Polska Plus

Vision TV Network Privacy and Cookie Policy

 

1. Introduction

 

This is our privacy policy. It tells you how we collect and process data received from you on our website, through our television services or on social media or otherwise in connection with our business.  Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

 

If you have any comments on this privacy policy, please email them to This email address is being protected from spambots. You need JavaScript enabled to view it.

 

 

2. Who We Are

 

Here are the details that the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regards to the processing of personal data and on the free movement of such data, known as General Data Protection Regulation (GDPR) says we have to give you as a 'data controller':

 

 

3. What we may collect

 

We may collect and process the following personal data from you:

 

·         Information you give us. You may give us information about you by filling in forms on the Website or by corresponding with us by phone, email or otherwise. This includes information you provide when you opt-in to receive information and marketing from us or other parties, subscribe to and use our television services, engage with us in social media, provide feedback or otherwise post content on the Website and when you contact our support or help-desk teams.

Please note that if you pay for a subscription to one of our television services on the Website, your credit/debit card or other payment details are not processed by use but by our third party payment processor, SagePay, who merely confirms to us when subscription payments are due and whether or not payment has been received by them.For more information please review our third party payment processor's policies at www.sagepay.co.uk/policies

·         With regard to each of your visits to the Website we may automatically collect the following information about you: the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, geographic location and time zone setting, browser plug-in types and versions, operating system and platform; Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the Website (including date and time); pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, video stream viewing behavior such as time viewed, channels/VoDs/streams viewed, data transit usage and internet connection speed.

·         We work closely with additional third parties (including, for example, advertising networks, business partners, credit card payment processors, data analytics providers, search information providers) and may receive information about you from them

 

4. Cookies

 

The website uses cookies or similar technology to collect information about your access to the site. Cookies are pieces of information that include a unique reference code that a website transfers to your device to store and sometimes track information about you. Some of the cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies are used to remember you when you return to the website and will last for longer. All cookies used on our site are set by us.

 

Most computer and some mobile web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can prevent the setting of cookies by adjusting the settings on your browser. Please note however, that by blocking or deleting cookies you may not be able to take full advantage of the site.

 

Our cookies will be used for:

 

Essential session management

  • creating a specific log-in session for a user of the website in order that the website remembers the users progress while form filling and/or that a user is logged in and that their page requests are delivered in an effective, secure and consistent manner;
  • recognising when a user of the website has visited before allowing us to identify the number of unique users we receive to the website and make sure we have enough capacity for the number of users that we get;
  • recognising if a visitor to the website is registered with us in any way;
  • we may also log information from your computer including the existence of cookies, your IP address and information about your browser program in order to allow us to diagnose problems, administer and track your usage of our website.

 

Functionality

  • customising elements of the promotional layout and/or content of the pages of the website.

 

Performance and measurement

  • collecting statistical information about how our users use the website so that we can improve the website and learn which parts are most popular to users.

 

5. How we use personal data

 

We use personal data you give to us or that we have collected [and/or received] about you in order to operate the Website and to provide and promote our services and in particular to:

 

·         provide you with access to our Website and our subscription video services;

·         carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;

·         ensure that the Website and our services are presented in the most effective manner for you and for your computer and devices;

·         enable our third party payment processor to administer payments;

·         notify you about changes to the Website and/or our services;

·         seek to improve the Website and/or our services;

·         administer the Website and our services for internal operational requirements, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

·         strive to keep the Website and/or our services safe and secure;

·         deliver and measure or understand the effectiveness of our content and advertising;

·         make suggestions and recommendations about gods or services that may interest you;

·         to enable you to interact with other users of the Website

·         to allow you to participate in interactive features of our services, when you choose to do so

 

 

6. Disclosure of your personal data

 

We may disclose your personal data to:

 

·         any member of our group, which means our subsidiaries, our company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;

·         business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you[, for example, our payment service provider];

·         Payment Processors that require the information to provide their services to you

·         Analytics and search engine providers that assist us in the improvement and optimization of the Website; and

·         credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.

 

The personal data we may disclose to third parties:

 

·         if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions and other agreements;

·         to protect the rights, property, or safety of us, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction;

·         data derived from usage of the Website and views and downloads of pages, profiles and adverts on the Website which will always be in aggregated and anonymized form to customers, purchasers and retailers;

·         where we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;

·         if we or substantially all of our assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;

 

7. Where we store and how we protect your personal data

 

Some countries outside of the European Union (EU) do not have laws that protect privacy rights and personal data as extensively as the UK and other countries within the EU. We do not generally or routinely transfer personal data outside of the EU but some of the organizations to which we may disclose personal data may be situated outside of the EU. If we do transfer your personal data outside of the EU, we will ensure that your personal data is protected to a similar degree, in accordance with data protection law. We do this by ensuring one of the specific safeguards approved by the European Commission is in place. You can find further information about these safeguards at https://ec.europa.eu/info/law/law-topic/data-protection_en.

 

We implement appropriate technical and organizational measures (taking into account the state of current technology, the costs of implementation and the nature, scope, context and purposes of processing as well as the likelihood and severity of risks for you and others whose personal data we process) to ensure a level of security appropriate to the relevant risks especially those presented by the processing, in particular from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, stored or otherwise processed.

 

We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know and we have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

8. The lawful basis of our processing

 

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data on the following lawful bases:

 

  • where we need it to perform the contract we are about to enter into or have entered into with you;
  • where we need to do so for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
  • where we need to comply with a legal or regulatory obligation.

 

Please note that these overlap and we may process your personal data under more than one of basis.

 

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to our use of cookies (which you accept when you first visit our Website) - see 4. Cookies above -  sending our newsletters and other direct marketing communications to you via email.

 

You have the right to withdraw your consent to such marketing by contacting us using the details in section 2. above or the opt-out link included in our emails and to our use of cookies at any time.

 

9. Purposes for which we use your personal data:

 

We have set out below, in a table format for ease of review, a description of all the ways we use your personal data, and which of the legal basis (as referred to in section 8.) we rely on to do so.  We have also identified what our legitimate interests are where appropriate. Please contact us if you need further details on any of the following:

           

Purpose/Activity

Lawful basis for processing (including our legitimate interest)

To process your order for services including: email confirmations, responding to questions/complaints and administering charges and refunds with our payment processor - where relevant in accordance with applicable sales law

Performance of a contract with you

Necessary to comply with a legal obligation

To manage your account and our relationship with you through this Website and our television services including: responding to questions/complaints, asking you to engage with service functionality, leaving a review or taking a survey or notifying you about changes to our terms or privacy policy or your account 

Performance of a contract with you

Necessary to comply with a legal obligation

Necessary for our legitimate interests (to operate our Website and television services in an optimal manner in order to promote our services)

To provide you with news, information and marketing when you opt-in to our communications but also to enable you to enter into a prize draw, competition or other promotion

Performance of a contract with you

Necessary for our legitimate interests (to promote our television and broadcasting services and our business/brand)

To administer and protect our business and the operation of this Website and our television services including technical troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise)

Necessary to comply with a legal obligation

To deliver relevant editorial and promotional content to you on this Website and our television services measure or understand its interest and effectiveness levels

Necessary for our legitimate interests (to study use of this Website and our television services, in order to develop them and inform our marketing and business strategy)

To make suggestions and recommendations to you about this Website and our television services

Necessary for our legitimate interests (to promote our television/broadcasting services and other products and our business/brand)

To respond to requests by or otherwise make contact with other persons in relation to legal or regulatory matters relating to use of this Website  

Necessary to comply with a legal obligation

Necessary for our legitimate interests (to operate our Website in a lawful manner and to protect the reputation of our business/brand)

[To use data analytics to improve this Website, products/services, marketing, customer relationships and experiences

Necessary for our legitimate interests (to define types of customers for our products and services, keep this Website updated and relevant and inform our marketing and business strategy)

 

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, this may have an impact on our ability to provide the Website, the services or otherwise engage with you, or to perform the contract in question - but we will notify you if this is the case at the time.

 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis of processing.

 

Please note that, in compliance with the above, we may process your personal data without your specific knowledge or consent where this is required or permitted by law.

 

10. Retention of your personal data

 

We retain your personal data for as long as we provide the services to you or your account remains open. However, we may keep some data after your account is closed or you cease using the Service, for the purposes set out below.

 

After you have closed your account we may retain personal data where reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, maintain security, prevent fraud and abuse, resolve disputes, enforce our Terms and Conditions, offer new features you may be interested in, or fulfil your request to “unsubscribe” from further messages from us. If none of these obligations apply we will delete Personal Data within 12 months of your account being closed.

 

We will retain de-personalized information after your account has been closed.

 

11. Your rights in relation to personal data

 

You have certain legal rights in respect of your personal data, including the following:

 

·         you have the right to request access to the personal data that we hold about you and, in some cases and where technically feasible, you have the right to have your personal data transferred to a third party in a machine-readable format;    

·         you have the right to ask us to limit or cease processing or erase the personal data that we hold about you in certain circumstances and in responding to such requests, we will explain to you the impact of such restrictions or deletions, for example, on our ability to provide all the functions of the Website to you;

·         you have the right to ask us to rectify any inaccurate data we may hold about you - and you can inform of us of any changes to your personal details for us to make - or you can do this yourself in the Account section of this Website;

·         you have the right to object to us using your personal data on the basis of our legitimate interests and the right to ask us not to process your personal data for marketing purposes (where relevant) - see section 8. above; and

·         you have the right to lodge a complaint about us to the relevant supervisory authority for personal data, in the UK this is Information Commissioner’s Office (https://ico.org.uk/).

 

You may action your rights at any time by contacting us using the details in section 2. and we will comply with your requests unless we have a lawful reason not to do so and within a reasonable period and, in any event, we will respond to you (even if we require an extension of time) within a month of the original request. Prior to meeting such requests, we may require you to confirm your identity by providing approved identification. We will not charge you unless your request is manifestly unfounded or excessive, in which case we may refuse to comply.

 

12. Changes to our privacy policy

 

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email.

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