The Walt Disney Company has acquired
certain 21st Century Fox businesses, including those providing the
services described below. This policy has been updated to reflect that
transaction.
Last updated: 20th March 2019
Table of contents:- Introduction
- Collection Of Information And Use
- Platform In-built Features
- Information Sharing And Disclosure
- Compliance With Laws And Law Enforcement
- Business Transfers
- Email Policies
- Data Security
- Data Retention
- Deleting Your Information
- Links To Other Sites / Financial Data
- Security
- Changes In Privacy Policy
- Phishing
- contact us
- Grievance Officer
1. Introduction
This Privacy Policy covers the information Novi Digital Entertainment Private Limited (formerly known as Indya Interactive Services Private Limited) (“Platform” and/or “We”) collects from the user(s) (“User(s)” and/or “You”) of www.hotstar.com (“Website”) and any associated mobile sites, applications (“apps”) and/or the Services provided by the Platform on the Website (as defined in the Terms of Use of the Website – “Terms of Use”), which Services can be used or accessed on the Site (as defined in the Terms of Use).This Privacy Policy should be read in conjunction and together with the Terms of Use available on Terms of Use. Personal Information of a User(s) is collected if the User(s) registers with the Website, accesses the Website or takes any action on the Website or uses or accesses the Services as defined in the Terms of Use. The terms ‘Personal Information’, ‘Sensitive Personal Data’ and ‘Information ’ shall have the meaning ascribed to it under the applicable laws in India. Your use of our services offered on the Website is constructed to mean that You consent to our collection, storage, processing and transfer of your Personal Information or Sensitive Personal Data or Information in accordance with this Privacy Policy and you consent to the terms and conditions of this Privacy Policy.
Here are our privacy principles:
- Providing information to us is Your choice.
- You can choose to have the Personal Information provided by You deleted.
- You always have the ability to opt-out of receiving communications from the Site or apps.
2. Collection of Information and Use
The Personal Information or Sensitive Personal Data or Information which You may provide to the Platform and/or which We may collect as part of the information provided is or could be the following:- Your Registration Details Which May Include The Name, Email Address, Mobile/Contact Details, Age, Gender, Password, Location, Pin Code, Area Code, Occupation, Provided By You.
- Your Billing, Tax Registration, And Other Information Pertaining To Your Transactions On The Website Or Related To The Services.
- You May In Some Cases Share Your Debit Or Credit Card Details Or Other Bank Account Details While Accessing Any services Offered On The Site On A Subscription Model.
- Your Comments, Pictures, Video Or Other Content That You Publicly Post Or Share On The Website.
- If You Access Or Engage With The Website Or Services Associated With The Website Through A Social Media Service, We May Collect Your User ID Or User Name, Any Information You Have Permitted The Social Media Service To Share With Us, And Any Information You Have Made Public With The Social Media Service.
- Your Usage Behavior Of The Website Or Interests, Purchasing Behavior, Other Traceable Activities Online, On Apps And On Mobile Such As Destinations Visited, Viewed Advertisements Or Content Consumed.
- Details Of The Computer System Or Computer Network Which You Use To Visit The Website And Undertake Any Activity On The Website, Such As A Unique Device Identifier Including User Behavior From Web Based Cookies, Session Identifiers From Device ID, Commercially Available Services, Data Aggregator Platforms.
- User Preferences (E.G., Preferred Language Settings);
- IP Address, Operating System, Browser Type, Browser Version, Browser Configuration, Name Of Internet Service Provider, And Other Types Of Computer And Connection Related Information Relevant To Identifying Your Type Of Device, Connecting To The Website, Enabling Data Exchange With You And Your Device, And Ensuring A Convenient Use Of The Website;
- The Uniform Resource Locator (URL) And IP Address Of The Website From Which You Accessed, Or Were Directed To, Our Website, Including Date And Time;
- Subpages Visited While On Our Website, Links Followed On The Website, Including Date And Time;
- The Full URL Click Stream To, Through And From The Website, Including Date And Time;
- Service Requests And Orders Placed;
- Transaction History, Including Open And Completed Transactions;
- Search Terms Entered;
- Services/Products Viewed Or Searched For On The Website;
- Shopping Cart And Payment Information;
- Credit Card Information;
- Information Collected By Cookies Or Similar Technologies (As Described In The Next Paragraph);
- Newsletter Subscriptions, Enrollment For Promotions, Use Of Special Offers, Etc.
- Consents, Authorizations, Etc. Granted;
- Survey Answers, Reviews, Ratings And Other Types Of Feedback Provided;
- Content Of Any Communication Sent Through The Website, Including Any Information Posted In Social Communities On The Website Or Otherwise Shared With Platform And/Or Other Users, As Well As Chat Messages And Chat Transcripts;
- Information On Software Downloaded From The Website; And
- Any Other Information That You Enter On, Or Upload To, The Website (E.G., Content That You Fill Into An Online Form, A Photo That You Upload).
Our primary purposes in collecting information including Personal Information or Sensitive Personal Data or Information from You is to allow You to use the Website and various features and Services on or in relation to the Website or any Sites contact you for any Services provided by the Platform or its affiliates or its various service providers or Platform business partners and advertisers; to record Your information and details as permitted and required under applicable laws, statutory direction or judiciary orders; to serve various promotion materials and advertising materials to You; and such other uses as provided in the Terms of Use and this Privacy Policy.
We may also use the Personal Information or Sensitive Personal Data or Information provided by You or collected by the Platform for content recommendations, transactional emails or to provide You with information, direct marketing, online and offline advertising and other materials regarding products, services and other offers from time to time in connection with the Platform or its parent, subsidiary and affiliated companies ("Platform Entities") and its joint ventures.
We may also collect information or Personal Information to track User behavior and preferences for internal analytics of all Users of the Website. We may also use your information: (i) to evaluate your eligibility for certain types of offers, products or services; (ii) to perform analytics and conduct customer research, including general market research or surveying our customers' needs and opinions on specific issues, generating sales and traffic patterns, and to analyze advertising effectiveness, both on an anonymous basis (e.g., by aggregating data) or on an individual basis (if legally permissible);
Novi may integrate certain third party software development kits (SDKs) within the Platform to assist in placing advertisements better suited to You and improve the overall user experience. Such third party SDK's may directly collect certain Personal Information from you on the Platform, such as user behavior, preferences, account activity, IP address, user's interactions with advertisements and identifiers for advertisers (IDFAs) and Google advertising ID (AAID).
This Personal Information or Sensitive Personal Data or Information is collected through the use of server log files and tracking technologies to collect and analyze certain types of technical information and may include cookies and web beacons. If You do not consent to the use of cookies and/or device session tracking by the Platform, You may at any time adjust Your browser settings and/or delete and/or disable the cookies. However, please note that should You choose to delete/ disable the use of cookies or other tracking technologies on Your computer, certain sections of the Website and/or Services provided by the Platform may not be available to You.
We may combine Your Personal Information or Sensitive Personal Data or Information, other information and information collected from tracking technologies and aggregate it with information collected from other Users using our Website to attempt to provide You with the Services and a better experience on the Website.
You understand, agree and acknowledge that our collection, storage and processing of your Personal Information or Sensitive Personal Data or Information is for a lawful purpose connected with a function or activity of the Platform Entities and its joint ventures. You hereby consent to the collection, storage, use, disclosure, transfer, of the Personal Information or Sensitive Personal Data or Information by Platform for the purposes set out herein. You further understand, agree and acknowledge that Your Personal Information which is classified as Sensitive Personal Data or Information as per applicable laws is considered necessary for the Platform to provide various services on its Website to You and for Your usage of the Website and other services provided by Platform in relation to the Website and you affirmatively consent to its collection, storage, transfer and processing.
3. Platform In-built Features
We may collect your television viewership data and use it along with other information that you provide us on the Platform, including any Personal Information, for the purposes set out in this Privacy Policy i.e. to provide you with better and personalised content, advertisements and suitable recommendations.We have integrated SDK in our Platform that is designed to measure and analyze television channel viewership of Hotstar Users ("TV SDK").
The TV SDK initiated after obtaining relevant permissions, uses the microphone on your device to capture audio samples (including ambient sounds) and create encrypted fingerprint files of such audio samples in real-time. The fingerprint files are matched against a database of known fingerprints of television channels and television content to identify and understand your television viewership patterns. The fingerprint files cannot be reverse engineered into audio samples and are stored on your devices for a period not more than 48 hours. No actual audio samples or voices including conversations that you may have will be saved on your device or transferred, at any point of time during the fingerprinting process.
You may consent to the Platform accessing your device microphone and recording functions for the fingerprinting process, as and when the pop-up appears on your device screen requesting your explicit consent. You may at any time deny such consent on the consent pop-up that appears from time to time or by disabling the microphone functionality on your device. Should you require assistance to revoke your consent earlier given, please contact us at our coordinates given towards the end of these Terms of Use.
4. Information Sharing and Disclosure
Platform is the recipient of Your Personal Information or Sensitive Personal Data or Information and shall exercise reasonable commercial endeavors for the prevention of unauthorized disclosure of the Personal Information including any Sensitive Personal Data or Information provided by the Users. We may enable access of Your Personal Information or Sensitive Personal Data or Information to the Platform Entities, joint ventures, business partners, agents or third parties for the purposes of the services provided by them or for any other marketing related activity undertaken by or on behalf of the Platform Entities and/or its joint ventures, and/or for the purposes of enhancing the quality of the services provided to You on the Website, and You expressly consent to the same. We shall endeavor that the third parties and agents engaged by us to whom we may provide access to Your Personal Information or Sensitive Personal Data or Information for the purposes set out herein are under an contractual obligation to protect Your Personal Information or Sensitive Personal Data or Information in accordance with the same standard as the Platform has agreed to be subject to in this Privacy Policy.Platform may disclose Your Personal Information or Sensitive Personal Data or Information to such extent as the Platform may deem necessary for You to enter into commercial transactions with the Website. Recipients of your Personal Information or Sensitive Personal Data may be located in any country. This may include countries where applicable data protection laws provide a lesser degree of protection than your home country.
5. Compliance with Laws and Law Enforcement
Platform cooperates with mandated government and law enforcement agencies or to any third parties by an order under law for the time being in force to enforce and comply with the law. We will also disclose any information including Sensitive Personal Data or Information about You to government and law enforcement agencies without your permission as we, in our sole discretion, believe necessary or appropriate to respond to valid claims and legal process, to protect the property and rights of Platform or a third party, to protect the safety of the public or any person, or to prevent or stop any illegal, unethical or legally actionable activity. Platform may also provide Your Personal Information including Sensitive Personal Data or Information to various governmental authorities including tax authorities upon any demand or request from them.6. Business Transfers
Platform may transfer or otherwise share some or all of its assets, including Your Personal Information including any Sensitive Personal Data or Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy and You consent to the same. Should such a sale or transfer occur, we will ensure that the Personal Information including any Sensitive Personal Data or Information You have provided through the Website is stored and used by the transferee in a manner that is consistent with this Privacy Policy.7. Email Policies
Platform may use Your Personal Information or Sensitive Personal Data or Information for the purposes mentioned in this Privacy Policy . You have full control regarding which emails You want to receive. If You decide at any time that You no longer wish to receive such communications from the Platform Entities, please follow the unsubscribe instructions provided in any of the communications. Please note that once we receive Your request, it may take an additional period of time for Your opt-out to become effective.8. Data Security
We understand the importance of data security and we want your user experience with us to be as safe as possible. We have implemented reasonable safeguards and precautions to protect Your Personal Information or Sensitive Personal Data or Information, including technical and organizational measures against unauthorized access, improper use, alteration, unlawful or accidental destruction, and accidental loss, both in an online and offline context.We have adopted reasonable and best security practices and procedure and We maintain technical and organizational security measures and procedures to protect the security of your Your Personal Information or Sensitive Personal Data or Information, which are consistent with measures used by other similar websites.
Please understand that, while we strive to protect Your Personal Information or Sensitive Personal Data or Information against potential risks and exposures, there is no absolute security in the online sphere. Hence, we ask you to support our IT security efforts by not disclosing any of Your Personal Information or Sensitive Personal Data or Information data on our website that is particularly sensitive or not required in the specific context. Furthermore, you can help us protecting your personal data by signing off when you finish using login-protected areas of the website.
9. Data Retention
We retain Personal Information or Sensitive Personal Data or Information only for as long as We believe it to be necessary for purposes set out herein for which the Personal Information or Sensitive Personal Data or Information was collected, subject to any legal requirements for the data to be retained for longer periods of time.10. Deleting Your Information
If You wish to have the Personal Information or Sensitive Personal Data or Information that You have provided to us deleted, You can always do so by sending a request to us on the e-mail id of our Customer Services department provided at the bottom of this page. You may note that deletion of certain Personal Information may lead to cancellation of your registration with the Site and/or your access to certain features of the Site can be restricted and may also lead to complete cessation of Your Access to the Site.11. Links To Other Sites / Financial Data
We provide links to other websites and portals such as third party payment gateway providers for your convenience and information (“Other Websites”). For instance, the Platform will be using third party payment gateway providers to process and facilitate the payment of Your Subscription Fee to the Platform for providing you access to the Subscription. Please note that the Platform does not directly collect any financial information such as Credit Card or Debit Card or Net Banking details from You. Such Other Websites are not controlled by us. When you visit such Other Website you do so at your own risk. These Other Websites may have their own privacy policies in place, which we recommend You review if You visit any such Other Websites. We do not assume any responsibility or liability for such Other Websites, the content of such Other Websites and their privacy practices, nor do we endorse them. We encourage you to familiarize yourself with the privacy statements provided by such Other Websites prior to providing them with information about you or entering into any transactions on them.While transacting with these Other Websites , You may provide Your financial information including without limitation Your bank account details, credit card account details or your details pertaining to any payment settlement or pre-paid instrument service provider. You understand, agree and acknowledge that the Site and Platform never receives Your financial and payment information from these Other Websites. Your Personal Information, Sensitive Personal Data or Information and financial information will be dealt with by these Other Websites in accordance with their respective privacy policies and other terms and conditions and the Platform shall not be liable, accountable or responsible for Your Personal Information, Sensitive Personal Data or Information and financial information which You provide to these Other Websites.
12. Security
Platform uses commercially reasonable security practices and procedures industry practices and procedures designed to help keep Your Personal Information or Sensitive Personal Data or Information safe. Secure server software (SSL) encrypts all information You submit before it is sent to the Platform. Furthermore, all of the User data we collect is protected against unauthorized access. To prevent unauthorized access, maintain data accuracy, and ensure correct use of information, We will employ commercially reasonable and practicable security practices and procedures and security methods and technologies. We will also ensure on reasonable commercial efforts basis that any agent or third party that we employ complies with the same security standards as We do for the protection of your Personal Information or Sensitive Personal Data or Information.Your information may be transferred to or may be maintained on computers, computer systems and computer resources located outside of Your state or country where the privacy laws may be different (but no less stringent than the restrictions imposed by Indian law) as those where you live. If You are located outside India and choose to provide information to us, please be aware that the Site is hosted in India and that Platform keeps or transfers information to and from India for storage and processing. Your submission of such information represents your agreement to that transfer.
Unfortunately, the transmission of information over the Internet is not completely secure. Although We strive to protect your personal data, We cannot guarantee the security of your data while it is being transmitted to our site; any transmission is at your own risk. Once We have received your information, We have commercially reasonable procedures and security practices in place to reasonably endeavor to prevent unauthorized access.
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