TurnOut Ventures Limited - Privacy Policy


Privacy Policy

We are a joint venture between Turner Entertainment Holdings Asia-Pacific Limited and Outblaze Investments Limited.  We combine and leverage the partner companies’ strengths in content development and mobile applications development to expand the digital portfolios of leading kids’ and youth properties.  Your privacy is important to us.  This Privacy Policy explains the ways we collect, use, store, disclose and manage the personal and non-personal information which you may provide to us in the course of using any of the applications, games or software offered from time to time by us (collectively, the “Services”). We reserve our right to modify our policies and practices from time to time to continue to ensure your privacy is protected.

The Information We Collect

Both Personal Information and Non-Personal Information (together “Information”) may be collected by us while you are using the Services.

Personal Information

For the purpose of this Privacy Policy, “Personal Information" includes information (1) that can be used to specifically identify or contact you (such as your first and last name, account or user name, account number, mailing address, e-mail address or telephone number); (2) about you or your activities or preferences when such information is directly linked to personally identifying information; and (3) that may be used to contact you on-line or off-line.  “Personal Information” may include your unique device or user identifier when that identifier is combined with your personal information. Before we collect any Personal Information from you we will let you know why we require that information, what it will be used for and the class of persons to whom that data may be transferred. For certain uses of that data, we will require you to provide your consent.

Non-Personal Information

For the purpose of this Privacy Policy, “Non-Personal Information" is information that, by itself, does not identify you personally and can include gender, age or interests and cannot be used to get in touch with you.

Non-Personal Information may also include "Aggregate Information", which is data we collect and use to create aggregate statistics about the characteristics and activities of the users and visitors of the Services and to enhance the Services.  Aggregate Information may include demographic information, such as your unique user or user identifier city of residence, information about your computer, software, platform and Internet IP address. We will never match or tie this Aggregate Information to your Personal Information. None of our affiliates or third party agents will be authorised by us to use your Personal Information in this way either.

We collect and use Aggregate Information about the use of the Services to provide the best possible service and to allow us to make certain recommendations and internal reports and share such information with our partners about how our customers use the Services so that our partners can also understand how people use the Services.

How We Use the Information

We may on occasion use Non-Personal Information to improve the design and content of our Services and to improve our visitors' experience of our Services. We may also use and share Aggregate Information with third parties to analyse site usage and to improve our Services.

We may use Personal Information you have provided to fulfill your requests for our Services and to respond to your inquiries about our offerings. We may sometimes use this information to contact you about your account with us (if any).

We may transfer Personal Information and Non-Personal Information and store it outside the jurisdiction in which our Services, or the users of those Services, are located. Although such information will be protected by the security measures described in this privacy policy, it will be also be subject to the local laws of the jurisdiction to which that data is transferred. We will not use or transfer your Personal Information in ways that are materially different from the ones described above without your specific consent.

We never sell, rent, or otherwise share your Personal Information with third parties without appropriate consent although we may engage agents or third party contractors to provide administrative services such as customer support. In these cases, we require the agent or contractor to keep the information provided confidential and to use it only for the specific services they are performing.

If you choose to submit content for publication on our site or as part of the Services, we may publish your screen name and any other information you have provided to us as part of that submission. If a third party complains that a comment you have submitted breaches our Terms of Use (for example, that it may be libelous) then, in accordance with our Terms of Use, we will use our reasonable efforts to contact you and alert you to the situation. If we are required by law to disclose your contact information, we will first attempt to contact you to give you the opportunity to respond. Please refer to our Terms of Use for more information.

We may be required to disclose your Personal Information in response to legal processes, for example, in response to a court order or a subpoena. We may also disclose such information in response to a law enforcement agency’s request, or where we believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Use, to verify or enforce compliance with the policies governing our site or the Services and applicable laws or as otherwise required or permitted by law or consistent with legal requirements.  In addition, we may transfer your Personal Information if we, or one of our business units, are acquired by, sold to, or merged with another company. Agents and contractors who have access to your Personal Information are required to protect this information in a manner that is consistent with this Privacy Policy.  We will not authorise any agents or third parties we engage to use your Personal Information for any purpose other than to carry out the services they are performing for us.

In addition, if you consent or do not object to our use of your Personal Information in direct marketing (please see further details in the "Use of Personal Information in Direct Marketing" section below), we may use your Personal Information to conduct direct marketing activities, such as sending you offers, promotions, rewards, discounts, events and benefits in relation to the Services and products and services offered by our business partners or third party merchants.

The uses outlined above may be carried out by us or one of our affiliated companies or entities.

Cookies & Web Beacons

To enhance your experience with our Services we use “cookies”.  Cookies are text files we place in the browser of your computer or mobile devices to store your preferences.

We use cookies to understand the use of our Services and to improve the content and offerings on those Services. For example, we may use cookies (e.g. to enable us to recognise your computer or other device when you return to our site), save your password in password-protected areas and enable you to use shopping carts on our site.

“Web beacons” or clear .gifs are small pieces of code placed on a web page to monitor the behaviour of, and collect data about, the visitors viewing a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page. We may use web beacons from time to time for this and other purposes.

Only Non-Personal Information is collected by these cookies and web beacons. This Non-Personal Information will not be matched with or tied to your Personal Information by us and none of our affiliates or third party agents will be authorised by us to use your Personal Information in this way either.

Use of Personal Information in Direct Marketing

From time to time, we may conduct direct marketing of the Services through email, direct mails, fax, telemarketing and/or other form of communication to you.  We intend to use your Personal Information for direct marketing carried out by us or one of our business partners or third party merchants.  For the purpose of direct marketing, we shall use your name (including surname and given name), address, telephone number, email address and other information, if any, that you provide to us for offers, promotions, rewards, discounts, events and benefits in relation to the Services and products and services offered by our business partners or third party merchants.  However, we may not use or provide your Personal Information to others unless exempted by the relevant regulations or we have received your consent (which includes an indication of no objection).

You may indicate your consent to the above by ticking the box(es) indicating your consent contained in the relevant communications.  If you do not wish (i) any of your Personal Information to be used in any of the described direct marketing activities, or (ii) to receive from us (a) any promotional and direct marketing materials, (b) any particular types of promotional and direct marketing materials, and/or (c) such materials through any particular means of communication, you can at any time opt-out, free-of-charge, by contacting us at support@turnoutventures.com, following the “opt-out” instructions contained in the relevant communications, or following the instructions in the “How You can Access or Correct Information” section below.

Collection of Information by Third-Party Sites, Ad Servers, and Sponsors

From time to time, the Services may contain links to other sites whose information practices may be different from ours. Visitors should consult those other sites’ privacy policies as we have no control over information that is submitted to, or collected by, those third parties. These third parties may obtain Personal Information that visitors voluntarily submit when they participate in the third party’s site activity. In addition, we have no control over the use of Personal Information you submit to any third parties.

From time to time we may also utilise a reputable third party to present or serve the advertisements that you may see on the Services. These third party advertisements servers may use cookies, web beacons, clear .gifs or similar technologies to help present such advertisements, and to help measure and research the advertisements’ effectiveness. The use of these technologies by these third party advertisements servers is subject to their own privacy policies and is not covered by our privacy statement. We will not provide any of your Personal Information to these third parties. For more information on the use of such third-party advertisements servers on this site or the Services, please contact us at the email address set out below.

Our Commitment to Security

We have put in place appropriate physical, electronic and managerial procedures to safeguard and help prevent unauthorized access to your Personal Information, to maintain data security and correctly use the Information.

Policies Regarding Children Under the Age of 13

Please note that this “Policies Regarding Children Under the Age of 13” section only applies to procedures when collecting information from children under the age of 13.

We recognise the obligation to protect Personal Information obtained from young children.  The Services are not geared toward children under the age of 13 and we do not knowingly collect any Personal Information from such children.  If we collect any personal information (as defined in the Children’s Online Privacy Protection Act (“COPPA”), which was established by U.S. Congress to protect children’s online privacy) from children under the age of 13, we will either (1) comply with the requirements of COPPA and gain prior verifiable parental consent or direct parental notification of the nature and intended use of such information, which shall include an opportunity for the parent to prevent use of the information and participation in the activity; or (2) take all reasonable steps to promptly remove from our files and records such information.  For more information about COPPA and children’s rights to online privacy, please visit the Children’s Privacy section of the Federal Trade Commission’s website at http://www.business.ftc.gov/privacy-and-security/childrens-privacy.

In addition, we advise that children over the age of 13 shall ask their parents for permission before transmitting any of their information to anyone over the Internet, and we suggest parents to tell their children not to provide their personal information, without permission, when using the Internet.

What types of information do we collect from children?

We mainly collect persistent identifier (such as an IP address, mobile device id, or a unique device identifier) from the child.  We may also collect the email address of the child.

Please note that all sites that are directed to children under the age of 13 are prohibited by COPPA from conditioning a child’s participation in an online activity on the child’s disclosure of more personal information than is reasonably necessary to participate in the activity.

How do we use and share the personal information collected from children?

We use the collected persistent identifier for the sole purpose of providing support for internal operations of the Service, including activities necessary for us to maintain or analyze the functioning of the Services, authenticate users or personalize content, serve contextual advertising or cap the frequency of advertising, protect the security or integrity of the user or the Service, or ensure legal or regulatory compliance.

The collected persistent identifier is not shared with other third parties.  However, we may, from time to time contract with certain third party service providers to provide support for the internal operations of the Service.  Your child’s personal information is not used or disclosed by these contracted third party service providers except for the limited service for which they have been contracted.

We collect a child’s email address in connection with a question emailed to us by the child for the sole purpose of communicating with the child on a one-time-only basis (e.g. responding to a question from the child).  We will not use or disclose such information to re-contact the child or for any other purpose, and such information will be deleted from our records promptly after responding to the child’s request.  If we choose not to respond to the child’s request, we will immediately delete the child’s information.

How can parents review or delete personal information about their child?

At any time, parents of children under the age of 13 may review or delete personal information about their children from our records, or refuse to permit our further collection or use of such personal information.  Please contact us at support@turnoutventures.com if you would like to review or delete your child’s personal information, or to inform us about your refusal to permit our further collection of such personal information.

Whenever a parent requests a deletion of his or her child’s personal information, we will use reasonable efforts to delete the child’s information from our records as much as possible and will not collect any other personal information from such child.  Please note that there may be residual information that will remain in our records that may or may not contain the personal information that was requested to be deleted.  Such residual information will not be disclosed or shared with any other third party or used for any commercial purpose.

Changes in our Privacy Policy Regarding Children Under the Age of 13?

We may amend our Privacy Policy Regarding Children Under the Age of 13 at any time.  We will provide parents notice by e-mail of any material changes in the way we intend to collect, use, and/or share a child’s personal information.  Please note that, at all times, parents should update their personal information to provide us current e-mail addresses.  We will apply material changes in our Privacy Policy Regarding Children Under the Age of 13 only in conformance with applicable law, including any applicable provisions of COPPA that require parental consent.

Contact us

If you have any other questions about our Privacy Policy for Children Under the Age of 13, including our practices in relation to children’s personal information, in particular collecting or maintaining such personal information, please contact us at:

TurnOut Ventures Limited
Unit 411-415, Cyberport 1, 100 Cyberport Road, Pokfulam, Hong Kong
Attention: Legal Department

or send us an email at: support@turnoutventures.com
Or call us at: +852 2534 1222

Your Options

You may not wish to disclose any of your information, even though such information may be necessary to take advantage of or register for certain features of the Services.  Please let us know at support@turnoutventures.com if you decide to opt out from receiving direct marketing materials from us or not to receive email or other mail from us in the future.  If you do not wish to receive any legal notices from us, including this Privacy Policy, such legal notices will continue to govern your use of the Services, and you are responsible for reviewing such legal notices for any changes.

How You can Access or Correct Information

If you would like to know what Personal Information we hold for you at any time, amend that information or request that it is deleted, or if you have any questions, comments or concerns regarding this Privacy Policy, you can do so by contacting us by e-mail at  support@turnoutventures.com  or by writing to us at the following postal address:

TurnOut Ventures Limited
Unit 411-415, Cyberport 1, 100 Cyberport Road, Pokfulam, Hong Kong

Updates & Effective Date

From time to time, we may update this Privacy Policy. We will notify you about material changes in the way we treat Personal Information by placing a notice on the site.  We encourage you to check back periodically and review this Privacy Policy so that you will always know what information we collect, how we use it and to whom we disclose it.

The Privacy Policy was last updated and posted on this site on 17 October 2013.