Revised 22 October 2019
A. Who we are:
We are Dplay Entertainment Limited. We provide a range of free and paid-for content services, such as dplay, which is available through our website (www.dplay.co.uk) or our mobile application in the United Kingdom and Ireland (the "Services").
We are based in the United Kingdom. Our company details are in section 1 below.
We value your privacy and want to be accountable and fair to you as well as transparent with you in the way that we collect and use your personal information. Our overall aim is to ensure that our collection and use of personal information is appropriate to the provision of the Services to you, and is in accordance with applicable data protection laws. We also want you to know your rights in relation to your information which you can find in section 10.
- Who we are
- The personal information we collect about you
- How we store and use your personal information
- 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
D. Your rights to object:
You have various rights in respect of our use of your personal information as set out in section 10. One of the fundamental rights to be aware of is that you may ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our, or another person's, legitimate interest.
You can find out more information in section 10.
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 (“dplay”) and we are the data controller of the personal information that we collect from you.
We do not and will not knowingly collect information from any unsupervised child under the age of 13. If you are under the age of 13, you may not use the Services unless your parent or guardian has provided us with their consent for your use of the Services.
3. The personal information we collect about you
Information from your online interactions
We collect the following information from your interaction with the Services:
- how you access our Services and the devices that you use to access our Services. This includes collecting unique online identifiers such as IP address and your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Services;
- information about how you use the Services, including but not limited to your video consumption and playback, sign-in and sign-out, playback error and browsing information; and
- any e-mail communications, including attachments, which you send to us.
Third parties or publicly available sources
We may receive personal information about you from various third parties as set out below:
technical data from the following parties:
- analytics providers based inside and outside the EU, such as Adobe Analytics;
- advertising networks based inside and outside the EU, such as Facebook Audience Network and FreeWheel; and
- search information providers based inside and outside the EU, such as Google and Adobe Audience Manager.
For further information about how each of these parties collect and use your data, please see the 'Third-Party advertising companies' section below;
- identity and contact data from data brokers, aggregators and publicly available sources; and
- third parties that provide certain services to us within the Services, for example, facilitating and administering customer feedback forms, newsletter subscriptions and competitions.
4. How we store and use your personal information
We store and use your personal information for the following reasons:
- it is necessary in order for us to fulfil a contract that we have with you;
- it is required in our legitimate interests;
- it is required in order for us to comply with our legal obligations; or
- it is permitted because you have provided your consent to us.
Where we need to collect personal information by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (in this case, to provide you with the Services). In this case, we may have to cancel the Services but we will notify you if this is the case at the time.
Necessary for us to fulfil our contract with you
- making the Services available to you;
- providing any Services that you request;
- administering the Services; and
If you have entered into a competition on the Services, then, pursuant to the competition terms and conditions provided to you at the time of entry, we will use your contact details (such as e-mail address or postal address) to administer your entry and inform you if you have won a prize.
Our legitimate interests
Sometimes, our use of your personal information is for purposes which are ancillary to the provision of the Services. In those circumstances, we believe we have a legitimate interest in handling your personal information, and believe that the benefits of this storage and use of your personal information will outweigh any potential impact on you and not unduly prejudice your rights or freedoms. The relevant circumstances are:
- detecting and preventing fraud;
- keeping our Services, 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;
- analysing your video consumption, playback and general viewing habits in order to understand viewership and update and improve our Services, including but not limited to our content, features, scheduling, technology and products;
- determining the effectiveness of our promotional campaigns and advertising;
- to use IP addresses and device identifiers to identify the location of users and block any unauthorised users;
- deal with your enquiries and requests (for example if you were to call customer services to ask for help and assistance then we would need to process your contact details);
- suggest similar products to you that you may be interested in and to understand which products appeal to our customers; and
- where you have opted out of our marketing or objected to receiving e-mails from us, then we need to keep records of your preferences to ensure that we do not contact you if you have asked us not to.
If we rely on our (or another person's) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person's) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information. You can ask us for information on this balancing test by using the contact details at section 13.
When you have provided consent to us
Where you have given us your consent, we will contact you by e-mail with products and Services which we think may interest you.
If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by contacting our Data Protection Officer at DPO@discovery.com and we will stop doing so.
For legal reasons
We will use your personal information in order to comply with our legal obligations. These obligations include:
- us complying with our legal obligations; and
- if we are asked by regulatory bodies or law enforcement agencies to share your personal information with them.
We collect anonymised details about visitors to our website for the purposes of aggregating statistics or reporting purposes. However, no single individual will be identifiable from the anonymised details we collect for these purposes.
Third-party advertising companies
We want to make sure that our advertising and marketing is relevant and interesting to you and our other users. To achieve this, we use third-party advertising and technology companies to serve ads and/or provide aggregated data to assist in serving ads when you visit or use our Services. This includes third party technology companies which collect data about you in order to build a profile of your preferences based on your activities when you visit or use our Services. We also use these companies to automatically collect data from you when you use our Services in order to help us identify the ads that are served to you and what you do after seeing those ads. In addition, we also share data with providers of web analytics tools, such as Google Analytics, which we use to analyse your use of the Services.
These third party advertising companies collect, store and use data by integrating cookies and other tracking software on our Services. Please see our Cookies Policy at for further information. In some cases these third parties will also use the data that they collect for their own purposes, for example they may aggregate your data with other data they hold and use this to inform advertising related services provided to other clients and work with other advertising companies and share your personal information with such companies as part of the process.
We might also share your data with social media or other similar platforms, so that you and other people can see relevant content on that platform. For example, we may use the Facebook Custom Audiences service and share your e-mail address in a protected format with Facebook so that we can: include you in a custom audience that we will serve relevant advertising content to on Facebook; or create an audience of other Facebook users based on the information in your Facebook profile.
5. How we share your personal information and who we share it with
We disclose information under the following circumstances:
● Third-party service providers: When we share information with third-party service companies to facilitate or to provide certain services on our behalf. This will include:
- IT infrastructure companies that facilitate our provision of the Services to you;
- IT support service providers; and
- other third-party service providers, for the purpose of providing or tracking our customers' use of the Services.
These companies are authorised to use your personal information only as necessary to provide these 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 e-mail and/or a prominent notice on our Services of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
6. International transfers
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"); or
- 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 US) ensure that the recipient is part of the Privacy Shield which requires them to provide similar protection to any personal information 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 .
7. Cookies and similar technologies
Technologies such as cookies, beacons, tags and scripts are used by us and our partners, affiliates, or analytics or service providers. These technologies are used in analysing trends, administering the Services, tracking users’ movements around the Services and to gather demographic information about our user base as a whole. We receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
Whilst we take appropriate technical and organisational measures to safeguard the personal information that you provide to us, no transmission over the Internet can ever be guaranteed 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.
9. Data Retention
We may delete your personal information (including any account that you set up to use on the Services) if you do not use the Services in five years.
In some circumstances, we may anonymise your personal information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
10. Your rights
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 our Data Protection Officer at DPO@discovery.com at any time. You have the right to request that we:
- provide access to any personal information we hold about you;
- 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.
If we delete any personal information which are holding about you, this deletion may only relate to the Services and not any other service provided by us in other jurisdictions. You should make requests for each account that you may have set up to access the Services or any other service provided by us.
11. Third party sites
13. Complaints, questions and suggestions
We have a Data Protection Officer that can assist with all queries regarding our processing of personal information. Our Data Protection Officer can be contacted by e-mailing DPO@discovery.com.
In the EEA, you may also make a complaint to our supervisory body for data protection matters (the Information Commissioner's Office in the UK) or seek a remedy through local courts if you believe your rights have been breached.
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 the Annex for your local data protection authority.
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.
Borgergade 28, 5
1300 Copenhagen K
Tel. +45 33 1932 00
Fax +45 33 19 32 18
Office of the Data Protection Ombudsman
P.O. Box 315
Tel. +358 10 3666 700
Fax +358 10 3666 735
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 here
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.
Tel: +47 22 39 69 00
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
Tel. +44 1625 545 745