Effective Date: 15 June 2020
The Warner Media company with whom you interact is the data controller for the Information we process relating to you.
- The way that we use your Information
- Retention of your Information
- Your rights and how to contact us
- How to Contact Us
1. The way that we use your Information
A. What Information do we collect?
- If you contact us to request information or register on our Sites, we may collect your name, contact details, and information about the/organization you work for and your role within such organization.
- If you are a journalist, we may collect details of press or screening events that you attend, or content that you are given access to.
- If you are a business partner, we may collect information about your services, and Information relating to your organisation’s staff.
We may occasionally ask you to disclose relevant sensitive Information, such as Information relating to your religion or health where such information is needed for the purposes outlined in this Policy (e.g. to host corporate events where food may be served, or to ensure appropriate health and safety measures in our offices or events). If you disclose sensitive Information to us, we will only process it where you have given us your explicit consent to do so, or where we have another lawful basis to do so.
Additionally, if you visit any of our Sites, we may collect the following Information:
- account and login information, technical information about the way that you use our web or mobile services, including the IP address, browser type and device information;
- information about your visit to our Sites and our other websites (such as how and when you came to visit our Site, how you interacted with the Site and what content has been read, viewed or otherwise opened);
To help us personalise your experience on our Sites, we may also collect information about your interests, preferences and demographics (such as age and gender), and location information related to the device that you use to visit our Sites.
B. How do we collect Information?
We may collect Information in a variety of ways, including:
- Directly from you:
- For example, when you register as a user of one of our Sites, express interest in our products, approach us to solicit interest in one of yours, or send us an enquiry.
- From other sources:
- We work closely with third parties providing services to us, and we may also receive Information about you from them.
- From other business contacts, for example by a referral or if you are invited to participate in activities on our Sites or to attend events.
- From publicly available sources.
- Through your browser or device or through our servers:
If you visit our Sites or use our apps, certain Information is collected by most browsers or automatically through your device, and we also collect your IP address (this enables us to recognise your computer or device when you use our Sites) via our server log files.
- Third party links, sponsors and advertisers.
C. How do we use Information, and what is our justification for doing so?
We use your Information for a variety of purposes related to the products and services that we provide to you or procure from you. From a legal perspective, there are various reasons for doing so. We have set out an explanation of this below.
- For purposes related to our business relationship:
- to establish, manage and maintain commercial and legal relationships with you, or the organisation you work for or collaborate with, including in connection with a tendering process, contract negotiation, day to day business correspondence, invoices and payments, and completing due diligence activities;
- to provide you with the information and services that you request or purchase from us or that you provide to us, to communicate with you regarding those services, and to respond to your questions and comments;
- to host corporate events.
We use your Information in this way either because we have a contract with you (or are considering entering into a contract with you), or because it is in our legitimate interests for the conduct of our business activities (for example, to manage the contact, or to be able to communicate with certain groups of people in a 'business to business' capacity in order to promote our products and services).
- For PR, advertising and marketing purposes, including to measure how effective our marketing communication is:
- to contact you and let you know about services we offer that we believe you might want to hear about (e.g. to send you marketing materials that we believe will be of interest to you or your organisation);
- to invite you to view our pre-release or premiere content, and to send you related information, such as press releases and newsletters;
- to measure the effectiveness of our marketing campaigns and our advertising (i.e. so that we can tell what interests people and what doesn't);
- to conduct surveys or obtain your feedback;
We will rely on our legitimate interests to market and promote our business, in order to process your Information for these purposes. However, where required by applicable law, we will obtain your consent to us contacting you.
- For administrative and internal business purposes:
- to tailor our Sites’ experience and content, to administer, monitor and improve our Sites, and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- for our internal business purposes, such as analysing and managing our businesses, audits and developing new products or services;
It is in our legitimate interests as a business to use your Information in this way. For example, we have a clear interest in ensuring that our Site works properly and that our products and services are high quality and efficient.
- For security and legal and compliance purposes:
- as part of our efforts to keep our Sites safe and secure;
- to detect or prevent fraud or other illegal activity;
- as we believe to be necessary or appropriate in each case in order to comply with laws or legal processes (including laws or legal processes in other countries);
- to protect our rights or property (or the rights or property of others), and to enforce or defend our rights and pursue available remedies.
In some cases, we will need to use your Information to fulfil a legal obligation (for example, if we receive a legitimate request from a law enforcement agency), and in other cases (such as the detection of fraud or ensuring the security of the Site) we will rely on our legitimate interests as a business to use your Information in this way.
D. How do we share your Information?
(i) Sharing Information within our group:
We are part of a large global group of companies that share various operations and business processes. Accordingly, we may need to share your Information with any member of our group as part of our business relationship with you, or because it is in our legitimate interests to do so. You can see a list of companies within our group that may receive your Information here.
(ii) Sharing with organisations providing services to us:
We engage various third parties to provide services to us, and this will often mean that we need to share your Information with them for the purposes outlined in this Policy, such as content hosting providers, event organisers and newsletter platforms.
We may also from time to time work with online advertisers, social media platforms and advertising networks to deliver, tailor and measure advertising to you and others both on our Sites and elsewhere on the internet (including on social media platforms).
(iii) Sharing in connection with changes to our group structure or the ownership of our business:
We may need to disclose your 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.
(iv) Sharing to comply with laws or protect our legal interests:
(v) With your consent:
On some occasion, we may ask for your consent to disclose Information with third parties.
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.
When you visit our Sites, we, and our affiliates, third party service providers, and partners may use "cookies" or similar technologies, such as pixels and SDKs to: (i) provide, develop, maintain, personalise, protect, and improve our Sites, apps, products, and services, (ii) perform analytics, including to analyse and report on usage and performance of our content and marketing materials, (iii) protect against, identify, and prevent fraud and other unlawful activity, (iv) create aggregate data about groups or categories of our users, and (v) for us and our affiliates, and partners to target, offer, market, or advertise products, apps, or services. 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. In order to set your cookie preferences, please click on the Privacy Settings/Cookie Preferences button on our site, or use your app/browser settings.
These cookies are required to enable core site functionality.
- 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. If you disable these cookies, some or all of the Site features may not work.
These cookies allow us to analyse site usage so we can measure and improve performance.
- 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 who may use their own cookies or similar technologies for this purpose. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage. To opt-out of Google Analytics relating to your use of our Sites, you can download and install the Browser Plugin available via this link: https://tools.google.com/dlpage/gaoptout?hl=en.
- Functionality cookies or similar technologies:
They allow our Site 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 may also be used to provide services you have asked for, such as watching a video or commenting on a blog.
- Social media timeline:
This cookie allows an embedded social media timeline to appear when you visit the website. Although it may be classified as a “targeting” cookie in some situations, we do not use it to target personalised advertisements.
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.
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.
3. Retention of your Information
4. Your rights and how to contact us
Subject to applicable data protection laws (such as those in the EU) you may have the right to access the Information we hold about you, to request it to be updated, restricted and/or erased, to ask us for a copy of your Information, to request us to transmit it to another controller in a machine readable format and the right to object to the processing of your Information. These rights are not absolute and are subject to various conditions under applicable data protection and privacy legislation and the other laws and regulations to which we are subject.
If the processing of your Information relies on your consent, you also have the right to withdraw your consent at any time.
You also have the right to lodge a complaint with your local data protection authority.
6. How to contact us