Privacy Notice

This Privacy Notice is provided to you by Freesat (UK) Limited. Our full contact details are below.

Freesat respects your right to privacy.  We are committed to being transparent about the personal information we collect, using that data in accordance with the law and respecting your rights.
 

When does this Privacy Notice apply?

This Privacy Notice applies to personal information that we may collect when you:

  • purchase a Freesat 4K TV box from Freesat (any model, including any Freesat Recordable 4K TV box) (“Freesat 4K TV Box”);
  • send for repair or return a Freesat 4K TV Box to Freesat;
  • register as a user of a Freesat 4K TV Box, as part of the installation journey; 
  • register for a Freesat account (sometimes referred to as a Freesat ID);
  • contact  Freesat  customer services for assistance;
  • use the Freesat mobile app (“Freesat App”);
  • sign up to receive news and other updates from Freesat; 
  • visit our website or engage with the marketing emails that we send you; or
  • engage with Freesat, or Freesat engages with you, for wider business purposes, including in the context of an existing or prospective supply, retail, distribution or other business relationship, or through industry forums or events (“Business Relationship”).
     

When this Privacy Notice does NOT apply:

  • If you are a user of any other Freesat-enabled device (such as one of the Freesat-enabled Humax or Manhattan boxes) (“Previous Generation Device”), in which case a different Privacy Policy applies to the collection and use of your personal data from the Previous Generation Device. Please refer to the Privacy Policy accessible via that device, or otherwise ask for a copy by contacting us using the details below.  (Please note that where you use a Previous Generation Device, but also have a relationship with Freesat through one of the channels described above under ‘When does this Privacy Notice apply’ - for example - you use the Freesat App or have a Freesat account - this Privacy Notice will apply to the collection and use of your personal data in connection with those channels.)
  • If you use a Freesat-enabled TV to access Freesat satellite TV services (i.e. without a freestanding Freesat set top box), you should contact the manufacturer of the TV for a copy of their Privacy Notice, as Freesat does not collect any personal information from your use of a Freesat-enabled TV.
  • If you use On Demand services, providers of On Demand services have their own Privacy Policies which will govern their collection and use of personal information. Freesat will know that you have accessed On Demand services and where you have used the backwards TV guide (where available), we will know which programme you selected to initially access their content. Freesat will not know about your further use of an On Demand service unless the provider of the On Demand service shares this information with us. For further information, see the Privacy Policies of the On Demand service providers. 

 

This Privacy Notice explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights.  

 

What does Freesat do?

Freesat is a UK-based, subscription-free television platform, offering free-to-air (FTA) channels together with the streaming services. Freesat is backed by the BBC and ITV, but also works with many other content providers.

In this Notice, we use the phrase ‘Freesat Guide’ to refer to the user interface application on the Freesat 4K TV Boxes through which you navigate to and access content for viewing. Freesat Guide includes the electronic programme guide, the On Demand screen and all other user interface screens through which you can access the content available through Freesat.
 

What personal information does Freesat collect?

Depending on how you access Freesat services and your relationship with us, we may collect the following information about you:

 

Information you may give us:

  • When you make a purchase from us, we may collect your name, address, postcode and email address, delivery and/ or purchase date, together with the details of the product purchased including model and serial number, payment method and any returns, repairs or queries.  
  • When you connect your box to the internet, either during original installation or at a later date, we may collect your email address and specific preferences detailed at the time.
  • When you connect your box to the internet, we will collect your postcode.
  • When you register for a Freesat account in order to use certain features of  the Freesat App or our website, we collect your name, postcode, email address and password, together with information about the set top box(es) paired with the Freesat App. If you choose to provide it, we may also collect your postcode where you use the Freesat App without logging in to your Freesat account.
  • If you call or email  Freesat  customer services, we may collect details of your box, including model and serial number, any queries or technical issues you raise (including with regards to warranty, repairs or returns), as well as your name, address, postcode and email address, box delivery and/ or purchase date, retailer from whom you purchased the box, bank account details and/or transaction information, such as the product price, payment method, and your payment details which are anonymised as per PCI DSS recommended standards.
  • If you sign-up to receive marketing communications from Freesat, for example via the website, through a promotion or when taking part in a competition, we will collect your name and email address, along with other information such as your current service provider(s) and your TV viewing preferences.
  • When you engage with us in the context of a Business Relationship, we may collect details such as your name, email address, telephone number, position and other details relating to your role, expertise and organisation.

 

Information we may collect from other sources:

  • When you purchase or otherwise acquire a Freesat 4K TV Box from a retailer (online or in-store) (including, for example, from Freesat via Amazon, or from a broadband provider), we may receive certain information about your purchase as your name, address, postcode and email address, delivery and/ or purchase date, together with the details of the product purchased including serial number, payment method and details of any returns, repairs or queries.
  • When we research potential business opportunities for the purpose of forming, or during the course of, a Business Relationship, we may collect information about you from your organisation, public records, third parties such as government or credit reporting agencies, or publicly available sources, such as social media platforms like LinkedIn.
  • When we attend industry forums and other events, we may collect information about you as a speaker or attendee, together with other information about your career and expertise.

 

Information we collect automatically when you use the Freesat App:

  • Where you pair your set top box with your Freesat account, information about which set top box is associated with you and your household.
  • Information about recordings that you schedule remotely using your Freesat account and the Freesat App, your management of existing recordings and any bookmarking of on-demand content.
  • Information about how you navigate around the Freesat App, which pages or functionality you visit, use or don’t use.
  • Your device (phone or tablet) model, operating system, device ID and IP address.
  • Certain technical information automatically generated by your device or the Freesat App, for example, error messages or diagnostic information.

 

Information we collect automatically, including technical information, where your box is connected to the internet:

  • Unique information about your device (such as device type or unique device identification numbers).
  • The IP address associated with your set top box, or any device you use when accessing your Freesat account.
  • Information about your internet connection, including your current internet provider.
  • Information about how you or your household access, view, record or otherwise interact with channels and programmes using the functionality on the remote control or using a voice-activated means to navigate.
  • Which on demand services you use; if you access such services via the backwards TV guide (where available) we will know what programme you selected to initially  access the on demand platform.  If you access on demand content via the on demand content provider’s icon on the On Demand screen, we will only know that you visited the third party On Demand content provider’s platform. As explained above, the On Demand services provider(s) will collect more information about how you use their services, but this is independent of Freesat and will be explained further in any notice relating to their platform.
  • Information about recordings you make or schedule using the recordings functionality on the box or via the Freesat App using your Freesat account.
  • Certain technical information automatically generated by your device, for example, error messages, diagnostic and navigational information.

 

Information we collect when we use cookies and when you engage with our website and marketing communications:

We use cookies and other means of tracking visitors and users (such as device ID), which enable us to collect data about what site you came from, what content you viewed on our website, which marketing communications you engaged with and how, and which ads you engaged with on our and third party sites, in order to understand your interests and show you relevant ads in the future. For more information, see our Cookies Policy on our website.

 

How do we use your information?

In general, we will use the personal information we collect from you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your personal information.  If we make any change to the way we use your personal information, we will ensure that we comply with the law when we do so. As a minimum, we will tell you about the change through an updated Privacy Notice and we will put appropriate safeguards in place to protect your information. 

 

We use your personal information for the following purposes:

  • To fulfil your order and provide customer care. We use your personal information to send you any goods you have ordered and to handle subsequent interactions with you concerning the order, including any warranty claims, provide customer care and after sales services.
     
  • To deliver the Freesat service.  We use information about your box or Freesat App software version, box ID and model/version, or where necessary your TV, to ensure that  your box or your Freesat App receives all necessary software, technical updates and refreshed Freesat Guide  content.  We use your postcode information to tune your set top box to receive the applicable regional channels (except that if box is not connected to the internet, we don’t collect the postcode in our systems). We also use your postcode (if you choose to provide it)  to display your regionalised channel listings within the Freesat App, or on the website, without the need for a Freesat account (we don’t collect the postcode in our systems in these circumstances). We use information about recordings you schedule using your Freesat account (whether via the Freesat App or through our website) to update the recording schedule on the associated box.
     
  • To deal with your enquiries and complaints and monitor issues that might affect other users too.  If you need assistance at any stage, we will try to help you. We will use any personal information you provide to respond to your query and help us understand how we can improve our product and services in the future.
     
  • To understand how people use our services and how we can improve them in the future.  In relation to each specific box, we capture information about how you use the Freesat service.  By knowing how you navigate around the Freesat service and how you interact with the content we offer, we can learn what is relevant and interesting, what viewers might like to see more of and what they have yet to discover. It will also help us innovate so we can offer you advanced functionality in the future.
     
  • To understand who our customers are and how we can attract more people to use Freesat.  We use information about you, your use of the Freesat service and Freesat account and your response to marketing communications to understand what makes a Freesat customer and to understand what might attract people to Freesat.

 

  • To personalise the communications we send you.
    1. As a consumer: Where we hold your email address, unless you have told us you do not wish to receive emails, we use information about the box(es) you have purchased/use, the content you like to watch, which emails from us have interested you previously, the content you view on our website, abandoned baskets in an online shop and/or other information we hold about you (including information we obtain from our direct relationship with you or from other sources), to send you more relevant recommendations in the future. These recommendations could relate to content available through the Freesat Guide or other products or services offered by Freesat, or where you have consented, to promotions, or other products and services offered by third parties with whom Freesat is collaborating.  You can opt out of receiving emails from us at any time, by clicking on the unsubscribe link at the bottom of every email.  You can also opt out of receiving communications by contacting us using the details below.  
    2. As a person connected to Freesat through a Business Relationship: Where we hold your contact details, we may use them to approach you regarding projects or initiatives we believe you might be interested in, including invitations to provide goods or services to Freesat.  You may inform us at any time if you no longer wish to receive such communications. In the event that such communications are sent using automated means, you will be able to unsubscribe using the link provided in the communication.

 

  • To personalise content, including advertisements, when you are within the Freesat Guide or the Freesat App. We may use information about the content you like to watch, your preferences and any marketing which has interested you in the past to promote related content to you in the future while you are within the Freesat Guide or the Freesat App. We may also use information about your preferences to show you targeted advertisements for Freesat or third party products or services within the Freesat Guide.
     
  • To personalise the content or advertisements we show you on our website and on third party websites. We may use information we hold about your previous visits to our website or online shop, your engagement with marketing emails you receive from us or advertising shown to you previously on search engines or social media, to tailor the ads you see on our website or on third party platforms.
     
  • To personalise our recommendations service to you within the Freesat Guide or Freesat App. We may use information about the content you like to watch via the box, and the genres and programmes that have caught your attention when viewing our emails and website to recommend similar content to you within the Freesat Guide or Freesat App.
     
  • To share box-specific viewing behaviours with the BBC and ITV, and other partners. Unless you opted out either when you first installed your Freesat 4K TV Box or where you connect your Freesat 4K TV Box to the internet at a subsequent date, we may share data about viewing patterns and habits relating to individual boxes and information generally showing how users of the box have interacted with channels and content accessed via the Freesat service.  We may also share the IP address and postcode where the box is installed as well as the box-specific unique ID.  This will enable the 3rd party partner to learn more about what content you find engaging and what you have yet to discover, they may also use the information to personalise advertising you see in their channel or in other channels through which they serve personalised advertising.  You should be aware that the 3rd party’s use of your data will be governed by the terms of their applicable privacy notice. 
     
  • To monitor the service and our performance levels and to protect Freesat’s business. We monitor performance and use of your box and Freesat App to detect technical problems and availability issues.  We also use information we receive about the use of the foregoing to protect Freesat’s and third party suppliers’, licensors’ and content providers’ software, hardware, intellectual property and other rights, as explained further in the terms and conditions of use.  
     
  • To develop, manage and maintain Business Relationships. We may use information we hold about you to contact you to discuss, pursue or otherwise interact with you regarding a Business Relationship.
     
  • To manage and secure access to our offices and facilities. We use your information when we welcome you to our offices and we also use your information to protect our systems, online platforms and other technology.
     
  • To support any other legitimate interests of Freesat or third parties. Where it is necessary to use your personal information to support an important and legitimate interest of Freesat, and where such interest is not overriden by your fundamental rights and freedoms or other interests, Freesat may use your personal data. It is difficult to anticipate when such circumstances will arise, however examples of Freesat’s legitimate interests would include protecting Freesat’s reputation, or bringing or defending legal claims.

 

Who does Freesat share my personal information with?

We may share your personal information with third parties:

·to enable  third party services providers engaged by us  to support our business  by processing your information on our behalf. These  third party  services providers  would be acting on our  instructions and may enable us to provide more  specialised  and/or cost effective services. Examples of the type of  third party  service providers we are referring to include  card payment, logistics  and email communication service providers;

·when we share data about viewing patterns and habits relating to individual boxes (and the postcode and IP address relating to where they are connected to the internet) with the BBC, ITV and our other partners; and

·in the unlikely event that we are required to share your information with any competent law enforcement body, regulatory, 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. 

 

Legal basis for processing personal information 

There are a number of different ways that we are lawfully able to process your data. We explain these below.  However, if you have ever opted out of specific processing of your data by Freesat or have objected to our use of your personal information, we will respect this where the law requires or permits this; in such circumstances, the explanation below will not apply to you.

Where processing your data is necessary for the purposes of a contract we have with you:

  • Where you have purchased a product from us, we will use your personal information to send you the goods and handle subsequent interactions with you concerning the order, including any claims under the manufacturer’s warranty.  
  • When you register as a user of a Freesat 4K TV Box, you will enter into a contract with us agreeing to abide by the terms of use and we will use your personal information to enforce or otherwise monitor your compliance with the terms of use.

 

Where processing your data is within Freesat’s or our partners’ legitimate interests and where you would reasonably expect us or them to use your data in that way:

  • To deliver the Freesat service to your box; 
  • To deal with your enquiries and complaints and monitor issues that might affect other users too;
  • To understand how people use our services and how we can improve them in the future;  
  • To understand who our customers are and how we can attract more people to use Freesat;
  • Where we hold your contact details as a result of your previous engagement with us, to send you personalised communications; 
  • To share box IDs, the box location based on postcode and IP address and specific box viewing behaviours with the BBC and ITV, and other partners;
  • To monitor the service and our performance levels and to protect Freesat’s business; and
  • To develop, maintain or manage Business Relationships.

 

Where, as a consumer, we have your consent to process personal information:

  • If you are not registered with Freesat as a customer but receive email communications from us, we will have received your consent to send you these emails. If you no longer wish to receive the emails, please change your preferences by clicking on the unsubscribe link at the bottom of one of our emails.

 

In some cases, we may also have a legal obligation to process your personal information.

 

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.  

Your personal information may be transferred to and processed in countries outside the UK. 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.

Data retention

We will delete your personal data when it is no longer reasonably required for the purposes described above, or, where applicable, if you withdraw your consent, unless we are legally required or otherwise permitted to continue to hold such data.  We may retain your personal data for an additional period if deletion would require us to overwrite our automated disaster recovery backup systems, or to the extent we deem it necessary to assert or defend legal claims.  In such circumstances, 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:

  • to object to our processing of your personal information where specific legal bases are relied upon by Freesat;
  • to withdraw your consent, where our processing of your personal information relies upon your consent;
  • to access the data we hold about you, in a commonly used, easily downloadable format;
  • to ask us to modify, update or rectify the information we hold about you where it is inaccurate, or to delete the information if it is no longer required; and
  • to ask us to limit our processing of information for specific purposes or entirely.

 

If you wish to exercise any of these rights, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below.

You have the right to complain about our collection and use of your personal information.  For more information, please contact the Information Commissioner’s Office via their website at https://ico.org.uk/.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

 

Updates to this Privacy Notice

We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy 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 Privacy Notice changes if and where this is required by applicable data protection laws.

 

How to contact us                     

If you have any questions or concerns about Freesat or our use of your personal information, please contact us using the following details: 

Call us on 0345 313 0051

Email us at customerteam@freesat.co.uk

Visit our website www.freesat.co.uk/help/ 

Write to us at Customer Team, Freesat (UK) Limited, 23-24 Newman Street, London W1T 1PJ.

 

The data controller of your personal information is Freesat (UK) Limited, which is registered with the Information Commissioner’s Office with registration number Z1223141.

September 2020