Updated: August 14, 2020
WarnerMedia ("we", "us", "our") is a leading media and entertainment group of companies. This Privacy Policy explains what personal information WarnerMedia companies collect, use, share and otherwise process about individuals ("you") interacting with our Offerings ("Information"). If you interact with our Offerings in the United States, please navigate to the relevant website or app in the United States to review the applicable Privacy Policy. Also, this Privacy Policy does not apply to Digital Services that are online services targeted at children.
The WarnerMedia family is made up of a number of different legal entities and business units. In this Privacy Policy, the "Controller" of your Information means the company that decides the purposes for which it is processed and how it is processed. Which WarnerMedia company is the Controller in relation to the processing of your Information will depend on which Offering you are using; it will often be the WarnerMedia company responsible for providing that Offering, as may be set out in our terms and conditions.
In some circumstances, more than one Controller may be responsible for processing your Information, for example, where Information is shared with other WarnerMedia companies for a purpose set out in this Privacy Policy. Please see our B2C WarnerMedia Controller List for more details. If you still have questions about who is the relevant Controller, please contact us using one of the methods set out below.
Under the laws of some countries outside the European Economic Area, we may need your consent to our processing of your Information set forth in this Privacy Policy. Subject to any indications you may give us to the contrary, such as opting out or not opting in if asked, and where permitted by law, by providing Information or otherwise interacting with our Offerings, you consent to our use of Information in accordance with this Privacy Policy.
TABLE OF CONTENTS
SCOPE OF THIS PRIVACY POLICY
Please read this policy carefully. It explains the types of Information we may collect about you, the purposes for and methods by which we collect it, and (where applicable) the lawful basis on which we do so, as well as information about data retention, your rights and how to contact us. This Privacy Policy covers both our online and offline data processing activities, including Information that we collect through our various Offerings such as those set out below:
Digital Services:
- WarnerMedia websites, including activities run through our websites, such as surveys, research studies, focus group tests, promotions, competitions and prize-draws, purchases within our services, calls to action for user-generated content ("UGC") and subscribing for newsletters;
- Mobile apps, including activities run through our apps, such as those listed for our websites;
- Subscription services or other streaming services offered by WarnerMedia to consumers and services where you receive our audio-visual content through our websites, mobile apps and/or via a service provided by a third party, such as an internet service provider, pay TV platform or mobile phone operator;
- Console games; and
- Our fan pages/channels/accounts on third party social networks (e.g. official pages on Facebook, Instagram, Twitter).
Offline Services:
- Studio tours;
- Attractions and exhibitions (e.g. theme parks, marketing activations at conventions or other public places, in person VR experiences) operated by a WarnerMedia company; and
- Events you attend as a consumer or guest (as opposed to in a business capacity) such as film premieres, marketing and influencer events, focus group or user tests and private events held at our premises or studios under hire.
Please note that we may combine Information that we collect via one source (e.g. a WarnerMedia website) with Information we collect via another source (e.g. a mobile app), including with Information possibly collected by a different WarnerMedia company or a third party (as further described below). Please also note our Offline Services may involve you interacting with our Digital Services and vice-versa, for example, where you book a studio tour or your participation to a marketing event through a WarnerMedia website. Certain WarnerMedia Offerings (for example, some WarnerMedia branded theme parks, online stores, and in-app purchases) are not operated by WarnerMedia but by a third party licensee or the app store; any processing of your personal information by such a licensee or app store is not subject to this Privacy Policy, so please check carefully whether the relevant terms and conditions refer to a WarnerMedia company or not.
INFORMATION WE COLLECT
We collect, use, share and otherwise process the following categories of Information:
1) Information we may collect from you:
- Registration, account, and sign-up Information, including information about you when you register or sign up with us for one of our Offerings (e.g. name, username, password, email, contact details, date of birth or age, interest in our content, etc.).
- Information about your purchase of an Offering, including relevant payment information (e.g. credit card information). We may also process Information about trial periods, redemptions of rewards or promotions, periods without an active subscription, payment history and any missed payments.
- Information about your use of, or participation in an Offering, including information about whether you have opened an email we have sent you, how you (including any account you use) interact with a Digital Service, content that you have viewed or posted, advertisements you have interacted with, games you have played and the level you reached, your preferences and interest in and use of various features, programs, services and content available on a Digital Service. This may also include demographic information, including at an individual or household level.
- Information you provide when participating in consumer surveys, research studies or focus group tests, including online or written replies and where applicable the recording of your audio or video interviews.
- Entries to promotions, competitions, prize-draws or calls to action, including images, videos and text.
- Camera access, including where for some Digital Services, we ask for permission to access your device's camera. If you grant permission, you may be able to take pictures or video within the app experience, to send them to us, or to access certain augmented reality ("AR") features. Some of these features may rely on camera systems to track movements of your eyes and other facial features or your immediate surroundings to apply AR effects.
- Sensitive data, including where you choose to share Information as part of one of our Offerings, or where you provide Information during one of our surveys or feedback sessions, including, where permitted by applicable law, information relating to your physical or mental health, race or ethnicity, religious or philosophical beliefs, sex life or sexual orientation, or your political beliefs. In some Offerings that include dynamic entertainment features, we may with your consent and in accordance with applicable law, collect information such as via facial scanning, eye tracking, or skin response that may be considered biometric.
- Information about your social media engagement, including your interactions with our fan pages/channels/accounts in third party communities, forums, and social media sites, services, plug-ins, and applications ("Social Media Sites"). This may include posts, your 'likes' and other user-generated content that you may provide, as well as details about yourself such as your name, user ID, profile photo, birthday, and, where you allow us to, lists of friends and people you follow. For information about how you can customize 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.
- Information shared on WarnerMedia public or community forums, including where you share photos, letters, videos or comments, while participating in online forums. Depending on your privacy settings, this Information or content and your username may become public on the Internet or within a community of users. We cannot prevent further use of this Information once you share it in a publicly available or community forum. Please refer to the specific forum's privacy policies for further information on how they handle your Information.
- Information about your location, including where it is derived from device information (such as an IP address or country code), your device's interactions with our Digital Services, or, with your consent, Information about your device's precise location (e.g. geolocation via mobile devices).
- Event Information, including images and clips, whether captured via a booth or by other means by us or a third party on our behalf, and other Information relating to the organisation and management of an event, such as food allergies and other individual requirements.
- Technical/usage Information from your device, including the type of device, browser, unique device identifier, operating system, internet provider, mobile device identifier and/or mobile advertising identifier, connected device identifier (including that of a connected television), IP address, network attributes, television device and application attributes and settings, and other device or browser attributes and settings.
- Information about your customer queries, including when you contact us through one of our customer helpdesks, email addresses, customer service chat boxes, forms or ticketing systems, Social Media Sites and customer call-centres, where calls may be recorded.
2) Information we may collect about you, from other sources, including friends:
Information from other sources. On occasion, we combine Information with other online information we receive, including usage information about your interactions with other websites and with online advertising and media. We also supplement or combine Information with Information from a variety of other sources or outside records, including third-party data providers that provide us with Information such as demographics, transaction and purchase history; Information about the content and advertisements you interact with. We may also receive Information about you from your friends who invite you to interact with any of our Digital Services. We may receive Information from third parties with which you have a subscription agreement that includes access to our content or services.
Information from friends. In certain situations, we may enable friends using our Offerings to provide Information about you. For example, someone can submit Information on our websites to invite you to participate in an Offering, make recommendations or share content through one of our apps, or have multiple players sharing the same game session. By processing these requests, we may receive your Information, including your name, contact details, or information about your interest in and use of our Offerings.
HOW WE USE THE INFORMATION
We may use Information for the purposes described in this Privacy Policy, or as otherwise disclosed at the time of collection. Below, we explain our various purposes, any processing activities that we believe may need further explanation and, where necessary, the 'lawful basis' on which we rely to process your Information.
INFORMATION SHARING AND DISCLOSURE
We share Information with and disclose it to the following parties, for the purposes set out below:
Within AT&T and/or WarnerMedia
Outside AT&T and/or WarnerMedia
Third Party 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 our Offerings, conducting marketing, providing IT services and security, handling payments, email and order fulfillment, administering promotions, competitions and prize-draws, conducting research, measurement and analytics, deriving insights, or customer service.
Linked Third Party Social Media Sites. Some of our Digital Services contain links to other sites, including Social Media Sites, for the purposes of customer interaction and marketing. The information practices of the Social Media Sites can be different from ours so you should consult their privacy policy and terms before submitting your personal information, as we have no control over personal information that is submitted to or collected by these third parties.
Third Party Partners. We sometimes offer Digital Services and Offline Services that are sponsored by or co-branded with identified third parties. By virtue of these relationships, the third parties collect or obtain personal information from you during the activity. We do not control these third parties' use of personal information. We encourage you to read their privacy policies to learn about their data practices.
Other third parties. In the event of a likely change of control of the business (or a part of the business) such as a transaction or reorganization, we may share your Information with interested parties, including a new business owner, and their respective professional advisers.
Law enforcement bodies, the authorities and courts. We disclose Information where necessary for the prevention, investigation or prosecution of criminal activities, and also in response to legal process, e.g. in response to a court order or a subpoena, or in response to a regulator, government authority or law enforcement body's request.
Public forums. If you post or share Information while interacting with one of our Digital Services, or through a Social Media Site, depending on the nature of the service or your privacy settings this Information can become public, after which, we cannot prevent further use or sharing of this Information. For information about how you can customize your privacy settings on Social Media Sites, please refer to their privacy help guides and terms of use.
DATA RETENTION
In broad terms, we will only retain your 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 Information and the reason that we have collected the Information in the first place. For example, some Information related to the provision of our Offerings to you will be kept for a number of years in order to comply with various finance and tax related legal obligations. We have detailed internal retention policies that set out the various retention periods for different categories of Information, depending on our legal obligations and whether there is a commercial need to retain the Information. After a retention period has lapsed, the Information is securely deleted, unless it is necessary for the establishment, exercise or defence of legal claims. For further information regarding applicable retention periods, you should contact us using the contact methods set out below.
INDIVIDUAL RIGHTS REQUESTS
Under certain conditions, you have the right to ask us to fulfil one or more of the following requests. We may ask you for proof of identity or other additional information before doing so.
- Right to access and rectification: You can request details of the Information we hold, along with a copy of your Information, and the correction of any errors in your Information.
- Right to erasure ("right to be forgotten"): The right, in certain circumstances, to ask for your Information to be deleted. In specific cases, we may not be able to delete some types of Information, in particular, where we have a legal obligation to keep that Information (e.g. for regulatory reporting purposes) or, for example, where you want us to continue to provide you with an Offering and the processing of the Information is necessary for the provision of that Offering.
- 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. Please see the "Ad Choices" section below for more information.
- Right to portability: The right in some cases to receive your Information in a digital format or to have it transmitted directly to another controller (where technically feasible).
- Right to object: The right to object (on grounds relating to your particular situation) to the processing of your Information on the basis of our legitimate interests, including for direct marketing purposes.
- Right to withdraw consent: You can withdraw your consent at any time in respect of any processing of Information which is based upon a consent.
We will assess any request to exercise these rights on a case by case basis. There may be circumstances in which we are not legally required to comply with a request because of relevant exemptions provided for in applicable data protection legislation. 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 through our individual rights request portal.
COOKIES AND OTHER TECHNICAL INFORMATION
When you visit our Digital Services, we, third party service providers, and partners may use "cookies" or similar technologies, such as pixels and SDKs to (i) provide, develop, maintain, personalize, protect, and improve our Digital Services and their content (ii) perform analytics, including to analyse and report on usage and performance of our Digital Services and any advertisements displayed on or delivered by or through them (iii) protect against, identify, and prevent fraud and other unlawful activity (iv) create aggregate data about groups or categories of our users (including advertising audiences), and (v) for us, our partners and third party service providers to deliver, target, offer, market, or personalise advertising relating to our Offerings or the offerings of our clients and partners (including limiting how often you see an advertisement).
For many Digital Services in the EEA, WarnerMedia participates in the IAB Europe Transparency & Consent Framework and complies with its specifications and policies on applicable websites and apps. OneTrust operates the consent management platform with the identification number 28.
Marketing communications. We provide you with an opportunity to express your preferences with respect to receiving certain marketing communications from us. If you would like to update these preferences, you can (i) log in to an account you may have created with us to adjust your settings (where the feature is available) or (ii) otherwise submit a request through our individual rights request portal. You can also follow the 'unsubscribe' instructions provided in any marketing email you receive.
Ad choices. On our own or working with affiliates or third parties, we may present advertisements and engage in data collection, reporting, ad response measurement, and site analytics on our Digital Services and on third party websites across the Internet and applications over time. We, our affiliates, or third parties may use cookies, web beacons, pixels, SDKs, or similar technologies to perform this activity. They obtain information about applications you use, websites you visit, and other information from across your devices and browsers and across websites, services, and apps over time, in order to help serve advertising that will be more relevant to your interests on and off our Digital Services and across your devices and browsers. This type of advertising is known as 'interest-based advertising'. We, our affiliates, or third parties may also use this information to associate your different browsers and devices together for interest-based advertising and for other purposes like research, analytics, internal operations, fraud prevention, and enhancing consumer experiences.
In addition to managing your preferences through our own consent management platform, for more information about interest-based advertising on your desktop or mobile browser, and to opt out of this type of advertising by third parties that participate in self-regulatory programs by visiting Your Online Choices if in the EEA, which is hosted by the European Interactive Digital Advertising Alliance (EDAA); if in Australia to the Australian Advertising Alliance (ADAA); and if in Canada, to the Digital Advertising Alliance of Canada (DAAC). To learn more about interest-based advertising on mobile apps in Canada and to opt out of this type of advertising by third parties that participate in the DAAC's AppChoices program, please visit the DAAC tools page to download the version of AppChoices for your device. 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 Information for other purposes, including research, analytics, and internal operations. You can therefore continue to receive advertising, but that advertising may be less relevant to your interests.
You may 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 may 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 enable or 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.
INTERNATIONAL TRANSFERS
We operate internationally, and some of the processes involved in our use of your Information will require your Information to be stored or processed in countries outside the country where you are located, including countries where the level of legal protection for your Information may be different and where you may have fewer legal rights in relation to it. In particular, your Information may be transferred to, and processed in the United States, where some of our systems are located.
Please see our affiliates' page for examples of the countries where your Information may be transferred.
However, whenever we transfer your Information outside of a country or region, such as the European Economic Area, we will make sure that we take steps necessary to comply with applicable legal requirements. Therefore, where required, we will ensure that appropriate safeguards are in place by using appropriate contractual mechanisms, such as the EU Standard Contractual Clauses, or by relying upon the service providers participating in an approved international data transfer mechanism, including the adoption of Binding Corporate Rules. For further information about the documents we use to protect your Information when it is transferred outside of your country or region, please submit a request through our individual rights request portal.
NOTIFICATION REGARDING UPDATES
From time to time, we may update this Privacy Policy. We will notify you about any material changes by placing a notice on our sites. We encourage you to periodically check back and review this policy so that you are up to date.
HOW TO CONTACT US
If you have any questions about this Privacy Policy, you can contact us and our Data Protection Officer through our individual rights request portal.
COMPLAINTS
If you are unhappy with how we have dealt with your query, in the first instance please contact us via our individual rights request portal. If you are still unhappy with our response, you may have the right to complain to your Data Protection Authority. Please contact us through our individual rights request portal to obtain details of how to contact them.