PRIVACY POLICY

The Turner ViP Service (“Service”) including the websites currently located at https://www.turnervip.com associated with it ("Site"), is a digital service operated by Turner Broadcasting System Europe Limited, with offices at Turner House, 16 Great Marlborough Street, London, W1F 7HS United Kingdom (“Turner” “We” or “Us”).

We take your privacy seriously. This privacy policy explains what personal data We collect from you and how We use it. We encourage you to read through the document thoroughly.

WHO IS RESPONSIBLE FOR YOUR DATA: Turner Broadcasting System Europe Limited is the data controller and responsible for processing your personal data provided.

If you have any questions, concerns or complaints about how We use your personal data please contact us at: TurnerViPSupport@Turner.com and insert in the subject line Privacy Office.

PERSONAL DATA WE COLLECT: We receive personal data directly from you and personal data that is automatically collected, such as usage information.

Personal Data You Provide To Us. We store personal data you provide to us, including your first and last name, your email address, your country or region of residence, and your employer or company. The personal data will be stored when you provide it using the Service, or when you contact our customer service.

Information That is Automatically Collected. We also collect automatically certain personal data when you visit the site or use our Service, including but not limited to information about the content that you have accessed (“Content”) and the location (IP address) and device from which you accessed the Service and the Content.

WHY WE PROCESS YOUR PERSONAL DATA: We receive personal data directly from you and personal data that is automatically collected, such as usage information.

We process your personal data for the following purposes:

To provide You with the Service and the Site

It is necessary for Us to process your personal data in order to provide the Service and the Site to you, for example:

  • to process your request to access the Service as a Registered Account Holder ( as defined in the Terms of Use) and provide you (once your request is approved) with an option to register;
  • if you register, to provide you with the Service in accordance with the Terms of Use and perform essential such as log in, authentication, password reset and recovery;
  • to fulfil your requests and inquiries regarding the Services and our shows ;
  • to provide technical support for the Services;
  • to communicate with you about the Service or your account with us;
  • to send you information about changes to our terms or policies;
  • to verify your identity;
  • to facilitate future business transactions, including when you contact our content licensing team.

To maintain and improve the Service

We also process your personal data in order to:

  • to enforce our policies and Terms of Use, including to protect the Content and Turner's intellectual property rights
  • to check for potential illegal activity (such as copyright infringement or fraud), and to protect the safety of other users of the Services;
  • to analyse how you (and where separate profiles are created each account user) use the Service including watch history, watch lists, search queries, viewing behaviour (for example frequency of viewing and length of viewing time), content preferences and details of your interaction with the Service (for example page views, clicks and user flows) to help us manage and improve the Service;
  • to send you invitations to watch our shows on the Service;
  • to send you information about Turner programming, offerings, business and services.

To comply with legal obligations

We may process your personal data

  • in response to requests by government or law enforcement authorities conducting an investigation.
  • to comply with our legal obligations.

THE LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA: The legal basis for processing personal data:

to provide You with the Service and Site is to fulfil the contract between us, and, at your request, to take steps prior to entering into a contract as set out in Article 6(1)(b) of Regulation 2016/679 of Regulation (EU) 2016/679 (“GDPR”).

to Maintain and Improve the Service is that it is necessary for purposes, which are in our, or third parties', legitimate interests pursuant to Article 6(1)(f) of the GDPR.

to comply with a legal obligation to which We are subject is lawful pursuant to Article 6(1)(c) of the GDPR.

PERSONAL DATA SHARING AND DISCLOSURE: We share your personal data:

  • With service providers we have engaged to perform business-related functions on our behalf. For example, to: (a) conduct research and analytics; (b) provide customer, technical or operational support services; (c) conduct or support marketing (such as email platforms); (d) fulfil users request; (f) host the Service. Specifically, Turner has engaged ScreenHits Limited, a UK based service provider (“Screenhits”), to deliver the Service and the Site. As a result, ScreenHits may receive Data provided by you, however, at all times, Turner will control and be responsible for the use of your Data and Screenhits will act as data processor on Turner’s instructions.
  • In response to a legal process, for example, in response to a court order or a subpoena, a law enforcement or government agency's request;
  • With third parties if this will help us to enforce our policies and Terms of Use, to investigate, prevent or take action regarding potential illegal activity (such as copyright infringement or fraud) or to protect the safety of other users of the Service; or
  • If we, or one of our business units, undergoes a business transition, like a merger, acquisition by another company, or sale of all or part of our assets;
  • We may share the Information with Turner Affiliates (as listed below), to better tailor our services to you, appropriately process your requests depending on your region or country, including, when you order a product or service, or request further information, and for internal reporting, so they can communicate directly with you about the products and services that you require or may be of interest to you.

We have entered into a data processing agreement fulfilling the requirements of the GDPR with all our processors.

LIST OF TURNER AFFILIATES: Below is a list of the Turner Affiliates with which we may share Information on the terms set out in this Privacy Policy. We update this list from time-to-time, so please check back periodically to keep up-to-date. 

  • Italy – Turner Broadcasting System Italia s.r.l.
  • France- Turner Broadcasting System s.a s.
  • Spain - Turner Broadcasting System España s.l.
  • Germany - Turner Broadcasting System Deutschland GmbH
  • Russia – TBS Limited Liability Co
  • Argentina – Imagen Satelital S.A.
  • Australia - Turner International Australia Pty Ltd

COOKIES AND SIMILARTECHNOLOGIES: Turner uses cookies on the Site which are essential in order to maintain your application sessions and authorize viewing of content. Cookies are text files containing small amounts of information which are downloaded to your device, or more technically, to the browser that you use on that device, when you visit a site. Without these cookies, the Services cannot be provided. Turner does not use any other cookies or other tracking technologies on the Site or in connection with the Services.

INTERNATIONAL TRANSFERS: From time to time we may need to share your personal data with Turner Affiliates who may be based outside of the European Economic Area ("EEA"). We may also allow our service providers or assistance providers, who may be located outside the EEA, access to your personal data. We may also make other disclosures of your personal data overseas, for example if we receive a legal or regulatory request from a foreign law enforcement body.

We will always take steps to ensure that any international transfer of information is carefully managed to protect your rights and interests.

You have the right to ask us for more information about the safeguards we have put in place as mentioned above. Contact us as set out above if you would like further information.

RETENTION OF YOUR PERSONAL DATA: We do not keep your personal data for any longer than is necessary in light of the reasons for which it was first collected. Your data will therefore be retained for the following periods (or its retention will be determined on the following basis):

  • All ‘pre-registration’ personal data including your request to register – up to 1 month if the request is rejected or if you do not complete the registration process within 1 month from the invitation to register
  • All personal data relating to an active Registered Account Holder, including your request to register – data will be kept for as long as you are a Registered Account Holder
  • An unsubscribed Registered Account Holder – up to 1 month from the date of unsubscribing;
  • An inactive Registered Account Holder – up to 1 month from the date of being deemed inactive (that is a Registered Account Holder that has not logged-in for at least 6 months and has not replied to at least two reminders);

Usage data will be held in anonymised form following the deletion of individual accounts.

YOUR RIGHTS/HOW TO CONTACT US: You have a number of rights in relation to your Personal data. Information about each of these rights is set out below.

  • Right of access. You have the right to access the personal data We process about you. This includes, the categories of personal data, recipients of personal data and a copy of the personal data undergoing processing. For more information about the right of access, see Article 15 of the GDPR
  • Right to rectification. You have the right to correct inaccurate personal data relating to you which We process. For more information about the right of rectification, see Article 16 of the GDPR.
  • Right to erasure. In certain circumstances you have the right to obtain from Us the erasure of personal data concerning you. For instance, you have this right if the personal data is no longer necessary to achieve the purposes as defined under this policy, or if your personal data has been unlawfully processed by Us. For more information about the right to erasure, see Article 17 of the GDPR.
  • Right to restriction of processing. In certain circumstances, you may obtain from Us the restriction of processing of your personal data. When your processing is restricted, We will only, except from storage, only process the personal data with your consent, to establish or defend a legal claim, or to protect another natural or legal person’s legal rights. The right of restriction of processing is applicable, inter alia, where you dispute the correctness of your personal data, or if our processing is unlawful and you do not wish erasure of the Personal data. For more information about the right to restriction, see Article 18 of the GDPR.
  • Right to data portability. With respect to our processing of your personal data based on your consent or processing which is necessary to provide you the Service pursuant to Chapter 3 of this policy, you have the right to data portability. The right to data portability means you may obtain your personal data you provide to Us in a structured, commonly used and machine-readable format. You may also transmit that personal data to another entity without hindrance from Us. Where technically feasible, We will also transmit that personal data directly to another entity on your request. For more information about the right of data portability, see Article 20 of the GDPR.
  • Right to object. For the processing of your personal data based on our or a third party’s legitimate interests, you have the right to object to our processing of your personal data. By objecting to the processing, We will no longer process your personal data, unless We demonstrate compelling legitimate grounds which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims. For more information about the right to object, see Article 21 of the GDPR.

You may always withdraw consent to our processing of your Personal data where consent is the lawful basis of processing.

In addition you can opt out of receiving email marketing communications by following the opt-out instructions provided to you in those emails.

Limitations may apply to the rights above, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete personal data which we are required by law to keep or have compelling legitimate interests in keeping.

To exercise any of these rights, you can get in touch with our Privacy Office using the details set out at the beginning of this Policy. Please include your registration information, such as first name, last name and e-mail address in the request. We may ask you to provide additional information for identity verification purposes. You have a right to lodge a complaint with the UK supervisory authority (the Information Commissioner (www.ico.org.uk)) or your local supervisory authority about our processing of your personal data.

UPDATES & EFFECTIVE DATE: From time to time, we may update this policy. We will notify you about material changes by either sending an email message to the email address you most recently provided to us or by prominently posting a notice on our Service. We encourage you to periodically check back and review this policy so that you know what personal data we collect, how we use it, and with whom we share it.

The policy posted on this Service was updated on 10 October, 2018.