CHANNEL 4 PRIVACY POLICY
This policy applies on and from 25 May 2018
(for reference, you can view both the previous Privacy and Cookies policies on our website http://www.channel4.com/4viewers/our-policies/)
Keeping your data safe
At Channel 4 we are committed to keeping your personal data safe and secure, and handling it in accordance with our legal obligations. This Privacy Policy sets out in detail the purposes for which we process your personal data, who we share it with, what rights you have in relation to that data and everything else we think it's important for you to know.
Please see below for full information about how your personal data is processed when you use the digital products and services within All 4 and our microsites. (This Privacy Policy also applies to business users who access the 4Sales Agency Portal and to journalists who register to receive Channel 4 Press Packs).
Who are we?
Channel 4 is a publicly-owned and commercially-funded UK public service broadcaster. We reinvest all of our profit back into programmes to ensure that we can continue to deliver high-quality, innovative, alternative content at no cost to the taxpayer.
As we don't receive any public funding, we pay for our programming by selling advertisements, like the advertisements you see when you watch our programmes and when you use the All4 platform. We also help other broadcasters sell their own advertising space. This means that when you use All4, we ask you to share some of your personal data with us, and we collect information about how you use All4, so that we can personalise the service for you and show you more of what you like. We also combine this data with information that you've given to other companies and brands so that we can show you more relevant advertising.
You can find out more about Channel 4 and our statutory remit here (https://www.channel4.com/corporate/about-4/what-we-do/channel-4s-remit)
1 Who's in control?
1.1 It is important that you understand who is responsible for keeping your data safe. We are the "controller" of all personal data collected and used for the purposes of providing All 4 and for any other purposes set out in this Privacy Policy. This means that we are responsible for deciding how and why your data is used and for ensuring that your data is handled legally and safely.
1.2 We have appointed a Data Protection Officer (DPO) who has ultimate responsibility within Channel 4 for making sure your data is treated in accordance with this Privacy Policy and the law. Our DPO can be contacted by emailing dataprotection@channel4.co.uk.
2 What data do we collect and where from?
2.1 We collect some data directly from you when you register for an account with All 4 (Account Data). This data includes the following:
2.1.1 your full name;
2.1.2 your email address;
2.1.3 the password you set up to access your account;
2.1.4 your date of birth;
2.1.5 your gender (if you choose to provide it);
2.1.6 your postcode and address (if you choose to provide them); and
2.1.7 your direct marketing preferences.
2.2 We also collect information that you voluntarily provide to us when you contact us with queries, complaints, comments or praise, or information that you voluntarily post about yourself on public areas of our platform (Voluntary Data).
2.3 We collect information about how you use All 4 using cookies and similar technology. This includes your viewing history, IP addresses, device identifiers and information about how long you have stayed on certain pages or what pages you have clicked on (Behavioural Data). You can find more detailed information about this in our Cookies Policy (http://www.channel4.com/4viewers/cookies) We also log and use information about any service errors or interruptions that you have experienced in order to help us create fixes and to make technical improvements to All 4. We also collect some data about you from third parties (Third Party Data). This includes:
2.3.1 other companies who have obtained your permission to share data with us, such as advertisers or other companies you have bought products or services from; and
2.3.2 reputable third party data pairing providers, such as Acxiom, who we have vetted. The data we obtain from Acxiom has been collected by Acxiom through publicly available records such as the electoral roll, or, with your consent, from surveys or other brands and companies that you engage with. Where Acxiom holds such data, this data may include data such as:
(a) Basic demographic information (for example, your age and gender)
(b) Regional location
(c) Household status (for example, if you own or rent your property)
(d) Household makeup and composition (for example, the number of people in your household)
(e) Financial status and information about your life stage (for example, if you are married or have children)
(f) Media habits (for example, which newspapers or TV channels you prefer)
(g) High level purchasing behaviours and personal interests (for example, the hobbies you have or how often you like to eat out)
(h) Credit information.
https://www.acxiom.co.uk/about-acxiom/privacy/uk-privacy-policy-2/
2.4 We collect information from research panels such as Core4. You can choose to sign up to and respond to surveys and polls and these help us to understand our viewers' opinions, views and attitudes. If you sign up to a research panel which we run, like Core4, and complete our surveys or polls, we will collect information about you including your name, contact details and survey responses (Survey Data). You can find more information about our research panels below.
2.5 We collect information about you when you participate in competitions, such as your contact information (Competition Data). This data is only used for the purposes of the relevant competition and will be subject to the terms and conditions of that competition, which will be notified to you when you enter the competition. Please see http://www.channel4.com/4viewers/comp-t-and-c for our general competition terms and conditions.
2.6 We also collect anonymised publicly available information from social networking sites such as Facebook and Twitter, for example likes, shares, tweets and posts about All 4. This information is provided to us by a third party and is fully anonymised so we cannot see who has posted the information. This information is used for internal analysis purposes.
3 What do we use your data for?
3.1 It is important that you understand how and why we use the personal data that we collect about you. This section sets out the different purposes for which we process personal data and which types of personal data we need for each purpose.
3.2 Managing your account and providing you with our services
3.2.1 We use your Account Data and Behavioural Data to set up, manage and administer your account, to log you into your account and to provide you with All 4 and any other services that you request from us. In particular, we use your Behavioural Data to provide you with programme recommendations when you log into All 4. These are programmes that we think you will be interested in watching based on your viewing history.
3.2.2 We use your Account Data to contact you occasionally with service messages about All 4 and other products and services you have signed up for, for example to provide you with password reminders, where your account is due to expire or to contact you about content you have submitted to us. If you sign up to Core4, we will also use your contact details to contact you from time to time to ask you to participate in surveys to help us to improve our offerings.
3.2.3 We use your Voluntary Data to enable us to respond to queries, complaints or comments that you have and to make sure that these are appropriately dealt with, for example when you contact Viewer Enquiries. If Voluntary Data you provide includes any special categories of personal data (such as information about your health, race or religion), you must make sure before you provide this that you are happy for us to use that Voluntary Data for the purposes set out in this Privacy Policy.
3.3 Competitions and surveys
3.3.1 We use Competition Data for the purposes of allowing you to participate in competitions and to carry out any activities required in relation to those competitions, for example contacting you to let you know you have won a prize and using your address to send your prize to you.
3.3.2 We use Survey Data for the purposes of analysing insights and information to enable us to improve our services.
3.4 Improving our services
3.4.1 We use Account Data, Behavioural Data, Voluntary Data and Survey Data to help us monitor, analyse and improve All 4. We use this data to help us understand which content and services are most interesting and enjoyable for our users and to help us identify errors and test features. This helps us to make sure that we are providing you with the best possible products and services.
3.5 Marketing and advertising
3.5.1 We use Account Data, Behavioural Data, Survey Data and Third Party Data for marketing and advertising purposes. This can include sending you personalised advertisements that use your first name in the advertisement. For more information on the ways in which we do this, please see How do we use your data for marketing and advertising purposes? below.
3.6 Profiling
3.6.1 We use and combine all the data that we hold about you in order to build up a picture of you and the types of products and services which might be of interest to you (your Profile). We will use your Profile to provide you with a more customised and tailored experience on our All 4 platform and to inform the advertising that is displayed to you. This makes sure that you see advertisements (including personalised advertisements) that are relevant and interesting to you. If you opt out of targeted advertising, you will still see advertising on All 4, but this will not be specifically tailored to you. For more detail about this, please see How do we use your data for marketing and advertising purposes? below.
3.7 Research panels – Core4, UK Tribes, Your4 and Toluna
3.7.1 We use a number of research panels to conduct market research for us which may involve collecting personal data for the purposes of carrying out this research. This collection of personal data will be subject to separate privacy policies. The information that is provided to us by the research panels is usually provided on an anonymous basis.
3.7.2 We use the data from these panels to:
(a) enable us to assess our performance and to improve our products and services including advertising;
(b) inform our marketing and promotional activities;
(c) inform and support our advertising partners;
3.8 enable us to notify you and provide you with any prizes you have won if you enter any prize draws.
3.9 Archiving
3.9.1 Channel 4 captures a copy of the www.Channel4.com website annually to archive data that may be of historical or statistical value and to use this data in the future for internal purposes or to allow third parties access to this data for research purposes, for example if someone is writing a book and the data we hold in our archives is useful for that book. Occasionally this may include copies of Voluntary Data that you have provided on public areas of the platform. We will only ever capture personal data that has already been made publicly available in this way and for these purposes. Where possible, when the sites are archived we anonymise or remove personal data.
3.9.2 We periodically review the data that we keep in our archive and we will delete or anonymise your data held in the archive where we consider it is no longer of value or interest.
3.10 How we use anonymised data
3.10.1 We use aggregated and anonymised data for certain purposes, such as to help us understand what type of content users like and to share with advertisers so that they know how effective their advertising is. When used for these purposes, this data does not enable you or any other individual user to be identified.
4 How do we use your data for marketing and advertising purposes?
4.1 At Channel 4, our programming is entirely funded by advertising revenue. Marketing and advertising are therefore key parts of our activities. This section sets out the various different types of marketing and advertising that we carry out and how your data is used for each type of activity.
4.2 Email marketing
4.2.1 We will use your email address to send you email marketing (including our newsletter, information about new shows, rewards and competitions) where you have signed up to receive this from us.
4.2.2 You can opt out of receiving marketing emails at any time by either following the instructions to unsubscribe in any of our email marketing communications or by changing your preferences in the "My Communications" section of your Account Settings. It may take up to 48 hours for your change in preference to take effect and the change will not affect any marketing emails which have already been scheduled to be sent in the future.
4.2.3 If you opt out of email marketing, we will still need to send you service communications by email from time to time, such as information about changes to our services.
4.3 Personalised advertising
4.3.1 We sometimes use your name to personalise advertisements that you see on the All 4 platform. This means that you may hear your first name in an audio/video advertisement or see your first name in a text advertisement.
4.3.2 If you have opted out of targeted advertising the advertisements you see will not be tailored to you, but they may still be personalised with your name.
4.3.3 You can opt out of personalised advertising at any time by changing your preferences in the "Privacy settings" section of your Account Settings. It can take up to 72 hours for the change to take effect. Some advertising campaigns are also set up to run for a particular time and we are unable to change these settings once they are set up. If that is the case, we will make sure that you are opted out of future campaigns, but you may continue to see advertising relating to a particular campaign if the campaign is ongoing at the time you have opted out.
4.3.4 If you opt out of personalised advertisements without opting out of targeted advertising, you will still see targeted advertisements on All 4 but they will not be personalised with your name.
4.4 Data pairing
4.4.1 We carry out "data pairing" to help us to build a better picture of you and enable your advertising experience on All4 to be as tailored and relevant to you as possible.
4.4.2 To carry out this data pairing exercise, we use reputable third party data pairing providers such as Acxiom. Those data pairing providers obtain personal data about you from publicly available sources and from other third parties who share your personal data on the basis of their legitimate interests or with your consent, in accordance with their own privacy policies and practices. We carry out vetting and ongoing monitoring of those data pairing providers to ensure that they comply with their data protection obligations and keep personal data secure.
Data pairing providers are vetted by us to ensure they comply with all their data protection obligations, keep your personal data secure and protect your personal data appropriately. A written agreement is in place with any data pairing providers we use and we regularly monitor their activities to ensure they are complying with our security requirements.
4.4.3 Data pairing works by sharing the personal data we hold about you with data pairing providers so that they can combine that with personal data that they hold about you. If there is a match, we collect and store additional Third Party Data (including, for example, information about your lifestyle and interests) and we use this to ensure that we serve you advertisements which are relevant to your interests.
An example of this is that we might take a list of users who regularly watch a particular programme and send this to data pairing provider Acxiom to match with Acxiom's own records. If Acxiom finds a match, Acxiom provides us with additional information about you, such as lifestyle and demographic information, which enables us to build a better picture of you and make your advertising experience more relevant to you by deciding what advertisements we think you will be most interested in. Another example is that we might ask Acxiom to match our customer database with the customer database of another Acxiom client. For example, if one of our advertisers wants to target advertisements through All 4 to customers in a particular region, Acxiom will match that advertiser's customer database with our own customer database and give us a list of everyone who is a customer of both us and the advertiser who is based in that region. We can then make sure that the advertisements are served to the appropriate customers.
For more information on Acxiom and the data it provides to companies like Channel 4, please visit https://www.acxiom.co.uk/about-acxiom/privacy/uk-privacy-policy/
4.4.4 You can opt out of data pairing at any time by changing your preferences in the "Privacy settings" section of your Account Settings. It can take up to 72 hours for the change to take effect. If you opt out of data pairing, this means that your personal data held by us will no longer be combined with data held by data pairing providers. However, unless you also opt out of targeted advertisements, we will still use your data to target advertisements to you in accordance with the section headed Targeted advertisements below. This targeting will be based on your Account Data.
4.5 Targeted advertisements on All 4
4.5.1 If we build a Profile about you (as set out under the section called Profiling) above, we will use this Profile to predict what products and services you will be interested in and to target advertisements for these types of products and services to you through All 4. These could be our own products and services or those of third party advertisers who have asked us to send their advertisements to certain categories of recipients.
4.5.2 In relation to advertisements for third party advertisers, when an advertiser is trying to reach a specific target audience, we may create target audiences for these advertisers, such as how many people of a particular age range (e.g. 16-34 year olds) or in a particular interest group (e.g. DIY enthusiasts). However these audiences are not shared with the advertiser in a way that enables individuals to be identified. We also tell our advertisers how many people in that audience have seen their specific advertisements and we provide them with your IP address so they can check that our viewing count is accurate. This enables those advertisers to assess the effectiveness of their advertising. We may also share “pseudonymised” versions of your personal data with those advertisers in order to help them carry out the targeting of advertisements on Channel 4’s platforms. “Pseudonymisation” means that the relevant data will be changed from personal identifiable data to a coded version of that data. For example, we create anonymous temporary advertiser IDs for our users that we share with advertisers so they can cap the number of times you see a particular advertisement: however advertisers are not able to identify you from these IDs.
4.5.3 You can opt out of targeted advertisements at any time by changing your preferences in the "Privacy settings" section of your Account Settings. It can take up to 72 hours for the change to take effect.
4.5.4 We and other third parties also use cookies to assist in targeted advertising. You can find out more about this, including how to opt out of targeted advertising using cookies, in our Cookies Policy (http://www.channel4.com/4viewers/cookies).
4.6 Promoting our own services on other platforms
4.6.1 We also promote our own content and features via third party platforms, such as social media sites.
4.6.2 This usually works by us sending a hashed or encrypted identifier to the third party platform which is then matched to that third party's records in order to identify whether you are also a user of the third party's platform. If you are identified as a user, this allows us to send you promotions for Channel 4 content and features that we think you will be interested in via your homepage or profile on that platform.
4.6.3 You can opt out of receiving this type of promotion at any time by changing your preferences in the "Privacy settings" section of your Account Settings. We will process this request as quickly as possible but you might continue to see our promoted messages whilst your instruction is being administered.
4.6.4 Our content might appear on third party sites based solely on your behaviours on these sites (for example, after liking our brand or its content on Facebook), or the behaviours of those within your networks (for example, a friend within your Facebook network likes our brand or its content on Facebook, so it appears in your News Feed). These branded messages are controlled by the third party site, but you may be able to update your preferences to stop these messages appearing in future (for example, you can customise your News Feed in Facebook via ‘News Feed Preferences’).
4.7 Third party advertising
4.7.1 Sometimes we will also share your Profile, or part of it, with reputable third parties such as other broadcasters to help them to target their own advertising on their own platforms. This helps to ensure that those third parties have as full a picture of you as possible and they can therefore target relevant advertisements to you on their own platforms that you will find interesting and helpful.
4.7.2 This data pairing applies where you have also shared your personal data with that third party in the course of using their service. The broadcaster then shares your data with us, and we combine it with any personal data we hold about you. If there is a match, we pass the broadcaster the information we hold about you, for example information about your lifestyle, interests and viewing habits. The broadcasters use this information to show you advertisements that are relevant to your interests.
4.7.3 Those third parties will be responsible for how they use the data that we share with them and how they advertise to you using that data.
4.8 Push notifications
4.8.1 If you download the All4 app, some of the communications that we send to you, including marketing communications, content recommendations and information about new content or features, may be sent by push notification. Push notifications are messages that pop up on your mobile device. You can choose whether or not to receive push notifications from the All4 app through your device settings.
4.8.2 If you use an Android device, your device will automatically opt you in for push notifications and you will need to turn these off if you don't want to receive them. If you use an Apple device, you will be asked when you set up your device if you want to receive push notifications and you can choose to receive them then. If you change your mind, you can change your preferences at any time in your device settings.
4.9 Preference centre and opting out
4.9.1 You can manage your advertising preferences at any time through the "My communications" and "Privacy settings" sections of your Account Settings. These sections enable you to choose the electronic marketing and advertising you are happy to receive.
4.9.2 We will always respect your preferences but please note that it can take up to 72 hours for changes to your preferences to take effect. This may mean that you see some advertising that you have opted out of for a short time after opting out. Some advertising campaigns are also set up to run for a particular time and we are unable to change these settings once they are set up. If that is the case, we will make sure that you are opted out of future campaigns, but you may continue to see advertising relating to a particular campaign if the campaign is ongoing at the time you have opted out.
4.9.3 Even if you opt out of all marketing and personalised/targeted advertising above, we will still display advertisements on All 4. These advertisements will not be in any way personalised or targeted to you and your personal data will not be used to serve these advertisements. They will be standard advertisements that will be served to every user who has opted out of personalisation and targeting of advertisements.
4.9.4 If you want to opt out of receiving push notifications, you need to do this through your device settings. Please see the section headed Push notifications above for more information.
5 What is our legal basis for using your data?
5.1 Data protection law says that we have to tell you the legal basis that we rely on to process your personal data for the purposes that we have notified to you. This section tells you what that legal basis is in relation to each of the purposes set out above.
5.2 With the exception of email marketing, we process your personal data for all of the purposes identified under What do we use your data for? and How do we use your data for marketing and advertising purposes? above on the basis that it is in our legitimate interests, or the legitimate interests of third parties with whom we share your data, to carry out these activities. Further information about what those interests are is set out below.
Purpose: Running your account and providing you with our services
Legitimate interests: To ensure that All 4 users enjoy the best experience possible, to help us deliver our remit as a public service broadcaster and to lead to increased viewing and therefore increased funding for our programming content.
Purpose: Improving our services
Legitimate interests: To make sure that we continue to improve our service and provide our users with the best and most effective service possible.
Purpose: Advertising
Legitimate interests: To provide advertising that is relevant to you to ensure that you have the best experience possible of using All 4 or third party broadcasters' platforms, as well as to generate more advertising revenue so that we can put more funding back into the free services we are able to provide to you.
Purpose: Profiling
Legitimate interests: To provide a customised experience of our All 4 platform to ensure you have the best experience possible of using All 4, as well as to generate more advertising revenue which in turn allows us to put more funding back into the free services we are able to provide to you. Where we use profiling to assist other broadcasters to target their advertising, we do this on the basis of the third party broadcasters' legitimate interests in ensuring they can deliver appropriate, relevant and effective advertising on their platforms.
5.3 You have the right to object to us processing your personal data for the purposes set out above. Unless we can show that we have a compelling legitimate reason to continue processing your personal data, we will stop processing it. Remember that you can delete your account at any time in which case we will fully anonymise your personal data.
5.4 In respect of the use of your email address for email marketing purposes, we process this on the basis that we have your consent to do so. You can withdraw your consent at any time by following the instructions to "unsubscribe" in any email marketing communications.
6 How do we use data collected through our 4sales and press websites?
6.1 As well as the collection and use of personal data set out above, we also collect data through our 4sales website (www.4sales.com) and our press and information website (www.channel4.com/info/press/press-packs). The information that we collect through these sites is primarily business information which does not identify a particular individual. However, we will collect some personal data about individual users who sign up to these areas of our platforms, such as individual journalists or employees at companies who sign up for sales information.
6.2 The personal data we collect through our sales website will be limited to your full name, email address, job title, company name and your email preferences. We will use this data to manage and administer your account and to send you the sales information that you request.
6.3 The personal data we collect when you sign up to the press and information website will be the same as the Account Data described above, plus your press credentials. We will use this data to manage and administer your account and to send you press packs and daily alerts and updates that you request. You can sign up for daily alerts without having an account. If you do this, we collect your first name, surname, email address, job title and company name.
6.4 We process this personal data on the basis that we have a legitimate business interest in ensuring that we communicate effectively with actual and potential sponsors and advertisers and with the press. This ensures that we can continue to generate sufficient revenue to fund our programming activities.
7 Freedom of information
7.1 We are required under the Freedom of Information Act 2000 to provide certain information in response to Freedom of Information requests. You can make a request by emailing FOIAdmin@Channel4.co.uk or by using our request form (https://www.channel4.com/corporate/about-4/operating-responsibly/freedom-information/freedom-of-information-request-form). In order to respond to requests, we will need to collect your name, address, email address, phone number and information about your request, including any additional personal data you choose to share with us when you make your request. We will use this personal data to respond to your request and will retain it for administrative purposes in line with the section headed How long do we keep your data for? below.
7.2 For more information about Freedom of Information, please see here.
8 Google Home
8.1 If you use Google Home, you can link your Google account to your All 4 account to log you into your All 4 account, enable you to use voice control to play All 4 content on compatible devices or to ask for information about All 4. If you do this, an authentication token will be generated. This authentication token is shared with Google to enable us to identify your account when you use voice control to control All 4 via Google Home.
8.2 When you use voice control to control All 4 playback (for example, by saying "OK Google, play Hollyoaks on All 4") or to ask for information about All 4, this instruction is made directly to Google and is subject to Google's own privacy policy. Your voice instruction will initiate a playback request which tells us what you want us to do (for example, play Hollyoaks on your account). Google will share the playback request with us, together with your authentication token and a transcription of your voice instruction that initiated the playback request, so that we can action your playback request (for example, by playing Hollyoaks on your All 4 account). We will keep records of your voice instructions that relate to All 4 and will use these for the purposes set out in this Privacy Policy.
8.3 If you decide to unlink your All 4 account and your Google account, Google will delete the authentication token associated with your account and no further data will be shared between us and Google unless you decide to link your accounts again. Google will retain records of voice instructions you have issued in relation to All 4 as part of your history and in accordance with Google's own privacy policy. We will also retain copies of the playback requests and transcriptions of voice instructions in accordance with the section headed How long do we keep your data for? below.
9 Who do we share your data with?
9.1 We do need to share your personal data with some third parties in some circumstances. This includes where we use third party suppliers to perform various services for us. The third party suppliers we share your personal data with are as follows:
9.1.1 third party service providers who help us to manage our customer database and registration process;
9.1.2 third party service providers who help us to manage our Viewer Enquiries process;
9.1.3 other service providers such as information security service providers who help us to manage our IT systems and ensure that they are secure; and
9.1.4 third party marketing and advertising agencies to ensure our marketing and advertising is delivered effectively in accordance with this Privacy Policy.
9.2 We will share your personal data with the following categories of recipients for the following purposes:
9.2.1 third party data pairing providers for the purposes of the data pairing exercise described under the section headed Data pairing above;
9.2.2 third party platforms to enable us to send you recommendations for our content and services through those platforms, as described in the section headed Promoting our own services on other platforms above;
9.2.3 third party media agencies, in which case data will be shared in a pseudonymised form as described in the section headed Targeted advertising on All4 above; and
9.2.4 other broadcasters and publishers where we act as advertising sales agent on their behalf to enable us to target and serve advertisements for those broadcasters and publishers.
9.3 We will also share your personal data with third parties in the following circumstances:
9.3.1 where you have specifically consented to us sharing your data with a particular third party; and
9.3.2 where we are required or permitted to do so by law or to protect or enforce our rights or the rights of any third party.
9.4 Except as stated in paragraph 9.5, we do not transfer or store your personal data outside the European Economic Area (EEA). If we do carry out any further transfers of your data outside the EEA, we will inform you and we will ensure that the recipient provides an adequate level of protection of your personal data.
9.5 If you use Google Home features with your All 4 account, Google will store the data that we share with Google in the USA. Google is certified with Privacy Shield, which means that Google provides a level of protection of your personal data that is deemed adequate by the European Commission. More information about Privacy Shield and Google's certification can be found here https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
9.6 You should also be aware that if you choose to share All 4 content on social media via the Facebook and Twitter share buttons on All 4, the relevant social media platform will know what page you are on in order to share that page. The use of that information will be governed by the social media platform's own privacy policy and clicking the "share" buttons does not result in any other personal data being shared between All 4 and the platform.
10 How long do we keep your data for?
10.1 We will keep all your personal data for as long as your All 4 account remains open. You can close your account at any time using the "Close account" section of your Account Settings. If you do this, we will anonymise all your Account Data as soon as we can after you have closed your account. All other information about you, such as Behavioural Data, will also be fully anonymised.
10.2 If your account is inactive for a period of two years, we will send you a reminder email to remind you to use your account. If you still do not use your account, we will send a further reminder email before deleting your account and anonymising your personal data as set out above.
10.3 We may need to keep your data after account closure for limited purposes, for example if we need your data in order to respond to any complaints or claims that you make. If this is the case, we will only keep the data for as long as we need to in order to fulfil those purposes.
10.4 We keep information relating to any service errors or interruptions you have experienced for between 15-30 days.
10.5 Any Voluntary Data you submit to our Viewer Enquiries team will be retained for a period of two years from submission, after which it is anonymised.
11 What rights do you have?
11.1 You have a number of rights under data protection law. These rights and how you can exercise them are set out in this section. We will normally need to ask you for proof of your identity before we can respond to a request to exercise any of the rights in this section and we may need to ask you for more information, for example to help us to locate the personal data that your request relates to.
11.2 We will respond to any requests to exercise your rights as soon as we can and in any event within one month of receiving your request and any necessary proof of identity or further information. If your request is particularly difficult or complex, or if you have made a large volume of requests, we may take up to three months to respond. If this is the case we will let you know as soon as we can and explain why we need to take longer to respond.
11.3 A right to access your information
11.3.1 You can access all of your Account Data through the "Personal details" section of your Account Settings.
11.3.2 You also have a right to ask us to send you a copy of your Account Data and all other personal data that we hold about you (subject to some exceptions). A request to exercise this right is called a "subject access request" and must be made in writing to: dataprotection@channel4.co.uk or to: Data Protection Officer, Channel 4 Enquiries, PO Box 1058, Belfast, BT1 9DU.
11.4 A right to object to us processing your information
11.4.1 You have a right to object to us processing any personal data that we process where we are relying on legitimate interests as the legal basis of our processing. This includes all of your personal data that we process for all of the purposes set out in this Privacy Policy, with the exception of our use of your email address to send you marketing communications with your consent (but you can withdraw your consent to this at any time).
11.4.2 If we have compelling legitimate grounds to carry on processing your personal data, we will be able to continue to do so. Otherwise, we will cease processing your personal data.
11.4.3 You can exercise this right by emailing dataprotection@channel4.co.uk.
11.4.4 Remember that you can always delete your account at any time through the "Close account" section of your Account Settings.
11.5 A right to ask us not to market to you
11.5.1 You can ask us not to send you direct marketing or advertising. You can do this by opting out of the advertising you no longer want to receive in the "My communications" and "Privacy settings" sections of your Account Settings. In relation to email marketing, you can also opt out by using the "unsubscribe" option in any of our email marketing communications.
11.5.2 Please note that it can take a short time for opt-out requests to take effect. The time taken to opt out of each type of marketing and advertising is detailed at How do we use your data for marketing and advertising purposes? above.
11.5.3 More information about opting out of marketing and advertising is provided at How do we use your data for marketing and advertising purposes? above.
11.6 A right to have inaccurate data corrected
11.6.1 You have a right to ask us to correct inaccurate data that we hold about you. If we are satisfied that the new data you have provided is accurate, we will correct your personal data as soon as possible.
11.6.2 You can update your own personal data at any time through your Account Settings. The only personal data you cannot change directly through your Account Settings is your date of birth, which can be updated by contacting Viewer Enquiries (https://www.channel4.com/contact)
11.7 A right to have your data erased
11.7.1 You have a right to ask us to delete your personal data in certain circumstances, for example if we have processed your data unlawfully or if we no longer need the data for the purposes set out in this Privacy Policy.
11.7.2 We will fully anonymise any personal data we hold about you when you close your account, as set out under How long do we keep your data for? above. This means that it will no longer identify you and ceases to be “personal data”.
11.7.3 If you ask us to delete your personal data and you are happy for your account to be closed, we will close your account and fully anonymise your personal data as set out above. If you ask us to delete your personal data but you do not want your account closed, we may not be able or obliged to comply with this as we will usually need to keep processing your data in a personally identifiable form to keep your account open.
11.7.4 If you would like to make a request to exercise this right, please contact Viewer Enquiries www.channel4.com/contact. If we are required by law to comply with your request, we will fully anonymise your data it so that it is no longer personal data and cannot be used to identify you.
11.8 A right to have processing of your data restricted
11.8.1 You can ask us to restrict processing of your personal data in some circumstances, for example if you think the personal data is inaccurate and we need to verify its accuracy, or if we no longer need the data but you require us to keep it so that you can exercise your own legal rights.
11.8.2 Restricting your personal data means that we only store your personal data and don't carry out any further processing on it unless you consent or we need to process the data to exercise a legal claim or to protect a third party or the public.
12 How can you contact us?
12.1 If you have any questions or concerns about this Privacy Policy and/or our processing of your personal data, you can get in touch with our Data Protection Officer using: dataprotection@channel4.co.uk.
13 What if you have a complaint?
13.1 You have a right to complain to the Information Commissioner's Officer (ICO), which regulates data protection compliance in the UK, if you are unhappy with how we have processed your personal data.
13.2 You can find out how to do this by visiting https://ico.org.uk/
14 What if this policy changes?
14.1 We may make changes to this Privacy Policy from time to time. Any changes we make will be posted on this page. We may also notify you by email if significant changes are made.
Policy updated on 25 May 2018
(You may find it easier to read these documents on your computer. Please go to: https://www.Channel4.com/4viewers/our-policies)
CHANNEL 4 COOKIES POLICY
This policy applies on and from 25 May 2018.
Whenever you use our Channel 4 websites, the 4sales.com site, any related programme microsites, mobile sites, mobile applications or applications on any other devices such as your games console or Smart TV (our “Services”), information may be collected through the use of cookies and similar technologies.
By using our Services, you agree to our use of cookies and other similar technologies as described in this Cookie Policy.
WHAT ARE 'COOKIES'?
Cookies are small text files which are downloaded to your computer or mobile device when you visit a website or application. Your web browser (such as Internet Explorer, Mozilla Firefox or Google Chrome) then sends these cookies back to the website or application on each subsequent visit so that they can recognise you and remember things like personalised details or user preferences.
Cookies are very useful and do lots of different jobs which help to make your experience on websites as smooth as possible. For example, they let you move between web pages efficiently, remembering your preferences, and generally improving your experience (see below for more examples). They can also help to ensure that adverts you see online are more relevant to you and your interests.
They are referred to as session or persistent cookies, depending on how long they are used:
• Session cookies only last for your online session and disappear from your computer or device when you close your browser.
• Persistent cookies stay on your computer or device after the browser has been closed and last for the period of time specified in the cookie. These persistent cookies are activated each time you visit the site where the cookie was generated.
WHAT DO WE MEAN BY "SIMILAR TECHNOLOGIES"?
We also use something called "local storage", which is a technology that is similar to cookies and performs very similar functions, such as caching data to enable us to improve our websites/apps, allowing you to register as an All 4 user, tracking activity to enable us and our advertisers to advertise to you in accordance with this policy and counting the number of people who view programmes/adverts on our platforms. Like cookies, local storage will either be for a session or persistent.
Local storage is often used as an alternative to cookies on devices which you use to access and use our Services. The devices that we use local storage on are:
Amazon Fire devices, Android devices, Apple iOS devices, Chromecast, Freeview Play, Now TV, Playstation 3, Playstation 4, Roku, Samsung, Windows 8 & 10, Xbox 360, Xbox One, Yourview.
Where we refer to “cookies” in this policy, we mean cookies or similar technologies.
WHICH COOKIES DOES CHANNEL 4 USE AND WHY?
When you use one of our Services such as All 4, either on a web browser or a device, the following 4 categories of cookies may be set:
1. ‘Strictly necessary' cookies
These cookies are essential in helping you to move around our website and app and to use their features, such as accessing secure areas of the website. Without these cookies, services you have asked for, such as setting up PIN protection on All 4, cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you've been on the internet.
Some examples of these essential cookies include:
• Identifying you as being signed in to All 4 or other services and keeping you logged in throughout your visit so that you don't need to sign in each and every time you visit.
• Remembering security settings, such as parental PIN control, which restrict access to certain content.
• Remembering settings across different devices (e.g. synching preferences you set on All 4 with your Xbox 360, if you use All 4 on your Xbox 360).
• Establishing links between your account and your device, for example if you link your All 4 registered account to an Apple device, a file containing information establishing this link will be stored.
• Tracking what content has been viewed so that we can count the number of views and pay the owners of the rights in that content accordingly.
2. Functional cookies
These cookies allow websites and applications to remember choices you make and provide enhanced, more personal features. They can also help us to display our advertisements and control how often an advertisement is shown to you, how long it is shown for and how often it will appear (these are commonly known as "ad-serving" or "ad delivery" cookies). Whilst these cookies don't collect things like your name or email address, they do collect a unique user identifier code. This enables us to identify your device so that we can improve your experience and make sure your settings are remembered correctly.
Some examples of how we do this include:
• Remembering your preferences and settings such as our “my list” setting, or your preferred volume setting.
• Remembering your place in a video if you leave any of the viewing services before you've finished watching a programme, so that you can pick up where you left off the next time.
• Remembering if we've already asked you if you want to fill in a survey or if you've completed a survey, so you're not asked to do it again.
• Remembering if you've been to the site before so that messages intended for first-time users are not displayed to you.
• Restricting the number of times you're shown a particular advertisement. This is sometimes called ‘frequency capping'.
• Working out when to show you advertisements on any of the viewing services so that you don't get shown too many.
• Making sure you get shown advertisements that are part of a sequence in the correct order.
3. Analytics cookies
In order to keep our Services relevant, easy to use and up-to-date, we use web analytics services to help us understand how people use them. For example, we can see which parts of All 4 are most popular, identify which programmes have been watched online, identify when errors occur, and test different versions of a page or feature to see which one works best. Web analytics services use cookies to recognise your browser or device and, for example, identify whether you have visited All 4 before and what you have previously viewed or clicked on. This allows us to track information, such as how many individual users we have and how often they visit All 4. It also helps us to analyse patterns of user activity and to develop a better user experience. For example, we might see that many people who viewed Programme A also viewed Programme B and we can then recommend Programme B to everyone else who viewed Programme A.
Again, these cookies do not identify you directly as they do not collect information such as your name or email address. However, the information collected by these cookies will be linked to a unique user identifier code. This is a random sequence of numbers and letters which we can use to link information collected by the cookies back to you without the cookies collecting your name or email address. This allows us to use the information collected by the cookies to understand more about your viewing habits and your interests so that we can make our advertising and marketing more relevant to you.
For example, one of these cookies might tell us that you have previously watched a programme about food and this may be used to decide to show you advertisements for other programmes about food, or a later series of the same programme. You can find out more about our advertising and marketing in our Privacy Policy.
The Broadcasters Audience Research Board (BARB), which is an independent body which provides the TV industry with viewing data, has worked with broadcasters including Channel 4 to add a bit of code to All 4. This code counts all of the All 4 programmes and adverts that people watch via their internet connection, across TVs, laptops, PCs, tablets and mobile phones. The code does not collect any data which enables individual viewers to be identified. This anonymous All 4 viewing data is passed from Channel 4 to a research agency called Kantar (acting on behalf of BARB) and includes what programme or advert has been watched, at what time, for how long and on what type of device. These figures do not contain any information on who is watching or any other personally identifiable information, and do not relate to any other activities apart from All 4 viewing. It is solely used by BARB to calculate the total amount of people who watched a programme or advert. You can opt out of this collection of non-personal data for programme and advertisement measurement purposes by requesting that the Kantar cookie (the small bit of code) is not captured.
4. Third party cookies
All the cookies described so far in this policy are "first party cookies", which means they are set and controlled by Channel 4. Occasionally, third parties may set cookies on our Services which Channel 4 does not control. These are called "third party cookies". This may happen in the following circumstances:
• Advertisement impressions: We work with advertisers to help them make sure that their advertisements are served to people who will find them relevant and interesting. For example, if an advertiser wants to advertise a car, we use information we hold about you and your viewing habits (including the information collected by analytics cookies as detailed above) to decide if you are likely to be interested in an advertisement for a car and, if so, to serve that advertisement for you. More information about this is set out in our Privacy Policy. We do not allow our advertisers to set their own cookies for the purposes of tracking you or advertising to you directly. However, our advertisers will set a cookie which counts the number of times their advertisements have been viewed, to make sure that their advertisements are reaching enough people. This is so they can verify that the view count that we give them is correct.
• Embedded content: On some pages of our websites (for example sites that are specific to one of our programmes, like f1.channel4.com) we may include embedded content, for example from YouTube. When you visit a page with embedded content, the service provider (for example, YouTube) may set its own cookies on your web browser to track the success of their application or to customise their application to you.
Channel 4 does not control the use of these cookies and cannot access them, as cookies can only be accessed by the party who originally set them. You should check the third party websites for more information about these cookies.
HOW TO CONTROL YOUR COOKIES
There are various ways that you can control and manage your cookies which are discussed in a bit more detail below. Please remember that any settings you change will not just affect Channel 4 cookies. These changes will apply to all websites that you visit (unless you choose to block cookies from particular sites). The settings you change will also only apply to the device on which you change them and will not apply across all your devices. If you want to opt out of cookies on all your devices, you will need to change the settings on all your devices individually.
Managing cookies in your browser
Most modern browsers will allow you to:
• See what cookies you've got and delete them on an individual basis.
• Block third party cookies.
• Block all cookies from being set.
• Delete all cookies when you close your browser.
You should be aware that any preferences will be lost if you delete all cookies. Ironically, this includes where you have opted out from cookies, as this requires an opt-out cookie to be set. This means that if you opt out from cookies and then delete all cookies, your opt out will not be saved and you will need to opt out again (which will store a strictly necessary cookie so that your device can remember that you have opted out).
If you block cookies completely, many websites will not work properly and some functionality on these websites will not work at all. We do not recommend turning cookies off when using our Services for these reasons.
The links below take you to the ‘Help' sections for each of the major browsers so that you can find out more about how to manage your cookies.
Google Chrome
http://support.google.com/chrome/bin/answer.py?hl=en&answer=95647
Firefox
http://support.mozilla.org/en-US/kb/Cookies
Safari
https://support.apple.com/kb/PH21411?locale=en_GB
Safari iOS
https://support.apple.com/en-us/HT201265
Android
http://support.google.com/chrome/answer/2392971?hl=en-GB
Internet Explorer
http://support.microsoft.com/kb/
We have set out links below to some of our specific functional cookies with information about what they can do and how you can opt out of them being set:
Freewheel
We use Freewheel cookies to help us with some of the advertisement delivery functionalities described in the "Functional Cookies" section above, for example frequency capping and displaying our advertisements.
http://www.freewheel.tv/privacy/
Please note that whilst this will opt you out of the Freewheel cookies, we still use Freewheel to serve you personalised advertisements on All 4 in accordance with our Privacy Policy. To opt out of these personalised advertisements, you will need to change your advertising preferences in your Account Settings.)
Innovid
Innovid cookies help us to make our advertisements interactive and also make sure that advertisements that are part of a sequence are shown in the correct order. We also use Innovid to count the number of views an advertisement has had.
http://www.innovid.com/privacy/
You can find out more about ad-serving cookies that are set on your device, and opt out of them, by visiting http://optout.aboutads.info.
Managing analytics cookies
It is possible to opt out of having your browsing activity recorded by analytics cookies. Channel 4 uses the following analytics providers and you can opt out of their cookies by clicking on the following links. Please note that this will take you to the relevant third party's website and generate a ‘no thanks' cookie, which will stop any further cookies being set by those third parties.
Don't forget that by not allowing analytics cookies, this stops us from being able to learn what people like or don't like about All 4 and our other Services, so that we can make them better.
Adobe
http://webstat.channel4.com/optout.html
Google Analytics
http://tools.google.com/dlpage/gaoptout
Optimizely
https://www.optimizely.com/legal/opt-out/
Kantar Media
http://optout.2cnt.net. Follow this link to opt out of having your anonymised activity collected for the purposes of measuring viewing data (see Analytics Cookies section above for more details). The link currently works only for desktop.
Managing cookies and similar technologies on devices
Please note that the local storage used on devices is essential to the operation of our Services on those devices and you cannot opt out of local storage being used on those devices.
Managing third party cookies
As detailed under the section headed "Third party cookies" above, we do not allow our advertising partners to set cookies through All 4 which enable them to track your activity themselves or to advertise to you directly. However, as noted above in the Third Party Cookies section, our advertisers do use impression tracking cookies to count the number of views each of their advertisements have had. We have set out links below to some of the impression tracking cookies that are used with instructions on how to opt out of their cookies.
Videology
https://videologygroup.com/en/privacy-policy/
Doubleclick
https://policies.google.com/technologies/ads
Flashtalking
http://www.flashtalking.com/privacypolicy/
Sizmek
https://www.sizmek.com/privacy-policy/optedout/#options
MORE INFORMATION
If you would like more information about our use of cookies, please contact us using the Contact Form on our website, which can be found here: www.channel4.com/contact
Last Updated 25 May 2018