We care about your privacy
This Policy applies to all customers of upc cablecom GmbH and its subsidiaries. It also applies to any visitors to our websites, who may or may not be customers of upc cablecom GmbH.
Please read this Policy in conjunction with our general terms and conditions and any terms and conditions that may apply to the products and services that you have signed up for. This Policy may be subject to change from time to time. Please check our websites on a regular basis for any changes made to this Policy.
Our products or services may contain links to other companies’ websites and services which they offer; these companies may have privacy policies of their own. We recommend that you read the privacy policies of such third parties. We are not responsible for the privacy practices or content of any such third parties’ products or third parties’ services.
What do we mean by “Personal Information”?
With the objective of setting high privacy standards, we support a wide interpretation of what constitutes Personal Information, which we define as data that relates to any natural person such as an employee or consumer, including but not limited to names, addresses, birthdates and billing records. With respect to our customers and when the context so requires, Personal Information also includes traffic data, location data, IP addresses, internet usage data and set top box usage data.
What Personal Information do we collect?
Due to the nature of our services and products, we may collect the following Personal Information subject to notice or consent where relevant:
- Contact Information, meaning information that allows us to identify or contact you. This information includes name, address, telephone number, e-mail address, user names and passwords, birthdates, gender, language preferences, delivery details, as well as other contact information which is collected directly from you.
- Account Information, meaning information you provide to us to set up our services such as bank account information, billing address, and information you provide us when you enter competitions or when you contact us inquiring about our products and services.
- Service Information, meaning information necessary for us to provide services to you, such as the model and service number of your set top box, software version used, smartcard ID, IP/MAC address and level of the service package.
- General Usage Information, meaning information generated when you use our products and services, for instance, when you utilize our network to make a phone call, use the internet, use our websites, view television programs, use Video on Demand (“VOD”) or when you browse the TV menus such as a TV Guide or VOD catalogue.
- Other Personal Information, meaning information we may obtain, in accordance with applicable law, from publicly available sources or from credit check agencies. We may also collect Personal Information about other people when you provide us with this, for example, if you buy one of our products as a present for another person.
For Horizon users:
- Preferred Viewing Information, meaning information with respect to TV channel viewership and recordings of your digital video recorder only if you have chosen to activate the personalized recommendations. We do not collect Preferred Viewing Information without your explicit and prior consent. Please refer to Section “How can you opt-in and opt-out?” for more details.
- Home Content Information, meaning the index of video, music and photo files stored on compatible devices in your home only if you have chosen to activate the home network setup wizard. We do not collect Home Content Information without your explicit and prior consent. Please refer to Section “What about home content?” for more details.
For what purposes do we use Personal Information?
We collect information about you due to the nature of our services and products. It is important for us to ensure that our products and services are simple, personal and reliable. We are constantly looking for ways to improve our services and products and to match them as much as possible to your personal needs. We may therefore collect Personal Information for the following purposes, subject to notice or consent where relevant:
To provide our products and services. We use Contact, Account and Service Information for setting up and maintaining our products and services, for our administrative processes and to administer contests and competitions. These activities include provisioning, technical support, hardware and software upgrades, billing, collection of payments and credit checking.
To enhance our products and services. We may rely on General Usage Information to identify improvement areas. For instance, high VOD usage in a certain genre may lead to a broader film catalogue in this genre. We may also conduct market research to improve our existing services and develop new products according to the needs of our customers.
To present new products and services. We may communicate with you about upcoming features in our products and services or promotions that might interest you. Please refer to Section “How can you opt-in and opt-out?” where we explain how you can update your marketing preferences.
To enable the purchase of goods and services from our Commerce Partners. From time to time, we may present you with special offers on screen or online while using our products and services enabling you to purchase goods and services from our partners, such as advertisers, promoters, application providers or app stores (all referred to herein as “Commerce Partners”). Should you decide to take advantage of such offers or engage in a transaction, we may collect and communicate your relevant Personal Information to Commerce Partners sponsoring the promotions or transactions. The information will be collected and disclosed by upc cablecom GmbH only upon your affirmative response to such offers. In addition to fulfilling your request, Commerce Partners may also use Personal Information to send you other information in which you might be interested. The use of Personal Information by Commerce Partners will be governed by their respective privacy policies, which you should refer to in the event that you have any queries regarding how our Commerce Partners might use your Personal Information.
To manage our performance. We may use Personal Information when asking for feedback in respect of the performance of our products and services, our customer care service and our maintenance and operations. Where allowed by applicable law, we may use information related to your use and access to our products and services for purposes of traffic management, customer enquiries and prevention or detection of fraud. Where allowed by applicable law, we may also monitor and record our communications with you, including e-mails and phone conversations, for training purposes, quality assurance and to record details about the products and services you order from us.
To meet our legal obligations. We may be required by law to disclose Personal Information in compliance with the terms of a valid legal process or where required to do so by law enforcement agencies. These disclosures may be made without your consent and knowledge, and without notice, in compliance with the terms of a valid legal process. We reserve the right to challenge the access to Personal Information by authorities.
Other uses. We may use anonymous and aggregated information to develop reports and analyses about what types of content and /or advertisements are watched or skipped, for research and for other legitimate business purposes.
For Horizon users who have activated the personalized recommendations:
To provide personalized recommendations. As part of the Horizon entertainment experience, we may use Preferred Viewing Information to recommend and record programs you may enjoy or offer promotions you may be interested in. Personalized recommendations are activated if you have expressly chosen to allow us to collect your Preferred Viewing Information. Personalized recommendations may be provided with respect to TV channels, VOD and applications. We do not use Personal Information regarding adult content usage other than for VOD billing purposes and do not provide personalized recommendations with regard to adult content. For more details please refer to Section “How can you opt-in and opt-out?”.
To whom may we disclose Personal Information?
upc cablecom GmbH is committed to protecting Personal Information. For the performance of our products and services, we may disclose, in compliance with applicable law and subject to prior notice or consent where relevant, Personal Information to third parties as described below, including third parties located in countries outside the EU and Switzerland where the privacy rules differ from the rules in the EU and Switzerland.
Entities within the Liberty Global Group. We may share your Personal Information with any parent company, subsidiaries, or other companies under common control (collectively "Affiliates"). In such event, we will require our Affiliates to honor this Policy.
Employees of upc cablecom GmbH. We limit the number of our employees who have access to your Personal Information to a select group of specially authorized employees. Access is granted to these employees for the proper performance of their duties on a need to know basis.
Commerce Partners. When you elect to participate in a special offer or engage in a transaction presented by us but provided by our Commerce Partners, we may disclose Personal Information to such Commerce Partners where relevant. For more details please refer to Section “For what purposes do we use Personal Information?”.
Purchaser of our business. If another company acquires upc cablecom GmbH, or acquires assets of upc cablecom GmbH that comprise or include your Personal Information, that company will possess the Personal Information collected by upc cablecom GmbH and it will assume the rights and obligations regarding your Personal Information as described in this Policy.
Other third parties. Where allowed by applicable law, we may also share Personal Information with third parties we trust where the disclosure is necessary for the performance of our products and services (e.g. customer care) and with third party vendors specifically engaged by upc cablecom GmbH to provide products or services to us, in which case we will require those parties to keep that information confidential and secure and to use it solely for the purpose of providing the specified products or services to us. Where allowed by applicable law, we may also share Personal Information with credit check agencies or debt collection agencies. There may be instances where we may be required by law to disclose Personal Information to authorities or other third parties.
How do we protect Personal Information?
We work very hard to protect your privacy and have taken key steps in protecting it. We have formally appointed individuals who are responsible for the security of our network, supporting infrastructure and our information systems. We have implemented solutions to protect Personal Information, which consist of a variety of both technical and policy based solutions which vary depending on the applicable service or product offered or provided to you. These solutions may include, but are not limited to, password protection, encryption, firewalls, anti-virus, intrusion detection, anomaly detection and access controls for our employees.
How long do we keep Personal Information?
We must keep Personal Information for no longer than is necessary for us to fulfill the purposes for which the Personal Information was collected unless we are specifically required to keep your Personal Information longer by applicable law.
How can you opt-in and opt-out?
We may contact you to tell you about our products and services that might be of interest to you on an opt-in basis. If you no longer wish to receive such direct marketing from us, you can choose to opt-out in one of several ways (such as email, SMS, phone, post) or by contacting our Customer Service. You can contact our Customer Service through the ‘Contact Us’ page on our website.
For Horizon services:
When you use the Horizon services, we will collect, use and disclose General Usage Information in addition to Contact, Account and Service Information, in ways consistent with this Policy. Before we collect Preferred Viewing Information, you will be given the choice to opt-in or opt-out as described below.
Horizon. When you install Horizon, we will ask you to agree to allow us to collect Preferred Viewing Information in order to provide you with personalized recommendations on content you may enjoy and offer you promotions that might interest you. Then at any time on Horizon, you can opt whether or not to receive personalized recommendations via the Horizon settings menu or Recommendations page. If you make the choice to opt-out, you understand that we will not inform you about any personally relevant content or promotions regarding the Horizon service. Opting-out will delete Preferred Viewing Information that was saved while your opt-in election was in effect.
Horizon Online. When you first register for Horizon Online, we will ask you to agree to allow us to collect your Preferred Viewing Information in order to provide you with personalized recommendations on content you may enjoy and offer you promotions that might interest you. The Horizon Online service provides you with personalized recommendations to enable you to take full advantage of the features of this service.
What about home content?
If you are a Horizon customer, you may connect your home network to your Horizon set top box. By using the home network setup wizard, you agree to connect your home network to the Horizon set top box. The Horizon set top box will then create an index of video, music and photo files stored on compatible devices in your home. Where possible, movie and TV program files from your home network will be enhanced with cover images and synopsis information. This home network feature may be turned on or off at any time within the Horizon settings menu. Disabling the home content feature deletes the index of video, music and photo files created by your Horizon set top box. We do not use any Home Content Information for personalized recommendations.
What about cookies?
"Cookies" are small pieces of information stored by your internet browser that collect data such as your browser type, your operating system, web pages visited, time of visits, content viewed, ads viewed and other click stream data.
You can manually disable and enable cookies on your computer or mobile or other device. Most internet browsers provide the ability to accept or decline specific cookies or types of cookies, and to refuse or delete all cookies. The process will depend on your browser. You should refer to the instructions of your specific web browser to use this functionality. Restricting or blocking cookies may, however, have a negative impact upon the usability of many websites.
What about third party applications?
As part of our Horizon services, you may have access to third party applications via the feature offered by our service called the App Store. You understand and acknowledge that upc cablecom GmbH is not responsible for any such third party applications you choose to access. These third party applications will operate under their own privacy policies; please read these policies carefully. We caution you not to enter any personal or sensitive information (such as social security or credit card numbers) while using a third party application unless you have verified it is from a source that you trust.
What are your rights?
You have a right to have incomplete, incorrect, inappropriate or outdated Personal Information deleted or updated. If you believe any of the details we hold about you are incomplete, incorrect, inappropriate or outdated, let us know and we will make the necessary corrections or deletions within the applicable legal time frames.
You have a right to know what Personal Information we hold about you. Where permitted by applicable law we may apply a small charge that will cover the cost of the administration involved in providing such information to you.
You also have a right to request that we stop processing your Personal Information for direct marketing purposes. If you no longer want to receive direct marketing information or telephone sales calls from us, please contact our Customer Service. You can contact Customer Service through the ‘Contact Us’ page on our website.
Please be aware that when you opt-out or request us to stop processing your Personal Information there may be instances where we may not be able to continue to provide you with our products or services.
How can you contact us about this Policy?
If you have any comments or queries concerning this Policy or you wish to request access to the Personal Information that we hold on you then please contact our Privacy Officer at email@example.com
Zurich, December 2012