Privacy Policy

Working Title Films Limited is within the NBCUniversal group of companies. NBCUniversal, its parent, subsidiary and affiliated companies (“NBCU”) maintain this site (“Site”) for your personal entertainment, information, education, and communication.

 

This Privacy Policy explains how NBCUniversal Media, LLC and its affiliates collect, use, and share information from or about you when you use our apps (such as games, interactive TV, voice-activated assistants, and mobile applications), websites, and web applications that link to this policy (“NBCUniversal Services”) and that are provided to you while in the European Economic Area (EEA), the United Kingdom and Switzerland (“European Data Protection Areas”).

 

As one of the world’s leading media and entertainment companies, we offer NBCUniversal Services through a wide range of businesses and under many different brands. Unless otherwise stated, this Privacy Policy applies to relevant NBCUniversal Services you use in European Data Protection Areas. When this policy mentions “NBCUniversal”, “we”, “our” or “us”, it refers to the NBCUniversal company that is responsible for your information under this Privacy Policy (the “Data Controller”). You can find out more information about NBCUniversal operations, including a list of NBCUniversal affiliated companies (“NBCUniversal Affiliates”) offering NBCUniversal Services, here.

 

  1. TYPES OF INFORMATION WE COLLECT
  2. HOW WE USE YOUR INFORMATION
  3. HOW WE SHARE YOUR INFORMATION
  4. CHILDREN
  5. YOUR RIGHTS AND CHOICES
  6. WHERE YOUR INFORMATION WILL BE USED
  7. HOW WE PROTECT YOUR INFORMATION
  8. HOW LONG WE KEEP YOUR INFORMATION
  9. UPDATES TO OUR PRIVACY POLICY
  10. CONTACT US
  1. TYPES OF INFORMATION WE COLLECT

We collect the following information from you when you use NBCUniversal Services:

Information You Provide to Us

Contact and registration information.  Depending on the NBCUniversal Services you use, when you register for an account or purchase something from us, we may ask you for your name, email address, telephone number and other contact details (in some cases, e.g., if we need to deliver a product to your address), age or date of birth (in some cases), and payment details (if relevant).

Information about you or your friends and family.  Any other information you provide to us through the NBCUniversal Services, including comments/posts, photos, videos, audio and other content.  

For example, if you use a service that allows you to purchase a film or other content for yourself or gift it to others, we will collect your email address, your payment details and purchase history, and if you are using the service to make a gift, we will also collect contact information for the recipient of the gift (if you ask us to deliver it for you) and any message or content that you create as part of the gift message.

Transaction information.  Payment information such as your credit/debit card details, purchase history, delivery address and other information related to your transaction.

Competition, sweepstakes and survey information.  We will collect your name and email address and any other information you may provide to us when entering into any competitions, prize draws and sweepstakes we run.  If you participate in one of our surveys or online panel discussions, we may ask you to provide (on a voluntary basis, with your consent) additional information, such as ethnicity and political opinions.

Customer care, technical support and other feedback.  If you contact one of our customer care teams, we will collect information about the contact method, time and date, frequency, and reason to maintain a record of services given. We may also record the content of any queries and other messages you address to us through online forms and social media platforms (in which case we will also record your social media name or handle, so our customer care teams can identify you) in order to address them appropriately and efficiently. If you contact us by phone, we may record the conversation and/or keep a summary of the call so that we have a record of the call for training and service management purposes.

Fitness and well-being information.  If you use a NBCUniversal service that allows you to track and improve your fitness and well-being, we will also ask for information about your lifestyle (e.g., current fitness level and health and fitness goals), so that we can recommend an appropriate fitness program or nutritional plan to help you achieve your goal.

Booking information. If you create an account directly with an NBCUniversal sporting activity booking service, we may collect additional information that is relevant to that activity and your sporting club membership (e.g., membership ID, scores, payment and booking history, and the personal details of any guests that you provide to us as part of any bookings).

Information We Collect Automatically

Device Information. Many NBCUniversal Services offered through our website and apps are free. We can make these services available to you in this way partially through support from our advertising partners. This requires us (or, in some cases, our advertising partners) to collect information from you when you use these services. This includes device, cookie, ad, user and other unique IDs, IP address, browser information, operating system, platform type, and gaming platform (if relevant).

Usage Information.  Depending on the NBCUniversal service you use, we will automatically collect information about how, when, how frequently and for how long you use our services, including websites you visit, content you view, ads you are shown and interact with, games you play or voice assistant skills you use. We will also collect technical information on how the relevant NBCUniversal Services you use are performing, such as crash reports and error logs.

Game Information.  When you play NBCUniversal games, we collect information about which of our games you own or play, play statistics, scores, replays, and achievements.

Location Information.  Depending on the NBCUniversal Services you are using, we will also collect information on your precise location where we have your consent, or determine a less-precise location where we do not (e.g., the city associated with your IP address). This could include apps that provide you with location-based services, such as showing the closest sports clubs or cinemas and how long it will take you to reach them.

Viewing Behaviour.  Where the NBCUniversal service you use allows you to interact with our video and other content, we will collect information on the content you view, how long you watch or interact with video and other content, the quality of the service you receive (e.g., buffering, load times), and generate predictions on the type of video you might enjoy. We will also collect information related to advertisements you have been shown or interacted with.

Information from Third Party Sources

Public Information As permitted by law, we may also receive publicly and commercially available information about you from online or offline sources provided by our partners and service providers to supplement the information you give to us or that we collect automatically, including demographic information, purchasing data, membership or loyalty programs or information about advertisements you have seen or acted upon.

Social Media Information. If you visit the NBCUniversal Services on a device on which you also use social networks or if you interact with us through a social media service or other platform, we may have access to some of your social media information. For example, if you use your Facebook account to log into one of our online services, we may receive information from Facebook (with your authorisation, where required), such as your name, email address, photo, gender, date of birth, social media ID / URL, number of followers, age, location / current city.

We may also collect comments, feedback and other information you provide via third parties like FeeFo about your satisfaction with our services, so that we can address any customer questions or concerns.

 

  1. HOW WE USE YOUR INFORMATION

We will use the information we collect for a variety of purposes depending on the NBCUniversal Services you use and how you use them. The legal basis on which we will use your information will also depend on the circumstances as further described below.

Provide the NBCUniversal Services.  We use the information you give us to provide you with the NBCUniversal Services or products you request from us. This may involve using the information we collect on how you use our websites and the content you interact with to tailor your view of a service or personalise the content and features made available to you. It may also involve seeking to identify you or the various devices you use to access the relevant NBCUniversal Services so that you are consistently receiving the best services from us where and however you choose to use them. We will also use your information to provide you with any technical and other customer support you need, and send you service-related communications, including announcements and administrative messages. In most cases, we will use your information for these purposes where we have a contract with you to provide the NBCUniversal Services or products. Where there is no contract, we will do so because it is in our legitimate interests that the NBCUniversal Services are offered to you at a high standard and to your satisfaction.

We may use your contact details (e.g., email address) to invite you to participate, if you agree, in surveys, panel discussions, and online forums to conduct market research to better understand what you like and don’t like about the NBCUniversal Services, so that we can continue to improve them.

Improve our services and product offerings. We use information from your use of the relevant NBCUniversal Services to understand how you interact with the services, so we can improve them and develop new ones to meet our customers’ needs. We may also use this information to conduct market research, statistical analysis and for business planning. For example, we will use the information to identify which NBCUniversal Services are the most popular, so we can ensure that our IT infrastructure is sufficient to meet demand. We will also use the information to identify less popular NBCUniversal Services to ensure that we are reaching our target audience and promoting our services effectively. We will typically use your information in this way because it is in our legitimate interests to ensure that our NBCUniversal Services offer customers the best experience. When we use information for these purposes, we will implement appropriate safeguards. This might include, for example, removing direct identifiers (e.g., your name, email address and device ID) from the data set before carrying out research and analysis.

Personalise your experience.  We may use your information to create consumer profiles and audience segments that can be used for targeted advertising and marketing on the NBCUniversal Services, on third party services, mobile apps and/or websites, and offline. We rely on a variety of technologies to do this, including cookies and other tracking technologies. You can opt out of our use of cookie-based tracking technologies at any time in the ways described in our Cookies Policy. If you opt out, you may still receive advertising from us and third parties, but it may be less interesting and relevant. We may also use technology (such as Facebook Custom Audiences) to deliver advertising to you on other sites and in mobile applications based on the email address or other personal information you provide to us, or through the use of information we receive from third parties, including consumer data resellers. We will typically do this because it is in our legitimate business interest to deliver advertising that is relevant for our users and will help us better understand our NBCUniversal Services users and customers.

Recognise you across different platforms and devices. Depending on the permissions you have granted through your settings, we will collect information from or about the computers, phones or other devices you use to access any NBCUniversal Services (regardless of whether you have logged into the service), such as your IP address, device ID, cookie or ad ID, and other unique user IDs that can be used to recognise you across platforms and provide you with a seamless user experience.  We will use this device and browser information for analytics, ad reporting and for business planning. We will typically do so because we have a legitimate business interest in offering services that are easy and simple to use and, for some NBCUniversal Services, also because we partially rely on advertising revenue in order to continue to offer these services for free.

Direct marketing.  We may also send you newsletters and information about products, services and promotions offered by NBCUniversal, our partners, and other organisations with whom we work. Typically, this will be where we have your consent or where it relates to a product or service we have provided to you. We will always respect your marketing preferences.

Deliver gifts and prizes.  If you use NBCUniversal Services to purchase and send gifts, we will use the additional information you provide about you and the recipients(s) to complete the transaction, arrange for delivery of the gift to the recipient (if you have asked for this), and to suggest other gifts we think you might be interested in. Similarly, where you have signed up to a competition and win, we will use your information to provide you with your prize, and may use some information for publicity purposes (where we have your agreement).

Prevent fraud and defend our legal rights.  We may also use your information to prevent fraud or any other potentially illegal activities, protect the safety of our users and others, enforce our terms of service and comply with our legal and regulatory obligations, requests from government bodies or courts, or respond to litigation. Typically, we will do this because it is necessary in order to comply with a legal or regulatory obligation to which we are subject (e.g., complying with subpoenas, search warrants and court orders).

We may combine all the information we collect from or receive about you for any of the foregoing purposes. Please see Your Rights and Choices section for further information.

Further, we may aggregate your information with other users’ information and use it for statistical analysis, research and reporting purposes. We may also share this information with our business partners. This aggregated information cannot be used to identify you or otherwise be traced back to you.

 

  1. HOW WE SHARE YOUR INFORMATION

We may share your information as described in this section.

Related Companies.  We may share your information with NBCUniversal Affiliates, as well as with our parent company Comcast Corporation and its affiliate Comcast Cable, to help better tailor services, products, marketing, and advertising to you.

Service Providers.  We may share your information with service providers that help us with tasks such as newsletter management; social media and email marketing campaign management (e.g., MailChimp); research and analytics; website hosting; the fulfillment of transactions and orders; database maintenance; contests, sweepstakes and promotions administration; the provision of technology services and platforms; identity management; acquisition and conversion services; payment processing and fraud prevention.

Advertisers, Advertising Networks and Other Third Parties .  We share information about how you use the NBCUniversal Services and interact with content or ads with our advertisers, media buying agencies, research and video measurement companies such as Nielsen TV Ratings, third party advertising networks and other third parties in order to offer you products and services that may interest you. These third parties may use their own tracking technologies/cookies to collect information about you including through surveys. See our Cookies and Tracking Technologies Policy. In some cases, we may also share your name and contact details (e.g., email address, mobile, postal address, post code) with third party data analytics and data reseller firms (e.g., Experian) for targeted advertising and marketing, to generate look-alike customer lists, and for data matching purposes (e.g., to help us track partner ad conversion on our sites).

Protect our legal rights and comply with law. We may disclose your information to law enforcement agencies, regulators, content protection organisations, anti-fraud coalitions and other regulatory entities if necessary to:

  • protect our legal rights, privacy or safety, and that of our NBCUniversal Affiliates, employees, agents, contractors, or other individuals;
  • protect the safety and security of visitors to the NBCUniversal Services or other properties;
  • protect against fraud or other illegal activity or for risk management purposes;
  • respond to inquiries or requests from government, regulatory, law enforcement, or public authorities;
  • permit us to pursue available remedies, commence, participate in, or defend litigation, or limit the damages that we may sustain;
  • comply with the law including with subpoenas, search warrants, court orders, and other legal process; or
  • enforce applicable terms of service.

Sale or transfer of all or part of our business or assets

In the event that we are involved in a merger, acquisition, transfer of control, bankruptcy, reorganisation or sale of assets, or diligence associated with such matters, we reserve the right to sell or transfer the information described in this Privacy Policy as part of that transaction. If you do not want your information to be processed following such a transfer, you should contact the subsequent owner of the business.

 

  1. CHILDREN

Most of the NBCUniversal Services are intended for users of all ages. Where required by applicable law, we will seek parental consent. If you are a parent or a guardian, and have questions about any personal information your child has provided to us, would like us to stop processing or delete this information, please contact us at EUPrivacy@nbcuniversal.com.

 

  1. 5. YOUR RIGHTS AND CHOICES

Communication preferences and opt-outs

You may unsubscribe from email newsletters or promotional emails we send you by following the opt-out instructions contained in the email. However, you cannot unsubscribe from service-related, transactional, or relationship email messages or from getting customer support service messages in response to your requests.

Cookies and similar technologies

For information about your choices for cookies and similar technologies, including where such technologies are used to provide targeted or other advertising on the NBCUniversal Services, please see our Cookies and Tracking Technologies Policy.

Mobile Apps

Depending on the mobile device you use, you may be able to manage your advertising preferences through the device settings:

  • For Apple Users:
  • iOS 7 or higher, you can change your settings in the following location: Settings > Privacy > Advertising
  • iOS 6, you can change your settings in the following location: Settings > General > About > Advertising
  • iOS 4 or 5, you can opt out following the instructions here

For further information please see Apple’s website here.

  • For other major mobile platforms:
  • Open the platform account settings
  • Select Ads

There also are different third-party tools that allow you to manage your choices around targeted advertising on mobile. For example, the Digital Advertising Alliance (“DAA”) offers a choice tool for the collection of cross-app data for interest-based advertising and other applicable uses. To exercise choice for companies participating in this choice tool, you can install the DAA’s AppChoices app (see http://www.aboutads.info/appchoices). You may also install the TRUSTe Privacy App (see https://www.trustarc.com/consumer-resources/privacy-app/). NBCUniversal does not maintain or control these opt out mechanisms and is not responsible for their operation.

To opt out of measurement services provided by Nielsen on mobile apps, please click here.

Access, correct, port and delete your information

You can access and correct certain information you have provided to us or we have collected automatically through the features provided in some NBCUniversal Services (such as “account settings”). In addition, where legally required, we will provide users with access to their information and the ability to review, update, and correct it. We will take reasonable steps to verify your identity, such as requiring a password and user ID, and possibly photo ID before granting access to your information.

You may have the right to have information you have provided to us and which we use to provide NBCUniversal Services to you in a machine-readable format. This right enables you to move your information from one provider to another, for example, so that the other provider can continue to service your needs effectively.

If you would like to delete the information that we have collected from your use of the NBCUniversal Services, please use the settings of the relevant NBCUniversal service or contact us. We may be required to retain some or all of this information in order to enable you to use the relevant NBCUniversal Services and features, and to ensure that these function properly. We may also retain such information where required by law, to resolve disputes, troubleshoot problems, enforce our terms and conditions of use, and to enable us to exercise or defend our legal rights. Some NBCUniversal Services can only be provided if we have your information, so deletion of your information will require deletion of your account and termination of your ability to use such services.

Change of mind or objection

Where you have given us consent to use your information for any of the above purposes, you have the right to withdraw that consent at any time. You may also have a right to object to our use of your information where we are relying on a legitimate interest and there is something about your particular situation that makes you want to object to our processing on this ground.

Opt-out of measurement research by Nielsen

NBCUniversal video services may feature Nielsen proprietary measurement software that will allow you to contribute to market research, like Nielsen’s TV Ratings.

To learn more about Nielsen digital measurement products and your choices in regard to them, please visit  http://www.nielsen.com/digitalprivacy for more information.

Please contact the relevant NBCUniversal service or EUPrivacy@nbcuni.com for more information about exercising these rights.

Links to other online services

NBCUniversal Services may contain links to third party websites and services. These other sites may collect information about you when you visit them and use this information in accordance with their own privacy policies and terms of use. We do not endorse or control those third parties’ policies or practices.

 

  1. WHERE YOUR INFORMATION WILL BE USED

As a global organisation, NBCUniversal may need to transfer your information outside the European Economic Area and make it accessible to our affiliates, partners and third party service providers internationally. We do so in order to provide you with our services and for the other purposes outlined above. Please be aware that the data protection laws in some of these countries may not offer the same level of protection as those in your country of residence. Before transferring your information in this way we will take steps to ensure that suitable safeguards are put in place aimed at ensuring an appropriate level of protection applies to your information. For further information on these safeguards, please contact us at EUPrivacy@nbcuni.com or Privacy, Legal Department, Central Saint Giles, St Giles High Street, London, WC2H 8NU, UK.  

 

  1. HOW WE PROTECT YOUR INFORMATION

We maintain procedural, technical, and physical safeguards for the NBCUniversal Services to help protect against loss, misuse or unauthorised access, disclosure, alteration, or destruction of the information you provide via the NBCUniversal Services. These safeguards vary depending upon the sensitivity of the information we collect and store. Please be aware that no security solutions are infallible.

 

  1. How long we keep your information

We will keep your information only for as long as it is necessary to fulfill the purposes described above unless a longer retention is required or permitted by law, after which we will delete or anonymise it. The period we keep your information will vary depending on your interactions with the NBCUniversal Services. For example, depending on the type of NBCUniversal Services you use, we may retain your account data for a reasonable period of time after your last activity or after you stop paying for the relevant services. This is to enable you to easily come back and start using the service again. We may also keep a record of correspondence with you relating to the NBCUniversal Services you use, for example, if you have made a complaint, for as long as is necessary to protect us from a legal claim. Similarly, when you unsubscribe from our email newsletters or promotional emails, we will keep a record of your email address to ensure we do not send you marketing emails in the future.

Some NBCUniversal Services may provide additional details on their data retention practices, so we encourage you to consult their website and/or FAQs.

 

  1. UPDATES TO OUR PRIVACY POLICY

If we make material changes to the way we collect or use your information, we will notify you by posting a revised version of this Privacy Policy online, and we may also notify you by other means. We encourage you to check the NBCUniversal Services periodically for updates.

The date at the top of the Privacy Policy tells you when it was last updated. Any changes to this Privacy Policy will become effective when the revised Privacy Policy is posted. If you use this online service after the changes are posted, you have agreed the changes. If you do not agree with this Privacy Policy or any changes we make, please do not continue to use the NBCUniversal Services.

 

  1. CONTACT US

For any questions or complaints about this Privacy Policy or our privacy practices, please contact us at  EUPrivacy@nbcuni.com or Privacy, Legal Department, Central Saint Giles, St Giles High Street, London, WC2H 8NU, UK.

If you are using NBCUniversal Services provided by any of the below NBCUniversal companies in Germany, please contact our local Data Protection Officer at Felix.Wittern@fieldfisher.com.

Universal Consumer Products Germany GmbH

NBC Universal Global Networks Deutschland GmbH

NBC Universal International Television Distribution Germany GmbH

Universal Pictures Germany GmbH

Universal Pictures International Germany GmbH

You may also have the right to lodge a complaint with the data protection authority in your country should you have any concerns about the manner in which we use your information. Before doing so, however, we would encourage you to first contact us directly to allow us an opportunity to resolve any concerns you may have.