Last updated: 10th May 2018
Freesat respects your right to privacy. This Privacy and Cookie Notice (“Notice”) explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights. This Notice applies to personal information that we collect when you use and interact with our services such as our website (“Website”), our call centre and our mobile app. For personal information that we collect when you use or interact with our services via TVs and set-top-boxes please refer to the privacy notice that can be accessed on the device concerned.
The Website may contain hyperlinks to websites owned and operated by third parties (for example, links to online retailers). These sites will have their own privacy policies which will govern the use of the information you submit whilst visiting them. Freesat accepts no responsibility or liability for the privacy practices of such third party websites.
If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Notice.
We recommend that you read this Notice in full to ensure you are fully informed. However, if you only want to access a particular section of this Notice, then you can click on the relevant link below to jump to that section.
- What does Freesat do?
- What personal information does Freesat collect and why?
- Who does Freeast share my information with?
- Legal basis for processing personal information?
- Cookies and similar tracking technology
- How does Freesat keep my personal information secure?
- Data retention
- Your data protection rights
- Updates to this Notice and changes to your data
- How to contact us?
What does Freesat do?
What personal information does Freesat collect and why?
Information that you provide voluntarily
We may ask you to provide personal information voluntarily: for example, we may ask you to provide your contact details in order to register an account with us, to subscribe to marketing communications from us, to enter a competition or other promotion and/or to submit enquiries to us. The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.
• Information that we collect automatically
When you visit and interact with our Website and/or use our services we may collect certain information automatically from your device or equipment. In some countries this information may be considered personal information under applicable data protection laws.
Specifically, the information we collect automatically may include information about how your device has interacted with our Website and/or our services, such as your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location), pages accessed, dwell time and links clicked and other technical information.
Collecting this information enables us to better understand the visitors who come to our Website and our customers’ use of our products and services and in particular which content and services are of interest to them. We use this information on an aggregated basis for internal analytical purposes and to improve the quality and relevance of our Website and products and services.
Aggregated data may be derived from your personal data but is not considered personal data as this data does not directly or indirectly reveal your identity. For example, we may aggregate usage data to calculate the percentage of users accessing a specific website feature. However if we were to combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we would treat the combined data as personal data and would use it in accordance with this Notice.
Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading Cookies and similar tracking technology below.
• Information that we obtain from third party sources
From time to time, we may receive personal information about you from third party sources (including for example device manufacturers), but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.
We may use the information we collect from these third parties for the administration and provision of our services, to improve our Website, products and services, and overall customer experience.
Who does Freesat share my information with?
We may disclose your personal information to the following categories of recipients:
• to our third party services providers and partners who provide data processing services to us (for example, to support the delivery of, monitor, enhance the security and user experience of our services or Website) or who otherwise process personal information for purposes that are described in this Notice or notified to you when we collect your personal information;
• to any competent law enforcement body, regulatory or government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
• to a potential buyer (and its agents and advisors) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer that it must use your personal information only for the purposes disclosed in this Notice;
• to any other person with your consent to the disclosure.
Third party service providers may only use and/or process the personal data we provide to them in accordance with our instructions.
Legal basis for processing personal information?
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
We will only use your personal data when the law allows us to. In general we will use the personal information we collect from you only for the purposes described in this Notice or for purposes that we explain to you at the time we collect your personal information. However, we may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (such as research or statistical purposes) if and where this is permitted by applicable data protection laws.
We will normally collect personal information from you only where we have your consent to do so, where we need the personal information to provide products or services to you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. (This may include for the administration or functioning of our services, to analyse and improve the services that we offer and to personalise the way certain content is presented to you). In some cases, we may also have a legal or regulatory obligation to collect personal information from you.
If we ask you to provide personal information to comply with a legal requirement or to provide services to you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
We may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.
If you have questions about or need further information on how we collect and use your personal information, please contact us using the contact details provided under the How to contact us? heading below.
Cookies and similar tracking technology
A cookie is a small amount of data, which often includes a unique identifier that is sent to your device browser and is stored on your device.
For further information about the types of cookies we use, why, and how you can control cookies, please see below.
There are two main categories of cookies:
o First party cookies: these are served directly by the website operator to your equipment and are often used to recognise your device when it revisits the site and to remember your preferences as you browse the site; and
o Third party cookies: these are served by a service provider on behalf of the website operator and can be used by the service provider to recognise your device when you visit other websites. Third party cookies are most commonly used for website analytics or advertising purposes.
We use the following cookies:
o Strictly necessary cookies. These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of the Website.
o Analytical/performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. For example, we use Google Analytics to report on the performance of the Website and use this information to improve the way our Website works. (To learn more or opt out, click here).
o Functionality cookies. These are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences.
o Targeting cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make our Website more relevant to your interests. Third parties may also share this information with Freesat to show Freesat based advertising based on their sites (see “Remarketing” below).
The Website uses DoubleClick and Facebook remarketing and custom audience pixels to display relevant ads tailored to you based on your prior use of the Website. This may include the use of look-a-like audiences to target similar users to those of the Freesat website (read more). We are not collecting any identifiable information through these remarketing programmes.
You can block or modify this activity by visiting the following links:
• Affiliate marketing
The retailer links on the “Get Freesat” section of the Website are affiliate links. This means that we get paid a small commission if you click on the link or make a purchase using the link. You’ll pay the same price whether you use the affiliate link or go directly to the retailer’s website. The only information we see is the number of clicks and sales. No payment or identifiable information is recorded or collected by Freesat. We undertake this type of marketing to help us better understand our most popular products and to enhance the user experience going forward.
We use various third parties to provide us with information to help us learn about how users interact with the Website and attribute sales of boxes.
App Nexus (www.appnexus.com/en/company/platform-privacy-policy)
How does Freesat keep my personal information secure?
We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.
International data transfers
Your personal information may be transferred to, and processed in, countries outside the UK. These countries may have data protection laws that are different to the laws of this country. We will in such circumstances implement appropriate safeguards with our third party service providers and partners, having regard to the nature of the information being transferred and applicable data protection laws and regulations to require that your personal information will remain protected in accordance with this Notice.
We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Your data protection rights
You have the following data protection rights:
• If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent;
• You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you;
• If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the How to contact us heading below;
• You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information in defined circumstances. Again, you can exercise these rights by contacting us using the contact details provided under the How to contact us heading below;
• You have the right to complain to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues (https://ico.org.uk/) about our collection and use of your personal information. (We would however appreciate the opportunity to deal with your concerns before you contact the ICO, so please contact us in the first instance).
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights).
Updates to this Notice and changes to your data
We may update this Notice from time to time in response to changing legal, technical or business developments. When we update our Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material changes to the Notice if and where this is required by applicable data protection laws.
You can see when this Notice was last updated by checking the “last updated” date displayed at the top of this Notice.
It is important that the personal data that we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
How to contact us?
If you have any questions or concerns about our use of your personal information, please contact us using the following details:
The data controller of your personal information is Freesat (UK) Limited which is registered with the Information Commissioner’s Office with registration number Z1223141.