. To exercise these rights, or to contact our Data Protection Officer, please submit a request by going to our individual rights request portal.
Additionally, California law grants California residents the right to, among other things, access, delete, and opt out of the sale of certain personal information. For a description of these rights, please see the section on California and CCPA Privacy Rights and Disclosures.
INTERNATIONAL TRANSFER
We operate internationally, and many of our systems are currently based in the United States, this means Information we collect will be processed by us in the U.S. where data protection and privacy regulations will not offer the same level of protection as in other parts of the world, such as the European Union.
When we transfer your Information to our United States group members outside the European Economic Area (EEA), we make use of standard contractual clauses which have been approved by the European Commission. We also use these clauses when we transfer your Information to third parties outside the EEA or we may adopt other means to ensure that adequate safeguards are applied to your Information (e.g. approved Standard Contractual Clauses, international data transfer certifications, codes of conduct, BCR, etc). To find out more about how we protect your Information when it is transferred outside the EEA, please submit a request by going to our individual rights request portal.
NOTIFICATION REGARDING UPDATES
From time to time, we can update this Privacy Policy. We will notify you about material changes to this Privacy Policy by placing a notice on our sites. We encourage you to periodically check back and review this policy so that you always know our current privacy practices.
JOINT-CONTROLLERS & HOW TO CONTACT US
Two Warner Bros. entities jointly control your Information, namely:
• Playdemic Limited, Warner House, 98 Theobalds Road, London, WC1X 8WB, United Kingdom
• WB Games Inc., 4000 Warner Blvd., Bldg. 160, Burbank, CA 91522, USA
If you have any questions about this Privacy Policy you can contact us and our Data Protection Officer by going to our individual rights request portal; by writing to us at Warner House, 98 Theobalds Road, London, WC1X 8WB (Attn: General Counsel - Legal & Business Affairs); or at WarnerMedia Privacy Office, 4000 Warner Blvd., Bldg. 160, Burbank, CA 91522.
CALIFORNIA AND CCPA PRIVACY RIGHTS AND DISCLOSURES
This California and CCPA Privacy Rights and Disclosure Section was last updated July 1, 2020 and addresses legal obligations and rights laid out in the California Consumer Privacy Act (“CCPA”) and other laws that apply only to California residents. These obligations and rights apply to businesses doing business in California and to California residents and information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with California consumers or households (“California Information”). It does not apply to information that has been de-identified or aggregated as provided by CCPA.
CALIFORNIA INFORMATION WE COLLECTED AND SHARED
This section provides the information California residents need to exercise their rights over their California Information. Here is information about the California Information we have collected from and shared about consumers in the year before this section was last updated.
California Information We Collected
In the year before this section was last updated, we may have collected the following categories of California Information:
• Address and other identifiers – such as name, phone number, postal address, zip code, email address, account name or number, date of birth, driver’s license number, payment card numbers, or other similar identifiers
• Characteristics of protected classifications – such as race, ethnicity, or sexual orientation
• Unique and other online identifiers – such as IP address, device IDs, or other similar identifiers that relate to your device and its operating system
• Commercial information – such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
• Internet or other electronic network activity information – such as browsing history, search history, and information regarding your interactions with our Sites, and content such as videos, ads, websites, and devices such as smart TVs, streaming media, browsers and apps
• Professional information or educational Information – such as your current occupation
• Biometric information
• Audio, visual, or similar information – such as photos, videos, video footage (CCTV) or recordings you choose to post to our Sites or provide by granting us access to your camera while using Sites or services
• Location information – such as your device’s precise location in connection with certain Sites
• Inferences or audience segmentation – such as individual profiles, preferences, characteristics, and behaviors
• In-Game or online viewing activities – such videos, content, and pages viewed
We may have collected or sold these categories of California Information for the following business or commercial purposes:
• Performing services on behalf of the business – such as customer service, processing or fulfilling orders, providing content recommendations, and processing payments
• Auditing customer transactions
• Fraud and crime prevention
• Debugging errors in systems
• Marketing and advertising
• Internal research, analytics and development – e.g., user-preference analytics
• Developing, maintaining, provisioning or upgrading networks, products, services, or devices
We may have obtained California Information from a variety of sources, including:
• Directly from you – such as technical and usage information when you use our Sites
• Linked sites – such as Social Media Sites and third-party platforms
• Our affiliates
• Our joint ventures and promotional and strategic partners
• Information suppliers
• Distributors and other vendors
• Marketing mailing lists
• Other users submitting information about you – such as to invite you to participate in an offering, make recommendations, or share content
• Publicly available sources
Disclosures of California Information:
In the year before this section was last updated, we may have disclosed the following categories of California Information to third parties:
• Address and other identifiers – such as name, phone number, postal address, zip code, email address, account name or number, date of birth, driver’s license number, payment card numbers, or other similar identifiers
• Characteristics of protected classifications – such as race, ethnicity, or sexual orientation
• Unique and other online identifiers – such as IP address, device IDs, or other similar identifiers that relate to your device and its operating system
• Commercial information – such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
• Internet or other electronic network activity information – such as browsing history, search history, and information regarding your interactions with our Sites, and content such as videos, ads, websites, and devices such as smart TVs, streaming media, browsers and apps
• Professional information or educational Information – such as your current occupation
• Biometric information
• Audio, visual, or similar information – such as photos, videos, video footage (CCTV) or recordings you choose to post to our Sites or provide by granting us access to your camera while using Sites or services
• Location information – such as your device’s precise location in connection with certain Sites
• Inferences or audience segmentation – such as individual profiles, preferences, characteristics, and behaviors
• In-Game or online viewing activities – such videos, content, and pages viewed
We may have disclosed each of these categories of California Information to the following categories of third parties:
• Affiliates – These entities are associated with us through common ownership. To view a list of Affiliates, please visit the affiliates page.
• Service Providers – These entities process information on our behalf for business purposes, helping us provide products or services to you
• Social Media Platforms – These entities maintain networks connecting individuals and organizations – such as Facebook, LinkedIn, or Twitter
• Advertising Partners – These entities help us advertise our products or services, as well as connect us with others who want to place advertisements on some of our products or services
• Analytics Partners – These entities help us collect data on how our products or services are used, so that we can improve them and better understand our consumers
• Promotional Partners – We partner with these entities to jointly promote our products, for example by running contests or other promotional campaigns
• Government Entities – These entities include law enforcement authorities, regulatory agencies, and courts
Categories of California Information sold to third parties
The CCPA defines ‘sale’ very broadly. It includes the sharing of California Information in exchange for anything of value. According to this broad definition, in the year before this section was last updated, we may have sold the following categories of California Information to third parties:
• Address and other identifiers – such as name, phone number, postal address, zip code, email address, account name or number, date of birth, driver’s license number, payment card numbers, or other similar identifiers
• Characteristics of protected classifications – such as race, ethnicity, or sexual orientation
• Unique and other online identifiers – such as IP address, device IDs, or other similar identifiers that relate to your device and its operating system
• Commercial information – such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
• Internet or other electronic network activity information – such as browsing history, search history, and information regarding your interactions with our Sites, and content such as videos, ads, websites, and devices such as smart TVs, streaming media, browsers and apps
• Professional information or educational Information – such as your current occupation
• Biometric information
• Audio, visual, or similar information – such as photos, videos, video footage, video footage (CCTV) or recordings you choose to post to our Sites or provide by granting us access to your camera while using Sites or services
• Location information – such as your device’s precise location in connection with certain Sites
• Inferences or audience segmentation – such as individual profiles, preferences, characteristics, and behaviors
• In-Game or online viewing activities – such videos, content, and pages viewed
We may have sold each of these categories of California Information to the following categories of third parties:
• Affiliates – These entities are associated with us through common ownership. To view a list of affiliates, please visit the affiliates page.
• Social Media Platforms – These entities maintain networks connecting individuals and organizations – such as Facebook, LinkedIn, or Twitter
• Advertising Partners – These entities help us advertise our products or services, as well as connect us with others who want to place advertisements on some of our products or services
• Analytics Partners – These entities help us collect data on how our products or services are used, so that we can improve them and better understand our consumers
• Promotional Partners – We partner with these entities to jointly promote our products, for example by running contests or other promotional campaigns
YOUR CALIFORNIA PRIVACY RIGHTS TO REQUEST DISCLOSURE OF INFORMATION WE COLLECT AND SHARE ABOUT YOU
If you are a California resident, California Civil Code Section 1798.83 permits you to request information about our practices related to the disclosure of your personal information by certain members of the Warner Bros. Family of companies to certain third parties for their direct marketing purposes. You may be able to opt out of our sharing of your personal information with unaffiliated third parties for the third parties’ direct marketing purposes in certain circumstances. Please send your request (along with your full name, email address, postal address, and the subject line labeled “Your California Privacy Rights”) by email at wmprivacy@warnermediagroup.com.
In addition, if you are a California resident, the CCPA grants you the right to request certain information about our practices with respect to California Information. In particular, you can request the following:
• The categories and specific pieces of your California Information that we’ve collected
• The categories of sources from which we collected California Information
• The business or commercial purposes for which we collected or sold California Information
• The categories of third parties with which we shared California Information
You can submit a request to us for the following additional information:
• The categories of third parties to whom we’ve sold California Information, and the category or categories of California Information sold to each
• The categories of third parties to whom we’ve disclosed California Information, and the category or categories of California Information disclosed to each
YOUR RIGHT TO REQUEST THE DELETION OF CALIFORNIA INFORMATION
Upon your request, we will delete the California Information we have collected about you, except for situations when that information is necessary for us to: provide you with a product or service that you requested; perform a contract we entered into with you; maintain the functionality or security of our systems; comply with or exercise rights provided by the law; or use the information internally in ways that are compatible with the context in which you provided the information to us, or that are reasonably aligned with your expectations based on your relationship with us.
YOUR RIGHT TO ASK US NOT TO SELL YOUR CALIFORNIA INFORMATION
You can always tell us not to sell your California Information by visiting our Privacy Center.
HOW TO EXERCISE YOUR CALIFORNIA RIGHTS
You may exercise your rights to request access to your California Information, deletion of your California Information, or to request we not sell your California Information by visiting our Privacy Center. You can also contact us toll free at 833-WB-PRVCY (833-927-7829) or TTY: 833-PRVCY-TT (833-778-2988) and an agent will assist you with submitting a request. These requests are generally free. When you submit a request, we will usually ask you to provide an email address which we will contact to confirm the request was not fraudulently submitted.
In addition, for access and deletion requests, we will use a third-party verification service to confirm that you are who you say you are. Our verification service does this by matching information you provide against information held about you in its records, or, if necessary, by allowing you to submit documents proving your identity.
If you are the parent of a child under 13 years of age, you may also submit a request on behalf of your child. In that event, we will ask you to provide your child’s email address, to verify your identity, and to submit a signed form authorizing us to proceed with the request regarding your child’s California Information.
You may also designate an authorized agent to submit a request on your behalf. To do so, we will require either (1) a valid power of attorney, or (2) signed written permission from you. In the event your authorized agent is relying on signed written permission, we may also need to verify your identity and/or contact you directly to confirm permission to proceed with the request.
Your authorized agent can make a request by contacting us toll free at 833-WB-PRVCY (833-927-7829) or TTY: 833-PRVCY-TT (833-778-2988).
OUR SUPPORT FOR THE EXERCISE YOUR DATA RIGHTS
You have the right not to receive discriminatory treatment if you exercise any of the rights explained in this section of the Privacy Policy. We are committed to providing you control over your California Information, we will not disadvantage you if you choose to exercise your rights.
CALIFORNIA CONSUMERS UNDER 16 YEARS OLD
CCPA has specific rules regarding the use of California Information from consumers under 16 years of age. In particular, consistent with the CCPA, if we knowingly collect the California Information of a consumer under the age of 16, we will not sell the information unless we receive affirmative permission to do so. If the consumer is between the ages of 13 and 16 years of age, the consumer may provide that permission; if the consumer is under the age of 13, the consumer’s parent or guardian must provide the permission. As of the Effective Date of this Privacy Policy, we do not have actual knowledge that we sell California Information of consumers under 16 years of age.
If you would like further information on how we handle California Information from consumers under the age of 16 years of age, or if you have questions about these information practices, you may contact us at wmprivacy@warnermediagroup.com, or at WarnerMedia Privacy Office, 4000 Warner Blvd., Bldg. 160, Burbank, CA 91522.
CALIFORNIA CONSUMERS UNDER 18 YEARS OLD
California consumers who are registered users of the Sites and under 18 years of age may request removal of content or information they posted on the Sites. We will remove such content or information when we are required to do so by law. To request removal of content or information you posted on the Sites, you may contact us at wmprivacy@warnermediagroup.com, or at WarnerMedia Privacy Office, 4000 Warner Blvd., Bldg. 160, Burbank, CA 91522.
However, even if we remove the content or information that you posted, we cannot completely prevent further use or disclosure of that content or information by others once you have shared it in a publicly available forum.