HBO UK Privacy Policy - UPDATED


Introduction


Please read this Privacy Policy carefully before using this online entertainment service. Access to and use of this online entertainment service (the "Service") is provided by HBO International Europe Limited ("HBO," "us" or "we") acting as the data controller and the Service is subject to the following. This Privacy Policy also applies to, without limitation, online and mobile web sites, services and applications, as well as all components, features and downloads that are, or may be, available through the Service, or that interact with the Service and display this Privacy Policy and which are collectively included in the definition of “Service.”

Your privacy is important to us. To better protect your privacy, we provide this notice explaining our online information practices and the choices you can make about the way your personal data is collected and used in connection with the Service. This Privacy Policy applies to the Service, and covers personal data collected on or through or in connection with your use of the Service.

HBO reserves the right to modify the terms and conditions of this Privacy Policy or to change, modify or otherwise alter any feature of the Service, at any time in its sole discretion. Changes may be communicated to you by making the revised Privacy Policy available for your review. If we make changes to this Privacy Policy that materially modify our rights to use your previously-collected personal data, we will notify you either through an email or a prominent posting on this Service. Your continued use of the Service after the revised version is made available and notified to you, constitutes your agreement to the revision.

Please note that throughout this Privacy Policy, you will see capitalised words or phrases. These capitalised words and phrases are defined terms. The defined terms are first set off from the other text in parentheses. Their definitions are found either in this Privacy Policy or in the Terms of Use, found here: www.hbo.co.uk/terms. Please review the Service’s Terms of Use, which governs your use of the Service.  


Table of Contents

It is important that you read and understand the entire Privacy Policy before using the Service. However, this table of contents highlights key issues and subjects.

1. Personal Data We Collect

2. How Do We Use The Personal Data Collected?

(a) To Enable and Improve Access to the Service

(b) To Assist Third Parties Acting on Our Behalf

(c) To Communicate With You

(d) To Improve the Service

(e) Cookies and Usage Data Collected as You Access and use the Service

(f) Third Party Ad Servers

(g) Additional Uses

3. When We Share Your Personal Data

(a) Administrative and Legal Reasons

(b) Sale of Assets or Change of Control

(c) Business Partners/Third Parties

(d) For Affiliate Use

(e) Advertising Networks

(f) Co-Branded Opportunities

4. Social Networks and Personal Data Sharing

5. Collection of Personal Data by Third Parties

6. Storage and Security

7. What Legal Basis We Rely On To Process Your Data

8. How You can Access or Correct Personal Data, or Opt Out

9. How to Contact Us

10. Data Transfer



1. Personal Data We Collect


On certain portions of the Service, you are requested to provide personal data. The types of personal data that may be collected on these pages may include, without limitation: e-mail address (mandatory for certain functions, such as to enter a sweepstakes or contest or establish an account but otherwise optional for many promotional materials), and other information (e.g., name, mailing address, cell phone numbers, date of birth, screen name, and information about your interests in and use of various products, programs, and services) you voluntarily provide. Personal data may be collected when you: (a) create an account; (b) register for promotions or other features of the Service; (c) report any issues relating to the Service or your use of the Service; (d) provide feedback or post comments on the Service; or (e) answer a survey or participate in research. HBO also may collect personal data and other information from you in the course of investigating suspected violations of this Privacy Policy and HBO’s Terms of Use.

We also may collect certain other information when you access the Service, such as: the type of browser you are using; the URL that referred you to our Service; the type of operating system you are using; the IP address or other unique identifier such as a Device Identifier (defined below) of any of your computer(s) or device(s) that are used to access the Service; your Device characteristics and certain Device Data; the name of your Internet service provider or mobile carrier; all the areas within our Service that you visit and your activities there; referring/exit pages; date/time stamp; clickstream data; web beacons; precise geolocation information (with your consent, where required) and information about your interests in and use of various products, programs, and services (collectively described as “Usage Information,” described in greater detail in Section 2(e) below). If you log in via a social media platform, see Section 5 regarding additional information that may be collected. In addition, when you visit the Service our servers automatically collect information describing your use of the Service, including but not limited to content accessed by you, page/screen visits, length of time viewing a certain page or program, how the content is viewed, etc.

We may on occasion combine your personal data we collect with additional records (including those of our analytics vendors and affiliated companies) to enhance our ability to market to you those products, features, or services that may be of interest to you, to assist us in providing, personalizing and improving our Service and other offerings, and for research purposes. 


2. How Do We Use the Personal Data Collected


(a) To Enable and Improve Access to the Service. In accordance with applicable laws, we may use or share the information you provide about yourself with our vendors, affiliates, partners and distributors to verify your eligibility to access the Service, fulfill your requests for our products, programs, and services, to customize your use of the Service based on your viewing patterns and areas of interest, verify the status of your account, for analytics, and to provide you with information regarding changes or updates to the Service, newsletters, and special offers and promotions.

The information we collect in connection with our online, mobile and video forums and communities is used to provide an interactive experience. We use this information to facilitate participation in these online forums and communities and, from time to time, to offer you products, programs and services.

If you choose to submit content for publication, we may publish your screen name and other information you have provided to us on the Service, on the Internet, or elsewhere. We also may access content posted about our programs and services on various online platforms (such as Twitter hash tags) and post them on our site.

 (b) To Assist Third Parties Acting on Our Behalf. We may use vendors to perform certain services on behalf of us, such as hosting the site or application, fulfilling your orders of products and/or services, designing and/or operating the Service’s features, tracking the Service’s activities and analytics, and enabling HBO to send you special offers or performing other administrative services. We may provide these vendors with access to user information, including Device Identifiers and personal data, to carry out the services they are performing for you or for us.

We may use analytics vendors for purposes such as to evaluate and provide us with information about the Service and viewing of our content (for more details see also Section (e)). These vendors may set and access their own Tracking Technologies (defined below) on your Device and they may otherwise collect or have access to information about you. Please recognize that HBO and/or its vendors (such as mailing houses or customer service vendors) may store this information, and may share this information with third parties as necessary to process your transactions and provide access to the Service by you. HBO may also use this information for internal review and analysis of the Service, the customer service process, and consumer comments.

(c) To Communicate With You. We sometimes use this information to communicate with you, such as to notify you when you have won one of our contests, sweepstakes or when we make changes to our user agreements, to provide you with newsletters, promotional information about HBO and/or the Service, in connection with incentive programs, rewards and fan engagement activities, to respond to your inquiries about our offerings and provide customer service assistance, to offer you other products, programs or services that we believe may be of interest to you, or to contact you about changes to the Service or other system requirements, your account, or any customer service requests submitted by you.

(d) To Improve the Service. We sometimes use the information that we collect to improve the design and content of our Service and to enable us to personalize your experience in using our Service. We also may use this information to analyze usage of the Service in the aggregate, to provide user ratings and other information to subscribers generally, to offer you products, programs, or services that we think you might enjoy, and to better assist with customer service. We may also share such information in the aggregate to enable partners, prospective partners, affiliates or third parties (such as Nielsen, movie studios, cable and satellite companies, etc.) to analyze usage of particular items of content, such as how often a particular film was streamed or how much of a particular film was watched.

 
(e) Cookies and Usage Data Collected as You Access and Use the Service


In addition to any personal data or other information that you choose to submit to the Service, we and our third-party service providers may use a variety of technologies that automatically or passively collect certain information whenever you visit or interact with the Service, which technologies may be downloaded to your Device (defined below) and may set or modify settings on your Device.  This Usage Information may include the browser that you are using, the URL that referred you to our Service, all the areas within our Service that you visit and your activities there, your Device location, your Device characteristics and certain Device data, and the time of day, among other information.  We also may collect precise geolocation in real time from your Device with your consent.  We may use Usage Information for a variety of purposes, including to assess, enhance or otherwise improve the Service or our activities in connection with it, for analytics or for marketing purposes.  In addition, we may collect your IP address or other identifier (“Device Identifier”) for your computer or other device used to access the Service (any, a “Device”).  


A Device Identifier is an identifier that is automatically assigned to your Device used to access the Service, and our computers identify your Device by its Device Identifier.  We may access and use Device Identifiers that have already been associated with your device.  


We may use various new and hereafter developed technologies to collect Device Identifiers, Usage Information and Demographic Information about you (“Tracking Technologies”).  A few of the methods that may be used to collect Usage Information include, without limitation, the following (and subsequent technology and methods hereafter developed):


Cookies


Our Service and third party vendors may use cookies and other similar technology such as “web beacons.” Cookies are text files containing small amounts of information which are downloaded to your device when you visit a site. Cookies are then sent back to the originating site on each subsequent visit, or to another site that recognises that cookie.

Web beacons are small strings of code that provide a method for delivering a graphic image on a web page for the purpose of transferring data, such as the IP address of the computer that downloaded the page on which the web beacon appears, the URL (Uniform Resource Locator) of the page on which the web beacon appears, the time the page containing the web beacon was viewed, the types of browser that fetched the web beacon and the identification number of any cookie on the computer previously placed by that server. When corresponding with you via HTML capable email, web beacons let us know whether you received and opened our email. Such technologies will only be used in accordance with applicable data protection laws.

Our Service uses the following types of cookies:

• Strictly Necessary Cookies: These cookies are essential in order to enable you to move around the Service and use its features, such as accessing secure areas of the site. Without these cookies, services like enabling appropriate content based on your type of device cannot be provided.

• Performance Cookies: These cookies collect information about how visitors use the Service, so that we can analyse traffic and understand how our visitors use our site. We may use third party vendors for this purpose who may use their own cookies. These cookies don’t collect information that identify an individual visitor. All information collected by these cookies is aggregated and therefore anonymous. This information is only used to improve how the Service works.

• Functionality Cookies: These cookies allow our site to remember choices you make (such as the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of the Service that you can customise. They may also be used to provide services you have asked for such as watching a video. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.

• Advertising Cookies: This Service may use a third party advertising network to deliver targeted advertising. These may also have the capability to track your browsing across different sites and apps. If you do not allow these cookies, you will experience less targeted advertising.

If you don’t want to allow cookies at all, or only want to allow use of certain cookies, please refer to your browser settings or mobile device settings. The procedure for doing so varies from one browser application to another. If you wish to reject cookies from our Service, but wish to accept those from other sites, you may be able to choose the option in your browser settings to receive a notice before a cookie is stored on your device. Please consult the “Help” section of your browser or device for more information.

If you would like to opt out of third party cookies relating to behavioural advertising, please go to www.youronlinechoices.eu. Opting out does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

By disabling cookies, you may be prevented from accessing some features of our Service or certain content or functionality may not be available.  


(f)  Third Party Ad Servers


As discussed in detail below in Section 5, on our sites or as part of our Services, third party ad servers may present or serve advertisements, provide us with data collection, reporting, ad response measurement, and site analytics, and assist with delivery of relevant marketing messages and advertisements. These third parties may view, edit, or set their own cookies. They may also collect information concerning your online activities over time and across different websites. The information they may collect includes the other sites you have visited or applications that you have downloaded to your mobile device, and other information about you or your device in order to help analyze and serve anonymous targeted advertising on the Service and elsewhere. For more information about third party ad servers and your ability to opt-out of targeted advertising from such third parties, please visit Your Online Choices (www.youronlinechoices.com)


(g)  Additional Uses


 HBO may on occasion combine your information we collect with additional records (such as publicly available information, including on social media sites, and those of our vendors and affiliated companies) to enhance our ability to market to you those products, features, or services that may be of interest to you, for analytics purposes, and to assist us in providing, personalizing and improving our Service and other offerings.

HBO has not implemented a response to browser-based Do Not Track signals. Because of the current lack of consensus with respect to the Do Not Track standard from both a compliance perspective and a technical perspective, we have not yet determined how or if we would implement a response to Do Not Track signals; we will continue to evaluate in the event a uniform standard is adopted. 

3. When We Share Your Personal Data


Information may be shared as set forth more particularly in Section 2 of this Privacy Policy. In addition, there may be times when we share your information, including your personal data as follows: 

 
(a) Administrative and Legal Reasons


We may disclose personal data in response to legal process, for example, in response to a court order or a subpoena. We also may disclose such information to third parties in connection with regulatory investigations, fraud-scoring, detection, and prevention activities or where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Use, to protect our rights and the rights of others, and as otherwise required by law.


(b) Sale of Assets or Change of Control


In the event of a sale of assets or change in ownership, we may transfer such information to a successor of HBO or any person or entity that acquires ownership or control of HBO or the Service via any means.


(c) For Affiliate Use


As you know, HBO is a Time Warner company, and as such, has affiliate sibling companies. We may share your personal data with our affiliates to identify products and services that may be of interest to you, for research, analysis and to assist in the improvement of our Service or those of our affiliates, and in connection with promotions conducted by us, by our affiliates, or jointly. Below is a list of some of the Time Warner companies that are affiliated with HBO and with whom we may share information we collect at our sites. We may update this list from time-to-time with additional Time Warner companies, so please check back periodically to keep up-to-date.

Time Warner Inc.

Turner Broadcasting System Inc.

Warner Bros. Entertainment Inc.

(d) Business Partners/Third Parties. We may share personal data with business partners and third parties (e.g. other companies, retailers, research organisations etc.). If we share personal data with such unaffiliated third parties for their own marketing we provide you with an opportunity to opt out of such uses either at the point of collection or through the choice mechanisms set forth in this Privacy Policy.

(e) Advertising networks. We may share certain information with third parties to provide advertising to you based on your interests. For more information, please see http://www.youronlinechoices.eu. Please note that any opt-out choice you exercise through this program will apply to interest-based advertising by the third parties you select, but will still allow the collection of information for other purposes, including research, analytics, and internal operations. You will continue to receive advertising, but that advertising may be less relevant to your interests. For European Economic Area (EEA) visitors, you can also access information about cookies on the pop up screen when you first access the Service. 


(f) Co-Branded Opportunities:  We sometimes may offer content (e.g., contests, sweepstakes, or promotions) that is sponsored by or co-branded with identified third parties. By virtue of these relationships, the third parties may obtain personal data that visitors voluntarily submit as a result of participation in such content or activities. We have no control over these parties' use of this information. We will notify you at the time your personal data is requested whether such information will be shared with these parties. 


4. Social Networks and Personal Data Sharing  


You can also engage with our content and other offerings, such as videos, games and applications, on or through third-party social media sites, plug-ins and applications, (collectively Social Networks) such as those offered by Facebook, Twitter, and others. If you log onto Social Network sites from the Service, the Social Network’s privacy policy governs your use of the Social Network.

In certain instances, you may have the ability to link your account with us to third party Social Networks. When you link your account or view or engage with our content on or through third party Social Networks, services, plug-ins, or applications, you allow us to have ongoing access to certain information from your Social Network account, consistent with your Social Network settings (e.g., name, e-mail address, profile photo, gender, birthday, location, your list of friends and their contact information, people you follow and/or who follow you, the posts or the 'likes' you make). We may also receive other information (e.g., content or videos viewed, game performance, high scores, and information about advertisements within the content you have been shown or may have clicked on, etc.) from your Social Network interaction with our content.

By agreeing to share or posting content from the Service to a Social Network site, or by linking your Social Network account with your HBO account, you acknowledge HBO’s collection and use of your Social Network information that you have made available to be shared, including video viewing information. HBO will collect information including video viewing information from your Social Network sites each time you share or post content from the Service to the Social Network, and may collect information from your postings for rewards or incentives. You can de-link your Social Network account from your HBO account on a going forward basis.

When you provide information from your Social Network account, it can help enable us to do things like (i) give you exclusive content, (ii) personalize your online experience with us within and outside our Service, and (iii) contact you through the Social Networks or directly with the latest news, special offers, and rewards. By providing such information, you consent to the use of the information in accordance with this Privacy Policy.

If you post information or content, such as by posting photos, commenting on a blog, or participating in online forums or communities at our Service, or when you interact with our Service through Social Networks, plug-ins or other applications, depending on your privacy settings this information may become public on the Internet. Therefore, we cannot prevent further use of this information. You can control what data you share through privacy settings available on some Social Networks. For more information about how you can customize your privacy settings and how Social Networks handle your personal data, please refer to their privacy help guides, privacy policies and terms of use.


5. Collection of Personal Data by Third Parties

The Service may contain links to other sites, including without limitation, the sites of our programming distributors and digital distribution partners, whose information practices may be different to ours. Visitors should consult the other sites' privacy notices as we have no control over information that is submitted to, or collected by, these third parties. As you use the Service, third parties may place cookies and collect personal data concerning your online activities over time and across different websites.


6. Storage and Security

We and/or our vendors (such as mailing houses, customer service vendors or cloud services) may store your information.

When we store your information, we do so for as long as necessary to (i) fulfill the specific purposes for which your personal data was collected to perform the services set out in this notice and (ii) comply with our legal obligations or enforce our legal rights. The precise period for which that information will be retained will vary on a case-by-case basis. Such period will be determined on the basis of the following criteria:

• the length of time that you have any registered account with us;

• whether there are contractual or legal obligations that exist that require us to retain the data for period of time;

• whether there is any ongoing legal claim that relates to any interaction you have with us, or that is otherwise related to your relationship with us; and

• whether any applicable law, statute, or regulation allows for a specific retention period.

We take information security seriously and use reasonable physical, electronic, and managerial procedures to help prevent unauthorized access, maintain data security, and correctly use the information we collect online. For example, HBO and its vendors secure any financial information, including credit card numbers, with encryption technologies. We incorporate commercially reasonable safeguards to help protect and secure your personal data.

Of course, no data transmission over the Internet, wireless data transmission, or data storage is 100% secure, and any message or information you send to the Service may be read or intercepted by others. Although we take appropriate measures to safeguard against unauthorised disclosures of information, we cannot assure you that personal data that we collect will never be disclosed in a manner that is inconsistent with this Privacy Policy.


7. What Legal Basis We Rely On To Process Your Data


On some occasions, HBO processes your data with your consent. For example, we rely on consent to place cookies, send you promotional material, or process information that you input into our website.

On other occasions, HBO processes your data when we need to do this to fulfil a contract with you, such as to complete transactions with you, or where we are required to do this by law, such as when we receive a law enforcement request.

HBO also processes your data when it is in our legitimate interests to do this and when these interests are not overridden by your data protection rights. For example, HBO has a legitimate interest in ensuring the security and integrity of our Services and in ensuring that our websites and apps operate effectively

8. How You can Access or Correct Personal Data, or Opt Out 


You may ask us for a copy of your personal information, to correct it, erase it or to transfer it to other organisations at your request. You also have rights to object to some processing and, where we have asked for your consent to process your personal information, to withdraw this consent.

Where we process your personal information because we have a legitimate interest in doing so (as explained above), you also have a right to object to this. You also have the right to restrict processing in certain circumstances. These rights may be limited in some situations – for example, where we can demonstrate that we have a legal requirement or other legitimate grounds to process your personal information. We may ask you to verify your identity and to provide other details to help us to respond to your request.

If you wish to exercise these rights, please contact us at the address indicated in Section 9 below. In addition, you can contact our EEA representative at:

HBO Nordic, A.B.

Attention Legal

Birger Jarlsgatan 6

114 34 Stockholm, Sweden

We hope that we can satisfy questions you may have about the way we process your personal information. However, if you have unresolved concerns you also have the right to complain to data protection authorities. You can bring the complaint in your member state of residence, place of work or where an alleged infringement of data protection law occurred.

9.  How to Contact Us


If you have any questions or concerns about the Privacy Policy for the Service or its implementation you may contact us at [email protected] 

10.  Data Transfer to the United States


In accordance with applicable laws, HBO International Europe Limited may transfer your personal data to its parent entity and/or its TW affiliates (as such term is defined in Section 3c) in the United States or to its vendors. Where the data is sent to a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a vendor's Processor Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review by contacting us at the address indicated in Section 9 above.



Effective Date:  May 25, 2018