Privacy Policy | Terms of Use

This app is a digital product published and operated by Turner Broadcasting System Europe Limited (“Turner”, “we” or “us”). This privacy policy (“Privacy Policy”) explains our information practices and the choices you can make about the way your information is collected and used by this digital service (the "Service"). We refer to your personal data as "Information".

The Policy is broken down into the following sections.

1. WHO IS RESPONSIBLE FOR YOUR INFORMATION
2. THE INFORMATION WE COLLECT
3. HOW WE USE YOUR INFORMATION
4. INFORMATION SHARING AND DISCLOSURE
5. SDKs AND SIMILARTECHNOLOGIES
6. OTHER IMPORTANT INFORMATION ABOUT YOUR PRIVACY
7. YOUR RIGHTS
8. HOW TO CONTACT US
9. UPDATES & EFFECTIVE DATE

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1. WHO IS RESPONSIBLE FOR YOUR INFORMATION

Turner Broadcasting System Europe Limited is the data controller with relation to the any Information collected by the Service and through your interaction with the Service.

We receive both Information that is directly provided to us, such as personal information you provide when you participate in an activity on the Service, and information that is passively or automatically collected from you, such as usage information collected each time you access the service on a mobile device.

Information You Provide To Us.

In order to participate in an activity on the Service such as a competition, game or other similar activity, you may be required to provide some contact information such as name and email address and other Information such as a photograph or a video, depending on the specific activity.

Additional details about the collecting and processing will be provided at the point of collection and by the specific terms for participating in that activity.

Information That is Passively or Automatically Collected.

We also receive Information when you visit the Service that is automatically collected from your device such as the sections you visit, buttons you tap, IP address, device ID (or equivalent), the name of your Internet service provider, and the type of device and operating system you are using.

We use your Information for the following purposes:

3.1. To fulfil a contract, or take steps linked to a contract pursuant to Article 6(1)(b) of Regulation (EU) 2016/679 (“GDPR”):

(a) to provide the Service and to communicate with you about your account with us where we offer registration;

(b) to send you information about changes to our terms or policies;

(c) to allow you to take part in any competitions that we run from time to time, administer the competition, notify you if you have won, verify your identity, residency and other eligibility requirements, as applicable, deliver the prize and respond to any query you may have around the competition;

(d) to allow you to submit End User Content (as defined in the Terms of Use), and allow us to use the End User Content you submit in accordance with the Terms of Use or other more specific terms which may apply from time to time.

3.2. Where this is necessary for purposes which are in our, or third parties', legitimate interests pursuant to Article 6(1)(f) of GDPR:

These interests are:
(a) to fulfil your requests and inquiries regarding the Service;

(b) to provide technical support (including testing, quality assurance, troubleshooting and security) for the Service;

(c) to analyse how the Service is used including search queries, frequency of viewing and length of viewing time, app launches, section views and taps to help us manage and improve the Service and to develop new services;

(d) to manage the delivery of advertising, including the number of times the same advertisement is served and viewed;

(e) to enforce our policies and terms of use, to check for potential illegal activity (such as copyright infringement or fraud);

(f) to run occasional surveys or market research on the Service to understand our audience;

(g) to set reminders for particular activities, subject to preferences set by the user; and

(h) protecting the safety of our users.

3.3. Where you give us consent pursuant to Article 6(1)(a) of GDPR:

(a) to send you newsletters about our products and services and third party products and services and to use technologies to check if these have been received and opened, in accordance with the additional information provided at the point of collecting your consent;

(b) if you are under sixteen and participate in an activity that requires consent, we will also make reasonable efforts to obtain your parents’ permission to process your Information pursuant to Article 8 of GDPR. We do not knowingly collect Information from anyone under sixteen for these types of activities without giving parents the option to consent to their child’s personal details being included in the applicable database for that activity.

During the period when parental consent is being requested, the Information provided will be held on a temporary basis. If we do not receive your parent’s consent we will delete the information provided by you within a reasonable period in accordance with the specific terms which will be provided with relation to that activity. For purposes of this Privacy Policy, any reference to “parent” shall include legal guardian.

3.4. For purposes which are required by law pursuant to Article 6(1)(c) of GDPR;

(a) in response to requests by government or law enforcement authorities conducting an investigation.

(b) to comply with our legal obligations.

We share your Information:

(a) With service providers we have engaged to perform business-related functions on our behalf. For example, to: (i) conduct research and analytics; (ii) create content; (iii) provide customer support services; (iv) conduct or support marketing; (v) fulfil orders; (vi) host Services; (vii) provide technical or operational support; (viii) administer competitions or other user activity; (ix) maintain databases; and (x) otherwise support the Service;

(b) In response to legal process, for example, in response to a court order or a subpoena, a law enforcement or government agency's request;

(c) With third parties if this will help us to enforce our policies and terms of use, to investigate, prevent take action regarding potential illegal activity (such as copyright infringement or fraud) or to protect the safety of other users of the Services; or

(d) If we, or one of our business units, undergoes a business transition, like a merger, acquisition by another company, or sale of all or part of our assets.

We use SDKs (Software Development Kits) developed by third party companies, and other similar technologies, to help provide the Service and to analyse how you use our Service and to deliver advertising. We also allow authorised third parties to use these technologies for similar purposes.

In short, SDKs used on the service provide audience research/analytics, deliver adverts and measure the delivery of our advertising campaigns

From time to time we may need to allow our service providers or assistance providers, who may be located outside the EEA, access to your Information. We may also make other disclosures of your personal data overseas, for example if we receive a legal or regulatory request from a foreign law enforcement body.

We will always take steps to ensure that any international transfer of information is carefully managed to protect your rights and interests:

(a) we will only transfer your personal data to countries which are recognised as providing an adequate level of legal protection such as Argentina, from where our affiliate Imagen Satelital S.A. provides support, security, infrastructure and maintenance services, or where we can be satisfied that alternative arrangements are in place to protect your privacy rights;

(b) transfers to our service providers and other third parties will always be protected by contractual commitments and where appropriate further assurances, such as standard data protection clauses, certification schemes, provider’s Processor Binding Corporate Rules. and the EU - U.S. Privacy Shield for the protection of personal data transferred from within the EU to the United States of America. We have entered into standard data protection clauses with our US affiliate Turner Broadcasting System, Inc, which provides support, security, infrastructure, maintenance services.

(c) any requests for information we receive from law enforcement or regulators will be carefully checked before personal data is disclosed.

You have the right to ask us for more information about the safeguards we have put in place as mentioned above. Contact us as set out below if you would like further information.

6.2. Retention of Your Information

We will retain your personal data for as long as is reasonably necessary for the purposes listed in Section 3 of this Privacy Policy. In some circumstances we may retain your personal data for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax or accounting requirements.

Where we offer registration, we keep details of users who have registered with us for as long as you use the Service and your user account details for up to 18 months afterwards. We delete user profile information provided to us for the Service automatically when the registration for the Service is cancelled.

If you contact us with support queries, we keep the data for between 3 and 18 months, depending on the nature of the query and whether you have registered with us.

Where we process Information for marketing purposes, we process the Information while you remain interested in the marketing (for example, where you open and read our offers) and for three years after that point. If you ask us to stop sending marketing we will keep your Information for a short period after this (to allow us to implement your requests).

Where we process Information for a competition, we keep the data for 12 months form the day the competition ends unless a longer period is required by law.

Where we process Information with relation to the submission of End User Content, we will keep the data for as long as necessary in accordance with the specific terms of the activity.

You have a number of rights in relation to your personal data. More information about each of these rights is set out below.

You have the right to ask us for a copy of your Information (Article 15 GDPR), to correct (Art. 16 of GDPR), delete (art. 17 of GDPR) or restrict (stop any active) processing of (Article 18 GDPR), your Information; and to obtain the Information you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share this Information with another controller (Article 20 of GDPR).

In addition, as far as the processing of your Information is based on our, or third parties', legitimate interest, you have the right to object to the processing in accordance with Article 21 of GDPR.

In the case of free apps that can be exercised by simply by uninstalling the app from your device and anu data processing will be stopped automatically. The third party app stores may keep a record that you have previously installed the app and if you require to clear that data you will need to address that with app store account provider

These rights to stop the active processing of data may be limited, for example if fulfilling your request would reveal Information about another person, or if you ask us to delete Information which we are required by law to keep or have compelling legitimate interests in keeping.

You can also withdraw your consent in respect of any processing of personal data which is based upon a consent which you have previously provided. You can also opt out of receiving email newsletters and other marketing communications by following the opt-out instructions provided to you in those emails.

To exercise any of these rights, you can get in touch with our Privacy Office using the details set out below in Section 9. Please include your registration information, where we offer registration, such as first name, last name and e-mail address in the request. We may ask you to provide additional information for identity verification purposes. You also have a right to complain to a supervisory authority for data protection in the country where you live, where you work, or where you consider that a breach of data protection has occurred, although we hope that we can assist with any queries or concerns you may have about our use of your Information.

The primary point of contact for all issues arising from this Privacy Policy, including requests to exercise data subject rights, is our privacy office. The privacy office can be contacted in the following ways:

EMEA.privacy@turner.com

Privacy Office
Turner Broadcasting System Europe Limited
Turner House
16 Great Marlborough Street
London, W1F 7HS
United Kingdom

If you have a complaint or concern about how we use your personal data, please contact us in the first instance and we will attempt to resolve the issue as soon as possible. You also have a right to lodge a complaint with your national data protection supervisory authority at any time.

From time to time, we may update this policy. We will notify you about material changes by either sending an email message to the email address you most recently provided to us or by prominently posting a notice on our Service. We encourage you to periodically check back and review this policy so that you know what Information we collect, how we use it, and with whom we share it.

The policy posted on this Service was updated on 23 May 2018.

1. INTRODUCTION

Please read these terms and conditions (“Terms Of Use”) carefully before using this application (“App”). By accessing and using this App, you expressly agree to comply with these Terms Of Use. If you do not agree with any of the below Terms Of Use, do not use this App. This App is controlled and operated by Turner Broadcasting System Europe Limited at Turner House, 16 Great Marlborough Street, London W1F 7HS, United Kingdom ("Turner" “we” or “us”). Our phone number is 020 7693 1000. Turner reserves the right, in its sole discretion, to modify, alter or otherwise update these Terms Of Use at any time. Any changes to these Terms of Use will become effective immediately after their publication on the App We encourage you to review these Terms of Use regularly so that you are familiar with their scope and any changes that may have been made. By using this App after we have published such modifications, alterations or updates, you agree to be bound by the revised terms. Turner retains the right to deny access to anyone who we believe has violated any of these Terms Of Use.

By downloading and using this App, you confirm that you are at least 18 years of age (or have reached the age of majority if that is not 18 years of age where you live) or that you have reviewed these Terms Of Use with your parent or legal guardian and he or she agrees to these Terms Of Use on your behalf and takes full responsibility for your compliance with them. You agree that you (and your parent or guardian) are fully able and competent to enter into and comply with these Terms of Use.

Supplemental terms and conditions may apply to some of the services we provide and will be disclosed to you in connection with the particular services. Those supplemental terms and conditions will be in addition to, not in lieu of, these Terms Of Use, but in the event of any conflict between those supplemental terms and these Terms Of Use, those supplemental terms will prevail to the extent of the conflict.

2. TRADEMARKS, COPYRIGHTS AND RESTRICTIONS

All material on this App, including, but not limited to text, images, illustrations, audio clips, video clips, games and software (“Materials”), is protected by copyrights, trademarks, and other intellectual property rights which are owned and controlled by Turner or by other parties that have licensed their material to Turner. Materials on this App Turner are solely provided for your personal, non-commercial use. Such Materials may not be copied, reproduced, republished, uploaded, posted, transmitted, distributed, decompiled, reverse engineered, or used in any manner, except as expressly permitted by these Terms of Use.

3. LINKS

This App may contain links to other sites ("Linked Sites"). The Linked Sites are for your convenience only, and you access them at your own risk. Turner is not responsible for the content of the Linked Sites, whether or not Turner is affiliated with sponsors of the sites. Turner does not in any way endorse the Linked Sites.

4. ACCOUNTS

As part of the services we provide, you may be able to register for an account (“Account”) and to access the services on this App through your Account. You agree to provide true, accurate, current and complete information about yourself as prompted by our registration processes. You shall not impersonate any person or entity or misrepresent your identity, including using another person’s username, password or other account information. You are responsible for all hardware, software, service and other costs you incur to access your Account. Accounts are available only to individual, natural persons who are adults or, in the discretion of such an adult, his or her minor child.
You shall not share your Account with anyone or allow anyone else other than you personally to access or use your Account. You are responsible and liable for all activities conducted through your Account, regardless of who conducts those activities. If you are a parent or guardian, you may permit your child to use the Account instead of you, provided that parents and guardians are liable for the activities of their child.

Upon registration for an Account, you must create a password (“Password”). You shall not disclose your Password to any third party or allow anyone to use your Password to access the services or your Account. You are responsible for maintaining the confidentiality of your Password and for any damage or harm resulting from your disclosure or allowing the disclosure of your Password or from use by any person of your Password to gain access to your Account. We shall not be liable for any financial or emotional damage or distress you may suffer (and/or subsequent loss or damage to your Account or Account attributes) as a result of the disclosure of your Password to a third party.

5. SUBMISSIONS

a. End User Content

The App may afford you and other end users the means to upload and communicate information, including without limitation, messages, notes, comments, opinions, ideas, photos, drawings, images, videos, profiles, artwork, audiovisual works, musical compositions (including lyrics), sound recordings or other materials (collectively, “End User Content”). As to End User Content, you agree that you are responsible for your End User Content, that you have the right to post any End User Content that you submit through the App, and that any End User Content you communicate or cause to be communicated shall not: (i) infringe the intellectual property, privacy or other rights of any third party; (ii) violate any law, rule or regulation; (iii) be defamatory, indecent, obscene, pornographic, abusive or threatening; (iv) advocate illegal activity; (v) advertise or otherwise solicit funds or is a solicitation for goods or services; (vi) or contain any viruses, trojan horses, disabling code, worms, or other computer programming or routines that are intended to, or which in fact, damage, detrimentally interfere with, monitor, intercept, or expropriate any Materials , data, information, packets, or personal information You agree that we may review, edit and delete any End User Content for any reason, including, in our sole judgment, that the End User Content violates these Terms of Use. Further, you acknowledge and agree that we may take any action we deem appropriate as to any End User Content communicated by you, if we believe, in our sole discretion, that it may expose us to liability, or damage our relationship with any of our suppliers, licensors or other users of the App.

You own your End User Content (except for any Materials and derivatives of Materials incorporated into End User Content). As to all End User Content, you hereby grant to us, our licensees, distributors, agents, representatives and other authorized users, a perpetual, worldwide, irrevocable, assignable, fully-paid, royalty-free licence, fully sub-licensable, to exercise all intellectual property rights, in and to all or any part of your End User Content, and exploit the End User Content by any means, including by creating derivative works of End User Content or for purposes of advertising and promotion, in any medium now known or hereafter developed. For the avoidance of doubt, when you or any other person authorised by you submits material, you agree that Turner has the right to publish or otherwise use the material or any of its elements for any type of use, including promotional and advertising purposes. You agree that you are not entitled to any payment, credit, notice attribution, or other compensation or consideration for any uses of End User Content by Turner. If we facilitate the creation of materials through features or activities on our Apps or through our services (including our “game creator” games, mash-ups, activities, competitions, promotions, forums, etc.) that require the use of our Materials, in whole or in part, we hereby grant to you a non-exclusive licence to create a derivative work using our Materials, but only for the purpose of creating your materials as part of your enjoyment of the services and always in accordance with these Terms Of Use, and you agree that Turner is the owner of such Materials and derivative works. If such rights in derivative works are not assignable to us, then your license to create derivative works using our Materials shall be null and void. You agree to the foregoing whether or not your materials are used by us in any manner.

Turner may review, edit, reject, refuse to post and/or delete any End User Content that in the sole judgment of Turner violates these Terms of Use or which might be offensive, illegal, or that might violate the rights, harm, or threaten the safety of any person. You understand that Turner has the right at all times to disclose any information (including the identity of the persons providing information or materials on this App) as necessary to satisfy any law, regulation or valid governmental request. This may include, without limitation, disclosure of the information in connection with investigation of alleged illegal activity or solicitation of illegal activity or in response to a lawful court order or subpoena. In addition, we can (and you hereby expressly authorize us to) disclose any information about you to law enforcement or other government officials, as we, in our sole discretion, believe necessary or appropriate in connection with the investigation and/or resolution of possible crimes or other actions, especially those that may involve personal injury or the safety of any person.

b. Unsolicited Submissions

Turner does not accept or consider unsolicited submissions of any kind. Any such unsolicited submissions are either discarded or deleted or returned to the sender, in our discretion, without being reviewed (or reviewed solely to the extent necessary to determine that the materials are an unsolicited submission). Therefore, please do not send any unsolicited submissions to us.
From time to time, areas on the App may expressly request submissions of concepts, stories, artwork, audiovisual works or other potential content from you (“Invited Submissions”). Where this is the case, please carefully read any specific rules or other terms and conditions which appear elsewhere on the Apps to govern those Invited Submissions, as they will affect your legal rights. If no such additional terms and conditions are presented, then these Terms Of Use will apply in full to any Invited Submissions you make and Invited Submissions shall be treated as “End User Content.”

In any event, any material, including Invited Submissions, you send to us will not be treated as confidential, and you agree that such materials shall not be subject to any obligation of confidence on the part of Turner, that no confidential or fiduciary relationship is intended or created between you and us in any way, that you have no expectation of review, compensation or consideration of any type, and that Turner shall not be liable for any use or disclosure of any such material.

6. PRIVACY

Any personal information you provide to us when you use our services will be processed in accordance with our Privacy Policy.

7. COPYRIGHT

Turner respects the rights of all copyright holders. If you believe that your work has been copied in a way that constitutes copyright infringement, please contact Turner.

If we determine that the material cited by you constitutes a copyright infringement, we will remove, or “take down” the infringing material.

8. INDEMNIFICATION

You agree, to the fullest extent permitted by law, to indemnify Turner and its officers, directors, employees, agents, distributors and affiliates from and against any and all third party claims, demands, liabilities, costs, or expenses, including reasonable legal fees, resulting from your breach of these Terms Of Use.

9. DISCLAIMER OF WARRANTIES AND LIABILITY

The Materials on this App are provided "as is" and without warranties in relation to the provision of the App services. Neither Turner, nor its affiliated or related entities, nor any person involved in the creation, production, and distribution of this App warrant that the functions contained in the Materials will be uninterrupted or error-free, that defects will be corrected, or that Turner or the server that makes them available are free of viruses or other harmful components. The Materials are provided solely for entertainment and promotional purposes. Turner does not warrant or make any representations regarding the use or the results of the use of the Materials on this App in terms of their correctness, accuracy, reliability, or otherwise.

You expressly agree that except for death and personal injury arising as a consequence of Turner's negligence, neither Turner, nor its affiliated or related entities, nor any of their respective employees, or agents, nor any person or entity involved in the creation, production, and distribution of this App are responsible or liable to any person or entity whatsoever for any loss or damage whatsoever resulting from the use of this App. By way of example, and without limiting the generality of the foregoing, Turner and related persons and entities shall not be responsible or liable for any claim or damage arising from failure of performance, error, omission, interruption, deletion, defect, delay in operation, computer virus, theft, destruction, unauthorised access to or the reliance upon or use of data, information, opinions or other materials appearing on this App. You expressly acknowledge and agree that Turner is not liable or responsible for any defamatory, offensive or illegal conduct of other subscribers or third parties.

10. JURISDICTIONAL ISSUES

Unless otherwise specified, the Materials on this App are presented solely for the purpose of entertainment and promoting programs and other products available in Europe, Africa and the Middle East, their territories, possessions and protectorates. This App is controlled and operated by Turner from its offices in London.

These Terms Of Use shall be governed by, construed and enforced in accordance with the laws of England and Wales. Any action you, any third party or Turner bring to enforce these Terms Of Use or, in connection with, any matters related to this App shall be subject to the exclusive jurisdiction of the courts of England and Wales. If any provision of this agreement shall be unlawful, void, or for any reason unenforceable, then that provision shall be deemed severable from this agreement and shall not affect the validity and enforceability of any remaining provisions. This is the entire agreement between the parties relating to the matters contained herein and shall not be modified except in writing, signed by Turner.

These Terms Of Use were last updated on 21 May 2018.

INTRODUCTION

In May 2018, new data protection laws were introduced across Europe that detail how and when a digital service can track or measure usage by its customers.

As well as making sure you know what information we collect to improve the apps and websites we make (which can be found in our respective Privacy Policies), the new law encourages developers to add easily understood written explanations of what is going on under the bonnet in these services.

As part of our commitment to all our fans, in Europe and beyond, we've now included two sections to this app that will hopefully give you a better understanding of what we do with the data we collect, if you decide to use the service.

Below you will find information on How Ads Work and About Analytics.

((They are not intended to replace the formal legal explanations that you will find in the Terms of Use and Privacy Policy, but have been written to give added reassurance that we take these matters seriously. If you have any questions about our policies you can contact our privacy team at EMEA.privacy@turner.com).

How Ads Work

Advertising has been around since ancient times. The Ancient Egyptians used papyrus to make sales messages, whilst wall posters and commercial messages have been found in the ruins of Pompeii, Rome and Arabia.

The earliest evidence of a mass produced advert is an Ancient Chinese copper printing plate (dating back to the Song dynasty) used to print posters for "JinanLiu's Fine Needle Shop". Etched in the metal is a rabbit logo and the sales slogan: "We buy high quality steel rods and make fine quality needles, to be ready for use at home in no time".

Today ads are part of everyday life and can be seen all around; from billboards, to the sides of buses, in newspapers, on websites and in mobile apps.

Companies who have products or services that they want people to buy, use these adverts to attract new customers or let existing customers know what's new in store.

These companies will also often hire advertising agencies to come up with creative ideas for posters or videos to show off their products and help decide where to advertise to reach the biggest audiences.

And that's where channels like Cartoon Network, Boomerang and Cartoonito come in.

Manufacturers who make toys or children's clothes, for example, often want to ensure that kids are aware of the latest products. Other companies, like film distributors, may want to promote their "products" to the whole family.

So our parent company, Turner, charges these 'third party' organisations to advertise on our TV channels, websites and apps. In other words the manufacturers pays us to display their ads and some of that money helps fund the new shows and games that we release each year.

However, there are also strict rules that we insist our partners follow so that the ads you see in the app are appropriate to the age groups of the kids who use it.

For instance, we will never allow adverts for alcohol or cigarettes or the practice of re-targetting. This is where some companies use information they know about you from your previous web activity to target an ad specifically at you.

Instead, we offer 'anonymous contextual advertising' where an ad agency can pay to have ad banners or video spots based on understanding who that app is aimed at. (E.g. a company selling soccer kit may decide to advertise on a Ben 10 app because they know the game in question is likely to appeal to young boys who enjoy football).

In the background, we will use measurement technologies to ensure that we can report back to the agencies how many times the ads have seen but we don't collect any personal information about you or your family.

In our Privacy Policy we outline the types of tools we use. These allow us to:
- report back to the ad companies how many times their ad was seen,
- monitor how many times an ad was clicked on,
- or to stop you seeing the same ad too often. This is called frequency capping.

We do take this responsibility to our fans very seriously and would encourage you to get in contact if you see any ads that you feel are inappropriate, so we can address this with the ad agencies accordingly.

If you feel uncomfortable about ads appearing as standard or about the measurement information we collect (as described above) we would recommend you uninstall the app by going to your device's app settings section.

If there are other issues about the ads, that are not covered here please contact our privacy team at EMEA.privacy@turner.com.

About Audience Measurement Tools

The new ‘GDPR’ laws that were introduced across Europe on May 25th 2018 are designed to place tighter controls about what information a website owner or app developer can collect, how they can collect it, and how they can use that information to understand how their fans or customers use that service.

This is often referred to as 'performance data' or 'measurement analytics' and a key principle of the new law was to make sure everyone understands upfront what information is being recorded about their digital activities and give our audiences a chance to agree or decline depending on their personal preferences.

The law also states that companies should only collect the data they actually need for the purposes they’ve stated in their Privacy Policies and don’t store up other information without a clear statement of how it will be used.

As part of our commitment to these laws, all our Cartoon Network, Boomerang and Cartoonito services in Europe have been updated to give you greater visibility of how we use Audience Measurement tools, as part of our ongoing production processes.

When people surf the web, access an app or read or leave a message on social media they are making hundreds of little interactions that, if properly analysed, can help developers understand what is working well and what is not, so they can then improve the service for future releases.

But these small interactions quickly multiply, and the more people that use a service, the more information the developers have to wade through – which why it’s often called ‘big data’.

As an example, if you play a game for just one minute you might do about 20 different things. If you played for 30 minutes, that would be 600 actions to interpret relating just to one person. If 5000 other people were also playing at the same time, that’s already 3 million audience data points to measure.

Typically, companies use ‘third party’ Audience Measurement tools, created by established technology firms like Adobe, to then make sense of these millions of different interactions. These technologies help us measure both what happened, and understand why it happened and are usually designed to give a big picture view of a whole group of users rather than information about any one individual.

However, it’s still the developer’s responsibility to decide what gets captured and for how long that information is stored within these Audience Measurement Tools, who has access to it and when that information should be automatically deleted.

On Cartoon Network, Boomerang and Cartoonito websites and apps, we take that very seriously, and have put in lots of measures to ensure we don’t collect any unnecessary information that could lead to a user or fan’s actual identity being revealed. (For instance, where we need an email or contact number for a competition, we will always ask for parental permission first, just to be sure). And we set ‘retention policies’ that all our partners need to adhere, stating when old data needs to be deleted.

We’ve also added new text and pop-ups to our websites and apps so we can help you get more visibility of what is going on behind the scenes.

On European websites, it’s already compulsory for us to show a ‘cookie bar’ when a visitor accesses a website for the first time, and that gives fans a chance to double check what ‘information is been collected by the different ‘cookies’ that are ‘dropped’ on the site. (if in doubt you should always read that specific website’s Cookie Policy).

In apps, it’s not always that straightforward, but we’ve applied the same principle that once you download the app, the first thing you will see is a short notice asking you to acknowledge that you are aware and understand that we use Audience Measurement Tools to monitor how that app is performing.

If you’re not comfortable with us collecting this data and choose not to accept, you will be told that you need to exit the app and will be encouraged to uninstall that app using the device’s App Settings menu.

And we will continue to review our processes every year so we can make sure we’re as clear as we can be to our fans who use the apps now and in the future.

As with all our services you can find out more specific details of the technologies we use in our full Privacy Policy, or, if you have further questions, you can contact our privacy team at EMEA.privacy@turner.com.