The purpose of this document ("Privacy Policy") is to inform you of how we handle or process Personal Data (as defined below) which is subject to the Personal Data Protection Act 2012 ("PDPA"). Please take a moment to read this Privacy Policy so that you know and understand the purposes for which we, Celestial Movie Channel Limited (“Celestial” as defined hereunder), collect, use and disclose your Personal Data.
By interacting with us, submitting information to us, or signing up for any products or services offered by us, and/or accessing or using CMGO, you agree and consent to Celestial and its related corporations (collectively, the "Companies"), as well as their respective representatives and/or agents ("Representatives") (the Companies and Representatives collectively referred to herein as "Celestial", "us", "we" or "our") collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to the Companies' authorised service providers and relevant third parties in the manner and for any of the purposes set forth in this Privacy Policy. In addition, this Privacy Policy will also provide you with more information on the basis upon which we may lawfully collect, use and/or disclose your Personal Data without your consent, where permitted by applicable law.
This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and any consents you may have provided in connection with this Privacy Policy are cumulative and additional to any rights which we may have under applicable law to handle or process your Personal Data.
We reserve the right to update or modify this Privacy Policy from time to time by posting the updated version on CMGO, including our website www.cmgo.com, and sending you notification of updates to this Privacy Policy by way of email and/or in app notification. By continuing to use CMGO, you agree to be bound by the prevailing terms of this Privacy Policy as may be updated and/or as you may be notified from time to time, to the maximum extent permissible under applicable law. Hence, please check back regularly for updated information on our handling or processing of your Personal Data.
1. Personal Data
1.1 In this Privacy Policy:
a) "Personal Data" refers to any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.
b) "Subscription Service Provider" means the third party telecommunications, TV, internet or other service provider(s) providing subscription services to users through which users may (among other things) gain access to CMGO.
1.2 Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your email address, name and other identifiers such as profile name and password, information about your computer, phone or other web enabled device, which may include mobile app token, the types and configurations of browsers, language settings, geo-location and location of your device, device type/manufacturer, Internet Protocol (IP) address (and domain names), operating system type and version, network type, your third party Subscription Service Provider, transactional data and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you.
2. Collection of Personal Data
2.1 Generally, we collect Personal Data in the following ways:
a) when you establish any online accounts with us, or when you update or add information to your user profile;
b) when you use CMGO, or interact with us via CMGO (i.e., when you share comments or feedback with us (such as by leaving a review));
c) when you communicate with us (such as contacting our online customer support center);
d) when we seek information about you and/or receive your Personal Data in connection with your relationship with us and our services, for example, from our business partners and/or third parties with whom you have an existing relationship such as your telecommunications, TV, internet, or Subscription Service Provider;
e) when you link your account with us with third-party services and applications, such as your instant messaging (e.g. WhatsApp) or other social media accounts (e.g. Facebook and Instagram); and/or
f) when you submit your Personal Data to us for any other reason.
2.2 If you provide us with any Personal Data relating to a third party (e.g. information on your customers, spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of such third party to you providing us with their Personal Data, and for the collection, use and disclosure of their Personal Data for all purposes set out in our herein and by or for the benefit of the persons referenced herein.
2.3 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with any products and/or services you have requested and / or affect your enjoyment of CMGO provided to the fullest extent.
3.3. Purposes for the Collection, Use and Disclosure of Your Personal Data
3.1 Generally, Celestial collects, uses and discloses your Personal Data for the following purposes depending on the nature of our relationship:
a) processing your registration / subscription, and verifying and processing your personal particulars in relation to the provision of goods and/or services;
b) providing movie streaming and entertainment services to you, and to carry out the functions of our mobile application(s) and website(s) in connection with CMGO, including without limitation geo-blocking, managing region-specific content catalogue availability and rights, managing your account and subscription, and conducting platform maintenance such as crash analysis and de-bugging;
c) responding to, processing and handling your queries, requests, feedback and suggestions, resolving complaints, or otherwise providing customer support;
d) managing the administrative and business operations of the Companies and complying with internal policies and procedures;
e) facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the Companies;
f) matching any Personal Data held which relates to you for any of the purposes listed herein;
g) requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes for us to design our products, understand customer behaviour, preferences and market trends, and to review, develop and improve the quality of our products and services;
h) providing system messages (such as in-app updates), media announcements and responses;
i) in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;
j) complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities;
k) to investigate, prevent, and detect prohibited or illegal activities and other security/technical issues;
l) displaying content to you which may be relevant to you (including to personalise and customise your experience based on your interactions with our platform(s) and other content you submit from time to time);
m) communicating with you and informing you of changes and development to the Companies' policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to the products and services offered to you;
n) providing or marketing our services, products and benefits to you, including promotions, special offers, information about new products, and loyalty and reward programmes, including joint marketing and/or cross promotions with third parties;
o) matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the customisation, provision or offering of products, services, marketing or promotions, whether by Celestial or other third parties;
p) conducting market research, profiling and statistical analysis, understanding and analysing customer behaviour, location, preferences, demographics, and interest in any services provided by us for us to offer you products and services as well as special offers and marketing programmes which may be relevant to your preferences and profile;
q) recommending, identifying and/or contacting you to inform you of products, services, special offers and rewards, either to our customers generally, or which we have identified may be of interest to you, or that are or may be relevant to you, in any case including on behalf of third parties, or sharing your Personal Data with such third parties or their service providers for them to collect, use, disclose or process your Personal Data for any of such purposes; and/or
r) any other purpose relating to or reasonably necessary for any of the above.
These purposes may also apply even if you do not maintain any account(s) with us, or have terminated these account(s).
3.2 We may also process Personal Data relating to a third party which you provide to us: (a) for fraud detection and prevention; (b) to facilitate your requests or for any other purpose you authorize; (c) to research, analyze, and improve our services; (d) to collaborate with third parties to offer promotions.
3.3 In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use and/or disclose your Personal Data. If so, we will collect, use and/or disclose your Personal Data for these purposes as well.
4. Disclosure of Personal Data
4.1 Subject to applicable law, your Personal Data may be provided, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas or in Singapore:
a) third parties who provide goods and services either independently or on our behalf, such as your telecommunications, TV, or internet service provider(s);
b) the Companies;
c) agents, contractors or third party service providers (including software providers) who provide services to Celestial;
d) vendors or other third party service providers, including in connection with marketing promotions and services offered by Celestial;
e) analytics, search engine providers or other third party service providers that assist us in delivering our products and services as well as improving and optimising the same;
f) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or any debt or asset sale) involving any of the Companies;
g) third party referrers;
h) our co-brand and other business partners;
i) our professional advisers such as our board of directors, auditors and lawyers;
j) relevant government regulators, government ministries, statutory boards or authorities and/or law enforcement agencies, to comply with any directions, laws, rules, guidelines, regulations or schemes issued or administered by any of them;
k) external business and charity partners in relation to corporate promotional events; and/or
l) any other party to whom you authorise us to disclose your Personal Data to.
5. Deemed Consent
5.1 In addition to the matters set forth above, subject to and in accordance with applicable law, you shall be deemed to have consented to Celestial collecting, using, disclosing and sharing amongst ourselves your Personal Data, and disclosing such Personal Data to the Companies' authorised service providers and relevant third parties:
a) where in response to a request for your Personal Data in connection with identified purposes, you voluntarily provide such Personal Data to Celestial for such purpose(s) and it is reasonable that you would voluntarily provide such Personal Data; and
b) where the collection, use and/or disclosure of your Personal Data is reasonably necessary for the conclusion and/or performance of a contract, between you and us or any other organisation entered into at your request, which may include recipients of your Personal Data not indicated in this Privacy Policy.
6. OTHER BASES FOR HANDLING OR PROCESSING YOUR PERSONAL DATA
6.1 In addition to and without limiting the consents you have provided to our collection, use and/or disclosure of your Personal Data for the purposes set out elsewhere in this Privacy Policy, where permitted by applicable law, Celestial may also in accordance the requirements thereof also collect, use and/or disclose your Personal Data as further detailed below including without consent, where we meet the requirements of applicable law:
a) for our legitimate interests or the legitimate interests of another person (but not for sending you direct marketing messages unless you have otherwise provided your consent), including without limitation for the following purposes:
i) any investigations or proceedings;
ii) fraud detection and prevention;
iii) entering into, managing or terminating an employment relationship or appointment; and
iv) detection and prevention of misuse of services by users; and
b) we may collect your Personal Data from any of the Companies, we may use your Personal Data, and any of the Companies may disclose your Personal Data to us, for improving our products, services, processes or business, understanding customer preferences and personalising experiences and recommendations (regardless whether you are an existing or prospective customer of any of the Companies).
7. Use of Cookies and Related Technologies
7.1 You acknowledge and agree that CMGO may include analytics code and other tools that may allow us to gather information on any use of any of CMGO, and may include our use of cookies, running of verification and compliance analysis and/or use of data capture, syndication analysis, and/or other similar tools to track, extract, compile, aggregate, archive, disclose or otherwise analyse any data and/or information resulting from any person's access to and/or use of any of CMGO, and further that: (a) we shall retain all rights, title and interest in and to all such gathered information and data; (b) you shall not disable or interfere with any such analytics code and tools; and (c) any intellectual property rights of or in the results of such analytics shall vest solely in us. For the avoidance of doubt, we may monitor, track and share with third parties your geo-location information obtained by any of CMGO for safety, security, technical, marketing and commercial purposes, including to provide and improve our products and services.
7.2 For example, CMGO may use cookies and other technologies. In this regard:
a) Cookies are small text files stored in your computing or other electronic devices when you visit CMGO for record keeping purposes. Cookies are stored in your browser's file directory, and the next time you visit CMGO, your browser will read the cookie and relay the information back to the website, platform or element that originally set the cookie. Depending on the type of cookie it is, cookies may store user preferences and other information.
b) Web beacons (also known as pixel tags and clear GIFs) involve graphics that are not apparent to the user. Tracking links and/or similar technologies consist of a few lines of programming code and can be embedded in CMGO. Web beacons are usually used in conjunction with cookies and primarily used for statistical analysis purposes. This technology can also be used for tracking traffic patterns on CMGO, as well as finding out if an e-mail has been received and opened and to see if there has been any response.
7.3 Without limiting the generality of the foregoing, we may employ cookies and other technologies as follows:
a) tracking information such as the number of visitors and their frequency of use, profiles of visitors and their preferred sites;
b) making CMGO easier to use. For example, cookies may be used to help speed up your future interactions with CMGO;
c) to better tailor our products and services to your interests and needs. For example, cookies information may be identified and disclosed to our vendors and business partners to generate consumer insights;
d) collating information on a user's search and browsing history;
e) when you interact with us on CMGO, we may automatically receive and record information on our server logs from your browser. We may collect for the purposes of analysis, any statistical and site-related information;
f) using such information to understand how people use CMGO, and to help us improve their structure and contents;
g) using cookies that are necessary in order to enable CMGO to operate, for example, cookies that enable you to log onto secure parts of CMGO; and/or
h) personalising CMGO for you, including delivering advertisements which may be of particular interest to you and using cookie related information to allow us to understand the effectiveness of our advertisements.
7.4 We may also collect information about your precise or approximate location as determined through data such as your IP address or mobile device's GPS to manage content rights and to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device's settings menu. Celestial may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions.
7.5 Some cookies we use are from third party companies to provide us with web analytics and intelligence about CMGO. These companies collect information about your interaction with CMGO. We use such information to compile statistics about visitors who interact with CMGO and other Celestial online content, to gauge the effectiveness of our communications, and to provide more pertinent information to our visitors.
7.6 If you do not agree to such use of cookies, you can adjust your browser settings. Unless you have adjusted your browser settings to block cookies, our system will issue cookies as soon as you visit our site or click on a link in a targeted email that we have sent you, even if you have previously deleted our cookies.
7.7 The way which cookies can be managed depends on your browser. Please check with your browser provider on how you may configure or disable cookies on your browser.
7.8 If you do not agree to our use of cookies and other technologies as set out in this Privacy Policy, you should delete or disable the cookies associated with CMGO by changing the settings on your browser accordingly. However, you may not be able to enter certain part(s) of CMGO. This may also impact your user experience while on CMGO.
8. Data Security
8.1. Celestial cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that no harmful code will enter CMGO (for example viruses, bugs, trojan horses, spyware or adware). You should be aware of the risks associated with CMGO.
8.2. We cannot ensure the security of the information you transmit to us via the Internet, and we urge you to take every precaution to protect your Personal Data when you use our platforms. We recommend that you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser.
8.3. If applicable, you undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken place. We are not liable for any damages resulting from any security breaches, on unauthorised and/or fraudulent use of your username and password.
9. Third-Party SERVICE PROVIDERS AND Sites
9.1. CMGO may contain links to other websites operated by third parties. We are not responsible for the privacy practices of third party service providers and websites operated by third parties that are linked to CMGO, including without limitation the privacy practices of any third party telecommunications, TV, internet, or Subscription Service Provider through which you have subscribed to our services. We encourage you to learn about the privacy policies of such third party websites and service providers. Some of these third party websites and service providers may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left CMGO, you should check the applicable privacy policy of the third party website to determine how they will handle any information they collect from you.
10. Contacting Us – QUESTIONS, Feedback, Withdrawal of Consent, Access and Correction of your Personal Data
10.1. If you:
a) have any questions or feedback relating to your Personal Data or our Privacy Policy, including without limitation our reliance on the legitimate interests and/or deemed consent bases of collecting, using and/or disclosing your Personal Data as described in this Privacy Policy;
b) would like to withdraw your consent to any use of your Personal Data as set out in this Privacy Policy; or
c) would like to obtain access and make corrections to your Personal Data records, you can approach us via email at privacy@cmgo.com
10.2 You may also write to our Data Protection Officer as follows:
Attn: Data Protection Officer
Address: Unit 1603, 16th Floor, Kwun Tong Harbour Plaza, 182 Wai Yip Street,
Kwun Tong, Kowloon, Hong Kong SAR
Please note that if your Personal Data has been provided to us by a third party, you should contact such party directly to make any queries, feedback, and access and correction requests to Celestial on your behalf.
10.3 You may withdraw your consent as provided under PDPA. However, if you withdraw your consent to any or all collection, use, and/or disclosure of your Personal Data, depending on the nature of your request, Celestial may not be in a position to continue to provide its products or services to you, administer any contractual relationship already in place, or perform or conclude an existing or prospective agreement. This may also result in the termination of any agreements you have with Celestial, and your being in breach of your contractual obligations or undertakings. Celestial's legal rights and remedies in such event are expressly reserved.
11. Governing Law
11.1 This Privacy Policy and your use of CMGO shall be governed by the laws of Singapore.
Last updated: 15/08/2024