LAST UPDATED: 24 MAY 2018
WBSL Privacy Notice
Thank you for your interest in WBSL’s products and services. Whether you have visited our website (the “Site”) or you have submitted your details elsewhere, your personal data has been stored in a database which is controlled and operated by Warner Bros. Studios Leavesden Limited, with its registered address at Warner House, 98 Theobald’s Road, London WC1X 8WB (“we”, “us” and “our”). We are committed to protecting the personal data that we hold and use about you and to respecting your privacy. We are confident that you will find the information that you need set out in this privacy notice, but if you need to know more about the personal data that we hold or the way that we use it, you can contact us by emailing WBPrivacyOffice@warnerbros.com.
The “data controller” of your personal data (in other words, the organisation that determines how your personal data is used) is Warner Bros. Studios Leavesden Limited (details are set out above).
A) What personal data do we collect?
This privacy notice gives you information about the way that we use your “personal data”. Personal data is any information that could be used to identify you in some way (even if, in some scenarios such as online advertising, we don’t know your name). The personal data that we collect from or about you will include the following, depending on the way that you use the Site:
Whenever you visit the Site, we will collect the following personal data:
To help us personalise your experience on the Site, we will also collect other personal data such as:
If you register on the Site, we will also collect the following information:
If you use the Site in connection with services that we provide to you or procure from you, we will also collect information related to those services. For example:
We may occasionally ask you to disclose relevant sensitive personal data such as personal data relating to your health to assist us with the administration and delivery of the services that we provide to you. If you do choose to disclose sensitive personal data, we will only process it where you have given us your consent to do so, or where we have a different lawful basis to do so. We will process that sensitive personal data in accordance with the terms of this privacy notice.
B) How do we collect personal data?
We (and other organisations that we work with, such as our suppliers and service providers) may collect personal data in a variety of ways including:
C) How do we use personal data, and what is our justification for doing so?
We use your personal data 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 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 respond to your questions and comments;|
· to send you by email or other electronic means information about films, television shows, production facilities, games or other products or services in which you express an interest;
· to send service related information to you and to send you administrative information such as changes to our terms, conditions and policies. It’s really important that we are able to send you this kind of information and so we do not give you the option to opt-out of receiving these communications (but we will keep such communications to a minimum);
· to allow you to participate in interactive features of the Site or of our service, when you choose to do so;
· where you choose to receive mobile services and content via SMS, MMS and other mobile services, we use the information collected to deliver such mobile services and content to you, to anticipate and resolve problems with our mobile services and content, to carry out market research, to record sales data and to plan other promotional activities which may be of interest to you.
|We use your personal data in this way either because we have a contract with you (for example, a contract to provide services to you or procure services from you) or because it is in our legitimate interests to do so (for example, it is in our interests to be able to communicate with certain groups of people in a ‘business to business’ capacity in order to promote our products and services) but we will always ensure that your rights are protected.|
|For advertising and marketing purposes, including to measure how effective our marketing is:|
|· to contact you and let you know about other products and services we offer that we believe you might want to hear about (i.e. to send you marketing materials that we believe will be of interest to you). If you would prefer us not to use your personal data in this way please contact us at WBPrivacyOffice@warnerbros.com;|
· 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;
· to make suggestions and recommendations to you and other users of our Site about products, services, promotions and offers that may interest you or them;
· to develop a more direct relationship with you for the purposes described in this privacy notice and to develop an online profile of you;
|In order to contact you directly with marketing (particularly electronically), we may in some cases need to obtain your consent. In other scenarios (for example, where we send direct marketing to anyone in a ‘business to business’ capacity, serving online adverts to you, creating a profile of you to understand more about your interests and preferences; or measuring the effectiveness of our marketing), we will rely on our legitimate interests as a business, always ensuring that your rights are protected.|
|For administrative and internal business purposes:|
|· to ensure that content on the Site is presented in the most effective and relevant manner for you and for your device and to tailor the Site’s experience and content based on the way that you use the Site;|
· to administer, monitor and improve the Site 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, developing new products or services, enhancing the Site, improving our services and products and identifying usage trends.
|It is in our legitimate interests as a business to use your personal data 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. We will always ensure that your rights are protected.|
|For security and legal and compliance purposes:|
|· as part of our efforts to keep the Site 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 our rights and pursue available remedies.
|In some cases, we will need to use your personal data 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 personal data in this way.|
|International transfer of your personal data:|
|· some of the processes involved in our use of your personal data will require your personal data to be stored or processed in countries outside of the European Economic Area. In particular, your personal data will be transferred to and processed in the United States where our central database is operated.||Whenever we send (or permit a third party to send) your personal data outside of the European Economic Area, we will make sure that we take steps necessary to protect your personal data as required by applicable laws. We will ensure that appropriate safeguards are in place by using EU Standard Contractual Clauses or by relying upon the service providers’ participating in an EU approved international data transfer mechanism, including the EU-U.S. Privacy Shield Framework, the adoption of Binding Corporate Rules or another EU approved data transfer mechanism.|
|Third party links, sponsors and advertisers:|
|The Site may contain links to other sites that are not covered by this privacy notice and where information practices may be different from ours. We do not own or operate these sites. If you click on any of the links on the Site, you should consult the privacy policies on such third party sites before submitting any personal data, as we are not responsible for and have no control over the manner in which such sites collect, use, disclose, or otherwise process your personal data.|
We may offer content or programs on the Site that are sponsored by or co-branded with identified third parties (e.g., competitions, sweepstakes, or promotions). These third parties can obtain personal data that you voluntarily submit to them to make use of the offer. We are not responsible for the collection and use of your personal data by these third parties. However, you will be informed at the point of collection of such personal data, if these third parties will obtain such information, how it will be processed and to whom it will be transferred.
D) How do we share your personal data?
We will never sell your personal data or give it to anyone else for them to use for their own purposes without making that clear to you and obtaining your consent where necessary. There are, however, various ways in which we will share your data, as set out below:
(i) Sharing personal data within our group:
We are part of a large global group of companies that share various operations and business processes. We may share your personal data 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 (for example, whilst you may request a service or some information from us, the delivery of that service or information might be fulfilled by another member of our group). You can see a list of companies within our group 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 personal data with them (it is in our legitimate interests to do so, since we may not have the capabilities or commercial reasons to provide these services ourselves). In each case, we will ensure that these third parties are only allowed to use your personal data in order to provide the relevant services to us. We will always make sure that we use organisations that we trust to look after your personal data appropriately and as required by applicable laws.
By way of example, we may engage service providers to: arrange press events, host the Site or other content or services, operate certain of the Site’s features, serve advertisements, send emails on our behalf, run our promotions, conduct customer research, manage and analyse our network status, the responsiveness of our services, and the effectiveness of our advertising, process any online transactions, auditing, and other similar services.
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 the Site and elsewhere on the internet (including on social media platforms such as Facebook and Twitter).
(iii) Sharing data in connection with changes to our group structure or the ownership of our business:
If we sell or propose to sell our business, one of our divisions or affiliates or any part of it, we may need to disclose your personal data to prospective buyers. Similarly, if there are changes to our group structure or if our ownership changes, we may need to disclose your personal data to the new owners or operators of the Site as part of that process.
(iv) Sharing data to comply with laws:
There may be scenarios where we are subject to a legal obligation to disclose or share your personal data, such as with law enforcement agencies or public authorities in order to prevent or detect crime.
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 Site. 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.
Managing cookies and other technologies.
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. Without them, services like enabling appropriate content based on your type of device cannot be provided.||N/A|
These cookies allow us to analyse site usage so we can measure and improve performance
|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 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.||See your browser settings.|
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.
(i) Security of your personal data:
We take the security of your personal data very seriously. We have implemented various strategies, controls and measures to keep your data secure and we keep these measures under close review in line with legal and technological developments.
There are ways that you can help – for example, where we have given you (or where you have chosen) a password which enables you to access certain parts of the Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
(ii) Retention of your personal data:
In broad terms, we will only retain your personal data for as long as is necessary for the purposes described in this privacy notice. This means that the retention periods will vary according to the type of personal data and the reason that we have the personal data in the first place. For example, some personal data 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 data 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 data depending on our legal obligations and whether there is a commercial need. After a retention period has elapsed, the personal data is securely deleted.
Applicable data protection laws give you a number of rights in relation to your personal data and our use of it. You have the right:
a) to ask us not to use your personal data for direct marketing purposes;
b) to ask to see what personal data we hold about you and to find out about the way that we process your personal data (and in some circumstances, you can ask us to provide a copy to a third party);
c) to ask us to correct or update any personal data which is inaccurate;
d) to ask for personal data to be deleted in some (but not all) circumstances where there is no good reason for us to continue to use it;
e) to ask us to temporarily stop using your personal data if you don’t believe that we have a right to use it, or to stop us from using your personal data where there is no good reason for us to continue to use it;
f) not to be subject to decisions made solely on the basis of ‘automated processing’ (i.e. the right not to be subject to decisions made solely by algorithms or computers without input from a human) in certain circumstances.
If you would like to exercise any of the rights listed above, or if you have any queries or concerns about the way that we use your personal data (or any questions about this privacy notice), you can contact us at WBPrivacyOffice@warnerbros.com.
You also have the right to complain about our use of your personal data. You can contact the Information Commissioner’s Office.
Any changes we may make to our privacy notice in the future will be posted on the Site. We may also email you with any changes if we have your email address. Please check back frequently to see any updates or changes to our privacy notice. You can request a copy of the most up to date version of the privacy notice by contacting WBPrivacyOffice@warnerbros.com .
Warner Bros. Entertainment Group: Warner Bros. Entertainment Group companies that agree to be bound by our privacy notice may access the information collected from users on our Site (even from users based in a different territory) and may use that information for the purposes notified to you in our privacy notice.
Australia: Warner Bros. Entertainment Australia Pty Limited
Austria: Warner Bros. Pictures Ges.mbH
Belgium: Warner Bros. Entertainment Nederland BV (Belgian Branch)
Warner Bros. Entertainment Canada Inc.
WB Games Montreal Inc.
France: Warner Bros. Entertainment France S.A.S
Germany: Warner Bros. Entertainment GmbH
Ireland: Warner Bros. Entertainment UK Limited (Ireland Branch)
Italy: Warner Bros. Entertainment Italia S.r.L.
New Zealand: Warner Bros. Features NZ Limited
Netherlands: Warner Bros. Entertainment Nederland B.V
Norway: Warner Bros. Entertainment Norge AS
Poland: Warner Bros. Entertainment Polska Sp z.o.o.
Spain: Warner Bros. Entertainment España SL
Sweden: Warner Bros. Entertainment Sverige AB
Switzerland: Warner Bros. Entertainment Switzerland GmbH
Turkey: Warner Bros Turkey Film Limited Sirketi
Warner Bros. Entertainment UK Limited
Warner Bros. International Television Production Limited
Warner Bros. Television Production UK Limited
Warner Bros. Studios Leavesden Limited
Warner Home Video (UK) Limited
Rocksteady Studios Limited
TT Games Limited
Travellers Tales (UK) Limited
Thompson Place Productions Limited
Burbank Television Enterprises LLC
Warner Bros. Animation Inc.
Warner Bros. Consumer Products Inc.
Warner Bros. Digital Networks Labs Inc. doing business as DramaFever
Warner Bros. Technical Operations Inc.
Warner Bros. Home Entertainment Inc.
Warner Bros. Distributing Inc.
Warner Bros. Entertainment Inc.
Warner Bros. International Television Distribution Inc.
WB Studio Enterprises Inc.
Warner Bros. Worldwide Television Distribution Inc.
WB Games Inc.
New Line Productions, Inc.
Telepictures Production Inc.
MBLC Productions, Inc.
Shed Media US Inc.
Below is a list of affiliates that are Time Warner companies:
E.C. Publications Inc. doing business as DC Entertainment
The Cartoon Network, Inc.
Home Box Office, Inc.
Time Warner Inc.
Turner Broadcasting System
Warner Bros. (South), Inc.