We do not knowingly collect data from individuals who are under the age of 13. You must be at least 13 years old to use our Platform. Individuals under the applicable age may use our Platform only through a parent or legal guardian's account and with their involvement. If you are a parent or legal guardian who believes your child has provided data to us without your consent, you may ask us to delete such information by emailing your request to: email@example.com
COLLECTING YOUR DATA
To create an account, you must provide your full name, a valid email address and password.
Account holders may create a profile and upload content such as videos, text and photographs to the Platform. As well as this content, we also collect associated metadata such as titles, descriptions and tags. Your profile may display information about you and your activities. Including: photos, videos, audio and text.
Technical data we collect about you
We automatically collect through Google Analytics certain types of data when you use our Platform, regardless of whether you are an account holder. This data includes your IP address, technical information about your device (e.g., browser type, operating system and basic device information), cookies, the web page you visited or search query you entered before reaching us, and your activities.
HOW WILL WE USE YOUR INFORMATION?
We and our authorised third parties will only process your personal information where we have legal grounds to do so. The legal grounds for processing differ depending on which of our content and services you use. Generally, we’ll only process your data on the following grounds:
- you have given consent for the processing. When we rely on consent to process your personal information, you always have the right to withdraw this consent;
- the processing is necessary for the performance of a contract to which you are a party (including the terms and conditions of the relevant product/service);
- the processing is necessary in order to take steps at your request prior to entering into a contract;
- the processing is necessary for compliance with a legal obligation placed on 66 of Us (for example our obligation to ensure that the data we hold is accurate);
- the processing is necessary for the purposes of the legitimate interests pursued by 66 of Us or by a third party. For example, we have a legitimate interest in understanding how people are using our content and services, both to improve them and to promote our services. Therefore, we use your personal information to understand and analyse use of our content and services. In certain limited circumstances you have the right to object to processing based on such legitimate interests (as explained in the ‘What are your rights?’ section below).
Legal grounds for processing your consent (which you can withdraw at any time) PURPOSES OF PROCESSING:
- Where you have actively asked to receive direct marketing from us or from third parties
- Where you have agreed that we can collect information about your viewing on certain third-party platforms along with associated information such as platform identifiers.
Legal grounds for processing fulfilment of contract (content/service Terms and Conditions) PURPOSES OF PROCESSING:
- Administering our content and services (e.g. account management, user authentication, playout of content, recording responses to polls/votes, competition winner pick, sending you service messages, monitoring your compliance with applicable product/service terms and conditions and investigating any breaches)
- Enabling you to submit photos, videos and comments to us (e.g. via our uploader tool)
- Queries and complaints handling
Legal grounds for processing items required in order to comply with legal obligation PURPOSES OF PROCESSING
- Compliance with legal and regulatory obligations (e.g. record keeping; regulatory audits)
- Publication of competition / prize draw winner details
- Managing serving of advertising (for example, where advertising or viewership is restricted on the basis of age)
PROCESSING - Based on Legitimate Interests
PURPOSE OF PROCESSING: Understanding our audience and use of our content and services:
We have a legitimate interest in analysing and understanding how people are using and responding to our content and services at an individual and household or broader level.
For example, we collect and analyse data about how you are using our content and services and we (or our authorised third parties) may contact you from time to time to ask you to participate in surveys or research projects to help us understand use of and improve our services.
If you use a product or service we may combine information we collect from that product and service with information we collect from our other content and services, with information from surveys and research and with information which is available publicly or from other reputable sources We may work with trusted third parties (including advertising clients and research providers) to understand the effectiveness of our content or advertising.
We also collect information and insights information from use and interactions with pages or accounts we operate on third party platforms for this purpose and also to administer those pages or accounts. In relation to such insights data, both we and the third-party platform are controllers of any insights data relating to that page or account.
PURPOSE OF PROCESSING: Making your user experience more relevant to you
We have a legitimate interest in tailoring your user experience to you and making it easier for you to find the shows and content that you enjoy. We therefore use information we hold about you in order to recognise you across our different services, recommend content to you or personalise your experience. For example, we may use this information to recommend new content to you.
PURPOSE OF PROCESSING: Managing serving of our advertising
Some of our content and services are funded by the sale of advertising and are free for viewers to use. We and our advertisers have a legitimate interest in serving and measuring our advertising efficiently. This is to ensure that our viewers have a good user experience, (for example don’t see the same advertising over and over again) and to allow our advertisers to reach more viewers and know when ads have been served.
PURPOSE OF PROCESSING: Making advertising and marketing on other services more relevant to you
We have a legitimate interest in making sure that you don’t see repetitive or less relevant advertising across both our platforms and those run by third parties. We work with third party advertisers and platforms (such as Facebook and Google) to advertise our content and services to the most relevant audiences. This can involve the provision of protected ID data (for example, an email address which is converted into a stream of numbers or letters (aka hashed) to help make it more secure) to match the data we hold about you with the data they hold on their platform and provide you with relevant advertising (Subject to your ad permissions on the relevant platform).
Advertising on other services may still be based on cookie data however unless you have chosen to disable your cookies on the relevant device.
PURPOSE OF PROCESSING: Direct Marketing
Subject to your direct marketing preferences, we have a legitimate interest in sending you marketing communications that we think will be the most relevant to you (and which will include our own- or third-party data). We also have a legitimate interest to analyse the performance of our communications. For more details on direct marketing, see below.
We use your data to promote or market our or third-party content or services to you via direct marketing in the following circumstances.
Why we send you marketing: At your request, if you have asked us to send you marketing messages about 66 of Us and/or selected third party content when you register on our site
How to control the marketing we send to you:
- You can stop receiving email, SMS or MMS marketing communications from us, by using the 'unsubscribe', 'stop' or similar facility contained in any such communication. Alternatively, you can email us at the email address set out in ‘Contact us’ below stating that you do not wish to receive further communications from us.
- You can stop receiving push notifications from one of our apps by turning these off at any time by adjusting the settings on your device or deleting the app from your device.
- If you agree that we can pass data to third party for their marketing purposes, you’ll need to contact the applicable third party to opt-out of receiving communications from that third party
- Please note that we are not responsible for the communications you receive from any such third party.
HOW LONG DO WE KEEP YOUR INFORMATION?
We keep your personal information for only as long as necessary, which is longer in some cases than in others. The length of this retention period depends on the purpose for which the data was obtained and its nature. For example:
- we need to keep some personal information about you so we can deal with any complaints you might make about the content and services we provide to you;
- if you ask us to stop processing your personal information for direct marketing, we need to retain enough information about you to enable us to ensure we stop including you in those direct marketing activities;
- we need to keep personal information so we can defend possible future legal claims. Unless there’s some other reason for keeping it, personal information will be deleted when such a claim could no longer arise, or it is no longer required in order to defend legal claims that have arisen;
- we have a legal or regulatory duty to retain particular personal information for a certain minimum period.
IN WHAT CIRCUMSTANCES DO WE SHARE YOUR INFORMATION?
We do need to share your personal data with third parties in some circumstances. We pass information about you to other parties as follows:
- to third parties authorised by us and acting on our behalf, such as our employees, contractors, partners, suppliers, auditors and/or agents, to administer the content and services provided to you and/or to help us review and improve these content and services (including reviewing the accuracy of our data and checking how effective we are at making content relevant to you)
- These third parties are only allowed access to your information as needed to perform functions of the content and services or to provide services to us. They’re not allowed to use it for any other purpose;
- to reputable third parties such as broadcasters to enable you to have a better cross-platform advertising experience (see "Making advertising and marketing on other services more relevant to you" above);
- for marketing communications, where we have your consent to do so (see section above on "Direct Marketing");
- to conduct analytics in relation to our content and services; including with regard to our user base, sales patterns, traffic volumes and related matters. This could include comparing the information we hold about you against third party datasets;
- so that our content and services can be marketed to you on third party platforms (for example, Facebook or our Facebook Fan Pages);
- where relevant, the user name and some profile information you voluntarily provide may be published on areas of the content and services such as forums, leader boards, chat rooms or pages where user submissions are displayed, and this will be the identity by which you are known on those areas;
- if there are changes to our business;
- to any other third party where you have provided your consent.
WHAT ARE YOUR RIGHTS?
Any personal information you supply will be treated in accordance with applicable data protection laws including the Data Protection Act 2018 and the General Data Protection Regulation (the "GDPR") and any other applicable or superseding legislation. We are committed to delivering the rights that individuals are entitled to under data protection laws in the UK. These are:
- the right to request a copy of the personal information we hold about you. To do this, please contact us at firstname.lastname@example.org making clear that you are requesting a copy of your personal information and including full details of what you require. You may also be required to submit a proof of your identity.
- the right to object to your personal information being used for direct marketing. Where required we will ensure we obtain your consent before undertaking marketing and you will have the ability to opt out (see the section on ‘Direct Marketing’ above).
- the right to object to your personal information being processed where the legal basis for the processing is our own legitimate interests as a business
- the right to rectification. You may request that we correct any inaccurate and/or complete any incomplete personal information.
- the right to withdraw consent. Where we are processing your personal information on the basis that you have given us your consent to do so, you may withdraw your consent at any time.
- the right of erasure. You may request that we erase your personal information and we will comply, unless there is a lawful reason for not doing so.
- the right to data portability. In certain circumstances, you may request that we provide your personal information to you in a structured, commonly used and machine-readable format and have it transferred to another provider of the same or similar services to us. Where this right is applicable, we will comply with such transfer as far as it is technically feasible.
- the right to lodge a complaint with the supervisory authority. We suggest that you contact us about any questions or if you have a complaint in relation to how we process your personal information. However, you do have the right to contact the relevant supervisory authority directly. To contact the Information Commissioner’s Office in the United Kingdom, please visit the ICO website (www.ico.org.uk) for instructions.
CHANGES TO OUR BUSINESS
If we decide to change or restructure our business or if we become involved in a merger, acquisition, restructuring, reorganisation or other transaction involving the sale of some or all of our company’s assets, then your information may be included in the assets that are transferred to the new owner and may be provided to the entities and advisors involved. Such a transaction could involve us: (i) retaining the right to continue to use transferred personal information in addition to the right of the new owner to use such information; and (ii) engaging in additional transfers of personal information (including new personal information) with the new owner from time to time following such a transaction.
If there are changes to our business (such as a re-organisation or restructuring), your personal information will remain subject to this privacy notice (as amended from time to time). However, where your personal information is transferred to a new owner following a merger or acquisition it may be subject to a different privacy notice. We, or the new owner, will provide notice to you before any of your personal information becomes subject to a different privacy notice.
As the Data Controller, 66 of Us can be contacted as follows:
66 of Us
Registered Address: PO Box 10818, Lutterworth, LE17 9FA
Phone: 01865 589350
The Information Commissioner’s Office (ICO) regulates our processing of your personal information. You have the right to lodge a complaint with the ICO. Details of how to contact the ICO can be found on their website at www.ico.org.uk.
If you want to contact us about our services, you can find more details at www.66ofUs.uk. If you wish to contact us generally about our privacy notice or with any privacy queries, please email us at email@example.com