Privacy Policy
Effective Date: September 28, 2020
1. Introduction
UPICtv (“UPICtv,” “we” or “us”) respects your privacy. This Privacy Policy explains the collection, use, and sharing of information from or about you in connection with your use of the UPICtv Services. The term “UPICtv Services” refers to our video service, including the selection of television shows, clips, movies, and other content we offer (collectively, the “Content”) and our player for viewing the Content (the “Video Player”), as well as any other products, features, tools, materials, or other services offered from time to time by UPICtv through a variety of Access Points. The term “Access Points” refers to, collectively, the UPICtv.com website (the “UPICtv Site”), applications, and other places through which the UPICtv Services may be accessed, including websites and applications of UPICtv’s third-party distribution partners and other websites where users or website operators are permitted to embed or have otherwise licensed the Video Player.
By viewing any Content or otherwise using the UPICtv Services, whether you are a subscriber, other registered user, or a visitor who has not subscribed to or registered for the UPICtv Services, you consent to the collection and use of information from or about you as explained in this Privacy Policy. If you do not consent to the collection and use of information from or about you in accordance with this Privacy Policy, then you may not use the UPICtv Services.
Please note that the website addresses (i.e., URLs) included within this Privacy Policy may not function as hyperlinks on all the Access Points. To view this Privacy Policy with clickable hyperlinks, please visit the UPICtv Site on your computer.
2. Information We Collect
UPICtv may collect the following information from or about you:
Information You Provide To Us. We collect information you provide to us. For instance, when you register to use the UPICtv Services, we may collect your name, email address, birth date, gender, credit card information, billing address, postal code, and other information. In addition, UPICtv may collect information you provide to us when you respond to surveys, set your preferences, contact UPICtv through customer service or by other means, or participate in promotions that UPICtv may offer from time to time. UPICtv also allows multiple profiles to be set up under one account, so we may collect information you provide to us if you create a profile.
Usage and Log Data. We collect information when you use the UPICtv Services or view UPICtv advertising outside of the UPICtv Services. Examples of this information may include your IP address, device, browser and software characteristics (such as type and operating system), location (which may include precise location data), activity on the UPICtv Services including information about the videos you view on UPICtv (e.g., show titles and episode names), page views, ad data, referral URLs, network state, device identifiers or other unique identifiers associated with browser cookies (see our description of “Cookies and Local Storage” below), and carrier information.
Data Collected Through Cookies and Similar Technologies. Like many online services, we use various technologies to collect usage data and store preferences. These technologies are discussed below.
Cookies and Local Storage. One technology we use is called a cookie. A cookie is a small data file that is transferred to your computer’s hard disk. We may use both session cookies and persistent cookies to better understand how you interact with the UPICtv Services, to monitor aggregate usage by our users and web traffic routing on the UPICtv Services, and to customize Content and advertising. These uses allow us to improve the UPICtv Services. We may create a unique device or user ID for you and store it in a cookie so we can customize your experience based on your preferences.
We may collect information through other kinds of local storage (also referred to as “Flash cookies”) and HTML5 local storage, including in connection with features such as volume/mute settings for the Video Player. Because these technologies are similar to browser cookies, they are sometimes called “browser cookies,” even though they may be stored in different parts of your computer.
Most Internet browsers automatically accept cookies. You can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. For information about disabling cookies or deleting information contained in Flash cookies, please visit Adobe.com Manage, disable Local Shared Objects. Please note that disabling cookies or deleting information contained in cookies or Flash cookies may interfere with the performance and features of the UPICtv Services, including the Video Player. For example, we may not be able to store your preferences or login information or customize the Content to your viewing habits.
Web Beacons or Pixels. In addition to cookies, we may use other technologies such as web beacons or pixel tags, which can be embedded in web pages, videos, or emails, to collect certain types of information from your browser or device, check whether you have viewed a particular web page, ad, or email message, and determine, among other things, the time and date on which you viewed the Content, the IP address of your computer, and the URL of the web page from which the Content was viewed.
Mobile Device Identifiers and Software Development Kits (“SDKs”). We may use or work with third parties including our business partners and service providers who use mobile SDKs to collect information related to how mobile devices interact with the UPICtv Services. An SDK is computer code that app developers can include in their apps to enable ads to be shown, data to be collected and related services and functionality to be implemented. A mobile SDK is in effect the mobile app version of a pixel tag or beacon. We may use this technology, for instance, to analyse how you interact with Content and to enable analytics or other features through mobile devices.
Account and Profile Data from Third-Party Services. If you choose to log-in, access or otherwise connect to the UPICtv Services, or contact UPICtv, through a third-party service (such as Facebook), we may, for example, collect your user ID and user name associated with that service, as well as any information you make public using that service. We may also collect information you have authorized the service to share with us (such as your user ID, billing information, public profile information, email address, birthday, friends list, pages you have “liked” and other account and profile data).
Third-Party Data. We may collect information about you from other sources, such as data aggregators, public databases, and our business partners. Examples of this may include information (whether identified, de-identified or anonymous, and whether collected online or offline) about your interests, demographic data, purchasing behaviour, and your activities online (such as websites visited and advertisements viewed).
We may combine the information we collect from or about you and use it in the manner described in this Privacy Policy or as otherwise permitted by law.
3. Use of Information We Collect
Use in General. We use the information we collect from or about you in order to help deliver a first-class user experience. Our use of this information may include the following:
providing the UPICtv Services;
contacting you, including for promotional purposes;
customizing the Content and advertising you view and evaluating how well the Content perform;
identifying Content you share;
customizing recommendations;
conducting research;
compiling aggregate data for internal and external business purposes;
preventing potentially illegal or harmful activities, including fraud;
protecting your and our rights;
other uses in accordance with our Terms of Use; and
any other purpose that is disclosed to you at the time we collect the information or that is related to a request made by you.
Use of Payment Information. We use payment information, such as credit card numbers and billing postal code, to help provide the UPICtv Services. For example, we use payment information to process payments from a subscriber (we use a third-party payment processor to do this), to retrieve account information for a subscriber, to determine whether a subscriber is eligible for promotions, and to detect abuse of the UPICtv Services.
Use of Precise Location Data. In order to access certain UPICtv Services from your mobile device, you may be required to share your device’s precise location data (e.g., latitude and longitude) with us. In addition to providing you with certain UPICtv Services, this also enables us to serve you Content related to your local area such as news and sports, depending on your subscription. To learn more about your choices with respect to our collection and use of precise location data, please see the information we have provided in Section 6 (“Your Choices, Including Opt-Out Options”).
Use of Aggregate or De-Identified Information. In addition to the individual data use described in this Privacy Policy, we may aggregate information about you and other individuals together, or otherwise “de-identify” the information about you (which means that the information does not identify you personally). We may use information in these forms for any legitimate business purpose, including for research and analysis, administration of the UPICtv Services, and promotional purposes.
4. Sharing Information with Third Parties
We may share information collected from or about you with third parties as explained further below, including business partners, social networking services, service providers, advertisers, and other companies that are not affiliated with UPICtv.
Business Partners. We work with a number of business partners who help us offer the UPICtv Services, including, for example, our content programmers, distributors, and corporate owners. We may share information collected from or about you with such business partners.
Social Networking Services. When you choose to share information with social networking services about your activities on the UPICtv Services, including shows you watch or like on UPICtv, information about you and your activities will be shared with that social network.
Sharing with Facebook. In addition to UPICtv collecting certain information from Facebook (as described in Section 2 (“Information We Collect”), if you connect your UPICtv and Facebook accounts, you may choose to share information about your activities on the UPICtv Services with Facebook and its users, including publishing shows you watch to Facebook. If you visit UPICtv while logged into Facebook, then Facebook may be able to identify your browser and associate the technical information provided by your web browser with other information that Facebook already has about you. In addition, when you choose to share information about your activities on the UPICtv Services with Facebook, UPICtv may send information about you to Facebook. Facebook may make that information visible to Facebook users in accordance with applicable law, Facebook’s data policy, and your Facebook privacy settings. We recommend that you familiarize yourself with Facebook’s data policy and privacy controls.
Service Providers. We may share the information collected from or about you with companies that provide services to us and our business partners, including companies that assist with payment processing, analytics, data processing and management (e.g., to facilitate our targeted marketing efforts), account management, hosting, customer and technical support, marketing (e.g., email, online or direct mail communications) and other services.
Your Browsers and Devices. We may work with service providers who use information collected from or about you to help us identify the browsers and devices you use for various purposes, including for analytics and attribution purposes. For example, these service providers (along with UPICtv) may use your activity on one browser or device to serve you with more tailored advertising on another browser or device. In connection with your use of browsers and devices, please note that certain opt out choices you have as described in Section 6 (“Your Choices, Including Opt-Out Options”) apply only to the specific browser or device from which you opt out.
Third Parties When Required By Law or When Necessary to Protect Your or Our Rights. In some instances, we may disclose information from or about you without providing you a choice. For example, we may disclose your information in the following ways: to protect the legal rights of UPICtv and our affiliates or partners, and each of our respective equity holders, directors, officers, employees, agents, and business partners; to protect the safety and security of users of the UPICtv Services or third parties; to enforce our Terms of Use; to protect against fraud; for risk management purposes; and to comply with or respond to the law or legal process or a request for cooperation by a government entity, whether or not legally required. If you notify us that you believe your legal rights have been violated by UPICtv or another user of the UPICtv Services, we may provide the information that you provide to us to others to the extent that we believe it is necessary to evaluate and respond to your complaint.
Third Parties in Connection with Certain Transactions. If we sell all or part of our business, make a transfer of assets, or otherwise might be involved in a change of control transaction, or in the event of bankruptcy, we may transfer information from or about you to one or more third parties as part of the transaction, including the due diligence process.
Parties with Your Consent or When You Otherwise Choose to Share. In addition to the sharing described in this Privacy Policy, we may share any information from or about you with any party when we have your consent or when you otherwise choose to share such information, including as set forth below in Section 5 (“Sharing What You Watch”). Also, certain functions within the UPICtv Services may give you the option to share information about your activities on the UPICtv Services, for example, by email, text message, social networking, or other sharing function.
5. Sharing What You Watch
We may ask for your consent to UPICtv sharing information about the videos you view on UPICtv (e.g., show titles and episode names) (“Viewing Information”) together with your personal information that we may collect (e.g., name, address, email address, and precise location data) with our content programmers, service providers, and other third parties set forth in Section 4 (“Sharing Information with Third Parties”). This information may help UPICtv or these third parties personalize your experience by providing you with more tailored content, features on UPICtv as well as on other platforms and services. Please note that we request consent on a per-profile basis (i.e., for each profile) and therefore the consent provided for one profile does not apply to the consent of any other profile associated with the account. To learn how to view or change your consent preference, please see the information we have provided in Section 6 (“Your Choices, Including Opt-Out Options”). For clarity, even if you have not consented to UPICtv sharing Viewing Information together with your personal information, we may still share information collected from or about you as otherwise permitted in this Privacy Policy. For example, we may still share Viewing Information together with account or device information that does not personally identify you (such as IP address).
6. Your Choices, Including Opt-Out Options
You have the following choices regarding how we and third parties use certain information collected from or about you.
Opt-Out from Promotional Communications.
You may opt out of receiving promotional communications from UPICtv by accessing your account and clicking on “Manage Email Notifications.” You may also opt out of certain promotional communications by clicking the “unsubscribe” link in a particular promotional communication. Please note that you cannot opt out from receiving all communications from UPICtv, including administrative messages, service announcements, and messages regarding the terms and conditions of your account because those may contain important information.
You can choose to receive push notifications from UPICtv on your device. If you do not wish to receive push notifications, you can use your device’s settings to turn them off.
Opt-Out from Collection of Precise Location Data from Your Mobile Device
You can opt out of our collection of precise location data from your mobile device in your device settings, for example, by disabling “Location Services” for the UPICtv application in your iOS device’s settings. Please note that by opting out of our collection of precise location data, your access to the UPICtv Services on your mobile device may be limited depending on your subscription.
Options for Sharing What You Watch
As set forth in Section 5 (“Sharing What You Watch”), we may ask for your consent to UPICtv sharing your Viewing Information together with your personal information with our content programmers, service providers, and other third parties. If we have asked for your consent, you may view or change your consent preference by logging into UPICtv on your computer, going to your account settings, and editing your profile. If you would like to consent to UPICtv sharing your Viewing Information together with your personal information, set your “Manage Video Sharing” preference to “Yes.” If you would like to withdraw your consent, set your “Manage Video Sharing” preference to “No.” You can change your consent on a case-by-case basis by changing your “Manage Video Sharing” preference before viewing a video. Please allow us a few minutes to process any changes to your preference.
7. Security and Account Access
We use a variety of physical, technical, and administrative measures to safeguard information in our possession against loss, theft and unauthorized use, disclosure, and modification. For example, we take steps to limit access to sensitive information from or about you to those UPICtv employees, agents, and contractors who have a legitimate business reason to access such information. We also use measures like encryption and hashing to help protect sensitive information when in transmission.
Despite these efforts, please note that there is always a possibility that a breach in data transmission or storage may occur. We want you to feel confident in our security when using the UPICtv Services, but we cannot guarantee the security of any information from or about you 100% of the time.
Please note that if you allow others to use your account (including others you permit to set up profiles under your account), they may be able to view information about your account or any of the profiles under your account, including information about the videos you view and your email address.
8. Children
Children under 15 years of age are not permitted to register with UPICtv. The UPICtv Services are not intended to be used by children without involvement and approval of a parent or guardian.
9. Third-Party Access Points, Devices, and Links
The UPICtv Services may be provided through third-party websites, applications and other means of access operated by other companies (collectively, “Third-Party Access Points”). For example, you can access the UPICtv Services through websites of our distributors. In addition, you may launch a Third-Party Access Point using various devices such as mobile devices and Living Room Devices. The UPICtv Services also may contain links to third-party websites or applications. None of these Third-Party Access Points, devices, websites or applications are operated by us, even if they contain our name or logo, and we are not responsible for the privacy practices of their operators. Accordingly, we recommend that you review their privacy policies.
10. Deleting Your UPICtv Account
You may delete your UPICtv account, in accordance with our Terms of Use, or via the link accessible on the Account page. You must cancel your subscription before you are able to delete your account. Please note that, after you delete your account, we may retain some information from or about you in accordance with applicable law, including for various legal, operational, accounting, and auditing purposes.
11. Applicable Law
UPICtv is headquartered in Botswana and the UPICtv Services are intended for users in the Botswana. By viewing any Content or otherwise using the UPICtv Services, you consent to the transfer of information to Botswana to the extent applicable, and the collection, storage, and processing of information under Botswana laws.
12. Changes to this Privacy Policy
From time to time, we may revise this Privacy Policy to reflect changes in the law or the UPICtv Services or for other reasons. Therefore, it is important to check the effective date posted at the top of the Privacy Policy each time you visit the UPICtv Site or use any of the UPICtv Services to ensure you are familiar with our most updated policies and practices. If we make any material change to this Privacy Policy, we will notify you by posting a notice on the UPICtv Site. If you are a registered user, we will also send an email to the email address that you most recently provided to us prior to the material change taking effect. Accordingly, please keep your account information, including email address, updated. Any material change to this Privacy Policy will be effective automatically 30 days after the revised Privacy Policy is first posted or, for users who register or otherwise provide opt-in consent during this 30-day period, at the time of registration or consent, as applicable.
13. Questions/Contacting Us
At UPICtv, we expect that our first-class customer support team will be able to resolve most issues you may have using the UPICtv Services. If you have any questions regarding this Privacy Policy, you may email us at privacy@upictv.co.bw or contact us by mail addressed to:
Attention:
Legal Department
BOTSWANA FIBRE NETWORKS (PTY) LTD
Registration Number: CO2012/12673
Address: Botswana Fibre Networks (Pty) Ltd
Zambezi Towers
Plot 54352 Floor 2 ,3 & 4
Central Business District
Gaborone,Botswana
Telephone: +267 3995500
Thank you for taking the time to read this Privacy Policy. We hope you enjoy the UPICtv Services!
