Manhattan TV Privacy Policy

We at Manhattan TV care about your privacy. This Privacy Policy sets out how and why we use your personal data, what your rights are and how you can contact us to enforce them.

This website is not directed at children and we do not knowingly collect information about children. 

If you have any questions about this Privacy Policy please contact our Privacy Officer, Michael Carver, at manhattan-tv.com/contact.

This Privacy Policy is effective as of 25/05/2018.

  • 1. Who we are

    This website is operated by Manhattan TV Limited, registered in the UK with company number 7350024, the "controller" of your personal information for the purposes of applicable data protection laws and this Privacy Policy. 

  • 2. What this Privacy Policy covers

    This Privacy Policy explains how we collect, use and share personal data which is:

    • collected or received when you use our websites https://manhattan-tv.com and https://manhattan-receivers.com (together the "Site");
    • collected or received when you purchase or make enquiries about our products, for example when we provide product support and information about our products (the "Service"); or,
    • received when you register your product with us.

    "Personal data" means data which can be connected to a living individual who can be identified from that data, either by itself or when combined with other data which may come into the possession of the controller, and can include information collected by certain cookies or tracking technologies.

    "Processing" includes a wide range of activity, for example collecting, storing, deleting, using, combining and sharing personal data.

  • 3. What types of personal data do we collect?

    We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

    • Identity Data includes first name, last name, title and age range.
    • Contact Data includes billing address, delivery address, email address and telephone numbers.
    • Financial Data includes bank account and payment card details.
    • Transaction Data includes details about whether you have requested to extend your warranty, payments to and from you and other details of products and services you have purchased from us.
    • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
    • Profile Data includes purchases or orders made by you; your interests, preferences, feedback and survey responses; and any other information which you give us.
    • Website Usage Data includes: information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Site (including date and time); products you viewed; page response times; download errors; length of visits to certain pages; page interaction information (such as scrolling, clicks, and mouse-overs); and methods used to browse away from the page.
    • Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

    We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

    We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

  • 4. How do we collect your personal data?

    We use different methods to collect data from and about you including through:

    • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
      • register your product;
      • request details about our products or services (marketing) to be sent to you;
      • subscribe to our publications;
      • place an order for products;
      • contact us for technical support;
      • enter a competition, promotion or survey; or,
      • give us some feedback.

    As a matter of ensuring optimum customer service levels at no point will any financial data that you may give us over the phone be recorded.

    • Automated technologies or interactions. 
      • As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. Please see Section 6 below for more information.
      • When you make an incoming call into us, the telephone number from which you were calling will be recorded on the systems of our phone service provider.
      • If you visit any of our offices or other work locations, footage of you may be captured and stored on our Closed Circuit TV or similar video systems (“CCTV”). CCTV is primarily used for maintaining the security of our property and premises and for preventing and helping with the investigation of crime.
    • Third parties or publicly available sources. We may receive Technical Data about you from analytics providers such as Google based outside the EU.
    • Information we share between our Group companies. Although it is not our standard practice, from time to time we might receive information about you if you use any of the other websites we operate or the other services we provide. The Corporate Group of companies are; 
      • Eurosat Holdings Limited;
      • Eurosat Distribution Limited;
      • Eurosat Distribution (Midlands) Limited;
      • Manhattan TV Limited; and,
      • National Broadband Limited T/A 4G Internet.
  • 5. How do we use your personal data?

    Our primary goals in collecting personal data are to provide you with information about our products and services, to provide you with our products and services and to improve our products.

    We have set out below, in a table format, a description of all the ways we plan to use your personal data, and what our legal bases are in accordance with applicable data protection legislation. We have also identified what our legitimate interests are where appropriate.

    Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

    Please contact us at manhattan-tv.com/contact if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.


    Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest

    To register you as the owner of a Manhattan product.

    (a) Identity

    (b) Contact

    (c) Transaction

    Performance of a contract with you

    To process and deliver your order including:

    (a) Manage payments, fees and charges

    (b) Collect and recover money owed to us

    (a) Identity

    (b) Contact

    (c) Financial

    (d) Transaction

    (e) Marketing & Communications

    (a) Performance of a contract with you

    (b) Necessary for our legitimate interests (to recover debts due to us)

    To manage our relationship with you which will include:

    (a) Notifying you about changes to our terms or privacy policy

    (b) Asking you to leave a review or take a survey 

     

    (a) Identity

    (b) Contact

    (c) Profile

    (d) Marketing & Communications

    (a) Performance of a contract with you

    (b) Necessary to comply with a legal obligation

    (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

    To understand the ages of our users better so that we know both what features to prioritise with our products and also where to target our marketing

    (a) Identity

    (a) Necessary for our legitimate interest to develop our products/services in accordance with the needs and preferences of the users of our products

    To enable you to partake in a prize draw, competition or complete a survey

    (a) Identity

    (b) Contact

    (c) Profile

    (d) Usage

    (e) Marketing & Communications

    (a) Performance of a contract with you

    (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

    To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

    (a) Identity

    (b) Contact

    (c) Technical

    (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

    (b) Necessary to comply with a legal obligation

    To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

    (a) Technical

    (b) Usage

    Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

    To send you updates about your product (for example news of important software updates & features)

    (a) Identity

    (b) Contact

    (c) Profile

    (d) Marketing & communications

    With your consent. necessary for our legitimate interests (to develop our products/services and grow our business)

    To provide you with exclusive offers, updates and other marketing communications.

    (a) Identity

    (b) Contact

    (c) Profile

    (d) Marketing & communications

    With Your consent. Necessary for our legitimate interests (to develop our products/services and grow our business)

    To share information as appropriate with applicable law enforcement agencies or regulators.

    (a) Identity

    (b) Contact

    (c) Technical

    (d) Profile

    (e) Usage

    (f) Marketing & Communications

    (g) Transaction

    (h) Financial

    (a)  Necessary to comply with a legal obligation

     

    (b) Necessary for our or a law enforcement agency or regulator's legitimate interests (to prevent or detect crime)

    Marketing

    We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

    Promotional offers from us

    We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

    You will receive marketing communications from us if you have requested information from us or purchased goods from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

    Third-party marketing

    We will get your express opt-in consent before we share your personal data with any company outside the corporate group of companies for marketing purposes.

    Opting out

    You can ask us to stop sending you marketing messages at any time by contacting us at manhattan-tv.com/contact.

    Change of purpose

    We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at manhattan-tv.com/contact.

    If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

    Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  • 6. Cookies and other tracking technology

    When you visit the Site, our servers automatically record Technical Data, which your browser sends whenever you visit a website, and Website Usage Data. 

    This may include information such as your IP address, browser type or the domain from which you are visiting, the web-pages you visit, the search terms you use, and any advertisements on which you click. For most users accessing the Internet from an Internet service provider the IP address will be different every time you log on. 

    We use this data to monitor the use of the Site and of our Service, and for the Site's technical administration. We do not associate your IP address with any other information to identify you personally, except in case of violation of our Site Terms of Service.

    Like many websites, we also use "cookie" technology to better understand how you interact with the Site and our Service, to monitor aggregate usage by our users and web traffic routing on the Site, and to improve the Site and our Service. Please see our Cookie Policy for more information.

  • 7. How we disclose your personal data

    We may have to share your personal data with the parties set out below for the purposes set out in the table in section 5 above. 

    • Internal Third Parties. We may share your personal data with other companies in the same corporate group as Eurosat Distribution Limited (defined in section 4)  acting as joint controllers and who are based in the UK and provide IT and system administration services.
    • External Third Parties:
      • Service providers acting as processors based in the United Kingdom who provide IT and system administration services.
      • Analytics and search engine providers that assist us in the improvement and optimisation of our Site.
      • Professional advisers acting as processors or controllers including bankers, lawyers, auditors and insurers based in the United Kingdom who provide banking, legal, consultancy, accounting and insurance services.
      • HM Revenue & Customs, regulators and other authorities based in the United Kingdom if required to do so by applicable law, or if it is in our legitimate interest to do so.

    Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

    We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions:

    • to enforce or apply our terms of this website and other agreements; or to protect the rights, property, or safety of Manhattan, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
  • 8. Where we store your data and international transfers

    We host your data on our secure Internal servers or on servers hosted by Google in one or more of its data centres in the EEA or in Switzerland and the United States of America.

    We may also transfer your personal data to a destination outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: 

    • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
    • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. 
    • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

    In exceptional circumstances, where there is no option to put adequate safeguards in place, we may rely on one of the derogations provided by Article 49 of the EU General Data Protection Regulation.

    Please contact us at manhattan-tv.com/contact if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

  • 9. How long we keep your personal data

    We will only keep your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

    To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

    You can, by contacting us at manhattan-tv.com/contact, request from us details of retention periods for different aspects of your personal data.

  • 10. How we keep your data secure

    We care about the security and confidentiality of your personal data. Data collected in the UK is held in accordance with applicable data protection laws. We use administrative, physical and electronic measures to protect your information from unauthorized access.  

    All information you provide to us is stored on Google's secure servers. 

    Any payment transactions will be encrypted using SSL technology. 

    Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access, such as SSL technology.

    We will make any legally-required disclosures of any breach of the security, confidentiality, or integrity of your electronically stored personal data to you via email or conspicuous posting on this Site without undue delay.

  • 11. Your Rights

    Depending on the circumstances, you have a number of rights under Regulation (EU) 2016/679 (the "GDPR"). You can also exercise the right at any time by contacting us at manhattan-tv.com/contact – see more information below on what we will require from you before we can respond to such requests.

    Right to object to direct marketing

    You have the right to ask us not to process your personal data for marketing purposes, including profiling (eg. tracking your usage of our websites) to the extent that it is related to direct marketing. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. Within a reasonable time after receipt and consideration of your objection we will no longer process your personal data for direct marketing purposes. You can exercise your right to prevent such processing by ticking certain boxes on the forms we use to collect your data, or by contacting us at any time.

    Access to Information

    The GDPR gives you the right to find out whether we are processing your personal data and, where that is the case, to receive a copy of the personal data we process and information on:

    • why we are processing it;
    • the categories of personal data we process about you;
    • the recipients or categories of recipient to whom the personal data have been or will be disclosed;
    • where possible, how long we plan to keep your personal data or the criteria we use to determine that period;
    • information on your rights under the GDPR;
    • information on where we received your data from if we did not receive it directly from you; and,
    • if we transfer your personal data outside of the EEA, details of the appropriate safeguards we have used to protect your personal data and uphold your data protection rights.

    We will not charge you for complying with your request and providing you with a first copy. Any further copies may be subject to a reasonable administrative fee. Where your personal data is inseparable from the personal data of others, we reserve the right to redact or withhold it if it will infringe the rights of those third parties.

    The right to withdraw your consent to the processing of your personal data

    If we process your personal data on the grounds of your consent, you have the right to withdraw your consent at any time. This will not affect the legality of our processing of your data up until the point at which you withdraw your consent. Please also note that we may still need to process your data on other grounds, for example to fulfil a contract with you or as required by law.

    The right to object to processing of your personal data

    You have the right to object to us processing of your personal data if we are using the lawful grounds 'legitimate interest' or that the processing is in the public interest. When we receive your objection we will assess our legal grounds for processing and will stop processing the data if we cannot demonstrate compelling legitimate grounds to continue processing the data.

     

    The right to request the restriction of your personal data

    You have the right to ask us to restrict our processing of (ie. stop using) your personal data if you think that it is inaccurate, that we are processing it illegally, or that we no longer need it for the purposes for which it was collected. While we consider your request we will stop processing your data within a reasonable time from the date we receive your request. We will notify you of our decision and any justifications for continuing to process your data as soon as we can.

     

    The right to request amendment or erasure of your personal data

    You have the right to request the amendment of your personal data at any time if it is inaccurate. If it is incomplete, you have the right to have the information completed, taking into account the purposes of processing. You also have the right to require us to delete your personal data as soon as possible where one of the following applies:

    1. the personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
    2. you withdraw your consent to us processing your personal data and we have no other legal grounds for processing it;
    3. the personal data have been unlawfully processed;
    4. the personal data must be erased for compliance with a UK or EU legal obligation on us;
    5. the personal data relates to a child under 13.
       

    The right to data portability

    You have the right to receive personal data which you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit those data to another data controller, if we are processing it on the grounds that you have consented to that processing or because it was necessary in order to perform a contract with you, and if we have no other legal bases for processing it.


    The right to complain to the Supervisory Authority

    If you feel that we have processed your data unfairly or unlawfully, you have the right to complain about us to the relevant Supervisory Authority. In the UK this is the Information Commissioner's Office. You can contact the Information Commissioner's Office here: https://ico.org.uk/global/contact-us/.


    To the extent that we can, and that it is proportionate to do so, we will communicate the amendment, restriction or erasure of your personal data to parties who have already received it and ask them to respect your wishes.

    You can exercise your rights at any time by contacting us at manhattan-tv.com/contact. Please state clearly in your email which rights you are seeking to enforce, a full description of the information or type of information that you are writing about, and include details which will confirm your identity, such as your data of birth and a scan of your passport or driving licence. This is so that we can keep your data secure. We aim to respond to your requests as soon as we can, and we will keep you informed of our decisions and reasons for those decisions.

     

    No fee usually required

    You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

     

    Time limit to respond

    We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

  • 12. Links to External Files & Websites

    Our Site contains links to external files and websites. The fact that we link to a file or website is not an endorsement, authorization or representation of our affiliation with it. We do not exercise control over third party files or websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personally identifiable information from you. Other sites follow different rules regarding the use or disclosure of the personally identifiable information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit. 

  • 13. Our Policy Towards Children

    The Site is not aimed at persons under 16. If you are a parent or guardian and you become aware that your child has provided us with personally identifiable information without your consent, please contact us at manhattan-tv.com/contact. We do not knowingly collect personally identifiable information from children under 16. If we become aware that a child under 16 has provided us with personal identifiable Information, we will delete such information from our files. 

  • 14. Changes to this Policy or to your personal data

    This Privacy Policy may be updated from time to time for any reason; each version will apply to information collected while it was in place. We will notify you of any material changes to our Privacy Policy by posting the new Privacy Policy on our Site or, where appropriate, by emailing you. You are advised to consult this Privacy Policy regularly for any changes.

    It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

  • 15. Contact us

    If you have any thoughts or questions about this Privacy Policy, or wish to exercise your rights, please use our online form at manhattan-tv.com/contact

    We are also contactable by telephone at +44 (0) 20 8450 0005, on Mondays to Fridays between 9am and 5:30pm. 

    You can also write to us at: Manhattan TV Limited, 3 Phoenix Park, Apsley Way, London, NW2 7LN. It may take us longer to process hard copy letters or requests but we will endeavour to respond to you as soon as we can.