1. GENERAL INFORMATION
- “Consent” means a freely given, specific, informed and unambiguous agreement to the processing of personal data;
- “Data controller” means the entity that determines the purposes and means of the processing of personal data;
- “Data processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the data controller;
- “GDPR” means the EU General Data Protection Regulation (Regulation (EU) 216/679);
- “Personal data” means any information relating to a natural person who can be identified, directly or indirectly, by using such information (e.g., name, address, email, phone number, and IP address); and
- “Processing” means the use of personal data in any manner, including, but not limited to, collection, storage, erasure, transfer, and disclosure of personal data.
1.3. Responsible entity (data controller). The entity that is responsible for the processing of your personal data through CompareTV is Twenty/Twenty Digital Pty Ltd having a registered place of business at Suite C, 13/1 Vuko Place, Warriewood, New South Wales 2102, Australia, and a business registration number (ABN) 20166855401 (“we”, “us”, and “our”).
1.4. Our role as a data controller under the GDPR. When handling personal data, we act as a data controller in terms of the GDPR when we ask you to submit your personal data that is necessary to ensure your access and use of CompareTV (e.g., when you sign up for a newsletter or communicate with us). In such instances, we are a data controller because we make decisions about the types of personal data that should be collected from the users and the purposes for which such personal data should be used. Therefore, we comply with data controller’s obligations set forth in the GDPR.
1.5. About CompareTV. CompareTV is an online platform, which provides consumers with an overview of third-party digital entertainment services (e.g., subscription and streaming television, music, gaming, broadband and mobile connection) available in their region. As a result, consumers can compare the services and choose the service provider that meets their needs best.
1.6. Applicable laws. We process personal data in accordance with applicable data protection laws, including, but not limited to, the UK Data Protection Act 2018, Australian Federal Privacy Act 1988, and the GDPR.
- If we are required by law to do so;
2. THE TYPES OF PERSONAL DATA THAT WE COLLECT
2.1. Types of personal data. We comply with data minimization principles and collect only a minimal amount of personal data that is necessary for ensuring your proper use of CompareTV:
- When you sign up for a newsletter, we collect your (i) name and (ii) email address.
- When you submit a comment under an article available on CompareTV, we collect your (i) name, (ii) email address, (iii) website, and (iv) any information that you decide to provide in your comment.
- When you contact us by email, we collect your (i) name, (ii) email address, and (iii) any information or personal data that you decide to provide us.
- When you use CompareTV, we collect your location information and may have access to your IP address.
2.2. Additional data. We may receive certain additional data when submitted through CompareTV if you participate in a focus group, contest, activity or event, request support, interact with our social media accounts, submit your feedback and reviews or otherwise communicate with us. Please note that the provision of such data is optional and you may choose what personal data you would like to share with us. We kindly request you to exercise your due diligence when making your personal data publicly available. We will use such personal data to reply to you, provide you with the requested services, or for pursuing our legitimate business interests (i.e., to analyse and improve our business).
2.3. Sensitive data. We do not collect any special categories of personal data (“sensitive data”) from you, such as your health information, opinion about your religious and political beliefs, racial origins, membership of a professional or trade association, or information about your sexual orientation, unless you decide to provide such sensitive data, at your own sole discretion.
2.4. Failure to provide personal data. If you fail to provide us with the personal data when requested, we may not be able to perform the requested operation and you may not be able to use the full functionality of CompareTV, receive the services provided through CompareTV, or get our response.
3. PURPOSES FOR WHICH WE USE PERSONAL DATA
|Personal data||Purpose||Legal basis|
When you sign up for a newsletter:
||To deliver the requested newsletter To update you about our and our partners’ new services||Your consent|
When you submit a comment:
||To feature your comment To contact you, if necessary To ensure security of CompareTV To improve CompareTV||Your consent Pursuing our legitimate business interests (to analyse, improve, and ensure security of our business)|
|When you contact us by email: Name Email address Any information or personal data that you decide to provide us in your message||To respond to your enquiries To provide you with the requested information||Pursuing our legitimate business interests (to grow and promote our business) Your consent (for optional personal data)|
|When you use CompareTV Location information IP address||To ensure that CompareTV is relevant for your location To analyse, improve, and evaluate our business activities||Performing a contract with you Pursuing our legitimate business interests (to analyse and improve our business activities)|
4. NON-PERSONAL DATA
4.1. Types of non-personal data. When you use CompareTV, we may automatically collect certain non-personal data about your use of CompareTV and your device for analytics purposes. Such non-personal data does not allow us to identify you in any manner. The non-personal data collected by us includes information about:
- The type of your device;
- Operating systems and browsers used by you;
- Your browsing patterns; and
- URL addresses of websites accessed from CompareTV.
4.2. Your feedback. If you contact us, we may keep records of any questions, complaints or compliments made by you and the response, if any. Where possible, we will de-identify your personal data. Please note that de-identified personal data is also considered to be non-personal data.
4.3. Purposes of non-personal data. We will use non-personal data in furtherance of our legitimate interests in operating CompareTV, conducting our business activities, and developing new products and services. More specifically, we collect the non-personal data for the following purposes:
- To analyse what kind of users visit and use CompareTV;
- To identify the channels through which CompareTV is accessed and used;
- To examine the relevance, popularity, and engagement rate of the content available on CompareTV;
- To investigate and help prevent security issues and abuse;
- To develop and provide additional features to CompareTV; and
- To personalise CompareTV for your specific needs.
4.4. Aggregated data. In case your non-personal data is combined with certain elements of your personal data in a way that allows us to identify you, we will handle such aggregated data as personal data. If your personal data is aggregated or de-identified in a way that it can no longer be associated with an identified or identifiable natural person, it will not be considered personal data and we may use it for any business purpose.
5. MARKETING COMMUNICATION
5.1. Marketing messages. After you sign up to receive our newsletter, we will send you marketing messages, such as newsletters, brochures, promotions and advertisements, informing you about our or our partners’ new services or new features of CompareTV. You will receive such marketing messages only if you have provided your express (“opt-in”) consent to receive marketing messages. Please note that your voluntary subscription to receive our newsletter constitutes such opt-in consent.
5.2. Opting-out. You can opt-out from receiving marketing messages at any time free of charge by clicking on the “unsubscribe” link contained in any of the messages sent to you or contacting us directly.
5.3. Informational notices. From time to time (if we have your email address), we may send you informational notices, such as service-related, technical or administrative emails, information about CompareTV, your privacy and security, and other important matters. Please note that we will send such notices on an “if-needed” basis and they do not fall within the scope of direct marketing communication that requires your prior consent.
6. RETENTION PERIOD
6.3. Retention as required by law. Please note that, in some cases, we may be obliged by law to store your personal data for a certain period of time. In such cases, we will store your personal data for the time period stipulated by the applicable law and delete the personal data as soon as the required retention period expires.
7. SHARING AND DISCLOSING DATA
7.1. Do we share your personal data? If necessary, we may disclose your personal data to the service providers with whom we cooperate and other third parties (our data processors). For example, we may share your personal and non-personal data with entities that provide certain technical support services to us, such as web analytics, data processing, advertising, and email distribution services, or if you explicitly request us to disclose the personal data.
7.2. When do we share your personal data? The disclosure of your personal data is limited to the situations when such data is required for the following purposes:
- Ensuring the operation of CompareTV;
- Ensuring the delivery of the services requested by you;
- Providing you with the requested information;
- Pursuing our legitimate business interests;
- Enforcing our rights, preventing fraud, and security purposes;
- Carrying out our contractual obligations;
- Law enforcement purposes; or
- If you provide your prior consent to such a disclosure.
|Hosting service provider||Amazon Web Services||United States||https://aws.amazon.com|
|Business analytics service provider||Google Analytics||United States||https://analytics.google.com|
|Email service provider||Campaign Monitor||United States||https://www.campaignmonitor.com|
|Form service provider||Gravity Forms||United States||https://www.gravityforms.com|
|Advertising and affiliate marketing partners||Google Ads Manager||United States||https://admanager.google.com|
|Google AdWords||United States||https://ads.google.com|
7.4. Sharing of non-personal data. We may disclose non-personal data and de-identified data for any purpose. For example, we may share it with prospects or partners for business or research purposes, for improving CompareTV, responding to lawful requests from public authorities or developing new products and services.
7.5. Legal requests. If necessary, we will to disclose information about the users of CompareTV, if requested by a public authority, to the extent necessary for pursuing a public interest objective, such as national security or law enforcement.
8. TRANSFER OF PERSONAL DATA OUTSIDE THE EEA
9.1. Our security measures. We put our best efforts to keep your personal data safe and secure. We implement organisational and technical information security measures to protect your personal data from loss, misuse, unauthorised access, and disclosure. The security measures taken by us include secured networks, limited access to your personal data by our staff, and anonymisation of personal data (when possible). In order to ensure the security of your personal data, we kindly ask you to use CompareTV through a secure network only.
9.2. Handling security breaches. Although we put our best efforts to protect your personal data, given the nature of communications and information processing technology and the Internet, we cannot be liable for any unlawful destruction, loss, use, copying, modification, leakage, and falsification of your personal data caused by circumstances that are beyond our reasonable control. In case a personal data breach occurs, we will immediately take reasonable measures to mitigate the breach, as required by the applicable law. Our liability for any security breach will be limited to the highest extent permitted by the applicable law.
10. PRIVACY OF CHILDREN
10.1. We do not allow anyone younger than 18 years old to use CompareTV. Thus, we do not knowingly collect personal data of persons below the age of 18. If you learn that anyone younger than 18 has unlawfully provided us with personal data and you are a parent or legal guardian of that person, please contact us and we will take immediate steps to delete such personal data.
10.2. To protect children’s privacy, we encourage parents and legal guardians to monitor their children’s Internet usage and instruct their children not to submit any personal data through CompareTV.
11. YOUR RIGHTS REGARDING PERSONAL DATA
11.1. What rights do you have? Individuals located in certain countries, including the EU, have certain statutory rights in relation to their personal data. You may ask us to:
- Get a copy of your personal data that we store;
- Get a list of purposes for which your personal data is processed;
- Rectify inaccurate personal data;
- Move your personal data to another processor;
- Delete your personal data from our systems;
- Object and restrict processing of your personal data;
- Withdraw your consent; or
- Process your complaint regarding your personal data.
11.2. How to exercise your rights? If you would like to exercise your rights, please contact us by email at firstname.lastname@example.org and explain in detail your request. In order verify the legitimacy of your request, we may ask you to provide us with an identifying piece of information, so that we would be able to locate you in our system. We will answer your request within a reasonable timeframe but no later than 2 weeks. Your requests can be submitted free of charge once per calendar year. If you submit your requests more than once per year, we reserve the right to charge a small administrative fee for providing the requested information.
11.3. How to launch a complaint? If you would like to launch a complaint about the way in which we handle your personal data, we kindly ask you to contact us first and express your concerns. After you contact us, we will investigate your complaint and provide you with our response as soon as possible (no later than 2 weeks). If you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.
12. THIRD-PARTY LINKS
12.1. CompareTV contains links to websites and digital entertainment services that are owned, operated and controlled by third-party service providers. Please be aware that we are not responsible for the privacy and security practices employed by such third parties. We encourage you to be aware when you leave CompareTV and read the privacy statements of each and every website or service that you access.
12.2. We advise you to carefully scan every link before clicking on it to ensure the link is not infected and free of any kind of virus or malware that can damage your operating system or device. Even if you did scan the links you should take extra safety and security precautions before accessing those links and carefully assess the security of the website or service that you intend to use.
13. TERM, TERMINATION AND AMENDMENTS
Postal address: CompareTV UK, Office 7, 35-37 Ludgate Hill, London, EC4M 7JN