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HBO GO - Polska

Polityka prywatności   Arrow
Data Policy
Processing of Personal Data
HBO Europe s.r.o., with its registered office at Praha 7, Jankovcova 1037/49, Czech Republic, registered in the commercial register administered by the City Court in Praha, File No. C 29418 ("HBO", "us" or "we") is the data controller for personal data processed under this Data Policy and is as such responsible for ensuring that the processing is conducted in accordance with applicable legislation.

By registering a user account, the user ("you" or “User”) acknowledges HBO's processing of your personal data in accordance with the provisions below.

Considering that this personal data policy ("Personal Data Policy”) constitutes an inseparable part of the Terms of Use and the definitions set out in the Terms of Use govern the interpretation of the Personal Data Policy, you are kindly requested to read the Terms of Use prior to reading the Personal Data Policy. Click here for the Terms of Use. [LINK TO Terms of Use] HBO uses cookies under the Cookies Policy that is inseparable part of this Personal Data Policy. Click here for the Cookies Policy [LINK TO Cookies Policy]

Summary

This is a summary of how we process your personal data. Information that is more detailed is set out after this summary.
The use of personal data is necessary for us to provide the Service to you. This means that you cannot object to us processing your personal data and in the meantime still require us to provide the Service. However, you are entitled to object to certain use of your personal data, for example if the relevant use is not required for us to be able to provide our Service to you, but only necessary e.g. to send you marketing by email. This right of yours is further explained below in Section 8. [link to Section 8]
As a data subject, you also have a number of other rights to gain insight into and influence how HBO processes your personal data. These rights include a right to gain access to the personal data HBO stores about you, request that we correct any incorrect data and a right to lodge complaints with supervisory authorities if you have concerns with HBO's use of your personal data. These rights are further explained in Section 8 of this Personal Data Policy. [link to Section 8]
The personal data that we process consist of the information provided by you when registering an account with HBO. We also process personal data that you otherwise may provide when contacting HBO (such as when calling customer service), and information provided by you when participating in a survey. HBO will also analyze how you use the Service, for example which movies and TV shows you watch, devices used to access the Service and locations from which the Service is used.
The purposes with our processing of personal data include the ability to deliver the Service to you through our different platforms and to fulfill our legal obligations. For example, we will;

1) Use your e-mail and password to make it possible for you to sign in to your account and use the streaming service provided by HBO;

2) Use your viewing history data, e.g. which movies or TV shows you have started watching and where you stopped, so that you can continue watching where you last stopped even if you change device;

3) Use your account identifiers, viewing history and device information to improve the quality and stability of our Service and to correct any errors, for example to minimize any interruptions and make the Service more accessible; and

4) Use your payment details and IP address to ensure that you are domiciled in a country where the Service is offered and allow you to use the Service in other countries in accordance with EU/EEA law.

Unless you inform us otherwise (opt out) when you sign up for the Service or anytime later, we will process account identifiers, viewing history and device information for profiling purposes. This means that we, based on your viewing history, device information and account identifiers will evaluate your preferences, and interests in different series and other content provided by us. HBO uses this data to provide you with customized information and news about series and special offers to analyze how the Service can be improved and to identify the content preferences of the Users in order to tailor the content offered to the Users.
If you do not want your personal data to be processed for purposes relating to direct marketing based on your profile you may contact us by email.
If, upon registration or later, you subscribed to a newsletter or any other marketing material, you can opt out from direct marketing by following the link at the bottom of a newsletter or any other marketing e-mail which you receive from HBO.
Your personal data will be transferred to companies outside the EU that we have engaged to, inter alia, be able to provide our Service to you. The relevant countries may not ensure the same level of protection for personal data as your country. However, the transfers are carried out in a manner to ensure that your personal data remains protected.

If you have any questions about how HBO uses and protects your personal data, you are always welcome to contact HBO's data protection officer.

Contact details to DPO: privacy@hbo.eu.

Below follows a more detailed description on how we use personal data.

1.	What entity is responsible for the processing of your personal data?
HBO Europe s.r.o., company registration no. 29418, is the data controller for the personal data processed under this Personal Data Policy.
Our contact details are:
Jankovcova 1037/49
170 00 Prague 7
Czech Republic
E-mail: privacypolicy@hbo.eu
Telephone no. +42061094444
2.	What is "personal data" and "processing of personal data"?

The term "personal data" as used in this Personal Data Policy is any piece of information that, either on its own or together with any other pieces of information, can be used to identify a living individual, and any other data that qualifies as personal data in accordance with the law applicable to HBO, including the General Data Protection Regulation (the "GDPR").

This Personal Data Policy covers all personal data that is in any form considered processed under applicable law in relation to you as a User, including personal data that is collected, kept, stored, transferred, disclosed or otherwise used by HBO.

3.	What personal data is processed and for what purposes?
HBO will only collect and process the personal data about you as explained in this Privacy Policy and as further set out in the "Data Processing Table" in Section 11. [make the underlined text a hyperlink to the relevant section.]
4.	How is your personal data protected?
HBO has implemented appropriate technical and organizational measures for the protection of your personal data to ensure that only authorized persons are given access to it. HBO uses technical security systems, such as firewalls, encryption technologies, passwords and anti-virus programs, to prevent and avoid unauthorized use of personal data.
5.	For how long is my personal data stored?
HBO will not store or process your personal data for any longer time than what is necessary to fulfill the purposes for the processing set out in this Personal Data Policy or according to any mandatory applicable law, as further specified in the "Data Processing Table" in Section 11. [link to section, as above]
Thus, when the purpose has been fulfilled in relation to a specific type of personal data, HBO will delete or anonymize the relevant personal data as soon as reasonably possible. Please note that we may store your personal data for sending you newsletters and marketing by e-mail purposes for a period after you have terminated the Service, to the extent allowed under applicable legislation. This time period may vary depending on in what country you live. You can at any time opt out from such newsletter or other marketing by following the link at the bottom of a newsletter or any other marketing e-mail which you receive from HBO.
6.	With whom do we share personal data?
HBO Group Companies
Your personal data may be provided to other companies within the HBO group and to companies with which the HBO group cooperates as the provision of such data is necessary for the purposes of the interests of HBO and the HBO group, namely, the provision of their services in the highest possible quality, direct advertising or other advertising, via e-mail or another channel, of services and products of HBO, companies within the HBO group or other companies and for market surveys. In the course of the review of such operations, HBO has established that the aforementioned interests are not overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
Companies engaged by HBO
Your personal data will be transferred to and processed by third party providers and suppliers which perform services for HBO, to enable these companies to perform the services requested by HBO. Such companies will be located both within and outside the EU. Services which will be requested include the provision of infrastructure and IT services, the provision of customer services, the processing of market surveys, management of send-outs via e-mail, the performance of statistical analyses and profiling, and processing of credit card and debit card transactions.
Only personal data that is necessary to fulfill the purposes stated in the "Data Processing Table" in Section 5 will be provided to the companies engaged by us. All third party providers and suppliers must follow HBO's instructions and applicable written data processor agreements and any other agreements that are in place between HBO and its third party providers/suppliers, and must implement appropriate technical and organizational measures for the protection of the personal data.
Authorities
HBO may need to provide personal data to relevant authorities (e.g. tax authorities or the police) in accordance with mandatory law and in order to fulfill legal mandatory obligations in each jurisdiction where HBO has Users. In the event of data breaches, certain personal data may need to be provided to data protection authorities.
7.	To what countries will your personal data be transferred?

Your personal data will be transferred to companies in other countries both within and outside the EU that we have engaged to, among other things, be able to provide our Service to you. The relevant countries outside the EU may not ensure the same level of protection for personal data as your country. In such cases, HBO will ensure that the personal data is adequately protected by the receiving parties in such countries. Adequate protection may typically be to impose on the receiving party contractual obligations that ensure that such party maintains the same high level of privacy and data security as practiced by HBO. Please see the Data Transfer Table in section 12 for a detailed description of the countries outside the EU to which personal data will be transferred. [place a link here, as above.]

8.	What are your rights as regards your personal data?
Right to access and rectification
You have the right to obtain information on what personal data HBO processes regarding you, the source of the data, for what purposes the data has been used, and the identity of parties to whom the data has been provided. You have also the right to, at any time, request a correction of any inaccurate or incomplete personal data. If a request is manifestly unfounded or excessive, in particular because of its repetitive character, HBO may charge a reasonable administrative fee or refuse to act on the request.
Right to erasure (‘right to be forgotten’)
You may request that your personal data be erased in specific circumstances if e.g. you have terminated the Service and (i) the personal data is no longer necessary in relation to the purposes for which is was collected and (ii) there is no lawful reason for continuation of processing, or the processing is unlawful or the personal data has to be erased to comply with a legal obligation in the European Union or the Czech Republic to which HBO is subject. This list is not exhaustive. Please contact HBO to receive further information on erasure of your personal data.
Right to object
You are entitled to object to certain processing or request that the processing of the personal data is restricted if(i)the personal data may not be correct, or (ii) you consider the processing to be unlawful, or (iii) HBO is basing its processing on a legitimate interest or (iv) you believe that HBO does no longer need the personal data for the purposes as set out in the "Data Processing Table" in Section 12 [place link here]. However, even if you object to certain processing, HBO may still continue such processing if allowed or obligated to do so under applicable legislation, for example to be able to fulfill legal requirements or to fulfil contractual obligations in relation to you.
Right to withdraw consent
If you at any time have provided a consent to HBO for processing of personal data (e.g. in case of newsletter subscriptions), you can always withdraw such consent for any future processing that is reliant on such consent.
Right to data portability
You have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine readable format. You may also ask us to transmit such data directly to another controller where technically feasible.
9.	What should you do if you have any complaints?
If you have any complaints on how we use your personal data, or would like further information, we would ask you to first contact our Data Protection Officer. However, you can also always make a complaint about how we process your personal data with the relevant public supervisory authority, specifically the authority where you live, work or where the alleged infringement has occurred. Use the following link to locate the relevant supervisory authority in your country: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
Without prejudice to your rights to make complaints, where you consider that your rights under this Data Policy have been infringed as a result of the processing of your personal data in non-compliance with the applicable laws, you may also bring proceedings before the competent courts, including the courts of the EU member state where you have your habitual residence.
In any event, it is advisable that, in order to resolve the issue more quickly and effectively, you send any complaints or enquiries to HBO first prior to addressing the authorities.
10.	Updates
This Personal Data Policy may be modified by HBO at any time. Should HBO wish to use personal data other than as stipulated in the Personal Data Policy in force at the time of data collection, notice of any such modifications will be provided to Users in a visible manner (e.g. such notice may be sent to you via email).
11.	Data Processing Table
The below Data Processing Table outlines the categories of personal data collected and processed by HBO in relation to its Users and the purposes for processing each category of data.
These terms are used in the table and may require an explanation:
-	Legal ground: According to applicable data protection legislation, Personal Data may only be processed if there is a legally valid ground to support the relevant processing. HBO bases its processing on the following legal grounds as set out in the table:

o Consent: The processing of personal data is based on your informed consent, e.g. to send direct marketing related materials such as electronic newsletters;

o Performance of a contract: The processing of personal data is necessary for HBO to be able to perform the Agreement with a User, e.g. to enable the User to sign into its account, use the Service and receive help from HBO's customer service;

o Legitimate interest: The processing is based on a legitimate interest that HBO has in the processing, e.g. to enable HBO to send churn surveys to Users. A requirement is that such a legitimate interest is not overridden by the interests, fundamental rights or freedoms of the Users and the Users have the right to object. In light of the limitations regarding data processing, the safeguards and the technical and organizational measures implemented by HBO, HBO has established that where the processing of your data is based on HBO’s legitimate interest, such interest is not overridden by your interests, fundamental rights or freedom relating to data protection. You may contact us at any time to request more information on how we have reached this conclusion for different types of processing;

o	Legal obligation: The processing is necessary for HBO to comply with legal obligations applicable to HBO, e.g. financial information that needs to be stored for bookkeeping purposes.

-	Retention time or criteria: In this column, HBO specifies how long the User's data will be stored.

Personal data type and source	Purpose	Legal ground	Retention time or criteria
Identification details including but not limited to account ID,
first name,
last name,
voucher codes and
age rate.

Source: Directly from the User at sign-up or from HBO's partners








To enable HBO to deliver the subscription service to its Users, including enforcing applicable terms and conditions (e.g. limitations on number of devices).	Performance of a contract
During the term of the User's account and until the end of limitation period but no longer than 3 years after the termination of subscription.
If the User never purchased a subscription (only the first step of the registration has finished), up to 12 months after account creation.
To enable HBO to provide customer service to its Users upon request (e.g. if a User contacts HBO), including troubleshooting.

To enable HBO to send reports to its vendors/partners for tracking purposes, if a User has signed up using a voucher code.	Legitimate interest

To enable HBO to prevent free trial period abuse and defend HBO from, fraudulent claims by Users in relation to payments.
To enable HBO to comply with legal obligations applicable to HBO, including responding to requests from authorities to access personal data.	Legal obligation
Contact information including but not limited to e-mail address, telephone number,

Source: Directly from the User at sign-up or contact with HBO's customer service	To enable HBO to deliver the subscription service to its Users including enforcing applicable terms and conditions (e.g. limitations on number of devices). Performance of a contract	During the term of the User's account and until the end of limitation period but no longer than 3 years after the termination of subscription.
If the User never purchased a subscription (only the first step of the registration has finished), up to 12 months after account creation.
To enable HBO, and its vendors where applicable to provide customer service to its Users upon request (e.g. if a User contacts HBO), including troubleshooting.
To be able to send the User relevant information in relation to the subscription/account, e.g. welcome e-mail, service updates and similar.
To be able to comply with legal obligations applicable to HBO, including responding to requests from authorities to access personal data.	Legal obligation
To enable HBO to prevent free trial period abuse and defend HBO from, fraudulent claims by Users in relation to payments.	Legitimate interest
To provide Users with marketing via e-mail, e.g. newsletters.	Consent	During the term of the User's account and 12 months after termination of subscription, unless the User has opted out from profiling or direct marketing
To be able to send Users surveys, which are voluntary to participate in. Legitimate interest
Payment details – including but not limited to debit card and credit card information (such as: credit/debit card number, expiration date, CVV/CVC number, and cardholder name, physical address) and payment history (including information about trial periods, periods without an active subscription etc.).

Source: Directly from the User at sign-up and, as regards payment history, continually as payments are made
To enable HBO to deliver the subscription service to its Users and to be able to charge the User for the subscription service.	Performance of a contract	During the term of the User's account and until the end of limitation period but no longer than 3 years after the termination of subscription.
If the User terminated its subscription during the free trial period, up to 12 months after end of free trial.




To enable HBO to provide customer service to its Users upon request (e.g. if a User contacts HBO), including troubleshooting.
To be able to send the User relevant information in relation to the subscription/account, e.g. notice about expiry of debit/credit card.
To enable HBO to analyze how the services offered to its Users can be improved.
Legitimate interest
To enable HBO to prevent free trial period abuse and defend HBO from, fraudulent claims by Users in relation to payments.
To be able to comply with legal obligations applicable to HBO, including bookkeeping and EU content portability regulations.	Legal obligation	During the term of the User's account and until the end of statutory retention period but no longer than 10 years after the termination of subscription.

Digital information data - including but not limited to geo-location/IP address, device type, device name, device ID, country code, ISP information, operating system version, password.

Source: Collected based on the User's use of the Service
To enable HBO to deliver the subscription service to its Users, including enforcing applicable terms and conditions (e.g. limitations on number of devices).	Performance of a contract	Geo-location/IP address, country code, ISP information: during the term of the User's account and until the end of limitation period but no longer than 3 years after the termination of subscription.
Device type, device name, device ID, operating system version, password event: during the term of the User's account and 12 months after termination of subscription.

To optimize the delivery of the Service to each specific device used to access the Service.
To enable HBO to provide customer service to its Users upon request (e.g. if a User contacts HBO), including troubleshooting.
To be able to send the User relevant information in relation to the subscription/account, e.g. service updates.
To enable HBO to improve its products and services offered to Users, including the security of HBO's systems/platforms.	Legitimate interest
To enable HBO to prevent free trial period abuse and defend HBO from, fraudulent claims by Users in relation to payments.
To enable HBO to comply EU content portability requirements. Legal obligation
Usage information - including but not limited to viewing history, device registration and deregistration, watch list, log in or log out events, etc. and results of marketing tracking.

Source: Collected based on the User's use of the Service	To enable HBO to deliver the subscription service to its Users, including the "continue watching" feature.	Performance of a contract	During the term of the User's account and 12 months after termination of subscription.
To enable HBO to provide customer service to its Users upon request (e.g. if a User contacts HBO), including troubleshooting.
To enable HBO to improve its products and services offered to its Users.	Legitimate interest

To enable HBO to track the direct marketing activities targeting the User. Consent	During the term of the User's account and 12 months after termination of subscription unless the User has opted out from profiling or direct marketing.
Call recordings - i.e. call recordings of inbound call to customer services

Source: Calls to customer service are recorded To improve the quality of the customer service provided to Users and others who call HBO's customer service.	Legitimate interest	12 months following the recording of the call.
Survey responses – i.e. User's responses to surveys that we ask Users to participate in, which responses may include personal information

Source: Directly from Users who choose to participate in surveys
To enable HBO to improve its products and services offered to its Users.	Legitimate interest	12 months following the completion of the survey.
Other information provided to customer service – including but not limited to further information that the User may provide to HBO's customer service in order for HBO to help the User with the matter, e.g. preferred language

Source: Directly from Users who contact HBO's customer service	To enable HBO to provide customer service to its Users upon request (e.g. if a User contacts HBO), including troubleshooting.	Performance of a contract	During the term of the User's account and until 12 months after termination of subscription.

12.	Data Transfer Table
The below Data Transfer Table outlines the category of personal data transferred by HBO to third countries (outside the EU), the purpose with such transfer and the safety measures that have been taken:
Personal data type that will be transferred The applicable third countries involved in the transfer of personal data	Purpose for the transfer of personal data	Safety measure(s) taken to ensure that the transfer of personal data complies with applicable law
Identification details
Contact information
Digital information data
USA troubleshooting and debugging
Standard Data Protection Clauses, (Article 46.2 GDPR) https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en

Identification details
Digital information data
Usage information	USA
Provision of a software used by HBO to monitor its subscription service
Standard Data Protection Clauses, (Article 46.2 GDPR) https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en

Identification details
Contact information
Digital information data
Usage information	USA Provision of IT systems used for marketing and campaign management

The EU-U.S. Privacy Shield, (adequacy decision, Article 45 GDPR) https://www.privacyshield.gov/welcome

Standard Data Protection Clauses, (Article 46.2 GDPR) https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en


Identification details
Contact information
Payment details	USA
Provision of billing services and related IT systems
The EU-U.S. Privacy Shield, (adequacy decision, Article 45 GDPR) https://www.privacyshield.gov/welcome

Standard Data Protection Clauses, (Article 46.2 GDPR) https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en

Identification details
Contact information
Digital information data
Usage information
Records of correspondence with customer service USA Provision of Customer Service /Technical support and related IT systems

The EU-U.S. Privacy Shield, (adequacy decision, Article 45 GDPR) https://www.privacyshield.gov/welcome

Standard Data Protection Clauses (Article 46.2 GDPR) https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en



Latest update on 22 May 2018