Privacy & Cookies Policy
CRIME + INVESTIGATION PLAY
PRIVACY AND COOKIE POLICY (Last updated 9 February 2023)
INTRODUCTION
We are AETN a company registered in England and Wales. Our company registration number is 03105704 and our registered office is at 1 Queen Caroline Street, London, UK, W6 9YN. Where we decide the means or purpose of processing your personal data, we are the data 'controller.'
This policy explains how we process your personal data as a data controller when you make use of the services we provide via the Crime + Investigation Play website and apps (the 'Services'). We update this policy from time to time so please check back in.
YOUR PERSONAL DATA AND HOW WE USE IT
1. Enquiry data (information we receive when you get in touch)
This includes: Name; Contact details; Other personal data you send to us as part of enquiries.
We process this information to respond to your support and other enquiries.
We may process this data in accordance with the terms of our contract with you (where we need this information to provide Services to you) or to take steps at your request prior to entering into a contract.
We also use this to pursue our legitimate interests, including: (a) our interest in responding to enquiries to ensure smooth operation of our business and services; and (b) to understand our customers and improve our website and Services, by taking on-board your feedback.
You may be required to provide us with certain information for us to respond to your enquiries.
We collect this information from you when you send it to us. We keep this data for 6 years from when our relationship with you ends.
2. Account data (information we receive when you set-up and use your account)
This includes: Name, age; Credentials (username & password, device ID); Location (approximated using your IP address); Account preferences; Playback information; Contact details (email, address, telephone); Subscription & payment details (including sums paid or due, and accounting records).
We process this information to set-up your account, enable you to use the Service (for example, to remember where you last left-off so you can resume a video, or view your history), and to allow you to manage and pay for your subscriptions.
As part of this we may also use your location (as approximated using your IP address) to optimise video delivery based on your location.
We process this information in accordance with the terms of our contract with you to provide Services to you, or to take steps at your request prior to entering a contract (such as asking your age and location to determine whether you are entitled to use the Services).
We maintain payment records to comply with our accounting and associated legal obligations.
You may be required to provide us with certain information for us to respond to your enquiries and to register an account.
We collect this information from you when you register and use the Services. We keep your account data for 7 years from when our relationship with you ends.
We use the following service providers to help us provide our Services and they may process your account data on our behalf: Accedo Broadband AB; Amazon Web Services; InPlayer; Google; Meta (Facebook); TikTok
3. Entitlements & Suggestions (information we may use to determine the programmes you can access and which are recommended through the Services)
This includes: Your watch history; Preferences & interests you submit through the Service; Location (approximated using your IP address); Subscription details.
The programmes available to you are determined by your location (if you are outside the UK, you cannot watch certain content) and the level of your subscription.
We may recommend content to you based on the content you have previously watched.
We process this information in pursuit of legitimate interests including: (a) our legitimate interests in geo-blocking certain content in order to comply with restrictions imposed by our licensors; and (b) our and your interests in helping you find the content you are likely to be most interested in (by featuring or recommending content related to your watch history, your preferences and interests).
If you agree to our use of push notifications, then we may also use this information to send you push notifications with updates and recommendations.
We collect this information from you when you use the Services. We use the following service providers to help us provide our Services and they may process this information on our behalf: Accedo Broadband AB; Amazon Web Services; InPlayer; Google.; Meta (Facebook); TikTok
4. Analytics (data about how users interact with our Services which might be associated with a unique ID)
This includes but is not limited to: browser type and version, IP address, approximate location and time zone, access logs, device type and settings, operating system, & other information provided by browser or device; use you make of our Services, including the URLs and content you visit, clickstream to, through and from our website and apps, date and time, page response times, errors, length of visits to pages, interaction (such as scrolling, clicks and mouse-overs) data, and methods used to leave our site; error reports generated if there are problems with our Service.
We use software to collect analytics data about users of our website and apps, to understand how people use them, where they come from, which devices and operating systems they use, and how they interact with our Service, and to help improve and maintain our Services, and to identify and address bugs.
We process analytics data from the following providers if you have given your consent:
Accedo Broadband AB; Amazon Web Services; InPlayer; Functional Software; Jump Analytics; New Relic; Brightcove; Meta (Facebook); TikTok; Google Analytics 4; Google advertising platforms (including Google Ads, Campaign Manager and DV360).
You can find out more about how Google processes analytics data here: https://support.google.com/analytics/answer/6004245. To withdraw your consent, please write to us using the contact details at the end of this document.
After 26 months underlying data is deleted, but we may retain aggregated statistics generated from that data which are anonymous.
5. Marketing
We process the following information about you to send you emails or push notifications, to let you know about news, content and updates relating to the Services: Name; Contact information (such as email address or device ID for push notifications)
We process this information to send you promotional material.
We process your personal data for this purpose where either: (a) we have your consent; or (b) where you decide not to opt-out of such marketing in the course of registering with the Services, in order to pursue our and your legitimate interests in ensuring you find out about new content, news and updates, to help you make the most of the Service.
You can withdraw your consent or opt-out at any time by dropping us a line or clicking on the unsubscribe link in our emails.
We collect this information from you. We use the following service providers to help us process this information on our behalf: Accedo Broadband AB; Amazon Web Services; InPlayer; Jump Analytics; Google Analytics; Google Ads; Google Campaign Manager; DV360; Meta (Facebook); TikTok
DATA RETENTION PERIODS
Where explicit retention periods are not described above, we hold data for as long as necessary bearing in mind the purpose for which it was collected. To determine the appropriate period, we consider the amount, nature, and sensitivity of the data, the potential risk of unauthorised access, and legal requirements.
COOKIES, ANALYTICS AND SIMILAR TECHNOLOGIES
Cookies, pixels and other technologies store and access data on your device to help websites and apps work. This section explains their purpose, how long they last, and who else can access their data. We get your consent to use them unless they are essential for our sites, apps or services.
We use the following cookies and similar technologies:
1. Authentication - To deliver our Services and keep you logged-in
The data/cookies are: one-token, one-refresh-token. They last until the end of your session and are set/accessed by Accedo Broadband AB.
2. Analytics - To help us understand how you use our Services, such as how often, so we can improve Services and deliver a better experience and also for us to carry out research and statistical analysis to help us develop new content, products and services.
The data/cookies are: Google Analytics Accedo Analytics, Google Ads, Google Campaign Manager / DV360, Meta (Facebook), TikTok and Jump Analytics. They last 26 months and are set/accessed by Google, Accedo Broadband AB, and Jump Analytics.
3. Consent tracking – These are used to record whether or not you have given consent to our use of non-essential cookies (such as the analytics cookies mentioned above).
The data/cookies are: OptanonAlertBoxClosed, OptanonConsent. They last 1 year and are set/accessed by OneTrust.
4. Recommendations – These are used to give you personalised recommendations based on your previous viewing.
These include Jump Analytics cookies/data. They last 1 year and are accessed by Jump Analytics.
5. Log-in and Transactions – These are necessary to keep you logged-in, and for the processing of your transactions.
These include InPlayer cookies/data. They last for the length of your session, and are accessed/set by InPlayer.
TRANSFERS
Your data is generally stored in the UK, where Google Analytics is turned on (where you have given your consent) your personal data may be stored by Google in the USA. Where we use data processors outside the UK and transfer personal data to a country which does not provide an adequate level of protection, we use contracts approved by the European Commission which give personal data protection similar to that which it has in Europe. For more information drop us a line using the contact details at the start of this policy.
DISCLOSURE
Other than as set out above, we may disclose your personal data:
• Where required by law, government, competent authorities or the courts or to establish, exercise or defend our legal rights, and for the purposes of preventing crime and fraud (for example, we may share personal data with our professional advisors, investigators, or credit reference agencies).
• With members of our corporate group, our suppliers, and subcontractors, as necessary for the purposes set out in this policy.
• If involved in an investment, merger, acquisition, or sale of our organisation or assets, personal data we hold may be shared based on the legitimate interests of us, our shareholders, customers and other parties to a transaction, unless those interests are outweighed by prejudicial impacts upon you.
QUESTIONS AND YOUR RIGHTS
If you have questions, please write to us at: help@crimeandinvestigationplay.co.uk.
If we can't resolve your issue, you can also get in touch with the Information Commissioner's Office: https://ico.org.uk/concerns.
You have the following rights, although these rights may be limited in some circumstances:
• Ask us to send a copy of your data to you or someone else
• Ask us to restrict, stop processing, or delete your data
• Object to our processing of your data
• Object to use of your personal data for direct marketing
• Ask us to correct inaccuracies
If we rely on consent to process data, or send direct marketing, you can withdraw consent by email to the address above.