PRIVACY POLICY

Thank you for using iflix! We respect your concerns about privacy and appreciate your trust and confidence in us.

Here is a summary of the information contained in this privacy policy (“Privacy Policy”). This summary is to help you navigate the Privacy Policy and it is not a substitute for reading everything! You can use the hyperlinks below to jump directly to particular sections.

What information do we need to provide the Services?

If you register an account to use the Service then we will need some information from you to set this up. If you choose to set up your profile using a social media account, such as Facebook, we also collect information, including contact details, gender and birth date, from that social media account when you link it with iflix. If you choose, you can provide certain other optional information to set up your account and/or to enable certain Service features. If you need to get in touch with us then we will also retain some information so that we can get back in touch with you and address any concerns. More Information.

How will we use your information?

We use your information to provide the many functions and services that comprise the Service. We also use your information for account verification, security purposes and to support and improve the Service.

Who do we share your information with?

We do not share your information with any third parties, except where we need to in order to provide the Service (e.g., use local cloud providers or to back up your data; using our affiliates around the world to help us to deliver the Service) or monitor the success of our marketing and advertising programs, or we are instructed to by a court, authority or compelled by law. More Information.

Where do we process your information?

Our servers are located in Singapore. Our support, engineering and other teams are located in our offices around the world (including Hong Kong and the People’s Republic of China (for the purpose of this Privacy Policy, this term excludes Taiwan, Hong Kong and Macau) (“PRC”)) and will have access to your information. More Information.

How long do we keep hold of your information?

We generally retain your information for the period during which you maintain an account for the Service, after which time your data is deleted (as further described in this Privacy Policy), unless otherwise required by applicable laws. More Information.

How can I exercise my rights over my information?

Depending on where you are, you may have certain rights with respect to your information, such as rights of access, to receive a copy of your data, or to delete your data or restrict or object to our processing of your data. More Information.

How to get in touch with us

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, please contact us here.

How will we notify you of changes?

Changes to this Privacy Policy will be posted here. Please check this page frequently to see if there are any updates or changes to this Privacy Policy. More Information.

Contact Information

Data Controller:

Image Future Malaysia Sdn. Bhd.

Welcome to iflix!

This Privacy Policy explains the when, how and why when it comes to processing of your personal information in connection with iflix (the “Service”), and sets out your choices and rights in relation to that information. Please read it carefully – it is important for you to understand how we collect and use your information, and how you can control it.

If you do not agree to the processing of your personal information in the way this Privacy Policy describes, please do not provide your information when requested and stop using the Service. By using the Service you are acknowledging our rules regarding your personal information as described in this Privacy Policy.

In this Privacy Policy, “we“, “our“, or “us” refers to Image Future Malaysia Sdn. Bhd., a Malaysia company located at Level 19­-1, Menara Milenium, Jalan Damanlela, Pusat Bandar Damansara, 50490 Kuala Lumpur W.P. Kuala Lumpur, Malaysia. Image Future Malaysia Sdn. Bhd. is a member of the Tencent corporate group.

Please reach out to us if you have any questions or concerns regarding the processing of your personal information: you can contact us anytime at privacy@iflix.com.

1. The Types of Personal Information We Use

This section describes the different types of personal information we collect from you and how we collect it. If you would like to know more about specific types of data and how we use that data, please see the section entitled “How we use your personal information” below.

The following is a high level summary of the types of personal information we use:

1. Information you provide to us (either directly or through a third party).

• • Account registration information: You give us information about you when you set up an account to register for the Service: your name, email address, phone number, profile picture, gender, birth date and login details. If you choose to register for the Service using your Facebook account, your information from your social media account, including your username, profile picture, gender and birth date.
  • Customer support and feedback information: Relevant information that you voluntarily provide to us when you communicate with our customer service, when you give us reviews or feedback, set preferences on the “Settings” page of the Service or otherwise provide information to us through the Service.
  • Survey information: When you participate in a survey in the Service or marketing promotions (in which case we will process the information you provide to us as part of the survey or marketing promotion, including your email address, birth date, gender, and information from your Facebook account, including your username, profile picture, gender and birth date, should you choose to log in via your Facebook account.

2. Information about you generated as part of the Service

We automatically collect certain data from you when you use the Service, namely:

• Your IP address, Open ID and device information, including device ID, the device you use to access the Service (e.g. computer, gaming systems, smart TVs, mobile devices etc.) and its type and configuration, connection information;
• Information regarding your use of the Service, such as statistics on page views, referral URLs and ad data;
• User log and running log information (i.e. log information on all the actions that you conduct when using the Service);
• Each time you interact with us, for example, if you contact our customer support team, we collect information including your name, date and time of contacting customer support, chat transcripts with customer support, your phone number (if you call us), Open ID, device ID, application version, battery level, WiFi strength, free space on device, iOS version, platform, network type, carrier, country code, and details of the ticket and error. You also have the option of providing your email address and a photo to illustrate the error;
• Your search history on iflix, including what content you select, what videos you watch and what videos you almost watched on iflix;
• If you click on a link that advertises the Service, we store the advertising ID for that advertisement and marketing analytics data (e.g. device ID, engagement data and search terms) with your profile;
• if you choose a paid subscription for the Service, we collect transaction information to facilitate your paid subscription and to maintain transaction records (Open ID, cost, product purchased, IP address, device details and, if it is a web-based transaction, your email address); and
• When you are using the Service, our security feature collects (in addition to the categories of data listed above) device information including a list of installed hack software, equipment brand and model, available space on the device, and information about your internet connection including the type (WiFi/4G/3G).

We do not collect your credit card details (name, credit card number, expiry date and billing address), which will be collected by third party payment processors instead (for example, if you choose to subscribe via in-app purchase).

Cookies

We use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience using the Service. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality.

For more information about our Cookies policy, click here.

Children

Children must not use the Service for any purpose, except where their parent or guardian has provided consent (to the extent this option is available in your jurisdiction).

By children, we mean users under the age of 18 years old; or in the case of a country where the minimum age for processing personal information differs, such different age. For users located in certain countries we have listed the relevant minimum age in the table below.

If you believe that we have personal information of a child under these ages without parental/guardian consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact us at privacy@iflix.com and we will delete such information.

2. How We Use Your Personal Information

This section provides more detail on the types of personal information we collect from you, and why.

3. How We Store and Share Your Personal Information

The Tencent group operates around the world. Pursuant to our contract with you to provide you with the Service, your personal information will be processed on servers that may not be located where you live. No matter where our servers are located, we take appropriate measures to safeguard your rights in accordance with this Privacy Policy. Our servers for the Service are located in Singapore.

In addition, our support, engineering and other teams are located in our offices around the world (including Hong Kong and the PRC) and will have access to your information.

Only where necessary will we share your personal information with third parties. Situations where this occur are:

• Third parties that provide services in support of the Service, including (i) iflix support staff who assist to provide you with the Service; (ii) our marketing partners who may offer marketing promotions to you during your use of the Service; (iii) service providers who assist with providing marketing, advertising, communications, messaging, infrastructure and IT services, to personalise and optimise the Service, to provide customer support and to administer customer surveys; (iv) Apple Pay and Google Pay, our payment processors for the purposes of processing payment and to process and limit fraud in connection with your payment method; and (v) AWS, a cloud service provider, for the purpose of providing us with platform, cloud storage, video transcoding and video streaming services in order to support the Service. All companies providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose other than providing us with their services.
• Companies within the Tencent corporate group who process your personal information in order to operate the Service. All related group companies may only use your personal information in accordance with this Privacy Policy.
• Regulators, judicial authorities and law enforcement agencies, and other third parties for safety, security, or compliance with the law. There are circumstances in which we are legally required to disclose information about you to authorities, such as to comply with a legal obligation or processes, enforce our terms, address issues relating to security or fraud, or protect our users. These disclosures may be made with or without your consent, and with or without notice, in compliance with the terms of valid legal process such as a subpoena, court order, or search warrant. We are usually prohibited from notifying you of any such disclosures by the terms of the legal process. We may seek your consent to disclose information in response to a governmental entity’s request when that governmental entity has not provided the required subpoena, court order, or search warrant. We may also disclose your information to:

• • enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
  • detect, prevent or otherwise address security, fraud or technical issues; or
  • protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
• A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.

The Security of Your Personal Information

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted to our services; therefore we do not assume any responsibility for any transmission of your information which you do at your own risk.

4. Data Retention

We do not keep your data for longer than is necessary unless we are required to do so under law. For further details on how long we keep your data, please refer to the time periods set out below.

If we are required to retain your information beyond the retention periods set out above, for example to comply with applicable laws, we will store it separately from other types of personal information.

5. Your Rights

Some jurisdictions’ laws grant specific rights to users of the Service, which are set out in this section.

You have certain rights in relation to the personal information we hold about you, depending on where you are located. Some of these only apply in certain circumstances. To exercise any of your rights, please contact us at privacy@iflix.com.

Announcements

We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend access to the Service for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these service-related announcements, which are not promotional in nature.

Advertising

You may choose to stop receiving personalised advertising or marketing promotions from us when using the Service by clicking here, following the opt out instructions included in the Settings section of iflix or you can contact us at privacy@iflix.com.

6. Contact & Complaints

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to privacy@iflix.com.

In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance at privacy@iflix.com and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the country in which you live or work where you think we have infringed data protection laws.

7. Changes

If we make any changes to this Privacy Policy we will post the updated policy here. Please check this page frequently to see if there are any updates or changes to this Privacy Policy.

SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

Some jurisdictions’ laws contain additional terms for users of the Service, which are set out in this section.

If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our Privacy Policy above.

Bangladesh

Agreement

By accepting this Privacy Policy, you expressly state that you authorize us to collect, use, store, and process your personal data, including, disclosing to third parties, to the extent provided by this Privacy Policy. By clicking “accept”, you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to the PRC.

Age Restriction

In order to use the Service, you represent that you are at least 18 years old and, therefore, legally capable of entering into binding contracts.

Indonesia

Consent

By accepting and consenting to this Privacy Policy, you agree that we may collect, use and share your personal information in accordance with this Privacy Policy, as revised from time to time. If you do not agree to this Privacy Policy, you must not access or use our services and we have the right to not provide you with access to our services.

Parental and Guardian Consent

If you are under the age of 21, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Service.

Data Subject Rights

You have the right to access your personal information stored in our Service from time to time in accordance with applicable data privacy laws and regulations in Indonesia.

Data Breach

In the event we fail to maintain the confidentiality of your personal information in the Service, we will notify you through the contact information provided by you or via the Service, to the extent required by local laws and regulations, at the latest 14 days since we acknowledge the breach of confidentiality.

Data Retention

Notwithstanding the provision on the erasure of personal information, to the extent required by local laws and regulations, we will retain your personal information, at the latest for five years.

Notification to Amendment of this Privacy Policy

In the event we amend this Privacy Policy, we will provide a notification to you regarding the effective date of the changes at the latest fourteen (14) days prior to the effective date, through (i) a notice to be posted on the landing page of our website, pop-up notification, or the splash screen of our mobile app or (ii) the contact information you provided to us. If you fail to explicitly express your objection to the amended privacy policy within the above notification period, you will be considered as accepting the changes and agreed to the new privacy policy. However, you may stop using or accessing our Service by unsubscribing or ceasing your use of the Service at any time, if you cease to agree with the amended privacy policy.

Data Accuracy and Third Party Consent

You are responsible for making sure that any personal details which you provide to us are accurate and current. In order to confirm the accuracy of the information, we may also verify the information provided to us, at any time. You hereby represent that you have secured all necessary consent(s) before providing us with any other person’s personal information (for example, for referral promotions), in which case we will always assume that you have already obtained prior consent, and as such, you will be responsible for any claims whatsoever from any party arising as a result of the absence of such consent(s).

Malaysia

Language of this Privacy Policy

In the event of any discrepancy or inconsistency between the English version and Bahasa Melayu version of this Privacy Policy, the English version shall prevail.

Parental and Guardian Consent

If you are under the age of 18, please do not use the Service.

In the event you are agreeing to this Privacy Policy in order for a minor to access and use the Service, you hereby consent to the provision of personal information of the minor to be processed in accordance with this privacy policy and you personally accept and agree to be bound by the terms in this Privacy Policy. Further, you hereby agree to take responsibility for the actions of such minor, and that minor’s compliance with this Privacy Policy.

Rights of Data Subjects

Right of access: You have the right to request access to and obtain a copy of your personal information that we have collected and is being processed by or on behalf of us. We reserve the right to impose a fee for providing access to your personal information in the amounts as permitted under law.

When handling a data access request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data access request.

Right of correction: You may request for the correction of your personal information. When handling a data correction request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data correction request.

Right to limit processing of your personal information: You may request to limit the processing of your personal information by using the contact details provided above. However this may affect our provision of the Service to you.

Contact

To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information:

• Our data protection officer, responsible for the management and safety of your personal information
• Email: privacy@iflix.com

Philippines

Minimum Age

You are at least 18 years of age to be able to use the Service.

Changes

We will not implement any material changes to the way we process your personal information, as described in this Privacy Policy, unless we have notified you and have obtained your consent to such material changes.

Your Rights

You are also entitled to the following rights:

• Right to object. You shall have the right to object to the processing of your personal information. When you object or withhold consent, we shall no longer process your personal data, unless the personal data is needed pursuant to a subpoena; the collection and processing are for obvious purposes, including, when it is necessary for the performance of or in relation to a contract or service to which you have bound yourself; or your personal information is being collected and processed as a result of a legal obligation.
• Right to access. You have the right to reasonable access to, upon demand, the following:
  • contents of your personal information that were processed;
  • sources from which your personal information were obtained;
  • names and addresses of recipients of your personal information;
  • manner by which such data were processed;
  • reasons for the disclosure of the personal data to recipients, if any;
  • information on automated processes where the data will, or is likely to, be made as the sole basis for any decision that significantly affects or will affect the data subject;
  • date when his or her personal information concerning the data subject were last accessed and modified; and
  • the designation, name or identity, and address of the personal information controller.

• Right to rectification. You have the right to dispute the inaccuracy or error in the personal information and have us correct it immediately and accordingly, unless the request is vexatious or otherwise unreasonable. If the personal information has been corrected, we shall ensure the accessibility of both the new and the retracted information and the simultaneous receipt of the new and the retracted information by the intended recipients thereof. Provided, that recipients or third parties who have previously received such processed personal data shall be informed of its inaccuracy and its rectification, upon your reasonable request.
• Right to erasure or blocking. You shall have the right to suspend, withdraw or order the blocking, removal or destruction of your personal information from our filing system.

This right may be exercised upon your discovery and substantial proof of any of the following:

• your personal data is incomplete, outdated, false, or unlawfully obtained;
• your personal data is being used for purpose not authorized by you;
• your personal data is no longer necessary for the purposes for which they were collected;
• you withdraw consent or object to the processing, and there is no other legal ground or overriding legitimate interest for the processing;
• your personal data concerns private information that is prejudicial to you, unless justified by freedom of speech, of expression, or of the press or otherwise authorized;
• the processing is unlawful;
• we violated your rights.

Consent

By checking the appropriate boxes, you consent to us:

• collecting and processing your personal information consisting of your nickname, social media information, gender, region location, real-time location, friends list, generated open ID; game play statistics, IP address, device ID and information, advertising ID, chat data, transaction records and payments on Google Play or iOS App Store; customer support ticket ID and user communications with Support; security-related information, survey information, sharing event report information, push notification-related information, as described in this Privacy Policy and for the purposes stated herein;
• sharing your personal information with third parties, companies within the Tencent group, and a third party that acquires substantially all or substantially all of us or our business, as described in this Privacy Policy and for the purposes stated herein; and
• transferring or storing your personal information in destinations outside the Philippines when the processing shall need to occur outside the Philippines, such as in servers located in Singapore.

We will also obtain your consent whenever we update or alter information in this Privacy Policy that is material to your consent above.

Singapore

By clicking “accept”, you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, the PRC.

Our designated data protection officer for the purposes of compliance with the Personal Data Protection Act 2012 can be contacted at privacy@iflix.com.

Thailand

By clicking “accept”, you acknowledge that you have read, understood, and agree to this Privacy Policy. If you do not agree with this Privacy Policy, you must not use the Service.

You may request us to discontinue, to restrict the use or provision of, and/or to request for data portability of any and all of your personal information which is stored by us, to the extent provided by the Act on the applicable data privacy laws and regulations in Thailand, including the Thai Personal Data Protection Act. When you wish to make such requests, please contact us at privacy@iflix.com.

We will give you notice by email of any changes to this Privacy Policy, and give you an opportunity to reject such changes, failing which the changes will become effective as stated in the notice.

Vietnam

By accepting this Privacy Policy, you expressly agree and authorize us to collect, use, store, and process your personal information, including, lawfully disclosing and transferring it to third parties, as described in this Privacy Policy.

We maintain international standards and security practices for data protection. When your personal information is transferred within or outside your jurisdiction of residence, it will be subject to the same or higher levels of security practices and data protection by the recipient entity as adhered to by us.

Where we permit any third parties to collect and use your personal information, we shall take reasonable measures to ensure that the third parties do not further disclose the personal information.

Your personal information, if required to be disclosed to the law enforcement agencies, public authorities or other judicial bodies and organisations, it will disclosed upon receipt of written request from such organizations.

Your Rights

You have the right to access, correct, and erase the personal information we hold about you. You also have the right to withdraw your earlier provided consent to collect, store, process, use and disclose your personal information and to request us to stop providing your personal information to a third party.