Last updated: April 4, 2024
Your privacy is important to us. This Privacy Notice explains what personal data Everyone TV Limited ("Freely", “we”, “us” and “our”) collect about you (“you”) and what we do with it. It also explains how you can exercise your privacy rights.
This Privacy Notice only applies to personal data that we collect through (or relating to) your use of:
- our Freely App (the "App") in the UK, the Isle of Man, Jersey and Guernsey.
- our websites which are www.everyonetv.co.uk, and www.freely.co.uk (our “Websites”).
- our Everyone TV and Freely advice lines, and our Facebook, Instagram, X (Twitter) and consumer help channels which you may use to find out more about or troubleshoot/report an issue.
To find out more, please continue reading or click on the link below to jump to the section you are interested in. We recommend that you read this Privacy Notice in full to ensure you are completely informed about your personal data.
Contents
Top
- What personal data do we process about you?
- How do we use your personal data for our purposes and what are our legal basis for processing it?
- Who do we share your personal data with?
- How is your personal data kept secure?
- Is your personal data transferred to other countries?
- What cookies and similar technologies do we use?
- How long do we retain personal data for?
- What are your data protection rights?
- Links to other websites
- Changes to this Privacy Notice
- How to contact us
If you have any questions or concerns about our use of your personal data, then please contact us using the contact details under the “How to contact us” heading below.
What personal data do we process about you?
- Information that you provide directly
Freely App
Where you interact with us via customer service communications regarding the App, we collect personal data that you provide, such as any information about your identity and contact details (Identity and Contact Data) and any details of your enquiry/communication (Enquiry Data).
Our Websites and Social Media
We may collect personal information that you provide to us voluntarily when visiting our Websites. This includes, for example, information you provide when you sign up to our newsletter, personalised TV Guide, when you participate in discussion boards or Freely social media functions, or when you enter competitions.
- Information that we process and/or access automatically
We process your personal data through automated means from your device when you set up and use the App or interact with our Websites. This data will either be stored on your device or in the cloud. Specifically, the information we collect automatically will include:
Freely App
- Freely Device ID: When you install the App, we create a "Freely Device ID" and store it on your device.
- CP Device IDs: From the Freely Device ID, we create "Content Provider Device IDs" (also known as "CP Device IDs"), which are different IDs for your device created specifically for and shared with each content provider such as the BBC, ITV, Channel 4 and Channel 5. In general, we create a unique CP Device ID per content provider. Only Freely would be capable of linking each CP Device ID back to the Freely Device ID.
- Device Information: We process a "user-agent string" which tells us the following information about your device: the type of device, device name and device variant.
- Network Data: which content delivery network (CDN) is used by your device (i.e. which a network of servers is being used.
- Error Data: Reported errors in and relating to the app.
- IP Address
- Navigational Behaviour (collected against the NGP Device ID): for example which parts of the App have been visited by the device user and where the device user has clicked)
- Linear viewing data: specifically the channel(s) watched, the programme(s) watched, programme viewing start/end times and viewing duration
- Region of the device: the region your device is located in (most regions are very large such as London, with the smallest region being a 10,000 household town
Our Websites
Specifically, the information we collect automatically may include information like your device type, any unique device identification numbers, browser-types, your broad geographic location (e.g. country or city-level location) or your specific device location if you grant us permission via your location settings, your IP address, the identity of your internet service provider, the name and version or your operating system and other technical information. We may also collect information about how your device interacts with our Websites, including the pages accessed and links clicked.
Collecting this information enables us to provide you with content that is relevant to your region, to better understand the visitors to our Websites, the number of visitors, where they come from, what content on our Websites is of interest to them, the average time spent on the Websites, and to personalise the content or advertisements we show on our Websites. We may use information we hold about your previous visits to our Websites, your engagement with marketing emails you receive from us or advertising shown to you previously on search engines or social media, to tailor the ads you see on our website or on third party platforms.
We use this information for our internal analytics purposes and to improve the quality, relevance and personalised nature of the content of our Websites to our visitors and for serving and measuring marketing and advertising.
We may collect some of this information automatically through the use of cookies and similar tracking technologies. For more information, please see the heading below "What cookies and similar technologies do we use?"
We do not collect or infer any sensitive personal data about you, such as health-related information or information about your race or ethnicity, or sexual orientation.
It is necessary to process certain data for the performance of our contract with you. If you do not provide this data, then we will not be able to perform a contract with you.
How do we use your personal data for our purposes and what are our legal basis for processing it?
We use the personal data that we collect from and about you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your information. Depending on our purpose for collecting your information, we rely on one of the following legal bases:
- Contract – we require certain personal data in order to facilitate the streaming/serving of channels requested via the App;
- Legitimate interests – we will use or disclose your personal data for our legitimate interests or those of a third party, but only when we are confident that your privacy rights will remain appropriately protected and are not outweighed;
- Consent - We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to our marketing newsletters.
Purposes Table:
The following table provides more details on our purposes for processing your personal data and the related legal bases. The legal basis under which your personal data is processed will depend on the data concerned and the specific context in which we use it. To see the data types included in each category of personal data listed below, see the "What personal data do we process about you" section above.
| Purpose/Activity | Type of personal data | Lawful basis for processing including basis of legitimate interest |
| Provide and maintain the App and its functionality and ensure user security: To administer and maintain our App and our IT systems (including monitoring, troubleshooting, data analysis, testing, system maintenance, repair and support, reporting and hosting of data, as well as ensuring user security). For example, to quantify platform use (to support the appropriate scaling of supporting infrastructure and maintain quality of service) and to support the investigation and diagnosis of issues, it is essential for ETV to collect Freely Device IDs (to accurately measure use and identify repeated faults with specific devices) and IP addresses (to localise issues to a specific regions of the UK or ISPs). |
Freely Device ID CP Device IDs Device Information Network Data Error Data IP Address Region of the device Navigational Behaviour Linear viewing data |
|
| Freely Analytics: Undertaking first-party analytics to understand the number of users of the App and to improve performance of the App (for example to establish whether the App is delivering valuable experiences to users and to establish whether the service is user-friendly and users can navigate to the services/features they want. |
Freely Device ID CP Device IDs Region of the device Navigational Behaviour Linear viewing data |
|
| Identifying the device to Content Providers to authorise the provision of an IP linear stream: This involves sending a Freely Device ID and data about the start/end of the stream to the relevant content provider in order to authorise the provision of the content you have chosen to watch. |
CP Device IDs Linear viewing data |
|
| Responding to your communications: Responding to your communications regarding the App (including your enquiries, requests or complaints). |
Identity and Contact Data Freely Device ID CP Device IDs Region of the device Navigational Behaviour Linear viewing data |
|
| Legal compliance: Comply with legal and regulatory obligations to which we are subject, including our obligations to respond to your requests under data protection law. |
Identity and Contact Data Freely Device ID CP Device IDs Region of the device Navigational Behaviour Linear viewing data |
|
| Protect our legal rights: Including where necessary, to share information with law enforcement and others. For example to defend claims against us and to conduct litigation to defend our interests. |
Identity and Contact Data Freely Device ID CP Device IDs Region of the device Navigational Behaviour Linear viewing data |
|
| Marketing and Service communications: If you sign-up to receive marketing communications from Freely, for example via the website, through a promotion or when taking part in a competition. Also for service emails. |
Name Email Address TV viewing preferences Engagement metrics (Open rate) Click through rate, unsubscribe) |
|
| Website Performance: We use website analytics to monitor the service and our performance levels for statistical purposes; such as aggregated information about how you anonymously navigate around our Websites, which pages or functionality is visited, used or unused. We also use your postcode (if you choose to provide it) to display your regionalised channel listings within the Freely TV Guide on the Website. |
IP address (masked) Browser type Device type Page views Session duration Engaged sessions Bounce rate Click through rate Conversion rate Traffic source Postcode |
|
| Personalising content or advertisements We may use information we hold about your previous visits to our website, your engagement with marketing emails you receive from us (unless you have told us you do not wish to receive emails) or advertising shown to you previously on search engines or social media, to personalise content and/or tailor the ads you see on our website, in marketing emails or on third party platforms. |
Email Address Viewing preferences and interests Engagement with marketing emails (Open rate; Click through rate; unsubscribe) Engagement with our Websites (Browser type; Device type; Page views; Session duration; Engaged sessions; Bounce rate; Click through rate; Conversion rate; Traffic source) Engagement with onsite and offsite ads (Clickthrough rate and impressions). |
|
Who do we share your personal data with?
We share your personal data with the following categories of recipients:
- our group companies, who provide data processing services necessary to provide you with our goods and services (for example, to support the delivery of, provide functionality on, or help to enhance the security of our App), or who otherwise process personal data for purposes described in this Privacy Notice.
- third party service providers and partners who provide data processing services to us as necessary to provide you with our goods and/or services (to support the delivery of, provide functionality on, or help to enhance the security of our App), or who otherwise process personal data for purposes described in this Privacy Notice. The following table lists the main third party service providers we engage to process your personal data, the categories of services they provide, and the types of personal data they receive in order to provide us these services;
| Service Provider | Services | Personal data |
| YouView TV Ltd | Technical support services for the App. | All categories of personal data listed in the "What personal data do we process about you" section above. |
| Braze Customer Engagement | Customer relationship management platform for Editorial and Service emails, In-browser messaging, Web Push notifications, in-app and mobile push notifications | All metrics listed in “Marketing and Service Communications” in the Purposes table. |
| Meta (Facebook and Instagram) | Social media retargeting and audience prospecting, as well as blacklisting if you have opted out of marketing | Email address (hashed) |
| SearchAds360 (Google and Microsoft Ads) | Paid Search retargeting and audience prospecting as well as blacklisting if you have opted out of marketing | Email address (hashed) |
- Content Providers such as (the BBC, ITV, Channel 4 etc) we share your personal data with content providers as set out above in the Purposes Table.
- any competent law enforcement body, regulatory, government agency, court or other third party (such as our professional advisers) where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
- any potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal data only for the purposes disclosed in this Privacy Notice; or
- any other person with your consent to the disclosure (obtained separately from any contract between us).
How is your personal data kept secure?
We use appropriate technical and organisational measures to protect the personal data that we collect and process about you. The measures are designed to provide a level of security appropriate to the risk of processing. Specific measures we use include keeping your personal information on secure servers and computer systems, protected from outside intrusions.
We also take measures to require third parties with whom your personal information is shared in accordance with this Privacy Notice have in place appropriate security measures and do not process your personal information for unauthorised purposes.
Is your personal data transferred to other countries?
For the most part your personal data will be stored in the UK or in the European Economic Area ("EEA"). Specifically, we operate out of the UK and our technical service provider YouView will host their software services in third party cloud infrastructure in Ireland or on occasion in other data centres in the EEA.
In some cases, where your personal data is transferred to third parties, it is processed in countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).
Where we transfer your personal data from the UK to countries and territories outside of the UK, which have been formally recognised as providing an adequate level of protection for personal data, we rely on the relevant “adequacy regulations" from the Secretary of State in the UK.
In particular, we transfer personal data in reliance on the Secretary of State's adequacy regulations for transfers to territories in the EEA.
Where we transfer your personal data from Guernsey, Jersey or the Isle of Man to countries and territories outside of these and the EEA, which have been formally recognised as providing an adequate level of protection for personal data, we rely on the UK “adequacy findings" from the European Commission.
What cookies and similar technologies do we use?
We use cookies and similar tracking technologies (collectively, "Cookies") on our Digital Properties to collect and use personal information about you. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our cookie statement.
How long do we retain personal data for?
We retain the personal data we collect from you where we have an ongoing legitimate business need to do so. Such legitimate business interests include for example, to deal with any requests made by you, to provide you with any help you have requested, or to comply with applicable legal, tax or accounting requirements.
In certain circumstances, we are required to retain your information for legal reasons after you have deactivated the Freely App. We will maintain your information for a standard retention period of 2 years, irrespective of the specific legal circumstances. This applies to various scenarios, including but not limited to:
- Complying with legal obligations: For instance, if we receive a court order concerning your personal data, we will retain your data for the 2-year period.
- Resolving requests and complaints: If there is an ongoing issue or complaint related to the App, your information will be kept for this duration to effectively address and resolve these matters.
- Protecting individual rights and property: As an example, information regarding a data subject access request will be retained for 2 years after addressing the request, to assist in handling any subsequent complaints and to demonstrate the response to the request.
- Handling litigation or regulatory matters: In cases where your information is relevant to an ongoing legal claim or regulatory inquiry, it will be retained for the 2-year standard period.
This 2-year retention period is a part of our commitment to responsible data management, ensuring that your information is handled appropriately while also respecting legal and regulatory requirements.
When we have no ongoing business need or legal reason to process your personal data, we will either delete or anonymise it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.
What are your data protection rights?
Individuals located in the UK and EEA have the following data protection rights. To exercise any of them see specific instructions below or contact us using the contact details provided under the “How to contact us” heading below.
- You may access, correct, update or request deletion of your personal data.
- You can object to processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data, (i.e. your data to be transferred in a readable and standardised format.
- You have the right to opt-out of marketing communications we send you at any time.You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), please contact us using the contact details provided below.
- You have the right to complain to a supervisory authority about our collection and use of your personal data. For more information, please contact your local supervisory authority. Contact details for the UK's ICO are here; for Guernsey's Office of the Data Protection Authority (ODPA) are here; for Jersey's Office of the Information Commissioner (JOIC) are here; and for the Isle of Man's Information Commissioner are here. Certain supervisory authorities may require that you exhaust our own internal complaints process before looking into your complaint.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
Links to other websites
The App may contain links to sites or applications operated by other entities, such as those of content providers. We do not control the privacy policies or the terms of use of the websites or applications reached through the links from the App. These may differ from this Notice and terms of use of the App. Ensure you check the relevant Privacy Notices of any third party so that you understand how they will use your data to determine if they are acceptable to you.
Changes to this Privacy Notice
We may update this Privacy Notice from time to time in response to changing legal, regulatory, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you (typically via notifications or banners), consistent with the significance of the changes we make.
You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice. You are advised to visit the Notice on a regular basis to stay informed of our current privacy practices.
How to contact us
If you have any questions or concerns about our use of your personal data, please contact us using the following details: by email to: [email protected] or post to: Legal Department, Everyone TV, Triptych Bankside (North Building), 185 Park Street, London SE1 9BL.
The data controller of your personal data is Everyone TV Limited, which is registered with the Information Commissioner's Office with registration number Z9156270.