MOBILE APPLICATIONS | PRIVACY NOTICE
Updated: 13 June 2018 – Version 2.0
This Privacy Notice covers your use of mobile applications (“Apps”) developed by BBC Studios Group (“BBCS”, “we”, “us” or “our”), a UK-based commercial subsidiary of the British Broadcasting Corporation, and sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
BBC Studios Group is the data controller of any personal data processed within the BBC Studios Group, including in relation to this App. Contact details for BBCS are shown at the end of this Privacy Notice.
Information we collect from you
During the course of providing you with Mobile App services, we will collect and process the following data about you:
Information you provide on a voluntary basis
This is information you give us about you by filling in forms on the App or by corresponding with us (for example, by e-mail or chat). It includes information you provide when you register to use the App, download or register an App, subscribe to any of our App services, share data via an App's social media functions, enter a competition, promotion or survey, sign up to receive marketing communications from us and when you report a problem with an App. If you contact us, we will keep a record of that correspondence. The information you give us may include your name, address, e-mail address and phone number, the device's phone number, age, username, password and other registration information, financial and credit card information.
Information we collect about you and your device
When you use an App, we may automatically collect the following information:
- technical information, including the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, mobile network information, your mobile operating system, the type of mobile browser you use and the time zone setting (“Device Information”);
- details of your use of any of our Apps including, but not limited to traffic data, weblogs and the resources that you access (“Log Information”).
BBCS Apps do not collect precise real-time location information about your device.
Purposes for which we will use your information
We may use your information for the following purposes:
Fulfilment of services
We collect and maintain personal information that you voluntarily submit to us during your use of the App to enable us to perform the services envisaged by the App.
What is our legal basis? It is necessary for us to process your information to perform our obligations in accordance with any contract that we may have with you in relation to the App. It is in our legitimate interest or a third party's legitimate interest to use your personal information in such a way to ensure that we provide the very best user service we can to you or others.
Business administration and legal compliance
We use your personal information for the following business administration and legal compliance purposes:
- to comply with our legal obligations;
- to enforce our legal rights;
- to protect the rights of third parties; and
- in connection with a business transaction such as a merger, or a restructuring, or sale.
What is our legal basis? Where we use your personal information in connection with a business transition, to enforce our legal rights, or to protect the rights of third parties it is in our or a third party's legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us.
User insight and analysis
By using this information, we are able to measure the effectiveness of our content and how visitors use our Apps. This allows us to learn what pages of our Apps are most attractive to our visitors, which parts of our Apps are the most interesting and what kind of offers our registered users like to see. We may also use this information for marketing purposes.
What is our legal basis? Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best products and services to you and our other users. Any other purposes for which we wish to use your personal information that are not listed above, or any other changes we propose to make to the existing purposes will be notified to you using your contact details, where available.
Who do we share your personal information with?
We share personal information with third parties who perform services on our behalf. These third parties are not authorised by us to use or disclose the information, except as necessary to perform services on our behalf or comply with legal requirements.
We may also share the personal information we obtain with our affiliates, subsidiaries and other group companies. If we share your personal information with such persons, we will ensure that an adequate level of protection is in place to protect your personal information in accordance with applicable law.
We may also disclose information about you in the following circumstances:
- if we are required to do so by law, regulation or legal process (such as a court order or subpoena) including lawful requests by public authorities to meet national security or law enforcement requirements;
- in response to requests by government agencies, such as law enforcement authorities;
- for the purpose of or in connection with legal proceedings, or otherwise for the purpose of establishing, exercising or defending our legal rights; or
- when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity.
We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganisation, dissolution or liquidation), but only where we have first taken reasonable steps to ensure the security and confidentiality of your information.
International data transfers
In order to provide our Apps, we may need to transfer your personal information to locations outside the jurisdiction in which you provide it. If you are based within the European Economic Area (EEA), please note that where necessary to deliver the App, this may involve the transfer of your personal information to countries outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring an appropriate safeguard is implemented.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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.
Users under 16 years of age
If you are under 16 years of age, you must have your parent/guardian’s permission before you provide us with any personal information.
How long we will store your information
We will hold your personal information on our systems for as long as is necessary for the relevant App service or as long as is set out in any relevant App contract you hold with us, in accordance with our retention policy. Where you contribute to one of our App services, we will generally only keep your content for as long as is reasonably required for the purpose(s) for which it was submitted. After this time, your personal information will either be securely deleted or anonymised so that it can be used for analytical purposes.
How to access your information and your other legal rights
You have the following rights in relation to the personal information we hold about you:
Your right of access
If you ask us, we'll confirm whether we're processing your personal information and, if necessary, provide you with a copy of that personal information (along with certain other details). You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
Your right to rectification
If the personal information we hold about you is inaccurate or incomplete, you are entitled to request to have it rectified. If you are entitled to rectification and if we've shared your personal information with others, we'll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we'll also tell you who we've shared your personal information with so that you can contact them directly.
Your right to erasure
You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If you are entitled to erasure and if we've shared your personal information with others, we'll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we'll also tell you who we've shared your personal information with so that you can contact them directly.
Your right to restrict processing
You can ask us to 'block' or suppress the processing of your personal information in certain circumstances, such as where you contest the accuracy of that personal information or you object to us. If you are entitled to restriction and if we've shared your personal information with others, we'll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we'll also tell you who we've shared your personal information with so that you can contact them directly.
Your right to data portability
You have the right, in certain circumstances, to obtain personal information you've provided us with (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
Your right to object
You can ask us to stop processing your personal information, and we will do so, if we are:
- relying on our own or someone else's legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
- processing your personal information for direct marketing purposes.
Your right to withdraw consent
If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Please note that some of these rights may be limited where we have an overriding interest or legal obligation to continue to process the data or where data may be exempt from disclosure due to reasons of legal professional privilege or professional secrecy obligations.
This App may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our App, we encourage you to read the Privacy Notice of every website, plug-in and application you visit.
Changes to this Privacy Notice Privacy Notice and your duty to inform us of changes
We may make changes to this Privacy Notice from time to time. To ensure that you are always aware of how we use your personal information we will update this Privacy Notice from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. Where it is practicable, we will notify you by email of any significant changes. However, we encourage you to review this Privacy Notice periodically to be informed of how we use your personal information.
How to contact us and your right to complain
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Privacy Notice. If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
If you have any questions or comments about this policy or our approach to privacy please contact us at:
Data Protection Officer
BBC Studios Limited
1 Television Centre, 4A
101 Wood Lane
We will do our very best to resolve any complaint. However, if you feel we have not resolved it you have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (https://ico.org.uk/)