Privacy Policy

Introduction

We are StarzPlay Direct UK Limited ("Starz", "us", "our" or "we"). We provide the Lionsgate+ subscription service (the "Service").

This policy explains how and why we use personal data (also known as personal information, personally identifiable information or PII) for the purposes of providing, promoting and developing the Service. Personal data is information about individuals or information from which individuals can be identified. This policy also provides contact details and important information about privacy rights.

We explain the Service in more detail in the Terms of Use. Please read this policy together with our Terms of Use https://www.lionsgateplus.com/gb/en/termsofuse.

This policy was last updated on September 28, 2022. We will periodically update this policy so please check back for updates.

Contact us

If you need assistance with any of the issues covered in this policy and are unable to resolve your question via the "Help" feature of the Service, please contact our Data Protection Officer ("DPO") at privacy@lionsgateplus.com. We are registered with the Information Commissioner’s Office in the United Kingdom with registration number ZA572608.

What personal data do we collect?

We collect personal data relating to subscribers of the Service and other authorized users ("Subscribers") when they interact with the website associated with the Service, any mobile or TV app associated with the Service and/or any of the features or downloads that we make available through the Service. We also collect personal data relating to other individuals that interact with the Service, such as website visitors or individuals who view our service via their device or profile, and visitors of Service related websites.

Specifically, we collect the following types of personal data relating to Subscribers and other individuals:

Name and address.
Date of birth.
Contact details (including email address and phone number).
Registration, username, password, password reminder and other information relating to “User Accounts” (as defined in the Terms of Use https://www.lionsgateplus.com/gb/en/termsofuse).
Payment details (ifor example, details of whether your subscription payments have been received or not. We do not collect payment card data from Subscribers: this is processed by our third party payment service providers).
Registration for any contests, features and other promotions offered as part of, or in relation to, the Service.
Participation in online research.
Reports of issues with the Service.
Correspondence (including email and chat).
Screen names.
Submissions, voting and polling activities.
Service usage and activity (including the content you have viewed and rated).
Search queries.
Information about interests.
Social media accounts and use (for example, if you interact with us, our content or advertising on social media).
Third party access to the Service via your account with another online service (for example, the fact you have logged into your Lionsgate+ account via social media, where this functionality is enabled).
Technology used to access the Service, including –

In addition to collecting personal data directly from Subscribers and other individuals, we collect personal data from third party service providers we work with (“Service Providers”) including:

- Distributors.
- Payment processors.
- Fraud and credit risk service screening providers.
- Advertising partners.
- Analytics and data service providers.
- IT providers.
- Professional services (for example, accountants and lawyers).

We receive information from Service Providers as necessary to enable them to provide their services to us. The personal data we receive includes information processed for the following purposes:

- to secure our systems;
- to determine location based on your IP address in order to customize our service and prevent fraud;
- to determine payment or balance information, or updates to that information, based on the Service Provider’s relationship with you;
- to understand how many Subscribers we have;
- to obtain aggregated demographic, interest based and online activity data for advertising and analysis purposes;
- for Service activation purposes; and
- IP addresses, device IDs or other unique identifiers for authentication and the presentation of content to Subscribers through our distributor’s services.

We also receive personal data from third party services which are integrated into our Service, such as voice assistant platforms. The types of personal data we receive includes the search queries and commands that you make through integrated devices or platforms.

Information we receive from other sources might vary over time but may include information from sources such as publicly available posts on social media platforms.

How and why we use personal data

We use the categories of personal data listed in the section above to provide, promote and develop the Service.

We can only use your personal data if we have a lawful basis to do so under data protection law. The grounds we rely on are as follows:

Necessary for the performance of a contract

Where we use personal data to provide the Service to Subscribers or to otherwise perform our obligations and exercise our rights under the Terms of Use (https://www.lionsgateplus.com/gb/en/termsofuse) our legal ground is that doing so is necessary for the performance of a contract with the Subscriber Article 6(1)(b), UK GDPR.

Legitimate interests

Where we use personal data (i) relating to individuals with whom we do not have a contract for the Service; and (ii) for the use of Subscribers’ personal data outside the Terms of Use, our legal ground is that doing so is necessary for the legitimate interest of operating, developing and promoting our business, Article 6(1)(f), UK GDPR.

It is also in our legitimate interests to use personal data where necessary for establishing, exercising or defending our legal rights.

Importantly, we will not use personal data on the grounds of a legitimate interest where the relevant individual or Subscriber’s rights and freedoms override the legitimate interest. In addition, where we rely on a legitimate interest to use personal data, the individual or Subscriber to whom the personal data relates may object. To object please contact us at privacy@lionsgateplus.com.

Consent

For certain specific uses of personal data we will ask for your consent (for example, to send you marketing communications or to set non-essential cookies and other tracking technologies), Article 6(1)(a), UK GDPR. We will request consent in a clear manner and explain for what purpose the personal data will be used. You have a right to change your mind at any time. If you withdraw your consent we will no longer use your personal data for that specific purpose.

Legal obligations

Separately from providing, developing and promoting the Service, we will also use personal data when we are required to do so by law, for example to the extent necessary to comply with tax and accounting legislation we are subject to Where that is the case, our legal ground is that the use of personal data is necessary to comply with a legal obligation, Article 6(1)(c), UK GDPR.

The table below gives you more detailed information of the specific purposes we use personal data for and the lawful grounds we rely on.

Purpose	Lawful basis
Set up, administer and manage your account with us	Necessary for the performance of our contract with you
Improve the Service by providing personalized content, language, help and instructions	Our legitimate interests (to make the Service as user-friendly as possible)
Customize the Service by location (for example, choosing content to be made available to you according to your location)	If you are a Subscriber this is necessary for our contract with you, otherwise this is in our legitimate interests (to comply with our content licensing agreements with third parties)
Provide customer service assistance	If you are a Subscriber this is necessary for our contract with you, otherwise this is in our legitimate interests (to harbour good customer relationships)
Ask Subscribers to participate in surveys, products, services, news and events	Our legitimate interests (to gain user insight into our Service and for user engagement purposes)
Provide Subscribers with essential Service updates	Necessary for our contract with you
Provide Subscribers with news, newsletters, targeted advertising, promotions, sweepstakes, special offers and other marketing	Your consent
Setting non-essential cookies and other tracking technologies	Your consent
Better understand how Subscribers use the Service (including checking traffic patterns and what types of content are most popular)	Our legitimate interests (to understand our Service in order to develop and improve it)
Receive and respond to submissions or correspondence	Our legitimate interests (to maintain good customer relations)
Use Subscriber submissions in accordance with the Terms of Use: https://www.lionsgateplus.com/gb/en/termsofuse for the Service	Our legitimate interests to exercise our legal and contractual rights in respect of submissions
Administer community postings (for example, chat and bulletin boards), including publishing screen names and other information provided by Subscribers on the Internet or elsewhere	Our legitimate interests (to harness community engagement)
Repost comments about the Service, programmes and/or content on various online platforms and social media (for example, Twitter)	Our legitimate interests (to promote the Service)
Recommend viewing content to you	Our legitimate interests (to make the Service user friendly)

We may also process your personal data for additional purposes in the future, but only if such purposes are compatible with those listed above and where we have a lawful basis to do so. If necessary, we will notify you of such processing in advance. Marketing

If you consent to receiving marketing from us, please be aware you are entitled to opt out of receiving those communications at any time and can do this via the opt out/unsubscribe link available in each marketing communication.

Consequences of not providing personal data

Subscribers are required to provide registration, contact and payment details in order to access the Service. We will not be able to provide the Service to Subscribers that do not provide this information.

Automated decision-making

We use automated decision-making to provide Subscribers with the most relevant content and develop the Service. However, we do not use automated decision-making to make any decisions producing legal effects concerning individuals or decisions which significantly affect them in a similar way.

Sharing personal data

Social media

Subscribers and other individuals may engage with the Service through third-party social networks (for example, Facebook, Twitter and Pinterest). We may also allow Subscribers to access their accounts or specific content through social networks. Where Subscribers or other individuals engage or login through social media, we will share personal data with and receive personal data from the relevant social network. Where Subscribers or individuals engage or login through a social network, we recommend they read the relevant social network's privacy policy.

If we and the social media platform are deemed to be joint controllers of personal data processed in connection with a business page we have on a social media platform or otherwise in connection with any data exchanged with a social media platform, we use your personal data in accordance with this privacy policy and the social media platform will use your personal data in accordance with its privacy policy. If you want to exercise your data protection rights in respect of our social media page or data we share with the platform, please contact us in respect of our page and this data and contact the social media platform in respect of the management and operation of the platform generally.

Service Providers

To help provide, develop and promote the Service, we share personal data with and receive personal data from our Service Providers as necessary for the provision of their services to us. You can find out more about the types of Service Providers we work with in the ‘What personal data do we collect? ‘above.

We have contracts in place with these Service Providers that govern how they may use the personal data we share with them.

Group companies and business reorganizations

We will share personal data with our group companies where necessary to provide, develop or promote the Service (this is in our legitimate interests).

We will share personal data with potential buyers, group companies and/or business partners where necessary for a reorganization, restructuring, merger, sale or transfer of assets involving Starz and/or the Service (this is in our legitimate interests in facilitating any such possible or actual transaction or restructuring).

Legal rights and obligations

We will share personal data where necessary to establish, exercise or defend our legal rights.

We will also share personal data where required by the courts, regulators or law.

Cookies and similar technologies

Our Service and the website associated with it uses cookies and similar technologies.

Cookies are small information files that we and our third party partners place on the devices used to access the Service. We use a combination of session and persistent cookies. Session cookies keep track of your current visit and how you navigate the website and persistent cookies enable our website to recognise you as a repeat visitor when you return. Session cookies will be deleted from your device when you close your browser. Persistent cookies remain on your device after you have left the website.

An embedded script is a programming code used to collect information about how Subscribers use the Service. The embedded script is temporarily downloaded onto devices used to access the Service. The embedded script is only active whilst the device is used to access the Service.

A web beacon is a small graphic image or programming code that is included in some parts of the Service and communications. For example, if you consent to receiving marketing communications from us, our email campaigns include technology so that we can track if an email has been opened in order for us to understand the effectiveness of our campaigns.

The types of cookies and similar technologies we use and why we use them are described below:

Essential cookies. Our sites and Service won’t work properly without essential cookies. For example, we and our Service Providers may use essential cookies to identify and authenticate Subscribers. We also use essential cookies to enforce our Terms of Use, maintain the security of our sites and services, enable core functionality and remember certain user preferences (such as your cookie preferences).

Performance cookies. Performance cookies (also known as analytics cookies) collect information about how visitors use our sites and Service, for example, which pages users visit most often, how they use the Service and error messages received by users from web pages. Performance cookies don’t collect information that identify a visitor and the information these cookies collect is aggregated and anonymized. We, and selected analytics service providers, use cookies, embedded scripts and web beacons and similar technologies to obtain analytical information about the Service.

Advertising cookies. Advertising cookies are used to deliver advertisements relevant to visitors based on the visitor’s interests and to measure the effectiveness of advertising campaigns. These cookies are usually placed by advertising networks with our permission. They remember that you have visited the website and this information is shared with other organizations such as advertisers. We, and selected third-party advertising partners, use cookies, embedded scripts, web beacons and similar technologies to present adverts through the Service and in connection with advertising campaigns related to our Service which may be displayed to you on other sites and platforms.

For more information about advertising and your ability to opt-out of targeted advertising from such third parties, please visit the Network Advertising Initiative (www.networkadvertising.org) and/or the Self-Regulatory Program for Online Behavioral Advertising (www.aboutads.info/choices).

You can find out more information about the specific third party analytics and advertising partners we work with, the cookies used by them and us and how long cookies last on your device on the Cookie Preference page.

We will ask for your consent to use non-essential cookies. We use an essential, persistent cookie to remember your cookie preferences, but periodically when you visit our website or Service you will be asked to reaffirm your preferences.

You can change your cookie preferences at any time by accessing the Cookie Preference page. In addition, you can also manage cookies by configuring the appropriate settings on your device (e.g. your browser settings).

Children

We do not knowingly collect or use any personal data relating to individuals under the age of 13 – except if necessary on a one-time basis in response to a specific issue. If you are a parent or guardian that has discovered that your child under 13 has submitted personal data without your permission, please contact us immediately at privacy@lionsgateplus.com.

International transfers

We routinely transfer personal data between the European Economic Area ("EEA"),the UK and the United States.

When personal data is transferred internationally, we are required to ensure you are afforded equivalent protection in respect of your personal data to that provided in the EEA and the UK (which has been grated adequacy status by the European Commission).

We generally do this by putting in place appropriate safeguards when making international transfers, for example, by using specific contractual clauses which have been approved by the European Commission or transfer mechanisms approved by the UK government together with supplementary measures if we deem it necessary in the circumstances.

If you would like more information about how we transfer personal data outside the EEA and the UK and the safeguards we use, please contact us at privacy@lionsgateplus.com.

Data retention

We retain your personal data for as long as we have a lawful reason to do so, which includes providing the Service to you, complying with legal and regulatory obligations we are under (such as accounting requirements), and resolving disputes and enforcing agreements.

In determining how long to hold your personal data we will consider legal and regulatory requirements, whether it is necessary for us to keep it to achieve the purposes we've described in this policy, as well as the amount, nature, and sensitivity of the personal data, and the potential risk of harm from unauthorised use or disclosure of your personal data. Where it is no longer necessary for us to keep it, we'll delete it or we'll anonymise it so that you cannot be identified from it.

We keep personal data relating a Subscriber while you have an active account with us to enable us to provide the Service to you. If you’ve consented to receive marketing from us and you later withdraw that consent we’ll no longer use your contact details for marketing purposes but we will keep a record of information needed to prevent you receiving further marketing from us.

Rights

Subscribers and other individuals have the rights to –

- Information about how we use personal data (which is what this policy is for).
- Access personal data.
- Object to direct marketing (including profiling for direct marketing purposes) and the use of personal data based on the grounds of legitimate interest.
- Erasure of personal data.
- Portability of personal data (for example, to ask us to provide your personal data to another party).
- Withdraw consent where our use of personal data is based on consent.
- Rectification of personal data if we hold inaccurate data about you.
- Restrict how we use personal data.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with your national data protection supervisory authority, (in the UK, this is the Information Commissioner’s Office) although we would ask that you contact us in the first instance.

Please note that the Account Management section of the Service provides access to a broad range of payment, contact and account information (including the content you have viewed and rated). You may access further information or exercise the other rights listed above using the contact details at the top of this privacy policy.

Please be aware that, with the exception of the right to object to direct marketing, these rights are not absolute and there may be some situations in which they cannot be exercised or they are not relevant. The Information Commissioner's Office has more information about each of these rights at www.ico.org.uk.

Exercising Your Rights

Exercising Your Rights. To submit a request to know, delete, or opt-out, please visit Lionsgate+ Privacy Rights Manager.

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