Privacy Policy

HDTV PRIVACY AND COOKIES NOTICE

INTRODUCTION AND SCOPE

This privacy and cookies notice applies to the processing of personal data, including information we collect and store via cookies, as explained below by:

HDTV Private Limited, if you access our products and services or our online digital platforms (including where HDTV Private Limited trades under the name “NOW”), and

references in this notice to “HDTV”, “we” “us” or “our” should be interpreted accordingly. The processing explained in this notice may be carried out by HDTV or other data controllers in the HDTV Private Limited.

References to Comcast refer to the parent company of HDTV, Comcast Corporation, 500 Gravers Road Suite 3000 Plymouth Meeting, PA 19462 United States.

If you access the products and services of other HDTV companies and businesses, you should refer to their privacy notices.

TYPES OF INFORMATION WE PROCESS AND WHERE IT COMES FROM

Information you've provided to us, including through our websites, applications or products, or when you access our services through applications on websites operated by other organizations.

Information about our content, products and services you've ordered or enquired about, including as collected on call recordings or via live chat, as further described below.

Information which we acquire from other organizations, such as address verification services, data brokers who supply us with contact information and modeled household profile information such as affluence and household composition, property and lifestyle companies and credit reference agencies including personal data that is publicly available.

Information, uploads, user generated content, and comments you make about, or generate, in accessing the shows, channels, programmes, advertisements, products and services you use, for example, how you or your household access, view, share, contribute to, communicate with, record or fast forward, download or interact with them.

Information about you and your household’s use of HDTV, and/or third-party content products and services (such as third party apps) including the content you watch, how long you watch it and where you have paused a piece of content (we call this viewing activity) as well as content you add to your Playlist.

Information from the devices you use to receive HDTV content, products and services, about your household's use of HDTV, and/or third party content, products and services (we call this data, product analytics). This includes information about your:

device, machine or browser
How you use our products and services (e.g. time spent watching content or within apps, how you navigate the user interface); and
other devices you use or have connected to your HDTV devices.
Voice data captured when you use the voice command feature on your remote control or, if you’re a HDTV Glass customer, when you say ‘Hello HDTV’ (which can be turned off using the switch on your device, via voice command or in the Voice Mics setting in the privacy section of the settings menu). All voice data captured is processed by Comcast to provide this functionality, Comcast retain this data for seven days. HDTV selects, stores and analyses certain pieces of the voice data strictly to help understand errors and improve the voice functionality and not for any other purpose.
IP addresses, MAC addresses, unique identification numbers, online identifiers (including device IDs and advertising IDs), browser information, location data port information, logical network address, and other similar identifying information required for your devices to communicate with websites and applications on the internet.
Technical information from the devices you use to receive HDTV content, products and services, for example, the collection of diagnostic and traffic or location information. Note that devices and applications have their own privacy settings and notices under which they collect your information, so please check and manage your device and application settings.
Information relating to your customer service interactions with us. This includes your image from CCTV footage recorded when you visit a HDTV Retail Store or other HDTV locations.
NI number (or equivalent), if you provide it to us to enable us to determine eligibility for certain products, services & offers.

HOW WE USE YOUR INFORMATION

The main purpose for which we process your personal data is so that we can provide you with content, products and services, in accordance with the contract you have with us. This includes determining eligibility for certain products, services and offers, as well as providing you with account management functionality (such as to update your contact information), processing and collecting payments, customer support (including diagnostics and trouble-shooting), call screening and blocking, and tailored and personalized experience whilst using our products and services such as recommendations for the content you subscribe to (including by sending you newsletters about your service, content and relevant products.)

We also process your data to deliver services to you under our contract in the following ways:

To enter into loan agreements with you, we obtain personal data about you from credit reference agencies. We then take automated decisions using that personal data about whether or not to enter into the loan agreement with you. This decision is influenced by your credit history and, depending on the outcome of this automated decision-making process, we may not enter into the loan agreement with you. If you would like us to review decisions taken about you as part of this process, please contact us as set out below.
To manage our products and services and traffic across our network. For example, HDTV uses your information to facilitate the operation of its network by choosing the most efficient route to transmit your requests for a communications service through the various parts of its network of equipment and systems. This information is held securely within restricted areas, accessible only by authorized personnel and in accordance with our data retention, deletion and acceptable use policies;
To send newsletters to you about your service, content and relevant products.
To determine your eligibility and then enable your ability to access special rewards, perks and experiences within our HDTV Programmes. Should you choose to enter into the terms and conditions for our HDTV Programmes we will send you direct marketing in accordance with the terms of that contract and;
To check that you are using our products and services in accordance with the terms of the contract you have with us.

If you’re a HDTV customer, where you give us consent, we will process your data in a number of ways, including:

In order to send or target you with direct marketing. This may include communications by post, telephone, SMS, email or other electronic means (such as push notifications and in-product notifications), using the contact details you have provided, about us and our content products and services, events and special offers, including, for a reasonable time after you have ceased to be a customer of ours (see further details below). We may also send you ‘abandoned basket’ marketing if you provided us your contact details (and given us consent to use them for marketing) during our online sales journey but didn’t complete your purchase. We will tailor the marketing based on what you added to your basket.
In order to process your data for online and digital advertising (see below at “How we share your information for online and digital advertising”) and;
In order to process special category data you’ve provided to us. This may include using data you have provided to us or to our business partners concerning your health to provide assistance and support on your account; and using biometric data in some scenarios as part of consumer credit agreement authorizations.

We may also use your information to comply with our legal and regulatory obligations. This includes:

By complying with police and other security investigations.
In some circumstances, we may process your personal data in reliance upon our legitimate interests, including to:
Improve our content, products, services and customer experiences by using product analytics and voice data and working with our suppliers to improve the products and services we offer, and develop new content, products and services;
Monitor, record, store and use customer service communications we have with you. This helps us to improve the quality of our customer service, to confirm any instructions you give us, to create a customer profile to have better conversations and/or for training, development and to meet our legal and regulatory responsibilities.
Evaluate and fix problems with our products and services using technical information collected from your device and to help us to develop future products and services.
Provide tailored and personalized recommendations based on your viewing activity which would require an additional purchase or transaction by you.
Confirm the personal data we hold about you (for example, your address);
Determine the country you are located in so we can provide you with the correct information (for example, product and pricing information on our websites).
Determine what offers for our products and services you are eligible for and how those offers will be made available to you. To do this, we create a profile about your time as a HDTV customer (for example, what products and services you have purchased, how you have used them, your offer and payment history, and your interactions with our customer service agents) and supplement this with information provided to us by other organizations as described in this notice. We use these profiles to target our offers at particular groups of customers and personalize the messages.
In some cases, we rely on legitimate interest to send or target you with direct marketing – for example, if you’re a prospective customer. This may include communications by post, email or other electronic means (such as push notifications and in-product notifications), using the contact details you have provided, to inform you about us and our content, products and services, events and special offers, including, for a reasonable time after you have ceased to be a customer of ours (see further details below). This may also involve processing your data for online and digital advertising (see below at ''How we share your information for online and digital advertising'').
For market research.
Protect or enforce our rights or the rights of any third party and prevent and detect fraud, including by analyzing activity on our network to help block unauthorized or illegitimate content, publication of, or access to it.
Help prevent and detect crime and for the purposes of public and road safety.
We will also process your data where we need to in order to safeguard your vital interests or those of another person, for example to support crime prevention and protect the safety of members of the public and HDTV employees.

HOW WE SHARE YOUR INFORMATION

We work with a number of suppliers and partners to process your personal data for the purposes described above. Where these suppliers and partners act on our behalf they must only process your personal data in accordance with our instructions. The categories of suppliers and partners that we use include:

Engineer services firms
Couriers (who may also process your contact data as a data controller when arranging or communicating with you about your delivery);
Payment service providers
IT and information technology and services companies
Customer service centers
Debt Collection agencies

Other HDTV Group companies (Information can be found here); and other companies in the Comcast group. This includes:

Comcast, with whom we share data in relation to the development, operation, infrastructure and performance of our products and services
Warranty companies (see further below);
Data brokers. This includes Experian who we use to match HDTV’s own data with data provided by brands in order to identify households to target for specific advertising campaigns.
For example, this data matching process could be performed on behalf of a supermarket that wants to target its television advertising to its existing customers who live near one of its stores.
The brand will receive back a report showing how successful the advertising campaign was (e.g. how many times their adverts were viewed), but will not receive information or data about specific households.
Marketing companies that deliver our communications.

One of HDTV’s data processors may contact you to ensure you are satisfied with your service experience and to let you know about the warranties that apply to your HDTV equipment and the options for extended cover.

In the event the structure of our business changes so that another company in the HDTV provides our products and services to you, we will pass your personal information to that company. This includes, for example, a merger between us and another company, where another company acquires us or some or all of our assets, where we acquire another company or where our holding company restructures our corporate group.

We share your personal data with credit reference, and fraud prevention agencies for use in automated credit decisions, for the detection and protection against crimes such as fraud and money laundering, and for debt recovery purposes, as further explained below. Where we carry out a credit check with a credit reference agency, the information that we give them (including details of your credit application and financial details) and the details of the search itself will be recorded by that credit reference agency. We also exchange information with credit reference agencies on payment performance under your credit agreement on an ongoing basis and this information could be used by us and third parties to make future credit assessment decisions. As part of your credit check, the credit reference agency may also review information in relation to individuals who are financially linked to the primary applicant. If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services or financing you have requested, or we may stop providing existing services to you. A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you.

We may share your personal data with debt collection agencies where there is an outstanding debt owed on the account. We do this so that they can use the information, alongside other information that they hold, to attempt to contact you on our behalf so that we can recover the debt. In some cases, where we have been unable to recover the amount owed, we may sell the debt to a third-party debt management company. You will be informed when this takes place and following the sale of the debt, any questions you have about communications you receive should be directed to the company in question.

We share certain personal data with third-party app and content providers (such as Netflix and Disney+) when you choose to pay and/or access those third-party services via HDTV. We do this solely to enable and/or verify your ability to access the relevant third-party service via HDTV and with certain third party providers this personal data is held on a joint controller basis (meaning we use and share the data for the joint purpose of ensuring your access to the service). Third-party app and content providers may also share personal data with us about your use of their apps and services. This is provided to us so we can provide functionality to you within HDTV’s services such as resume options for programmes you have started watching elsewhere and personalized recommendations. You should refer to the third-party’s own privacy notice for more details about what information they share and how to manage your preferences.

Occasionally, we share limited data about you (such as your name, address, email address and device information) with third party service providers that are necessary for you to enjoy our services, such as broadband providers. This allows us to identify and resolve technical issues impacting the delivery of our services to you so you can continue to receive uninterrupted HDTV services. Data shared in this way, is deleted by the third party once the purpose has been fulfilled.

We share personal data with the courts, enforcement agencies (e.g. the police) and with regulatory authorities where this is required, in order for us to comply with our legal and regulatory obligations. We may also share your NI number with government departments to determine eligibility for certain products, services & offers.

Where HDTV receives a request for the ownership of a vulnerable customer’s account to be transferred to a nominated individual, personal data of the existing account holder may be shared with the new account holder. The ownership of the account would only be transferred once HDTV has received signed acceptance and authorization of the transfer from both parties.

HOW WE USE YOUR INFORMATION FOR ONLINE AND DIGITAL ADVERTISING

We work with trusted partners to process your personal data for online and digital advertising purposes. This is to enable:

Third-party advertising on websites and apps; and
HDTV’s own advertising on websites, apps and social media platforms.
The purposes described in this section we use information collected through cookies or similar technologies on our websites, apps and devices (such as device IDs, mobile advertising IDs, and IP addresses). We may also use your phone number and email address, though this will only be in a hashed format (which means that it has been converted into a string of numbers or letters to make it more secure), and our partner will only see that data if it is already used for an account on their site. We will never share your name and physical address with our partners, though you may choose to provide it to them directly when you interact with an advert (see below for more information).
Where we process your personal data for online and digital advertising purposes on our and third party websites, apps, and devices (including through cookies and similar technologies, which you will separately be asked to accept), the data may be combined with other information we hold about you, including information you have provided to us, information about websites you have visited, viewing activity, product holding and information about your use of our products and services, account number and history and HDTV iD preferences so we can tailor the adverts you see, show you more relevant content or offers and define groups of audiences to whom we and our partners deliver digital adverts. We also use aggregated data to better understand advertising performance. We perform due diligence before a company becomes a partner to ensure they will handle your data in a secure and responsible manner.
We work with our partners to make sure personal data is processed only if appropriate measures and controls are in place to protect your personal data in accordance with applicable data protection laws and regulations and regulatory guidance. Any data transfers will only take place on the basis of an approved data transfer mechanism as described in the section ‘How we share your information’ above.
to request us to restrict the processing of the personal data we hold about you.
to object to us processing personal data relating to you.
where you have given us consent to process your personal data, you have the right to withdraw that consent at any time.
you have the right to obtain certain personal data from us in a format that can be transferred electronically to a third party (also called “data portability”).
Please note that some of these rights are not absolute. In some cases, for example, we may refuse a request to exercise particular rights if complying with it meant that we are no longer able to meet our contractual obligation to provide you with particular products and services, or if we had a legal obligation or right not to comply with the request. However, we will keep you informed as to the actions that we can take, when you make your request.

MANAGING YOUR PREFERENCES

The "unsubscribe" link or replying STOP in any electronic marketing information from us

By calling HDTV Mobile
Emailing: info@hdtvasia.com
When you make a request not to receive marketing, it can take us up to one month to process that request.
If you receive direct marketing from other HDTV group companies or in relation to other HDTV services (such as Now TV, HDTV Connect, HDTV WiFi) you can choose not to by contacting them directly.
Use of product analytics and viewing activity
You can always choose to opt out of us processing product analytics and viewing activity data by calling HDTV using the number above and asking to opt out of profiling.
By opting out of this, you will no longer receive certain features on your HDTV products (such as tailored and personalized recommendations or resume options for programmes you have started watching) and we won’t be able to use your data to make improvements to our products and services.

Please refer to our Cookies notice for information on how to adjust cookie settings for your devices.

COOKIES NOTICE

Cookies are created when you visit a website or use an app. They are small files that are stored on your device and used to customize your experience.

When you access hdtvasia.com, the HDTV News and HDTV Sports sites and apps, or other HDTV websites and apps for the first time, you will be asked to set your cookie preferences for the site.

To help you make your choices this notice explains how we use cookies and similar technologies to collect information when you access our services and how we use that information. We also explain when and how you can manage your cookie preferences.

We use cookies to make your use of our sites and apps quicker, easier and more relevant to you. If you don’t turn these cookies on it may affect your browsing experience. To avoid impacting your browsing experience cookies need to be enabled in your browser settings.

WHAT DO WE USE COOKIES FOR?

ESSENTIAL COOKIES

These cookies are needed to provide the content, product or service you have asked for. We use essential cookies for the following purposes:

Keeping you logged in during your visit
Enabling you to stream content properly
Making sure that what you’ve added to your basket is still there when you get to the checkout and to personalise our ‘abandoned basket’ marketing (where we are permitted to send you marketing) described in our Privacy Notice above.
Make sure our website is working properly
Remembering if you've been to the site or app before
Making content recommendations based on other content you have watched
Enabling features of our service.

PERFORMANCE COOKIES

We use cookies to help improve our products. For example:

To keep track of what pages, content and links are popular and which ones don't get used.
To see how users navigate through our sites and apps, when error messages appear and what caused them.
To see how effective our adverts are.
The information collected using these cookies is grouped with the information from everyone else so we can see overall patterns rather than individual activity. When given the option, we recommend you turn on cookies used for these purposes.

ADVERTISING & MARKETING COOKIES

In addition, cookies are used for advertising and marketing purposes. These cookies are used to identify your interests by understanding how you interact with our sites and apps and your web browsing activity. We do this so that we and our trusted partners can:

Tailor the advertising you see on our and third party sites and apps to your interests (this is known as online behavioural advertising) whilst limiting the number of times you see the same advert.
Link to social networks who may use the information to target advertising to you on their platforms.
Tailor the advertising you see on our and third party sites and apps for our own HDTV products.
Measure the effectiveness of adverts and content you’re shown, including where and how often they’re shown and any action you took in relation to them.
If you don’t turn these cookies on when given the option you will still see the same amount of advertising and marketing, but it is less likely to be of interest to you.

AFFILIATE COOKIES

We use 'affiliate' cookies. Some of our web-based information will contain promotional links to other companies’ sites. If you follow one of these links and then register with or buy something from that other site, a cookie is used to tell the other site that you came from one of our sites. That other site may then pay us a small amount for the successful referral. For more information, see the Internet Advertising Bureau's guide about how affiliate marketing works. Note that when you visit those other companies’ sites, they will have their own privacy notices which set out what personal data they collect and how they will use it.

HOW LONG DO OUR COOKIES STAY ON YOUR DEVICE?

When you set your cookie preferences on one of our sites or apps, we will remember those preferences. We will ask you again to confirm your preferences after 180 days, unless we add new cookies or use non-essential cookies for different purposes in the meantime, in which case we will ask you to confirm your preferences again when we make those changes. Please note that if you change your preferences to reject cookies which you had previously accepted, HDTV will stop collecting data from these cookies but some of them may remain on your device until you clear them. To find out how to do this, please see “Other ways to manage your cookie preferences” below.

MANAGING YOUR COOKIE PREFERENCES

We don’t give you the option to turn off essential cookies when you manage your cookie preferences because these cookies are necessary to make our sites and apps function properly. For the other categories of cookies referred to above, you can control how they are used on that HDTV site. After you have made your initial choice, you can change your preferences via the ‘Privacy options’ link in the footer of the site or the settings within the app.

OTHER WAYS TO MANAGE YOUR COOKIE PREFERENCES

Most modern browsers allow you to see what cookies you have on your device and to clear them all or individually. To find out how to do this, go to aboutcookies.org, which contains comprehensive information on how to do this on a variety of browsers.

Please remember that any settings you change will not just affect the cookies we use. The changes will apply to all websites you visit unless you choose to block cookies only from specific sites.

Deleting cookies means that settings you have made on a site will be lost. If you’ve set your preferences to opt out of cookies, this setting will be lost too if that information is stored in a cookie. Blocking all cookies means functionality on our sites and apps may be lost. Therefore, we don’t recommend turning all cookies off when using our sites and apps.

How long we keep your information

In this section, we explain the categories of personal data that we may keep, the periods applied and our reasons for keeping them.

These categories of data include customer contact information, the addresses where we have provided services, account, activation and viewing card numbers, pay per view records, account correspondence with notes and complaints, payment card and financial history. We keep this information for business, legal and regulatory purposes. Some of the legal reasons why we keep this data are: tax purposes, to enable us to defend potential legal claims under the statutory periods set out in the Limitation Act 1980 or the Statute of Limitations, 1957. We will also need to keep some information to demonstrate compliance with the Data Protection Act 2018, for example, where we need to evidence compliance with suppression requests. This information is also helpful if we receive customer enquiries or complaints, and to verify your identity when you contact HDTV.

These records are retained securely for up to 7 years after your account is cancelled. After this time they will either be securely deleted or anonymized.

Some categories of data are deleted sooner where the data is no longer needed for the purposes for which it was collected (such as where we have recorded calls, these are retained for 12 months). Please read the 'Keeping your data up to date and your rights' section above to understand how to get in touch to discuss a right to erasure request.

COMPLAINTS

If you wish to make a complaint about how we use your information, please Contact Us here and we will do our best to help. You may find our Customer Complaints Code of Practice helpful. If you are still unhappy, you can contact the Information Commissioner's Office via their website.

CONTACTING HDTV

If you have any queries or comments about this privacy and cookies notice, please contact us info@hdtvasia.com.

CHANGES TO THIS NOTICE

We will occasionally update our privacy and cookies notice. We will post a notice of any material changes on our website prior to implementing the changes, and, where appropriate, notify you using any of the contact details we hold for you for this purpose. This may include phone, SMS, e-mail, post or interactive social media. We encourage you to periodically review our notice to be informed of how we use your information.

This privacy and cookies notice was last updated April 2022.

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