Sky Privacy Centre

DATED 2022-07-01 · VERSION 20220801_rev01 · COMPARED WITH 20220501_rev01 · ARCHIVE SNAPSHOT

Full text changes — 20220501_rev01 to 20220801_rev01

COLOUR MARKS THE SEVERITY OF A FLAGGED CLAUSE · + AND − MARK ADDED AND REMOVED

 ## 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:
+This privacy and cookies notice applies to the processing of personal data, including information we collect and store via cookies, by:
 - **Sky UK Limited**, if you access our UK products and services or our online digital platforms (including where Sky UK Limited trades under the name "NOW"), or
 - **Sky Ireland Limited**, acting as agent for Sky Subscribers Services Limited (Irish branch), if you access our Irish products and services or our online digital platforms (including where Sky Ireland Limited trades under the name "NOW"), and
 references in this notice to "**Sky**", "**we**" "**us**" or "**our**" should be interpreted accordingly. The processing explained in this notice may be carried out by Sky or other data controllers in the Sky group of companies (including Sky Subscribers Services Limited, Sky In-Home Service Limited and Sky Retail Stores Limited).
 References to Comcast refer to the parent company of Sky, Comcast Corporation, 500 Gravers Road Suite 3000 Plymouth Meeting, PA 19462 United States.
 If you access the products and services of other Sky companies and businesses, you should refer to their privacy notices.
+## **Information we collect and how we use it**
+### Information you provide to us
+**Contact Details & Account Information**
+Contact details and other information on or about your account. This includes your:
+- name
+- address
+- contact information (such as phone numbers and email addresses)
+- date of birth
+- Sky iD
+- account number
+- viewing card number
+- marketing preferences
+- payment information
+- National Insurance number
+- ID documents (such as your passport or driving licence)
+**Contact Details & Account Information**
+From you, through our websites, applications or products and services, when you access our services through applications on websites operated by other organisations, or when you otherwise provide it to us (for example on calls or via live chat or our messaging services).
+**Contact Details & Account Information**
+_To provide your service / perform our contract with you_
+- to provide you with content, products and services (including trials), in accordance with the contract you have with us. This includes providing you with tailored and personalised experiences with our products and services (such as recommendations about your content) and sending you newsletters about your content, products and services. **1.** (see **Additional info** tab)
+- to enrol you in our Sky VIP Programme and provide the applicable rewards. **2.**
+- to enter into a loan agreement with you. For these we need to take automated decisions on whether to grant you the loan based on personal data we obtain from credit reference agencies (See the below section on "Information from third parties"). **3.**
+- to verify your identity, including when you exercise your subject rights.
+- check that you are eligible for our products, services and that you are using these in accordance with the terms of the contract you have with us.
+_With your consent_
+- to send you direct marketing about our content, products, services events and special offers by post, telephone, SMS, email, notification or other electronic means to the contact details you have provided. **4.**
+_Where we have a legitimate interest_
+- to prevent and detect fraud and protect or enforce our or any third party's rights. This may involve analysing activity on our network to help stop unauthorised access to content or publication of or access to unlawful content.
+- to prevent and detect crime.
+- to support public and road safety.
+- for market research.
+- to send you direct marketing where we're not relying on your consent to do so. For example, to send you push or in-app notifications or if you're a prospective customer.
+- For the following activities explained further in the section "More information about certain activities" below:
+    - AdSmart
+    - PromoSmart
+    - Online and Digital advertising
+    - AdVance
+- to verify the personal data we hold about you is accurate (for example, your address).
+- to monitor, record, store and use customer service communications we have with you. **5.**
+_Where we have a legal obligation_
+- to comply with police and other security investigations.
+- to enable Sky to support customers whose circumstances might make them vulnerable or in need of special assistance, including to comply with (and demonstrate compliance with) Ofcom's consumer protection requirements.
+_Where there is a vital interest_
+- to safeguard your vital interests or those of another person to support crime prevention and protect the safety of members of the public and Sky employees.
+**Contact Details & Account Information**
+**1.** This also includes providing account management functionality, billing and payments, customer support (inc. diagnostics and trouble-shooting).
+**2.** The Sky VIP Programme enables you to access special rewards, perks and experiences. We will process your data to administer the Sky VIP Programme, including sharing with third parties who provide experiences and fulfilment agencies. Where you choose to enter into the separate and additional terms and conditions for our Sky VIP Programme, we will send you direct marketing in accordance with the terms of that contract.
+**3.** The automated 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.
+**4.** In addition to marketing we send while you are a Sky customer, we may also send marketing:
+- before you become a Sky customer, such as 'abandoned basket' marketing if you gave us consent to use your contact details for marketing during an online sales journey but didn't complete your purchase. We will tailor the marketing based on what you added to your basket.
+- for a reasonable time after you cease to be our customer.
+**5.** This helps us to: improve the quality of our customer service; confirm any instructions you give us; create a customer profile so we can have better conversations with you, and train and develop our staff.
+**Product Holdings**
+Information about the products and services you have (or enquired about) or previously had, and your (i) interactions with us about those products and services; (ii) payment and offer history in respect of them.
+**Product Holdings**
+From you, through our websites, applications or products and services, when you access our services through applications on websites operated by other organisations, or when you otherwise provide it to us (for example on calls or via live chat or our messaging services).
+**Product Holdings**
+_To provide your service / perform our contract with you_
+- to provide you with content, products and services (including trials), in accordance with the contract you have with us. This includes providing you with tailored and personalised experiences with our products and services (such as recommendations about your content) and deciding what to include in newsletters about your content, products and services.
+- to enter into a loan agreement with you.
+- to check that you are using our products and services in accordance with the terms of the contract you have with us
+- to tailor our Sky VIP Programme to you and provide the applicable rewards.
+_Where we have a legitimate interest_
+- for market research
+- to build a profile about you and your time as a Sky customer, which we use to target and tailor the direct marketing we send you, determine what offers about our products and services you are eligible for and how to provide those offers to you.
+- For the following activities explained further in the section "More information about certain activities" below:
+    - AdSmart
+    - PromoSmart
+    - Online and Digital advertising
+    - AdVance
+- to provide tailored and personalised recommendations based on your viewing activity which would require an additional purchase or transaction by you.
+- to monitor, record, store and use customer service communications we have with you. **1.** (see **Additional info** tab)
+_Where we have a legal obligation_
+- to comply with police and other security investigations.
+- to enable Sky to support customers whose circumstances might make them vulnerable or in need of special assistance, including to comply with (and demonstrate compliance with) Ofcom's consumer protection requirements.
+**Product Holdings**
+**1.** This helps us to improve the quality of our customer service; confirm any instructions you give us; create a customer profile to have better conversations with you, and train and develop our staff.
+**Customer Service Interaction Data & CCTV Data**
+This includes:
+- records of your customer service interactions with us, such as call recordings and records of your conversations and correspondence with us.
+- images recorded by cameras at Sky Retail Stores or fitted to Sky's engineer vans.
+**Customer Service Interaction Data & CCTV Data**
+From you, including when you contact us and your image from CCTV footage recorded when you visit a Sky Retail Store or other Sky locations.
+from you when in the vicinity of one of our Sky vans.
+**Customer Service Interaction Data & CCTV Data**
+_Where we have a legitimate interest_
+- for market research.
+- to monitor, record, store and use customer service communications we have with you. **1.** (see **Additional info** tab)
+- to help prevent and detect crime.
+- to support public and road safety.
+- to protect the safety of Sky employees.
+_Where we have a legal obligation_
+- to comply with police and other security investigations.
+- as part of supporting or defending legal claims (for example, where we need to disclose information as part of Court proceedings).
+_Where there is a vital interest_
+- to safeguard your vital interests or those of another person.
+**Customer Service Interaction Data & CCTV Data**
+**1.** This helps us to: improve the quality of our customer service; confirm any instructions you give us; create a customer profile so we can have better conversations with you, and train and develop our staff.
+**Special category data**
+This includes:
+- health data or other special category data
+- biometric information (such as facial scans)
+**Special category data**
+From you, when you provide it to us or our business partners.
+**Special category data**
+_With your explicit consent:_
+- to provide assistance and support on your account.
+- to verify your identity as part of consumer credit agreement authorisations, such as by matching your facial scans to your ID documents.
+### Information we collect automatically
+**Viewing Data, Usage Data and User Generated Content**
+Information about how you or your household use, access, view, share, contribute to, or otherwise interact with Sky and/or third-party content, websites, products and services.
+This includes the content you watch and how long you watch it for (we call this viewing activity), as well as content you add to your Playlist (if using Sky Glass).
+**Viewing Data, Usage Data and User Generated Content**
+From you and your household when using Sky and/or third-party content, websites, products and services (such as third party apps).
+**Viewing Data, Usage Data and User Generated Content**
+_To provide your service / perform our contract with you_
+- to provide you with tailored and personalised experiences with our products and services (such as recommendations about content available within your services) and sending you newsletters about your content, products and services.
+- to check that you are using our products and services in accordance with the terms of the contract you have with us.
+- to manage traffic across our networks and operate our products and services effectively. **1.** (see **Additional info** tab)
+_Where we have a legitimate interest_
+- to provide tailored and personalised recommendations based on your viewing activity which would require an additional purchase or transaction by you. **2.**
+- to prevent and detect fraud and protect or enforce our or any third party's rights. This may involve analysing activity on our network to help stop unauthorised access to content or publication of or access to unlawful content.
+- for market research.
+- to build a profile about you and your time as a Sky customer, which we use to target and tailor the direct marketing we send you, determine what offers about our products and services you are eligible for and how to provide those offers to you.
+- For the following activities explained further in the section "More information about certain activities" below:
+    - AdSmart
+    - PromoSmart
+    - Online and Digital advertising
+    - AdVance
+- to improve and develop new content, products, services and customer experiences.
+_Where we have a legal obligation_
+- to comply with police and other security investigations.
+**Viewing Data, Usage Data and User Generated Content**
+**1.** For example, transmitting your requests for any communications service through the most efficient route in our network of equipment and systems.
+**2.** For example, this may include content available on Sky Store or content you'd need a package upgrade to watch.
+**Device Information & Telemetry Data**
+This includes:
+- technical information, including diagnostic (such as errors and system statuses), traffic and location data.
+**Device Information & Telemetry Data**
+From the devices you use to receive Sky content, products and services.
+**Device Information & Telemetry Data**
+_To provide your service / perform our contract with you_
+- to diagnose, evaluate and fix problems with our products and services.
+- to manage traffic across our networks and operate our products and services effectively. **1.** (see **Additional info** tab)
+- to check that you are using our products and services in accordance with the terms of the contract you have with us.
+_Where we have a legal obligation_
+- to comply with police and other security investigations.
+**Device Information & Telemetry Data**
+**1.** For example, transmitting your requests for any communications service through the most efficient route in our network of equipment and systems.
+**Product Analytics**
+This includes information about your household's use of Sky, and/or third party content, products and services such as 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 Sky devices.
+**Product Analytics**
+From the devices you use to receive Sky content, products and services.
+**Product Analytics**
+_To provide your service / perform our contract with you_
+- to provide you with content, products and services (including trials), in accordance with the contract you have with us.
+_Where we have a legitimate interest_
+- to improve and develop new content, products, services and customer experiences.
+- to tailor the direct marketing we send you, determine what offers about our products and services you are eligible for and how to provide those offers to you.
+- For the following activities explained further in the section "More information about certain activities" below:
+    - AdSmart
+    - PromoSmart
+    - Online and Digital advertising
+    - AdVance
+**IP Addresses & Online Identifiers**
+This includes information from the devices you use to communicate with websites and applications on the internet, such as:
+- IP addresses
+- MAC addresses
+- unique identification numbers
+- online identifiers (for example, device IDs and advertising IDs)
+- browser information.
+**IP Addresses & Online Identifiers**
+From the devices you use to communicate with websites and applications on the internet
+**IP Addresses & Online Identifiers**
+_To provide your service / perform our contract with you_
+- to provide you with content, products and services (including trials), in accordance with the contract you have with us.
+- to check that you are using our products and services in accordance with the terms of the contract you have with us.
+- to manage traffic across our networks and operate our products and services effectively. **1.** (see **Additional info** tab)
+_Where we have a legitimate interest_
+- to determine the country you are located in, so we can provide you with the correct information such as product and pricing information on our websites.
+- For the following activities explained further in the section "More information about certain activities" below:
+    - AdSmart
+    - PromoSmart
+    - Online and Digital advertising
+    - AdVance
+- to prevent and detect fraud and protect or enforce our or any third party's rights. This may involve analysing activity on our network to help stop unauthorised access to content or publication of or access to unlawful content.
+_Where we have a legal obligation_
+- to comply with police and other security investigations.
+**IP Addresses & Online Identifiers**
+**1.** For example, transmitting your requests for any communications service through the most efficient route in our network of equipment and systems
+**Voice data**
+Your voice data when using voice command or 'Hello Sky' features.
+**Voice data**
+When you use the voice command feature on your remote control or, if you're a Sky Glass customer, when you say 'Hello Sky'. For Sky Glass this 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.
+**Voice data**
+_To provide your service / perform our contract with you_
+- to action your voice search or voice control commands when using our products and services.
+_Where we have a legitimate interest_
+- to improve and develop our voice-related services (including our voice algorithms, the recording of the voice searches made and the success of the "Hello Sky" command when you use Sky Glass).
+- to understand how people are using our voice-related services and the common themes and trends based on that usage.
+### Information from third parties
+**Third Party Data**
+Information we obtain from third parties, including:
+- address verification data
+- contact information
+- modelled household
+- profile information (such as affluence and household composition)
+- personal data that is publicly available.
+**Third Party Data**
+From other organisations, such as address verification services, data brokers, property and lifestyle agencies, and credit reference agencies.
+These organisations include:
+- Royal Mail
+- Experian
+- Dunnhumby
+- CACI
+- TwentyCi
+- TransUnion
+- Mastercard
+- Ordnance Survey
+- Emma's Diary (where you have consented to this)
+- Nectar360
+- Frasers Group
+If you want to manage how these organisations use your personal data and share it with companies like Sky, you should get in touch with them directly. In the case of Experian, you can access their Consumer Information Portal [here](https://www.experian.co.uk/privacy/consumer-information-portal/opt-out-options/).
+**Third Party Data**
+_To provide your service / perform our contract with you_
+- to enter into a loan agreement with you. For these we need to take automated decisions on whether to grant you the loan based on personal data we obtain from credit reference agencies. **1.** (see **Additional info** tab)
+_Where we have a legitimate interest_
+- to send you direct marketing where we're not relying on your consent to do so. For example, if you're a prospective customer.
+- to verify the personal data we hold about you is accurate (for example, your address).
+- to build a profile about you and your time as a Sky customer, which we use to target and tailor the direct marketing we send you, determine what offers about our products and services you are eligible for and how to provide those offers to you.
+- For the following activities explained further in the section "More information about certain activities" below:
+    - AdSmart
+    - PromoSmart
+    - Online and Digital advertising
+    - AdVance
+**Third Party Data**
+**1.** The automated 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.
+## More information about certain activities
+AdSmart is Sky's tailored TV advertising solution. AdSmart allows us to show adverts within your TV services (including on Sky+, Sky Q, Sky Glass and Sky Go) to the people most likely to be interested in the products and services being promoted. We also work with Virgin Media to enable AdSmart for their customers on their TV platforms.
+With AdSmart, Sky and Virgin can show different adverts to different households (in groups of 5,000 or more across Sky and Virgin households) watching the same programme or service. To do this we create a profile about a household comprising factors like interests, age and location using the information you have provided to us, information about your use of our products and services, and information we have acquired from other organisations, and which we may combine with information received from brands wishing to target their advertising to a particular audience. We use this profile information to define groups of audiences to whom we send adverts.
+As part of showing these adverts, we also carry out quality and frequency checks, such as whether adverts were displayed correctly and how often particular adverts have been shown.
+PromoSmart uses the same process described above to deliver tailored promotions (e.g. for upcoming content) within your TV services.
+To the extent any special category data (for example, data concerning health) is processed within AdSmart, Sky relies on your consent for such processing.
+If you don't want your data to be processed for AdSmart & PromoSmart let us know using one of the methods in the "Managing Your Preferences" section below. You will still see adverts and promotions within your TV services, but they may be less relevant to you.
+More information about how AdSmart can be used by advertisers can be found [here](https://www.adsmartfromsky.co.uk/how-sky-adsmart-works/).
+We work with trusted partners to process your personal data to tailor and deliver online and digital advertising, specifically:
+- Sky's own advertising on websites, apps and social media platforms; and
+- third-party advertising on websites and apps.
+_Information we use_
+_How we use this information_
+This information 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 Sky 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.
+_What happens if you interact with an advert_
+If you interact with an advert (such as by clicking a link or scanning a QR code displayed in the advert) we will collect and use the information you provide to enable our partner to fulfil the interaction. For example, if you enter your name, address and payment details to purchase an advertised item, this data will be processed by the fulfilment agency to deliver that item. This information will also be used by us for the purposes described in this section. We also use aggregated data to better understand advertising performance.
+_Your online and digital advertising preferences_
+If you don't want your data matched with the social media sites you use, let us know using one of the methods in the "Managing Your Preferences" section below. You might still see Sky posts or adverts on those social media sites, but they won't be personalised using your Sky account data. You can also change your settings on that social media site to control the promoted posts you see there, and you can find more information on how that social media site uses your personal data in its privacy policy.
+Where we use cookies or similar technologies to process your personal data for online and digital advertising purposes, you can set and manage your cookie preferences on the relevant Sky or third-party website or app. After you have made your initial choice, you can change your preferences on Sky websites and apps using the 'Privacy options' link in the footer of the site or the settings within the app.
+_Our partners_
+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 outside the UK or EU will only take place on the basis of an approved data transfer mechanism as described in the section 'How we share your information'.
+AdVance is Sky's online and digital advertising solution which allows us to tailor the digital adverts that you see on Sky and third-party websites and apps based on information we know about you or to reinforce or extend the reach of TV adverts you may have seen (or based on content you may have watched).
+To do this, we collect and use the same types of information explained in the 'Online and digital advertising' section and combine this with information about your viewing activity so we know what programmes you like and adverts you may have seen.
+Subject to your SkyiD and cookie preferences, this may be further combined with device information and information about websites you have visited and other information we hold about you, including information you have provided to us and information about your use of our products and services, to define groups of audiences to whom we deliver digital adverts. If you don't want your data to be processed for AdVance let us know using one of the methods in the "Managing Your Preferences" section below.
+Where we use cookies or similar technologies to process your personal data as part of AdVance, you can set and manage your cookie preferences on the relevant Sky or third-party website or app. After you have made your initial choice, you can change your preferences on Sky websites and apps using the 'Privacy options' link in the footer of the site or the settings within the app.
 **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 customise your experience.
 When you access Sky.com, the Sky News and Sky Sports sites and apps, or other Sky websites and apps for the first time, you will be asked to set your cookie preferences for the site.
 If you have any queries or comments about this privacy and cookies notice, please write to Customer Relations, Sky Subscriber Services Ltd, PO Box 43, Livingston, West Lothian, EH54 7DD, UK or to Customer Relations, Sky Subscriber Services Limited, One Burlington Plaza, Burlington Plaza, Dublin 4, ROI or contact Sky's Data Protection Officer via dp.department@sky.uk.
 ## 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 14 April 2022.**
+**This privacy and cookies notice was last updated 1 July 2022.**