Privacy Notice

Last updated: 22 August 2024

Your privacy is important to us. This Privacy Notice explains what personal data Everyone TV Devices Limited ("Freesat", “we”, “us” and “our”) collect about you (“you”) and what we do with it. It also explains how you can exercise your privacy rights.

This Privacy Notice only applies to personal data that we collect through (or relating to)you:

purchasing a Freesat 4K TV box from Freesat (any model, including any Freesat Recordable 4K TV box) (“Freesat 4K TV Box”);
sending a product to Freesat for repair, replacement or return;
setting up your box as part of the installation journey for the first time or after a factory reset;
using your Freesat box.
contacting out Freesat advice lines, and our Facebook, Instagram, X (Twitter) and consumer help channels which you may use to find out more about or troubleshoot/report an issue.;
using the Freesat mobile app (“Freesat App”);
participating in competitions or promotions promoted by or on behalf of Freesat;
signing up to receive news and other updates from Freesat;
visiting our website or engage with the marketing emails that we send you;
being part of a look-a-like group which has a profile similar to that of our customers (we may be involved in such processing together with third party organisations, such as social media providers, YouGov or CACI); or
engaging with Freesat, or Freesat engages with you, for wider business purposes, including in the context of an existing or prospective supply, retail, distribution or other business relationship, or through industry forums or events (“Business Relationship”).

Please note that our website (including the webstore), Freesat 4K TV Boxes and Freesat App are not designed for children and we do not knowingly collect data relating to children. If we are made aware that we have received information from anyone under the age of 18, we will use reasonable efforts to locate and remove that information from our records on request.

When this Privacy Notice does NOT apply:

If you are a user of a Freesat-enabled device other than a Freesat 4K TV Box (such as one of the Freesat-enabled Humax or Manhattan boxes) (“Previous Generation Device”), in which case a different Privacy Policy applies to the collection and use of your personal data from the Previous Generation Device. Please refer to the Privacy Policy accessible via that device, or otherwise ask for a copy by contacting us using the details below. (Please note that where you use a Previous Generation Device, but also have a relationship with Freesat through one of the channels described above under ‘When does this Privacy Notice apply’ - for example - you use the Freesat App or have a Freesat account - this Privacy Notice will apply to the collection and use of your personal data in connection with those channels.)
If you use a Freesat-enabled TV to access Freesat satellite TV services (i.e. without a separate Freesat set top box), you should contact the manufacturer of the TV for a copy of their Privacy Notice, as Freesat does not collect any personal information from your use of a Freesat-enabled TV. However, we may process your personal data in relation to any other service described under “When does this Privacy Notice apply”, for example, where you have purchased a Freesat-enabled TV from our webstore, or sign up to marketing emails from Freesat.
If you use On Demand services, providers of On Demand services have their own Privacy Policies which will govern their collection and use of personal information. Freesat will know that you have accessed On Demand services (including which services) and where you have used the backwards TV guide (where available), we will know which programme you selected to initially access their content. Freesat will not know about your further use of an On Demand service unless the provider of the On Demand service shares this information with us. For further information, see the Privacy Policies of the On Demand service providers.
If you engage in market research directly with us (for example, through product or user testing, surveys, focus groups, or interviews) or with a service provider appointed by us, a separate privacy notice will apply and will be notified to you at the time of your participation.

This Privacy Notice explains who we are, how we collect, share and use personal information about you, and how you can exercise your privacy rights.

In this Notice, we use the phrase ‘Freesat Guide’ to refer to the user interface application on the Freesat 4K TV Boxes through which you navigate to and access content for viewing. Freesat Guide includes the electronic programme guide, the Home Screen, the On Demand screen and all other user interface screens through which you can access the content available through Freesat.

To find out more, please continue reading. We recommend that you read this Privacy Notice in full to ensure you are completely informed about your personal data.

What personal information does Freesat collect?

Depending on how you access Freesat services and your relationship with us, we may collect the following information about you:

Information you may give us:

When you make a purchase from us, we may collect your name, address, postcode and email address, delivery and/ or purchase date, together with the details of the product purchased including model and serial number, payment method, chosen delivery option and any returns, repairs or queries.
When you connect your box to the internet, either during original installation or at a later date, we may collect your email address and specific preferences detailed at the time.
When you connect your box to the internet, we will collect your postcode.
If you choose to provide it, we may also collect your postcode where you use the Freesat App.
If you call or email Freesat customer services, we may collect details of your box or other device relevant to your query (for example, your TV or mobile device). We may ask for your model, make and/or serial number, device ID, any queries or technical issues you raise (including with regards to warranty, repairs or returns), as well as your name, address, postcode, telephone number and email address, box or TV delivery and/ or purchase date, retailer from whom you purchased your box, bank account details and/or transaction information, such as the product price, payment method, and your payment details which are anonymised as per PCI DSS recommended standards.
If you sign-up to receive marketing communications from Freesat, for example via the website, through a promotion or when taking part in a competition, we will collect your name and email address, along with other information such as your current service provider(s) and your TV viewing preferences.
When you engage with us in the context of a Business Relationship, we may collect details such as your name, email address, telephone number, position and other details relating to your role, expertise and organisation.
If you contact us through social media, or enter into a Freesat competition through social media, such as Facebook, Instagram or Twitter, we may collect your social media handle, your name, details of your enquiry and any further contact or other details you share with us.
When you participate in a competition or promotion, we may collect your name, contact details, age or date of birth and any personal data in your entry.

Information we may collect from other sources:

When you purchase or otherwise acquire a Freesat 4K TV Box from a retailer (online or in-store) (including, for example, from Freesat via Amazon, eBay or from a broadband provider), we may receive certain information about your purchase such as your name, address, postcode and email address, delivery and/ or purchase date, together with the details of the product purchased including serial number, payment method and details of any returns, repairs or queries.
When we research potential business opportunities for the purpose of forming, or during the course of, a Business Relationship, we may collect information about you from your organisation, public records, third parties such as government or credit reporting agencies, or publicly available sources, such as social media platforms like LinkedIn.
When we attend industry forums and other events, we may collect information about you as a speaker or attendee, together with other information about your career and expertise.
We may obtain data from third party consumer profiling organisations, such as YouGov or CACI to help better understand our customers' demographics and lifestyles.
We may be involved in processing personal data (including postcodes) together with third parties, such as social media providers, YouGov or CACI, about households and individuals who are similar to our customers and to whom we may wish to send marketing (where we can do so in accordance with applicable data protection law).
Where you have purchased goods or services or entered into a promotion on a third party website and have consented to receive marketing emails from Freesat, we may receive your name and email address from such third parties in order to send you marketing emails in accordance with your request.
We may receive statistical information from social media platforms relating to targeted advertisements we instigate and which are shown on the social media platform. Such statistical information will be based on the information you may provide to the social media provider and the criteria selected to target advertisements to particular audiences.

Information we collect automatically when you use the Freesat App:

Information about how you navigate around the Freesat App, which pages or functionality you visit, use or don’t use.
Your device (phone or tablet) model, operating system, device ID and IP address.
Certain technical information automatically generated by your device or the Freesat App, for example, error messages or diagnostic information.

Information we collect automatically, including technical information, where your box is connected to the internet:

your postcode at the time of set-up, solely to provide you with the appropriate regionalised version of the satellite feed;
Unique information about your device (such as device type or unique device identification numbers).
The IP address associated with your set top box.
Information about your internet connection, including your current internet provider.
Information about how you or your household access, view, record or otherwise interact with channels and programmes using the functionality on the remote control.
Which On Demand services you use; if you access such services via the backwards TV guide (where available) we will know what programme you selected to initially access the On Demand platform. If you access On Demand content via the On Demand content provider’s icon on the On Demand screen, we will only know that you visited the third party On Demand content provider’s platform. As explained above, the On Demand services provider(s) will collect more information about how you use their services, but this is independent of Freesat and will be explained further in any notice relating to their platform.
Information about recordings you make or schedule using the recordings functionality on the box.
Certain technical information automatically generated by your device, for example, error messages, authentication, diagnostic and navigational information.
Information about your box settings, for example date and time of last session, hard disk size and where applicable, last viewing event

Information we collect when we use cookies and pixels when you engage with our website and marketing communications:

We use cookies, pixels and other means of tracking visitors and users (such as device ID), which enable us to collect data about what site you came from, what content you viewed on our website, which marketing communications you engaged with (including when and how), and which ads you engaged with on our and third party sites, in order to understand your interests and show and/or send you relevant ads or marketing communications in the future. For more information, see our Cookies Policy on our website.

How do we use your information?

In general, we will use the personal information we collect from you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your personal information. If we make any change to the way we use your personal information, we will ensure that we comply with the law when we do so. As a minimum, we will tell you about the change through an updated Privacy Notice and we will put appropriate safeguards in place to protect your information.

Please note, we will not use the personal information we collect from you to share box-specific viewing behaviours with the BBC and ITV, and other partners. Upon first installation or first connecting your box to the internet, you may see a screen which says that such data may be shared. Please ignore this screen which is part of the legacy software setting of our boxes.

We use your personal information for the following purposes:

To fulfil your order and provide customer care. We use your personal information to send you any goods you have ordered and to handle subsequent interactions with you concerning the order, including any warranty claims, registering your warranty with a third party (where applicable), provide customer care and after sales services. This includes where we source goods from a third party supplier who fulfils yours order and delivers the goods to you on our behalf (so called “drop ship arrangements”).

To deliver the Freesat service. We use information about your box or Freesat App software version, box ID and model/version, or TV, to ensure that your box, TV or your Freesat App receives all necessary software, technical updates and refreshed Freesat Guide content. We use your postcode information to tune your set top box to receive the applicable regional channels (except that if box is not connected to the internet, we don’t collect the postcode in our systems). We also use your postcode (if you choose to provide it) to display your regionalised channel listings within the Freesat App, or on the website(we don’t collect the postcode in our systems in these circumstances).
To deal with your enquiries and complaints and monitor issues that might affect other users too. If you need assistance at any stage, we will try to help you. We will use any personal information you provide to respond to your query and help us understand how we can improve our product and services in the future.
To understand how people use our services and how we can improve them in the future. In relation to each specific box, we capture information about how you use the Freesat service. By knowing how you navigate around the Freesat service and how you interact with the content we offer, we can learn what is relevant and interesting, what viewers might like to see more of and what they have yet to discover. It will also help us innovate so we can offer you advanced functionality in the future.
To understand who our customers are and how we can attract more people to use Freesat. We use information about you, such as your postcode, your use of the Freesat service and your response to marketing communications to understand what makes a Freesat customer and to understand what might attract people to Freesat.
To personalise the communications we send you.
As a consumer: Where we hold your email address, unless you have told us you do not wish to receive emails, we use your postcode and information about the products you have purchased/use, information you have told us about the content you like to watch, apps you use, which emails from us have interested you previously, the content you view on our website, abandoned baskets in an online shop and/or other information we hold about you (including information we obtain from our direct relationship with you or from other sources), to send you more relevant and/or timely recommendations or promotions in the future. These recommendations could relate to content available through the Freesat Guide or other products or services offered by Freesat, or where you have consented, to promotions, or other products and services offered by third parties with whom Freesat is collaborating. You can opt out of receiving emails from us at any time, by clicking on the unsubscribe link at the bottom of every email. You can also opt out of receiving communications by contacting us using the details below.
As a person connected to Freesat through a Business Relationship: Where we hold your contact details, we may use them to approach you regarding projects or initiatives we believe you might be interested in, including invitations to provide goods or services to Freesat. You may inform us at any time if you no longer wish to receive such communications. In the event that such communications are sent using automated means, you will be able to unsubscribe using the link provided in the communication.
To personalise the content or advertisements we show you on our website and on third party websites. We may use information we hold about your previous visits to our website or online shop, your marketing preferences, your engagement with marketing emails you receive from us or advertising shown to you previously on search engines or social media, to tailor the ads you see on our website or on third party platforms.
To identify new customers, create marketing profiles and inform our advertising and marketing strategies. We may use information we hold about products or services you use or have previously purchased (including broadband or TV provider, date and time of purchase, product type and model), information about when you have visited our website in the past and your postcode, alone and/or in combination with third party demographic data and/or data held by social media companies and search providers (such as Facebook and Google) to identify where our customers are based, and identify groups of potential new customers, including “lookalike” audiences, in order to better tailor our advertising or marketing strategies. For example, we may analyse the personal data, including but not limited to viewing behaviour, of people who have purchased a 4K TV Box from our webstore or retail partners and then compare them with other people in our database. If we identify people in our database who have similar personal data or behaviour to the original purchasers, we may then target marketing about Freesat to the new people we have identified in our database, for example by sending direct marketing emails. activities for our legitimate interests in providing the Services and ensuring they operate in a commercially suitable way which is tailored to your use and interests.
To send marketing to groups of potential new customers, including “lookalike” audiences, where we can do so in accordance with data protection law.
To monitor the service and our performance levels and to protect Freesat’s business. We monitor performance and use of your box and Freesat App to detect technical problems, establish support requirements, assess demand for support and availability issues. We also use information we receive about the use of the foregoing to protect Freesat’s and third party suppliers’, licensors’ and content providers’ software, hardware, intellectual property and other rights, as explained further in the terms and conditions of use.
To develop, manage and maintain Business Relationships. We may use information we hold about you to contact you to discuss, pursue or otherwise interact with you regarding a Business Relationship.
To manage and secure access to our offices and facilities. We use your information when we welcome you to our offices and we also use your information to protect our systems, online platforms and other technology.
To invite you to review our products or services. We may contact you by email to invite you to review our services and products you have received from us in order to collect your feedback and improve our services and products in the future.
To administer competitions or promotions. We will use your personal data in relation to the entry, administration and fulfilment of competitions or running of promotions that we operate, support or co-promote.
For the good governance of our business. This includes keeping financial records, to allow us to pay suppliers and to charge, invoice or refund customers.
To support any other legitimate interests of Freesat or third parties. Where it is necessary to use your personal information to support an important and legitimate interest of Freesat, and where such interest is not overriden by your fundamental rights and freedoms or other interests, Freesat may use your personal data. It is difficult to anticipate when such circumstances will arise, however examples of Freesat’s legitimate interests would include protecting Freesat’s reputation, or bringing or defending legal claims.

Who does Freesat share my personal information with?

We will not share share box-specific viewing behaviours with the BBC and ITV, and other partners. Upon first installation or first connecting your box to the internet, you may see a screen which says that such data may be shared. Please ignore this screen which is part of the legacy software setting of our boxes.

We may share your personal information with third parties as follows:

to enable third party services providers engaged by us to support our business by processing your information on our behalf. These third party services providers would be acting on our instructions and may enable us to provide more specialised and/or cost effective services. Examples of the type of third party service providers we are referring to include card payment, customer support and email communication service providers;
to our or our suppliers’ nominated third party carriers, warehousing and logistics providers to enable them to provide tracking information, contact you relating to delivery of a product, or to arrange a collection or return.
our nominated marketing agencies who provide marketing services on our behalf, including data analysts, media buyers and data segmentation agencies. These organisations help us to analyse our customer base to identify potential new customers and to target our marketing in a more relevant way.
social media sites such as Facebook and search engines such as Google in order to tailor our advertising to specific audience groups. In particular, we may share the email addresses of customers on our database with a social media network, in order than the social media network can match this with its users’ email addresses, in order to target or exclude our customers from targeted advertising;
third party companies such as broadband partners, TV channel or app providers who may be co-hosting a competition or running a promotion and you have consented to the transfer of your data;
to register a consumer warranty offered by a third party for a TV purchased directly from Freesat, where you wish us to (and we are able to) register the warranty on your behalf. We may pass your name and contact details as well as details relating to your TV and its purchase to such warranty providers. Please check the privacy notices of such third party warranty providers to understand how they process your data;
with third party review platforms, such as Trustpilot, to collect your feedback on our products and/or services. We will share details such as your name, email address and order or other reference number in order for you to leave a review of our products or services. Please check the privacy notices of such third party review platforms to understand how they process your data;
in the event that our business assets are sold or purchased by another company, our data records will be sold as part of our business. Similarly where divisions or the whole business is transferred to new owners, your personal data will be transferred to the new owner or controlling party;
with affiliate partners and related software platforms and marketing agencies, to enable them to process your cashback, commission and other rewards; and
in the unlikely event that we are required to share your information with any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person.

Legal basis for processing personal information

There are a number of different ways that we are lawfully able to process your data. We explain these below. However, if you have ever opted out of specific processing of your data by Freesat or have objected to our use of your personal information, we will respect this where the law requires or permits this; in such circumstances, the explanation below will not apply to you.

Where processing your data is necessary for the purposes of a contract we have with you:

Where you have purchased a product from us, we will use your personal information to send you the goods and handle subsequent interactions with you concerning the order, including, for example, any claims under the manufacturer’s warranty for the Freesat 4K TV Boxes.
When you register as a user of a Freesat 4K TV Box, you will enter into a contract with us agreeing to abide by the terms of use and we will use your personal information to enforce or otherwise monitor your compliance with the terms of use.

Where processing your data is within Freesat’s or our partners’ legitimate interests and where you would reasonably expect us or them to use your data in that way:

To deliver the Freesat service;
To deal with your enquiries and complaints and monitor issues that might affect other users too;
To understand how people use our services and how we can improve them in the future;
To understand who our customers are, where they are located and how we can attract more people to use Freesat;
Where we hold your contact details as a result of your previous engagement with us, to send you personalised communications;
To monitor the service and our performance levels and to protect Freesat’s business;
To send marketing via social media providers to audiences that "look like" Freesat customers; and
To develop, maintain or manage Business Relationships.

Where, as a consumer, we have your consent to process personal information:

If you are not registered with Freesat as a customer but receive email communications from us, we will have received your consent to send you these emails. If you no longer wish to receive the emails, please change your preferences by clicking on the unsubscribe link at the bottom of one of our emails.

In some cases, we may also have a legal obligation to process your personal information.

How does Freesat keep my personal information secure?

We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. Specific measures we use include keeping your personal information on secure servers and computer systems, protected from outside intrusions.

We also take measures to require third parties with whom your personal information is shared in accordance with this Privacy Notice have in place appropriate security measures and do not process your personal information for unauthorised purposes.

Is your personal data transferred to other countries?

Your personal information may be transferred to and processed in countries outside the UK. We will in such circumstances implement appropriate safeguards with our third party service providers and partners, having regard to the nature of the information being transferred and applicable data protection laws and regulations.

Data retention

We will delete your personal data when it is no longer reasonably required for the purposes described above, or, where applicable, if you withdraw your consent, unless we are legally required or otherwise permitted to continue to hold such data. We may retain your personal data for an additional period if deletion would require us to overwrite our automated disaster recovery backup systems, or to the extent we deem it necessary to assert or defend legal claims. In such circumstances, we will securely store your personal information and isolate it from any further processing until deletion is possible.

Your data protection rights

Individuals located in the UK and EEA have the following data protection rights. To exercise any of them see specific instructions below or contact us using the contact details provided under the "How to contact us" heading below.

You may access, correct, update or request deletion of your personal data.
You can object to processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data, (i.e. your data to be transferred in a readable and standardised format.
You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), please contact us using the contact details provided below.
You have the right to complain to a supervisory authority about our collection and use of your personal data. For more information, please contact your local supervisory authority. Contact details for the UK's ICO are here; Certain supervisory authorities may require that you exhaust our own internal complaints process before looking into your complaint.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Links to other websites

The Freesat service and mobile app may contain links to sites or applications operated by other entities, such as those of on demand services. We do not control the privacy policies or the terms of use of the websites or applications reached through the links from the App. These may differ from this Notice and terms of use of Freesat service and the mobile app. Ensure you check the relevant Privacy Notices of any third party so that you understand how they will use your data to determine if they are acceptable to you.

Changes to this Privacy Notice

We may update this Privacy Notice from time to time in response to changing legal, regulatory, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you (typically via notifications or banners), consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.

You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice. You are advised to visit the Notice as made available here: https://www.freesat.co.uk/legal-policies/privacy-notice on a regular basis to stay informed of our current privacy practices.

How to contact us

If you have any questions or concerns about Freesat or our use of your personal information, please contact us or contact us by following the instructions available here: https://www.freesat.co.uk/about/contact-us

or by post to: Legal Department, Everyone TV, Triptych Bankside (North Building), 185 Park Street, London SE1 9BL

The data controller of your personal information is Everyone TV Devices Limited, which is registered with the Information Commissioner’s Office with registration number Z1223141.