Privacy Policy

Privacy Policy

05/02/2019 at 10:23Updated 03/03/2020 at 10:17

We are Dplay Entertainment Limited. We provide a range of free and paid-for content services, such as Eurosport and Eurosport Player.

This is the privacy policy for the Eurosport Player and Eurosport websites, and the Eurosport Player and Eurosport applications made available on certain mobile phones and other connected devices (together, the "Services"). Please read this privacy policy carefully.

We are based in the United Kingdom. Our company details are set out in section 1 below.

We respect your right to privacy. Our overall aim is to ensure that our collection and use of personal information is appropriate to the provision of the Services to you, and is in accordance with applicable data protection laws.

This privacy policy describes the following important topics relating to your personal information:

1. Who we are

2. Children

3. The personal information we collect about you

4. How we store and use your personal information

5. How we share your personal information and who we share it with

6. International transfers

7. Cookies and similar technologies

8. Security

9. Data Retention

10. Your rights

11. Marketing

12. Third party sites

13. Changes to this privacy policy

14. Complaints, queries and suggestions

1. Who we are

We are Dplay Entertainment Limited, registered in England with company number 09615785 whose registered office is at Chiswick Park Building 2, 566 Chiswick High Road, London W4 5YB, United Kingdom (“Dplay”) and we are the data controller of the personal information that we collect from you.

If you are accessing our Services in Germany, then our Services are operated by JOYN GmbH, Landsberger Straße 110, 80339 Munich, Germany.

2. Children

We do not and will not knowingly collect information from any unsupervised child under the age of 16. Our Services are not directed at children and we do not knowingly collect any personal information from children.

3. The personal information we collect about you

Information from your online interactions

We collect the following information from your interaction with the Services:

  • how you access our Services and the devices that you use to access our Services. This includes collecting unique online identifiers such as IP address, login data, screen names, social media handles and user IDs, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Services; and
  • information about how you use the Services, including but not limited to your video consumption and playback, your favourites, sign-in and sign-out, playback error and browsing information.

Information that you share with us

When you submit personal information to us through data entry fields on our website or app, we may collect the following information from you:

  • your name and contact details (including your postal address, email address and phone number);
  • your age, gender and date of birth;
  • any email communications, including attachments, which you send to us;
  • where you are purchasing services from us, your payment information including cardholder name, billing address and payment card details if you pay by debit or credit card (or your PayPal, iDeal, Apple or Google identification tokens if you pay using one of these methods) and information about the transactions such as the products or services purchased;
  • your marketing preferences;
  • your entry into a competition (including the entry itself which may be a photo, comment or answer to a question);
  • your favourite sports, teams and athletes, if you enter this information in your account; and

profile data including your username and password for registering an account, purchases or orders made by you, your interests, favourites and preferences.

Third parties or publicly available sources

We may receive personal information about you from various third parties as set out below:

  • technical data from the following parties:

- analytics providers based inside and outside the EU, such as Adobe Analytics;

- advertising networks based inside and outside the EU, such as FreeWheel; and-

- data management platform providers based inside and outside the EU, such as Adobe Audience Manager.

For further information about how each of these parties collect and use your data, please see the 'Third-Party advertising companies' section below;

  • identity and contact data from data brokers, aggregators and publicly available sources;
  • contact, financial and transaction data from providers of technical, payment and delivery services; and
  • third parties that provide certain services to us within the Services, for example, facilitating and administering customer feedback forms and newsletter subscriptions.

4. How we store and use your personal information

We store and use your personal information for the following reasons:

  • it is necessary in order for us to fulfil a contract that we have with you;
  • it is required in our legitimate interests;
  • it is required in order for us to comply with our legal obligations; or
  • it is permitted because you have provided your consent to us.

Where we need to collect personal information by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (in this case, to provide you with the Services). In this case, we may have to cancel the Services but we will notify you if this is the case at the time.

Necessary for us to fulfil our contract with you

  • creating your account;
  • managing your account and providing any Services that you request or purchase;
  • administering the Services and processing your payment where you are purchasing Services from us (including but not limited to using third party service providers to process such payment);
  • contacting you to notify you of any prize won by you in one of our competitions by using the contact information that you provided when entering the competition and using your address to send your prize to you.

Our legitimate interests

Sometimes, our use of your personal information is for purposes which are ancillary to the provision of the Services. In those circumstances, we believe we have a legitimate interest in handling your personal information, and believe that the benefits of this storage and use of your personal information will outweigh any potential impact on you and not unduly prejudice your rights or freedoms. The relevant circumstances are:

  • detecting and preventing fraud;
  • keeping our Services, products and IT systems secure;
  • optimising our own processes, procedures and systems;
  • analysing and enhancing the information that we collect;
  • analysing your video consumption, playback and general viewing habits in order to recommend content to you, understand viewership and update and improve our Services, including but not limited to our content, features, scheduling, technology and products;
  • determining the effectiveness of our promotional campaigns and advertising;
  • using IP addresses and device identifiers to identify the location of users and block any unauthorised users and to ensure that we serve you with the correct content based on your location (e.g. where we only have rights to show certain content in certain jurisdictions);
  • dealing with your enquiries and requests (for example if you were to contact customer services to ask for help and assistance then we would need to process your contact details);
  • suggesting similar products to you that you may be interested in and to understand which products appeal to our customers;
  • using information submitted for a competition to analyse how our subscribers use our Services; and
  • where you have opted out of our marketing or objected to receiving emails from us, then we need to keep records of your preferences to ensure that we do not contact you if you have asked us not to.

If we rely on our (or another person's) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person's) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information.

When you have provided consent to us

We explain our use of your personal information for marketing purposes and the circumstances in which we need your consent to do so in the ‘Marketing’ section below.

For legal reasons

We will use your personal information in order to comply with our legal obligations. These obligations include:

  • if you have a paid subscription to use the Services and live in the European Union (the "EU"), we are legally required to allow you (and you are legally entitled) to watch the Services when you're visiting another country in the EU provided that we have verified your country of residence. We use personal information (usually, your IP address and/or your payment card information) to verify your country of residence;
  • us complying with our legal obligations; and
  • if we are required by regulatory bodies or law enforcement agencies to share your personal information with them.

Anonymous data

We collect anonymised details about visitors to our website for the purposes of aggregating statistics or reporting purposes. However, no single individual can be identified from the anonymised details we collect for these purposes.

Third-party advertising companies

We want to make sure that our advertising and marketing is relevant and interesting to you and our other users. To achieve this, we use third-party advertising and technology companies to serve ads and/or provide aggregated data to assist in serving ads when you visit or use our Services. This may include third-party technology companies which collect data about you in order to build a profile of your preferences based on your activities when you visit or use our Services. We may also use these companies to automatically collect data from you when you use our Services in order to help us identify the ads that are served to you and what you do after seeing those ads. In addition, we also share data with providers of web analytics tools, such as Adobe, which we use to analyse your use of the Services.

We might also share your data with social media or other similar platforms, so that you and other people can see relevant content on that platform. For example, we may use the Facebook Custom Audiences service and share your email address in a protected format with Facebook so that we can: include you in a custom audience that we will serve relevant advertising content to on Facebook; or create an audience of other Facebook users based on the information in your Facebook profile.

5. How we share your personal information and who we share it with

We disclose information under the following circumstances:

  • Third-party service providers: When we share information with third-party service companies to facilitate or to provide certain services on our behalf. This will include:

- IT infrastructure companies that facilitate our provision of the Services to you;

- Third parties who provide first level customer support on our behalf such as Zendesk who assist us in providing customer services;

- IT support service providers;

- payment service providers such as Adyen or PayPal who will process your subscription payments on our behalf; and

- other third-party service providers, for the purpose of providing or tracking our customers' use of the Services (such as Adobe, Conviva and Google).

These companies are authorised to use your personal information only as necessary to provide these Services to us and in accordance with our instructions.

  • Group companies: We may provide your personal information to our subsidiaries or affiliated companies for the purpose of processing personal information on our behalf to provide the Services to you. These parties are required to process such information based on our instructions and in accordance with this privacy policy. They do not have any independent right to share this information.
  • Compliance with laws and legal proceedings: When we respond to court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. When we believe in our sole discretion it is necessary to share information in order to investigate, prevent or take actions against illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Use, or as otherwise required by law.

Merger or acquisition: When we need to transfer information about you if we are acquired by or merged with another company. If we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified afterwards via email and/or a prominent notice on our Services of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Social media platforms: We include features on our Services which allow you to easily share our content with other people or render public your viewing or appreciation of such content by clicking on social media sharing buttons such as Recommend (Facebook, Google+), Tweet (Twitter) or Send by email. Even if you do not use social media share buttons when using our Services, the social networks that provided the buttons can identify you through them. Indeed, the mere fact that your account with a social network is activated on your device (open session) when you use our Services, can allow that network to monitor your navigation of our Services. Our use of those features means that we will share certain personal information with Facebook and Twitter, and they will share certain personal information with us. Any subsequent use of your personal information by Facebook or Twitter will be governed by its own privacy policy, which you should read carefully. We cannot be responsible for any personal information about you that is collected and stored by those third parties.

6. International transfers

If you are located in the EU then we may transfer personal information that we collect from you to third party data processors located in countries that are outside of the European Economic Area ("EEA") (including to the United States) or to members of our group of companies in connection with the above purposes. Please be aware that countries which are outside the EEA may not offer the same level of data protection as the EEA, although our collection, storage and use of your personal information will continue to be governed by this privacy policy.

When transferring personal information outside the EEA, we will:

  • include the standard contractual data protection clauses approved by the European Commission for transferring personal information outside the EEA into our contracts with those third parties (these are the clauses approved under Article 46.2 of the General Data Protection Regulation ("GDPR"); or
  • ensure that the country in which your personal information will be handled has been deemed "adequate" by the European Commission under Article 45 of the GDPR; or
  • (where appropriate when we are transferring your personal information to a recipient in the US) ensure that the recipient is part of the Privacy Shield which requires them to provide similar protection to any personal information shared between Europe and the US.

7. Cookies and similar technologies

Technologies such as cookies, beacons, tags and scripts are used by us and our partners, affiliates, or analytics or service providers. These technologies are used in analysing trends, administering the Services, tracking users’ movements around the Services and to gather demographic information about our user base as a whole. We receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

We use cookies, for example, to remember users’ settings (e.g. language preference) and for authentication. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our Services, but your ability to use some features or areas of our Services may be limited. We are working on a new tool which will give you more control over our use of these technologies; we will make you aware once we have implemented that tool.

8. Security

Whilst we take appropriate technical and organisational measures to safeguard the personal information that you provide to us, no transmission over the Internet can ever be guaranteed secure. Consequently, please note that we cannot guarantee the security of any personal information that you transfer over the Internet to us.

We are committed to protecting your personal information using appropriate technical and operational measures such as access controls that restrict and manage the ways in which your personal information is stored and handled.

9. Data Retention

We will retain information (including personal information) for as long as we need to use it for the reasons set out in this privacy policy. We will delete information relating to a paid subscription 5 years after your subscription ends if you do not have a live and valid entitlement to our Services and you have not logged into your account for 5 years except where we need to keep any personal information to comply with our legal obligations, resolve disputes, or enforce our agreements.

In some circumstances, we may anonymise your personal information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

10. Your rights

You have certain rights in relation to your personal information.

You have the right to request that we provide access to any personal information we hold about you. You can access your personal information at any time by clicking the ‘Access my data’ link in the ‘Personal Data’ section of the ‘Account’ area of the site. If you would like more information about how we use your personal information and protect your privacy, please click on the ‘Information about my data’ link which can also be found in the ‘Account’ area of the site. Alternatively, you can contact our Data Protection Officer and customer services team using the details set out below.

You also have the right to request that we:

  • update any of your personal information which is out of date or incorrect;
  • delete any personal information which we are holding about you;
  • restrict the way that we process your personal information;
  • prevent the processing of your personal information for direct-marketing purposes;
  • provide your personal information to a third party provider of services;
  • provide you with a copy of any personal information which we hold about you; or
  • consider any valid objections which you have to our use of your personal information.

If you are a French resident then you have the right to provide us with instructions on the management (e.g., retention, erasure and disclosure) of your personal information after your death. You can change or revoke your instructions at any time.

We will consider all such requests and provide our response within a reasonable period (and in any event within any time period required by applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances.

If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.

If we delete any personal information which we are holding about you, this deletion may only relate to the Services and not any other service provided by us in other jurisdictions. You should make requests for each account that you may have set up to access the Services or any other service provided by us.

11. Marketing

We will collect and use your personal information for undertaking marketing by email.

For Eurosport Player subscribers, historically (prior to 17 September 2019) we obtained your prior opt-in consent to send you marketing and we will continue to respect your preference when sending email communications. If you have subscribed to Eurosport Player since 17 September 2019, we will send you certain marketing communications (including electronic marketing communications) if it is in our legitimate interests to do so for marketing and business development purposes and you have not to date opted-out of receiving these communications. (As explained below, if you have not to date opted-out of receiving these communications from us, you are able to opt out at any time.)

If you register a Eurosport account or purchase a Eurosport Pass on Eurosport, we obtain your prior opt-in consent to send you marketing.

We will always obtain your consent to direct marketing communications where we are required to do so by local law. We will also obtain your consent if we intend to disclose your personal information to any third party for such direct marketing communications.

12. Third party sites

The Services contain links and pages to other websites operated by third parties. Please note that this privacy policy applies only to the personal information that we collect through the Services and we cannot be responsible for personal information that third parties may collect, store and use through their website. You should always read the privacy policy of each website you visit carefully.

13. Changes to this privacy policy

This privacy policy was last updated on 1 February 2020.

Please check back regularly to keep informed of updates to this privacy policy. Where we make significant changes to this privacy policy, and we have your email address, we will send you notification of the changes.

14. Complaints, queries and suggestions

In the EEA, you may also make a complaint to our supervisory body for data protection matters (the Information Commissioner's Office in the UK) or seek a remedy through local courts if you believe your rights have been breached.

You have the right to lodge a complaint with local data protection authorities in the EEA if you believe we have not complied with applicable data protection laws. The local authority differs depending on the country. Please see the Annex for your local data protection authority.

Annex

List of data protection authorities (EEA countries)

You have the right to lodge a complaint with local data protection authorities in the EEA if you believe we have not complied with applicable data protection laws.

The local authority differs depending on the country. Please see below for details of the local data protection authorities in the EEA countries in which we operate.

France
Commission Nationale de l'Informatique et des Libertés - CNIL
3 Place de Fontenoy - TSA 80715
75334 PARIS CEDEX 07
Tel. +33 1 53 73 22 22
Fax +33 1 53 73 22 00
Website: http://www.cnil.fr/

Germany