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: 4th December 2019
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Novi Digital Entertainment Private Limited, Starhouse, Urmi Estate, 95 Ganpatrao Kadam Marg, Lower Parel (West), Mumbai 400013, India ("we", "us", "our", "Novi") as the owner, operator, manager of the Hotstar UK Platform (“Platform” or the “Hotstar Service”) has appointed Star Advertising Sales Limited ("SASL" or “our distributor”) to distribute the Platform in the United Kingdom.
Novi values the trust placed by users of the Hotstar Service ("you", "your", "user", "subscriber") and therefore, we follow the highest standards to protect your Personal Information.Novi is always the data controller of your Personal Information and is solely responsible for the use of your Personal Information even though SASL as our distributor contracts with you to provide the Hotstar Service.
If you require any information or clarification regarding the use of your Personal Information or this Privacy Notice or if you require any general information or clarification or inquiry regarding the Platform please email us at hello@hotstar.com.
Alternatively, you may contact our EU Representative:
Star Advertising Sales Limited:
2nd Floor, Profile West,
950 Great West Road,
Brentford, Middlesex, TW8 9ES, UK.
This Privacy Notice ("Privacy Notice") explains how we use and protect Personal Information of the users or subscribers of our Hotstar website or mobile application in United Kingdom ("UK").
This privacy notice describes the usage of information provided or collected through sites and applications, where this privacy notice is posted ("Platform") and affiliate or third-party sites / platforms through which the Platform and/or any of its features may be provided. 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 features or services. Those notices are to be read in combination with this Privacy Notice.
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.
We encourage you to read the applicable Terms of Use to understand the terms related to the use of the Platform and Hotstar Service in general.
Where we refer to 'Personal Information' we mean 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 your name, postal address, email address, and mobile number, and also includes all other information which is linked to that information such as your location. Where we refer to “ID” we mean a list of numbers and/or letters (also known as a numeric or alphanumeric string) which we or our service providers may generate and which is used as a means to give you a unique customer or user identifier – it cannot directly identify personally but it may be able to do so where your Personal Information is associated with it.
We may ask for and you may choose to provide the below Personal Information when you use or register for the Hotstar Service and create a subscription account, upload content to or via the Platform, use any of the features of the Platform (such as game play) or contact us directly:
We collect this information in a number of ways, including when you enter it while using our Platform, interact with our customer support, or participate in game play events on our Platform, surveys, or marketing promotions, prize draws or competitions. In some cases, where you access our Platform service available via mobile devices, Smart TVs or Internet connected TVs or Internet connected devices (“streaming devices”) your streaming device may store some of your Personal Information in their memory. These streaming devices are operated by third parties and these third parties will have their own privacy notices or other policies regarding the handling of Personal Information that they independently collect from such streaming devices. You should carefully read the privacy notice and policies of these streaming devices. We are not responsible for the privacy practices of these third parties, and the information practices of these third parties are not covered by this Privacy Notice.
We collect information about you and your use of our Platform, your interactions with us or our advertising or any direct marketing we have permission to send you, as well as information regarding your computer or other streaming device used to access our service. The information includes:
We may track certain information about the content viewed and your visit to our website. 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.
We may obtain your Personal Information from other sources.
If you choose to link, connect or login to our Platform using a social media platform like Facebook, Twitter, Instagram or Google the social media platform may send us your profile and social information such as Email ID, Name, Friend list, Friend’s social information, etc.
We may also receive information about you) from third parties but will only do so where we have assurances that you have given your permission. For example, we may obtain data related to you and your interests from i) publicly available sources such public or open government databases or ii) online and offline data providers (including advertising networks and analytics providers).
When you purchase a subscription package our payment gateway service provider, or any other online or mobile payment services provider we may use, the following payment information will be collected: your credit/debit card details (number, card expiry date, CVC code) or other bank account details along with the date, time and amount of the transaction payment. This payment information is stored by our payment processors and associated with a merchant name/ID and location which our payment processor gives to us, together with a unique customer ID which we share with them but this payment information is never stored or processed by us. Our payment processors use this payment information to process and facilitate the payment of your subscription fee in order that we may provide you with the service you have requested or to enter into a contract with you to access the Platform (in other words to perform the contract). So that we know you have paid your subscription fee our payment processors will send us a unique transaction ID which we associate with your unique customer ID and which we keep for internal accounting purposes because we have a legal obligation to do so.
Our payment processors may use third party fraud detection software or providers which analyse your payment information in order to make automated decisions as to whether or not payment from you will be accepted. You have the right to contest any fraud decision made about you and to be given more information about why any such decision was made by contacting us.
Where you pay a third party for your subscription package (e.g. Apple iTunes) your payment information is directly collected and controlled by that third party. However, we receive invoice receipts from third parties for your subscription purchase and these receipts are stored by us as we have a legitimate interest to keep them for internal accounting and tax purposes.
Where our payment processors are providing payment processing services to us (as data processors) we put in place appropriate contracts to protect your personal information and, where your personal information is transferred internationally outside of the UK, we take steps to ensure any transfer is subject to appropriate safeguards in accordance with data protection laws. For the following aspects of the payment processing our payment processor is a data controller of your payment information (identified and listed above): providing the payment processing services to you at your request, monitoring, preventing and detecting fraudulent payment transactions, complying with legal or regulatory obligations which apply to the financial services sector and analysing, developing and improving their products and services. Our payment processors have their own privacy policies in place and we recommend you read those policies before you provide your payment information.
In order to process any of your customer support queries related to payment processing, our payment processors give us access to the first 6 digits and last 4 digits of your credit/debit card (including any updates) so that we can perform the contract with you and provide you with a quick resolution of your queries. We also use the first 6 digits of your credit/debit card so that, on the basis of our legitimate interest, we can analyse the most popular card types and issuing banks of our customer base. Our payment processors will also pass us your expiry date after each payment transaction is completed and we will use this to send you an email reminder to update your payment information before your card expires as we believe we have a legitimate interest to make sure your access to the Platform is not interrupted, you can still cancel at any time. However, at no point in time do we have access to or store the full credit/debit card number in our systems.
We will only collect and process Personal Information about you where we have lawful basis. Our lawful basis for processing your Personal Information will vary depending on the context in which we collect and use it and the following examples give you as a guide as to which basis we think applies (but if the context changes or other circumstances arise then the lawful basis may also change). Where we refer to ‘perform the contract’ we mean the subscription contract between you and our distributor:
For example, we use your information where we need the Personal Information to perform the contract with you (for example, to provide the Platform or our services to you) so as to:
In some contexts, we use your Personal Information where we have a legal obligation to do so or to protect your vital interests or those of another person:
In other contexts, we use your Personal Information where the processing is in our legitimate interests and not overridden by your fundamental rights and freedoms (for example, our direct marketing activities in accordance with your preferences) such as to:
We will use your Personal Information with your consent as follows:
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.
At times we may make your Personal Information available to our or our distributor’s service providers (such as but not limited to: marketing, analytics, research, communication, advertisements, infrastructure and IT services, technology or software providers, payment processing and other service providers) that work with us or assist us to provide services to you or license us software which we include in our application(s). Personal Information will only be shared with our service providers to provide or improve the Hotstar Service and to enable us to analyse our marketing efforts. We do not authorize our service providers to use or disclose your Personal Information except in connection with providing their services.
We may offer joint promotions that, in order for you to participate and benefit from any promotional offer, will require us to share your Personal Information with third parties so that we co-ordinate and fulfil the incentive offered. These third parties are responsible for their own privacy practices.
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.
To opt out of interest-based ads from Hotstar UK platform in connection with a resettable device identifier on a mobile device, tablet, or streaming media devices, please configure the appropriate setting on your device (usually found under "privacy" or "ads" in your device's settings). You may still see Hotstar ads on your device, but they will not be tailored to your interests.
If you have enabled push notifications then you can disable (or enable) any time by going to your device “Settings” and clicking on “Notifications,” and then changing those settings for some or all of the apps on your device.
(Different device configurations, or updates to devices, may affect or change how these settings work)
You can ask us to correct inaccurate or incomplete Personal Information concerning you by sending us an email to our support email address. 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:
The data that we collect to create a profile of you for the purpose marketing and advertising (i.e. your watch history and activity on the platform) is retained for a period of 12 months.
The data that we collect for sending your direct marketing communications (i.e. your phone number), except your registration information, is retained and used for a period of 2 years from the last date of your active subscription.
At the end of the retain period your personal data will be anonymised.
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 data that we collect and process based on permissions or consent obtained from you, you may withdraw your consent at any time, by selecting preferences available in the app or by sending us an e-mail. We shall review your request and may ask you to verify your identity.
You have the right to object to the use of your Personal Information with respect to certain types of processing, including processing for direct marketing and profiling. You can object by changing your preferences, disabling cookies as set out in our Cookies Policy or by contacting us (see Contact Information). If you wish use to cease or restrict processing of your Personal Information in relation to personalised content or interest-based advertising then, unless the Platform allows you to select available preferences, then you should cease to use the Platform and we can arrange to cancel your subscription. 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.
The Platform is not intentionally designed for or directed at persons less than 18 years of age and it is our policy not to collect and process any Personal Information from such persons. We do not knowingly permit any person who is under 18 years of age to register 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.
Should a parent or guardian have any reason to believe that a minor has provided us with Personal Information without their prior consent, please contact us (see Contact Information below).
We operate globally and may transfer your Personal Information to Novi affiliated companies or service providers in locations around the world for the purposes described in this Privacy Notice. Wherever your Personal Information is transferred, stored or processed by us or our affiliates or service providers, we will take reasonable steps to safeguard the privacy of your Personal Information. Additionally, when using or disclosing Personal Information transferred from the UK, we use standard contractual clauses approved by the UK Regulator, or 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 us (See Contact Information below).
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your Personal 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. These measures are designed to provide a level of security appropriate to the risks of processing your Personal Information. 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 (See Contact Information below).
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 or in response to changing regulatory or operational requirements ("Updated Terms"). The Updated Terms shall be effective immediately (unless we state otherwise) and shall supersede the terms of this Privacy Notice. We will notify you of any changes to this Privacy Notice if the changes significantly affect your rights or as may be required by law. Your continued use of the Hotstar Service after any updates will mean you have accepted those changes. If you do not agree to the updates you should stop using the Service and cancel your subscription.
To see the previous version of this Privacy Notice please link.
If you’re not satisfied with our response to any complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the Information Commissioner’s Office (ICO) using the following details:
Address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Telephone number: 0303 123 1113
Website: www.ico.org.uk