Sky Privacy Centre

DATED 2023-01-31 · VERSION 20230201_rev01 · COMPARED WITH 20230101_rev01 · ARCHIVE SNAPSHOT

Full text changes — 20230101_rev01 to 20230201_rev01

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

 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, information about your use of our products and services, and information we obtain from third parties (such as Experian) 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.
+### Sharing with third parties
+Sometimes we share information with suppliers and partners to provide our services and for the other purposes described above. We only share information with these companies where necessary or where we have a legitimate reason to do so and only where we are satisfied that they have appropriate security measures and controls in place to protect your personal data. When these companies act on our behalf, they will only process your personal data in accordance with our instructions and for the reasons set out in this notice.
+Some of our suppliers and partners process personal data outside of the UK or EEA (as applicable). We ensure that these companies have measures in place to comply with their obligations under UK or Irish data protection law, and we will only transfer personal data to these companies where we can rely on an approved data transfer mechanism, such as a [UK Government](https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/international-transfers-after-uk-exit/) or [EU Commission](https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en) adequacy decision or by including the appropriate [Standard Contractual Clauses](https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en) in our contracts with these companies. Sky typically relies on the Standard Contractual Clauses available here, together with the ICO's [data transfer addendum](https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/international-data-transfer-agreement-and-guidance/) (where appropriate).
+You can see more information below about how we share your information with third parties.
+Credit reference agencies ([Experian](https://www.experian.co.uk/legal/crain/), [Equifax](https://www.equifax.co.uk/crain) and [CRIF](https://www.crif.com/privacy-policy/)) fraud and crime prevention agencies ([CIFAS](https://www.cifas.org.uk/fpn))
+We share your personal data, such as your contact details, financial data and other information described below, with credit reference and fraud prevention agencies:
+- for use in automated credit decisions;
+- to help assess whether you are likely to be able to afford the products and services you wish to take from us to help protect your interests and ours;
+- for the prevention and detection of crimes such as fraud, piracy and money laundering; and
+- for identity check and data verification purposes.
+_Credit checks_
+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 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 you.
+_Fraud prevention_
+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.
+Fraud prevention agencies may allow the transfer of your personal data outside of the UK. This may be to a country where the UK Government has decided that your data will be protected to UK standards, but if the transfer is to another type of country, then the fraud prevention agencies will ensure your data continues to be protected by ensuring appropriate safeguards are in place. Where appropriate, we may also share your data with other organisations to assist with the prevention and detection of fraud.
+Where we reasonably suspect that you are pirating Sky or third-party content, we may share information with other organisations with a similar legitimate interest in preventing, detecting and prosecuting piracy.
+Data brokers
+Where a brand or advertiser wishes to target a specific advertising campaign to particular Sky households (for example, using AdSmart), we share your contact details with a data broker (such as Experian) The data broker will match that data against data provided by the brand or advertiser to identify Sky households for that campaign without Sky and the brand or advertiser accessing each other's customer data.
+For example, this data matching process could be performed on behalf of an advertiser that wants to target its television advertising to its existing customers who live near one of its stores.
+Separately, the advertiser would receive back a report showing how successful the advertising campaign was (e.g. how many times their adverts were viewed), but would not receive information or data about specific households that have seen their adverts.
+Debt collection agencies
+We will share contact information such as name, address, telephone number and email address 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.
+Payment service providers
+We may share contact details and financial details and any required associated information with our payment service providers to process payments in relation to our services.
+This includes Worldpay, who processes some data as a data controller and whose privacy notice can be found [here](https://online.worldpay.com/terms/privacy).
+Customer service centres
+We use third party contact centres, including Firstsource, to provide customer service, sales and support. These companies and their customer service agents can access contact details, account information, product holdings and customer service interaction data to enable them to support you. They may also access any special category data (such as health information) which you have provided to us to help us assist you.
+Firstsource's contact centres in India may process your personal data. Sky relies on Standard Contractual Clauses to safeguard this international transfer.
+Couriers
+We may pass on contact details (such as your name, address and contact information) to deliver packages to you on behalf of Sky. Couriers may also process your contact details as a data controller when arranging or communicating with you about your delivery.
+Our couriers include DHL (whose privacy notice can be found [here](https://www.dhl.com/gb-en/home/our-divisions/parcel/business-users/about/privacy-notice.html)) and Panther, (whose privacy notice can be found [here](https://panthergroup.co.uk/)).
+Engineer services firms
+We will share contact information such as name, address, telephone number and email address as well as and product holding information to manage, administer and schedule visits to your home where works are required as part of taking services with Sky.
+Information Technology companies and service providers
+We use technology companies and other service providers as part of our IT infrastructure which we use to deliver your service and where your personal data is stored and processed. These companies may process your personal data (such as your contact details, account information, product holdings and the information described in the 'Information we collect automatically' section above) as part of providing their services to Sky.
+Communication providers
+We share data about you (such as your name, address, email address and device information) with third party communication providers that are necessary for you to enjoy our services, such as broadband and mobile communication 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 Sky services. Data shared in this way, is deleted by the third party once the purpose has been fulfilled.
+Warranty Companies
+When you purchase Sky's products and services, we share your contact information with Domestic & General (Domestic & General Insurance PLC and Domestic & General Services Limited) to enable them to contact you to ensure you are satisfied with your service experience and to let you know about the warranties that apply to your Sky equipment and the options for extended cover.
+Loyalty / promotional partners
+We may share contact and account information with loyalty scheme and other types of promotional partners (such as Nectar), who send information about Sky's offers, products and services to their customers (where they are permitted to do so) and then report back to us on the performance of such marketing (for example confirmation if you purchased something from Sky based on receiving that marketing).
+Marketing companies
+We pass contact details and account information onto agencies who require this information to create and deliver our marketing communications.
+Promotional and reward fulfilment partners
+When you take advantage of promotions, competitions and rewards when you purchase our products and services or within the Sky VIP scheme, we may share your contact details with third parties to fulfil these.
+Third party app and content providers
+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 Sky. We do this to enable and/or verify your ability to access the relevant third-party service via Sky 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 Sky's services such as resume options for programmes you have started watching elsewhere and personalised 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.
+Other nominated individuals
+When Sky receives a request for the ownership of a vulnerable customer's account to be transferred to a nominated individual, the existing account holder's personal data may be shared with the new account holder. The ownership of the account would only be transferred once Sky has received signed acceptance and authorisation of the transfer from both parties.
+Courts, enforcement agents, government bodies, regulators
+We share personal data with the courts, enforcement agencies (e.g. the police) and with regulatory authorities (e.g., Ofcom in the UK) where this is required, in order for us to comply with our legal and regulatory obligations.
+We may also share your contact details and account information with government departments to determine eligibility for certain products, services & offers (such as the Sky Broadband Social Tariff).
+Business Successors
+In the event the structure of our business changes so that another company in the Sky Group 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.
+### Sharing with Sky Group and Comcast Group Companies
+We share personal data with other companies:
+- in the Sky Group (more information available here);
+- in the Comcast Group, specifically Comcast Corporation and Comcast Cable Communications LLC ("Comcast"); and
+- in the NBCUniversal Group, specifically Peacock TV Emea Ltd("NBCU")
+We share such personal data where necessary to provide our services and for the other purposes described in this notice. Please also be aware that:
+- we share personal data with Comcast to support the development, operation, performance and infrastructure of our products and services. This includes viewing data, product analytics data, telemetry data and voice data. Comcast companies may process this personal data in the USA and India;
+- we share personal data with Neos Ventures Limited (Sky Protect), including third party data, information on marketing and online & digital advertising that we have carried out promoting their products and service and to allow the application of offers and discounts to Sky customers who also decide to become customers of Sky Protect (and vice versa). Sky Protect may process some of this personal data in India when you contact them via phone; and
+- we share data showing how many customers have watched NBCUniversal or Peacock content on Sky with NBCU.
+As with our suppliers and partners, we only transfer data to Comcast Group companies based in the US or other countries outside the UK or EEA where we can rely on an approved transfer mechanism. For these transfers, Sky typically relies on the appropriate Standard Contractual Clauses together with the ICO's data transfer addendum.
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 ## 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 1 November 2022.**
+**This privacy and cookies notice was last updated 31 January 2023.**