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Privacy Notice

BACKGROUND

Lost in TV understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our customers and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Information About Us

Lost in TV.
Limited company registered in England under company number 04801855.
Registered address: 11-12 Hallmark Trading Centre, Fourth Way, Wembley, Middlesex, HA9 0LB.
Data Protection Officer: Jay Honosutomo.
Email address: info@lostintv.com
Telephone number: (020) 8530 8100.
Postal address: 11-12 Hallmark Trading Centre, Fourth Way, Wembley, Middlesex, HA9 0LB.

What Does This Notice Cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

What Is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below.

What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

  • The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
  • The right to access the personal data we hold about you. Part 10 will tell you how to do this.
  • The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
  • The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 11 to find out more.
  • The right to restrict (i.e. prevent) the processing of your personal data.
  • The right to object to us using your personal data for a particular purpose or purposes.
  • The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
  • The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
  • Rights relating to automated decision-making and profiling.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 11.

What Personal Data Do You Collect and How?

Depending upon your use of Our Site, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table.

Data Collected How we Collect the Data
Identity Information including name, title, date of birth, gender. Registration
Contact information including address, email address, telephone number. Registration
Payment information including card details, bank account numbers. Registration
Profile information including preferences, interests, login details, purchase history. Cookies and account information
Technical information including IP address, browser type and version, operating system. Cookies.
Data from third parties including technical information, contact information, profile information. Cookies

How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and Our lawful bases for doing so:

What we Do What Data we Use Our Lawful Basis
Registering you on Our Site. Name, address, contact information. Consent
Providing and managing your Account. Name, address, contact information, preferences. Contractual
Providing and managing your access to Our Site. Name, address, contact information. Consent.
Personalising and tailoring your experience on Our Site. Name, address, contact information, preferences. Consent.
Administering Our Site. Name, address, contact information, preferences Contractual.
Administering Our business. Name, address, contact information, preferences Contractual.
Supplying Our services to you. Name, address, contact information, preferences Contractual.
Managing payments for Our services Name, billing address, contact information, payment details. Contractual
Legitimate Interest
Personalising and tailoring Our services for you. Name, address, contact information, preferences Consent.
Communicating with you. Name contact information including email address. Consent
Legitimate Interest
Supplying you with information by email and post that you have opted-in-to (you may opt-out at any time) Name, address, contact information, preferences. Consent.

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message or with information, news, and offers on Our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with Our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Type of Data How Long we Keep It
Identity Information including name, title, date of birth, gender Indefinite
Contact information including address, email address, telephone number. Indefinite
Payment information including card details, bank account numbers. Indefinite
Profile information including preferences, interests, login details, purchase history. Indefinite
Technical information including IP address, browser type and version, operating system. Indefinite
Data from third parties including technical information, contact information, profile information. Indefinite

How and Where Do You Store or Transfer My Personal Data?

We will only store or transfer some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the Data Protection Legislation, GDPR, and/or to equivalent standards by law.

Do You Share My Personal Data?

We share your personal data with other companies with whom we contract to supply certain services.

Where your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, Our obligations, and the third party’s obligations under the law, as described above in Part 8.

If we sell, transfer, or merge parts of Our business or assets, your personal data may be transferred to a third party. Any new owner of Our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover Our administrative costs in responding.

We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of Our progress.

How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

Email address: info@lostintv.com
Telephone number: (020)8530 8100.
Postal Address: 11-12 Hallmark Trading Centre, Fourth Way, Wembley, Middlesex, HA9 0LB.

Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change Our business in a way that affects personal data protection.

This Privacy Notice was last updated on 19th September 2018.

Lost in TV
Data Retention Policy
September 2018

Introduction

This Policy sets out the obligations of Lost in TV, a company registered in England and Wales under number 04801855, whose registered office is at 11-12 Hallmark Trading Centre, Fourth Way, Wembley, Middlesex, HA9 0LB (“the Company”) regarding retention of personal data collected, held, and processed by the Company in accordance with EU Regulation 2016/679 General Data Protection Regulation (“GDPR”).

The GDPR defines “personal data” as any information relating to an identified or identifiable natural person (a “data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

The GDPR also addresses “special category” personal data (also known as “sensitive” personal data). Such data includes, but is not necessarily limited to, data concerning the data subject’s race, ethnicity, politics, religion, trade union membership, genetics, biometrics (if used for ID purposes), health, sex life, or sexual orientation.

Under the GDPR, personal data shall be kept in a form which permits the identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. In certain cases, personal data may be stored for longer periods where that data is to be processed for archiving purposes that are in the public interest, for scientific or historical research, or for statistical purposes (subject to the implementation of the appropriate technical and organisational measures required by the GDPR to protect that data).

In addition, the GDPR includes the right to erasure or “the right to be forgotten”. Data subjects have the right to have their personal data erased (and to prevent the processing of that personal data) in the following circumstances:

  • Where the personal data is no longer required for the purpose for which it was originally collected or processed (see above);
  • When the data subject withdraws their consent;
  • When the data subject objects to the processing of their personal data and the Company has no overriding legitimate interest;
  • When the personal data is processed unlawfully (i.e. in breach of the GDPR);
  • When the personal data has to be erased to comply with a legal obligation; or
  • Where the personal data is processed for the provision of information society services to a child.

This Policy sets out the type(s) of personal data held by the Company, the period(s) for which that personal data is to be retained, the criteria for establishing and reviewing such period(s), and when and how it is to be deleted or otherwise disposed of.

For further information on other aspects of data protection and compliance with the GDPR, please refer to the Company’s Data Protection Policy.

Aims and Objectives

The primary aim of this Policy is to set out limits for the retention of personal data and to ensure that those limits, as well as further data subject rights to erasure, are complied with. By extension, this Policy aims to ensure that the Company complies fully with its obligations and the rights of data subjects under the GDPR.

In addition to safeguarding the rights of data subjects under the GDPR, by ensuring that excessive amounts of data are not retained by the Company, this Policy also aims to improve the speed and efficiency of managing data.

Scope

This Policy applies to all personal data held by the Company and by third-party data processors processing personal data on the Company’s behalf.

Personal data, as held by the Company is stored in the following ways and in the following locations:

  • The Company’s servers located in Germany;
  • Third-party servers in various locations within the UK and Europe;
  • Computers permanently located in the Company’s premises at our Wembley office;
  • Laptop computers and other mobile devices provided by the Company to its employees;
  • Physical records stored in Wembley, UK

Data Subject Rights and Data Integrity

All personal data held by the Company is held in accordance with the requirements of the GDPR and data subjects’ rights thereunder, as set out in the Company’s Data Protection Policy.

Data subjects are kept fully informed of their rights, of what personal data the Company holds about them, how that personal data is used, and how long the Company will hold that personal data (or, if no fixed retention period can be determined, the criteria by which the retention of the data will be determined).

Data subjects are given control over their personal data held by the Company including the right to have incorrect data rectified, the right to request that their personal data be deleted or otherwise disposed of (notwithstanding the retention periods otherwise set by this Data Retention Policy), the right to restrict the Company’s use of their personal data, the right to data portability, and further rights relating to automated decision-making and profiling.

Technical and Organisational Data Security Measures

  • The following technical measures are in place within the Company to protect the security of personal data. Please refer to the Company’s Data Protection Policy for further details:
  • All emails containing personal data must be encrypted;
  • All emails containing personal data must be marked “confidential”;
  • Personal data may only be transmitted over secure networks;
  • Personal data may not be transmitted over a wireless network if there is a reasonable wired alternative;
  • Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself and associated temporary files should be deleted;
  • Where personal data is to be sent by facsimile transmission the recipient should be informed in advance and should be waiting to receive it;
  • Where personal data is to be transferred in hardcopy form, it should be passed directly to the recipient;
  • All personal data transferred physically should be transferred in a suitable container marked “confidential”;
  • No personal data may be shared informally and if access is required to any personal data, such access should be formally requested from the Data Protection Officer.
  • All hardcopies of personal data, along with any electronic copies stored on physical media should be stored securely;
  • No personal data may be transferred to any employees, agents, contractors, or other parties, whether such parties are working on behalf of the Company or not, without authorisation;
  • Personal data must be handled with care at all times and should not be left unattended or on view;
  • Computers used to view personal data must always be locked before being left unattended;
  • No personal data should be stored on any mobile device, whether such device belongs to the Company or otherwise without the formal written approval of the Data Protection Officer and then strictly in accordance with all instructions and limitations described at the time the approval is given, and for no longer than is absolutely necessary;
  • No personal data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the Company’s Data Protection Policy and the GDPR;
  • All personal data stored electronically should be backed up with backups stored offsite. All backups should be encrypted;
  • All electronic copies of personal data should be stored securely using passwords and encryption;
  • All passwords used to protect personal data should be changed regularly and should must be secure;
  • Under no circumstances should any passwords be written down or shared. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;
  • All software should be kept up-to-date. Security-related updates should be installed as soon as reasonably possible after becoming available;
  • No software may be installed on any Company-owned computer or device without approval; and
  • Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of the Data Protection Officer to ensure that the appropriate consent is obtained and that no data subjects have opted out, whether directly or via a third-party service such as the TPS.

The following organisational measures are in place within the Company to protect the security of personal data. Please refer to the Company’s Data Protection Policy for further details:

  • All employees and other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the GDPR and under the Company’s Data Protection Policy;
  • Only employees and other parties working on behalf of the Company that need access to, and use of, personal data in order to perform their work shall have access to personal data held by the Company;
  • All employees and other parties working on behalf of the Company handling personal data will be appropriately trained to do so;
  • All employees and other parties working on behalf of the Company handling personal data will be appropriately supervised;
  • All employees and other parties working on behalf of the Company handling personal data should exercise care and caution when discussing any work relating to personal data at all times;
  • Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed;
  • The performance of those employees and other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;
  • All employees and other parties working on behalf of the Company handling personal data will be bound by contract to comply with the GDPR and the Company’s Data Protection Policy;
  • All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all relevant employees are held to the same conditions as those relevant employees of the Company arising out of the GDPR and the Company’s Data Protection Policy;
  • Where any agent, contractor or other party working on behalf of the Company handling personal data fails in their obligations under the GDPR and/or the Company’s Data Protection Policy, that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure.

Data Disposal

Upon the expiry of the data retention periods set out below in Part 7 of this Policy, or when a data subject exercises their right to have their personal data erased, personal data shall be deleted, destroyed, or otherwise disposed of as follows:

  • Personal data stored electronically (including any and all backups thereof) shall be deleted;
  • Special category personal data stored electronically (including any and all backups thereof) shall be deleted;
  • Personal data stored in hardcopy form shall be shredded and recycled;
  • Special category personal data stored in hardcopy form shall be shredded.

Data Retention

As stated above, and as required by law, the Company shall not retain any personal data for any longer than is necessary in light of the purpose(s) for which that data is collected, held, and processed.

Different types of personal data, used for different purposes, will necessarily be retained for different periods (and its retention periodically reviewed), as set out below.

When establishing and/or reviewing retention periods, the following shall be taken into account:

  • The objectives and requirements of the Company;
  • The type of personal data in question;
  • The purpose(s) for which the data in question is collected, held, and processed;
  • The Company’s legal basis for collecting, holding, and processing that data;
  • The category or categories of data subject to whom the data relates.

If a precise retention period cannot be fixed for a particular type of data, criteria shall be established by which the retention of the data will be determined, thereby ensuring that the data in question, and the retention of that data, can be regularly reviewed against those criteria.

Notwithstanding the following defined retention periods, certain personal data may be deleted or otherwise disposed of prior to the expiry of its defined retention period where a decision is made within the Company to do so (whether in response to a request by a data subject or otherwise).

In limited circumstances, it may also be necessary to retain personal data for longer periods where such retention is for archiving purposes that are in the public interest, for scientific or historical research purposes, or for statistical purposes. All such retention will be subject to the implementation of appropriate technical and organisational measures to protect the rights and freedoms of data subjects, as required by the GDPR.

Type of Data Purpose of Data Review Period Retention Period or Criteria Comments
Identity Information including name, title, date of birth, gender Legitimate Interests 2 years Indefinite Will be updated as advised
Contact information including address, email address, telephone number Legitimate Interests 2 years Indefinite Will be updated as advised
Payment information including card details, bank account numbers Legitimate Interests 2 years Indefinite Only transaction information stored. No banking informing (card numbers, account numbers) stored.
Profile Information including preferences, interests, login details, purchase history Legitimate Interests 2 years Indefinite Stored securely and updated in line with SAR’s and client requests for updates / removal.
Data from third parties including technical information, contact information, profile information Legitimate Interests 2 years Indefinite Only data related to legitimate Interest is stored by third party (Consent)

Roles and Responsibilities

The Company’s Data Protection Officer is Jay Honosutomo, info@lostintv.com.

The Data Protection Officer shall be responsible for overseeing the implementation of this Policy and for monitoring compliance with this Policy, the Company’s other Data Protection-related policies (including, but not limited to, its Data Protection Policy), and with the GDPR and other applicable data protection legislation.

The Data Protection Officer shall be directly responsible for ensuring compliance with the above data retention periods throughout the Company.

Any questions regarding this Policy, the retention of personal data, or any other aspect of GDPR compliance should be referred to the Data Protection Officer.

Implementation of Policy

This Policy shall be deemed effective as of September 2018. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.

This Policy has been approved and authorised by:

Name: Jay Honosutomo
Position: Director
Date: 18th September 2018
Due for Review by: 18th September 2020