Privacy Policy
Effective: 21 May 2018

INTRODUCTION


Baby Network Limited, whose principal place of business is at 10 Hammersmith Grove, London W6 7AP (“Company” or “we” or “Baby TV”), which can be contacted at the email address privacy@babytvchannel.com  wants to inform you about how we collect, use and disclose personal data from and about you through the website www.babytv.com and its associated mobile sites, apps, tv applications, widgets, features, services, prize, promotions and contests (collectively, the “Baby TV  Services”), as well as about the minor under your parental or guardian responsibility, whose personal data may be provided by you through some of BabyTV Services (such as BabyTV Studio Clip, Birthday Clip, BabyTVClip Prize Promotion) (hereinafter"Your child")

You can find a Table of Content and a brief summary of this Privacy Policy in the chart below. For further details with regard to the data processing carried out by the Company click on the links in each section of the summary. 

Contents

1.WHAT AND WHO THIS PRIVACY POLICY COVERS?

2.WHAT TYPE OF PERSONAL DATA DO WE COLLECT ABOUT YOU AND ABOUT YOUR CHILD?

3. HOW DO WE COLLECT YOUR PERSONAL DATA AND YOUR CHILD’S?

4. ON WHAT LEGAL BASIS DO WE PROCESS YOUR PERSONAL DATA AND YOUR CHILD’S?

5. HOW DO WE PROCESS YOUR PERSONAL DATA AND YOUR CHILD’S?

6. WHO HAS ACCESS TO YOUR PERSONAL DATA AND YOUR CHILD’S?

7. IS YOUR PERSONAL DATA OR YOUR CHILD’S TRANSFERRED ABROAD?

8. WHAT ARE YOUR AND/OR YOUR CHILD RIGHTS WITH REGARD TO YOUR PERSONAL DATA OR YOUR CHILD’S?

9. WHAT IS GOING TO HAPPEN FROM MAY 25, 2018?

10. UPDATE TO THIS PRIVACY POLICY

11. CONTACT US

 

 

Issue

Information

1

What and who this Privacy Policy covers?

BabyTV is the data controller of the personal data we collect from and about you and about your child, through BabyTV Services.

This Privacy Policy applies to all users, including both those who use BabyTV Services without being registered or having subscribed and those who have registered with or subscribed to a BabyTV Service.

For further information click here

2

What kind of personal data do we collect about you and about your child?

BabyTV might collect data from and about you and about your child.

More in particular,BabyTV may collect (1) registration data regarding you and your child ,2) your child’s image (2) public data and information you post, (3)your social media data that you have permitted social media to share with BabyTV and (4) your activity data.

However, we do not collect either financial information from a payment service provider or sensitive data, relating to you or to your child.

For further information click here

3

How do we use your personal data and your child’s?

The main reason why we collect data about you and about your child, is to provide you with Company Services and to allow you to interact with such services.

For further information click here

4

On what ground do we use your personal data and your child’s?

Your personal data and your child’s personal data is mainly collected in order to provide you with Company Services.

Your personal data and your child personal data, as it may be the case, may also be collected to comply with applicable legal obligations and/or to protect the legitimate interest of BabyTV.

Failure to provide such data will mean that it is impossible to offer and/or provide to you BabyTV Services.

For further information click here

5

How do we process your personal data and your child’s?

The security of your data, as well as your child’s, is a priority for us. Accordingly, BabyTV has implemented adequate administrative, technical and physical measures designed to safeguard the personal data against loss, theft and unauthorized use, disclosure and modification.

For further information click here

6

Who can access your personal data and your child’s?

 

BabyTV might share your personal data and your child’s personal data, with (i) service providers, (ii) our affiliated companies and (iii) national authorities, when allowed by the applicable laws.

For further information click here

7

Is your personal data or your child’s transferred abroad?

Your personal data and your child personal data might be transferred to other countries within or outside the European Economic Area, including the United States of America. In any case, we always make sure that appropriate and suitable safeguards designed to protect your personal data and your child personal data (such safeguards being compliant with applicable laws) are in place to protect your personal data.

For further information click here

8

What are your rights and/or your child’s rights with regard to your personal data or your child’s?

Amongst other things, you have the right to request access to, to complete, to update, to amend and to delete your personal data, as well as your child personal data.

For further information click here

9

What is going to happen on May 25, 2018?

The EU General Data Protection Regulation 2016/679 becomes effective on May 25, 2018, which introduces certain additional rights for individuals in respect of their personal data.

For further information click here

10

Updates to this Privacy Policy

BabyTV may modify or update this Privacy Policy also in order to comply with applicable law.

Please look at the Effective Date at the top of this Privacy Policy to see when this Privacy Policy was last revised.

11

How can you contact us with regard to the processing of personal data?

You can contact us at the following email address privacy@babytvchannel.com.

 
1. WHAT AND WHO THIS PRIVACY POLICY COVERS?

BabyTV is  the data controller of the personal data (e.g. information that identifies a specific person, such as full name or email address) we collect from and about you through BabyTV Services, as well as about your child, if you use certain BabyTV Services (such as BabyTV Studio ClipBirthday Clip and BabyTV Clip Prize and Promotion) that is processed in compliance with the terms of this Privacy Policy.

This Privacy Policy and our Cookies Policy apply to all users, including both those who use BabyTV Services without being registered with or subscribing to a Company Service and those who have registered with or subscribed to a Company Service.

BabyTV Services are not intended for users below 18 years old. The personal data we may collect about minors are only those directly provided by the users of certain BabyTV Services (such as BabyTV Studio Clip, Birthday Clip and BabyTV Clip Prize and Promotion)[A3] )that, according to the BabyTV Terms & Condtions of such services have warrant to be the legal parent or guardian of the minors in question (as defined in this Privacy Policy: “your child”).

2. WHAT TYPE OF PERSONAL DATA DO WE COLLECT ABOUT YOU AND ABOUT YOUR CHILD?

BabyTV collects (1) registration data about you and about your child, as it might be the case, when you sign up or for a Company Service, (2) Child images, when you provide your child picture through certain BabyTV Services (2) your public data and posts that you share through BabyTV Services, (3) your data that you have permitted social media to share with this Company, (4) your activity data when you access and interact with a Company Service. More in particular, BabyTV collects the following types of data from and about you:

  1. Registration data is the information you submit to register for a Company Service. Registration Information may include, for example, your name, surname, email address, gender, country, postcode and birthday date, as well as your child name, birthday and country.
  2. Child image. When you upload or provide to us a  picture (JPEG or png format) of the minor under your guardian or parental responsibility through certain BabyTV Services (e.g. by uploading it on BabyTV Studio Clip);
  3. Public data and Posts which consist of comments or content that you post on BabyTV Services and the personal data about you that accompanies those posts or content, which may include a name, user name, comments, likes, status, profile information and picture. Public information and Posts are always public, which means they are available to everyone and may be displayed in search results on external search engines.
  4. Data from Social Media. If you access or log-in to a Company Service through a social media service or connect a Company Service to a social media service, the data we collect may also include your user ID and/or user name associated with that social media service, any information or content you have permitted the social media service to share with us, such as your profile picture, email address or friends lists, and any information you have made public in connection with that social media service. When you access BabyTV Services through social media services or when you connect a Company Service to social media services, you are authorizing BabyTV to collect, store, and use such data and content in accordance with this Privacy Policy.
  5. Activity Data. When you access and interact with BabyTV Services, we may collect certain information about those visits. For example, in order to permit your connection to BabyTV Services, our servers receive and record information about your computer, device, and browser, including potentially your IP address, browser type, and other software or hardware information. If you access BabyTV Services from a mobile or other device, we may collect a unique device identifier assigned to that device, geolocation data, or other transactional information for that device. Cookies and other tracking technologies (such as browser cookies, pixels, beacons) and Adobe Flash technology commonly called “Flash cookies”) may also be collected. These technologies may also be used to collect and store information about your usage of BabyTV Services, such as pages you have visited, content you have viewed, search queries you have run and advertisements you have seen. For more information please visit our Cookie Policy.
  6. Information from Other Sources. We may supplement the information we collect with information from other sources, such as publicly available information from social media services and commercially available sources.

We do not collect:

  • Financial information from a payment service provider: in some cases, we may use an unaffiliated payment service to allow you to purchase a product or make payments (“Payment Service”). If you wish to purchase a product or make a payment using a Payment Service, you will be directed to a Payment Service webpage. Any information that you provide to a Payment Service will be subject to the applicable Payment Service's privacy policy, rather than this Privacy Policy. We have no access to any payment data regarding the Payment Service.
  • Sensitive information: we ask that you do not send us, and you do not disclose, any sensitive personal data (such as social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through BabyTV Services or otherwise.

Linked Services. BabyTV Services may also be linked to sites, including social media sites, operated by unaffiliated companies, and may carry advertisements or offer content, functionality, games, newsletters, contests or sweepstakes, or applications developed and maintained by unaffiliated companies. BabyTV is not responsible for the privacy practices of unaffiliated companies, and once you leave BabyTV Services or click an advertisement you should check the applicable privacy policy of the other service.

3. HOW DO WE COLLECT YOUR PERSONAL DATA AND YOUR CHILD’S?

We use the personal data we collect from and about you to and about your child, as it may be the case:

  1. Provide BabyTV Services and features to you. When you participate to a BabyTV Prize Promotion)this may include showing your child image on Baby TV’s television channel and display your name and your child name on BabyTV website, among the list of the winners, if that is the case;
  2. Measure and improve those Company Services and features;
  3. Improve your experience with both online and off-line Company Services by delivering content you will find relevant and interesting;
  4. Allow you to comment on content, and participate in online games, contests, or rewards programs;
  5. Provide you with customer support and to respond to inquiries;
  6. Protect the rights of BabyTV and others: more in particular there may be instances when BabyTV may use such data, including situation where BabyTV has a good faith belief that such processing is necessary in order to: (i) protect, enforce, or defend the legal rights, privacy, safety, or property of BabyTV, our Company Affiliates or their employees, agents, contractors, licensors and suppliers (including enforcement of our agreements and our terms of use); (ii) protect the safety, privacy, and security of users of BabyTV Services or members of the public; (iii) protect BabyTV, as well as other third parties involved, such as Company suppliers, against fraud or for risk management purposes;
  7. Comply with the law or legal process; or (v) respond to requests from public and government authorities;
  8. Complete a corporate transaction, such as a proposed or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Company business, assets or stock (including in connection with any bankruptcy or similar proceedings).For example if BabyTVisinvolved in a merger or transfer of all or a material part of its business, BabyTV may transfer your information or your child personal data to the party or parties involved in the transaction as part of that transaction;
  9. Allow social sharing functionality; if you log in with or connect a social media service account with BabyTV Services, we may share your user name, picture, and likes, as well as your activities and comments with other users of that BabyTV Service and with your friends associated with your social media service. We may also share the same information with the social media service provider;

We may use anonymized personal data or information that does no longer identify you personally, even indirectly (e.g. statistics) for additional purposes or share it with third parties.

4. ON WHAT LEGAL BASIS DO WE PROCESS YOUR PERSONAL DATA AND YOUR CHILD’S?

The processing of your personal data for the purposes of:

  • Section 3, letters from a) to f) of this Privacy Policy is necessary for the provision of BabyTV Services and therefore it is mandatory since otherwise the services could not be provided;
  • Section 3, letter g) of this Privacy Policy is mandatory as it is requested under applicable laws; and
  • Section 3, letter h) of this Privacy Policy is performed on the basis of the legitimate interest of BabyTV and of its counterparties to perform such economic activities which is adequately balanced with your interest since the data processing is performed within the limits strictly necessary to perform such economic activities. This data processing activity is not mandatory and you can object at any time through the modalities as per Section 11 of this Privacy Policy.

On the contrary, the processing of:

Section 3, letter i) is discretionary, but without your consent, it is impossible   to connect to social media services account with BabyTV Service so that you will have to log to BabyTV Service using a different mechanism. You can revoke your consent to the processing of your personal data for the purposes as per Section 3, letter i) at any time by sending a communication to the e-mail address of Section 11 below.

Below you can find an explanatory chart on the matter above:

Purpose of processing

Legal Basis

Voluntary or necessary provision of personal data

Section 3 lett. a): Provision of Company Services

Performance of contract

Provision is necessary

Failure to provide data would cause impossibility for us to provide BabyTV Services

Section 3 lett. b): Analysis and improvement of Company Services

Performance of contract

Provision is necessary

Failure to provide data would lead to impaired Services

Section 3 lett. c): Improvement of user experience

Performance of contract

Provision is necessary

Failure to provide data would lead to impaired Services

Section 3 lett. d): User interactions (comments, contests participation, etc.).

Performance of contract

Provision is necessary

Failure to provide data would cause impossibility for us to provide BabyTV Services

Section 3 lett. e): Costumer support

Performance of contract

Provision is necessary

Failure to provide data would cause impossibility for us to provide BabyTV Services

Section 3 lett. f): Protection of Company and third parties’ interests

Performance of contract

Provision is necessary

Failure to provide data would cause impossibility for us to provide BabyTV Services

Section 3 lett. g): Compliance with legal obligation

Legal obligation

 

Provision is mandatory

Failure to provide data would cause impossibility to provide BabyTV Services

Section 3 lett. h): Corporate transaction

Legitimate interest

Provision is not mandatory

You can exercise your right to object to processing, but BabyTV may continue to process the data in case of compelling legitimate grounds, which override your interests or your child interests, or for legal defense.

Section 3 lett. i): Social media sharing

Consent

Provision is voluntary

You can exercise your right to withdraw your consent at any time, without consequences other than need to log in with a different account

 

5. HOW DO WE PROCESS YOUR PERSONAL DATA AND YOUR CHILD’S?

With regard to the above mentioned purposes, the data is processed through both electronic and manual means, and is protected through adequate security measures, taking into account the state of art, the costs of implementation and the nature, scope, context and purpose of processing as well as the risk of varying likelihood and severity for the rights and freedoms of individuals. With this regards, BabyTV uses appropriate administrative, technical, personnel and physical measures to safeguard personal data in its possession against loss, theft and unauthorized use, disclosure or modification.

6. WHO HAS ACCESS TO YOUR PERSONAL DATA AND YOUR CHILD’S?

For purposes consistent with the purposes as per Section 3 of this Privacy Policy, BabyTV may share your personal data, as well as your child personal data as it may be the case, to the following categories of recipients located within the European Union or outside of the European Union in compliance and within the limits of the provisions of Section 7 below:

Third parties service providers entrusted with processing activities and duly appointed as processors when required by applicable laws, e.g. cloud service providers, other entities of the group, providers of services instrumental to or supporting BabyTV Services - and thus, by way of example and without limitation, companies that provide IT services, experts, consultants and lawyers - companies resulting from possible mergers, demergers, or other transformations, and

BabyTV Affiliates, in their capacity as data controllers or data processors; a Company Affiliates list is available here https://www.21cf.com/businesses/;

Competent national authorities in order to comply with applicable laws.

The data processor appointed by BabyTV for hosting BabyTV Services are Applicaster (30 Stamford Street, London, SE1 9LQ) and XGlobe  (http://www.xglobe.com/company/contact). A complete list of the data processors may be requested from BabyTV at the addresses as per Section 11 of this Privacy Policy.

7.IS YOUR PERSONAL DATA OR YOUR CHILD’S TRANSFERRED ABROAD?

Your personal data or your child’s personal data may be transferred to countries within and outside the European Economic Area, in particular in the United Staes and Israel. Some non EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards. The full list of these countries is available at http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place appropriate and suitable safeguards designed to protect your data and your child personal data and the transfer of such data in compliance with  applicable data protection laws, such as standard contractual clauses adopted by the European Commission as per Articles 45 and 46 of the EU General Data Protection Regulation 2016/679 (the “Privacy Regulation”).

You have the right to request a copy of the above measure or further information on your personal data and/or your child personal data  by contacting BabyTV at the address indicated in Section 11 of this Privacy Policy.

8.WHAT ARE YOUR RIGHTS WITH REGARD TO  PERSONAL DATA?

You have the right, at any given time, also on behalf of your child, when you have provided to us your child personal data, to:

  1. Obtain confirmation as to whether or not your personal data and/or your child personal data exist and to be informed of its content and source, verify its accuracy or request rectification, update or amendments;
  2. Request the deletion, conversion to an anonymous form or restriction of any personal data processed in breach ofapplicable law;
  3. Oppose its processing, in all cases, for legitimate reasons.

With this regard you may send your request at the address outlined in Section 11 of this Privacy Policy. In your request, please include your email address, name, address, and telephone number and specify clearly what information you would like to access, change, update, surppress or delete.

Remember that even after you cancel your account, or if you ask us to delete your personal data and/or your child’s personal data, copies of some information from your account may remain viewable in some circumstances where, for example, you have shared information with social media or other services or, for example, when retention of such copies is necessary to comply with legal obligation or legal defense.  Because of the nature of caching technology, your account may not be instantly inaccessible to others.  We may also retain backup information related to your account on our servers for some time after cancellation or your request for deletion, to comply with applicable law.

With reference to your child personal data, all the above rights are also granted to your child, that will be able to exercise them when reaching the legal age to exercise such rights under applicable law. Until that moment you, as legal parent or guardian of your child, may exercise your child’s rights on his/her behalf.

Also, the additional rights outlined in Section 9 below will be effective from May 25, 2018.

9.WHAT IS GOING TO HAPPEN ON MAY 25, 2018?

On 25 May 2018, the Privacy Regulation becomes effective and the following provisions will apply:

A. Retention period applying to your personal data and your child’s

We will retain your data and your child’s data only for the period necessary to fulfill the purposes for which the data was collected as outlined in this Privacy Policy. In any case, the following retention periods will apply to the processing of such data for the purposes indicated below:

  • Data collected for the purposes as per Section 3, letters from a) to h) of this Privacy Policy is retained for the time of provision of BabyTV Services plus the length of any applicable statutory limitatation period following the termination of BabyTV Services. However the personal data under Section 2 no. 2) (i.e. Child images), will be retained for a shorter period, considering they refer to a minor.In particular Child Images that you have uploaded through BabyTV Studio Clip, Birthday Clip, BabyTVClip Prize Promotion and similar BabyTV Services that may be available from time to time, will be retained on our servers for 24 hours: for this reason the link you receive from us to download the Clip will expire after 24 hours from receipt, but you will have the possibility to download the Clip and keep your own copy (for which we will not be responsibleany more); in case you have entered the Baby TV Clip Prize Promotion or other similar prize promotions, the Child Images will be retained for 6 months from receipt.
  • Data collected for the purpose as per Section 3, letter i) of this Privacy Policy is retained for the time necessary to log on to BabyTV Services through a social network.

At the end of the retention period your personal data and your child’s personal data will be either cancelled, anonymized or aggregated.

B. Additional rights

In addition to the rights as indicated in paragraph 8 of this Privacy Policy and further to the application of the Privacy Regulation, you will also have the right, in any given moment, also on behalf of your child, to:

  1. Request to Company to limit the processing of your personal data and/or your child’s personal data where:
  • You contest the accuracy of such data until we have taken sufficient steps to correct or verify its accuracy;
  • The processing is unlawful but you do not want us to erase the data;
  • We no longer need the personal data for the purposes of the processing, but you require the personal datafor the establishment, exercise or defense of legal claims; or
  • Where you have objected to processing justified on legitimate interests grounds pending verification as to whether BabyTV has compelling legitimate grounds to continue processing.
  1. Object to the processing of such data;
  2. Request the erasure of such personal data without undue delay;
  3. Receive an electronic copy of your personal data, that you have provided to us, if youwould like to port your personal data to yourself or a different provider (“data portability”), when the personal data is processed by automatic meansand the processing is either (i) based upon we are relying upon your consent or (ii) the fact that the processing is necessary for the provision of BabyTV Service; and
  4. Lodge a complaint with the relevant supervisory authority. The UK supervisory authority for data protection issues is the Information Commissioner's Office (www.ico.org.uk).

With reference to your child’s personal data, all the above rights are also granted to your child, that will be able to exercise them when reaching the legal age to exercise such rights under applicable law. Until that moment you, as legal parent or guardian, may exercise your child rights on his/her behalf.


10. UPDATE TO THIS PRIVACY POLICY

BabyTV may modify or update this Privacy Policy for any reason (including, but not limited to, changes in applicable law and interpretations, decisions, opinions and orders relating to such applicable law). Please look at the Effective Date at the top of this Privacy Policy to see when it was last revised. Any changes to this Privacy Policy will be notified in advance by posting the revised Privacy Policy on BabyTV Services. If we make material chances to this Privacy Policy that  change the nature or processing or expand our rights to use the personal data we have already collected from you, we will notify you in advance and provide you with a choice about our future use of the personal data, as may be required by applicable law.

11. CONTACT US

If you have questions about this Privacy Policy, please contact BabyTV at the following email address privacy@babytvchannel.com.

Please note that this policy will be made available in Polish in due course.

 


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