Sky Privacy Centre

20220801_rev01 · COMPARED WITH 20220501_rev01 · ARCHIVE SNAPSHOT, DATE APPROXIMATE

Full text changes — 20220501_rev01 to 20220801_rev01

11## Introduction and scope
22
3This privacy and cookies notice applies to the processing of personal data, including information we collect and store via cookies, as explained below by:
3This privacy and cookies notice applies to the processing of personal data, including information we collect and store via cookies, by:
44
55- **Sky UK Limited**, if you access our UK products and services or our online digital platforms (including where Sky UK Limited trades under the name "NOW"), or
66- **Sky Ireland Limited**, acting as agent for Sky Subscribers Services Limited (Irish branch), if you access our Irish products and services or our online digital platforms (including where Sky Ireland Limited trades under the name "NOW"), and
77
88references in this notice to "**Sky**", "**we**" "**us**" or "**our**" should be interpreted accordingly. The processing explained in this notice may be carried out by Sky or other data controllers in the Sky group of companies (including Sky Subscribers Services Limited, Sky In-Home Service Limited and Sky Retail Stores Limited).
99
1010References to Comcast refer to the parent company of Sky, Comcast Corporation, 500 Gravers Road Suite 3000 Plymouth Meeting, PA 19462 United States.
1111
1212If you access the products and services of other Sky companies and businesses, you should refer to their privacy notices.
1313
14## **Information we collect and how we use it**
15
16### Information you provide to us
17
18**Contact Details & Account Information**
19
20Contact details and other information on or about your account. This includes your:
21
22- name
23- address
24- contact information (such as phone numbers and email addresses)
25- date of birth
26- Sky iD
27- account number
28- viewing card number
29- marketing preferences
30- payment information
31- National Insurance number
32- ID documents (such as your passport or driving licence)
33
34**Contact Details & Account Information**
35
36From you, through our websites, applications or products and services, when you access our services through applications on websites operated by other organisations, or when you otherwise provide it to us (for example on calls or via live chat or our messaging services).
37
38**Contact Details & Account Information**
39
40_To provide your service / perform our contract with you_
41
42- to provide you with content, products and services (including trials), in accordance with the contract you have with us. This includes providing you with tailored and personalised experiences with our products and services (such as recommendations about your content) and sending you newsletters about your content, products and services. **1.** (see **Additional info** tab)
43
44- to enrol you in our Sky VIP Programme and provide the applicable rewards. **2.**
45
46- to enter into a loan agreement with you. For these we need to take automated decisions on whether to grant you the loan based on personal data we obtain from credit reference agencies (See the below section on "Information from third parties"). **3.**
47
48- to verify your identity, including when you exercise your subject rights.
49
50- check that you are eligible for our products, services and that you are using these in accordance with the terms of the contract you have with us.
51
52_With your consent_
53
54- to send you direct marketing about our content, products, services events and special offers by post, telephone, SMS, email, notification or other electronic means to the contact details you have provided. **4.**
55
56_Where we have a legitimate interest_
57
58- to prevent and detect fraud and protect or enforce our or any third party's rights. This may involve analysing activity on our network to help stop unauthorised access to content or publication of or access to unlawful content.
59
60- to prevent and detect crime.
61
62- to support public and road safety.
63
64- for market research.
65
66- to send you direct marketing where we're not relying on your consent to do so. For example, to send you push or in-app notifications or if you're a prospective customer.
67
68- For the following activities explained further in the section "More information about certain activities" below:
69
70 - AdSmart
71
72 - PromoSmart
73
74 - Online and Digital advertising
75
76 - AdVance
77
78- to verify the personal data we hold about you is accurate (for example, your address).
79
80- to monitor, record, store and use customer service communications we have with you. **5.**
81
82_Where we have a legal obligation_
83
84- to comply with police and other security investigations.
85
86- to enable Sky to support customers whose circumstances might make them vulnerable or in need of special assistance, including to comply with (and demonstrate compliance with) Ofcom's consumer protection requirements.
87
88_Where there is a vital interest_
89
90- to safeguard your vital interests or those of another person to support crime prevention and protect the safety of members of the public and Sky employees.
91
92**Contact Details & Account Information**
93
94**1.** This also includes providing account management functionality, billing and payments, customer support (inc. diagnostics and trouble-shooting).
95
96**2.** The Sky VIP Programme enables you to access special rewards, perks and experiences. We will process your data to administer the Sky VIP Programme, including sharing with third parties who provide experiences and fulfilment agencies. Where you choose to enter into the separate and additional terms and conditions for our Sky VIP Programme, we will send you direct marketing in accordance with the terms of that contract.
97
98**3.** The automated decision is influenced by your credit history and, depending on the outcome of this automated decision-making process, we may not enter into the loan agreement with you. If you would like us to review decisions taken about you as part of this process, please contact us as set out below.
99
100**4.** In addition to marketing we send while you are a Sky customer, we may also send marketing:
101
102- before you become a Sky customer, such as 'abandoned basket' marketing if you gave us consent to use your contact details for marketing during an online sales journey but didn't complete your purchase. We will tailor the marketing based on what you added to your basket.
103- for a reasonable time after you cease to be our customer.
104
105**5.** This helps us to: improve the quality of our customer service; confirm any instructions you give us; create a customer profile so we can have better conversations with you, and train and develop our staff.
106
107**Product Holdings**
108
109Information about the products and services you have (or enquired about) or previously had, and your (i) interactions with us about those products and services; (ii) payment and offer history in respect of them.
110
111**Product Holdings**
112
113From you, through our websites, applications or products and services, when you access our services through applications on websites operated by other organisations, or when you otherwise provide it to us (for example on calls or via live chat or our messaging services).
114
115**Product Holdings**
116
117_To provide your service / perform our contract with you_
118
119- to provide you with content, products and services (including trials), in accordance with the contract you have with us. This includes providing you with tailored and personalised experiences with our products and services (such as recommendations about your content) and deciding what to include in newsletters about your content, products and services.
120- to enter into a loan agreement with you.
121- to check that you are using our products and services in accordance with the terms of the contract you have with us
122- to tailor our Sky VIP Programme to you and provide the applicable rewards.
123
124_Where we have a legitimate interest_
125
126- for market research
127
128- to build a profile about you and your time as a Sky customer, which we use to target and tailor the direct marketing we send you, determine what offers about our products and services you are eligible for and how to provide those offers to you.
129
130- For the following activities explained further in the section "More information about certain activities" below:
131
132 - AdSmart
133
134 - PromoSmart
135
136 - Online and Digital advertising
137
138 - AdVance
139
140- to provide tailored and personalised recommendations based on your viewing activity which would require an additional purchase or transaction by you.
141
142- to monitor, record, store and use customer service communications we have with you. **1.** (see **Additional info** tab)
143
144_Where we have a legal obligation_
145
146- to comply with police and other security investigations.
147
148- to enable Sky to support customers whose circumstances might make them vulnerable or in need of special assistance, including to comply with (and demonstrate compliance with) Ofcom's consumer protection requirements.
149
150**Product Holdings**
151
152**1.** This helps us to improve the quality of our customer service; confirm any instructions you give us; create a customer profile to have better conversations with you, and train and develop our staff.
153
154**Customer Service Interaction Data & CCTV Data**
155
156This includes:
157
158- records of your customer service interactions with us, such as call recordings and records of your conversations and correspondence with us.
159- images recorded by cameras at Sky Retail Stores or fitted to Sky's engineer vans.
160
161**Customer Service Interaction Data & CCTV Data**
162
163From you, including when you contact us and your image from CCTV footage recorded when you visit a Sky Retail Store or other Sky locations.
164
165from you when in the vicinity of one of our Sky vans.
166
167**Customer Service Interaction Data & CCTV Data**
168
169_Where we have a legitimate interest_
170
171- for market research.
172
173- to monitor, record, store and use customer service communications we have with you. **1.** (see **Additional info** tab)
174
175- to help prevent and detect crime.
176
177- to support public and road safety.
178
179- to protect the safety of Sky employees.
180
181_Where we have a legal obligation_
182
183- to comply with police and other security investigations.
184
185- as part of supporting or defending legal claims (for example, where we need to disclose information as part of Court proceedings).
186
187_Where there is a vital interest_
188
189- to safeguard your vital interests or those of another person.
190
191**Customer Service Interaction Data & CCTV Data**
192
193**1.** This helps us to: improve the quality of our customer service; confirm any instructions you give us; create a customer profile so we can have better conversations with you, and train and develop our staff.
194
195**Special category data**
196
197This includes:
198
199- health data or other special category data
200- biometric information (such as facial scans)
201
202**Special category data**
203
204From you, when you provide it to us or our business partners.
205
206**Special category data**
207
208_With your explicit consent:_
209
210- to provide assistance and support on your account.
211- to verify your identity as part of consumer credit agreement authorisations, such as by matching your facial scans to your ID documents.
212
213### Information we collect automatically
214
215**Viewing Data, Usage Data and User Generated Content**
216
217Information about how you or your household use, access, view, share, contribute to, or otherwise interact with Sky and/or third-party content, websites, products and services.
218
219This includes the content you watch and how long you watch it for (we call this viewing activity), as well as content you add to your Playlist (if using Sky Glass).
220
221**Viewing Data, Usage Data and User Generated Content**
222
223From you and your household when using Sky and/or third-party content, websites, products and services (such as third party apps).
224
225**Viewing Data, Usage Data and User Generated Content**
226
227_To provide your service / perform our contract with you_
228
229- to provide you with tailored and personalised experiences with our products and services (such as recommendations about content available within your services) and sending you newsletters about your content, products and services.
230- to check that you are using our products and services in accordance with the terms of the contract you have with us.
231- to manage traffic across our networks and operate our products and services effectively. **1.** (see **Additional info** tab)
232
233_Where we have a legitimate interest_
234
235- to provide tailored and personalised recommendations based on your viewing activity which would require an additional purchase or transaction by you. **2.**
236
237- to prevent and detect fraud and protect or enforce our or any third party's rights. This may involve analysing activity on our network to help stop unauthorised access to content or publication of or access to unlawful content.
238
239- for market research.
240
241- to build a profile about you and your time as a Sky customer, which we use to target and tailor the direct marketing we send you, determine what offers about our products and services you are eligible for and how to provide those offers to you.
242
243- For the following activities explained further in the section "More information about certain activities" below:
244
245 - AdSmart
246
247 - PromoSmart
248
249 - Online and Digital advertising
250
251 - AdVance
252
253- to improve and develop new content, products, services and customer experiences.
254
255_Where we have a legal obligation_
256
257- to comply with police and other security investigations.
258
259**Viewing Data, Usage Data and User Generated Content**
260
261**1.** For example, transmitting your requests for any communications service through the most efficient route in our network of equipment and systems.
262
263**2.** For example, this may include content available on Sky Store or content you'd need a package upgrade to watch.
264
265**Device Information & Telemetry Data**
266
267This includes:
268
269- technical information, including diagnostic (such as errors and system statuses), traffic and location data.
270
271**Device Information & Telemetry Data**
272
273From the devices you use to receive Sky content, products and services.
274
275**Device Information & Telemetry Data**
276
277_To provide your service / perform our contract with you_
278
279- to diagnose, evaluate and fix problems with our products and services.
280
281- to manage traffic across our networks and operate our products and services effectively. **1.** (see **Additional info** tab)
282
283- to check that you are using our products and services in accordance with the terms of the contract you have with us.
284
285_Where we have a legal obligation_
286
287- to comply with police and other security investigations.
288
289**Device Information & Telemetry Data**
290
291**1.** For example, transmitting your requests for any communications service through the most efficient route in our network of equipment and systems.
292
293**Product Analytics**
294
295This includes information about your household's use of Sky, and/or third party content, products and services such as your:
296
297- device, machine or browser
298- how you use our products and services (e.g. time spent watching content or within apps, how you navigate the user interface); and
299- other devices you use or have connected to your Sky devices.
300
301**Product Analytics**
302
303From the devices you use to receive Sky content, products and services.
304
305**Product Analytics**
306
307_To provide your service / perform our contract with you_
308
309- to provide you with content, products and services (including trials), in accordance with the contract you have with us.
310
311_Where we have a legitimate interest_
312
313- to improve and develop new content, products, services and customer experiences.
314
315- to tailor the direct marketing we send you, determine what offers about our products and services you are eligible for and how to provide those offers to you.
316
317- For the following activities explained further in the section "More information about certain activities" below:
318
319 - AdSmart
320
321 - PromoSmart
322
323 - Online and Digital advertising
324
325 - AdVance
326
327**IP Addresses & Online Identifiers**
328
329This includes information from the devices you use to communicate with websites and applications on the internet, such as:
330
331- IP addresses
332- MAC addresses
333- unique identification numbers
334- online identifiers (for example, device IDs and advertising IDs)
335- browser information.
336
337**IP Addresses & Online Identifiers**
338
339From the devices you use to communicate with websites and applications on the internet
340
341**IP Addresses & Online Identifiers**
342
343_To provide your service / perform our contract with you_
344
345- to provide you with content, products and services (including trials), in accordance with the contract you have with us.
346- to check that you are using our products and services in accordance with the terms of the contract you have with us.
347- to manage traffic across our networks and operate our products and services effectively. **1.** (see **Additional info** tab)
348
349_Where we have a legitimate interest_
350
351- to determine the country you are located in, so we can provide you with the correct information such as product and pricing information on our websites.
352
353- For the following activities explained further in the section "More information about certain activities" below:
354
355 - AdSmart
356
357 - PromoSmart
358
359 - Online and Digital advertising
360
361 - AdVance
362
363- to prevent and detect fraud and protect or enforce our or any third party's rights. This may involve analysing activity on our network to help stop unauthorised access to content or publication of or access to unlawful content.
364
365_Where we have a legal obligation_
366
367- to comply with police and other security investigations.
368
369**IP Addresses & Online Identifiers**
370
371**1.** For example, transmitting your requests for any communications service through the most efficient route in our network of equipment and systems
372
373**Voice data**
374
375Your voice data when using voice command or 'Hello Sky' features.
376
377**Voice data**
378
379When you use the voice command feature on your remote control or, if you're a Sky Glass customer, when you say 'Hello Sky'. For Sky Glass this can be turned off using the switch on your device, via voice command or in the Voice Mics setting in the privacy section of the settings menu.
380
381**Voice data**
382
383_To provide your service / perform our contract with you_
384
385- to action your voice search or voice control commands when using our products and services.
386
387_Where we have a legitimate interest_
388
389- to improve and develop our voice-related services (including our voice algorithms, the recording of the voice searches made and the success of the "Hello Sky" command when you use Sky Glass).
390- to understand how people are using our voice-related services and the common themes and trends based on that usage.
391
392### Information from third parties
393
394**Third Party Data**
395
396Information we obtain from third parties, including:
397
398- address verification data
399- contact information
400- modelled household
401- profile information (such as affluence and household composition)
402- personal data that is publicly available.
403
404**Third Party Data**
405
406From other organisations, such as address verification services, data brokers, property and lifestyle agencies, and credit reference agencies.
407
408These organisations include:
409
410- Royal Mail
411- Experian
412- Dunnhumby
413- CACI
414- TwentyCi
415- TransUnion
416- Mastercard
417- Ordnance Survey
418- Emma's Diary (where you have consented to this)
419- Nectar360
420- Frasers Group
421
422If you want to manage how these organisations use your personal data and share it with companies like Sky, you should get in touch with them directly. In the case of Experian, you can access their Consumer Information Portal [here](https://www.experian.co.uk/privacy/consumer-information-portal/opt-out-options/).
423
424**Third Party Data**
425
426_To provide your service / perform our contract with you_
427
428- to enter into a loan agreement with you. For these we need to take automated decisions on whether to grant you the loan based on personal data we obtain from credit reference agencies. **1.** (see **Additional info** tab)
429
430_Where we have a legitimate interest_
431
432- to send you direct marketing where we're not relying on your consent to do so. For example, if you're a prospective customer.
433
434- to verify the personal data we hold about you is accurate (for example, your address).
435
436- to build a profile about you and your time as a Sky customer, which we use to target and tailor the direct marketing we send you, determine what offers about our products and services you are eligible for and how to provide those offers to you.
437
438- For the following activities explained further in the section "More information about certain activities" below:
439
440 - AdSmart
441
442 - PromoSmart
443
444 - Online and Digital advertising
445
446 - AdVance
447
448**Third Party Data**
449
450**1.** The automated decision is influenced by your credit history and, depending on the outcome of this automated decision-making process, we may not enter into the loan agreement with you. If you would like us to review decisions taken about you as part of this process, please contact us as set out below.
451
452## More information about certain activities
453
454AdSmart is Sky's tailored TV advertising solution. AdSmart allows us to show adverts within your TV services (including on Sky+, Sky Q, Sky Glass and Sky Go) to the people most likely to be interested in the products and services being promoted. We also work with Virgin Media to enable AdSmart for their customers on their TV platforms.
455
456With AdSmart, Sky and Virgin can show different adverts to different households (in groups of 5,000 or more across Sky and Virgin households) watching the same programme or service. To do this we create a profile about a household comprising factors like interests, age and location using the information you have provided to us, information about your use of our products and services, and information we have acquired from other organisations, and which we may combine with information received from brands wishing to target their advertising to a particular audience. We use this profile information to define groups of audiences to whom we send adverts.
457
458As part of showing these adverts, we also carry out quality and frequency checks, such as whether adverts were displayed correctly and how often particular adverts have been shown.
459
460PromoSmart uses the same process described above to deliver tailored promotions (e.g. for upcoming content) within your TV services.
461
462To the extent any special category data (for example, data concerning health) is processed within AdSmart, Sky relies on your consent for such processing.
463
464If you don't want your data to be processed for AdSmart & PromoSmart let us know using one of the methods in the "Managing Your Preferences" section below. You will still see adverts and promotions within your TV services, but they may be less relevant to you.
465
466More information about how AdSmart can be used by advertisers can be found [here](https://www.adsmartfromsky.co.uk/how-sky-adsmart-works/).
467
468We work with trusted partners to process your personal data to tailor and deliver online and digital advertising, specifically:
469
470- Sky's own advertising on websites, apps and social media platforms; and
471- third-party advertising on websites and apps.
472
473_Information we use_
474
475_How we use this information_
476
477This information may be combined with other information we hold about you, including information you have provided to us, information about websites you have visited, viewing activity, product holding and information about your use of our products and services, account number and history and Sky iD preferences so we can tailor the adverts you see, show you more relevant content or offers and define groups of audiences to whom we and our partners deliver digital adverts.
478
479_What happens if you interact with an advert_
480
481If you interact with an advert (such as by clicking a link or scanning a QR code displayed in the advert) we will collect and use the information you provide to enable our partner to fulfil the interaction. For example, if you enter your name, address and payment details to purchase an advertised item, this data will be processed by the fulfilment agency to deliver that item. This information will also be used by us for the purposes described in this section. We also use aggregated data to better understand advertising performance.
482
483_Your online and digital advertising preferences_
484
485If you don't want your data matched with the social media sites you use, let us know using one of the methods in the "Managing Your Preferences" section below. You might still see Sky posts or adverts on those social media sites, but they won't be personalised using your Sky account data. You can also change your settings on that social media site to control the promoted posts you see there, and you can find more information on how that social media site uses your personal data in its privacy policy.
486
487Where we use cookies or similar technologies to process your personal data for online and digital advertising purposes, you can set and manage your cookie preferences on the relevant Sky or third-party website or app. After you have made your initial choice, you can change your preferences on Sky websites and apps using the 'Privacy options' link in the footer of the site or the settings within the app.
488
489_Our partners_
490
491We work with our partners to make sure personal data is processed only if appropriate measures and controls are in place to protect your personal data in accordance with applicable data protection laws and regulations and regulatory guidance. Any data transfers outside the UK or EU will only take place on the basis of an approved data transfer mechanism as described in the section 'How we share your information'.
492
493AdVance is Sky's online and digital advertising solution which allows us to tailor the digital adverts that you see on Sky and third-party websites and apps based on information we know about you or to reinforce or extend the reach of TV adverts you may have seen (or based on content you may have watched).
494
495To do this, we collect and use the same types of information explained in the 'Online and digital advertising' section and combine this with information about your viewing activity so we know what programmes you like and adverts you may have seen.
496
497Subject to your SkyiD and cookie preferences, this may be further combined with device information and information about websites you have visited and other information we hold about you, including information you have provided to us and information about your use of our products and services, to define groups of audiences to whom we deliver digital adverts. If you don't want your data to be processed for AdVance let us know using one of the methods in the "Managing Your Preferences" section below.
498
499Where we use cookies or similar technologies to process your personal data as part of AdVance, you can set and manage your cookie preferences on the relevant Sky or third-party website or app. After you have made your initial choice, you can change your preferences on Sky websites and apps using the 'Privacy options' link in the footer of the site or the settings within the app.
500
14501**COOKIES NOTICE**
15502
16503Cookies are created when you visit a website or use an app. They are small files that are stored on your device and used to customise your experience.
17504
18505When you access Sky.com, the Sky News and Sky Sports sites and apps, or other Sky websites and apps for the first time, you will be asked to set your cookie preferences for the site.
19506
40527If you have any queries or comments about this privacy and cookies notice, please write to Customer Relations, Sky Subscriber Services Ltd, PO Box 43, Livingston, West Lothian, EH54 7DD, UK or to Customer Relations, Sky Subscriber Services Limited, One Burlington Plaza, Burlington Plaza, Dublin 4, ROI or contact Sky's Data Protection Officer via dp.department@sky.uk.
41528
42529## Changes to this notice
43530
44531We will occasionally update our privacy and cookies notice. We will post a notice of any material changes on our website prior to implementing the changes, and, where appropriate, notify you using any of the contact details we hold for you for this purpose. This may include phone, SMS, e-mail, post or interactive social media. We encourage you to periodically review our notice to be informed of how we use your information.
45532
46**This privacy and cookies notice was last updated 14 April 2022.**
533**This privacy and cookies notice was last updated 1 July 2022.**