We respect your right to privacy. Our overall aim is to ensure that our collection and use of personal information is appropriate to the provision of Discovery Kids Content to you, and is in accordance with applicable data protection laws.
- Who we are
- The personal information we collect about you
- How we store and use your personal information
- Anonymous data
- How we share your personal information and who we share it with
- International transfers
- Cookies and Similar Technologies
- Data Retention
- Your rights
- Third party sites
- Complaints, questions and suggestions
1. Who we are
We are DPlay Entertainment Limited, registered in England with company number 09615785 whose registered office is at Chiswick Park Building 2, 566 Chiswick High Road, London, W4 5YB, United Kingdom (“DEL”) and we are the data controller of the personal information that we collect from you.
Our Data Protection Officer’s contact details are: firstname.lastname@example.org.
Only those who are aged 18 years or over may install and use the App but we allow children to use the App with your permission and under your supervision.
We do not collect personal information such as full names, contact details or account details directly from children who use the App because they are not permitted to have their own account, but we do collect information provided by parents when they set up profiles for their children and information about what Discovery Kids Content is accessed through each account. This means that we may collect certain personal information relating to a child (for example, the username and age range allocated to that child by their parent and whether they access certain programmes, if a parent sets up an individual profile for the child in their account).
We collect, store and use anonymised usage data from the App for the purpose of monitoring usage of our Discovery Kids Content and informing future improvements (for example, finding out what content is most popular). To the extent that this inadvertently includes any personal information relating to children, we do not believe that this storage and use will unduly prejudice a child’s rights or freedoms.
3. The personal information we collect about you
When you access and browse the App (including when you submit personal information to us through data entry fields on the App sign up) and Discovery Kids Content and subscribe to our Discovery Kids Content, we collect the following information from you:
- your name;
- your email address;
- any email communications, including attachments, which you send to us;
- where you are when you purchase a subscription from us and your location when you use your subscription to access Discovery Kids Content;
- your payment information including billing address;
- your username and password for registering a Discovery Kids account;
- your Facebook login, where you use a Facebook log-in to create a Discovery Kids account;
- how you use our Discovery Kids Content and the devices that you use to access our Discovery Kids Content. This includes collecting unique online identifiers such as IP address; and
- details of your interactions with Customer Services.
We may also need to collect your mobile number in order to complete the sign-up and subscription process.
4. How we store and use your information
We also collect, store and use your personal information including your name, contact details and other information submitted to us, user name, password and service usage data for our legitimate interests, so that we can:
- make App available to you;
- provide any Discovery Kids Content that you request;
- administer the App and the Discovery Kids Content; and
- suggest similar Discovery Kids Content to you that you may be interested in and to understand which Discovery Kids Content appeals to our customers.
We do not believe that our storage and use of your personal information for these purposes will unduly prejudice your rights and freedoms.
We also need to process information about your location to ensure that we provide any location specific Discovery Kids Content to you and (where applicable) to comply with any request by you to exercise your right to portability within the European Union.
Sometimes, our use of your personal information is for purposes which are ancillary to the provision of the Website, App or the Discovery Kids Content. In those circumstances, we believe we have a legitimate interest in handling your personal information, and do not believe that this storage and use of your personal information will unduly prejudice your rights or freedoms.
The relevant circumstances are:
- detecting and preventing fraud;
- keeping our websites, apps, products and IT systems secure;
- ensuring that our own processes, procedures and systems are as efficient as possible;
- analysing and enhancing the information that we collect;
- to use IP addresses and device identifiers to identify the location of users and block any unauthorised users;
- in some very limited circumstances, we will need to handle your personal information in a certain way to comply with our legal requirements; for example, if we are asked by regulatory bodies or law enforcement agencies to share the information; and
- where you have given your consent, contacting you by e-mail, with products and Discovery Kids Content which we think may interest you. We do not contact minors for this purpose.
5. Anonymous data
We collect anonymised details about visitors to the Website and App for the purposes of aggregate statistics or reporting purposes. However, no single individual will be identifiable from the anonymised details we collect for these purposes.
6. How we share your personal information and who we share it with
We disclose information under the following circumstances:
- Third-party service providers: We share information with third-party service companies to facilitate or to provide certain Discovery Kids Content on our behalf. This will include companies providing IT infrastructure and services that facilitate our provision of the Website, App and the Discovery Kids Content to you, for example;
- IT support service providers; and
- other third-party service providers, for the purpose of tracking our customers’ use of the Website, App and the Discovery Kids Content or sending our marketing communications to you (in accordance with your marketing preferences).
We will only disclose such personal information as is necessary for these companies to provide their services to us. These companies are authorised to use your personal information only as necessary to provide their services to us.
- Merger or acquisition: When we need to transfer information about you if we are acquired by or merged with another company. If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified afterwards via email and/or a prominent notice on our App of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
7. International transfers (for EU subscribers)
When transferring personal information outside the EEA, we will:
- include the standard contractual data protection clauses approved by the European Commission for transferring personal information outside the EEA into our contracts with those third parties (these are the clauses approved under Article 46.2 of the General Data Protection Regulation (GDPR));
- ensure that the country in which your personal information will be handled has been deemed “adequate” by the European Commission under Article 45 of the GDPR; or
- (where appropriate when we are transferring your personal information to a recipient in the USA) ensure that the recipient is part of the Privacy Shield which requires them to provide similar protection to any personal data shared between Europe and the US.
You can find out further information about the rules on data transfers outside the EEA, including the mechanisms that we rely upon, on the European Commission website here.
8. Cookies and Similar Technologies
We will take appropriate technical and organisational measures to safeguard the personal information that you provide to us in order to prevent unauthorised access, collection, use, disclosure, copying, modification, deletion or other similar risks.
Whilst we take such appropriate technical and organisational measures, no transmission over the Internet can ever be guaranteed to be entirely secure. Consequently, please note that we cannot guarantee the security of any personal information that you transfer over the Internet to us.
We are committed to protecting your personal information using appropriate technical and operational measures such as access controls that restrict and manage the ways in which your personal information is stored and handled.
10. Data Retention
Information that you provide when creating an account, or that we collect automatically when you use the App, will be retained for one year after the date of your last activity on the App. This means that if you no longer have a live and valid entitlement to the App and have not logged into the App for over one year, then we will take steps to either delete or anonymise your personal information.
Financial and billing data will be maintained for seven years in accordance with our tax requirements. Location coordinates will be retained for 30 days from each time that you access and use the App.
11. Your rights
We are reliant on you to ensure that your personal information provided to us is accurate, complete and up-to-date. If there are any changes to your personal information, or if you believe that the personal information we have about you is inaccurate, incomplete, misleading or not up-to-date, please contact us so that we may take steps to update your personal information.
You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact us at email@example.com at any time. You have the right to request that we:
- provide access to any personal information we hold about you;
- correct or update any of your personal information which is out of date or incorrect;
- delete any personal information which we are holding about you;
- restrict the way that we process your personal information;
- prevent the processing of your personal information for direct-marketing purposes;
- provide your personal information to a third-party provider of services;
- provide you with a copy of any personal information which we hold about you; or
- consider any valid objections which you have to our use of your personal information.
We will consider all such requests and provide our response within a reasonable period (and in any event within any time period required by applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances.
If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.
12. Third party sites
14. Complaints, questions and suggestions
c/o DPlay Entertainment Limited
Chiswick Park Building 2
566 Chiswick High Road
London W4 5YB
You may also make a complaint to a European supervisory body for data protection matters. For example, in the UK this is the Information Commissioner’s Office who you can contact at:
The Information Commissioner’s Office
Water Lane, Wycliffe House
Wilmslow – Cheshire SK9 5AF
Tel. +44 1625 545 745
Please see our list of the various EEA supervisory bodies in the Annex below.
You may also seek a remedy through local courts if you believe your rights have been breached.
List of data protection authorities (EEA countries)
You have the right to lodge a complaint with local data protection authorities in the EEA if you believe we have not complied with applicable data protection laws.
The local authority differs depending on the country. Please see below for details of the local data protection authorities in the EEA countries in which we operate..
||Data protection authority
Tel. +43 1 531 15 202525
Fax +43 1 531 15 202690
||Commission de la protection de la vie privée
Rue de la Presse 35
Tel. +32 2 274 48 00
Fax +32 2 274 48 10
||Commission for Personal Data Protection
2, Prof. Tsvetan Lazarov blvd.
Tel. +359 2 915 3523
Fax +359 2 915 3525
||Croatian Personal Data Protection Agency
Tel. +385 1 4609 000
Fax +385 1 4609 099
e-mail: firstname.lastname@example.org or email@example.com
||Commissioner for Personal Data Protection
1 Iasonos Street,
P.O. Box 23378, CY-1682 Nicosia
Tel. +357 22 818 456
Fax +357 22 304 565
||The Office for Personal Data Protection
Urad pro ochranu osobnich udaju
Pplk. Sochora 27
170 00 Prague 7
Tel. +420 234 665 111
Fax +420 234 665 444
Borgergade 28, 5
1300 Copenhagen K
Tel. +45 33 1932 00
Fax +45 33 19 32 18
||Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon)
Tel. +372 6274 135
Fax +372 6274 137
||Office of the Data Protection Ombudsman
P.O. Box 315
Tel. +358 10 3666 700
Fax +358 10 3666 735
||Commission Nationale de l’Informatique et des Libertés – CNIL
3 Place de Fontenoy – TSA 8071575334 PARIS CEDEX 07
Tel. +33 1 53 73 22 22
Fax +33 1 53 73 22 00
||Die Bundesbeauftragte für den Datenschutz und die Informationsfreiheit
Tel. +49 228 997799 0; +49 228 81995 0
Fax +49 228 997799 550; +49 228 81995 550
The competence for complaints is split among different data protection supervisory authorities in Germany.
Competent authorities can be identified according to the list provided under
||Hellenic Data Protection Authority
Kifisias Av. 1-3, PC 11523
Tel. +30 210 6475 600
Fax +30 210 6475 628
||Data Protection Commissioner of Hungary
Szilágyi Erzsébet fasor 22/C
Tel. +36 1 3911 400
||The Icelandic Data Protection Authority
Rauðarárstígur 10, 105 Reykjavík, Iceland
||Data Protection Commissioner
Lo-Call: 1890 25 22 31
Tel. +353 57 868 4800
Fax +353 57 868 4757
||Garante per la protezione dei dati personali
Piazza di Monte Citorio, 121
Tel. +39 06 69677 1
Fax +39 06 69677 785
||Data State Inspectorate
Director: Ms Signe Plumina
Blaumana str. 11/13-15
Tel. +371 6722 3131
Fax +371 6722 3556
Tel: +423 236 60 90
||State Data Protection
Žygimantų str. 11-6a
Tel. + 370 5 279 14 45
Fax +370 5 261 94 94
||Commission Nationale pour la Protection des Données
1, avenue du Rock’n’Roll
Tel. +352 2610 60 1
Fax +352 2610 60 29
||Office of the Data Protection Commissioner
Data Protection Commissioner: Mr Joseph Ebejer
2, Airways House
High Street, Sliema SLM 1549
Tel. +356 2328 7100
Fax +356 2328 7198
Prins Clauslaan 60
P.O. Box 93374
2509 AJ Den Haag/The Hague
Tel. +31 70 888 8500
Fax +31 70 888 8501
Postboks 8177 Dep.0034 Oslo
Tel: +47 22 39 69 00
||The Bureau of the Inspector General for the Protection of Personal Data – GIODO
ul. Stawki 2
Tel. +48 22 53 10 440
Fax +48 22 53 10 441
e-mail: firstname.lastname@example.org; email@example.com
||Comissão Nacional de Protecção de Dados – CNPD
R. de São. Bento, 148-3°
Tel. +351 21 392 84 00
Fax +351 21 397 68 32
||The National Supervisory Authority for Personal Data Processing
President: Mrs Ancuţa Gianina Opre
B-dul Magheru 28-30
Sector 1, BUCUREŞTI
Tel. +40 21 252 5599
Fax +40 21 252 5757
||Office for Personal Data Protection of the Slovak Republic
820 07 Bratislava 27
Tel.: + 421 2 32 31 32 14
Fax: + 421 2 32 31 32 34
Ms Mojca Prelesnik
Tel. +386 1 230 9730
Fax +386 1 230 9778
||Agencia de Protección de Datos
C/Jorge Juan, 6
Tel. +34 91399 6200
Fax +34 91455 5699
104 20 Stockholm
Tel. +46 8 657 6100
Fax +46 8 652 8652
||The Information Commissioner’s Office
Water Lane, Wycliffe House
Wilmslow – Cheshire SK9 5AF
Tel. +44 1625 545 745