Virgin Media Television Privacy Policy
A. We care about your privacy
Virgin Media Television Limited, Macken House, 39/40 Mayor Street Upper, Dublin 1, (“Virgin Media Television”, “our”, “we” or “us”) is committed to protecting your privacy. We want you to be confident in the knowledge that we treat your information with care and in accordance with our obligations under applicable data protection and privacy laws. This privacy policy (“Policy”) describes how we obtain and process your information when you use our services and when we provide you with our services.
This Policy applies to all individuals that provide their personal data to Virgin Media Television as well as including visitors to or users of our websites or apps, or any person that engages with us such as by phone, text, post, email, social media or audience participation.
When you use our services, your information will be handled as set out here in this Policy. While we may make changes to this Policy from time to time, we will publish any updated version of this Policy on our website, and we will take steps to inform you in advance of any material change that may affect the services that you have subscribed to.
B. Information we collect
· Registration Details, means information you provide to us when you register for use of our online services including the Virgin Media Player. This data includes name, email address, password you set up to access your account, age, gender, county of residence and your marketing preferences;
· Interaction Data, meaning information you voluntarily provide to us when you provide feedback including queries, complaints, comments, or when you enter competitions or interact with Virgin Media Television through any means including phone, post, text, email, social media, audience participation or through apps and websites;
· Website Data, such as when you use our website, we collect the time and duration of the session, pages visited, campaign attributes, information on the selection of shows you watch, how much time you have spent using our online services and what are the most popular sections of our online services as well as technical details (IP/MAC address, operating system and browser type). We also use cookies on our websites and please see our Cookie Policy for more information on the management of cookies;
· App Data, we keep a record of whether or not and how often you use the Virgin Media Television Apps;
· Personalisation Information, meaning information you provide to us in order to personalise a Virgin media Television website or App to your preferences;
· Service Data, means information about any service errors or interruptions that you have experienced in order to help us create fixes and to make technical improvements to our services;and
· Third Party Data, we may also use information about you from trusted commerce partners that have obtained your permission to share data with us, such as advertisers, market researchers, panels you take part in and or other companies you have bought products and services from.
As further explained below, we may combine this information even where it is collected in different ways.
C. How we use your information
1. To provide our services
We use your information so we can provide you with Virgin Media Television services. For example:
- To set up, manage and administer your online account and provide access to our Apps
- To bring you relevant and entertaining TV content and advertising at home or via mobile devices.
- To make sure our services are working as they should be.
- To respond quickly to your queries or issues.
- To administer competitions you may enter.
Providing our services to you also involves performing the following activities which are necessary to make the service available to you such as technical and commercial support including providing service messages about our online services such as password reminders, to provide account administration and quality controls. We use IP addresses and device identifiers to determine you are accessing the services from Ireland as sometimes content is bought for Irish viewing only.
We may also use your information when asking for feedback in respect of the performance of our services such as requesting you to take part in surveys. This information helps us to understand which content and services are most interesting and enjoyable for our users and to ensure we are providing you with the best possible services.
If you voluntarily provide us with any information which includes any special categories of personal data (such as information about your health, race or religion), you must make sure before you provide this that you are happy for us to use that information for the purposes set out in this Policy. We may also monitor and record our communications with you, including e-mails and phone conversations, for training purposes, quality assurance and to record details about the services you avail of from us. Please note that you need to be 18 or over to register for the Virgin Media Television Player service. You will be asked to confirm your age at the registration stage.
Legal basis for processing this information:
Legitimate interests
2. To personalise your service and build your profile
TV recommendations:
Should you choose to become a registered user of our Virgin Media Player, you can experience catch-up TV like you\'ve always wanted; easy access to your favourite shows, get personal recommendations of what to watch next and download the episodes you want to save for later. Where you have registered an account with us, we need to analyse the information you supply so that we can offer you a better personalisation service or to contact you about a comment you have sent us.
For example, when you watch something on Virgin Media Player through a registered account, we use that information to make recommendations to you of new shows to watch, based on what you\'ve previously seen and \'favourited\'.
Legal basis for processing this information
Legitimate interest/consent
Personalised advertisements:
We may use your information to personalise the ads you see where you allow us to do so.
We work with advertisers to make sure the ads are as relevant to you as possible. Where you register on our 3player, we ask that you provide your age, gender and county as this allows us to tailor the ads that you see within your favourite shows. Virgin Media Television does not receive any television license revenue and relies on advertiser funding to continue providing top-quality entertainment shows for Irish viewers.
Trusted third party providers help us to present personalised advertisements or other content on our website and other websites that display Virgin Media Television advertisements.
In order to ensure that the most relevant type of advertising is presented to you while using our services, information can be analysed to allow Virgin Media Television to show a selection of advertisements to different viewers. We may use information we collect from you while using our services to choose which adverts you see. We may engage with trusted commerce partners to ensure that any advertisements presented to you are more useful and relevant. Sometimes this is based on Third Party Data that these companies provide to us. We may analyse your viewing information to provide you with suitable advertising.
Advertising network providers use cookies, web beacons, or similar technologies on your computer or mobile or other device to serve you advertisement or content tailored to interests you have shown by building an understanding of your internet browsing on the website and other websites you have visited. The use of cookies, web beacons, or similar technologies by our advertising network providers is subject to their own privacy policies, not Virgin Media Television’s Policy. For more information on how we use cookie type technologies and how you can manage them, please read our cookies policy found at the following link.
We may use Registration Details, Website Data, App Data Third Party Data and Personalisation Information, to personalise the TV content and ads you see on websites and Apps and to build an understanding of your interests and preferences.
Legal basis for processing this information:
Legitimate interest/consent
3. Marketing
We will use the email address you provide to us to send you email marketing (including our newsletter, information about new shows, rewards and competitions) where you have signed up to receive this from us. You can opt out of receiving marketing emails at any time by contacting us via our website. If you opt out of email marketing, we will still need to send you service communications by email from time to time, such as information about changes to our services.
Provided you agree to receive marketing information from us by the means you have chosen, we will continue to send you information about our services until you contact us to opt out of receiving some or all of the marketing in which you receive the information.
We may use your Registration Details, Website Data, App Data, Service Data, Third Party Data and Personalisation Information Data in order to offer you such products and services.
Push notifications
If you download the Virgin Media Player App, some of the communications that we send to you, including marketing communications, content recommendations and information about new content or features, may be sent by push notification. Push notifications are messages that pop up on your mobile device. You can choose whether or not to receive push notifications from the Virgin Media Player App through your device settings (e.g. android, iphone). If you change your mind, you can also change your preferences at any time in your device settings.
Legal basis for processing this information:
Marketing communication we send to you requires your consent.
4. To meet our legal obligations and for safety and security
We need to store some of your information to meet our legal obligations. We may be required by law to retain or disclose your information to competent authorities, including law enforcement agencies, where we have a good faith belief that we are required to do so under applicable law. These disclosures may be made without your knowledge, and without further notice, in compliance with our legal obligations. We reserve the right to challenge the access to information by authorities but we do not promise to challenge every demand.
We may retain, preserve or share other information if we have a good faith belief that it is reasonably necessary to (a) respond, based on applicable law, to a legal request; (b) detect, investigate, prevent, and address fraud and other illegal activity, security, disruptive use or technical issues; (c) protect our rights, property, or safety; (d) enforce our terms and conditions of providing services to you or any other agreements we have with you; (e) prevent physical injury or other harm to any person or entity, including yourself and members of the general public.
Legal basis for processing this information:
Compliance with a legal obligation, or where in our, your or others’ legitimate interests or vital interests, or in the public interest.
5. For Statistics
We perform statistical analyses of user behaviour and characteristics, in order to measure interest in, comments or feedback on, and use of the various sections of our websites or any content shown and type and manner in which it is viewed and advertisements presented so as to improve design and navigation and to gather market information.
We may use depersonalised and aggregated information to develop reports and analysis about what types of content and /or advertisements are watched or skipped, for research and for other legitimate business purposes. We combine your information, in aggregated form, with those of other users to generate summarised reports that help us to optimise our services and programming, and can also help other entities, like advertisers, better plan their activity. This information will allow us, for example, to make better decisions about the content we make available and to ultimately improve our services.
We use your Registration Details, Website Data, App Data, Service Data, Third Party Data and Personalisation Information Data for these statistical purposes.
Legal basis for processing this information:
Legitimate interest.
D. How do we protect your information?
We work very hard to protect your privacy and have taken key steps in protecting it. We have formally appointed individuals who are responsible for the security of our information systems. We have implemented solutions to protect your information, which consist of a variety of both technical and policy based solutions which vary depending on the applicable service or product offered or provided to you. These solutions may include, but are not limited to, password protection, encryption, firewalls, anti-virus, intrusion detection, anomaly detection and access controls for our employees. However, the nature of the internet is such that we cannot guarantee or warrant the security of any information you transmit to us via the internet. No data transmission over the internet can be guaranteed to be 100% secure.
E. Lawful basis for processing:
To use your information lawfully we rely on one or more of the following legal bases:
- Performance of a contract;
- Legal obligation;
- Our legitimate interests;
- Your consent (where you have provided it);
- Protecting the vital interests of you and others; and
- Public Interest.
To help you better understand where these legal bases apply we have set out for you some examples of each lawful bases at various point throughout this policy, for example at Section C “How we use your information” we clarify that your information is used for legitimate interests in some cases, using your consent for email marketing and for legitimate interest purposes in the case of statistical purposes. Where we rely on your consent to process your information, you have the right to withdraw or decline your consent at any time.
F. Data Retention:
We retain your information in accordance with our record retention policy. This policy operates on the basis that we only retain information for as long as is necessary and in accordance with any legal requirements that we are required to meet.
Where applicable and in order to offer you information on our services, we collect and store certain information for so long as you remain a registered user of the 3player. You can of course contact us at any time as set out in the ‘Your rights’ section of this Policy.
We retain your information even after you have stopped receiving services from us if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our terms and conditions of service, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalised information after your account has been closed.
G. Confidentiality of your information
We will keep your information confidential except where disclosure is required or permitted by law for example to government bodies and law enforcement agencies.
H. Sharing your information
We share your information with the following third parties:
Service Providers – we rely on trusted third parties to help us run our business and to provide us with specialised services. These can include companies who provide the following:
- Third Party login service providers:
We may request that you sign in to the Virgin Media Player via a third party service (e.g. Facebook) to participate in a game or use an app. In such instances you will be presented with a dialog box which will ask for your permission to allow your information (e.g. your full name, date of birth, work) to be provided to Virgin Media Television.
- Analytics Service Providers:
We use third party analytics services to help understand your usage of our services. In particular, we provide a limited amount of your information (such as your email address and sign-up date) to trusted third party analytics providers and utilise their services to collect data for analytics purposes when you visit our website or use our online services. Your use of our website and/or services is analysed so we can improve our service to you. We may also use analytics service providers as a medium for communications, either through email, or through messages within our service(s). Analytics service providers collect publicly available contact and social information related to you, such as your email address, gender, company, job title, photos, website URLs, social network handles and physical addresses, to enhance your user experience. If you would like to opt out of having this information collected or submitted to an analytics service provider please contact us.
- Other third parties:
We may also use legal advisors, accountants and consultants and we may share your information with them for legitimate business purposes.
Regulators – in certain circumstances we are required to provide your information to a regulator or other statutory bodies (e.g. in the investigation of complaints).
Group Companies – Virgin Media Television is part of Liberty Global Group. We may share your information with companies within the Liberty Global Group, with our parent company, subsidiaries, or other companies under common control (collectively "Affiliates"), for the operation of services or a purchaser of our business. We will require our Affiliates or any purchaser to honour this Policy where we share your information with them.
We require all of the above third parties to keep your information confidential and secure and use it solely for the purpose of providing the specified services to us.
Transfers outside the European Economic Area (EEA)
Some third parties may be located in countries outside the EU and Switzerland where different privacy rules apply. We will continue to use the European Commission-approved Standard Contractual Clauses as a legal mechanism for data transfers from the E.U. These clauses are contractual commitments between companies transferring personal data (for example Virgin Media Television to its parent company, Liberty Global Inc.), binding them to protect the privacy and security of the data. Virgin Media Television adopt Standard Contractual Clauses so that the data flows necessary to provide, maintain and develop our services takes place legally.
Further information about the Standard Contractual Clauses adopted by the EU Commission can be found at the end of this Policy.
I. Your rights
Here we set out your rights in relation to how we use your information. You can exercise these rights by submitting a request to any of the following at any time, by contacting the Data Protection Officer at Data Protection Officer, Virgin Media Television, Ballymount, Dublin 24. While some of these rights apply generally, certain rights apply only in certain limited cases.
Withdraw your consent:
Where you have given your consent to any of the uses of your information mentioned you can withdraw your consent at any time. If you withdraw your consent to the use or sharing of your information for purposes set out in this Policy, you may not have access to all (or any) of our products or services and we might not be able to provide you all (or any) of the products or services under this Policy. In certain cases, we may continue to process your information after you have withdrawn consent if we have a legal basis to do so or if your withdrawal of consent was limited to certain processing activities.
Access your information:
You can request a copy of the information that we hold about you.
Rectify your information:
If the information we hold about you is inaccurate or incomplete you can request a rectification.
Erase your information:
You can ask us to delete your information.
Portability:
You can request that the information you provided to us be returned to you in a commonly used machine readable format, or, if you wish, directly transferred to another provider.
Restriction of processing:
You can request restriction of processing for the following cases (please state which case you are in when making your request):
- If you are contesting the accuracy of the your information;
- If you believe that we shouldn’t be processing your information, but you don’t want us to erase it;
- If we no longer need the information but you need it for the instigation or defence of a legal claim;
- If you have objected to the processing and we are in the process of verifying whether we have legitimate grounds to keep processing the information.
You can request to stop receiving our latest offers from us:
- You can choose not to be notified of our latest offers.
Automated decisions including profiling:
You have the right to ask for any automated decision, including profiling, to be manually assessed by a person in certain circumstances.
J. How can you contact us about this Policy?
The controller of your information is Virgin Media Television Limited having its registered office at Macken House, 39/40 Mayor Street Upper, Dublin 1, Ireland.
Data Protection Officer (DPO): You can address any question, comment or request regarding your information to our Data Protection Officer by post to the address provided above.
Data Supervisory Authority: In case you’re not satisfied with the response we give you, you can also lodge a complaint with a data protection supervisory authority such as the Office of the Data Protection Commission:
Data Protection Commission
21 Fitzwilliam Square South
Dublin 2
EirCode D02 RD28
Telephone: +353 01 7650100
E-mail info@dataprotection.ie
Additional information about International data transfers using Standard Contractual Clauses
The European Commission can decide that standard contractual clauses offer sufficient safeguards on data protection for the data to be transferred internationally.
It has so far issued two sets of standard contractual clauses for data transfers from data controllers in the EU to data controllers established outside the EU or European Economic Area (EEA).
It has also issued one set of contractual clauses for data transfers from controllers in the EU to processors established outside the EU or EEA
EU controller to non-EU or EEA controller
EU controller to non-EU or EEA processor