The Circle – Privacy Policy 

12 September 2018

The Circle TV App – Privacy and Cookie Policy 

1. Who is in control? 

At Channel 4, we are committed to keeping your data safe and secure and handling it in accordance with our obligations under the Data Protection Act 2018 and GDPR. 
This privacy policy applies to the collection and use of your personal information by us and our third party technology partners when you download and use The Circle TV App. All personal information that we process on you will be kept secure and only used in accordance with this privacy policy or your permission. Please see our full here: http://www.channel4.com/4viewers/privacy for more detail about how Channel 4 handles your personal information.
We have appointed a Data Protection Officer (DPO) who has ultimate responsibility for making sure your data is treated in accordance with this privacy policy. Our DPO can be contacted by emailing dataprotection@channel4.co.uk.
By accessing and continuing to use The Circle TV App, you accept that your personal information is being used in accordance with this Privacy Policy. Please note that we may update and amend the Privacy Policy from time to time and any changes will be posted on this page. If you do not agree with any of our Privacy Policy then you should not use The Circle TV App.

2. What personal data do we collect from you and why?

The Circle TV App allows you to see and react to exclusive content relating to the show and you can also vote and take part in polls relating to the show.
In order to vote on iOS devices, you must make an in app purchase for £0.00 to enable the App to validate your device info with Apple as part of the vote registration process. This generates a unique user ID that is used by our voting technology partner, Tectonic, when you vote or take part in polls using The Circle TV App. A similar process occurs with Android devices, only you won’t need to make an in-app purchase when completing the vote registration process.
The Circle TV App collects the following information about your Apple or Android device which is not personally identifiable:

  • iOS identifierForVendor;
  • The receipt ID from an iOS In-App Purchase;
  • Android Device ID; and
  • A unique anonymous number from the Google Play download licence.

The Circle TV App also collects your IP address in order for our third party voting technology provider to monitor the integrity of the vote and prevent excessive votes from a single IP address. This information is encrypted and stored in a database by our voting partner and is deleted after 6 months.

3. What cookies / metrics do we use in The Circle TV App?

The Circle TV App contains analytics software, provided by Google Analytics, that allows us to collect anonymous statistical information about how the app is used e.g. the number of times the app has been accessed and things like that. This provides us with useful information so that we can improve and update both The Circle TV App and any other apps we create. These metrics will be associated with a completely anonymous unique identifier generated for your device that is created when the metrics are first sent. This cannot be cross-referenced with any other information that can personally identify you. If your device is not connected to the Internet no data will be sent. The information is completely anonymous and is safe and secure and will never include any sensitive details. It is used only by us and the trusted partners we work with. By installing and using The Circle TV App, you hereby confirm that you consent to us collecting and using this anonymous statistical information. 
The Circle TV App also stores information locally on your device; this is used to facilitate the general working of the App and remember when you have “liked” content within The Circle TV App. The Circle TV App does not store any information or browsing behaviour for the purpose of targeted advertising.

4. Do we use push notifications?

When you download The Circle TV App, a completely anonymous unique identifier generated for your device will be created and stored by Urban Airship on our behalf. This unique identifier will track how you use the App so that if you choose to receive push notifications in the App, this identifier will provide you with those push notifications that are appropriate to your use of the App. This is completely anonymous and cannot be cross-referenced with any other information that can personally identify you. It is used only by us and the trusted partners we work with. You can choose to unsubscribe from push notifications from us in your device's 'Notifications' screen, however you cannot prevent your device from sending anonymous metrics information to Urban Airship.

5. Who do we share your data with?

Your IP address and online identifiers are only seen by Tectonic, our voting technology partner and this information is not shared with anyone else.
Urban Airship also uses a unique device identifier in order to enable push notifications if you have this switched on on your device.
We also use Google Analytics to obtain metrics on your use of The Circle TV App (as described above).
We also reserve our rights, with or without notice to you, to disclose your personal information, (a) in response to a request by law enforcement, a court order or other legal process; or (b) if we believe that doing so may protect your safety or the safety of others.
The relevant App Store’s privacy policy and terms and conditions shall also apply in respect of any personal information you have supplied to that App Store to enable your download of the App and/or push notifications in respect of the App.

6. What is our legal basis for using your data? 

We process your personal data in The Circle TV App on the basis that it is in our legitimate interests to do so in order to provide you with the ability to vote and use The Circle TV App.

7. How long do we keep your data for?

Your IP address is stored in an encrypted database for 6 months and is then anonymised. Your unique device identifiers are also retained for 6 months.

8. What rights do you have in respect of your data?

You have various rights in respect of the personal data that we process on you, including the right of access to your personal data, the right to object to or restrict our processing of your data and the right to have your data erased. For further information about your rights, please refer to the full Channel 4 privacy policy here: http://www.channel4.com/4viewers/privacy.

9. How can you contact us?

If you have any questions or concerns about this privacy policy and/ or our processing of your data, you can get in touch with our Data Protection Officer using: dataprotection@channel4.co.uk.

10. What if you have a complaint?

You have a right to complain to the Information Commissioner’s Office, which regulates data protection compliance in the UK if you are unhappy with how we have processed your personal data.