Last Updated: November 2018
I. SCOPE OF THIS POLICY
Thank you for visiting us.
Your privacy is important to us. One Animation collects, uses and discloses Personal Data (as defined below) in order to provide a rewarding online experience for all visitors. “Personal Data” means information that identifies you such as name, photo or contact details or data that can be linked with such information in order to identify you. Personal Data does not include data where your identity has been removed, which is known as “Anonymous Data”.
II. THE TYPES OF PERSONAL DATA WE COLLECT
The types of Personal Data that we collect depend on the circumstances of collection and on the nature of the service required or transaction undertaken.
There are 10 broad categories of Personal Data collected by us:
- a. Identity Data, which includes your first name, last name, country of residence, gender, age and/or date of birth.
- b. Contact Data, which includes your email address and/or telephone number.
- c. Profile Data, which includes your username, password, favourite character, shopping preferences and/or your public posts in public forums on our Sites and Applications.
- d. Social Media Data, which includes information about you on third-party social media sites and applications, such as your username, profile picture, information about friends and followers, and/or content posted or viewed through the third-party social media sites and applications.
- e. Electronic Postcard Data, which includes the first name and email address of the intended recipient of the electronic postcard or email function available on our Sites and Apps. We collect Electronic Postcard Data where this is provided by you, and only in connection with sending the electronic postcard or email to its intended recipient.
- f. Payment Data, which includes your credit card details.
- g. Transaction Data, which includes your billing address, your mailing address or the mailing address of the intended recipient of your order, and/or details about orders and payments from you.
- h. Technical Data, which includes your Internet Protocol (IP) address, domain name of your Internet Service Provider, type of mobile device you use, your mobile device’s unique ID, type of mobile or computer operating system you use and/or type of mobile or computer browser you use.
- i. Location Data, which includes details about your location obtained from your mobile device or computer browser.
- j. Usage Data, which includes information about how you use our Sites and Apps (including which of our Sites you have accessed or which games you have played), and/or advertisements that you have been shown on our Sites and Apps.
We do not typically collect any Special Categories of Personal Data about you (which are details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data), nor do we typically collect any data relating to criminal convictions and offences.
If you provide us with any information or material relating to another individual, you must make sure that the sharing with us and our further use as described to you from time to time is in line with applicable laws, so for example you should duly inform that individual about the processing of his/her Personal Data and obtain his/her consent, as may be necessary under applicable laws.
How we collect your Personal Data
We collect your Personal Data as follows:
- a. Directly from you. You may provide us with your Identity, Contact, Profile, Payment, Transaction as well as Electronic Postcard Data when you do any of the following:
- (i) create an account on the “Join Us” page on our Sites, or when you register and create an account via our Apps;
- (ii) contact us to obtain customer service support for some features of our Sites or to give us some feedback;
- (iii) participate in sweepstakes, contests, games, campaigns, message boards, chat rooms, profile pages, online polls, surveys or social community environments;
- (iv) subscribe to informational and promotional offers;
- (v) request marketing materials to be sent to you;
- (vi) order merchandise or virtual items from our Sites;
- (vii) participate in a voluntary survey conducted by us regarding your personal shopping preferences; or
- (viii) send an electronic postcard or email using the electronic postcard or email function available on our Sites and Apps.
- b. When you interact with our Sites and Apps. We collect your Technical and Usage Data when you interact with our Sites and Apps. We may collect such data by using website cookies. We may also collect your Location Data when you interact with our Sites and Apps. We usually do not collect precise information about your location and would do so only if you have specifically provided us with your consent to do so. You can manage your location preferences at any time by adjusting the relevant settings on your computer or mobile device.c. From third parties. We may receive your Social Media, Technical and Location Data from various third parties including:
- (i) analytics providers (such as Google and Hotjar) based inside or outside the EU;
- (ii) advertising networks (such as Outbrain) based inside or outside the EU; and
- (iii) social media platforms (such as Facebook, Twitter and LinkedIn) based inside or outside the EU.
What happens if we are not provided with your Personal Data
If you do not provide the Personal Data necessary or withdraw your consent (where given) for the processing of your Personal Data, where such data is necessary in order for us to provide our Sites, Apps, products and services to you, we will not be able to provide them to you.
However, in circumstances where the data is not necessary for us to provide our Sites, Apps, products and services to you, there will be no impact our provision of the Sites, Apps, products and services if you do not provide your Personal Data or withdraw your consent.
III. HOW WE USE THE PERSONAL DATA
We may use your Personal Data for the following purposes:
- a. to register you as a new user;
- b. to provide you with the experiences, products, and services you request, view, engage with, or purchase
- c. to personalise and deliver relevant content and experiences to you;
- d. to enable you to participate in sweepstakes, contests, games, campaigns, message boards, chat rooms, profile pages, online polls, surveys or social community environments;
- e. to manage our relationship with you, including to communicate with you about your account or transactions with us;
- f. to make suggestions and recommendations about our products or services, or third-party products or services that may be of interest to you;
- g. to send you relevant information about our events, news, announcements or promotions;
- h. to deliver relevant advertisements to you, as well as to measure or understand the effectiveness of such advertisements;
- i. to operate, understand, optimize, develop, or improve our Sites, Apps, products, services and operations, including by using guest survey research and data analytics tools;
- j. to detect, investigate and prevent activities that may violate our policies or be illegal; and
- k. where we have to use your personal data for another purpose as required by law or regulation – for example, to respond to administrative, judicial or law enforcement requests or to comply with applicable laws and regulations.
If you are located in the European Economic Area (“EEA”) or Switzerland, we will only process your Personal Data for the above purposes when we have a valid ground for the processing, including if:
- a. we need your Personal Data to provide you with products and services, or to respond to your queries;
- b. where the processing is necessary for our legitimate interest or those of a third party, which may include:
- (i) ensuring and improving the safety, security and performance of our Apps, Sites, products and services;
- (ii) protecting against and preventing fraud; and
- (iii) anonymising your Personal Data to carry out data analyses, and your interests and fundamental rights do not override these interests;
- c. where we need to comply with a legal or regulatory obligation; or
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at firstname.lastname@example.org. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis (where required under applicable law) which allows us to do so.
Promotion offers and marketing
You can ask us or third parties to stop sending your marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time at email@example.com.
IV. SHARING YOUR PERSONAL DATA WITH OTHERS
We do not share your Personal Data with third parties except in limited circumstances, as set out below.
External third parties
- a. We share your Personal Data with companies that perform functions on our behalf and who also provide services to us, including package delivery service providers, marketing and advertising companies, customer service providers, IT service providers, cloud service providers, data storage providers, and other professional advisors.
- b. We may share your Personal Data with our business partners to offer co-branded products or services to you.
- c. With your consent, we may share your Personal Data with carefully selected companies so that they can send you offers and promotions about their products and services.
- d. Where directed to do so by you, we may share your Personal Data with third-party sites or platforms, such as social networking sites.
- e. We may share your Personal Data with third parties to comply with a legal obligation, when we believe in good faith that an applicable law requires it, at the request of government authorities conducting an investigation, to verify or enforce our contractual rights or other applicable policies, to detect and protect against fraud or any technical or security vulnerabilities, to respond to an emergency, or otherwise to protect the rights, property, safety or security of third parties and visitors to our website or the public.
- f. As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or merges with us, your Personal Data will be disclosed to such entity. Also, if any bankruptcy or reorganisation proceeding is brought by or against us, all such information will be considered an asset of ours and as such it is possible, they will be sold or transferred to third parties.
We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes, and we only permit them to process your Personal Data for specified purposes and in accordance with our instructions.
V. DATA SECURITY, INTEGRITY AND RETENTION
The security, integrity, and confidentiality of your information are extremely important to us. We have implemented appropriate technical, administrative, and operational measures that are designed to protect your information from unauthorised access, disclosure, use, and modification. We regularly review our security procedures to consider appropriate new technology and methods. Please be aware that, despite our best efforts, no security measures are perfect or impenetrable.
We only retain your information for as long as is necessary for us to use your information as described above, where it is in our legitimate interest, or to comply with our legal obligations. However, please be advised that we may retain some of your information after you cease to use our services, for instance if this is necessary to meet our legal obligations, such as retaining the information for tax and accounting purposes.
When determining the relevant retention periods, we will take into account factors including:
- a. contractual obligations and rights in relation to the information involved;
- b. legal obligation(s) under applicable law to retain data for a certain period of time;
- c. our legitimate interest where we have carried out a balancing test;
- d. statute of limitations under applicable law(s);
- e. (potential) disputes;
- f. if you have made a request to have your information deleted; and
- g. guidelines issued by relevant data protection authorities.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
VI. INTERNATIONAL DATA TRANSFERS
One Animation operates globally and so it may be necessary to transfer your Personal Data to other One Animation’s service providers or business partners in countries outside of your country.
We may need to transfer personal data outside of your country, including to:
- a. Hong Kong;
- b. Singapore;
- c. the United Kingdom; and
- d. the United States of America.
If you are a user in the EEA:
When we send your information to a country that is not in the EEA, we will make sure that your Personal Data is properly protected. We will always ensure that there is a proper legal agreement that covers the data transfer. If a country is not considered to have laws that are equivalent to European Union data protection standards, we will ask the third-party service provider to enter into a legal agreement that reflects those standards.
If you are a user in a country outside the EEA:
We may need to transfer personal data outside of your country. When we send your information from a country (not in the EEA) outside of that country, we will make sure that your information is protected to at least the same standard as that which is required in the originating country. For example, we will always ensure that there is a proper legal agreement that covers the data transfer.
VII. COOKIES AND WEB BEACONS
“Web beacons”, clear. gifs or similar technologies are small pieces of code placed on a web page to monitor the behaviour 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, our third-party service providers and/or our partners may use web beacons on our Sites or Apps from time to time for this and other purposes.
VIII. LINKS TO THIRD-PARTY SITES, AD SERVERS AND SPONSORS
Our Sites and Apps contain links to other websites, including those of sponsors and advertisers, whose information practices may be different from ours.
IX. CHILDREN’S PRIVACY
Our Sites and Apps are not directed at children under the age of 16. If you have reason to believe that a child has provided Personal Data to us, please contact us at firstname.lastname@example.org, and we will endeavour to delete the child’s Personal Data from our databases.
X. CHANGES TO THIS POLICY
By communicating with One Animation, using our Sites and Apps or purchasing products from us, you acknowledge that you have read and understood this Policy and agree and consent to the use, processing and transfer of your Personal Data by One Animation as described in this policy.
One Animation shall have the right to modify, update or amend the terms of this policy at any time by placing the updated policy on our Sites. By continuing to communicate with One Animation, continuing to use our Sites and Apps, or purchasing products from us following the modifications, updates or amendments to this policy, such actions shall signify your acceptance of such modifications, updates or amendments.
For information collected on our Apps, you can stop all collection of information by the App easily by uninstalling it from your device. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. If you would like to opt out and stop receiving marketing communications from us, you may follow the “unsubscribe” instructions provided in any marketing email or for mobile device push notifications, you can manage your preferences either through your device or App settings depending on the type of device.
XII. YOUR RIGHTS
You have a number of rights under applicable law when it comes to your Personal Data. If you’d like to exercise any of your rights in relation to your Personal Data on our Sites and Apps, please contact us at email@example.com. To protect your privacy and security, we will take reasonable steps to verify your identity before processing your request. Please note that some or all of the user data provided may be required in order for our Sites or Apps to function properly, and we may be required to retain certain information by law.
Further information and advice about your rights can be obtained from the data protection regulator in your country.
|Right||What does the right entail?|
|1. The right to object to processing||You have the right to object to certain types of processing, including processing for direct marketing (i.e. if you no longer want to receive promotional emails from us).|
|3. The right to rectification||You are entitled to have your Personal Data corrected if it is inaccurate or incomplete.|
|4. The right to erasure||This is also known as ‘the right to be forgotten’, which enables you to request the deletion or removal of your Personal Data where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions – for example, this does not apply if processing of data is necessary for us to comply with legal obligations or handle legal claims.|
|5. The right to restrict processing||You have rights to ‘block’ or suppress further use of your Personal Data. When processing is restricted, we can still store your Personal Data, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.|
|6. The right to data portability||You have rights to obtain and reuse your Personal Data for your own purposes across different services. For example, if you decide to transfer your Personal Data to another animation studio, this enables you to move, copy or transfer your Personal Data easily between our IT systems and theirs safely and securely, without affecting its usability.|
|7. The right to lodge a complaint||You have the right to lodge a complaint about the way we handle or process your Personal Data with your national data protection regulator.|
|8. The right to withdraw consent||If you have given your consent to anything we do with your Personal Data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your Personal Data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your Personal Data for marketing purposes.|
We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for baseless or excessive/repeated requests, or further copies of the same information. Alternatively, we may be entitled to refuse to act on the request.
Please consider your request responsibly before submitting it. We’ll respond as soon as we can. Generally, this will be within one month from when we receive your request, but if the request is going to take longer to deal with, we’ll come back to you and let you know.
XIII. CONTACT US
One Animation Pte Ltd
305 Alexandra Road
Vantage Automotive Centre
#05-05 Singapore 159942