PRIVACY POLICY
PRIVACY POLICY
Also see our Terms Of Use and Cookie Policy.
Updated: July 22, 2021
This Privacy Policy explains what personal information Dust Studios LLC and/or its subsidiaries or affiliates (“Dust”, “we”, “us”, “our”) collect, use, share and otherwise process about individuals (“you”) interacting with our Offerings (“Information”). Also, this Privacy Policy does not apply to Digital Services that are online services targeted at children.
Dust is an affiliate of the WarnerMedia group of media and entertainment companies, as well as an affiliated group of businesses with a number of different legal entities and business units. In this Privacy Policy, the “Controller” of your Information means the company that decides the purposes for which it is processed and how it is processed. Which company is the Controller in relation to the processing of your Information will depend on which Offering you are using; it will often be the company responsible for providing that Offering, as may be set out in our terms and conditions.
In some circumstances, more than one Controller may be responsible for processing your Information, for example, where Information is shared with other companies affiliated with Dust for a purpose set out in this Privacy Policy. Please navigate to our Controller List for more details. If you still have questions about the relevant Controller, please contact us using one of the methods set out below.
Under the laws of some countries outside the European Economic Area, we may need your consent to our processing of your Information set forth in this Privacy Policy. Subject to any indications you may give us to the contrary, such as opting out or not opting in if asked, and where permitted by law, by providing Information or otherwise interacting with our Offerings, you consent to our use of Information in accordance with this Privacy Policy.
TABLE OF CONTENTS
SCOPE OF THIS PRIVACY POLICY
Please read this policy carefully. It explains the types of Information we may collect about you, the purposes for and methods by which we collect it, and (where applicable) the lawful basis on which we do so, as well as information about data retention, your rights and how to contact us. This Privacy Policy covers both our online and offline data processing activities, including Information that we collect through our various Offerings such as those set out below:
Digital Services:
Please note that we may combine Information that we collect via one source (e.g. a Dust website) with Information we collect via another source (e.g. a mobile app), including with Information possibly collected by a different company affiliated with Dust, or a third party (as further described below). Please also note our Offline Services may involve you interacting with our Digital Services and vice-versa, for example, where you book a studio tour or your participation to a marketing event through a Dust website. Certain Dust Offerings (for example, some online stores, and in-app purchases) are not operated by Dust but by a third party licensee or the app store; any processing of your personal information by such a licensee or app store is not subject to this Privacy Policy, so please check carefully whether the relevant terms and conditions refer to a Dust company or not.
THE INFORMATION WE COLLECT
We collect, use, share and otherwise process the following categories of Information:
1) Information we may collect from you:
2) Information we may collect about you, from other sources, including friends:
Information from other sources. On occasion, we combine Information with other online information we receive, including usage information about your interactions with other websites and with online advertising and media. We also supplement or combine Information with Information from a variety of other sources or outside records, including third-party data providers that provide us with Information such as demographics, transaction and purchase history; Information about the content and advertisements you interact with. We may also receive Information about you from your friends who invite you to interact with any of our Digital Services. We may receive Information from third parties with which you have a subscription agreement that includes access to our content or services.
Information from friends. In certain situations, we may enable friends using our Offerings to provide Information about you. For example, someone can submit Information on our websites to invite you to participate in an Offering, make recommendations or share content through one of our apps, or have multiple players sharing the same game session. By processing these requests, we may receive your Information, including your name, contact details, or information about your interest in and use of our Offerings.
HOW WE USE THE INFORMATION
We may use Information for the purposes described in this Privacy Policy, or as otherwise disclosed at the time of collection. Below, we explain our various purposes, any processing activities that we believe may need further explanation and, where necessary, the ‘lawful basis’ on which we rely to process your Information.
Please note that while Information may be processed for more than one purpose (e.g. Information we obtain when Providing Our Offering may also be used for Improving and Developing Our Offering and/or for Marketing and Personalized Advertising), not all of the purposes or processing activities below will necessarily apply in every case. Our particular use of your Information will depend on the Offering you engage with and the manner in which you interact with us, including the permissions you give us (e.g. whether or not you consent to certain uses, such as direct marketing) and other controls you exercise regarding our processing of your Information (e.g. whether or not you choose to opt-out, where this is offered). Your ability to control some of the purposes for which your Information is processed is described in the INDIVIDUAL RIGHTS REQUEST and COOKIES AND OTHER TECHNICAL INFORMATION sections below.
Providing Our Offerings
We may use your Information for the purpose of setting up your account with us, registering you for an Offering, enabling you to pay for it, providing the Offering, allowing you to participate in a promotion, competition, prize-draw or a call to action to submit UGC, or maintaining the Offering and resolving any issues. This may include enforcing applicable terms and conditions (e.g. for our subscription services, limitations on number of devices and displaying the right content based on location) and optimizing the delivery of the Offering to each specific device used to access it and to provide the “continue watching” feature on our subscription services.
In countries where our processing of Information requires a lawful basis, we rely upon the following:
Improving and Developing Our Offerings
We may use your Information for the purpose of analyzing, improving, personalizing and evaluating our Offerings and your use of them, as well as to develop new Offerings. This may include analyzing your responses to consumer surveys.
In countries where our processing of Information requires a lawful basis, we rely upon the following:
Marketing and Personalized Advertising
We may use your Information for the purpose of marketing and/or advertising our Offerings and those of our clients and partners. Dust uses AdTech technologies, such as real-time bidding, to monetize advertising space within its Digital Services and/or to create a ‘profile’ based on Information about your interactions with us, including our Offerings, our service providers, and our partners and their websites, apps and online advertising, which is used to provide you with personalized advertising and marketing. We may also aggregate information about users to create groups or categories of users, such as ‘segments’, to communicate with you about our offerings and let you know about our clients’ and partners’ offerings, including on Social Media Sites.
While processing of your Information for this purpose may involve an algorithm automatically selecting advertising which is intended to be of interest to you, we do not make fully-automated decisions that may have a legal or significant effect on you without either your explicit consent, or where otherwise permitted by applicable law.
We may also use UGC for marketing or advertising purposes, subject to the relevant terms and conditions of the Offering.
In countries where our processing of Information requires a lawful basis, we rely upon the following:
Providing Customer Services
We may use your Information for the purpose of providing Customer Services, including dealing with your queries and complaints (including troubleshooting), whether you contact us by telephone, email, chat boxes, forms or ticketing services, letter, website or via a Social Media Site.
In countries where our processing of Information requires a lawful basis, we rely upon the following:
Detecting, preventing and investigating criminal and other illegal activities
We may use your Information for the purpose of detecting, preventing or investigating criminal activities (including fraud and copyright infringement), protecting user safety and enforcing our civil rights in the courts. For example, where necessary, we may share your Information with law enforcement bodies or use it to take legal action against you to enforce our rights.
In countries where our processing of Information requires a lawful basis, we rely upon the following:
Compliance with legal obligations
We may use your Information for the purpose of complying with our legal obligations, including accounting rules, responding to Individual Rights Requests and responding to requests from regulators, judicial authorities and law enforcement or governmental bodies.
In countries where our processing of Information requires a lawful basis, we rely upon the following:
INFORMATION SHARING AND DISCLOSURE
We share Information with and disclose it to the following parties, for the purposes set out below:
Within AT&T, WarnerMedia, and any Dust affiliated entities. Dust is part of the AT&T group of companies, which includes WarnerMedia. These companies support and interact with each other to run their businesses. As a result, a WarnerMedia company and/or AT&T company may receive your Information to process for the purposes set out in this Privacy Policy, where there is a legal basis for them to do so and consistent with any permissions you have given (e.g. whether or not you wish to receive marketing communications) and any other controls you exercise regarding our processing of your Information (e.g. where you have chosen to opt-out of certain processing), as described in the INDIVIDUAL RIGHTS REQUEST and COOKIES AND OTHER TECHNICAL INFORMATION sections below.
Outside AT&T, WarnerMedia, and Dust affiliated entities:
Third Party Service Providers. Our agents and contractors have access to Information to help carry out the services they are performing for us, such as, but not limited to, fulfilment, creation, maintenance, hosting, and delivery of our Offerings, conducting marketing, providing IT services and security, handling payments, email and order fulfillment, administering promotions, competitions and prize-draws, conducting research, measurement and analytics, deriving insights, or customer service.
Linked Third Party Social Media Sites. Some of our Digital Services contain links to other sites, including Social Media Sites, for the purposes of customer interaction and marketing. The information practices of the Social Media Sites can be different from ours so you should consult their privacy policy and terms before submitting your personal information, as we have no control over personal information that is submitted to or collected by these third parties.
Third Party Partners. We sometimes offer Digital Services and Offline Services that are sponsored by or co-branded with identified third parties. By virtue of these relationships, the third parties collect or obtain personal information from you during the activity. We do not control these third parties’ use of personal information. We encourage you to read their privacy policies to learn about their data practices.
AdTech Providers. We share certain Information with third parties (e.g. other companies, retailers, research organisations, advertisers, ad agencies, advertising networks and platforms, participatory databases, publishers, and non-profit organisations) for processing generally in a hashed or de-identified form, to provide advertising to you based on your interests, including where applicable, through real-time bidding. In some instances, we may also share segments or custom audience data with third parties for marketing purposes. For more information, please see our (i) Marketing and Personalized Advertising purpose above (ii) Cookies and Other Technical Information and (iii) Ad Choices sections below.
Other third parties. In the event of a likely change of control of the business (or a part of the business) such as a sell, a merger, and acquisition, or any transaction, or reorganisation, we may share your Information with interested parties, including as part of any due diligence process with new or prospective business owners and their respective professional advisers.
Law enforcement bodies, the authorities and courts. We disclose Information where necessary for the prevention, investigation or prosecution of criminal activities, and also in response to legal process, e.g. in response to a court order or a subpoena, or in response to a regulator, government authority or law enforcement body’s request.
Public forums. If you post or share Information while interacting with one of our Digital Services, or through a Social Media Site, depending on the nature of the service or your privacy settings this Information can become public, after which, we cannot prevent further use or sharing of this Information. For information about how you can customize your privacy settings on Social Media Sites, please refer to their privacy help guides and terms of use.
DATA RETENTION
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 collected the Information in the first place. For example, some Information related to the provision of our Offerings to you will be kept for a number of years in order to comply with various finance and tax related legal obligations. We have detailed internal retention policies that set out the various retention periods for different categories of Information, depending on our legal obligations and whether there is a commercial need to retain the Information. After a retention period has lapsed, the Information is securely deleted, unless it is necessary for the establishment, exercise or defense of legal claims. For further information regarding applicable retention periods, you should contact us using the contact methods set out below.
INDIVIDUAL RIGHTS REQUESTS
Under certain conditions, you have the right to ask us to fulfill one or more of the following requests. We may ask you for proof of identity or other additional information before doing so.
We will assess any request to exercise these rights on a case by case basis. There may be circumstances in which we are not legally required to comply with a request because of relevant exemptions provided for in applicable data protection legislation. In some instances, this may mean that we are able to retain your Information even if you withdraw your consent. To exercise these rights, or to contact our Data Protection Officer, please submit a request by navigating to the Individual Rights Request Portal.
COOKIES AND OTHER TECHNICAL INFORMATION
When you visit our Digital Services, we, third party service providers, and partners may use “cookies” or similar technologies, such as pixels and SDKs to (i) provide, develop, maintain, personalize, protect, and improve our Digital Services and their content (ii) perform analytics, including to analyze and report on usage and performance of our Digital Services and any advertisements displayed on or delivered by or through them (iii) protect against, identify, and prevent fraud and other unlawful activity (iv) create aggregate data about groups or categories of our users (including advertising audiences), and (v) for us, our partners and third party service providers to deliver, target, offer, market, or personalize advertising relating to our Offerings or the offerings of our clients and partners (including limiting how often you see an advertisement).
Cookie Description
These cookies are required to enable core website functionality
Strictly necessary cookies or similar technologies: They are essential in order to enable you to move around our Digital Services and use their features, such as accessing secure areas. If you disable these cookies, some or all of the Digital Services’ features may not work.
These cookies allow us to analyze usage of our Digital Services so we can measure and improve performance
Performance cookies or similar technologies: They collect information about how you use our Digital Services, so that we can analyze traffic, understand users’ interactions, and improve the relevant Digital Service. Our emails and newsletters may contain a ‘web pixel’ to let us know how you have interacted with what we have sent you. For games, these technologies collect information about your gameplay, including accomplishments, use of features and other in-game activities. We may use third party service providers such as Google Analytics for this purpose who may use their own cookies or similar technologies. You can find out more information by clicking on the Google Analytics cookies usage resource link: https://tools.google.com/dlpage/gaoptout?hl=en
Functionality cookies or similar technologies: These allow our Digital Services to remember choices you make (such as your username or the region you are in) and provide enhanced, more personalized features, including personalized content. They may also be used to provide Digital Services you have asked for, such as watching a video or commenting on a blog.
These cookies are used by advertising companies to serve ads that are relevant to your interests
Social media cookies or similar technologies: These are used when you share Information using a social media sharing button or ‘like’ button via our Digital Services, or when you link your account or engage with our content on or through a Social Media Site, such as Facebook or Twitter. The Social Media Site will record that you have done this, and this Information may be linked to targeting/advertising activities, including building custom audiences.
Advertising cookies or similar technologies: Some of our Digital Services may use a third-party advertising network, an AT&T company or WarnerMedia company, or a Dust affiliated company. to deliver targeted advertising. They may also have the capability to limit the number of times you see an advertisement and track your browsing or usage across our Digital Services and Social Media Sites.
Managing cookies and other technologies. For Digital Services in some jurisdictions, including the EEA, you may learn more information about our use of cookies and other technologies, and provide or withdraw consents, or set your cookie preferences and in some cases object legitimate interest purposes for processing your personal information, by clicking Manage Cookies+ or otherwise adjusting cookie preferences. These settings are accessible on a site or app specific basis, at any time through the ‘Manage Cookies+’ link or a similar link located on webpages or in application settings. You may also use your app/browser settings to set your cookie preferences.
For many Digital Services in the EEA, WarnerMedia participates in the IAB Europe Transparency & Consent Framework, which is described in more detail by navigating to the IAB’s website, and complies with its specifications and policies on applicable websites and apps. OneTrust operates the consent management platform with the identification number 28.
Marketing communications. We provide you with an opportunity to express your preferences with respect to receiving certain marketing communications from us. If 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 (where the feature is available) or (ii) otherwise submit a request by navigating to our Individual Rights Request Portal. You can also follow the ’unsubscribe’ instructions provided in any marketing email you receive.
Ad choices. On our own or working with affiliates or third parties, we may present advertisements and engage in data collection, reporting, ad response measurement, and site analytics on our Digital Services and on third party websites across the Internet and applications over time. We, our affiliates, or third parties may use cookies, web beacons, pixels, SDKs, or similar technologies to perform this activity. They obtain information about applications you use, websites you visit, and other information from across your devices and browsers and across websites, services, and apps over time, in order to help serve advertising that will be more relevant to your interests on and off our Digital Services and across your devices and browsers. This type of advertising is known as ‘interest-based advertising’. We, our affiliates, or third parties may also use this information to associate your different browsers and devices together for interest-based advertising and for other purposes like research, analytics, internal operations, fraud prevention, and enhancing consumer experiences.
In addition to managing your preferences through our consent management platform, for more information about interest-based advertising on your desktop or mobile browser, and to opt out of this type of advertising by third parties that participate in self-regulatory programs by visiting the Your Online Choices website if in the EEA, which is hosted by and can be visited at the European Interactive Digital Advertising Alliance (EDAA) website; if in Argentina to the Alianza de Publicidad Digital de Argentina (APDA); if in Canada, by visiting the Digital Advertising Alliance of Canada (DAAC) website and if in the United States, by navigating to the Digital Advertising Alliance of the US (DAA) website. To learn more about interest-based advertising on mobile apps and to opt out of this type of advertising by third parties that participate in the DAA’s AppChoices tool, please visit the Ad choice link to download the version of AppChoices for your device. 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 Information for other purposes, including research, analytics, and internal operations. You can therefore continue to receive advertising, but that advertising may be less relevant to your interests.
Important things to note about cookie-based web browser opt outs (such as those utilized by the EDAA, APDA and DAAC):
The opt out does not block or delete cookies: It also does not prevent the use of cookies or other technologies for purposes other than selecting ads based on your interests as inferred by your online behavior. If you opt out, data may still be collected about your web browsing activities and you will still see advertising. Ads may be selected, for example, based on the content of the web page in which they are shown. If you wish to block or delete cookies altogether, you can use web browser settings to do so.
You may 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 may 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 enable or 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. You may also limit the collection of precise location information from websites through browser settings.
INTERNATIONAL TRANSFER
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, including countries where the level of legal protection for your Information may be different and where you may have fewer legal rights in relation to it. In particular, your Information may be transferred to, and processed in the United States, where some of our systems are located.
Please see our Affiliates Table for examples of the countries where your Information may be transferred.
However, 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 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.
NOTIFICATION REGARDING UPDATES
From time to time, we may update this Privacy Policy. We will notify you about any material changes by placing a notice on our sites. We encourage you to periodically check back and review this policy so that you are up to date.
HOW TO CONTACT US
If you have any questions about this Privacy Policy, you can contact us and our Data Protection Officer at [email protected]
COMPLAINTS
If you are unhappy with how we have dealt with your query, in the first instance please contact us at [email protected]. If you are still unhappy with our response, you may have the right to complain to your Data Protection Authority. Please contact us at [email protected] to obtain details of how to contact them.