PRIVACY AND COOKIES POLICY
Narrative Entertainment UK Limited (a company registered in England with registered number 12769816 (“NEUK” or when we use “we”, “us” and “our”) is the controller of your personal data collected through the popfun.co.uk and tinypop.com websites and the online features (“Content”) that link to this Privacy and Cookies Policy (“Policy”). You can also learn more about cookies and similar technology which we use in this Policy.
It is important that you read this Policy together with any other privacy notice or fair processing notices that we may provide on the Content at or around the time that we collect or process personal data about you (for example, fair processing notices that we may display to you at the time that you sign up to receive e-mail updates from us) so that you are fully aware of how and why we are using that data.
This Policy supplements other notices and terms displayed on the Content and this Policy is not intended to override or replace them.
By visiting our sites or otherwise using the Content, you agree to our terms (including as amended from time to time) and this Policy. If, for any reason, you do not agree to the terms of this Policy, please stop using the Content.
- We use personal data to allow you to use the features in the Content, to process your registration, and to provide you with requested Content related to our movies and other offerings.
- If you give us permission, we will send you news and promotional material about NEUK and its channels. You can change your mind at any time and ask us not to process your personal data for direct marketing purposes, including profiling related to direct marketing. This Policy also explains when we process personal data, for our legitimate interests. You can ask us to stop processing this data.
- We provide interactive features that engage with social media sites, such as Facebook and Twitter. If you use these features, these sites will send us personal data about you.
- We may collect personal data about Children. If you believe we have collected personal data about your child, you may contact us at email@example.com and request that we cease processing data about your child or children. We may ask for your age before you can sign up to receive newsletters or to use our Content.
- When you make a purchase from one of our sites or apps, we will use your personal data to fulfil your order. We will disclose your personal data to our third-party partners to process your payment and perform some of the other fulfilment on our behalf.
- We disclose your personal data publicly when you post User-Generated Content via our sites or apps. We disclose personal data with any member of our company group or when you agree that we can share data with our business partners. We also share data with third parties we engage to process data on our behalf or when such sharing is required by law, or in certain other situations.
- Where we transfer your data to a third party that is outside of the UK we seek to ensure that appropriate safeguards are in place to make sure that your personal data is held securely and that your rights as a data subject are upheld including the use of European Commission approved standard contractual clauses to protect your personal data.
HOW WE USE YOUR INFORMATION
We might use personal data collected via our Content:
- To fulfil a contract, or take steps linked to a contract;
- To process your registration on a site or app, or entry into a competition, prize draw or contest
- To send you information about changes to our terms or policies
- To process your payment and fulfil your purchased order
- Where this is necessary for purposes which are in our, or third parties, legitimate interests and your fundamental rights do not override those interests. These interests are:
- To provide you with access to Content and features in the sites and apps
- To send you information you have requested
- To ensure the security of our sites and apps, by trying to prevent unauthorised or malicious activities
- To tailor Content for you.
- Where you give us consent or have asked us to do so:
- Where you ask us to send marketing information to you via a medium where we need your consent (for example, email marketing)
- Where you give us consent to place cookies and to use similar technologies
- On other occasions where we ask you for consent, for a purpose which we explain at that time.
- For purposes which are required by law or a regulatory obligation:
- In response to requests by government or law enforcement authorities conducting an investigation.
We retain personal data for so long as we think is reasonably necessary for the purposes described above.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
INFORMATION WE RECEIVE FROM THIRD PARTIES
Sometimes, we receive information about you from third parties. For example, if you login to a site or app using Facebook Connect you will be asked if you wish to share information from your Facebook account with us. If you participate in a game or other feature where your score is posted on a social media content, or if you use a “like” or a “share” button for a feature on our sites or apps, then the third party will share information with us.
If you participate in activities on non-NEUK sites or apps – such as participating in a Facebook application – you may allow us to have access to personal data held by Facebook, or other site or app owners.
Please note that if you participate in activities on non-NEUK sites or apps or where we provide links to third party websites, plug-ins and applications that are not affiliated with us or our Content such sites are out of our control and are not covered by this Policy. If you access or participate in activities on such third party sites or apps, the operators of these sites may collect personal data from you that could be used by them, in accordance with their own privacy policies. Please check these policies before you submit any personal data to those websites.
We will also receive personal data about you if individuals give us access to their profiles, or similar features, on non-NEUK sites or apps, and you are one of their “connections”.
Some of our Content has ‘send to a friend’ features. The ‘send to a friend’ feature is when users can ask us to send features to their friends. If a friend asks us to send you a feature, then we will process your contact details (i.e. email address). The contact details are only used to send you the feature and we do not retain the contact detail. If you want to use this feature, you should only provide your friend’s contact details to us when you know they would like to hear from us. Your friend will know that you provided their contact details to us.
If we provide online services to a child where we need parental consent for this, we may ask for a parent’s email address, in order to obtain the consent.
COOKIES AND SIMILAR TRACKING TECHNOLOGY
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your device if you agree. Cookies contain information that is transferred to your device’s hard drive. Cookies and similar tracking technologies allow us to recognise you when you visit a site, or app, or open an email – they do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving your experience.
We use tracking technologies for three purposes:
- To provide you with the service you have requested: for example, keeping you logged in during your visit and ensuring security of the Content.
- To show Content that are more relevant to your interests: for example, with your consent, we use tracking technologies to remember Content that has interested you and then use this to help us serve more relevant Content to you.
- To enable us to deliver advertisements properly: Tracking technologies help limit the number of times that you see an ad, measure the effectiveness of advertising campaigns and help us and others track whether ads have been properly displayed so we can pay for this. We also allow other organisations to use tracking technologies for these advertising purposes too.
- To analyse and improve your experience: to analyse which Content is most popular and gets viewed the most and which gets viewed the least on our websites and in our emails (where you have chosen to receive emails from us), and to provide us with general information about users of the Content (such as age, gender and interest areas). We also check for bugs and glitches in the Content and remember the choices you have made, such as your language or region, to enhance and personalise your experience. We use analytics services provided by Adobe, Google and NPAW to help us do this.
How to manage tracking technologies
If you are using our Content via a browser you can change your cookie preferences and withdraw your consent at any time using the Cookie Consent Tool.
- the Help menu on the menu bar of most browsers tells you how to prevent your browser from accepting new cookies, how to delete old cookies, how to have the browser notify you when you receive a new cookie and how to disable cookies altogether
- you can opt-out of analytics as described above.
We use Flash cookies to provide some Content such as video clips or animation. Flash cookies are managed through the Flash Player Settings Manager, which is a different interface than the one provided by your web browser. This Settings Manager lets you manage global privacy settings, storage settings, security settings, and automatic notification settings. Beginning with Flash Player 10.3, the Flash Player Settings Manager can be accessed locally on your computer: in the Control Panel on Windows and in System Preferences on Mac. Users of other operating systems and earlier versions of the Flash Player should manage their global privacy settings using the Flash Player Settings Manager provided online from Adobe: http://www.macromedia.com/support/documentation/en/flashplayer/help/sett…
Mobile and TV Devices
By accessing certain applications from these devices, you consent to cookies being stored to your device for the following purposes: analytics and advertising. These cookies are essential to the operation of the application. It is not currently possible to opt out or remove these cookies from the devices without deleting the application.
HOW WE SHARE YOUR PERSONAL DATA
If we ask you for consent to share your personal data with third parties for their own marketing purposes, and if you give consent, we will share personal data with these third parties. We do not share your personal data with third parties for their own marketing unless you agree to this.
If you register for a promotion, such as a competition, prize draw or contest, which is administered by a third party, your personal data will be disclosed to the organiser for them to administer the promotion. This may also mean that your personal data will be included on a winners list.
If you submit Content to a site or app this will be disclosed publicly.
We share data with third parties who perform functions on our behalf, such as hosting or operating our site and apps, sending e-mails, and carrying out data analysis. Where you make a purchase on one of our sites or apps, we will share your personal data with third parties to process your card payment and deliver your order.
We share your personal data with any member of our company group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
NEUK or any of its assets, including the Content, may be sold, or other transactions may occur in which your personal data may be considered one of the business assets of the transaction. In this case, your personal data may be transferred, either as part of the transaction or during any due diligence process.
We share information with government and law enforcement authorities and with other parties involved in, or contemplating, legal proceedings to comply with a legal obligation, when we believe in good faith that the law requires it, or where this is necessary for us or for third parties to protect our or their rights, property, safety, or security.
Our sites and apps are hosted and operated in the United Kingdom but some of our service provider or group companies may be based outside of the UK.
Where we transfer your data outside of the UK we seek to ensure that appropriate safeguards are in place to make sure that your personal data is held securely and that your rights as a data subject are upheld. Transfers of personal data are either made:
- to a country recognised by the European Commission as providing an adequate level of protection; or
- to a country which does not offer adequate protection but whose transfer has been governed by the standard contractual clauses of the European Commission or by implementing other appropriate cross-border transfer solutions to provide adequate protection.
As and when the UK Information Commissioner’s Office (“ICO”) publishes new UK-specific guidelines and clauses, we will update our policies accordingly.
By submitting your personal data, you agree to this transfer, storing or processing. If you would like more information about how the mechanism via which your personal data is transferred, please contact firstname.lastname@example.org.
AMENDING OR REMOVING YOUR PERSONAL DATA, CONTROLLING MARKETING COMMUNICATIONS, OTHER PRIVACY QUESTIONS AND RIGHTS
You have the right to access your personal data and, if necessary, have it amended or deleted or restricted. You may also ask us to provide some types of personal data to you, or another organisation nominated by you, in a structured and machine-readable format.
You can also ask us not to send marketing communications and not to use your personal data when we carry out profiling for direct marketing purposes. You can opt out of receiving email newsletters and other marketing communications by following the opt-out instructions provided to you in those emails. If you sign up to receive SMS or MMS messages, you can unsubscribe from those messages received by replying “STOP.” Transactional account messages will be unaffected if you opt-out from marketing communications.
When you write to us making a request to exercise your rights we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity.
It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be, the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information then we may delay actioning your request until you have provided us with additional information (and where this is the case we will tell you).
For more details on or if you have any queries regarding this Policy; if you wish to exercise any of your rights set out above; or if you think that the Policy has not been followed, please contact us by e-mailing at email@example.com.
You may also wish to lodge a complaint to the supervisory authority about the way we process your personal data. In the UK this is the ICO. We would however appreciate the chance to address your concerns before you approach the supervisory authority so please contact us in the first instance so we can we can assist with any queries or concerns you may have about our use of your personal data.
CHANGES TO THIS POLICY
We reserve the right to change the terms of this Privacy and Cookies Policy at any time, by prominently posting notice of the amendment on the Content or relevant site or app. To the extent permitted by law, these changes will apply from the time they are posted.
Effective Date: This Privacy and Cookies Policy was updated on 01/02/24 and is effective as of that date.