Privacy Policy

Heard Digital Ltd – Privacy Policy

13th December 2023

We want you to be fully informed about your rights, and how Heard Digital Ltd used your data.

This Privacy Policy explains the types of personal data we may collect about you when you interact with us. It also attempts to explain how we store and handle that data and keep it safe. 

We hope the following sections will answer any questions you have but if not, please do get in touch with us via the contact page, or via traditional post at – Heard Digital Ltd, West Wing Studios, Unit 166, The Mall, Luton, Bedfordshire, LU1 2TL UK. We may need to amend this Privacy Policy from time to time. We will notify you of any significant changes, but we recommend that you check it regularly for updates. 

1. Introduction to General Data Protection Regulation (“GDPR”) From May 2018, the new UK General Data Protection Regulation (“GDPR”) on data protection sets out several different reasons for which a company may collect and process your personal data those will include:

Consent

In specific situations, we can collect and process your data with consent. For example, when you provide us with your email address, or tick a box in order to receive email newsletters this could potentially be collected with your consent. When collecting your personal data, we will always try to make clear to you which data is necessary in connection with a particular service.  

Contractual obligations

In certain legal or contractual circumstances, we need your personal data to comply with those contractual obligations.

Legal compliance

If the law requires us to, we may need to collect and process your data appropriately. For example, we can pass on details of people involved in fraud or other criminal activity if requested by law enforcement bodies.

Legitimate interest.

In some specific situations, we make use of your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our legitimate business and which does not materially impact your rights, freedom or interests.

2. When do we collect your personal data? Examples of this might be:

  • When you create an account with us.
  • When you visit our website.
  • When you use your website account to subscribe to services.
  • When you potentially engage with us on social media.
  • When you download or install our App.
  • When you contact us with queries, complaints, feedback, or other reasons.
  • When you use a code or discount offer shared via a third party.
  • When you’ve potentially given a third-party permission to share with us the information, they hold about youa

3. What sort of personal data do we collect?

For example – Details of your visit to our website or app, including your IP address, devices, operating system, browser, traffic data, access to download data, geographical location data, weblogs, and other communication data.

4. How and why do we use your personal data?

We want to offer you the best possible customer experience. To achieve this, we will use the data we hold about you to offer you content and services that are most likely to interest you. General Data Protection Regulation (“GDPR”) allows this as part of our legitimate business interests in understanding our customers and providing customer service to you. If you wish to change how we use your data, you’ll find details in the “what are your rights over your personal data?” section of this Privacy Policy.

This is how we’ll use your personal data and why:

  • For us to respond to your queries, refund requests and complaints. Handling this information, you send enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this based on our contractual obligations to you, our legal obligations in providing you with the best service we can.
  • To protect our business and your account with us from fraud and other illegal activities.
  • With your consent, we will use your personal data, and preferences to keep you informed by email and via the App about relevant content and services. You are free to opt out of hearing from us by any of these channels at any time.
  • To send you communications required by any law, or which are necessary to inform you about changes to the services we provide you. If we do not use your personal data for these purposes, we would be unable to comply with our required legal obligations.
  • To display the most interesting and appropriate content to you on our website or app, we may use data we hold about your use and browsing activity. We’ll do this based on our legitimate business interests.
  • To comply with all contractual or legal obligations to share data with law enforcement.

5. IP addresses & cookies on our app or websites

We may use automated systems to collect appropriate information about your computer, including its IP address, or operating system and browser type. This is statistical data that will not identify you individually. We will use this information to help us run and improve our services. For the same reasons, we may potentially gather information about your internet usage by using a cookie file stored on your computer. Cookies contain information that help us to improve our site by enabling us to carry out our legitimate business tasks and needs. You can of course refuse cookies using the setting on your internet browser – unless you do this our system, will potentially issue cookies when you log on to our site. But, if you choose to refuse cookies you may be unable to access certain parts of our site, such as the “My Account” section and you will be unable to access parts our website. 

6. How we protect your personal data

We know how much data security matters to all our customers. We will treat your data with the utmost care and take all appropriate and sensible steps to protect it. 

We attempt secure access to all transactional areas of our websites and apps using ‘https’ technology. Access to your personal data is password protected. We regularly monitor our system for possible vulnerabilities and attacks. Sensitive data (such as payment card information) is secured by SSL encryption and payment is taken by third party payment providers, we do not use it directly. 

To protect your payment details, the checkout service used is Stripe. You will automatically be transferred to Stripe when subscribing. Payment card information is not stored by Heard Digital Ltd. All credit card data is processed by Stripe. Sensitive data such as names and email addresses is secured by SSL encryption. We do not receive or retain any details relating to specific credit/debit cards, only the authorisation from Stripe once the transaction has been completed. Never send credit/debit card details directly to us by e-mail. Information about how Stripe protects your information can be views on their website. In the unlikely event of unauthorised card use please be sure to contact your card issuer immediately as per your arrangement with them. Where we have given you (or where you have chosen it) a password which enables you to access certain parts of our site or app, you are responsible for keeping this password confidential. You should not share this password with anyone at all, and make sure you change it regularly throughout your subscription period. We will continue to use reasonable endeavours to ensure that your personal data is protected against loss, unlawful use or access. We also have procedures in place to deal with any suspected breach and to notify you and the regulator of any suspected breach, where required. 

7. How long will we keep your personal data?

Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected. At the end of the legally required retention period, your data will either be deleted or anonymised.

Your Subscription History

In order to enable access and to use the App, it is necessary for us to retain core information about you and your order history as part of your personal data, we need to keep the personal data you give us for five years so we can comply with our legal and contractual obligations, and after that we will not delete any information relating to your history from our website until or unless you ask us to do so. 

8. Sharing your data with specific third parties.

We will only do this under very specific circumstances, for example:

  • To apply our own Terms & Conditions, or to protect the rights, property, or safety of Heard Digital Ltd, our customers or content suppliers, or others. This includes exchanging information with other companies and organisations for the purposes of copyright protection, fraud protection and credit risk reduction.
  • We may share information about fraudulent or potentially fraudulent activity in our systems. This may include sharing data about individuals with law enforcement bodies.
  • We may also be required to disclose your personal data to the police or other enforcement, regulatory or government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration. 

9. What are your rights over your own personal data?

You potentially have the right to request:

  • Access to the personal data we hold about you, free of charge. However, we reserve the right to charge a ‘reasonable fee’ when a request is manifestly unfounded or excessive, particularly if it is requested repetitively.
  • The correction of your personal data when incorrect, out of date or incomplete.
  • That we stop using your personal data for direct marketing.
  • That we stop any consent-based processing of your personal data after you withdraw that consent.
  • You also have the right to request a copy of any information about you that Heard Digital Ltd holds, and to have that information corrected if it is inaccurate.

To request a copy of your information, please contact Data Protection Officer, Heard Digital Ltd, West Wing Studios, Unit 166, The Mall, Luton, Bedfordshire, LU1 2TL, UK. 

To ask for your billing information to be amended, please update your online account directly. 

If we choose not to action your request, we will always explain to you the reasons for our refusal.

10. Your right to withdraw consent.

Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent unless we are legally required not to.

Where we rely on our legitimate interest, in cases where we are processing your personal data based on our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

Direct Marketing

You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.

Checking you identity

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Policy. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

11. How can you stop the use of your personal data for direct marketing?

There are several ways you can stop direct marketing communications from us if you no longer want them:

  • Click the ‘unsubscribe’ link in any email communication that we send you.
  • Log in to your online account, visit the ‘My Account’ area and update your communication preferences.
  • Write to Data Protection Officer, Heard Digital Ltd, West Wing Studios, Unit 166, The Mall, Luton, Bedfordshire, LU1 2TL, UK

Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated, and we may still retain your data where permitted.

12. For non-UK customers of Heard Digital Ltd

By using our entertainment services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. You still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes. Potentially on occasion we will need to transfer your personal data between countries to enable us to supply the goods or services you’ve requested. In the ordinary course of business, we may transfer your personal data from your country of residence to ourselves and to third parties located in the UK. By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes. This may occur because our information technology storage facilities and servers are located outside your country of residence and could include storage of your personal data on servers in the UK. We will ensure that reasonable steps are taken to prevent third parties outside your country of residence using your personal data in any way that’s not set out in this Privacy Policy. We’ll also make sure we adequately protect the confidentiality and privacy of your personal data.

13. Contacting the Regulator

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the UK Information Commissioner’s Office. You can contact them by calling 0303 123 1113. Or go online to http;//www.ico.org.uk/concerns

If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.