This privacy notice was last updated on the 1st of March 2019.
- What information do we collect?
- What do we do with the information we collect?
- Personalised Advertising
- Who do we share this information with?
- Your rights
- Linking to other websites
- Children's information
Please read this privacy notice carefully as it sets out how TVPlayer Limited, a company registered in England and Wales under company number 12154738 with its address at Suite 1, 3rd Floor, 11-12 St. James's Square, London, SW1Y4LB ("us" "we" or “the Company”) uses your personal information.
We are an online content service provider offering access to live television channel streams and on-demand content using either a web-browser or application software, known as "TVPlayer".
We may change this privacy notice from time to time by updating this page. When we do we'll revise the 'last updated' date at the top of this privacy notice and we will take reasonable steps to make you aware of any material changes to it. We also recommend that you check this page from time to time to ensure you keep informed of our current privacy practices.
2. What information do we collect?
When you use TVPlayer, please bear in mind that we may record:
- the areas of the website or application that you visit;
- content you consume such as channels and shows you have viewed; and
- information about your device, such as which browser you are using, your network location, the type of connection you are using (e.g. broadband, ADSL etc) and your IP address.
Once you register or log in or submit information through our website or apps we will know who you are, and your activities on our website and TVPlayer. Information about you may be recorded on our systems. For example, we may ask for the following information when you submit an online enquiry, register for our newsletter, subscribe to TVPlayer or create an account:
- your name;
- email address;
- billing address;
- post code;
- country where you are based or purchasing our products/services from;
- date of birth;
- content preferences such as favourite channels and genres.
We may also collect personal information from you at trade shows/events, from telephone calls and/or other correspondence with you.
We may receive information about you and your activities on and off TVPlayer from third-party partners, such as information from a partner when we jointly offer services or from an advertiser about your experiences or interactions with them.
We may also ask for payment information, i.e. the details of the payment card you are using to pay for any products/services. This type of information is processed strictly in accordance with relevant payment card industry standards.
We do not store your billing address, billing country or any payment information – this is held securely by the payment processor who is fully PCI compliant.
3. What do we do with the information we collect?
We use this information for all sorts of reasons, which are set out in this section.
In accordance with data protection laws, we will only process your personal data where we have a lawful basis for doing so.
- Where we have to collect personal data from you and/or use it in order to provide you the services which you have signed up for, our lawful basis is processing necessary for the performance of a contract with you (necessary for a contract).
- Where our use of your personal data is a benefit to us or a third party and your fundamental rights and freedoms are not prejudiced, our lawful basis is processing necessary for our (or a third party’s) legitimate interests (legitimate interests). You can learn about your right to object, in certain circumstances, to us continuing to use your personal data where we rely on legitimate interests below.
- In addition we will also use your information when we are required to do so by law. Where that is the case, our lawful basis is processing necessary for us to comply with a legal obligation that we are under (legal obligation).
Specifically, the following are a list of the purposes for which we process your personal information and the lawful bases on which we rely to carry out such processing:
|To provide you with TVPlayer (whether available via the website, a TVPlayer app or offline).||Necessary for a contract.|
|Internal record keeping.||Legitimate interests (for business administration purposes and in accordance with our data retention policy) We may also keep records where we are required to do so to comply with a legal obligation.|
|Product and service development (including error detection and rectification).||Legitimate interests (of us and our customers, so that TVPlayer works as effectively as possible).|
|Answering your queries or complaints.||Legitimate interests (of us and our customers, so we can provide good customer service).|
|Marketing our own products and services to you.||Legitimate interests (sending our customers marketing is a commercial benefit to us and helps our customers keep up to date with other products they may be interested in). Our customers always have the right to opt-out of our use of their personal data for direct marketing purposes.|
|Making recommendations for programmes and content you might like based on your past viewing habits and demographic.||Legitimate interests (of us and our customers so that our customers can easily locate content likely to interest them).|
|Analysing your use of our website and TVPlayer and the effectiveness of our advertising (including information collected via cookies).||Legitimate interest (of us and you, so our website is user-friendly and so we can understand how people use our service, what content is popular and which advertising campaigns are effective).|
|Fraud prevention.||Legitimate interests (of us and our customers) and we will also take such steps as are necessary to comply with any legal obligations we are under.|
|Sharing an identifier relating to you (such as a truncated IP address) or limited account registration information (such as your postcode) with our trusted third party advertising partners (including Videology and GroupM UK Limited (who also work with Videology Limited and Finecast Limited)).||Legitimate interests (of us and our advertising partners, to enable them to match against data they may legally hold about you and use that combined information to serve ads of particular relevance to you, for frequency capping to limit repetitive advertising, and for analytics purposes).|
|Showing you personalised advertising so that you receive advertising likely to be most relevant for you (which may be banner adverts or video adverts which are shown before or during content you select to view). This is commonly known as online behavioural advertising.||Legitimate interests (of us, to enable us to keep the cost of our subscription service as low as possible and to keep our free service free of charge for users).|
|Benefiting from the services and expertise of third party service providers (such as technical infrastructure providers, analysis and research providers, payment providers and customer services providers).||Legitimate interests (of us, for service efficiency and our customers, so they experience a good quality of service).|
|To verify your country of residence upon registration, when your subscription renews or if we have reasonable doubts about your usual place of residence during the period in which you pay for any relevant TVPlayer service.||Legal obligation.|
We may also depersonalised data in order to create aggregated statistics about the users of our site in order to describe our sales, customers and their viewing habits traffic patterns and other site information to prospective partners, advertisers, investors and other reputable third parties and for other lawful purposes, but these statistics will include no personally identifying information.
We would like to provide you with information about TVPlayer’s products and services, and other information which we think you may find interesting. We may send you such information by post, email, app notification and/or telephone unless you have asked us not to do so.
If you are a customer of ours or you have previously asked us for information on our products and services, we may send you information by email or notification. However, you have a right under data protection legislation to opt-out of our use of your personal data for direct marketing purposes (including profiling for direct marketing purposes). In every marketing email message we send you we will give you the opportunity to unsubscribe from our mailings altogether. You can also disable notifications from us within your device’s notification settings, as well as by visiting the notifications section within the “Accounts” section online. Alternatively, you can contact us at email@example.com if at any time you do not want your information used for direct marketing purposes.
We do not pass on your contact details to external organisations (i.e. outside of the Company) for their own marketing purposes without your consent.
5. Personalised Advertising
The sale of advertising helps to fund our service and keep subscription costs down. We want our advertising to be as relevant and engaging as the other information you find on TVPlayer. With this in mind, we work with advertising partners to show you relevant ads, for example, if you live in Leeds then you may be more likely to see an ad for an event in Yorkshire - and less likely to see an ad for an event in London. We pass on limited data relating to you (such as a truncated version of your IP address or your postcode) to our advertising partners (including Videology Limited and GroupM UK Limited (who also work with Videology Limited and Finecast Limited)) who display website banner advertising and video advertising before and during TVPlayer content. Our advertising partners may use advertising software which can combine the information we provide about you with other information (such as your previous browsing behaviour) in order for them to select adverts which are likely to be most relevant to you.
If you do not want to receive personalised advertising on TVPlayer you can opt-out of your information being used for personalised advertising purposes by logging into your TVPlayer account and updating your advertising preferences. Please note that if you opt-out of receiving personalised advertising, you will still see the same number of ads, but these ads will not be tailored to you.
6. Who do we share this information with?
In addition to sharing information with our advertising partners as described above, we also transfer information to vendors, service providers, and other partners who support our business, such as providing technical infrastructure services, analysing how our services are used, measuring the effectiveness of ads and services, providing customer service, facilitating payments, or conducting academic research and surveys. These partners must adhere to strict confidentiality obligations and use your personal information in a way that is consistent with this privacy notice and the agreements we enter into with them.
We may also share your personal information with a purchaser or potential purchaser of our business.
In some circumstances, we may have to disclose your personal information by law, because a court or the police or other law enforcement agency has asked us for it or in connection with legal proceedings.
7. Your rights
Under certain circumstances, by law, you have the right to:
- Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground and where we do not have compelling legitimate interests to override such objection. You also have the right to object where we are processing your personal information for direct marketing purposes including profiling for direct marketing purposes (as set out above).
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request the transfer of your personal information to another party.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive.
If you would like to exercise any of your rights please contact us. We may take steps to verify your identity before providing you access to your personal data.
Please be aware that the rights above are not absolute and there may be circumstances where we are unable to comply with your request. In such cases we will explain why we cannot comply with the request.
You also have the right to make a complaint to the Information Commissioner's Office in respect of the processing of your personal data.
If you think any information we have about you is incorrect or incomplete, please contact us as soon as possible. We will correct or update any information as soon as we can.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect, including secure data storage facilities and electronic password protection.
If at any point you suspect or become aware of a security incident (i.e. your password is stolen or you receive suspicious communication from someone holding themselves out to be a TVPlayer employee or from a dupe website claiming to be affiliated with TVPlayer), please forward the communication to us or report the incident by email to firstname.lastname@example.org
9. Linking to other websites
10. Children's information
You must be at least thirteen years of age to use TVPlayer; sixteen years of age to register for and use our free service; and eighteen years of age to register for and use the paid for service. Where you are under sixteen years of age we recommend that you discuss this privacy notice with your parent or guardian. We do not knowingly collect personal data from children under the age of thirteen.
We will only retain your data for as long as is necessary in accordance with the purposes set out in this privacy notice.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and applicable legal requirements.
Accordingly, we will keep a record of your viewing data for up to 26 months following no activity with our website or apps, and we will keep other personal data we hold about you for up to 26 months following the date you close your account with us. This retention period may be extended if any applicable statutory or regulatory obligation requires us to hold information for a longer period. We will endeavor to delete any personal data sooner where it is not necessary for us to hold this.
Please note that if you opt-out of any marketing we will retain a record of your data to ensure that you do not receive any marketing.
In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you.