Effective from 25 May 2018
Objective and Scope
Asia TV Limited (“we”, “us”, “ATL”) values the trust placed in us by data subject (“you”, “your”, “user”, “subscriber”) and therefore, we follow the highest standards of privacy guidelines to protect the information shared by you with us.
By using ZEE Services (for example, when you register for an account, purchase a service, enter a contest or promotion, communicate with us, on our sites or applications), you agree to provide consent to our collection, use and sharing of your personal information as described in this policy. In some cases, particularly if you reside in a country governed by a data protection regulation, we may ask you to provide explicit consent to access our rvices before proceeding for further operations.
Collection and Use of Personal Information
‘Personal Information’ or ‘PII’ is defined as any information that identifies (whether directly or indirectly) to a particular individual or natural person, such as the individual’s name, postal address, email address, and mobile number indicating to that particular person or is identifiable. When anonymous information is directly or indirectly associated with personal information, the resulting information also is treated as personal information.
Information you provide to us
We may ask for and collect the following personal information about you when you use the Zee Services and without this information we may not be able to provide you with all the requested services;
- First/Last Name
- Mobile No.
- Email id
- Date of birth
Information we collect automatically
We collect information about you and your use of our service, your interactions with us and our advertising, as well as information regarding your computer or other device used to access our service. The information includes:
- Activities on the Zee Services such as type of content, watch history, search queries etc.
- Your interactions with our email, customer care and messaging platform.
- Geo-location information like IP addresses,
- Device information like device id, device model etc. and other unique identifiers
Inferred Information through usage and log data
We may track certain information about you based upon your behaviour on the Zee Services We use this information for conducting internal research on our users’ demographics, devices, interests, and behaviour to better understand, protect and serve our users. This information is compiled and analysed on an aggregated basis. This information may include the platform that you just visited (whether this platform is on Zee Services or not), which platform you next visit, your computer browser information.
We may also collect Your Information to track user behaviour and preferences for internal analytics and research. We may also use your information:
- to evaluate Your interest for various genres of content, services, offers;
- to perform analytics and conduct customer research, to determine your interest, for identifying Content that generate sales and to analyse traffic patterns.
If you choose to post messages on social media accounts, message boards, chat rooms or other message areas or leave feedback, we will collect that information you provide to us. We retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law.
If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the Zee Services, we may collect and store such information.
We identify and use Your IP address to help diagnose any problems with our server, and to administer ZEE5. Your IP address is also used to help identify you and to gather broad demographic information to customize your experience on the Zee Services .
We will occasionally ask you to complete optional online surveys. These surveys may ask you for contact information and demographic information (like zip code, age, etc.). We use this data to tailor your experience on the Zee Services , providing you with content that we think you might be interested in and to display content according to your preferences.
Information we collect through third parties
Third party services
If you link, connect or login through you the Zee Services account with a third party service i.e. Google, Facebook and Twitter they may send us information such as your registration and profile information from the service. Below mentioned are the information getting collected through social platforms such as:
- Facebook – Public information, Name, Email id, friend list
- Google – Email id
- Twitter – Email id, twitter handle, read tweets from your timeline and see who the user is following.
Based on Your purchase of a subscription package, our payment gateway partners including payment via Apple iTunes and Samsung Smart Pay may collect information with respect to your credit/debit card details or other bank account details along with your billing address. This information is stored by our payment gateway partners. For instance, the Zee Services will be using third party payment gateway partners to process and facilitate the payment of your subscription fee to the Zee Services for providing you access to the subscription. Please note that the Zee Services do not directly collect any financial information such as credit card or debit card or net banking details from you. Such payment gateway partners are not controlled by us. When you visit such payment gateways you do so at your own risk. These payment gateways may have their own privacy policies in place, which we recommend you review if you visit any such payment gateways. We do not assume any responsibility or liability for such payment gateways, the content of such payment gateways and their privacy practices, nor do we endorse them. We encourage you to familiarize yourself with the privacy statements provided by such payment gateways prior to providing them with information about you or entering into any transactions with them.
While transacting with these payment gateways, you may provide your financial information including without limitation your bank account details, credit card account details or your details pertaining to any payment settlement or pre-paid instrument service provider. You understand, agree and acknowledge that the Zee Services never receive your financial and payment information from these payment gateways. Your Personal Information, Sensitive Personal Data or Information and financial information will be dealt by these payment gateways in accordance with their respective privacy policies and other terms and conditions and Zee shall not be liable, accountable or responsible for Your Personal Information, Sensitive Personal Data and Financial Information which you provide to these payment gateways.
Purposes and Lawfulness of processing
We will only collect and process personal data about you where we have lawful basis. Lawful basis on which we would process our personal information includes obtaining explicit consent from you for processing your personal information or processing for “legitimate interests” where processing is necessary by us to provide you with customer support or process your data for providing premium services (For e.g. processing your information by our payment gateway service providers).
We use information to provide, analyse, administer, enhance and personalize our service and marketing efforts, to process your registration, your orders, payments, and to communicate with you related to below mentioned points. For example, we use information to:
- determine your general geographic location, provide localized content, provide you with customized and personalized viewing recommendations for movies and TV shows we think will be of interest to you, determine your Internet service provider, and help us quickly and efficiently respond to inquiries and requests;
- prevent, detect and investigate potentially prohibited or illegal activities, including fraud, and enforcing our terms (such as determining free trial eligibility);
- analyze and understand our audience, improve our service (including our user interface experiences) and optimize content selection, recommendation algorithms and delivery;
- communicate with you concerning our service (for example by email, push notifications text messaging, and online messaging channels), so that we can send you news about ZEE5, details about new features and content available on the Zee Services, and special offers, promotional announcements, and consumer surveys, and to assist you with operational requests such as password reset requests.
- notify you about changes in terms of service.
- allow you to participate in interactive features offered through our Services.
- carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing, chargeback and collection.
We may also use your information to contact you about our own and third-party services that may be of interest to you. If you do not want us to use your information in this way, please provide explicit consent for the same when we collect your data and/or adjust your user preferences in your account profile concerning your choices/preferences provided.
Disclosure to third parties
We do not share your personal information with Companies, organizations, or individuals outside of ATL except in the following cases:
We may share non-personally identifiable information publicly and with our partners — like publishers, advertisers, developers, or rights holders. For example, we share information publicly to show trends about the general use of our services. We also allow specific partners to collect information from your browser or device for marketing/promotions and measurement purposes using their own cookies or similar technologies.
We’ll share or disclose your personal information outside of ATL when we have your consent. For example, providing SMS and E-mail related services such as marketing newsletters, promotions and offers.
In the event of any requirement by court order, government or quasi-government agency to disclose Your Personal Information, We will disclose information as may be legally required. We may also disclose Your Personal Information if we, in the good faith believe that such disclosure is reasonably necessary to respond to subpoenas, court orders, or other legal process.
In the event ATL is merged with or acquired by another company or in case of re-organization or re-structuring of business, we and our affiliates may share your personal information, wholly or in part, with another business entity.
Your Controls and Choices
We provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your personal information. In accordance with applicable law, your controls and choices may include:
Managing Your Information
You can access and update some of your personal information through your account settings. If you have chosen to connect your Zee Services account to a third-party application, like Facebook or Google, you can change your settings and remove permission for the app by changing your account settings. You are responsible for keeping your personal information up-to-date. the Zee Services will send you periodic reminders via e-mail to maintain the accuracy of your personal information
Rectification of Inaccurate or Incomplete Information
You can ask us to correct inaccurate or incomplete personal information concerning you (this is the information which you cannot update yourself within your Zee Services account) by sending us an e-mail
Data Access and Portability
In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).
Data Retention and Erasure
We retain your personal information as long as necessary for the performance of the contract between you and us to comply with our legal obligations. If you no longer want us to use your information then you can request that we erase your personal information and close your Zee Services account. Please note that if your request for the erasure of your personal information;
We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend a Zee Services account for fraud or safety reasons, we may retain certain information from that account to prevent that user from opening a new account in the future.
We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting and auditing obligations.
Information you have shared with others (e.g., Reviews, forum postings) may continue to be publicly visible on the Zee Services , even after your account is cancelled. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
Because we maintain copies of the Zee Services to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
Withdrawing Consent and Restriction of Processing
For withdrawing your consent at any time during the tenure of your services with us, you may choose to do so by sending us an e-mail. We shall review your request and may ask you to verify your identity. Post verification we will withdraw the consent for which request was made by you and stop any further processing of your personal information
Objection to Processing
Where your personal information is processed for direct marketing purposes, you may, at any time ask us to cease processing your data for these direct marketing purposes by sending an e-mail to us
You can write to our data protection officer in case of any grievance or compliant. You have the right to complaint about the data processing activities carried out by ATL before the competent data protection authorities.
Please be aware that if you do not allow us to collect personal information from you, we may not be able to deliver certain experiences, products, and services to you, and some of our services may not be able to take account of your interests and preferences. If collection of personal information is mandatory, we will make that clear at the point of collection so that you can make an informed decision whether to participate. If you have questions about the specific personal information about you that we process or retain, and your rights regarding that personal information, please contact our customer support team
ZEE5 is not intentionally designed for or directed at persons less than 16 years of age. ATL does not knowingly permit any person who is under 16 years of age to register with the services or to provide any other personally identifying information. If ATL becomes aware that any personally identifiable information of persons less than 16 years of age has been collected on the Zee Services without verified parental consent, then ATL will take the appropriate steps to delete any such information and notify the parent.
However, we consider it the responsibility of parents to monitor their children’s use of our services. Nevertheless, it is our policy not to collect and process any personal information from children below 16 years of age or offer to send any promotional materials to persons in that category. ATL does not seek or intend to seek or receive any personal information from children. Should a parent or guardian have reasons to believe that a minor has provided ATL with personal information without their prior consent, please contact our customer support team to ensure that the personal information is removed from the Zee Services.
Data transfer, storage & processing globally
Security and compliance with laws
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your Zee Services account credentials have been lost, stolen, altered, or otherwise compromised or in case of any actual or suspected unauthorized use of your account, please contact us by contacting our customer support team.
Change in Policy
Data Controller Officer
The data controller for the Zee Services is Asia TV Limited (ATL) with the business address of: Hygeia Building, 66-68 College Road, Harrow, United Kingdom, HA1 1BE.
The data protection officer (DPO) appointed by ATL is Mr. Gordon Finlayson who can be contacted at firstname.lastname@example.org.
If you have any queries, complaints regarding the collecting, processing, transfer of personal data/information or regarding this policy please do contact our Data Protection Officer.