SkyShowtime Privacy Statement

Last updated: 28 February 2024

SkyShowtime Limited (referred to as “we”, “our” or “us”) is the data controller for all personal data collected through the SkyShowtime website, platform and related applications (collectively “SkyShowtime”), that allow users to access on demand digital content and associated services.

We understand that your privacy is important to you, so it is important to us too! We take your privacy seriously when we handle your personal data, which includes information that personally identifies you, such as your name, contact details, payment details, marketing preferences or data that can be linked to such information to identify you directly or indirectly.

This Privacy Statement describes our practices in relation to personal data we process about you, and the rights and choices you have about our use of your personal data.

Users under 18

Individuals under the age of 18 may not have a SkyShowtime account but may use SkyShowtime with the consent and supervision of their parent or guardian. Registered parents or guardians can also create a separate age-restricted profile(s) for under 18’s from within SkyShowtime’s account settings.

QUICK GUIDE TO
1. HOW WE COLLECT AND USE YOUR PERSONAL DATA
2. WHEN WE SHARE YOUR PERSONAL DATA
3. AUTOMATED DECISION MAKING
4. TRANSFERRING YOUR DATA OUTSIDE YOUR HOME COUNTRY
5. HOW LONG WE KEEP YOUR PERSONAL DATA
6. SENSITIVE PERSONAL DATA
7. YOUR PRIVACY RIGHTS
8. UPDATES TO THIS PRIVACY STATEMENT

1. HOW WE COLLECT AND USE YOUR PERSONAL DATA

We receive personal data about you in several ways: (i) directly from you; (ii) through automated collection through your use of SkyShowtime; and (iii) from third parties.

We use this information for a variety of reasons (which you may have heard referred to as a “lawful basis”), including:

  • providing a requested service, or performing a contractual obligation, to you (such as delivery of the SkyShowtime service);
  • to comply with a legal obligation that applies to us (for example, ensuring the correct content library is available to you);
  • where you have given us your consent (for example, to send you marketing); and
  • where the use is necessary for our legitimate interests (or that of a third party) – a legitimate interest is a compelling reason for using your personal data, which is always assessed to ensure it is balanced against your rights and interests. (An example of this is where we use your personal data to authenticate your rights and access to SkyShowtime through a third party partner platform).

If you decide not to provide your personal data when requested by us, or if you object to our use of your personal data where we have made it clear that it is mandatory, we may not be able to provide you with the services you have requested or otherwise fulfil the purpose(s) for which we have requested your personal data.

1.1 Personal data collected from you, to:

  • Register and manage your account (to perform our contract with you): to register your account and provide you with features for your account on SkyShowtime, such as arranging access to your account, maintaining your account and providing related customer service to you, and to send you administrative information, including information about SkyShowtime and changes to our terms and policies, you provide us with your personal data when you sign up for SkyShowtime and manage your account and profiles. Generally, this is your name, address, email address, payment information (such as your credit or debit card, PayPal, Apple Pay or Google Pay information), your account preferences, and information about the various user profiles you create.
  • Provide you with customer services support (necessary for our legitimate interests & perform our contract with you): to help you resolve an order query, support request or general enquiry, when you contact the customer services team, you may be required to provide personal data to validate your identity (as the account holder) and in relation to your specific query. Generally, this will include your name, email address, last 4 digits of payment card, postcode, billing date, details of your question or request, but may also include any additional information required to provide you with the required support, or other information you voluntarily provide to us.
  • Send you direct marketing (with your consent): where you have consented to (or signed up to) receive marketing communications via email, or push notifications from us, our affiliates, and/or our partners, we will pair your name, email address and sometimes device information with your marketing preferences. You can opt-out at any time from receiving marketing emails using the unsubscribe link in any marketing message from us or disabling the appropriate button in your account settings. If you opt-out of receiving marketing messages, we will continue to send administrative and service messages to you as necessary. You can opt out of marketing via push notifications by disabling push notifications on your device.

1.2 Personal data we collect automatically:

In this section, where we have referred to “browser and device data”, this broadly means your Media Access Control (MAC) address, device type (Windows or Macintosh), screen resolution, operating system version, internet browser type, and version of SkyShowtime you are using. When we mention “app data”, we mean app usage data, such as the time and date the app on your device(s) accesses our servers and what information and files have been downloaded to the app (whether downloaded to a device or smart TV). References to “IP address” refer to the number that is automatically assigned by your Internet Service Provider to your device and is automatically identified and recorded in our server log files when you access SkyShowtime, along with the time of your visit and your activity on SkyShowtime.

  • Providing you with access to SkyShowtime ((i) performance of contract and (ii) necessary for our legitimate interests): to (i) perform our contractual obligations around delivering the SkyShowtime service to you; and (ii) to help us to calculate the level of usage on SkyShowtime, diagnose technical problems, monitor and report on the performance of the content on SkyShowtime (by analysing the viewing behaviour of users), we collect some personal data when you visit, or interact with, SkyShowtime. Generally, we will collect information such as browser and device data; app data; and IP address.
  • Providing you with personalised SkyShowtime content recommendations in adult profiles (performance of contract): Adult profiles include the option to restrict content in the profile settings e.g. Family (up to and including 12 rated content), Teens (up to and including 16 rated content) and Adult (all content is available, including 18 rated content). All adult profile options will show personalised content and recommendations. It is possible that you may be recommended any content available on the adult profile, but access is restricted based on your settings. In order to provide you with personalised content/viewing recommendations as an integral part of our service, we will collect some viewing information and device information (for example, when you “like” content). Generally, this will be app data, recently viewed titles (and when they were viewed); browser and device information; and IP address. There are no personalisation features for child profiles.
  • Sending you targeted advertising on social media and related platforms ((i) with your consent (based on browser settings) and (ii) for our (and our platform partners/third party partners) legitimate interests): To (i) send you customised ads about SkyShowtime on social media and (ii) measure the effectiveness of our advertising campaigns using audience-targeted technology, we collect (and share with social media– refer to section 2 below for more information on social media partners), your name, email address and information about how you use SkyShowtime. For example, our social media and other platform partners may associate your (hashed) email address and other information about your use of SkyShowtime with your social media data so that we can send targeted advertising. Although we may send targeted advertisements to you, we cannot see whether you are included in the tailored audience list and do not have access to information held on social media or any other platform. You can opt out of this tailored advertising at any time through your SkyShowtime account settings. Please see our Cookie Policy here for information on what Cookies (and other similar technologies) are and how we use them.
  • If you have a subscription that includes advertising, to provide you with appropriate and relevant ad’s ((i) performance of contract; (ii) compliance with laws; (iii) & (iv) necessary for our & our advertising partners legitimate interests): to (i) provide you with relevant and appropriate advertising e.g. ads that are region or country specific (such as offering items available in your region or in the language relevant to your region), content-based (where advertisers have paid for advertising to be placed in certain shows, or genres (e.g. comedy), (ii) meet consumer and advertising legal requirements (e.g. restricted products advertising) (iii) ensure ads are delivered effectively and display properly, and (iv) conduct analytics on our users’ interactions with advertising on SkyShowtime. Generally we collect information such as browser and device data; app data (which for these purposes also includes your engagement level with ads); usage data and IP address. There is no advertising on content within a Child profile.
  • Assessing marketing email deliverability (necessary for our legitimate interests): to enable us to understand the performance of the marketing emails we send you (where you have consented or signed up to receive these), and to tailor future marketing emails we send you based on your interactions with our previous emails, we collect come personal data via automated means. Generally, this is information such as whether you opened the email and what you clicked on the email.

1.3 Personal data we collect from third parties:

  • Registering and managing your account through a third party partner ((i) performance of contractual obligations; (ii) necessary for our legitimate interests): where you have signed up to or access SkyShowtime through a third party partner, you will provide the third party partner with your personal data, through their service. The third party partner will share these details with us so that we can (i) verify you and provide you with access to SkyShowtime and our services in accordance with the contract you have with us. We will also use this information to (ii) diagnose technical problems and monitor performance of our services, in line with our internal business processes. Generally, this information will include account authentication information (username or email address and password for example) and related credentials, search queries, login events, browser and device data, and your IP address.

1.4 General Uses of Your Personal Data:

  • Internal analytics of aggregated and anonymised data (necessary for our legitimate interests): we may use any information you provide to us, or collected by us about you, in an aggregated and/or anonymised form. In this form, the data will no longer directly identify you. For example, by using personal data collected through your use of SkyShowtime to calculate the percentage of our users who like a particular show or movie. We use the aggregated and/or anonymized data generated for various purposes, including to develop new products and services, to improve or adapt our current products and services, to determine the effectiveness of our promotional campaigns so that we can tailor our campaigns more closely to the needs and interests of our users, and to conduct and expand our business e.g. to understand which parts of SkyShowtime are of most interest to our users so that we can effectively target resources and development efforts.
  • Compliance with our Terms of Use When we collect your personal data (necessary for our legitimate interests): to ensure that the services and content are only used in the ways expressly permitted in our Terms of Use (as updated from time to time), our Terms of Use compliance procedures may apply to any of the above personal data we hold about you.
  • Content portability (compliance with a legal obligation): to determine which content library is appropriate to show you, we collect personal data that helps us to verify your country of residence. This information may include your IP address, billing address, and payment information.
  • Audits (internal and external) and compliance (compliance with a legal obligation): to verify that our internal processes comply with legal, regulatory or contractual requirements, our audit and compliance process may apply to any personal data we hold about you.
  • Fraud and security (necessary (i) for our legitimate interests or (ii) compliance with a legal obligation, depending on the situation): to carry out fraud and security checks, for example to detect and prevent cyberattacks or attempts to commit identity theft, and to protect our content rights, including the protection of our interests and rights in relation to the content we make available on SkyShowtime, our fraud and security review process may apply to any personal data we hold about you.
  • To run our business (necessary for our legitimate interests): to operate efficiently within our business model and structure, in a way that effectively serves our users, including by using a range of centralised and localised business functions, our administrative procedures apply all personal data that we hold about you.
  • Legal claims (necessary for (i) compliance with a legal obligation or (ii) for our legitimate interests, depending on the situation): to effectively defend or make claims to protect our legal rights and interests and to respond to regulatory or law enforcement investigations, our legal claims process may apply to any personal data we hold about you.

2. WHEN WE SHARE YOUR PERSONAL DATA

We share your personal data as described below, for the purposes described in this Privacy Statement.

  • Third party partners: If you sign up for or access SkyShowtime through a third party or with another product or service (such as an app store or where SkyShowtime is included in a bundle or package by another TV platform or service provider), we share your personal data with these third party providers in connection with your use of SkyShowtime, such as user identification and IP address.
  • Contractors, subcontractors and service providers: We share your personal data with third parties who perform services on our behalf (and in some cases our affiliates), to facilitate the services they provide to us. These may include consultants from other Comcast Group and Paramount companies, professional consulting service providers (lawyers and accountants), service providers involved in hosting, marketing technology, data analytics, payment processing, order processing, infrastructure provisioning, IT services, customer service, email delivery, auditing and other similar services.
  • Marketing partners: With your consent, we share your personal information with third parties (including Comcast Group and Paramount companies) to enable them to send you marketing communications, in accordance with your marketing preferences.
  • Social media partners: (including Meta - Facebook) for the purpose of placing public advertisements on social media. Depending on your privacy settings and actions on such networks, we may share contact information, identification and demographic information, user-generated content, device information and identifiers, connection and usage data, and social media information. Please note that Meta Ireland is a joint controller for the joint processing (as set out here). Further information (including on the basis on which Meta Ireland relies and how you can exercise your rights as a data subject) can be found here in the Meta Ireland Data Policy.
  • As needed to protect us or others (including you): We share your personal data if we are required to do so, to comply with (and/or when we reasonably believe that we are required to comply with) a legal or regulatory obligation, such as pursuant to court orders, regulatory or law enforcement actions; or to enforce an agreement we have with you; or to protect the rights, property, safety or security of SkyShowtime, our affiliates, you, other third parties, SkyShowtime users or the general public.
  • Business transfers: We have a legitimate interest in disclosing or transferring your personal data to a third party in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or part of our business, services, assets, shares (including in connection with bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.
  • To comply with our terms and conditions: including to protect our interests and rights to the content we make available on SkyShowtime, or other contracts we have with you and to enable us to pursue available remedies or limit the damages we may incur as a result of any action, such as on the basis of court orders and the use of debt collection agencies.

3. AUTOMATED DECISION-MAKING

We do not use automated decision-making for any legal or other significant aspects of your account with us.

4. TRANSFERRING YOUR DATA OUTSIDE YOUR HOME COUNTRY

Please note that due to the international scope of SkyShowtime's business, your personal data may be stored and processed in any country where we have facilities or where we engage service providers. By using SkyShowtime, you understand that your personal data may be transferred to countries outside your country of residence, including to locations, such as the United States, which may have data protection rules different from those of your country.

To protect your personal data, SkyShowtime only transfers your personal data within the European Union and to countries that the European Commission has deemed as having adequate levels of protection in place. Where this is not possible, we use standard contractual clauses adopted by regulatory authorities, such as the European Commission. You have the right to obtain a copy of the recipient countries or security measures we use by contacting us as described at the end of this Privacy Statement.

5. HOW LONG WE KEEP YOUR PERSONAL DATA

We will retain your personal data for as long as necessary or permitted, taking into account the purpose(s) for which it was obtained and in accordance with applicable law.

The criteria we use to determine our retention periods include:

  • The length of time we have an ongoing relationship with you and provide SkyShowtime to you (for example, as long as you have an account with us or continue to use SkyShowtime) and where we have legitimate interests to further retain your personal data as set out in this Privacy Statement;
  • Where there is a legal obligation to which we are subject (for example, certain laws require us to retain your transactions for a certain period of time before we can delete them such as regulatory, tax and audit laws);
  • Where retention is advisable due to our legal position (such as in relation to applicable statutes of limitations, litigation or regulatory investigations); and
  • All guidelines issued by relevant legal and data protection authorities.

6. SENSITIVE PERSONAL DATA

We ask that you do not send us sensitive personal information (e.g. social security numbers, information related to racial or ethnic origin, sexual orientation or sex life, political opinions, religion or philosophical beliefs, health-related information, criminal background, or trade union membership) on or through SkyShowtime or otherwise, unless we expressly request this information. If you provide this information proactively and voluntarily, you will be deemed as having given your consent for us to process this data.

7. YOUR PRIVACY RIGHTS

You have the right to, access, correct, object, restrict, delete, transfer, withdraw consent (where relied upon as a legal basis as listed above) and be informed about how we use your personal data. You can submit your request here, or contact us through our Help Centre (you will need to be logged in to access this). You or your authorized representative may also submit your request, or any other questions or concerns about this Statement or our data processing practices, by contacting us at: privacy@SkyShowtime.com. We will respond to your request in accordance with applicable law. Please note that these rights may be limited in certain circumstances, for example, if providing the requested information reveals another person's personal data. For your protection, we may need to verify your identity before responding to your request. If you are an authorised representative, we may ask for proof that you have authority to act on behalf of the account holder.

You can also write to us at: Compliance Team, SkyShowtime Limited, Sky Central, Grant Way, Isleworth, Middlesex, TW7 5QD, United Kingdom.

Our Data Protection Officer (“DPO”) is responsible for ensuring the protection of your personal data and ensuring compliance with data protection laws. You can contact our DPO at dpo@skyshowtime.com for any questions or concerns related to your personal data.

Please note that email communication is not always secure, so please do not include credit card information or other sensitive information in your email messages to us.

You also have the right to lodge a complaint about us to the UK Information Commissioner’s Office (www.ico.org.uk) or your local Data Protection Authority (“DPA”). A list of the EU DPA’s can be found here.

8. UPDATES TO THIS PRIVACY STATEMENT

We may change this Privacy Statement at any time. We will notify you of significant changes if we have a relationship with you and otherwise post updated versions on our website from time to time. Please see the LAST UPDATED legend at the top of this page to see when this Privacy Statement was last revised. Any changes to this Privacy Statement will become effective when we make the revised Privacy Statement available on or through the SkyShowtime website.