Privacy Policy


BBC STUDIOS DISTRIBUTION | PRIVACY POLICY

Last updated: 28 September 2020

Whenever we provide you with our services or through your other interactions with us (for example via our social media platforms or through market research), BBC Studios Distribution may collect information about you and about your use of our services.  We are the “data controller” of this information, meaning we decide what your personal information is used for, and the ways in which it is processed.

We are committed to being transparent and fair in our handling of personal information and we will always endeavour to comply with best practice and applicable privacy and data protection laws in all the territories within which we operate. This policy describes the information we collect, how we use it, the circumstances in which it may be shared, and your rights in relation to the information we hold

  1. Who we are
  2.  Scope of this policy
  3.  Information we may collect
  4.  How we use your information
  5.  Sharing and disclosing your information
  6.  Where we will store and use your information
  7.  How long we will keep your information
  8.  Children using our services
  9.  How we secure your information
  10.  Your rights and choices
  11.  Changes to this policy
  12.  Contact Us
  13. Right to complain

If you have any questions or comments about this policy or our approach to privacy please contact us at: dataprotection@bbc.com. We aim to reply to any queries within three working days.

1.WHO WE ARE

BBC Studios Distribution is part of the BBC Studios group, the commercial production and distribution arm of the British Broadcasting Corporation (the ‘BBC’). The group brings together the majority of the BBC’s former in-house production departments (under ‘BBC Studios Productions’) and the international licensing and distribution business (under ‘BBC Studios Distribution’).  It is a UK based group operating in countries around the world through its subsidiaries.

2.SCOPE OF THIS PRIVACY POLICY

This notice governs BBC Studios Distribution’s processing of your information in relation to the products and services we supply to you and as otherwise processed in the course of our commercial activities. We will provide additional notices where appropriate, for example, to explain how we use web technologies such as cookies (you can find the link in the footer of the site you are using) or our mobile app notice.  

The processing of personal information by BBC Studios Productions is covered by the notice provided here, unless expressly indicated otherwise.

Other companies using our brands

We license our brands and content to other companies who may produce their own websites, events and digital content. These companies must clearly identify themselves through their website branding and privacy policies and handle your information appropriately. When you use a service operated by another company, the use of your information will be subject to their privacy practices and you should ensure you read their notices. If you wish to raise any concerns with us about the treatment of your information by such companies, please contact us at: dataprotection@bbc.com.

3.INFORMATION WE MAY COLLECT

The information we collect depends on the circumstances and the service you are using. We will only collect and store the information we need to. We may collect information relating to you and/or your use of our services in the following ways:

Personal information provided by you:

When you use our services or otherwise interact with us, for example via our social media platforms or through market research, we may ask you to provide information relevant to the circumstances. This information could include your email address, which we require to enable you to subscribe to receive news about our brands, or your contact details and payment information if you purchase something from us. It should be obvious why we are asking for particular information and if it is not we will provide an explanation.  In the next section, we explain in more detail the types of information we might collect.

When you share your comments and content with us (User Generated Content)

We may sometimes invite you to comment or to share your photos and videos with us.  If you take part then we may publish or use your content on our services or other platforms. There may also be times when you proactively choose to post content on our social media pages or elsewhere that relates to our brands (i.e. simply to show your love for our brands).  When you do this, we may contact you (via the relevant platform) to ask if we can publish or use your content on our services or other platforms.

Before we can accept or use your content, you must ensure you have the consent of anyone else featured. We may ask you to provide your email address to verify your age and that you are the legal parent or guardian of any children who may be featured in the content, as may be applicable under section 8 of this Privacy Policy (“Children Using Our Services”).

Interacting with us via social media and other platforms:

When you choose to participate in or receive a service from us via social media and similar platforms, for example by posting comments, entering a competition or playing a game on our social pages, we may collect information from you directly or the social network may share with us personal information about you, if you have given permission.  We only collect information that you have chosen to share with us, such as your name and email address. Please keep in mind that any information provided to us via a social network or other third party may also be subject to their privacy policy.

Information collected automatically during your use of our services:

When you use or receive services from us over the internet, we automatically record information about your use of those services, your interaction with our adverts and our emails as well as information about the device you are using and your internet connection. We do this in two ways:

Log data: When you use our services, certain information gets recorded in our log files such as your device's Internet Protocol (IP) Address, its unique ID, its operating system and location, and your browser type, the pages you viewed, cookie information and referral links (the link that sent you to a particular page).

Web technologies: In conjunction with our log data we may use specialist web technologies such as pixels or tags embedded in our web pages and emails and small data files which we store on your device (known as "cookies"). These technologies enable us to recognise your device and to track your interaction with our services, emails and adverts. We do not use these technologies to personally identify you, although we may add some data collected via these technologies to marketing records we hold about you.  In the UK and the European Economic Area (EEA), we will obtain your consent prior to storing or accessing data on your device (for e.g. a Cookie ID), in-line with our legal obligations.  For all users, we will provide you with tools and/or clear instruction on how to opt-out from these technologies.

See the Cookies Notice for the site you are using to find out more about the technologies deployed through the particular service you are using. You can find the link in the footer.

 

Information collected via specialist companies:

We sometimes use specialist companies to provide us with information they hold in relation to you or to collect information on our behalf.  For example, we use market research agencies to provide us with consumer insights to help shape BBC Studios programmes, products and services.  Generally speaking, this will be anonymous or aggregated data that means we are unable to identify you specifically.  If personal information is shared with us then we will always ensure this is done lawfully and, where appropriate, with your consent.

We might also use the services of social media platforms, advertising agencies or data brokers to enable us to reach certain audiences and to better target our marketing messages or the advertising shown on some of our services.  For example, we might use anonymous information about your browsing on our services or elsewhere to infer your interests and to put you into appropriate "market segments". This information is not used to identify you as a person and we do not attempt to combine it with personal information that we may hold. See the specific cookies notice for the service you are using for more information.

4.HOW WE USE YOUR INFORMATION AND LEGAL BASIS FOR PROCESSING

Purposes for which we will use your information

Depending on which of our services you are using (or how you are otherwise interacting with us), we may use your data for the purposes described below, and in ways which are  consistent with our relationship with you. We have set out a description of all the ways we might use your personal data and the types of data this could include.  Under UK or European data protection law we are required to tell you our lawful basis or processing your personal data and we have included this in the table below.

 

PURPOSE

CATEGORIES OF PERSONAL DATA (EXAMPLES)

LAWFUL BASIS

(UK/EEA ONLY)

To provide our products and services to you. Including, as applicable, (i) the administration of your account, (ii) processing and delivering your order, providing a service you have requested or administering our events.

·    Identity (e.g. name)

·    Contact details

·    Payment card information

·    Your transaction(s) and/or usage

·    Marketing and Communications preferences

(i) Our legitimate interests to keep our records updated and to manage our services effectively.

(ii) Performance of a contract with you

 

To manage and secure our services. Including troubleshooting, testing, system maintenance, reporting, and data hosting, preventing fraud or other potentially illegal activities (including copyright infringement), blocking disruptive users, protecting the safety of users and enforcing our terms of service.

 

·   Device identifiers, which may include your device’s IP address, user agent, and cookie IDs (see the Cookies Notice for the service you are using to learn more).

·   Usage/analytics data

·   Log data

Our legitimate interests for running our business, provision of administration and IT services, network security, and to prevent fraud

To measure and improve our products and services, the effectiveness of our marketing and emails, and our customer relationships and experiences. We may use specialist companies to help us to do this. Please see the Cookies Notice for the service you are using to learn more.

·   Device identifiers, which may include your device’s IP address, user agent, and cookie IDs (see the Cookies Notice for the service you are using to learn more).

·   Usage/Analytics data (e.g. browsing history, whether you opened or clicked an email etc)

·   Demographics (e.g. through market research)

·   Log data

Our legitimate interests to study how customers use our products and services, to keep our services updated and relevant, to develop our business and to inform our marketing strategy

To manage our relationship with you, including: responding to your requests and feedback; managing our competitions (including publication of winners names, if required); contacting you about a submission you have made to our online services, including through our social media pages and accounts (refer to our Code of Conduct); asking you to leave a review or take a survey; sending you service-related communications; and notifying you about changes to our terms or privacy policy.

·   Identity (e.g. name)

·   Contact details             

·   Communication preferences

Our legitimate interests to ensure you have a good experience in using our services, to keep our records updated and to respond to requests and feedback.

To send you emails with news, offers and promotions relating to our brands and services and special promotions from our brand partners in accordance with your contact preferences. These communications may be personalised to you based on what we think may interest you.

We may also send notifications via your device or web browser, where you have specifically given permission when requested by your browser or device.

If you unsubscribe or opt-out from email marketing, we may add your email address to a suppression list to ensure we respect your preference.

·    Identity (e.g. name)

·    Contact details

·    Profile (e.g. your preferences and interests inferred from your interactions with our services)

·    Marketing and communications preferences

Consent, as applicable, or

Our legitimate interests to promote our brands and services, and those of our partners and to manage your preferences.

To personalise our content and marketing to make it more relevant to you and to tell you about goods or services that we think might interest you.

We sometimes promote our products and services to you through advertising on other websites and services.  This advertising may be personalised to you based on your browsing or purchase history with us.

·   Identity

·   Contact details

·   Device identifiers, which may include your device’s IP address, user agent, and cookie IDs (see the Cookies Notice for the service you are using to learn more).

·   Usage/analytics data (e.g. your browsing history)

·   Profile (e.g. your preferences and interests inferred from your interactions with our services)

·   Log data

 

Consent (in relation to cookies and related technologies in the UK/EEA), or

Our legitimate interests to promote our services and engage our consumers and audiences

 

To market our products and services to you via social media. When we post marketing messages on social media platforms, we sometimes use the audience segmentation tools of the platform to show these to particular types of people – for example, based on your age, interests or (broad) location. When we do this, we only receive aggregated anonymous reports on the performance of these posts, no personal data is shared with us.

Any use of your data by those platforms in providing these services to us will be subject to their Privacy Policy and the preferences you have set for their platform(s).

 

If you are in the US or Canada:

Marketing Pixels & Custom Audiences: We may use your contact details and browsing/transactions data we hold about you in order to show you relevant marketing and promotional posts on social media. When we do this, an encryption technique is applied to the data so the social media platform can only read the data that it already holds in order to create a match so it can show you the relevant advertising post.

For general social media marketing we do not use personal data we hold about you.

US and Canada only:

·   Contact details

·   Transactions

·   Device identifiers, which may include your device’s IP address, user agent, and cookie IDs (see the Cookies Notice for the service you are using to learn more).

·   Usage/analytics data (e.g. your browsing and/or transactions history)

·   Profile (e.g. your preferences and interests inferred from your interactions with our services)

 

Our legitimate interests to promote our services and engage our consumers and audiences

Measuring and analysing the effectiveness of our marketing messages shown to you on our websites, in our emails and elsewhere online (e.g. where we purchase media space on other websites).

 

·   Device identifiers, which may include your device’s IP address, user agent, and cookie IDs (see the Cookies Notice for the service you are using to learn more).

·   Usage/analytics data (e.g. the ad shown to you and whether you clicked on it)

·   Log data

Our legitimate interests to analyse how customers use our products and services, to develop our products and services, to grow our business and to inform our marketing strategy

To analyse and report on brand sentiment and feedback on social media. When you post about us, our brands or programmes on social media, we may collate and report on this using a specialist platform so that we can better understand public perception. To do this we use a service called Brandwatch (find out more about their practices here).

·   Username/handle

·   Social media post

Our legitimate interest to better understand how our brands are perceived and to engage with our customers/audiences.

To conduct market research into our brands and services. We use specialist market research agencies to conduct research on our behalf. When we do this, the agencies will not usually share any information to enable us to identify respondents.  If they were to do this, it would be explained to you at the time you take part in the research.

 

However, we may carry out research relating to actors and public figures and when we do this, we will receive information about public opinion of such people.

For respondents: no personal data only anonymous demographical data and opinions.

 

For ‘talent’ and other public figures: name and public opinions/perceptions about them.

Our legitimate interest to better understand how our brands or talent are perceived and to engage with our customers/audiences.

To personalise adverts shown to you by our partners and advertisers on our services (that include advertising). This may include advertising personalised to you based on your browsing of our websites and other websites, and inferred interests or demographics for the service you are using.

Our partners and advertisers may also measure and analyse the effectiveness of the adverts shown to you.

To find out more about advertising and to opt out of your data being used to personalise it, see the Cookies Notice for the service you are using.

·   Device identifiers, which may include your device’s IP address, user agent, and cookie IDs (see the Cookies Notice for the service you are using to learn more).

·   Ad Profile (e.g. demographics and interests inferred from your interactions with our services and elsewhere online)

·   Usage/analytics data (e.g. browsing history, ad views and click throughs)

·   Log data

Consent (in relation to cookies and related technologies in the UK/EEA), or

Our legitimate interests to promote our brand partners and to generate revenue to help fund services.

 

5.SHARING & DISCLOSING YOUR INFORMATION

Information shared among BBC Studios Group Companies

To improve your experience of our services and brands, information about your use of our services may be shared between companies in the BBC Studios Group for the purposes of research, analysis, marketing and ad-serving. In addition, a BBC Studios company may provide data processing services on behalf of other companies within the group. For example, most of our newsletter subscription services are managed by a team in the BBC Studios Distribution UK headquarters.

Information shared with our suppliers

We use third parties to perform business functions on our behalf, such as sending our newsletters, hosting our online services, providing our customer services and fulfilling product orders and processing payments. We only disclose the information necessary to enable these third parties to perform their services. Our suppliers are contracted to comply with our instructions and we require that they do not use your personal information for their own business purposes.

Information shared via third party sharing buttons, widgets and other embedded content

Some of our online services include content controlled by third parties for services such as social sharing, recommended stories, commenting/reviewing, and displaying video or images. When you interact with these services they may collect information from and about you and your interaction with their content. This activity will be subject to the privacy policy of the third parties, and your settings for your chosen network. Please be aware that they may track your activity, through the use of cookies or similar technology, without you needing to interact with them. If this concerns you, ensure you log out of their services before using ours.

Information shared through pixels and cookies

We work with third parties who use cookies and similar technologies to provide a variety of services to us, including to: measure and analyse use of and engagement with our online services and emails; deliver and personalise our online marketing and third party advertising on our services.  These companies may be independently making decisions about how and why your personal data is processed, meaning they are a separate “Data Controller”. Full details of how these technologies are used are provided in the Cookies Notice provided for the service you are using.

Information shared with other parties

Generally, we will only disclose your data to other parties with your consent, for example if you choose to share content via social media functionality. Where required or allowed by law, we may disclose your personal information to law enforcement agencies, government/regulatory bodies, internet service providers and content protection organisations without your consent. For example, if you post inappropriate or objectionable content on our services or where we reasonably believe you may be in breach of the law or there is a safety concern, we may report your content and behaviour to relevant parties.

Sale or transfer of all or part of our business or assets

We reserve the right to transfer your personal information in the event we sell or transfer all or a part of our business or assets so that the buyer can continue to offer you the online services. We will make reasonable efforts to provide you with advance notification of the transfer of your information in such circumstances.

6.WHERE WE STORE AND USE YOUR INFORMATION

As described in the previous section, we may share your information with other companies in the BBC Studios Group or with contracted third party service providers. These companies may be located in, or use IT equipment located in, countries different to that in which your information is collected. Where this is the case, we will take steps to ensure that your information receives an equivalent level of protection.

BBC Studios is a global group of companies headquartered in the United Kingdom (UK), with subsidiaries around the world. This means your information may be processed in the UK and other locations globally, including in the United States.

If you are in the UK, or EEA:

Processing your data in countries such as the United States involves transferring your data outside the European Economic Area (EEA). Many of our external third parties are also based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

We require our recipients to provide a similar level of protection when transferring personal data out of the EEA.

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7.HOW LONG WE KEEP YOUR INFORMATION

We will hold your personal information on our systems for as long as is necessary for the relevant service or as long as is set out in any relevant contract you hold with us, in accordance with our retention policy. Where you contribute to one of our online 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. 

8.CHILDREN USING OUR SERVICES

Except where otherwise indicated, we do not knowingly collect or store any personal information from children under the age of 16.  In some cases, we may restrict our services, such as competitions, to those aged 18 or over. If appropriate, we will take steps to determine the age of persons submitting their information to us and may seek to obtain the consent of your parent or guardian.  

If you are under 16, we request that you do not provide us with information relating to you or to others.  Please seek the guidance of your parent or guardian before using our services.

If you are the parent or guardian of a child who is under 16 and you become aware that your child has provided us with information without your consent, please contact us at dataprotection@bbc.com. We will delete such information from our records within a reasonable time.

9.PROTECTING YOUR INFORMATION

We protect your information in many different ways. These include staff training, investing in technology and following strict handling and storing procedures. We maintain appropriate organisational and technological safeguards to help protect against loss, misuse or unauthorised access, disclosure, alteration or destruction of the information we hold about you. We also seek to ensure our service providers do the same. Unfortunately, no system can be guaranteed as completely secure and there is an inherent risk in transmitting information over the internet. It may be possible for an unrelated party to intercept or access such transmissions unlawfully.

If you believe that your personal information under our control has been compromised, including access to any accounts you hold with our services, please contact us immediately using the details under ‘Contact Us’ below.

10.YOUR RIGHTS & CHOICES

You have a number of rights and choices available to you in relation to personal information we hold about you.  If you would like to exercise any of these, please follow the instructions provided or submit a request to us in writing using the contact details provided below.

Communication Preferences: If you wish to stop receiving marketing communications from us, please click on the "unsubscribe" link at the bottom of the relevant email. This will not necessarily unsubscribe you from all communications, only the brand/service in question.  If you wish to opt-out completely then please contact us using the details provided below. Please note that you cannot unsubscribe from some service-related messages (which are not used to send marketing materials).

In accordance with industry standards, we reserve the right to retain a minimal amount of data necessary to ensure we do not contact you in the future – for example by adding your email address to a ‘suppression list’.

Opt-out from personalised advertising cookies and other tracking: If you wish to opt-out of personalised advertising or other forms of "tracking" please refer to the cookies notice for the service you are using (you can find the link in the website footer). Be aware that opting out of personalised advertising will not prevent adverts from being displayed to you but they will no longer be tailored to your interests or browsing behaviour.

Access information we hold about you: You can find out what information we hold about you and can receive a copy of it. When submitting a request, please provide us with enough information to enable us to locate your record(s), including the email address we may hold for you and the details of the service you use.

We will require you to prove your identity before granting access to your personal information. You will not have to pay a fee to access your personal data (or to exercise any of the other rights detailed below). However, we may be entitled to 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.

We will process your request within applicable legal timeframes. For the UK and the EEA, this is one calendar month, but we can extend this time if your request is particularly complicated or large.

Correct your information: You can have any incomplete or inaccurate personal information we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Delete your information: In some circumstances you can ask us to delete information we hold about you.  For example, when we no longer need it because you initially gave us consent and you wish to withdraw it. Sometimes we may not be able to delete your information because (i) we are legally required to keep it; or (ii) we need it for our own legitimate business purposes, for example if you were to unsubscribe from an email list, we would need your email address to add to a suppression list to ensure you were not contacted. We will only refuse to delete information where permitted by law. Where applicable, we will explain the reasons for refusing your request.

 

IF USING UK OR EEA SERVICES, YOU HAVE THE FOLLOWING ADDITIONAL LEGAL RIGHTS:

Stop us from using your personal information: You can ask us to stop using your information for direct marketing purposes (see communication preferences).  You can also ‘object’ to us processing your information where we are relying on a legitimate interest. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Restrict the processing of your personal information: You can ask us to suspend the processing of your personal information if you are concerned about its accuracy or how it is being used.  You can also ask us not to delete your information (for example because you need it to establish, exercise or defend legal claims).

Transfer your personal information in a machine-readable format (to you or a third party): This right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

 

CALIFORNIA RESIDENTS HAVE THE FOLLOWING SPECIFIC LEGAL RIGHTS:

Under the Californian law, including the California Consumer Privacy Act (Cal. Civ. Code 1798.100), if you are a resident in California you may contact us in relation to the following rights regarding your personal data:

Right to access: You have the right, twice a year, to request access to the personal information that we have collected about you and/or shared outside the BBC Studios group in the past 12 months.

You also have the right to access a list of companies with whom we have shared your personal data for direct marketing purposes.  However, BBC Studios group companies do not share personal information with unrelated companies without providing you with a choice in such disclosures.

Right to deletion: You have the right to request that we delete your personal information.  There may be exceptions to the right to deletion for specific legal reasons which, if applicable, we will set out for you in response to your request.

Right to opt in/opt out of sale of personal data: For individuals aged 16 years or older, you have the right to opt-out of sale of personal data we may hold on you to third parties. For individuals between 13 to 16 years old, you have the right to opt-in to the sale of personal data we may hold on you.

BBC Studios group companies do not “sell” customers’ personal data other than in the limited ways described in our cookies notice. The cookies notice provides instructions on how you can opt out from the sharing of your personal information.

Exercising your rights: If you wish to exercise any of your privacy rights or have any queries about how we use your personal data, please contact our Privacy Team at: dataprotection@bbc.com or write to us at the appropriate address below.

If you are a BBC Shop customer who resides in California, you can also call our toll-free number (provided below) to exercise your rights of access to your personal information.

11. CHANGES TO THIS PRIVACY POLICY

This Privacy Policy may be updated from time to time to reflect changes in law, best practice or in our practices regarding the treatment of personal information. If material changes are made to this Privacy Policy we will notify you by placing a notice on our relevant services. The date of the most recent revision will appear at the top of this page. If you do not agree to the changes, please do not continue to use our services. You should check this policy frequently for updates.

12.CONTACT US

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the DPO by email at: dataprotection@bbc.com

Alternatively, you can write to us by post::

Data Protection Officer

Regulatory Affairs (4B)

BBC Studios

1 Television Centre, 4A

101 Wood Lane

London

W12 7FA

For questions or requests relating to BBC Shop, please email : dataprotection@bbc.comor write to:

BBC Studios Americas Inc

1120 Avenue of the Americas

5th Floor

New York

NY 10036-6700

USA

BBC Shop Customer Services (toll-free)

US: 1-800-898-4921

Canada: 1-800-435-5685

12.RIGHT TO COMPLAIN

If you have a concern about how we have processed your personal data, you should contact us in the first instance via the contact details above.

For UK and/or EEA services:

If you feel we have not resolved your concern 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 (www.ico.org.uk).

If you live in a country or territory located in the European Union (EU) or European Economic Area (EEA), and you think that some, or all, of the issues you are concerned about have taken place in your country of residence, you can complain to your national data protection regulator. For contact details of national data protection regulators in the EU and EEA, please refer to the European Data Protection Board website.