The TV Room

THE TV ROOM PRIVACY POLICY

OVERVIEW

At Sparkler Ltd protecting and respecting your privacy is an important part of our commitment to clients, panel participants and the general public.

When you participate in a community run by our organisation, you can be confident that any personal data that you share with us will stay confidential.

Aggregated data from the community in the form of percentages may be used in the public domain, but won’t be attributed on an individual basis or to personally identifiable data.

By using THE TV ROOM community you are consenting to have your personal data transferred to and processed in the UK or forwarded to our client, Freeview who may operate in various jurisdictions (including outside the EEA) in accordance with this Privacy Policy.

You are free to choose whether or not to participate in a panel survey, free to choose not to answer any specific questions and free to discontinue participation at any time.

The Sparkler Privacy Policy is a statement of principles and guidelines describing the level of protection of personal data provided by Sparkler Ltd to respondents and the general public. The objective of the Sparkler Privacy Policy is to promote responsible and transparent personal data management practices in a manner consistent with the provisions of the Data Protection Act 1998 (UK) (the “Act”).

Sparkler Ltd will continue to review its Privacy Policy to make sure that it is relevant and remains current with changing industry standards, technologies and laws.

Please read the following Sparkler Privacy Policy carefully to understand Sparkler Ltd’s practices regarding personal data and how the same is treated.

If you have any concerns about how your privacy is protected at Sparkler Ltd, please contact our Privacy Officer (the “data controller‟ for the purpose of the Act) by e-mail at privacyofficer@sparkler.co.uk, or by mail at: Sparkler, 58-60 Berners Street, London W1T 3NQ Attention: Privacy Officer

THE DETAILED SPARKLER PRIVACY POLICY SCOPE AND APPLICATION

The scope and application of this Sparkler Privacy Policy are as follows:

- The Sparkler Privacy Policy applies to personal data collected, used, or disclosed by Sparkler Ltd in the course of commercial activities.

- The Sparkler Privacy Policy applies to the management of personal data in any form whether oral, electronic or written. - The Sparkler Privacy Policy does not impose any limits on the collection, use or disclosure of the following information by Sparkler Ltd: (a) non-personally identifiable information; (b) the name, title, business address and/or telephone number of an employee of an organization; (c) other information about an individual that is publicly available and is specified by regulation pursuant to the Act. - The application of this Sparkler Privacy Policy is subject to the requirements and provisions of the Act, the regulations enacted thereunder, and any other applicable legislation or regulation.

DEFINITIONS

Collection: The act of gathering, acquiring, recording, or obtaining personal data from any source, including third parties, by any means.

Consent: Voluntary agreement for the collection, use and disclosure of personal data for defined purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorised representative. Express consent can be given orally, electronically or in writing, but is always unequivocal and does not require any inference on the part of Sparkler Ltd. Implied consent is consent that can reasonably be inferred from an individual's action or inaction.

Disclosure: Making personal data available to a third party.

Employee: An employee of or independent contractor to Sparkler Ltd.

Personal data: data about an identifiable individual, but does not include the name, title, business address or telephone number of an employee of an organisation, and does not include descriptive, factual information about an organisation.

Respondent: A member of the public who provides personal data to Sparkler Ltd in the course of participating in a panel survey conducted by Sparkler Ltd. For example, a respondent is an individual who discloses personal data to Sparkler Ltd in the course of quantitative or qualitative marketing or social research.

Third party: An individual or organisation outside of Sparkler Ltd.

Use: The treatment, handling, and management of personal data by and within Sparkler Ltd or by a third party with the knowledge and approval of Sparkler Ltd.

ACCOUNTABILITY

Sparkler Ltd is responsible for personal data under its control and shall designate one or more persons who are accountable for Sparkler Ltd’s compliance with this Sparkler Ltd Privacy Policy. Responsibility for compliance with the provisions of this Sparkler Privacy Policy rests with the Sparkler Privacy Officer. The Sparkler Privacy Officer can be contacted by e-mail at privacyofficer@sparkler.co.uk, or by mail at: Sparkler, 58-60 Berners Street, London W1T 3NQ Attention: Privacy Officer

Other individuals within Sparkler Ltd may be delegated to act on behalf of the Privacy Officer or to take responsibility for the day-to-day collection and/or processing of personal data.

Sparkler Ltd is responsible for personal data in its possession or control and shall use contractual or other means to provide a comparable level of protection while information is being processed or used by a third party.

INFORMATION WE MAY COLLECT FROM A RESPONDENT

We may collect and process the following data about a respondent: (a) Information that an individual provides when an individual participates in a panel research survey or community activity conducted by Sparkler Ltd. This includes information provided at the time of registration and information provided as a respondent in one of the Sparkler Ltd panel surveys. (b) If an individual contacts us, Sparkler Ltd may keep a record of that correspondence.

IDENTIFYING PURPOSES FOR COLLECTION OF PERSONAL DATA

Sparkler Ltd shall identify the purposes for which personal data is collected at or before the time the information is collected. Sparkler Ltd collects personal data from the public only for the following purposes:

(a) to conduct quantitative or qualitative marketing and social research;

(b) to understand respondent opinions to establish suitability for further quantitative and qualitative marketing and social research; and

(c) to meet legal and regulatory requirements.

Further reference to "identified purposes" mean the purposes identified herein. Sparkler Ltd shall specify orally, electronically or in writing the identified purposes to the respondent at or before the time personal data is collected in a survey. Upon request, persons collecting personal data shall explain these identified purposes or refer the individual to a designated person within Sparkler Ltd who can explain the purposes.

When personal data that has been collected is to be used or disclosed for a purpose not previously identified, the new purpose shall be identified prior to use. Unless the new purpose is permitted or required by law, the consent of the respondent will be acquired before the information will be used or disclosed for the new purpose. Sparkler Ltd may provide clients or other third parties with information from any survey, in aggregate form. In aggregate form it is impossible to identify an individual respondent's personal data.

OBTAINING CONSENT FOR COLLECTION, USE OR DISCLOSURE OF PERSONAL DATA

The knowledge and consent of an individual are required for the collection, use, or disclosure of personal data, except where inappropriate.

Participation by respondents in panel research is always voluntary. When a respondent agrees to participate in a panel survey, he/she gives consent to the panel survey by participating. Generally, any personal data collected in the course of a panel survey is not disclosed to third parties other than the client sponsoring the research project. In circumstances where Sparkler Ltd does disclose information to a third party other than the client sponsoring the research project, Sparkler Ltd always explains the reason for the disclosure to the respondent and obtains express permission from the respondent before making any such disclosure. A respondent is always free to choose whether or not to participate in a panel survey, free to choose not to answer any specific questions and free to discontinue participation at any time.

In obtaining consent, Sparkler Ltd shall use reasonable efforts to ensure that a respondent is advised of the identified purposes for which personal data will be used or disclosed. The identified purposes shall be stated in a manner that can be reasonably understood by the respondent. Generally, Sparkler Ltd shall seek consent to use and disclose personal data at the same time it collects the information. However, Sparkler Ltd may seek consent to use and/or disclose personal data after it has been collected, but before it is used and/or disclosed for a new purpose.

In determining the appropriate form of consent, Sparkler Ltd shall take into account the sensitivity of the personal data and the reasonable expectations of its respondents. The participation of a respondent in a quantitative or qualitative marketing or social research study may constitute implied consent for Sparkler Ltd to collect, use and disclose personal data for the identified purposes.

LIMITING COLLECTION OF PERSONAL DATA

Sparkler Ltd shall limit the collection of personal data to that which is necessary for the purposes identified by Sparkler Ltd. Sparkler Ltd shall collect personal data by fair and lawful means. In conducting surveys, Sparkler Ltd limits the amount and type of personal data it collects. We collect only the amount and type of information needed for the purposes identified to individuals. Sparkler Ltd collects personal data about an individual primarily from that individual or a member of that individual's household. Except as permitted by law, Sparkler Ltd will only collect personal data from external sources, such as client organisations, if individuals have consented to such collection.

LIMITING USE, DISCLOSURE, AND RETENTION OF PERSONAL DATA

Sparkler Ltd shall not use or disclose personal data for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law. Personal data shall be retained only as long as necessary for the fulfilment of those purposes. Sparkler Ltd may disclose a respondent's personal data to:

(a) a client of Sparkler Ltd where the respondent has consented to such disclosure;

(b) a third party engaged by Sparkler Ltd to perform functions on its behalf;

(c) a public authority or agent of a public authority if, in the reasonable judgment of Sparkler Ltd, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information; or

(d) a third party or parties, where the respondent consents to such disclosure, disclosure is required or permitted by law, or where Sparkler Ltd is under a duty to disclose or share a respondent’s personal data in order to comply with any legal obligation.

Only Sparkler Ltd’s employees with a business need-to-know, or whose duties reasonably so require, are granted access to personal data about respondents. Sparkler Ltd shall keep personal data only as long as it remains necessary or relevant for the identified purposes or as required by law. Depending on the circumstances, where a respondent may have to be re-contacted for purposes of clarifying responses to a survey, or to seek additional responses, Sparkler Ltd shall retain the personal data for a period of time that is reasonably sufficient to allow this re-contact. Sparkler Ltd shall maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to personal data that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information shall be destroyed, erased or made anonymous.

WHERE SPARKLER LTD STORES PERSONAL DATA

The personal data that Sparkler Ltd collects from a respondent may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for Sparkler Ltd or for a third party engaged by Sparkler Ltd to perform functions on its behalf. By submitting your personal data, you agree to this transfer, storing or processing. Sparkler Ltd will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Sparkler Privacy Policy.

Unfortunately, the transmission of information via the internet is not completely secure. Although Sparkler Ltd will do its best to protect a respondents personal data, we cannot guarantee the security of such data transmitted to electronically over the internet; any transmission is at the respondent‟ owns risk. Once Sparkler Ltd has received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.

IP ADDRESSES AND COOKIES

Sparkler Ltd may collect information about a respondent’s computer, including where available a respondent’s IP address, operating system and browser type, for system administration. This is statistical data about Sparkler Ltd’s users' browsing actions and patterns, and does not identify any respondent. A respondent may refuse to accept cookies by activating the setting on his/her browser which allows him/her to refuse the setting of cookies. However, if a respondent selects this setting he/she may be unable to access certain parts of Sparkler Ltd’s site. Unless an respondent has adjusted his/her browser setting so that it will refuse cookies, Sparkler Ltd’s system will issue cookies when he/she logs on to Sparkler Ltd’s site.

ACCURACY OF PERSONAL DATA

Personal data shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. Personal data used by Sparkler Ltd shall be sufficiently accurate, complete, and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about a respondent. Sparkler Ltd shall update personal data about respondents and employees as necessary to fulfil the identified purposes or upon notification by the individual.

SECURITY SAFEGUARDS

Sparkler Ltd shall protect personal data by security safeguards appropriate to the sensitivity of the data. Sparkler Ltd shall protect personal data against such risks as loss or theft, unauthorised access, disclosure, copying, use, modification or destruction, through appropriate security measures, regardless of the format in which it is held.

Sparkler Ltd shall protect personal data disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used. All of Sparkler Ltd’s employees with access to personal data shall be required to respect the confidentiality of that information.

OPENNESS CONCERNING POLICIES AND PROCEDURES

Sparkler Ltd shall make readily available to individuals, specific information about its policies and procedures relating to the management of personal data. Sparkler Ltd shall make information about its policies and procedures easy to understand, including: (a) the title and address of the person or persons accountable for Sparkler Ltd’s compliance with its Privacy Policy and to whom inquiries and/or complaints can be forwarded;

(b) the means of gaining access to personal data held by Sparkler Ltd

(c) a description of the type of personal data held by Sparkler Ltd, including a general account of its use; and

(d) a description of what personal data is made available to related organisations (e.g. subsidiaries).

INDIVIDUAL ACCESS TO PERSONAL DATA

Upon request, Sparkler Ltd shall inform an individual of the existence, use, and disclosure of his or her personal data and shall give the individual access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Upon written request to the Privacy Officer, Sparkler Ltd will inform an individual of the existence, use and disclosure of his/her personal data and shall be given access to that information. In certain situations, Sparkler Ltd may not be able to provide access to all the personal data that it holds about a respondent. For example, Sparkler Ltd may not provide access to information if doing so would likely reveal personal data about a third party or could reasonably be expected to threaten the life or security of another individual. Also, Sparkler Ltd may not provide access to information if disclosure would reveal confidential commercial information.

In order to safeguard personal data, a respondent may be required to provide sufficient identification information to permit Sparkler Ltd to account for the existence, use and disclosure of personal data and to authorise access to the individual's file. Any such information shall be used only for this purpose.

Sparkler Ltd shall promptly correct or complete any personal data found to be inaccurate or incomplete. Any unresolved differences as to accuracy or completeness shall be noted in the individual's file. Where appropriate, Sparkler Ltd shall transmit to third parties having access to the personal data in question any amended information or the existence of any unresolved differences. Respondents and employees can obtain information or seek access to their individual files by contacting the Sparkler Privacy Officer.

CHANGES TO OUR PRIVACY POLICY

Any changes we may make to this Sparkler Privacy Policy in the future will be posted on THE TV ROOM Website.