- Scope of this Policy
This privacy and cookies policy (“Policy”): (i) sets out the types of personal data we collect; (ii) explains how and why we collect and use your personal data; (iii) explains when and why we will share personal data with other organisations; and; (iv) explains your rights and choices when it comes to your personal data.
When you use our services (“Services”) by accessing our website at https://www.trueroyalty.tv/ (the “Website”) or streaming any content accessed from the Website or via our mobile applications (our “App”) this Policy will apply to you. This Policy also applies if you contact us or we contact you about our Services.
Our Website or App may contain links to other websites operated by other organisations. These third party organisations will have their own privacy policies which you should read carefully before providing any of your personal data as we do not accept any responsibility or liability for websites of other organisations.
The Data Controller is ABM Communications Ltd (“we” or “us”). We determine the purpose and manner in which your personal data is used.
This Policy was last updated on 30th April 2018.
- Our collection of your Personal data
Upon subscribing to our Services, you may provide us with:
- Your personal details, including your name, title, postal and billing addresses, email addresses, phone numbers and date of birth;
- Your debit or credit card details, bank details and other payment information;
- Your account login details, such as your username and password.
When you browse our Website or use our App, we may collect:
- Purchase Information(e.g., what you have bought, when and where you bought it and how you paid for it)
- Information about your online browsing behaviour on our Website and App and information about when you click on one of our advertisements (including those shown on other organisation’s websites);
- Information (including the make, model and operating system, IP address, browser type and mobile device identifiers) about any devices you have used to access our Service.
When we communicate with each other or you take part in promotions, competitions, surveys or questionnaires about our Services, we may collect:
- Personal data you provide about yourself anytime you contact us about our Services, (for example, your name, username and contact details)including by phone, email or post or when you speak with us through social media
- Details of the emails and other digital communications we send to you that you open, including any links in them that you click on
- Your responses to customer surveys and questionnaires
We may also use personal data from companies that supply information, online media channels, and our Service Providers.
- Protecting your personal data
We use technical safeguards such as firewalls and data encryption, and we employ access controls to our buildings and files to keep your data safe.
- We protect the security of your information while it is being transmitted by encrypting it using Secure Sockets Layer (SSL).
- We enforce physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personal data. We will ask for proof of identity before we share your personal data with you.
- We will reveal only the last four digits of your credit card number when confirming an order.
While we cannot guarantee the security of any personal data that you transfer over the internet to us, we do take appropriate technical and organisational measures to safeguard your personal data.
The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by companies operating outside the EEA who work for us or for one of our service providers. If we do this we ensure that your privacy rights are respected in line with this Policy. The most common way we do this is to put in place a specific type of contract, a copy of this type of contract can be found here or through an approved scheme such as the Privacy Shield
- Our use of your personal data
We set out below how we use your data and the lawful basis for doing so. Our references to our “legitimate interests” are to those interests that allow us to:
- -service our customers’ needs, including delivery of the services.
- -promote and market our products and services.
- -service your account, manage complaints and resolve any disputes.
- -understand our customers including their patterns, behaviours as well as their likes and dislikes
- -test and develop new products and services as well as improve existing ones.
- -satisfy legal/regulatory obligations.
|Our use of your personal data||Explanation of this use||Reason for using your personal data in this manner||Legal Basis|
|Make our services available to you||Manage the accounts you hold with us, check whether our products are appropriate for you, and process your orders and refunds.||We need to process your personal data so that we can manage your customer accounts, provide you with the services you want to buy and to help you with any orders and refunds that you may request.||Contractual necessity:|
At the time we collect the data:
-purchase & transactions data
We will not be able to provide you with your products or services if you do not provide us with this information.
-following fulfilment of your order and for the other personal data set out in this section
Some cookies are necessary so you should not disable these if you want to be able to use all the features of our Website and App. You can disable other cookies but this may affect your customer experience..
|Help to develop and improve our content, services, information technology systems, know-how and the way we communicate with you||We depend on the use of personal data to carry out market research and evolving our customer insights, and to improve our information technology systems (including security) and our content and services.|
|Detect and prevent fraud and other crimes|
|It is important for us to monitor how our Services are used to detect and prevent fraud, other crimes and the misuse of services. This helps us to ensure that you can safely use our Services. We also need to comply with laws that apply to us.|
|Personalise your user experience|
|Use your online browsing behaviour to help us better understand your purchase patterns and provide you with personalised offers and services.||Looking at your browsing behaviour and purchases allows us to personalise our offers and services for you. This helps us meet your needs as a customer.||Legitimate Interests|
|Provide you with relevant marketing communications (including by text, email, post or online advertising), relating to our products and services. As part of this, online advertising may be displayed on websites across other organisations’ websites and online media channels. We may also measure the effectiveness of our marketing communications and those of our suppliers.||We want to be able to tailor our marketing communications, including online advertising, to your interests. To achieve this we also measure your responses to marketing communications relating to the services you have subscribed to, which also means we can offer you products and services that better meet your needs as a customer.|
You can change your marketing choices, both when you register with us, and at any time after that.
You also have choices when it comes to online advertising. We set out below your choices when it comes to cookies, and how you can control your online behavioural advertising preferences.
|It is in our Legitimate Interests to provide marketing communications about our own services for all other marketing communications we rely on your Consent|
|Contact and interact with you||Contact you about our Services,|
for example by phone, email, online or post or responding to social media posts that you have directed at us.
|We use personal data to provide clarification or assistance in response to your communications; this helps with the quality of service we provide to you.||Legitimate Interests|
|Manage promotions and competitions you take part in, including those we run with our suppliers.||We need to process your personal data so that we can manage the promotions and competitions you choose to enter.|
|Invite you to take part in and manage customer surveys, questionnaires and other market research activities carried out by us and by other organisations on our behalf.||We carry out market research to improve our Services. You do not have to take part in the activities. You will always be able to tell us that you do not want us to contact you for market research and this will not affect your ability to use our Services|
- Sharing personal data with Service Providers and other organisations
We work with carefully selected Service Providers that carry out certain functions on our behalf. These include, for example, companies that help us with customer care services, network and technology services, storing and combining data, processing payments and fulfilling orders. We only share personal data that enable our Service Providers to provide their services.
Some of the Service Providers we work with operate online media channels (websites, social media sites, pay TV providers), and they place relevant online advertising for our products and services, on those online media channels on our behalf. For example, you may see an advertisement for our products and services as you use a particular social media site or watch television through your pay TV account.
Sharing personal data with other organisations
We may share personal data with other organisations in the following circumstances:
- if the law or a public authority says we must share the personal data;
- if we need to share personal data in order to establish, exercise or defend our legal rights (this includes providing personal data to others for the purposes of preventing fraud and reducing credit risk); or
- to an organisation we sell or transfer (or enter into negotiations to sell or transfer) any of our businesses or any of our rights or obligations under any agreement we may have with you to. If the transfer or sale goes ahead, the organisation receiving your personal data can use your personal data in the same way as us.
- How long we use personal data for
Your personal data won’t be kept longer than necessary, giving due regard to: initial purpose of collection; age of data; any legal/regulatory reason for us to keep it; and whether needed to protect you or us.
- Marketing and market research
Provided that you have not objected to receiving marketing communications, we will send you relevant offers and news about our products and services in a number of ways including by email or text. When you register with us we will ask if you object to receive marketing communications, and you can change your marketing choices at anytime by visiting your
Your views are important and will help improve our Services, so we may contact you (but participations is optional) for market research purposes.
- Your Data Protection Rights
Subject Access Rights
You have a right to see the personal data we hold about you. This is called a Subject Access Request. If you would like a copy of the personal data we hold about you, please write to:
ABM Communications Ltd,
The Cursitor, 38 Chancery Ln.,
London WC2A 1LF, United Kingdom
You can also email us at SubjectAccess@www.trueroyalty.tv
Have inaccurate information corrected -- if you believe we hold inaccurate or missing information, please let us know and we will correct it.
Object to our use of your data -- We will consider you objection to our use of your personal data. If on balance, your rights outweigh our interests in using your personal data, then we will at your request either restrict our use of it or delete it
Object in relation to direct marketing – If you make such an objection, we will stop using your personal data for direct marketing purposes.
Restrict our use of it -- you can restrict our use of your personal data, if:- you have successfully made a general objection, you are challenging the accuracy of the personal data we hold or we have used your personal data unlawfully, but you do not want us to delete it
Have it deleted -- you can have us delete your personal data when: we no longer need to keep your personal data; you have successfully made a general objection; you have withdrawn your consent to us using your personal data and we do not have any other grounds to use it; we have unlawfully processed your personal data
Complain to the data protection regulator
We’d like the chance to resolve any complaints you have, however you also have the right to complain to the UK data protection regulator (the ICO) about how we have used your personal data. Their website is https://ico.org.uk/.
- How to contact us
If you have any questions about how we collect, store and use personal data please contact us.
ABM Communications Ltd,
81 Chancery Lane, London