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Privacy Notice for ITV Racing App

Your privacy is our priority

Your data is important. It’s important to us, and we understand that it’s important to you. ITV is committed to safeguarding your information in line with the latest data protection and privacy laws. We also want to be transparent about what information we collect about you, how we use it, and how you can control what we do with this information.

About this notice

This privacy policy covers all versions of the ITV Racing App (collectively, the “App”) that are controlled by us and made available for mobile devices via iTunes or the Google Play Store (and any data shared with ITV by Sky Games relating to your participation in an ITV7 competition).

Our general privacy notice at itv.com/privacy also applies. In this notice, “ITV”, “we”, “us” and “our” means ITV Consumer Limited, and “Sky Games” means Hestview Limited.

Any personal information you supply to us via the App (and by other means) will be treated in accordance with this privacy notice.

The App includes functionality which enables users to enter the ITV7 competition.

This privacy notice does not cover:

  • your participation in an ITV7 competition, except in the limited scenarios where Sky Games shares information with us as set out in the ITV7 section below;

  • your use of Sky Games services;

  • the ITV Shop which is operated by Monterosa Productions Limited.

ITV7

The ITV7 section of the ITV Racing App is outside our control. Personal information collected as part of your general participation in ITV7 whether via the ITV Racing App, the ITV7 App, or the ITV7 website (the “ITV7 Services”) or your use of Sky Games' services will be processed in accordance with the Sky Games’ privacy notice at: https://itv7.itv.com/privacy. If you have any questions about their processing of your personal information, please contact them directly.

To enter an ITV7 competition you will need to register and login to a Sky Games account. To register you will need to submit your details including your name, date of birth and full address and Sky Games reserves the right to share your data with third parties in order to verify your identity. Sky Games may share your information with ITV when you use any of the ITV7 Services in the following scenarios:

  • if you have won an ITV7 competition where you have agreed to be referenced on-air in ITV content; and

  • where you have made a complaint or provided feedback.

In respect of the personal information shared by Sky Games with us, we will be an independent data controller.

What information do we collect?

We may collect the following information in the provision of the App to you:

  • how you access the App - for example your internet protocol (IP) address, device type and identifier, and operating system; and

  • information about your use of and interaction with the App.

Depending on your activity on the App, we may also collect:

  • a unique identifier which represents your device to enable us to avoid duplication of your responses to polls and other content within the App; and

  • information you disclose to us when you contact us with an enquiry, request or feedback.

If you choose to participate in ITV7 then you will need to submit some additional personal information to Sky Games via the ITV7 Services. Please see the section titled “ITV7” above for more information.

How will we use your information?

We and our authorised third parties will only process your personal information where we have legal grounds to do so. Please see the table below for the legal grounds for processing different types of information:


Purpose of processing: Provision of the App and play-out of content (including sending service messages, monitoring compliance with the Ts&Cs)

Data involved: Information about how you access the App (e.g. IP address, device type and identifier, and operating system)

Legal grounds for processing: Fulfilment of contract (App Ts&Cs)


Purpose of processing: Voting in polls

Data involved: A unique identifier which represents your device

Legal grounds for processing: Fulfilment of a contract (App Ts&Cs)


Purpose of processing: Queries and complaints handling - App related

Data involved: Names, email addresses, phone numbers, postal address and any personal data submitted by you to ITV or shared with us by Sky Games

Legal grounds for processing: Legitimate interest (for details see below)


Purpose of processing: Queries and complaints handling - ITV7 related*

Data involved: Names, email addresses, phone numbers, postal address and any personal data submitted by submitted by you to ITV*Note - only applies to queries/complaints submitted to ITV. Queries/comments submitted to Sky Games will be subject to Sky Games’ privacy notice as set out in the ITV7 section above

Legal grounds for processing: Legitimate interest (for details see below)


Purpose of processing: Analytics

Data involved: Device identifier, device type (including operating system), IP address, and information about your use of the AppLegal grounds for processing: Legitimate interest (for details see below)


Purpose of processing: Sending push notifications

Data involved: Device ID number, device type, device operating system type, device IP address, marketing consents and historyLegal grounds for processing: Your consent (for details see below)


Purpose of processing: Announcing an ITV7 winner on-air

Data involved: Names and cities, towns, villages or county

Legal grounds for processing: Your consent (for details see the ITV7 section above)


Legitimate Interests

Where we process your personal data on the basis of legitimate interest (as set out above), for analytics we are referring to our legitimate interest in understanding how people are using the App both to improve the App and for it to function more effectively. Therefore, we may use your personal data to understand and analyse use of the App. Where we process your personal data on the basis of legitimate interest for queries and complaints handling we are referring to our legitimate interest in trying to resolve your issue and to keep track of our progress in resolving your issue. In some cases, we may need to verify your details before we can resolve your issue.

When you contact us with feedback, we have a legitimate interest to pass your feedback on to the relevant team within ITV if appropriate, to Sky Games if your feedback relates to ITV7, or to the production company if your feedback relates to a programme that is not produced by ITV and if it is appropriate. We also have a legitimate interest in monitoring our communications to improve our customer services.

Will we send you marketing messages?

You may be asked if you would like to receive push notifications. You can turn these off at any time by adjusting the settings on your device.

If you register for ITV7 you may asked if you wish to subscribe to receive marketing about Sky Games services. These marketing messages are not subject to this privacy notice - instead, please refer to Sky Games' privacy (https://itv7.itv.com/privacy) notice for more information.

Cookies in this App

What are cookies? Cookies are small files of letters and numbers. These files are stored in the memory of your computer or other device such as mobile phones or tablet devices.

Cookies are created when you visit a website or other service that uses cookies (such as this App). Cookies are commonly used to help the user’s browsing experience and provide more information about the user’s experience and interests. This information is generally used to make content, services and advertising more relevant and useful during future visits.

For more details about cookies and details of how to delete and disable cookies you can visit www.aboutcookies.org.

Please note this App uses the following cookies or cookie like devices within it to perform the following functions:

  • LViS enmasse session id - this cookie is used to distinguish you from other users, provide some functionality of the App and analyse user interaction.

  • App functionality cookies (key_need_to_restart, key_reset_grid, key_project_config_url, key_config_project_uuid, key_menu_show_hidden_elements, keyShowSecretMenu, .lvis/lvisSettings, lvisConfig, lastSelectedConfig) – these cookies are used to make the App work e.g. by identifying issues or ensuring that the correct content is displayed.

  • CookieEnabled, keyCookieConfirmed – these cookies recognise whether you have already seen the cookies pop up banner so that we don’t display it again.

  • keyTips, keyLivePreviousMessage – these cookies recognise whether you have already seen other messages in the App so we don’t display the same message twice.

  • Tectonic and Monterosa cookies for voting and polls (lvis_storage.ser, key_registration_ticket, key_vote_logs_storage, key_secret_keys, keyRegistrationSuccessAccepted, this.mqqKey, lastAnsweredQuestion, votes, key_live_msg_was_shown, voteStateForPollServiceId: [serviceID]voteStateForPollId:[pollId], howto_already_shown, preShowTutorialShowedFlag, key_logs) – we use a number of cookies to check whether you have registered to vote, to record your votes, and to keep track of your participation in votes and polls.

  • Content tracker cookies (key_viewed_elements, key_reacted_elements, keyLikedElements, keyReactKVOStorage) – these cookies are used to collect information about how you use the App.

  • Firebase Crashlytics - we use Firebase Crashlytics provided by Google for the purpose of reporting and fixing crashes and problems with the App.

  • Firebase ID / IDFV – we use these identifiers to collect information about how you use the App.

  • Google Analytics - Google Analytics uses these cookies to provide us with analytical information about use of the App.

  • Push notifications - if you choose to receive notifications your device will store that choice and we use a unique ID to select notifications for you.

These cookies will be deleted if the App is deleted/uninstalled (although note there may be a period before Apple/iOS and/or Android decide to delete secure storage where App cookies may still be active). If you choose to participate in ITV7 then additional cookies may be used. Please see Sky Games’ privacy notice at https://itv7.itv.com/privacy for information about any cookies set by the ITV7 Services.

Identifiers

If you download the App on a mobile device with a Google Android or Apple iOS operating system then the App may check the status of user identifiers provided by that operating system or collect certain information submitted by you when voting. We will pass on that identifier and its status to permitted third parties so that you can vote in polls and for analytics purposes.

In what circumstances do we share your information?

We do need to share your personal data with third parties in some circumstances. This will only take place in accordance with the applicable law and for the purposes set out below. We pass information about you to other parties as follows:

  • to Sky Games where necessary to investigate and resolve complaints and to pass on feedback as set out in the Legitimate Interests section above;

  • to our outsourced service providers or suppliers to facilitate the provision of our products or services to our users, for example, disclosure to our polling provider in order to allow you to participate in, and for ITV to collect votes in relation to ITV Racing polls; and

  • to third party service providers and consultants in order to protect the security or integrity of our business, databases and systems and for business continuity reasons, including any third-party service provider used to screen communications for legal and regulatory compliance purposes;

  • to another legal entity, on a temporary or permanent basis, for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation, change of legal form, dissolution or similar event. In the case of a merger or sale, your personal data will be permanently transferred to a successor company;

  • to the police, regulatory bodies or legal advisers in connection with any alleged criminal offence, unlawful activity or suspected breach of the Terms of Use and/or the breach of other terms and conditions or otherwise where required by law or where we suspect harm or potential harm to others. We will cooperate with any law enforcement authorities or court order requesting or directing us to disclose the identity or location of or any other information about anyone breaching any relevant terms and conditions or otherwise for the prevention or detection of crime or the apprehension or prosecution of offenders; and/or

  • to any other third party where you have provided your consent.

We also share your personal information with other parts of the ITV group of companies.

We do this to:

  • provide a more personalised experience across our different products and services

  • provide and/or manage cross or intergroup products and services; and/or

  • provide other services and products you request or to promote those which might be of interest to you.

For privacy notices of other ITV group companies please see www.itv.com/groupprivacy.

Service providers based outside Europe

In providing our services to you we may use third party companies to perform or enable us to provide some of the functions of our services. Some of these companies may be located, or have servers that are located, outside the European Economic Area. For details on how we protect your data where this is the case, please see our general privacy notice at itv.com/privacy.

Third Party Links

The App may contain links to other websites which are outside our control and are not covered by this privacy notice. If you access other websites using the links provided, the operators of these websites may collect information from you (including by using cookies) in accordance with their own cookie policy and / or privacy notice, which may differ from ours.

Any personal data which you submit in accessing the App via the Apple and/or Android device app store providers (including without limitation Google Play, Samsung App store or other Android store) is held by the app store provider under their privacy notice and cookie policy.

Under-17s

We do not intentionally collect any information via the App from children under 17 years of age, and we shall delete the details of such users when a parent or guardian notifies us that any details have been obtained from their child.

What are your rights?

Any personal information you supply will be treated in accordance with applicable data protection laws including the General Data Protection Regulation (the “GDPR”) and any other applicable or superseding legislation. We are committed to delivering the rights that individuals are entitled to under data protection laws in the UK. These are:

  • the right to request a copy of the personal information we hold about you. To do this, please contact us at myprivacy@itv.com making clear that you are requesting a copy of your personal information and including full details of what you require. You may also be required to submit proof of your identity.

  • the right to object to your personal information being used for direct marketing. Where required we will ensure we obtain your consent before undertaking marketing and you will have the ability to opt out.

  • the right to object to your personal information being processed where the legal basis for the processing is our own legitimate interests as a business (see ‘How will we use your information?’ section above). We will comply with such a request unless there is a lawful reason for not doing so, such as when we need to continue to process your information to defend a legal claim or if this information is necessary for the ongoing provision of our products and services.

  • the right to rectification. You may request that we correct any inaccurate and/or complete any incomplete personal information.

  • the right to withdraw consent. Where we are processing your personal information on the basis that you have given us your consent to do so, you may withdraw your consent at any time. Please note that if you withdraw your consent, you may not be able to benefit from certain service features for which the processing of your personal information is essential.

  • the right of erasure. You may request that we erase your personal information and we will comply, unless there is a lawful reason for not doing so. For example, there may be an overriding legitimate ground for retaining your personal information.

  • the right to data portability. In certain circumstances, you may request that we provide your personal information to you in a structured, commonly used and machine readable format and have it transferred to another provider of the same or similar services to us. Where this right is applicable, we will comply with such transfer as far as it is technically feasible. To submit a request please contact us at myprivacy@itv.com making clear that you are requesting a copy of your personal information and including full details of what you require. You may also be required to submit proof of your identity.

  • the right to lodge a complaint with the supervisory authority. We suggest that you contact us about any questions or if you have a complaint in relation to how we process your personal information. However, you do have the right to contact the relevant supervisory authority directly. To contact the Information Commissioner’s Office in the United Kingdom, please visit the ICO website (www.ico.org.uk) for instructions.

Data controllers

App: ITV Consumer Limited (company number 2937518) with registered office at 2 Waterhouse Square, 140 Holborn, London, EC1N 2AE and VAT registration number 197 0041 67.

ITV7 Services: (Sky Games) Hestview Limited (company number 01100741) with registered office at 2 Wellington Place, Leeds, West Yorkshire, LS1 4AP. Hestview Limited may share with ITV information regarding the winner of an ITV7 competition where the winner has agreed to be referenced on-air in ITV content and information provided by users to Hestview in complaints or feedback, and in respect of this data ITV Consumer Limited will be an independent data controller.

If you want to contact us about our services, you can find more details at www.itv.com/contact. If you wish to contact us generally about our privacy notice or with any privacy queries, please email our Data Protection Officer at myprivacy@itv.com.

The Information Commissioner’s OfficeThe Information Commissioner’s Office (ICO) regulates our processing of your personal information. You have the right to lodge a complaint with the ICO. Details of how to contact the ICO can be found on their website at ico.org.uk.

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