Warner Bros. B2B Privacy Policy

Effective Date: 5 March 2019

This Privacy Policy explains how your Information is collected, used, and disclosed by Warner Bros. entities (“we” or “us”). “Information” is defined below and includes information that identifies individuals and devices, among other things. This Privacy Policy 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, 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 from different sources, including that collected by different Warner Bros. entities (e.g. we may combine information collected from a Warner Bros. website with information that we collect at an event or information we receive from our partners).

The Warner Bros. entity with whom you interact is the data controller for the Information we process relating to you. Some websites, mobile apps, and online services (collectively, our “Sites”) have more than one controller that is responsible for your Information. Please see more information here.

Please read this Privacy Policy carefully as it will help you to understand the way that we use your Information and our reasons for doing so. If you have any questions about this Privacy Policy, you can contact us through our individual rights request portal here or at Warner Bros. Privacy Office, 4000 Warner Blvd., Bldg. 3, Burbank, CA 91522 USA.

  1. The way that we use your Information
    1. What Information do we collect?
    2. How do we collect Information?
    3. How do we use Information, and what is our justification for doing so?
    4. How do we share your Information?
  2. Cookies
  3. Retention of your Information
  4. Your rights and how to contact us
  5. Changes to this Privacy Policy
  6. Warner Bros. group affiliates

1. The way that we use your Information

 

A. What Information do 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”. For instance:

If you reach out to us for more information or register on our Sites, we may collect the following information:

  • name;
  • name of the organisation, society or entity that you represent;
  • business/organisation address;
  • business/organisation email address;
  • business/organisation or personal phone number;

We will also collect Information related to use of the Site and any services associated with the Site.  For example:

  • if you are a journalist, we may collect details of press events that you attend or enquire about, or content or materials that you are given access to;
  • if you are a business partner, we may collect information about the services that you provide or services that we provide to you and detailed company Information, which may include specific Information relating to your company’s staff;
  • if you hire our production space (or make an enquiry about the same), we will collect information about the services and facilities that you require.

We may occasionally ask you to disclose relevant sensitive Information such as Information 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 Information, 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 Information in accordance with the terms of this Privacy Policy.

Additionally, if you visit any of our Sites, we will collect the following Information:

  • account and login information, technical information about the way that you use our web or mobile services, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, device information;
  • information about your visit to our Sites and our other websites, including information about how and when you came to visit our Site, how you interacted with the Site and where you went next (including full URLs and methods used to browse away from the Site.

To help us personalise your experience on our Sites, we will also collect other Information such as:

  • information collected from our Sites and elsewhere across the Internet through cookies, pixel tags, device identifiers and other technologies including information about the type of device, browser, and operating system you are using, your Internet service provider or mobile carrier, unique device identifier, 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.
  • information about your interests, preferences and demographics (such as age and gender);
  • location information related to the device that you use to visit our Sites.

B. How do we collect Information?

We (and other organisations that we work with, such as our suppliers and service providers) 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, or express interest in our products at an event;
    • In some cases, it will be mandatory for you to provide this information in order for us to meaningfully be able to respond to your query or provide the information or service that you have requested.  Mandatory data fields will be clearly identified at the time you provide the information.
  • From other sources:
    • We work closely with third parties providing services to us (including, for example, business partners, sub-contractors providing technical services, advertising networks, social networking platforms, analytics providers, search information providers) and we may also receive information about you from them;
    • If you connect your social media accounts via our Sites or any of our apps, certain Information from your social media account will be shared with us which may include Information that is part of your profile or your friends’ profiles;
    • We may combine Information that we collect about you from other sources with the Information that you give to us directly. We may use this combined Information as described in this Privacy Policy.
  • 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.

  • Collecting data from you about other people:

You may be given the opportunity to submit Information about other people.  For example: you may invite them to participate in activities on our Sites, send them a message from our Sites or provide us with a referral. 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. In these cases, please ensure that you notified such individuals that you will share their personal information with us. Please note, when contacting them, we may disclose your identity.

  • Cookies:

If you visit one of our Sites, we may use cookies. For more information about how we use cookies, please see the Cookies section below.

Third party links, sponsors and advertisers.

Our products and services may contain links to other websites or services that are not covered by this Privacy Policy and where information practices may be different from ours.  We do not own or operate these websites or services.  If you click on any of the links on our Sites, you should consult the privacy policies on such third party websites or services before submitting any Information, as we are not responsible for and have no control over the manner in which such websites or services collect, use, disclose, or otherwise process your Information.

We may offer content or programs on our Sites that are sponsored by or co-branded with identified third parties (e.g., competitions, sweepstakes, or promotions).  These third parties can obtain Information that you voluntarily submit to them to make use of the offer.  We are not responsible for the collection and use of your Information by these third parties.  However, you will be informed at the point of collection of such Information, if these third parties will obtain such information, how it will be processed and to whom it will be transferred.

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 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 service related information to you and to send you administrative information such as changes to our terms, conditions and policies;
    • to allow you to participate in interactive features of our Sites or of our services, when you choose to do so;
    • to manage our business relationship, such as the tendering process, contract negotiation, day to day business correspondence, payments and completing due diligence activities.

We use your Information 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).

  • For advertising and marketing purposes, including to measure how effective our marketing is:
    • to send you by email, phone, SMS, MMS or other electronic means information about films, television shows, production facilities, games or other products or services in which you express an interest;
    • to contact you and let you know about other 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);
    • 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 Sites 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 Policy (such as inviting you to events) and to develop an online profile of you;
    • for information on how we use cookies, please see the Cookies section below

In order to contact you directly with marketing, 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 advertising 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.

Where required by applicable law, we will obtain your consent to us contacting you (such as via phone call, email, text or other means.

  • For administrative and internal business purposes:
    • to ensure that content on our Sites is presented in the most effective and relevant manner for you and for your device and to tailor our Sites’ experience and content based on the way that you use the Site;
    • 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, developing new products or services, enhancing our Sites, improving our services and products and identifying usage trends.

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.  We may 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 (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 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 (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 allowed to use your Information only 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 Information appropriately and as required by applicable laws.

By way of example, we may engage service providers to: manage the booking process for hiring production facilities, arrange press events, host the Site or other content or services, operate certain of our Sites’ features, serve advertisements, send emails on our behalf, run our promotions, conduct research, manage and analyse our network status, the responsiveness of our services, and the effectiveness of our advertising, and 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 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:

There may be scenarios where we are subject to a legal obligation to disclose or share your Information, such as: (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.

(v) With your consent:

On some occasion, we may ask for your consent to disclose Information with third parties.

 

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. In particular, your Information may be transferred to, and processed in the United States, where some of our systems are located.

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 EU-U.S. Privacy Shield Framework or 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 here.

2. Cookies

We, and our affiliates, third party service providers, and 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.  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 apps.  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, they let us know about your activity, including whether you received and opened our emails, 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, app, 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, and (v) to synchronise users across devices, affiliates, and partners, and (vi) 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.

Required Cookies

These cookies are required to enable core site functionality.

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.

Functional Cookies

These cookies allow us to analyse site usage so we can measure and improve performance. 

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 apps.  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.

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.

Advertising/Social media cookies

These cookies are used by advertising companies to serve ads that are relevant to you and by social media companies to facilitate your engagement with their platforms.

They are used when you share information using a social media sharing button or “like” button on our Site or apps, or when you link your account or engage with our content on or through a social media site.  The social network will record that you have done this.  This information may be linked to targeting/advertising activities.

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.

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 partners for their direct marketing purposes. If you ever decide in the future that 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, or (ii) submit a request through our individual rights request portal here. To opt out of receiving our email marketing communications, you can also follow the "unsubscribe" instructions provided in any marketing email you receive from us. 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. 

3. Retention of your Information

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 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.

4. Your rights and how to contact us

Subject to applicable data protection laws (such as those in the EU) you may have a the following rights in relation to your Information:

(a) to ask us not to use your Information for direct marketing purposes;
(b) to ask to see what Information we hold about you and to find out about the way that we process your Information (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 Information which is inaccurate;
(d) to ask for Information to be deleted in some (but not all) circumstances;
(e) to ask us to temporarily stop using your Information if you don't believe that we have a right to use it, or to stop us from using your Information;
(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, contact our Data Protection Officer or if you have any queries or concerns about the way that we use your Information (or any questions about this Privacy Policy), please submit a request through our individual rights request portal here.

You also have the right to lodge a complaint with your local data protection authority.

5. Changes to this Privacy Policy

From time to time, we can update this Privacy Policy. We will take reasonable measures to communicate any substantial changes we may make to the Privacy Policy in the future, for example by posting an update on our Sites or sending you an updated version of the Privacy Policy.

6. Warner Bros. group affiliates

Warner Bros. Entertainment Group: Warner Bros. Entertainment Group companies 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 Policy. These companies are listed here. We may update this list from time-to-time, so please check back periodically to keep up-to-date.