Our privacy notice

Abstract

Banana Fingers Ltd and EpicTV SAS belong to a publicly listed EU-based group of companies, Elisa Oyj, and have adopted Elisa’s high operating standards in privacy, including Elisa’s privacy policy. The confidentiality of personal data and communications as well as protection of customers’ privacy are important basic values in all our operations. We observe legislation, authorities’ provisions and good data processing practice in processing the data of our customers, employees and partners as well as other stakeholders. At Banana Fingers and at EpicTV, we abide with a high level of data protection. We process your personal data only for appropriate purposes defined in advance and only when it is necessary. We protect our service with technically appropriate measures and train our personnel regularly in principles related to data processing. We have compiled the most significant principles regarding data protection in this privacy notice, which we abide with in order to ensure privacy and the confidentiality of communications. This privacy notice applies to all processing of personal data related to our services. We check regularly that these pages are up-to-date and update them when needed.

The confidentiality of communication and safe processing of personal data are of primary importance to us

Confidentiality

We provide a number of different kinds of services for your use. In order to provide the services, we process information about you and the services you use, and maintain confidentiality and your privacy in such a manner that outsiders will not know the content or existence of our interactions.

Data protection

We take a high data protection level into account in all our operations: we process data in a confidential manner. We ensure this by using appropriate technology and data security solutions and ensuring the confidentiality of the data with administrative measures.

What data do we collect?

Why do we collect your personal data?

In order to agree on the delivery of services, we require sufficient information about you. We may also require your social security number or tax payer identification number in order to identify you for e.g. invoicing purposes. We need your contact information in order to communicate with you, to deliver products and services to you, and e.g. to inform you of changes in services. In addition, our services require providing different kinds of data based on which we can identify you individually and improve the service to be suitable for you. In some services, legislation obligates us to collect sufficient data about you to deliver the service. We also provide services that require providing your data in order to use them. Due to the nature of our services, the processing of personal data is an essential and inseparable part of providing certain services, even though in the service itself we will not process your name, social security number or other information that directly identifies you as a person.

Personal data to be processed

We process appropriate and necessary personal data. Such data include identification data, contact information, information related to your customer relationship and the use of services. Examples of personal data processed in our various services: • Contact information, such as first name and last name, address, telephone number, e-mail address, social media contact information • Identification and personalisation information, such as social security number or tax payer identification number, date of birth, the name and address of the user of the possible service, language of communication or other preference information • Bonus and loyalty benefit information and information about the services for which these are collected • Direct marketing prohibitions and consents • Payment transaction information • Other further information provided by you • Additional information regarding products, services and subscriptions • Subscription, delivery and contract information for products, services and subscriptions and start and end date for customer relationship for services • Customer information and classifications, such as information about the customers of Elisa subsidiaries and information about the customer classification of Elisa or its subsidiaries • Possible contact persons and user information of corporate and community customers and information about their tasks in the company • Customer history, for example communication, service changes or social media communication • Phone call, online chat, and other recordings regarding customer service situations • Information regarding invoicing and collection • Information about cookies and third-party cookies as well as other web analytics data

Customer data generated from transactions

When you call our customer service or use our other interactive service channels, we may record or otherwise save our conversation in order to verify the transactions. We retain these recordings only for the necessary time period and take into consideration data security factors when storing the recordings. The recordings may also be used for training our personnel and to ensure and develop the quality of our services.

Data generated from using the services

When you use our services on a browser, app or separate device, different kinds of data regarding your visits and use are saved. Such data include e.g. the IP address you use, browsing data or cookie data. In addition, we collect your information via the online services and mobile applications you use or devices using these services.

Cookies

Modern websites and services are based on a technology known as cookies that we use on our website. Cookies are small, user-specific text files that are saved on your browser. The server may later read the cookie installed on your browser and in this manner your browser may be identified as having visited our site previously. In this manner, you will get the best possible user experience on our website. With the help of cookies, we may also collect data e.g. regarding the devices, browser and objects of interest of the users visiting our websites. The collected information can be used also for analytics, improving user experience and targeting marketing both in our own and our partners’ advertisements. We aim to provide you with targeted content so that your user experience would be as smooth as possible. We use both our own and third-party cookies. The third-party cookies we use include e.g. DoubleClick, Facebook, Google Analytics, HubSpot and Smartly cookies. We monitor the functionality of the e-mails we send and we wish to ensure that you only receive communication from us that interests you. This means that we can follow which e-mails we have sent you and connect this data to your customer data. Therefore, when you call the customer service and ask e.g. about the offer you have received, the customer service person knows which message you have received and which offers have been sent to you. You may disable the use of cookies in your browser settings, in which case you may lose a part of your user experience. If you disable the use of cookies, our website may become slower and the use of some features may be prevented. In this event also our possibilities to develop our services in accordance with your user preferences is hampered, and we cannot provide you with adverts targeted for you on the website.

Collecting data on potential customers, for example in competitions, webinars and events

When you participate in competitions and sign up to e.g. our events or webinars, we may ask for your contact information or other personal data. We will use this data in order to organise the competition or event in question and possibly in order to contact you to tell you more about our products and services. We can also combine this data in our customer data systems. Competitions or events may also be organised by our partners, in which case we will receive your contact information directly from them.

How and for what purposes are we using your data?

Grounds for data processing

When you acquire a service from us, we make a contract with you. In order to implement the service agreed upon, such as delivering the products you have bought, we process necessary personal data, for example your invoicing data. We process your data when we have need for it in order to implement our appropriate interests (legitimate interest). The processing may be done to ensure the functionality of the services and for their improvement and to develop business operations (e.g. based on your purchase history, evaluating the need of future products that will be ordered for the warehouse). In such processing, we process your data typically as a part of a larger mass and we do not aim to examine your data specifically. By evaluating the data of a large group of people we can e.g. develop our services based on accurate and up-to-date information. In addition, with our legitimate interest, we offer you our services that you might be interested in. We will process a part of your personal data based on the consent that you have provided. Such processing includes cookies used online that improve the functionality of our services. When we process your data based on your consent, you can cancel your consent at any time. In exceptional situations we may process your data in order to protect vital interests. Such situations are life-threatening situations where we can reduce the threat by processing necessary information. Protecting vital interests might include, for example, finding out buyers from our register if a device we have sold were to manifest some dangerous manufacturing fault. In addition, we process personal data for compliance with our legal obligations.. Such obligations include retaining invoicing data separately for a legislated period of time.

Processing your personal data as a part of a large group of people

When providing services, a lot of information is collected e.g. when providing websites. Utilising this data is a part of modern information society.

Profiling

We wish to customise and develop our services, marketing and other interaction to suit you. For example, in our video services we will recommend interesting films that might interest you based on your viewing history. We can target the marketing of products that may interest you in our direct marketing. In order to form a marketing target group, we can process your age, purchase and payment history, place of residence, contact information, cookie information and other information and external classifications, such as the average size of a household of the postal code area of your invoicing address. When profiling, we therefore utilise both collective information and information directly related to you. We use automatic credit check in our web shop when you purchase products or services with a credit purchase. In some cases, the purchase may be prevented due to credit history issues. In this case, please contact our customer service so that we can look for an alternative solution.

Checking your own data

You can check the data concerning you and data generated from the use of services from your profile data accessible by you upon logging in on our web site. Please note that the right to inspect your own data only concerns your own personal data. Due to this, inspection rights cannot be used for inspecting the data of other family members.

Transferring your own data

If you wish you can download the information that you have disclosed to us based on a contract or consent. More information about this is found in the profile page section of our website.

Updating and specifying personal data

When you use our services we will ask you for your personal data. If your data has changed, we ask you to update the changed information to us. If you detect an error in your own data, you can fix this by notifying us via self-service or our customer service channels. In addition, we update and specify the personal data regarding you from other sources. We may, for example, receive your contact information from our partners for marketing purposes. We aim to keep your personal data accurate and up to date.

The retention period for personal data

We retain your personal data only for the necessary time period. The retention period for your personal data varies depending on the service and the nature of the data. When the retention period for the data has terminated, we dispose of the personal data either by removing them or making them anonymous (i.e. anonymisation of the data in question). For example, we process your customer data for the entire duration of the customer relationship and due to certain legal obligations also for a required period afterwards or, based on our legitimate interest, for direct marketing purposes. On the other hand, the retention period of the data collected in connection with producing the services may be quite short. Please note that the public comments or other content you produce on our online discussion forums may remain visible even after your customer relationship with us has ended. We regularly evaluate the need for the retention period of the data and evaluate their purposefulness as technology and use needs develop.

Marketing

We constantly develop and produce new services and introduce new products that correspond with our customers’ needs in a changing and developing world. To be able to tell you about such products and services, we use your personal data for direct marketing purposes. We may be in contact with you by letter or phone and also via e-mails, text messages, and other methods of communication. We may also be in contact with you as a potential new customer when we have received your contact information e.g. when you participate in our competition or an event we organise or in another way. If you do not wish to receive marketing communication from us, you can let us know i.e. via your profile page or customer service.

Direct marketing by third parties

If you wish, you have the possibility to receive offers and marketing from our partners. If you have given us your consent to utilise e.g. traffic or location data in targeting marketing, you may receive relevant offers from service providers in your area. When we transmit our partners’ communication to you, we do it ourselves. We do not disclose your contact or other information to third parties for marketing purposes. In this manner, we ensure that direct marketing meets your needs and does not disturb you. If you do not wish to receive marketing communication from our partners, you can let us know for example via your profile page or customer service.

Personal data processors and data disclosures

Disclosing personal data

When we provide services, we may disclose your personal data also to our subcontractors or partners when they need to receive your data to e.g. provide a service. Such needs include e.g. sharing your delivery address with a small parcel delivery company so that they can deliver your purchases. On our website, we use different kinds of techniques enabled by our partners for analysis and marketing purposes. When providing these services, we disclose personal data to the service provider. In these cases we do not disclose personal data that identifies you, but technical data enabled by the service, for example with the help of cookies. These services are very common properties of modern websites. You can read more about our cookies in this privacy notice. We produce some of our services in cooperation with our partners. To provide such such services, we disclose your personal data to the service provider. In some cases, using the service requires that you approve the privacy notice or terms of the service provider before using the service. Third parties process your data for their own purposes in accordance with their privacy notice. Before disclosing the data, we ensure that the disclosure is in accordance with the law.

Assisting authorities

Some authorities, such as data protection authority, police or emergency centre authority are entitled to receive your data in order to implement their legislated duties. We can also disclose your data to other authorities or parties with the decision of a competent authority or a court of law within the limits allowed by the law.

Subcontractors and processing data outside of the EU

The production of our services is primarily within the UK and EU/EEA. We use subcontractors when producing our services as well as related support services. When using subcontractors, we ensure that they abide with our privacy notice and process the data with care and confidentiality. We ensure this with contracts. Some of the personal data is processed outside of the EU area. This is necessary in order to produce the services, improve quality, provide expertise or enhance operations. Some of the processing work consists of maintaining the data located in the EU and processing them with remote management, but in some cases we transfer the personal data to be processed by our subcontractors for example in South Africa, India, Israel and the United States. In these cases we ensure that the processing party operates in accordance with our privacy notice, appropriately and with care, and that the justification of the processing is ensured e.g. with model contract clauses approved by the EU Commission. We process your personal data when needed between us, our parent company Elisa Oyj and its other subsidiaries. Regardless of the data processor or the location of the data, the protection of your service and personal data works equally through the services we provide.

Special notices about some of our services

Service-specific data protection principles

Elisa Oyj produces numerous different services for its customers. Some of the services have separate privacy notices that describe the data processing in connection with the service in question. In some of their services that Elisa Oyj produce themselves or in their other subsidiaries’ services data has to be processed in a manner that has not been mentioned in this privacy notice. Therefore, please remember to check the possible special terms in those other services and their changes in connection with starting to use the service and continuing the use. Separate privacy practices are applied at least in the following services: Elisa Kirja, Sulake games, such as Habbo Hotel and Hideaway, and Elisa Videra service.

Protecting copyright content

When providing material under copyright, such as video content for your use, we may protect the material with copy protection technology or water stamp in a manner that it can only be used by you or connected with you via your user or customer ID. In this manner, we aim to prevent possible abuse.

Data security

Data security

We ensure data security when processing your personal data. Most of your data will be processed in our own server rooms. We control the security of the server rooms by using appropriate measures to protect the data. The servers always use appropriate protective measures, such as access control based on passwords and other protective methods as well as technical encryption of the data. Our operating environment has been secured with fire walls and appropriate anti-virus software. We primarily process your data in a form where an outsider cannot identify you as an individual. Everyone is responsible for looking after data security. In order to ensure the protection of your data, we ask you to pay attention to looking after the data security of your own online devices in a manner as appropriate as possible. You can read more information about this at e.g. www.elisa.fi/dataprotection.

The scope of our privacy notice, our contact information, and other information

The scope of our privacy notice

This privacy notice concerns the processing of personal data in Banana Fingers Ltd and in EpicTV SAS. Our parent company Elisa Oyj may also have privacy policies that complement this privacy notice or that are parallel to this privacy notice.

Our contact information

Banana Fingers Ltd customer service: mailto:support@bananafingers.co.uk of phone +44 (0)117 955 1313 EpicTV & SHOP customer service: mailto:support@epictv.com
Elisa Oyj contact information: http://corporate.elisa.com/on-elisa/contact/

Data Protection Officer

Data Protection Officer / Elisa Oyj, P.O. Box 1, 00061 Elisa Oyj, FINLAND E-mail tietosuojavastaava@elisa.fi

Your rights regarding the processing of your data

You have the right to influence the processing of your own data.

You have a right to check what data we process on you. You can access your own data in the profile section of our online service.

If you notice incorrect or outdated data in the personal data we process, we ask you to correct the data either via self-service forms or our customer service. With your up-to-date information, we can provide you the best possible service.

In the profile page section of our service you can cancel the consents that you have given, such as marketing consents. If the consent is related to using a particular service, you can cancel the consent in the manner described in the service in question.

You have the right to request us to remove the data that are no longer necessary for its purpose of use. We do our best to remove such data automatically, but if you, for one reason or another, notice outdated or unnecessary information in our processing, you can contact us through our customer service.

You have the right to receive the data you have provided yourself if processing them is based on a contact between us or a consent you have provided. Services related to this are available as in-built properties and accessible by you via you profile page online but you can also be in contact with us via our customer service.

In addition, you can ask us to restrict the data processing in certain situations or object to their processing. We have aimed to describe all our processing in an open and comprehensible manner in this privacy notice.

Cancellation of consent

When we process your data exclusively based on the consent you have given, you have the possibility to cancel it if you change your mind. This can be done easily via your online profile page. Please note, however, that this does not affect the data processing that is done before the cancellation of consent.

Right to appeal

Please contact us if you wish to make an appeal or present development suggestions about our processing of personal data. You can find the contact information on this page in the Contact Information section.

You can make an appeal concerning data protection or processing of personal data to a supervising authority, such as the Information Commissioner’s Office (ICO) in matters related to communications or to Elisa Oyj’s Data Protection Officer in matters concerning other processing of personal data.

Updated: May 17, 2018