Privacy Policy
PRIVACY POLICY
Thank you for visiting www.turneraccess.com, a site operated by Turner Broadcasting System Europe Limited (“Turner”, “we” or “us”). This privacy policy (“Privacy Policy”) explains how we use information we collect about you and the choices you can make about the way your information is collected and used by us and among members of the Turner group (“Turner Affiliates”). Please take the time to read the full Privacy Policy.
1. Who is responsible for looking after your personal data?
The personal data collected by the website and your interaction with the service is collected by Turner Broadcasting System Europe Limited who acts as the data controller.
You should be aware that although Turner will be principally responsible for looking after your personal data, information will be shared with other Tuner Affiliates. When processing your personal data, the Turner Affiliates will comply with the standards set out in this Privacy Policy.
A list of Turner Affiliates with which information is shared is available at section 4 of this Privacy Policy.
2. Information we collect
We receive both information that is directly provided to us, such as personal information you provide when you contact us, and information that is passively or automatically collected from you, such as usage information collected from your browser or device. In this Privacy Policy, we refer to all of this as the “Information”.
Information You Provide To Us. The types of information that may be collected from you include your name, surname, e-mail address, the company/airline you work for, your role, your country, and your phone number.
Information That is Passively or Automatically Collected. We collect various types of Information about you such as clicks, page views, IP address, the type of browser you are using, what content has been read or opened, what content you interact with and what links you follow.
3. What do we use your personal data for?
In order to perform a contract with you or take the necessary steps prior to entering into a contract with you or the entity you represent, including:
• processing your registration request for the restricted area of the site;
• performing operational tasks such as registration, login and authentication, password reset and recovery;
• providing the services and communicating with you about them or your account with us;
• sending you information about changes to our terms or policies;
• fulfilling your requests and responding to your inquiries.
Where the use of your Information is necessary for the purposes of our, or a third party's (including Turner Affiliates), legitimate interests, including:
• providing technical support (including testing, quality assurance, troubleshooting and security) to the services;
• performing analysis regarding how the services on this site are used;
• preventing fraud or potentially illegal activities (including, without limitation, copyright infringement) on or through the site;
• enforcing the legal terms (including without limitation our policies and terms of service) that govern your use of the site;
• protecting the safety of our users;
• creating contact information directories;
• keeping in touch with you with the latest news from us.
For purposes which are required by law:
• in response to requests by government or law enforcement authorities conducting an investigation;
• complying with our legal obligations.
Where you give us consent:
• to send you New Release Alerts.
4. Who do we share your personal data with?
We may disclose the Information as follows:
To service providers that we have engaged to perform business-related functions on our behalf. This may include service providers that: (a) conduct research and analytics; (b) provide customer, technical or operational support; (c) conduct or support marketing (such as email platforms); (d) fulfill orders and user requests; (e) handle payments; (f) host our services, (g) maintain databases; (h) otherwise support our Services.
In response to legal process, for example, in response to a court order or a subpoena, a law enforcement or government agency's request or similar request.
With third parties in order to investigate, prevent, or take action (in our sole discretion) regarding potentially illegal activities, suspected fraud, situations involving potential threats to any person, us, or the services, or violations of our policies, the law or our Terms of Use, to verify or enforce compliance with the policies governing our services.
We may also share Information where it is necessary for compliance with a legal obligation to which we are subject, for example, if we are required to disclose Information to a law enforcement agency.
We may transfer some or all of your Information 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, or if a substantial portion of our or of a business unit’s assets is sold or merged in this way.
We may share the Information with Turner Affiliates (as listed below), to better tailor our services to you, administer and appropriately process your requests, including, when you subscribe to this site, order a product or service, or request further information, and for internal reporting, so they can communicate directly with you about the products and services that you require or may be of interest to you.
List of Turner Affiliates
Below is a list of the Turner Affiliates with which we share Information on the terms set out in this Privacy Policy. We may update this list from time-to-time, so please check back periodically to keep up-to-date.
Hong Kong - Turner International Asia Pacific, Limited
USA - Turner International Latin America, Inc.
5. International Transfers
From time to time we may need to share your personal data with Turner Affiliates who may be based outside of the European Economic Area ("EEA"). We may also allow our service providers or assistance providers, who may be located outside the EEA, access to your personal data. 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:
• we will only transfer your personal data to countries which are recognised as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights;
• in respect of transfers to Turner Affiliates located outside the EEA in countries which are not recognised as providing an adequate level of legal protection, we will enter into standard data protection clauses with these entities to ensure the safety of your information;
• 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 and certification schemes - for example, the EU - U.S. Privacy Shield for the protection of personal data transferred from within the EU to the United States of America; and
• any requests for information we receive from law enforcement or regulators will be carefully checked before personal data is disclosed.
6. How long do we keep your personal data?
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.
In specific circumstances we may also retain your personal data for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges.
If your personal data is no longer required we will ensure it is either securely deleted or stored in a way which means it will no longer be used by us.
When you have registered for our restricted area we will keep your registration details for as long as you use the Service and for up to 12 months afterwards.
If you ask us to stop sending New Release Alerts or other marketing communication, we will keep your Information for a short period after this (to allow us to implement your requests).
7. Cookies and similar technologies
We use cookies and other similar technologies for purposes such as improving the functionality of our website, letting you navigate between pages efficiently and analysing how you use our services. We also allow third parties to use these technologies for similar purposes. Please see our Cookie Policy [hyperlink to cookie policy] for more information.
8. What are your rights?
You have a number of rights in relation to your personal data. More information about your rights is set out below.
Access. You can ask us to: confirm whether we are processing your personal data; give you a copy of that data; provide you with other information about your personal data such as what data we have, what we use it for, who we disclose it to, whether we transfer it abroad and how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your data from and whether we have carried out any profiling, to the extent that such information has not already been provided to you in this Privacy Policy.
Rectification. You can ask us to rectify inaccurate Information. We may seek to verify the accuracy of the data before rectifying it.
Erasure. You can ask us to erase your personal data, but only where: it is no longer needed for the purposes for which it was collected; you have withdrawn your consent (where the data processing was based on consent); following a successful right to object (see 'Objection' below); it has been processed unlawfully; or to comply with a legal obligation to which we are subject.
We are not required to comply with your request to erase your personal data if the processing of your personal data is necessary: for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims. There are certain other circumstances in which we are not required to comply with your erasure request, although these two are the most likely circumstances in which we would deny that request.
Restriction. You can ask us to restrict (i.e. keep but not use) your personal data, but only where: its accuracy is contested (see Rectification), to allow us to verify its accuracy; the processing is unlawful, but you do not want it erased; it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; you have exercised the right to object, and verification of overriding grounds is pending.
We can continue to use your personal data following a request for restriction, where: we have your consent; to establish, exercise or defend legal claims; or to protect the rights of another natural or legal person.
Portability. You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it 'ported' directly to another data controller, but in each case only where: the processing is based on your consent or on the performance of a contract with you; and the processing is carried out by automated means.
Objection. You can object to any processing of your personal data which has our 'legitimate interests' as its legal basis (see Section 3), if you believe your fundamental rights and freedoms outweigh our legitimate interests.
Once you have objected, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
Withdrawal of Consent. You can withdraw your consent in respect of any processing of personal data which is based upon a consent which you have previously provided. You can withdraw your consent by contacting us using the details provided below.
International Transfers. You can ask to obtain a copy of, or reference to, the safeguards under which your personal data is transferred outside of the European Economic Area. We may redact data transfer agreements or related documents (i.e. obscure certain information contained within these documents) for reasons of commercial sensitivity.
Supervisory Authority. You have a right to lodge a complaint with your local supervisory authority about our processing of your personal data. In the UK, the supervisory authority for data protection is the ICO (https://ico.org.uk/).
We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
To exercise your rights you may contact us as set out in Section 9. Please note that if you do wish to exercise these rights we reserve the right to ask you for proof of your identity if you make a request. We aim to respond to any valid requests within one month unless it is particularly complicated or you have made several requests, in which case we aim to respond within three months. We will let you know if we are going to take longer than one month.
9. Contact and complaints
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:
Privacy Office
CNN Inflight
CNN International Commercial
160 Old Street
London, EC1V 9BW
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.
10. Updates & Effective Date
From time to time, we may update this Privacy 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 will always know what information we collect, how we use it, and with whom we share it.
This Privacy Policy was updated in May 2018.
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