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About us

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This website and/or mobile app is operated by Cloudtopia Entertainment Limited, a company registered in Hong Kong, with company number 1024117, and whose registered office is at Room 705-706 China Insurance Group Building, 141 Des Voeux Road Central, Central, Hong Kong(CEL, We, Us).

We are committed to protecting your privacy. This privacy policy (Privacy Policy) tells you how we collect, store, process and use your/your children’s personal information when you use this website and/or mobile app (the Services). It also provides you with details about your rights in relation to your/your children’s personal information. 

 

Children

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The Services are designed partly for children. Therefore we are aware that we must be extra cautious when processing personal information. Most of our Services contain a children’s section (the “Children’s Area”) and a separate parents’ (or guardians’) section (the “Grown-Up Area”). In the Children’s Area, children mainly participate only by playing games, reading e-books and/or watching videos. We generally do not offer any place in the Children’s Area where a child can sign up or enter personal information themselves. Typically, the only part of the Services where anyone can enter personal information directly is the Grown-Up Area. Accordingly, in most cases, we do not anticipate that we will be collecting personal information directly from any children. We anticipate and assume that we will be collecting personal information only from parents or guardians.

If you are under the age of 13, you may only use the Services and provide personal information if you have the consent of, and are supervised by, a parent or guardian.

If we believe a child using the Services is under 13 we will not process any personal information of that child without the consent of the parent or guardian. If the user is 13 or over we will only collect and process personal information as the long as we believe the user understands what is involved.

What personal information do we collect?

We may collect the following personal information:

• name;

• email address;

• address;

• postcode;

• country and other geolocation information;

• date of birth;

• password and other authentication information;

• responses to any customer satisfaction surveys or market

• research (unless these are provided anonymously);

• marketing preferences;

• children’s name(s);

• children’s date(s) of birth;

• gender;

• any information you (or your child) submits as part of a

• competition; and

• information about your device (such as your IP address or other device identifier) and your (or your child’s) usage or the Services through cookies (and similar technologies) as further described below.

If you contact us with a complaint or query, we may keep a record of any phone number used to call our customer service team as well as the correspondence.

How and when we collect your/your children’s personal information

We may collect personal information from you when you/your children:

• participate in, access or sign up to any of the Services’ activities, online content, newsletters, or competitions;

• create an online account or fill in any other forms on the Services;

• contact our customer service teams or request information from us in any other way;

• respond to communications from us;

• participate in our customer satisfaction surveys or other market research; or

• communicate with us via social networking websites, third party apps or similar technologies.

When you browse or otherwise use the Services, we will also collect certain information about your device and your use of the Services using cookies and similar technologies as further described below.

We will indicate where any personal information we have requested is mandatory or optional. Please note that if you decide not to provide certain information which we have indicated is mandatory, in some circumstances this may mean we are unable to provide you with a certain service or product.

We may also collect personal information about you from third party sources, such as from our sub-contractors.

How we may use your/your children’s personal information

We (or third party data processors acting on our behalf) may collect, store and use your/your children’s personal information for the following purposes:

• ​to provide our Services, activities or online content and to provide information about our Services, activities and online content which may be tailored to your/your children’s individual tastes;

• to contact prize winners of competitions;

• to identify you/your child as the winner of a particular competition;

• to send out newsletters you/your children have subscribed to;

• to provide you/your children with services that you request;

• for system administration purposes and for internal operations (including troubleshooting, data analysis, and testing) to ensure the Services operate properly;
  to distinguish you from other users (for example to remember your log-in details);

• to analyze your use of the Services to improve the user experience and to ensure that content is presented in the most effective manner for you and for your device;
  to notify you of any changes to the Services;

• to provide customer support and ensure we provide a good level of customer service;

• where you have given us your consent or we are otherwise permitted by law, to contact you/your children (including by e-mail) with products and services which we think may interest you/your children – you can unsubscribe from our marketing communications at any time;

• where you have given your consent, to pass your personal information to selected third parties for marketing purposes; and

• for geo-based redirection (so that if you see the correct version of the Services depending on the country from which you are accessing the Services);

• for security and fraud prevention;

• to ensure that our Services are safe and secure; and

• to comply with applicable laws and regulations.

We may also collect information about visitors to and users of the Services for the purposes of aggregate statistics or reporting purposes.

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Legal basis for processing your personal information

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We will only process your/your child’s personal information where we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and use the personal information. In almost every case the legal basis will be one of the following:

• Consent: For example, where you have provided your consent to receive certain marketing from us. You can withdraw your consent at any time, including by clicking on the “unsubscribe” link at the bottom of any marketing email we send you.

• Our legitimate business interests: Where it is necessary for us to understand our customers, promote our services and operate effectively as a provider of children’s content and related services, provided in each case that this is done in a legitimate way which does not unduly affect your or your child’s privacy and other rights.

• Compliance with law: Where we are subject to a legal obligation and need to use your personal information in order to comply with that obligation.

 

Where we store your personal information

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The personal information that we collect may be transferred to, and stored at, a destination outside the Hong Kong, including countries, which have less strict, or no data protection laws, when compared to those in Hong Kong.

Whenever we transfer your/your child’s personal information as described in the paragraph above, we will take steps which are reasonably necessary to ensure that adequate safeguards are in place to protect such personal information and to make sure it is treated securely and in accordance with this privacy policy. In these cases, we rely on approved data transfer mechanisms (such as the EU “Standard Contractual Clauses” and the EU-US “Privacy Shield”) to ensure your information is subject to adequate safeguards in the recipient country. If you are located in the EEA, you may contact us for a copy of the safeguards which we have put in place to protect your personal information and privacy rights in these circumstances.

 

How we keep your personal information

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We take steps to ensure that the personal information we collect is retained for only as long as it is necessary for the purpose for which it was collected. After this period it will be deleted or in some cases anonymized.

Where we have collected personal information based on your consent and we have no other lawful basis to continue with that processing, if you subsequently withdraw your consent then we will delete your personal information. However, please note that where you unsubscribe from our marketing communications, we will keep a record of your email address to ensure we do not send you marketing emails in future.

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Do we share personal information with any third parties?

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We may share your (or your child’s) personal information with our marketing vendor/data processor, who hosts the Services and stores all associated data on our behalf, and sends out certain e-mails on our behalf.

If a third party acquires all (or substantially all) of our business and/or assets, we may disclose your/your children’s personal information to that third party in connection with the acquisition. We may also disclose your/your children’s personal information where we are required to do so by applicable law, by a governmental body or by a law enforcement agency.

We may also disclose personal information to protect the rights, property or safety of us or our users, or others, and in order to enforce or apply our terms and conditions (this includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction) or where we are required to do so by applicable law, by a governmental body or by a law enforcement agency.

Other than as described in this Privacy Policy, we will not disclose, sell or rent your/your children’s personal information to any third party unless you have consented to this. If you do consent but later change your mind, you may contact us and we will cease any such activity.

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Third party sites

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The Services contain links to other websites and services operated by third parties. Please note that this Privacy Policy applies only to the personal information that we collect through the Services (or via competitions on our applications on third party websites including social networks where there is a link to this policy), or receive from third parties and we cannot be responsible for personal information that third parties may collect, store and use through their own websites and services. You should always read carefully the privacy policy of each such third party website and service you visit or use.

In addition, when you provide to us information on a third party site or platform, (for example via our competitions on our applications on social networking sites), the information may also be collected by the third party website and may be subject to their privacy policy.

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Security

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We take appropriate technical and organizational measures to safeguard the personal information that we hold about you and regularly review our security measures to consider new technologies and methods, to safeguard your data. Please note that no transmission over the Internet can ever be guaranteed secure and we consequently cannot guarantee the security of any personal information that we receive over the Internet.

You must keep your password and any other authentication information for the Services confidential. If you know or suspect that anyone other than you knows your password or any other authentication information, you must promptly notify us using the contact details below.

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Your rights

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You have certain rights in relation to your personal information. These include: the right to object to the processing of your information for certain purposes, the right to access your personal information, and the ability to erase, restrict or receive a machine-readable copy of your personal information.

We will handle any request to exercise your rights in accordance with applicable law and any relevant legal exemptions. If you wish to exercise any of these rights please conduct us using the contact details below.

You may also have the right to complain to a data protection authority if you think we have processed your personal information in a manner which is unlawful or breaches your rights. If you have such concerns we request that you initially contact us (using the contact details below) so that we can investigate, and hopefully resolve, your concerns.

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Changes to this Privacy Policy

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We may from time to time revise this Privacy Policy so please check back regularly to keep informed of updates. We will provide notice to you if these changes are material and will seek your consent if the change could have a detrimental effect on you.

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If you have any questions regarding this Privacy Policy or would like to exercise any of the above rights, please contact us by e-mail: privacypolicy@cloudtopiaentertainment.com

Please note, the email address above is for privacy related queries only. For other queries please use the following email addresses:

For any technical issues:
support@cloudtopiaentertainment.com

For any general queries:
familyenquiries@cloudtopiaentertainment.com

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Alternatively, you can contact us in writing or by phone via the details below:

Cloudtopia Entertainment Limited
Room 705-706 China Insurance Group Building

141 Des Voeux Road Central
Central, Hong Kong
Phone No: +852 61601616

This privacy policy was last update on January 31 2020

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