Last Modified: 7 October 2024

SCOPE OF THIS POLICY

This privacy policy describes the treatment of information that can be used to identify you (“Personal Data”) in connection with contests that we operate and which you participate in. The Personal Data may be: (a) provided by you via email, SMS or other direct communication channels, or (b) collected on our websites and/or applications, or (c) provided by you via our social media handles/accounts or on applications we make available on third-party sites or platforms. The applicable law that applies to you under this privacy policy depends on where the contest that you participate in is hosted. We will host contests within Singapore (“Country”). 

Please keep in mind that when you provide Personal Data to us on a third-party site or platform (for example, via social media), the Personal Data we receive may be separately collected by the third-party site or platform. Our use of your Personal Data for the purposes of the contests within the Country is covered by this privacy policy, and the Personal Data the third-party site or platform collects is subject to the third-party site or platform’s own privacy practices. Privacy choices you have made on the third-party site or platform will not apply to our use of the Personal Data for the contests, and vice versa. Please also keep in mind that our sites and applications may contain links to other sites not owned or controlled by us and we are not responsible for the privacy practices of those sites. We encourage you to be aware when you leave our sites or applications and to read the privacy policies of other sites that may collect your Personal Data.

You may refuse to provide any Personal Data at any time, however this may affect our ability to administer the contest and your ability to receive the prize. If collection of Personal Data is mandatory, we will make that clear at the point of collection so that you can make an informed decision as to whether you wish to participate in a contest.

WHO WE ARE          

Star Vijay Singapore Pte. Ltd., incorporated in Singapore, is the data controller of your Personal Data.

TYPES OF PERSONAL DATA WE COLLECT       

We may collect the following types of Personal Data in connection with your participation in our contests:​

• For contests we host in the form of games on a separate microsite (“Gaming Contests”): Personal Data you provide when you create an account to enter into the contest, or link your profile on a third-party site or platform with your registration account, such as your first name and surname, social media account name, age, your username, performance data (such as high-scores, log-in session details and so on) photograph (as available on your profile on a third-party site or platform), location/city, IP address, email address, phone number nationality, country of residence and gender.
• For contests we host on the Company’s channels (“Channel Contests”): Name, email address and phone number.
• For contests we host on third party platforms through the Company’s social media handles/accounts (“Social Media Contests”): Social media account name, photograph (as available on your social media profile), email address and phone number.
• For contests where you are required to share original creative entries (“UGC Contests”): Name, photographs, audio-visual files, sound recordings and/or text, that are originally created by you (individually, or as a part of the group depending on the contest); social media account name, photograph (as available on your social media profile), email address, location and phone number. It is clarified that in the event that any entry shared by you features other persons, the Personal Data specified herein shall be required for each participating person, and you should not feature any other person without their informed and express consent to do so. 

We may create data in the form of aggregated information by collecting and using your Personal Data containing any of the above, or metadata (i.e. information about the Personal Data you provide, such as the time of communication, the frequency of communication etc.) relating to the above, for purposes including analysis of contest popularity and engagement, administration of contests and ensuring fairness, audit purposes, security and network monitoring and other purposes. Where your Personal Data is aggregated, we can no longer link you to or identify you from the aggregated information and it is no longer Personal Data.

GRATIFICATION 

If you are selected as a winner of, or shortlisted as one of the contestants eligible to win, one of our contests, you may be required to provide the following Personal Data, in addition to Personal Data that may have already been received by us:  

• For verification: Name, date of birth, nationality, place of residence and/or any other document/information (including without limitation a consent form from a guardian) that may be required to confirm the details shared by you, to verify your eligibility to participate in the contest and receive the prize.
• For digital prizes: Name, email address, phone number.
• For physical prizes: Name, mailing address, phone number.
• For travel and accommodation related prizes: Name, phone number, Government ID, passport copy, visa (or travel authorisation or equivalent) copy (if applicable), food preferences and information of allergens.
• For prizes where you stand a chance to feature on television: Release or consent form, name, email address, phone number, age, personal background, social media handle, your image/photograph/likeness, your footage, your voice.
• For creation of vignettes that capture your experience of winning the prize: Release or consent form, name, email address, phone number, age, personal background, your image/photograph/likeness, your footage, your voice. 

In the event that more than one type of prize is being awarded for a particular contest, we may require the Personal Data specified for each kind of prize. 

Further, in the event that a prize is awarded to you and one or more companions that you select, and who fulfil the Company’s eligibility criteria (“Eligible Companion”), the relevant Personal Data for each Eligible Companion will also be required to be provided (“Companion Data”) to the Company and any such Companion Data will also be processed by the Company in accordance with this Privacy Policy. 

We may collect other types of Personal Data relating to your general use of our websites and other services such as;

• Personal Data you provide in public forums on our sites and applications, such as your name/username;
• Personal Data we obtain from a third party, such as a site or platform provider, about use of our applications on third-party platforms or devices, for example, where it is a Gaming Contest or Social Media Contest;
• Location Personal Data, including location information provided by a mobile or other device interacting with one of our sites or applications (including through beacon technologies), or associated with your IP address, where we are permitted by law to process this Personal Data;
• Activity Personal Data about your use, and the use by any person(s) you authorize through your account, of our sites and applications, such as the content you view or post, how often you use our services, and your preferences; and/or
• Usage, viewing, technical, and device data when you visit our sites, use our applications on third-party sites or platforms, or open emails we send, including your browser or device type, unique device identifier, and IP address. 

HOW WE COLLECT YOUR PERSONAL DATA 

We may collect Personal Data:

• You provide voluntarily to us when you enter a contest, through the appropriate channel. You may provide Personal Data in a variety of ways, including by typing, using voice commands or uploading files and content; and/or
• During the course of administering a contest, including through correspondence with you and providing any prizes or entitlements you have gained.

USE OF YOUR PERSONAL DATA 

Star Vijay Singapore Pte. Ltd. is the data controller for your Personal Data and is responsible for and may use your Personal Data for the purposes described in this policy. Star Vijay Singapore Pte. Ltd.’s affiliates and/or third party service providers may have access to your Personal Data where they perform services on behalf of the data controller(s) (as a data processor). Consistent with applicable law, we may use Personal Data collected from you, or from devices associated with you, to:

• Provide you with the experiences and services you request, view and engage with, in particular, allowing you to participate to our contests and promotions.
• Determine whether you are one of the winners in our contest (whether in a physical location or online).
• Communicate with you about the above, including about your participation in our contest and promotions and if you have won a prize, and send you information.
• Administer any contests you have entered, including keeping records of entries, selecting and assessing winning entries, publishing the results of the contest and awarding prizes.
• Operate, understand, optimize, develop, or improve our sites, applications, products, services and operations.
• Detect, investigate and prevent activities that may violate our policies or be illegal. 

LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA 

Our basis for processing your Personal Data in accordance with this privacy policy includes: 

- to perform a contract with you or to take steps at your request to do so;

- to comply with our legal obligations or a court order or order of a competent tribunal or regulator;

- to exercise or defend our legal rights; and/or

- with your express or implied consent for a particular purpose. 

Where permitted by applicable law, we may also process your personal data for our legitimate interests, if we have suitably assessed how to balance our interests and your privacy rights. 

SHARING YOUR PERSONAL DATA WITH OTHER BUSINESSES   

We will not share your Personal Data with a third party except in limited circumstances, including:

• When companies perform services on our behalf, including without limitation management, development, package delivery, marketing and advertising, production, travel and accommodation booking, customer service, IT services such as support and hosting; however, these companies are prohibited from using your Personal Data for purposes other than those requested by us or required by law.
• Where you have entered a contest which is being run in collaboration with a third party and you have agreed to them having access to your Personal Data for the administration or fulfilment of the contest, including prize judging and awarding.
• When we share your Personal Data with third parties in connection with the sale of a business, to enforce these Terms and Conditions or applicable contest rules, to ensure the safety and security of third parties, to protect our rights and property and the rights and property of third parties, to comply with legal process, or in other cases if we believe in good faith that disclosure is required by law.
• When we are required to share your Personal Data by a competent government authority or a court order, or other binding legal mandate.In such circumstances we will attempt to verify the legitimacy of such request and limit disclosure to the minimum reasonable extent (if legally permitted to do so). 

OUR CONTROLS AND CHOICES

We may provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of Personal Data.

• You may withdraw consent to the use of your Personal Data by sending us an email to to marketing@disney.com. Withdrawal of your consent may result in your withdrawal or disqualification from participation in our contests. Please note that notwithstanding this, we may retain your Personal Data where necessary for legal or business purposes in accordance with the law.
• If you are awarded a prize that allows you to select an Eligible Companion, you may choose not to share the Companion Data of an Eligible Companion. However, this may result in you having to either select another Eligible Companion or not having an Eligible Companion.

CHILDREN’S PERSONAL DATA

We do not knowingly collect the Personal Data of children under the age of 13. For children between (and inclusive of) the ages of 13 to 17, where appropriate, a parent or guardian may provide consent on behalf of a child for the collection and use of the child’s Personal Data for limited purposes and only in accordance with this policy and applicable laws.

DATA SECURITY, INTEGRITY, AND RETENTION          

The security, integrity, and confidentiality of your Personal Data is extremely important to us.

DATA TRANSFERS, STORAGE, AND PROCESSING GLOBALLY          
We operate globally and may transfer your Personal Data to our affiliates or third parties in locations around the world for the purposes described in this privacy policy, including in particular (but not exclusively) where there is an international aspect to the contest. Wherever your Personal Data is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your Personal Data and to ensure that any transfers comply with applicable laws (which may include ensuring that the Personal Data is transferred to a destination deemed to be adequate by competent authorities, or may involve the implementation of additional safeguards such as approved contractual clauses).

CHANGES TO THIS PRIVACY POLICY    
From time to time, we may change this privacy policy to accommodate new technologies, industry practices, regulatory requirements or for other purposes.

COMMENTS AND QUESTIONS      
We have appointed a Data Protection Officer to oversee compliance with this privacy policy. If you have a comment or question about this privacy policy, please contact the Data Protection Officer at star.marketing@disney.com.

YOUR RIGHTS

You have rights under applicable privacy laws. If you believe we have not respected your rights or you have a complaint, you may be entitled to file a complaint with a relevant data protection supervisory authority. If you wish to contact us about your data protection rights, please contact the Data Protection Officer at star.marketing@disney.com.