Last updated – 06 March 2023
Digital UK Limited - Privacy Notice
Introduction
Your privacy is important to us. This Privacy Notice explains what personal information Digital UK Limited ("DUK", “we”, “us” and “our”) collect about you (“you”) and what we do with it. Please take a few minutes to read it.
This Privacy Notice applies to the personal information we collect through (or relating to) your use of:
- our website at www.hdsatelliteupgrade.co.uk; and
- our hotline, which you may use to apply for the HD Satellite Upgrade Scheme.
What personal information do we collect about you and why?
We may collect personal information about you in the following ways:
(i) Information you provide voluntarily
We collect personal information you provide to us voluntarily when using our Digital Properties or contacting us via our hotlines, email or post. This includes, for example, information you provide through our Digital Properties (such as your name, telephone number or postcode when you register to check your eligibility for the HD Satellite Upgrade Scheme), or when you contact us via the website or our hotlines (for example, to claim a voucher).
The personal information you are asked to provide, and the reasons you are asked to provide it will be made clear to you at the point we ask you to provide it (such as name, email address, set-top box number, telephone number, etc).
(ii) Information we collect automatically
When you use our Digital Properties, we may also collect certain information automatically from your device (which may include your computer, mobile, tablet or other device depending on which Digital Property you are using). In some countries, including countries in the European Economic Area and the UK, this information may be considered personal information under applicable data protection laws.
Specifically, the information we collect automatically may include anonymous information such as your device type, any unique device identification numbers, browser-types, your broad geographic location (e.g. country or city-level location) or your specific device location if you grant us permission via your location settings, your IP address, the identity of your internet service provider, the name and version or your operating system and other technical information. We may also collect information about how your device interacts with our Digital Properties, including the pages accessed and links clicked.
Collecting this information enables us to understand better the visitors to our Digital Properties, the number of visitors, where they come from, and the average time spent on the Digital Properties. We use this information for our internal analytics and other similar purposes.
We may collect some of this information automatically through the use of cookies and similar tracking technologies. For more information, please see the heading below “What cookies and similar technologies do we use?”
(iii) Information we obtain from third-party sources
From time to time, we may receive personal information about you from third-party sources but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us.
We use the information we receive from these third parties to provide assistance regarding the HD Satellite Upgrade Scheme and to improve our products and services.
In general, we will use the personal information we collect about you only for the purposes described in this Privacy Notice or for the purposes we explain to you at the time we collect your personal information.
With whom do we share your personal information?
We may disclose your personal information to the following categories of recipients:
- to our group companies Freesat UK Limited, Digital UK Trading Limited and its affiliates, the British Broadcasting Corporation (BBC), as well as third-party service providers and partners who provide data processing services to us (for example, to support the technical aspects, to help respond to support and advice requests; or to administer competitions on our behalf), or who otherwise process personal information for purposes described in this Privacy Notice or notified to you when we collect your personal information;
- to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
- to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice;
- to any other person with your consent to the disclosure.
What legal grounds do we have to process your personal information?
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only (i) where we have your consent to do so, (ii) where we need the personal information to perform a contract with you; or (iii) where the processing is in our legitimate interests and not overridden by your rights. In some cases, we may also have a legal obligation to collect personal information from you.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our Digital Properties, communicating with you as necessary to provide our Digital Properties and for our legitimate commercial interest, for instance, when responding to your queries, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to contact us” heading below.
Is your personal information transferred to other countries?
Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws different from the laws of your country. This means when we collect your personal information we may process it in any of these countries.
We will take appropriate measures to ensure your personal information is adequately protected in accordance with this Privacy Notice and data protection laws. Such measures may include transferring the data to a recipient that has executed standard contractual clauses adopted or approved by UK adequacy decisions. For further details about these measures, please contact us using the details provided below.
What cookies and similar technologies do we use?
We use cookies and similar tracking technologies (collectively, "Cookies") on our Digital Properties to collect and use personal information about you. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our cookie statement.
How long do we retain your personal information?
We retain personal information we collect from you where we have an ongoing legitimate business need to do so. Such legitimate business interests include, for example, to deal with any requests made by you, to provide you with a service or any help you have requested, to complete a competition or promotion we are running, to complete research insight or analysis, or to comply with applicable legal, tax or accounting requirements.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
What are your data protection rights?
You have the following rights in respect of the personal information we collect and use about you:
- If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided below.
- In addition, you can object to the processing of data relating to you on legitimate interest grounds, to restrict processing of your personal information or request portability of your personal information.
- You have a right to opt out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you. To opt out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided below.
- Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. Contact details for the UK Information Commissioner’s Office can be found at www.ico.org.uk.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
How is your personal information kept secure?
We use appropriate technical and organisational measures to protect the personal information we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. Specific measures we use include keeping your personal information on secure servers and computer systems, protected from outside intrusions.
We also take measures to require that third parties with whom your personal information is shared in accordance with this Privacy Notice have in place appropriate security measures and do not process your personal information for unauthorised purposes.
Links to other websites
The Digital Properties may contain links to sites or applications operated by other entities. We do not control the privacy policies or the terms of use of the websites or applications reached through the links from the Digital Properties. These may differ from this Privacy Notice and the terms of use of the Digital Properties. Ensure you check the relevant privacy notices of any third party so that you understand how they will use your personal information to determine if they are acceptable to you. We accept no responsibility for the content or the privacy practices employed by such other websites or applications.
Changes to this Privacy Notice
We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update this Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material changes if and where this is required by applicable data protection laws.
You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top. You are advised to visit the Privacy Notice on a regular basis to stay informed of our current privacy practices.
How to contact us
If you have any questions or concerns about our use of your personal information, please contact us using the following details: by email to: mydata@freesat.co.uk or post to: Legal Department, Digital UK Limited, Fieldfisher, Riverbank House, 2 Swan Lane, London EC4R 3TT.
The data controllers of your personal information are (1) Digital UK Limited which is registered with the Information Commissioner's Office with registration number Z9156270 and (2) British Broadcasting Corporation which is registered with the Information Commissioner’s Office with registration number Z517352X acting as joint data controllers.
BBC (HD Device) Help Scheme - Privacy Notice
Your trust is very important to us. This means the BBC is committed to protecting the privacy and security of your personal data. It is important that you read this notice so that you are aware of how and why we are using such personal data. This privacy notice describes how we collect and use personal data about you during and after your relationship with us, in accordance with data protection law.
Why are we doing this?
A small portion of TV licence customers/households will be affected by the closure of Single-Definition Satellite transmission. To help our audience receive superior broadcast transmission in high-definition we have created a help scheme to migrate vulnerable audiences onto HD devices.
Depending on the contact method you prefer, you can either contact the call centre or use the online web form.
Both contact options will use an eligibility test to understand the level of support we will provide you with. The answers to the eligibility test are not saved, only the outcome.
Advisory services are provided to everyone. Customers who are deemed vulnerable will receive financial contribution towards a new box and in some cases home installation.
The BBC is working with two (2) third-parties to help facilitate the scheme.
What personal data will BBC collect and how will we use it?
Personal data will be collected and processed by our third-parties for the purpose of providing advice and to facilitate the help scheme.
Personal data:
Depending on the service provided, the third party will collect and process the following personal data about you:
- Full name
- Telephone number
- Email address
- Postal address (for delivery or installation) if applicable
- Bank details (for payment contribution to a new HD box) if applicable
- Outcome of the Disability/Vulnerability test
- Set top box serial number (if applicable)
- IP address (if applicable)
Who is the Data Controller?
The BBC is the “data controller” of your personal data. This means that the BBC decides what your personal data is used for, and the ways in which it is processed. For the avoidance of doubt, your personal data will be collected and processed solely for the purposes set out in this privacy notice. As the data controller, the BBC has the responsibility to comply, and to demonstrate compliance with, data protection law.
Lawful basis for processing your personal data
The legal basis on which the BBC processes your personal data is the performance of its public task. This ties into our distribution duty in the Agreement;
“(1) The BBC must do all that is reasonably practicable to ensure that viewers, listeners and other users (as the case may be) are able to access the UK Public Services that are intended for them, or elements of their content, in a range of convenient and cost-effective ways which are available or might become available in the future. These could include (for example) broadcasting, streaming or making content available on demand, whether by terrestrial, satellite, cable or broadband networks (fixed or wireless) or via the internet.”
Sharing your personal data
The BBC works with our approved third-party providers who help us to provide some of our services. These partners only use your personal data on behalf of the BBC and not independently of the BBC.
For this help scheme we are using two (2) separate third-parties. They will share personal data between them to serve our customers in a joined-up fashion. The BBC will receive anonymised data for performance management purposes of the help scheme.
We may share personal data with a third party where required or permitted by law.
Retaining your personal data
Your personal data is retained for the duration of the help scheme (12 months, or in the event of extension, not more than 6 months following the initial 12 months) after which it will be deleted.
If you have been provided with an HD box, your personal data will be retained for the duration of the warranty (24 months) after which it will be deleted.
Transaction data will be retained for up to six (6) years for regulatory purposes.
Your personal data will be stored within the UK.
Your rights and more information
You have rights under data protection law:
- You can request a copy of the personal data BBC stores about you.
- You have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you.
- You have the right to ask for the personal data we collect about you to be deleted however there are limitations and exceptions to this right which may entitle the BBC to refuse your request.
- In certain circumstances, you have the right to restrict the processing of your personal data or to object to the processing of your personal data.
- You have the right to ask that we transfer the personal data to you or to another organisation, in certain circumstances.
You can contact our, Data Protection Officer if you have questions or you wish to find out more details about your rights, please visit the BBC’s Privacy and Cookies Policy at http://www.bbc.co.uk/privacy.
If you have a concern about the way the BBC has handled your personal data, you can raise your concern with the supervisory authority in the UK, the Information Commissioner’s Office (ICO) https://ico.org.uk/.
Updating this privacy notice
We will revise the privacy notice if there are significant changes to how we use your personal data.