We, Sanrio Digital (HK) Limited, respect you, our user, and your privacy. It is our policy to comply with internationally recognized standards of personal data privacy protection.
This statement set outs our privacy policies and practices in relation to the following:
- What information is collected
- How information is used
- Use of information in direct marketing
- With whom the information is shared
- How we protect children under the age of 13
- How you access or change your information
- Your options
WHAT INFORMATION IS COLLECTED
We collect the following information from you.
The first kind is personally identifiable information ("Personally Identifiable Information") which we collect during your registration for any of our services such as E-mail, message board etc ("Services"). Personally Identifiable Information may include your first and last name and year of birth.
The second kind is non-personally identifiable information which includes your IP address (such as your computer's unique signature), your device's or platform's unique signature (such as your device's IMEI), operating system, browser software, Internet Service Provider, domain type and other numeric codes which identify a device or computer ("Aggregated Information").
HOW INFORMATION IS USED
Personally Identifiable Information is used solely for the purpose of identifying, managing and servicing individual user. If you consent or do not object to our use of your Personally Identifiable Information in direct marketing (please see further details in the "Use of Personally Identifiable Information in Direct Marketing" section below), we may use such information to conduct direct marketing activities, such as sending you offers, promotions, rewards, discounts, events and benefits in relation to the Services and products and services offered by our business partners or third party merchants.
Aggregated Information is collected to help us to compile aggregate statistics on the usage of our applications and/or website and to analyse our users' demographics, interests and behaviour. This will give us a better understanding of the needs of our users and design our services and products accordingly.
USE OF INFORMATION IN DIRECT MARKETING
From time to time, we may conduct direct marketing of the Services through email, direct mails, telemarketing, fax and/or other form of communication to you. We intend to use your Personally Identifiable Information for direct marketing carried out by us or one of our business partners or third party merchants. For the purpose of direct marketing, we shall use your name (including surname and given name), address, telephone number, email address and other information, if any, that you provide to us for offers, promotions, rewards, discounts, events and benefits in relation to the Services and products and services offered by our business partners or third party merchants.
Please note that we may not use or provide your Personally Identifiable Information to others for direct marketing purposes unless exempted by the relevant regulations or we have received your consent (which includes an indication of no objection).
You may indicate your consent to the above by ticking the box(es) indicating your consent contained in the relevant communications. If you do not wish (i) any of your Personally Identifiable Information to be used in any of the described direct marketing activities, or (ii) to receive from us (a) any promotional and direct marketing materials, (b) any particular types of promotional and direct marketing materials, and/or (c) such materials through any particular means of communication, you can at any time opt-out, free-of-charge, by contacting us at email@example.com, following the "opt-out" instructions contained in the relevant communications, or following the instructions in the "Your Options" section below.
WITH WHOM THE INFORMATION IS SHARED
We do not disclose any of your Personally Identifiable Information to any third parties except:
We only share your Personally Identifiable Information with our business partners in accordance with our operating agreements with them.
- with your written permission;
- as required by any applicable law; or
- to our business partners as explained below.
HOW WE PROTECT CHILDREN UNDER THE AGE OF 13
Please note that this "How We Protect Children Under the Age of 13" section only applies to procedures when collecting information from children under the age of 13.
A. What types of information do we collect from children?
We mainly collect persistent identifier (such as an IP address, mobile device id, or a unique device identifier) from the child. We may also collect the email address of the child.
Please note that all sites that are directed to children under the age of 13 are prohibited by COPPA from conditioning a child's participation in an online activity on the child's disclosure of more Personally Identifiable Information than is reasonably necessary to participate in the activity.
B. How do we use and share the Personally Identifiable Information collected from children?
We use the collected persistent identifier for the sole purpose of providing support for internal operations of the Service, including activities necessary for us to maintain or analyze the functioning of the Services, authenticate users or personalize content, serve contextual advertising or cap the frequency of advertising, protect the security or integrity of the user or the Service, or ensure legal or regulatory compliance.
The collected persistent identifier is not shared with other third parties. However, we may, from time to time contract with certain third party service providers to provide support for the internal operations of the Service. Your Personally Identifiable Information is not used or disclosed by these contracted third party service providers except for the limited service for which they have been contracted.
We collect a child's email address in connection with a question emailed to us by the child for the sole purpose of communicating with the child on a one-time-only basis (e.g. responding to a question from the child). We will not use or disclose such information to re-contact the child or for any other purpose, and such information will be deleted from our records promptly after responding to the child's request. If we choose not to respond to the child's request, we will immediately delete the child's information.
C. How can parents review or delete Personally Identifiable Information about their child?
At any time, parents of children under the age of 13 may review or delete Personally Identifiable Information about their children from our records, or refuse to permit our further collection or use of such Personally Identifiable Information. Please contact us at firstname.lastname@example.org if you would like to review or delete your child's Personally Identifiable Information, or to inform us about your refusal to permit our further collection of such Personally Identifiable Information.
Whenever a parent requests a deletion of his or her child's Personally Identifiable Information, we will use reasonable efforts to delete the child's information from our records as much as possible and will not collect any other Personally Identifiable Information from such child. Please note that there may be residual information that will remain in our records that may or may not contain the Personally Identifiable Information that was requested to be deleted. Such residual information will not be disclosed or shared with any other third party or used for any commercial purpose.
E. Contact us
Sanrio Digital (HK) Limited
Unit 1109, Cyberport 2, 100 Cyberport Road, Hong Kong. Attention: Legal Department
or send us an email at: email@example.com
Or call us at: (852) 9101 3960
HOW YOU ACCESS OR CHANGE YOUR INFORMATION
You have the right to access and change any of your Personally Identifiable Information collected by us. If you would like to access or change your information, please follow the simple instruction in your user account option or please contact us at firstname.lastname@example.org.
By registering for any of our services, you also consent to the transfer of any of your information collected by us to other jurisdictions which may not have any laws protecting Personally Identifiable Information similar to those in your jurisdiction.
If you have any questions concerning our use of your Personally Identifiable Information, please contact us at email@example.com.
Last updated June 2013
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