The Walt Disney Company has acquired certain 21st Century Fox businesses, including those providing the services described below. This policy has been updated to reflect that transaction.
Last updated: 20th March 2019
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Novi Digital Entertainment Private Limited ("we", "us", "our", "Novi") as the owner, operator, manager of the Hotstar UK Platform has appointed Star Advertising Sales Limited ("SASL") to distribute the Platform in the United Kingdom.
Novi values the trust placed by its data subject ("you", "your", "user", "subscriber") and therefore, we follow the highest standards of privacy guidelines to protect the information shared by you with us.
This Privacy Notice ("Privacy Notice") governs the use of Personal Information shared (as defined below) with or collected from the users or subscribers of our online services in United Kingdom ("UK").
This privacy notice describes the usage of information provided or collected on the sites and applications, where this privacy notice is posted ("Platform"). We follow this privacy notice in accordance with applicable law in the places where we operate. In some cases, we may provide additional data privacy notices specific to certain services or regions. Those terms are to be read in combination with this privacy notice.
Please keep in mind that when you provide information to us on a third-party site or platform, the information we collect through those third-party sites linked with our applications is covered by this privacy notice, and the information the third-party site or platform collects is subject to the third-party site or platform's privacy practices. Privacy choices you have made on the third-party site or platform will not apply to our use of the information we have collected directly through our applications. Please also keep in observance that our sites and applications may contain links to other sites not owned or controlled by us and we are not responsible for the privacy practices of those sites. We encourage you to be aware when you leave our sites or applications and to read the privacy policies of other sites that may collect your personal information.
All capitalized terms that have not been specifically defined herein shall have the same meaning as provided under the Terms of Use.
This Privacy Notice should be read in conjunction and together with the Terms of Use applicable to the service you are using.
By using our services (for example, when you register for an account, purchase a service, enter a contest or promotion and communicate with us on our sites or applications), we may ask for your explicit consent to certain uses of personal data (for example more sensitive types of personal data, including precise information about your location). If you give this consent, you can withdraw it at any time as described in paragraph 7.5 below.
If you are a traveller visiting various countries around the world and avail the Platform's services, then we will determine your location using your IP address to determine the relevant Hotstar services which should be offered to you. In the event IP detection fails, we will consider the last cached location as your current location to provide you with Hotstar services and the consents obtained at the time of registration in that location will be valid for processing of your personal information. We use third party service providers to help us determine your location to provide you with appropriate content and services on our Platform.
'Personal Information' or 'PII' is defined as any information related to a particular individual who we identify (whether directly or indirectly) a particular individual or natural person. This includes direct identifiers such as the individual's name, postal address, email address, and mobile number, and also includes all other information which is linked to that information (e.g. IP addresses, information about what sort of videos you have watched, and information about you contained in emails or other contacts with is.
We may ask for and collect the below personal information (among other personal information) when you use the services and without this information you may not be able to access our Platform and its services;
The payment information data which we collect from you is never stored by us and is transmitted immediately upon receipt to the third-party payment gateway for payment / invoice processing purposes. In order to process any of your customer support queries related to payment processing, we may have access to this payment information via our payment gateway partners for quick resolution of your queries. However, at no point in time do we have access to the actual Credit / Debit card data.
We collect information about you and your use of our service, your interactions with us, as well as information regarding your computer or other device used to access our service. The information includes:
We do not store your IP address or device information with us in our servers /systems.
We may track certain information about the content viewed and your visit to our website. We use this information for conducting internal analytics and research to better understand, protect and serve our users. This information is compiled and analysed on an aggregated basis. This information may include the platform that you just visited (whether this platform is on Hotstar Services or not), which platform you next visit, your computer browser information, your mobile phone OS version.
If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities on the Hotstar Services, we may collect and store such information.
We identify and use your IP address to help diagnose any problems with our server, and to administer Hotstar. Your IP address is also used to help identify your location and to gather broad demographic information to customize your experience on the Hotstar Services.
We use third party service providers to help us determine your location and to provide you with appropriate content and services. We collect your IP address and share the IP address with our third party services providers to help us determine your location. For example, we use Akamai services to help us determine your location basis your IP address and for delivering localized content.
Based on Your purchase of a subscription package, our payment gateway partners may collect information with respect to your credit/debit card details or other bank account details along with your billing address, and mobile number. This information is stored by our payment gateway partners. We do not store any of your credit/debit card details or other bank account details that you enter on our payment information page. For instance, the Hotstar Services will be using third party payment gateway partners to process and facilitate the payment of your subscription fee to the Hotstar Services for providing you access to the content.
In case of Apple iTunes, your payment information data is directly collected by them. However, we receive invoice receipts from Apple iTunes for each of your purchase and these receipts are stored by us for payment / invoice processing purposes.
Such payment gateway partners are not controlled by us. When you visit such payment gateways you do so at your own risk. These payment gateways may have their own privacy policies in place, which we recommend you to review if you visit any such payment gateways. We do not assume any responsibility or liability for such payment gateways, the content of such payment gateways and their privacy practices, nor do we endorse them. We encourage you to familiarize yourself with the privacy statements provided by such payment gateways prior to providing them with information about you or entering into any transactions with them.
We will only collect and process personal data about you where we have lawful basis. Lawful basis on which we would process your personal information includes where it is necessary to carry out our obligations or exercise rights under a contract with you (e.g. under our Terms of Use) or processing for "legitimate interests" where processing is not necessary to meet contractual obligations, but is necessary to provide you with customer support or process your data for providing premium services (For e.g. processing your information by our payment gateway service providers). In some limited cases, as described above, we obtain your consent for processing.
We use your information to provide, and enhance our services, to deliver content, to process your registration, your orders, payments, and to communicate with you. For example, we use information to:
When you access or use the Services or send any data, query, request or communication to us via our Support email, You understand that You are communicating with us electronically, and that we may respond via electronic means from us, such as by email.
We use third party service providers to help us determine your location, to provide you with appropriate content and services basis your location, to deliver DRM protected content, and to provide non-personalized content item based recommendations.
In some cases, were Hotstar UK is available in Smart TVs or Internet connected TVs we may share user identity details post successful activation of Hotstar application on streaming devices which may include:
This information is being disclosed to third -parties basis of Data Protection Addendum (DPA) signed with them to provide our services across all platforms and to ensure the transparency/authenticity of users. We validate the activation session from backend which helps us to provide you with seamless and uninterrupted services across all platforms.
The shared personal information as mentioned above is stored in the memory of your device which is used for streaming Hotstar application. The service provider does not have access to your personal information unless it is explicitly shared by Us.
We use third party analytics and event collection tools to capture non-personally identifiable information such as crash logs, build analytics, and performance analysis for our Platform at an aggregate level. For instance, we use
We provide personal information to our affiliates and other trusted businesses or persons to process it for us, based on our instructions and in compliance with our Privacy Notice and any other appropriate confidentiality and security measures.
In the event of any requirement by court order, government or quasi-government agency to disclose our Personal Information, we will disclose information as may be legally required. We may also disclose Your Personal Information if we, in the good faith believe that such disclosure is reasonably necessary to respond to subpoenas, court orders, or other legal process.
In the event Novi is merged with or acquired by another company or in case of re-organization or re-structuring of business, we and our affiliates may share your personal information, wholly or in part, with another business entity.
We provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your personal information. In accordance with applicable law, your controls and choices may include:
You can access some of your personal information through the 'My Account' section of the platform post successful login. You are responsible for providing us with your accurate personal information and keeping your personal information up-to-date. You can reach us via the provided Support email to know more about any information that the Platform is collecting.
You can ask us to correct inaccurate or incomplete personal information concerning you by sending us an email to our support email address. We may not be able to update your email addresses as this is the primary information we need to uniquely recognise you on our platform, you may choose to delete your account instead. Deletion of your account would result in termination of your subscription with no refunds issued to you. In case you have made your subscription via Apple iTunes, then you will have to rectify your subscription and / or personal data on the Apple iTunes platform as per their applicable processes.
In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible). You can issue such a request by contacting us via the provided support email. In case you have made your subscription via Apple iTunes, then you will have to request for access to your subscription / personal data or portability of your subscription / personal data on the Apple iTunes platform as per their applicable processes.
We retain your personal information as long as necessary for providing you the services and as per the lawful basis of processing and to comply with our legal obligations. In particular, when determining how long we retain personal data, we take into account how long we need it to:
If you no longer want us to use your information then you can request that we erase your personal information and close your Platform account. Erasure of your information from the Platform will result in your subscription being terminated without any refunds. In case you have made your subscription via Apple iTunes, then you will have to unsubscribe yourself from the Apple iTunes platform as per their applicable processes to ensure that you are not being charged by Apple any further. Additionally in case of Apple iTunes, you will have to request for erasure of your personal / subscription data on Apple iTunes platform as per their applicable process. Please note that if your request for the erasure of your personal information;
For withdrawing your consent at any time during the tenure of your services with us, you may choose to do so by sending us an e-mail. We shall review your request and may ask you to verify your identity. Post verification we will withdraw the consent for which request was made by you, and will delete all your personal data from our systems. Withdrawing your consent to the processing of your personal information will lead to termination of your services with us. In case you have made your subscription via Apple iTunes, then you will have to unsubscribe yourself from the Apple iTunes platform as per their applicable processes to ensure that you are not being charged by Apple any further. Additionally, in case of Apple iTunes, you will have to withdraw your consent and request for restriction of processing of your personal / subscription data on Apple iTunes platform as per their applicable processes.
Where your personal information is processed for purposes that is likely to cause or is causing distress or damage to you, you may, at any time ask us to cease processing your data for these purposes by sending an email to our Data Subject Request Handling team. We may not be able to cease processing of your data for our subscription process. In the event, you wish to restrict processing of your personal data for our subscription process, then this may lead to termination of your services with us and your subscription will be terminated without any refunds. In case you have made your subscription via Apple iTunes, then you will have to unsubscribe yourself from the Apple iTunes platform as per their applicable processes to ensure that you are not being charged by Apple any further. Additionally, in case of Apple iTunes, you will have to object to processing of your subscription / personal data on Apple iTunes platform as per their applicable processes.
You can write to our data subject request handling team in case of any grievance or compliant. You have the right to complaint about the data processing activities carried out by us before the competent data protection authorities.
Please be aware that if you do not allow us to collect personal information from you, we may not be able to deliver certain experiences, products, and services to you. If collection of personal information is mandatory, we will make that clear at the point of collection so that you can make an informed decision whether to participate. If you have questions about the specific personal information about you that we process or retain, and your rights regarding that personal information, please contact our data subject request handling team via the provided support email address.
We hope to be able to manage any complaints or concerns you have about our uses of your personal data. However, if you feel we have not appropriately dealt with such requests, you can complain to the data protection supervisory authority in the country in which you live.
The Platform is not intentionally designed for or directed at persons less than 18 years of age. We do not knowingly permit any person who is under 18 years of age to register with the services or to provide any other personally identifying information. Please do not use or register with us if you are below 18 years of age. If we become aware that any personally identifiable information of persons less than 18 years of age has been collected on the Platform without verified parental consent, then we will take the appropriate steps to delete any such information.
However, we consider it the responsibility of parents to monitor their children's use of our services. Nevertheless, it is our policy not to collect and process any personal information from children below 18 years of age. We do not seek or intend to seek or receive any personal information from children. Should a parent or guardian have reasons to believe that a minor has provided us with personal information without their prior consent, please contact our data subject request handling team to ensure that the personal information is removed from the Platform.
We operate globally and may transfer your personal information to Novi affiliated companies or third parties in locations around the world for the purposes described in this privacy notice. Wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information. Additionally, when using or disclosing personal information transferred from the European Union, we use standard contractual clauses approved by the European Commission, adopt other means under European Union law for ensuring adequate safeguards. If you would like to review a copy (which may be partially redacted for business confidentiality reasons), please contact our data subject request handling team.
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your account credentials have been lost, stolen, altered, or otherwise compromised or in case of any actual or suspected unauthorized use of your account, please contact us by contacting our data subject request handling team.
This Privacy Notice is subject to change from time to time. We reserve the right, at our sole discretion, to modify the terms of this Privacy Notice from time to time in order to ensure compliance with applicable laws ("Updated Terms"). The Updated Terms shall be effective immediately and shall supersede these the terms of this Privacy Notice. We will notify you of any changes to this privacy notice if the changes made to the notice significantly affects your rights or as may be required by law.
If you require any information or clarification regarding the use of your personal information or this privacy notice or grievances with respect to use of your personal information, or if you require any general information or clarification or inquiry regarding the platform please email us at uk@hotstar.com via your subscribed email address only. We will not be able to process any requests which have been initiated via a non-subscribed email address.
The data controller for the Platform is Novi Digital Entertainment Private Limited with the business address of:
Starhouse,
Urmi Estate,
95 Ganpatrao Kadam Marg,
Lower Parel (West),
Mumbai 400013
India.
The EU representative of Novi Digital Entertainment Private Limited shall be Star Advertising Sales Limited with the business address of:
2nd Floor, Profile West,
950 Great West Road,
Brentford, Middlesex, TW8 9ES, UK.