NOW PRIVACY AND COOKIES NOTICE

Introduction and scope

This privacy and cookies notice applies to the processing of personal data by NOW, including information we collect and store via cookies. NOW is a trading name of:

Sky UK Limited, if you access our UK products and services or our online digital platforms, or
Sky Ireland Limited acting as agent for Sky Subscribers Services Limited (Irish branch), if you access our Irish products and services or online digital platforms, and

references in this policy to “NOW”, “we” “us” or “our” should be interpreted accordingly. The processing explained in this notice may be carried out by Sky or other data controllers in the Sky group of companies (including Sky Subscribers Services Limited, Sky In-Home Service Limited and Sky Retail Stores Limited).

If you access the products and services or online and digital platforms of other Sky companies and businesses, you should refer to their privacy notices.

Types of information we process and where it comes from

Information you've provided to us, including through our websites, applications or products or when you access our services through applications on websites operated by other organisations.
Information about our content, products and services you've ordered or enquired about, including as collected on call recordings or via live chat as further described below.
Information which we acquire from other organisations, such as address verification services (e.g. Royal Mail in the UK), data brokers (e.g. Experian), property and lifestyle companies and credit reference agencies; including personal data that is publicly available. We acquire data from several organisations including Dunnhumby, CACI, 20ci, Mastercard, Emma’s Diary, and Game that we use to enhance the household profiles we use within AdSmart (as described further below). If you want to manage how these organisations use your personal data and share it with companies like NOW you should get in touch with them directly. In the case of Experian you can access their Consumer Information Portal here.
Information, uploads, user generated content, and comments you make about or generate in accessing the shows, channels, programmes, advertisements, products and services you use, for example how you access, view, share, contribute to, communicate with, download, or interact with them.
Information from the devices you use to receive NOW content, products and services, about your use of NOW, and/or third party content, products and services. This includes information about your device, machine or browser.
IP address, MAC address, unique identification number, online identifier (including device IDs and advertising IDs), browser information, location data port information, logical network address, and other similar identifying information required for your devices to communicate with websites and applications on the internet
Technical information from the devices you use to receive NOW content, products and services, for example, the collection of diagnostic and traffic or location information. Note that devices and applications have their own privacy settings and notices under which they collect your information, so please check and manage your device and application settings.
Information relating to your customer service interactions with us.

Images recorded by cameras fitted to Sky’s engineer vans.

How we use your information

The main purpose for which we process your personal data is so that we can provide you with content, products and services in accordance with the contract you have with us. This includes providing you with account management functionality (such as to update your contact information), processing and collecting payments, customer support (including diagnostics and trouble-shooting), call screening and blocking, and tailored and personalised recommendations (including by sending you newsletters about your service, content and relevant products). In addition, we also process your personal data to manage our products and services and traffic across our network. For example, NOW uses your information to facilitate the operation of its network by choosing the most efficient route to transmit your requests for a communications service through the various parts of its network of equipment and systems. This information is held securely within restricted areas accessible only by authorised personnel and in accordance with our data retention deletion and acceptable use policies.

If you’re a NOW member, where you give us consent, we will process your data in a number of ways, including:

In certain circumstances, in order to send you direct marketing. This may include communications by post, telephone, SMS, email or other electronic means (such as push notifications and in-product notifications), using the contact details you have provided, about content, products, and services, events and special offers, including, for a reasonable time after you have ceased your membership and are no longer a customer of ours. Where you receive Now through BT, you might not receive marketing from us for 6 months after you cancel, but we will send marketing to you after this period (unless you have opted out). In order to process your data for online and digital advertising (see below at “How we share your information for online and digital advertising”);

In order to process special category data you’ve provided to us. This may include using data you have provided to us or to our business partners concerning your health to provide assistance and support on your account.

We may also use your information to comply with our legal and regulatory obligations. This includes:

by enabling NOW to support customers whose circumstances might make them vulnerable in order to comply with Ofcom’s consumer protection conditions; and
by complying with police and other security investigations.

In some circumstances, we may process your personal data in reliance upon our legitimate interests, including to:

improve our content, products, services and member experiences by monitoring your use of our products and services and working with our suppliers to improve the products and services we offer, and develop new content, products and services;
monitor, record, store and use customer service communications we have with you. This helps us to improve the quality of our customer service, to confirm any instructions you give us, to create a member profile to have better conversations and/or for training, development and to meet our legal and regulatory responsibilities.
determine what offers for our products and services you are eligible for and how those offers will be made available to you. To do this, we create a profile about your time as a NOW member (for example, what products and services you have purchased, how you have used them, your offer and payment history, and your interactions with our customer service agents) and supplement this with information provided to us by other organisations as described in this notice. We use these profiles to target our offers at particular groups of members and personalise the messages.
send you direct marketing, including if you're a prospective member. This may include communications by post, email or other electronic means (such as push notifications and in-product notifications), using the contact details you have provided, about us and our content products and services, events and special offers, including, for a reasonable time after you have ceased your membership and are no longer a customer of ours (see further details below) We may also send you ‘abandoned basket’ marketing if you provided us your contact details (and we are permitted to use them for marketing) during our online sales journey but didn’t complete your purchase. We will tailor the marketing based on what you added to your basket.
For online and digital advertising (see below at “How we share your information for online and digital advertising”).
enable and deliver AdSmart and PromoStart. With AdSmart we show adverts within your TV services to the people most likely to be interested in the products and services being promoted. NOW can show different adverts to different households (in groups of 5,000 or more) watching the same programme or service. To do this we create a profile about a household comprising factors like interests, age and location using the information you have provided to us, information about your use of our products and services, and information we have acquired from other organisations (as detailed in the section above ‘Types of information we process and where it comes from’), and which we may combine with information received from brands wishing to target their advertising to a particular audience. We use this profile information to define groups of audiences to whom we send adverts. As part of showing these adverts, we carry out quality and frequency checks, such as whether adverts were displayed correctly and how often particular adverts have been shown, and we may also adjust the volume of ads you see. More information about how AdSmart can be used by advertisers can be found here. To the extent any special category data (for example, data concerning health) is processed within AdSmart, NOW relies on your consent for such processing.PromoSmart uses the same process described above to deliver tailored promotions (e.g. for upcoming content) within your TV services.
send you newsletters about your service, content and relevant products, which may include personalised and tailored recommendations.
for market research.
protect or enforce our rights or the rights of any third party such as by analysing activity on our network to help block unauthorised or illegitimate content, publication of, or access to it.
help prevent and detect crime and for the purposes of public and road safety.
We will also process your data where we need to in order to safeguard your vital interests or those of another person, for example to support crime prevention and protect the safety of members of the public and NOW employees.

How we share your information

We work with a number of suppliers to process your personal data for the purposes described above. Where these suppliers act on our behalf they must only process your personal data in accordance with our instructions. The categories of suppliers that we use include:

Engineer services firms,
Couriers (who may also process your contact data as a data controller when arranging or communicating with you about your delivery);
Payment service providers;
IT companies;
Customer service centres;
Debt collection agencies;
Other Sky group companies (Information can be found here) and other companies in the Comcast group (including NBCU companies, such as Peacock); and
Credit reference agencies (see further below);
Data brokers. This includes Experian who we use to match NOW’s own data with data provided by brands in order to identify households to target for specific advertising campaigns (for example, using AdSmart).

For example, this data matching process could be performed on behalf of a supermarket that wants to target its television advertising to its existing customers who live near one of its stores.
The brand will receive back a report showing how successful the advertising campaign was (e.g. how many times their adverts were viewed), but will not receive information or data about specific households that have seen their adverts;

Marketing companies that deliver our communications;

Sometimes we share personal data with suppliers and business partners who may process it outside of the European Economic Area (for example we use customer service centres in India and some IT services in USA). Most of the time the data we share will be with companies who supply services to us to enable us to supply our services to you. On occasion we may share personal data with our parent company, Comcast Corporation, based in the US. We grant these companies access to personal data only where necessary and only where appropriate security measures and controls are in place to protect your personal data in accordance with applicable data protection laws, regulations and regulatory guidance. This means these transfers will take place on the basis of an approved data transfer mechanism, such as EU Standard Contractual Clauses and EU Commission Decisions on Adequacy (country details here).
If you access NOW through BT, we and BT will share personal data with each other in order to provide you with NOW services and administer your account.
In the event the structure of our business changes so that another company in the Sky group provides our products and services to you, we will pass your personal information to that company. This includes, for example, a merger between us and another company, where another company acquires us or some or all of our assets, where we acquire another company or where our holding company restructures our corporate group.
We share your personal data with credit reference (e.g, Equifax) and fraud prevention agencies (e.g. CIFAS) for use in automated credit decisions, for the detection and protection against crimes such as fraud and money laundering, and for debt recovery purposes, as further explained below.Where we carry out a credit check with a credit reference agency, the information that we give them (including details of your credit application and financial details) and the details of the search itself will be recorded by that credit reference agency. We also exchange information with credit reference agencies on payment performance under your credit agreement on an ongoing basis and this information could be used by us and third parties to make future credit assessment decisions. As part of your credit check, the credit reference agency may also review information in relation to individuals who are financially linked to the primary applicant. If we, or a fraud prevention agency, determine that you pose a fraud or money laundering risk, we may refuse to provide the services or financing you have requested, or we may stop providing existing services to you. A record of any fraud or money laundering risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. Whenever fraud prevention agencies transfer your personal data outside of the European Economic Area, they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the European Economic Area. They may also require the recipient to subscribe to 'international frameworks' intended to enable secure data sharing. CIFAS has published more information about data transfers.
We share personal data with the courts, enforcement agencies (e.g. the police) and with regulatory authorities (e.g. OFCOM in the UK) where this is required in order for us to comply with our legal or regulatory obligations.

Where NOW receives a request for the ownership of a vulnerable customer’s account to be transferred to a nominated individual, personal data of the existing account holder may be shared with the new account holder. The ownership of the account would only be transferred once NOW has received signed acceptance and authorisation of the transfer from both parties.

How we share your information for online and digital advertising

We work with a number of partners to process your personal data for online and digital advertising purposes. This is different to our AdSmart service (described above) and for the purposes described in this section we use information collected through cookies or similar technologies on our websites, apps and devices (such as device IDs, mobile advertising IDs, and IP addresses). We may also use your phone number and email address. We will never share your name and physical address with any of our partners, and where we share an email address or phone number, it will be in a hashed format (which means that it has been converted into a stream of numbers or letters to make it more secure), and our partner will only see that data if it is already used for an account on their site. Where we use cookies and similar technologies on our and third party websites, apps, and devices (which you will separately be asked to accept), the data may be used in conjunction with other information we hold about you, such as your browsing behaviours, NOW viewing history, product holding or account history so we can show you more relevant content or offers. We perform due diligence before a company becomes a partner to ensure they are able to handle your data in a secure and responsible manner.

If you don’t want your data to be matched with the social media sites you use, you can follow the steps to opt-out of profiling and tailored advertising in the “Managing Your Marketing Preferences” section below. You might still see NOW posts or adverts on those sites, but they won’t be personalised using your NOW account data. You can also change your settings on that social media site to control the promoted posts you see there.

Where our partners are based outside of the European Economic Area, we work with these partners to make sure personal data is processed only if appropriate measures and controls are in place to protect your personal data in accordance with applicable data protection laws and regulations and regulatory guidance. Any data transfers will only take place on the basis of an approved data transfer mechanism as described in the section ‘How we share your information’ above.

Keeping your data up to date and your rights

Please contact us via My Account or via livechat on the NOW website to update, amend, correct your information. You also have the following rights:

to request access to, or erasure of, the personal data we hold about you (we explain more about this below)
to request us to restrict the processing of the personal data we hold about you
to object to us processing personal data relating to you
where you have given us consent to process your personal data, you have the right to withdraw that consent at any time
you have the right to obtain certain personal data from us in a format that can be transferred electronically to a third party (also called “data portability”).

Please note that some of these rights are not absolute. In some cases, for example, we may refuse a request to exercise particular rights if complying with it meant that we are no longer able to meet our contractual obligation to provide you with particular products and services, or if we had a legal obligation or right not to comply with the request. However, we will keep you informed as to the actions that we can take when you make your request.

Managing your marketing preferences

Direct marketing and tailored advertising

You can always choose not to receive direct marketing from us in the following ways:

via the tickbox in My account or by clicking on the “unsubscribe” link or replying STOP in any SMS you receive from us;
contacting NOW via live chat and explaining that you wish to opt out of direct marketing;
Emailing: optout@nowtv.com.

When you make a request not to receive marketing, it can take us up to one month to process that request.

If you receive direct marketing from other Sky group companies or in relation to other Sky services (such as Sky TV, Sky Broadband, Sky Mobile, or Sky WiFi) you can choose not to by contacting them directly.

You can also choose to opt out of profiling and tailored advertising (including AdSmart) in these ways:

contacting NOW via live chat and explaining that you wish to opt out of tailored advertising and profiling; and
emailing preferences@nowtv.com

Cookies and online behavioural advertising

Please refer to the Sky Privacy and Cookies Notice on sky.com.

Please see the section on “Controlling my Cookies” on how to adjust cookie settings for your devices.

COOKIES NOTICE

When you create or log in to an online account you agree to a cookie banner which provides a link to the Privacy and Cookies notice. Otherwise, by continuing to use our websites, content, products or services, you agree to the use of cookies as described in this notice.

You should be aware that when you access or use our content, products and services, we may collect information from the devices you use to receive NOW content, products and services by using “cookies”. We also collect such information from third party websites, mobile sites and from apps where we show our own adverts, using cookies and related ad technology.

If you'd like to learn how to manage these cookies and choose whether or not to receive information of different types, please see the section “Controlling My Cookies” below.

What are cookies and how do they work?

Cookies are small bits of text that are downloaded via the internet to the devices you use to receive NOW content, products and services and access online information. Your browser on your device makes these cookies available every time you visit the website again, so it can recognise you and can then tailor what you see on your device.

What do you use cookies for?

Cookies are an important part of the internet. They make using devices and accessing online information much smoother and affect lots of the useful features of websites. There are many different uses for cookies, but they fall into four main groups.

Cookies that are needed to provide the content, product or service you have asked for

Some cookies are essential to help your devices download or stream the information, or so you can move around websites and use their features. Without these cookies, content, products or services you've asked for can't be provided.

Here are some examples of essential cookies:

Positioning information on a smartphone screen, tablet device or other screen so that you can see the website and use its functionality.
Keeping you logged in during your visit or enabling you to stream content. Without cookies, you might have to log in on every website you visit or repeatedly adjust your volume and viewing settings.
When you add something to the online shopping basket, cookies make sure it's still there when you get to the checkout and to personalise our ‘abandoned basket’ marketing (where we are permitted to send you marketing) described in our Privacy Notice above.
Some are session cookies which make it possible to navigate through the website smoothly.

Improving your browsing experience

Cookies allow the application or website to remember choices you make, such as your language or region and they provide improved features.

Here are a few examples of just some of the ways that cookies are used to improve your experience on our applications and websites:

Remembering your preferences and settings, including marketing preferences, such as choosing whether you wish to receive marketing information.
Remembering if you've filled in a survey, so you're not asked to do it again.
Remembering if you've been to the application or website before.
Restricting the number of times you're shown a particular online advertisement. This is sometimes called 'frequency capping'.
Showing you information that's relevant to content, products or services that you receive.
Giving you access to content provided by social-media sites like Facebook or Twitter.
Showing 'related article' links that are relevant to the information you're looking at.
Remembering an application or website you've entered, such as weather forecasts.

Analytics

We like to keep track of what websites, information and links are popular and which ones don't get used so much, to help us keep our information relevant and up to date. It's also very useful to be able to identify trends of how people navigate (find their way through) our information and when and where 'error messages' may originate.

This group of cookies, often called 'analytics cookies' are used to gather this information. The information collected is grouped with the information from everyone else’s cookies. We can then see the overall patterns of usage rather than any one person’s activity. Analytics cookies are used to improve how an application, a website and its pages work.

Our applications, web locations, websites and communications you get from us contain small invisible images known as 'web beacons' or ' pixels'. These are used to manage the interaction between you and the online information or email and allow us to assess the effectiveness of the communication.

Affiliate cookies

We use 'affiliate' cookies. Some of our web based information will contain promotional links to other companies’ sites. If you follow one of these links and then register with or buy something from that other site, a cookie is used to tell the other site that you came from one of our sites. That other site may then pay us a small amount for the successful referral. For more information, see the Internet Advertising Bureau's guide about how affiliate marketing works. Note that when you visit those other companies’ sites, they will have their own privacy notices which set out what personal data they collect and how they will use it.

How we show advertising and marketing that is relevant to your interests

We sell space on Sky News and Sky Sports websites, mobile sites and apps to advertisers. The resulting advertisements often contain cookies and related ad technology that is placed by third party partners such as ad servers, ad agencies, ad network providers and research firms. These partners use the browsing information collected from these cookies to:

restrict the number of times you see the same advertisement (frequency capping) and
help show other advertisements that are relevant to you while you're accessing our information. This information about your browsing activity may be grouped with information about what is being accessed by other users, into interest groups, and then used to show you advertisements based on those interests. This is often called online behavioural advertising (OBA). OBA is a way of using information about your web-browsing activity, collected by using cookies, to group you with other users into interest groups and show you advertisements based on those interests.

Please select Privacy options in the footer of the Sky Sports or Sky News websites to manage your marketing preferences in relation to these third party advertising platforms and to understand more about how these third party advertisers may use your data. The details of the third party advertisers are available here

Sometimes our websites contain advertisements for our own Sky products. These advertisements use cookies in the same way as described above. We may also use cookies and related ad technology on third party websites, mobile sites and apps to show you OBA ads based on data collected by those cookies.

Cookies Explained

We do not sell personal data collected from cookies to any other organisations. If you want to know about data collected by third parties when you click on their adverts, you should check their privacy notices to find out what they collect, how they process it and what they use it for.

It’s easy to choose not to receive behavioural advertising and manage your cookies if you want to.

Controlling my Cookies

How can I see and manage my cookies in my browser?

Virtually all modern browsers allow you to see what cookies you've got, and to clear them individually or clear all of them. To find out how to do this, go to aboutcookies.org, which contains comprehensive information on how to do this on a wide variety of desktop browsers.

For the Sky News and Sky Sports websites and apps you indicate your preferences when you initially access the websites or app on your device. You can change your permissions at any time regarding your preferences in relation to third party advertising by selecting the Privacy options link that appears at the bottom of the website page.

How can I choose not to receive Online Behavioural Advertising and other tracking cookies?

In addition to the controls available on your computer, there are other ways of choosing not to receive Online Behavioural Advertising and other tracking cookies.

Please note that most of these choices work by setting a cookie that overrides the behavioural advertising cookie. If you clear all your cookies, you will also clear these opt-out cookies, therefore changing your preferences. In this instance you would need to choose again.

Organisations which provide more information on Online Behavioural Advertising

Evidon is a provider of privacy solutions.
Internet Advertising Bureau (IAB)Internet Advertising Bureau (IAB) “Your Online Choicess” page allows you to choose not to receive behavioural advertising from each of the advertising networks represented by the IAB.
Network Advertising Initiative (NAI) opt out page allows you to choose not to receive behavioural advertising from each of the ad networks represented by the NAI.
Digital Advertising Alliance’s self-regulatory program for online behavioural advertising choices page.

How long we keep your information

In this section, we explain the categories of personal data that we may keep, the periods applied and our reasons for keeping them.

These categories of data include member contact information, the addresses where we have provided services, account, account correspondence with notes and complaints, payment card and financial history. We keep this information for business, legal and regulatory purposes. Some of the legal reasons why we keep this data are: tax purposes, to enable us to defend potential legal claims under the statutory periods set out in the Limitation Act 1980 (for Sky UK Limited and other Sky companies based in England and Wales) or the Statute of Limitations, 1957 (as amended) (for Sky Ireland Limited). We will also need to keep some information to demonstrate compliance with the Data Protection Act 2018, for example, where we need to evidence compliance with suppression requests. This information is also helpful if we receive customer enquiries or complaints, and to verify your identity when you contact NOW.

These records are retained securely for 7 years after your account is cancelled. After this time they will either be securely deleted or anonymised. Some categories of data are deleted sooner where the data is no longer needed for the purposes for which it was collected. For example, call records are retained for 12 months and payment information is deleted 2 years after an account is closed or becomes inactive. For NOW Broadband, account closure occurs on the day your services cease, and for NOW, an account becomes inactive a year after you have last purchased a Now membership. Please read the ‘Keeping your data up to date and your rights’ above to understand how to get in touch to discuss a right to erasure request.

Complaints

If you wish to make a complaint about how we use your information, please Contact Us here and we will do our best to help. You may find our Customer Complaints Code of Practice helpful. If you are still unhappy, you can contact the Information Commissioner’s Office via their website or the Irish Data Protection Commissioner via their website.

Contacting NOW

If you have any queries or comments about this privacy and cookies notice, please contact Sky’s Data Protection Officer via dp.department@sky.uk.

Changes to this notice

We will occasionally update our privacy and cookies notice. We will post a notice of any material changes on our website prior to implementing the changes, and, where appropriate, notify you using any of the contact details we hold for you for this purpose. This may include phone, SMS, e-mail, post or interactive social media. We encourage you to periodically review our notice to be informed of how we use your information.

This privacy and cookies notice was last updated 11 March 2021

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