Sky Privacy and Cookies Notice

• Information you've provided to us, including through our websites or when you access our services through applications on websites operated by other organisations.

• Information about our content, products and services you've ordered or enquired about, including call recordings, as further described below.

• Information which we acquire from other organisations, such as address verification services (e.g. Royal Mail in the UK), data brokers (e.g. Experian), property and lifestyle companies and credit reference agencies including personal data that is publicly available. We acquire data from several organisations including Dunnhumby, CACI, 20ci, Mastercard, Emma’s Diary, and Game that we use to enhance the household profiles we use within AdSmart (as described further below). If 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.

• Information, uploads, user generated content, and comments you make about, or generate, in accessing the shows, channels, programmes, advertisements, products and services you use, for example, how you or your household access, view, share, contribute to, communicate with, record or fast forward them.

• Information from the devices you use to receive Sky content, products and services, about you and your household's use of Sky, and/or third party content, products and services. This includes information about your device, machine or browser.

• IP address, MAC address, unique identification number, online identifier, browser information, location data port information, logical network address, and other similar identifying information required for your devices to communicate with websites and applications on the internet.

• Technical information from the devices you use to receive Sky content, products and services, for example, the collection of diagnostic and traffic or location information. Note that devices and applications have their own privacy settings and notices under which they collect your information, so please check and manage your device and application settings.

• Information relating to your customer service interactions with us. This includes your image from CCTV footage recorded when you visit a Sky Retail Store or other Sky locations.

The main purpose for which we process your personal data is so that we can, in accordance with the contract you have with us, provide you with content, products and services. This includes providing you with account management functionality (such as to update contact information), customer support (including diagnostics and trouble-shooting), call screening and blocking, and tailored and personalised recommendations (including by sending you newsletters about your service, content and relevant products.)

We also process your data to deliver services to you under our contract in the following ways:

• In order to enter into loan agreements with you, we obtain personal data about you from credit reference agencies. We then take automated decisions using that personal data about whether or not to enter into the loan agreement with you. This 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.

• In order to manage our products and services and traffic across our network. For example, Sky uses your information to facilitate the operation of its network by choosing the most efficient route to transmit your requests for a communications service through the various parts of its network of equipment and systems. This information is held securely within restricted areas, accessible only by authorised personnel and in accordance with our data retention, deletion and acceptable use policies;

• In order to send newsletters to you about your service, content and relevant products.

If you’re a Sky customer, where you give us consent, we will process your data in order to send you direct marketing. This may include communications by post, telephone, SMS, email or other electronic means, using the contact details you have provided, about us and our content products and services, events and special offers, including, for a reasonable time after you have ceased to be a customer of ours (see further details below). We also rely on your consent to process special category data (for example, data you have provided to us or to our business partners concerning your health).

We may also use your information to comply with our legal and regulatory obligations. This includes:

• by enabling Sky to support customers whose circumstances might make them vulnerable in order to comply with Ofcom’s consumer protection conditions; and
• by complying with police and other security investigations.

In some circumstances, we may process your personal data in reliance upon our legitimate interests, including to:

• Improve our content, products, services and customer experiences by monitoring your use of our products and services and working with our suppliers to improve the products and services we offer, and develop new content, products and services;

• monitor, record, store and use customer service communications we have with you. This helps us to improve the quality of our customer service, to confirm any instructions you give us, to create a customer profile to have better conversations and/or for training, development and to meet our legal and regulatory responsibilities.

• Determine what offers for our products and services you are eligible for and how those offers will be made available to you. To do this, we create a profile about your time as a Sky customer (for example, what products and services you have purchased, how you have used them, your offer and payment history, and your interactions with our customer service agents) and supplement this with information provided to us by other organisations as described in this notice. We use these profiles to target our offers at particular groups of customers and personalise the messages.

• In some cases we rely on legitimate interest to send you direct marketing – for example, if you’re a NOW TV customer, or a prospective customer. This may include communications by post, email or other electronic means, using the contact details you have provided, about us and our content, products and services, events and special offers, including, for a reasonable time after you have ceased to be a customer of ours (see further details below).

• Enable and deliver AdSmart. With AdSmart we show adverts within your TV services to the people most likely to be interested in the products and services being promoted. Sky can show different adverts to different households (in groups of 5,000 or more) 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 we have acquired from other organisations (as detailed in the section above ‘Types of information we process and where it comes from’), 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. As 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. More information about how AdSmart can be used by advertisers can be found here. To the extent any special category data (for example, data concerning health) is processed within AdSmart, Sky relies on your consent for such processing.

• Enable and deliver AdVance. With AdVance, we tailor the digital adverts that you see on Sky or 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. To do this, we process your household viewing data so we know what programmes you like and adverts you may have seen. We combine this with device information and (subject to your cookie preferences) information about websites you have visited to define groups of audiences to whom we deliver digital adverts. More information about how AdVance can be used by advertisers can be found at https://www.skymedia.co.uk/skyadvance/ and in the 'Use of your information for online and digital advertising' section below.

• For market research.

• protect or enforce our rights or the rights of any third party such as by analysing activity on our network to help block unauthorised or illegitimate content, publication of, or access to it.

We will process your data where we need to in order to safeguard your vital interests or those of another person, for example to support crime prevention and protect the safety of members of the public and Sky employees.

We work with a number of suppliers to process your personal data for the purposes described above. These suppliers act on our behalf and must only process your personal data in accordance with our instructions. The categories of suppliers that we use include:

• Engineer services firms

• Couriers

• IT companies

• Customer service centres

• Other Sky group companies (Information can be found here)

• Credit reference agencies (see further below);

• Warranty companies (see further below); and

• Data brokers. This includes Experian who we use to match Sky’s own data with data provided by brands in order to identify households to target for specific advertising campaigns (for example, using AdSmart).

  • For example, this data matching process could be performed on behalf of a supermarket that wants to target its television advertising at its existing customers who live near one of its stores.
  • The brand will receive back a report showing how successful the advertising campaign was (e.g. how many times their adverts were viewed), but will not receive information or data about specific households that have seen their adverts;

• Marketing companies that deliver our communications.

Sometimes we share personal data with suppliers and business partners who may process it outside of the European Economic Area. (for example, we use customer service centres in India and some IT services in USA). Most of the time the data we share will be with companies who supply services to us to enable us to supply our services to you. On occasion, we may share personal data with our parent company, Comcast Corporation, based in the US. We grant these companies access to personal data only where necessary and only where appropriate security measures and controls are in place to protect your personal data in accordance with applicable data protection laws, regulations and regulatory guidance. This means these transfers will take place on the basis of an approved data transfer mechanism, which are the EU-USA Privacy Shield, EU Standard Contractual Clauses and EU Commission Decisions on Adequacy (country details here).

One of Sky’s data processors (Domestic & General Insurance PLC and Domestic & General Services Limited) may contact you to ensure you are satisfied with your service experience and to let you know about the warranties that apply to your Sky equipment and the options for extended cover.

In the event the structure of our business changes so that another company in the Sky group provides our products and services to you, we will pass your personal information to that company. This includes, for example, a merger between us and another company, where another company acquires us or some or all of our assets, where we acquire another company or where our holding company restructures our corporate group.

We share your personal data with credit reference (e.g, Equifax) fraud prevention agencies (e.g. CIFAS) for use in automated credit decisions, for the detection and protection against crimes such as fraud and money laundering, and for debt recovery purposes, as further explained below. If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services or financing you have requested, or we may stop providing existing services to you. A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. Whenever fraud prevention agencies transfer your personal data outside of the European Economic Area, they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the European Economic Area. They may also require the recipient to subscribe to "international frameworks" intended to enable secure data sharing. CIFAS has published more information about data transfers.

We share personal data with the courts, enforcement agencies (e.g. the police) and with regulatory authorities (e.g., OFCOM in the UK) where this is required, in order for us to comply with our legal and regulatory obligations.

Where Sky receives a request for the ownership of a vulnerable customer’s account to be transferred to a nominated individual, personal data of the existing account holder may be shared with the new account holder. The ownership of the account would only be transferred once Sky has received signed acceptance and authorisation of the transfer from both parties.

We work with a number of trusted partners to process your personal data for online and digital advertising purposes on Sky and third party websites and apps. This is different to our AdSmart service (described above), which relates to the advertising you see within Sky's TV services. For online and digital advertising we use data like your IP address and device ID, which are required to serve advertisements to your device. We will never share your name, physical address or phone numbers with any of our trusted partners. We perform due diligence on our partners to ensure they will to handle your data in a secure and responsible manner. This processing is based on your acceptance of cookies on our and third party websites and your Sky ID preferences. The categories of partner that we work with include:

• Advertising agencies and advertisers, which buy advertising on Sky’s online and digital platforms so they can deliver targeted and tailored advertising and can measure which advertisements are clicked and other such results associated with displaying such advertisements; and

• Advertising platforms (e.g. Google, Rubicon, Unruly and Outbrain) which, with consent, deliver tailored and targeted advertising across Sky’s online and digital platforms on their own and/or other’s behalf using data from Sky. These advertising platforms enable Sky to offer its advertising space and manage use of that advertising space efficiently. Please select Privacy options in the footer of the Sky Sports or Sky News websites to manage your marketing preferences in relation to these third party advertising platforms.

Where our partners are based outside of the European Economic Area, we work with these 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 will only take place on the basis of an approved data transfer mechanism as described in the section ‘How we share your information’ above.

You can contact us via My Account on Sky.com or My Account for NOWTV or on 03442 414 141 (in the UK) or 0818 719 819 (in ROI), or by emailing boxofficesupport@sky.uk for Sky Box Office to update, amend, correct your information. You also have the following rights:

• To request access to, or erasure of, the personal data we hold about you.
• To request us to restrict the processing of the personal data we hold about you.
• To object to us processing personal data relating to you.
• Where you have given us consent to process your personal data, you have the right to withdraw that consent at any time.
• You have the right to obtain certain personal data from us in a format that can be transferred electronically to a third party (also called “data portability”).

Please note that some of these rights are not absolute. In some cases, for example, we may refuse a request to exercise particular rights if complying with it meant that we are no longer able to meet our contractual obligation to provide you with particular products and services, or if we had a legal obligation or right not to comply with the request. However, we will keep you informed as to the actions that we can take, when you make your request.

Direct marketing and tailored advertising

You can always choose not to receive direct marketing or tailored advertising (including AdSmart) from us in the following ways:

• Via My Account on Sky.com or My Account for NOW TV
• Clicking on the "unsubscribe" link or replying STOP in any electronic marketing information from us
• Calling Sky on 03442 414 141 (in the UK) or 0818 719 819 (in ROI) for Sky TV, Sky Broadband & Talk and Sky Mobile
• Emailing: optout@nowtv.com for NOW TV
• Emailing: preferences@nowtv.com for NOW TV
• Emailing: boxofficesupport@sky.uk for Sky Box Office

When you make a request not to receive marketing, it can take us up to one month to process that request. If you receive direct marketing from other Sky group companies (such as Sky WiFi) you can choose not to by contacting them directly.

Cookies and online behavioural advertising

Please see the section on "Controlling my Cookies" on how to adjust cookie settings for your devices.

Cookies are small bits of text that are downloaded via the internet to the devices you use to receive Sky content, products and services and access online information. Your browser on your device makes these cookies available every time you visit the website again, so it can recognise you and can then tailor what you see on your device.

Cookies are an important part of the internet. They make using devices and accessing online information much smoother and affect lots of the useful features of websites. There are many different uses for cookies, but they fall into four main groups.

Cookies that are needed to provide the content, product or service you have asked for

Some cookies are essential to help your devices download or stream the information, or so you can move around websites and use their features. Without these cookies, content, products or services you've asked for can't be provided.

Here are some examples of essential cookies:

• Positioning information on a smartphone screen, tablet device or other screen so that you can see the website and use its functionality.
• Keeping you logged in during your visit or enabling you to stream content. Without cookies, you might have to log in on every website you visit, or repeatedly adjust your volume and viewing settings.
• When you add something to the online shopping basket, cookies make sure it's still there when you get to the checkout.
• Some are session cookies which make it possible to navigate through the website smoothly.

Improving your browsing experience

Cookies allow the application or website to remember choices you make, such as your language or region, and they provide improved features.

Here are a few examples of some of the ways that cookies are used to improve your experience on our applications and websites:

• Remembering your preferences and settings, including marketing preferences, such as choosing whether you wish to receive marketing information.
• Remembering if you've filled in a survey, so you're not asked to do it again.
• Remembering if you've been to the application or website before.
• Restricting the number of times you're shown a particular online advertisement. This is sometimes called 'frequency capping'.
• Showing you information that's relevant to content, products or services that you receive.
• Giving you access to content provided by social-media sites like Facebook or Twitter.
• Showing 'related article' links that are relevant to the information you're looking at.
• Remembering an application or website you've entered, such as weather forecasts.

Analytics

We like to keep track of what websites, information and links are popular and which ones don't get used so much, to help us keep our information relevant and up to date. It's also very useful to be able to identify trends of how people navigate (find their way through) our information and when and where 'error messages' may originate.

This group of cookies, often called 'analytics cookies', are used to gather this information. The information collected is grouped with the information from everyone else’s cookies. We can then see the overall patterns of usage rather than any one person’s activity. Analytics cookies are used to improve how an application, a website and its pages work.

Our applications, web locations, websites and communications you get from us contain small invisible images known as 'web beacons' or ' pixels'. These are used to manage the interaction between you and the online information or email and allow us to assess the effectiveness of the communication.

Affiliate cookies

We use 'affiliate' cookies. Some of our web based information will contain promotional links to other companies’ sites. If you follow one of these links and then register with or buy something from that other site, a cookie is used to tell the other site that you came from one of our sites. That other site may then pay us a small amount for the successful referral. For more information, see the Internet Advertising Bureau's guide about how affiliate marketing works. Note that when you visit those other companies’ sites, they will have their own privacy notices which set out what personal data they collect and how they will use it.

Our advertising and marketing partners use cookies and similar technologies to :

• Tailor to your interests the adverts and content you see on our own and third party sites and apps.
• Limit the number of times you see the same advert or content.
• Measure the effectiveness of adverts and content you’re shown, including where and how often they’re shown and any action you took in relation to them.

The information our partners collect and share through these cookies does not directly identify you. It does not include your name or address or personal contact details like your email address of phone number. Instead they collect and share your IP address, online identifiers such as device IDs, and information about your browsing habits which can be used to make inferences about your interests.

When you access sky.com or our Sky News and Sky Sports sites and apps for the first time you will be asked to set your preferences for the use of these cookies on those sites and apps. After that you can use the Privacy Options link (e.g. in the site footer) to manage those preferences. There you can also find out more information about our partners. If you turn these cookies off you will still see adverts, but they are less likely to be of interest to you. Please note that you are not yet able to set your preferences for all our advertising and marketing partners. We will be adding the remainder soon and when we do we will ask you to set your preferences again.

If you want to know about data collected by third parties when you click on their adverts, you should check their privacy notices to find out what they collect, how they process it and what they use it for.

It’s easy to choose not to receive behavioural advertising and manage your cookies, if you want to.

How can I see and manage my cookies in my browser?

Virtually all modern browsers allow you to see what cookies you've got, and to clear them individually or clear all of them. To find out how to do this, go to aboutcookies.org, which contains comprehensive information on how to do this on a wide variety of desktop browsers.

When you access Sky.com, or our Sky News and Sky Sports sites and apps for the first time, you will be asked to set your preferences for the use of these cookies on those sites and apps. After that, you can use the Privacy Options link (in the site footer) to manage those preferences. There you can also find out more information about our partners. If you turn these cookies off, you will still see adverts, but they are less likely to be of interest to you. Please note that you are not yet able to set your preferences for all our advertising and marketing partners. We will be adding the remainder soon and when we do, we will ask you to set your preferences again.

How can I choose not to receive Online Behavioural Advertising and other tracking cookies?

In addition to the controls available on your computer, there are other ways of choosing not to receive Online Behavioural Advertising and other tracking cookies.

Please note that most of these choices work by setting a cookie that overrides the behavioural advertising cookie. If you clear all your cookies, you will also clear these opt-out cookies, therefore changing your preferences. In this instance you would need to choose again.

Organisations which provide more information on Online Behavioural Advertising

• Evidon is a provider of privacy solutions.

• Internet Advertising Bureau (IAB) “Your Online Choices” page allows you to choose not to receive behavioural advertising from each of the advertising networks represented by the IAB.

• Network Advertising Initiative (NAI) opt out page allows you to choose not to receive behavioural advertising from each of the ad networks represented by the NAI.

• Digital Advertising Alliance’s self-regulatory program for online behavioural advertising choices page.