Privacy notice of Telia TV service

In Telia Finland (Telia) we recognize that privacy is important to our customers and we are committed to respect and safeguard our customers’ privacy. Our customers trust us with their private information and we are responsible for living up to this trust placed in us every day.

We have developed this Privacy Policy to:

• Demonstrate Telia’s commitment and accountability to protect and respect your privacy,
• Explain how we collect, use and safeguard your personal data, and
• Help you to understand what rights you have.

When processing your personal data, we comply with the Finnish legislation and the mandatory regulations, including General Data Protection Regulation, and instructions issued by the competent authorities. You can find Telia Privacy Notice.  

1. Controller details

Telia is the data controller of your personal data, when you use Telia TV services.

Telia Finland Oyj
Pasilan asema-aukio 1, Helsinki
PB 106 00051 TELIA
Business ID 1475607-9

National telephone exchange 020401 (Abroad +358 20401)
Privacy officer: tietosuoja-telia@teliacompany.com
Phone: 020401 (Abroad +358 20401) and
Customer service and phone 020 690 400

2. Telia TV Services

This Privacy Policy covers Telia TV services. Services are offered via Internet connection, using a set-top-box or an app on different devices or an Internet browser. Customer may have several accounts for Telia TV app.

Features in the service may vary according to the platform used.

You may also have additional applications which supplement set-top-box use:

• remote control application and/or
• remote scheduling application for personal video recording related to the personal video recording functionality.

In case you are using these supplementing applications this privacy policy also covers those.

This Privacy Policy applies when you use our Telia TV Services. This Privacy Policy does not apply to any other company’s applications, services or websites, even if accessed through Telia’s network or services. Such other company’s applications, services or websites may be provided and maintained for example by different broadcasters’, Netflix or Youtube.

3. How and what personal data do we collect?

When offering Telia TV services, we collect your personal data, which:

• You provide us; e.g. when you communicate or do business with us, for example, when you buy our Services or register to our Services or contact us requesting information. You can also for example change some of your setting in the Telia TV user interface directly, such as contact details or password.
• Generates when you use the Service; for example, when you use Telia TV Services by watching content in Telia TV Service, by recording programmes, by renting movies or when you browse through the TV user interface. Data generated by usage of Telia TV Services consist e.g. of TV viewing data and of information about your interaction with user interface of the Service e.g. by choosing between functionalities in the interface, clicking visible banners or choosing your settings for the services.

You are not required to provide any personal data to Telia, but if you decide not to do so, it is possible that we will not be able to provide our Services to you. When you subscribe to Telia TV Service it is necessary you to provide information to enter into and maintain a contract with us.

Telia TV Services are not especially offered or targeted for children. Therefore, it remains in responsibility of the child’s parent or guardian to ensure that if a child has access to any Telia TV Services they are guided and supervised appropriately.

4. Structure and main features of Telia TV Service subscription

We process usage data of the Telia TV set-top box in general in a way that usage data of possible several users of the household cannot be separated. In case of multiple users, the usage data of a user of the service cannot be linked back to an individual user. Please note that this means that incase of several users using the same service in the household, all users of the service may access to the information visible from the user interface of the set-top-box, such as the viewing details for example.

We process usage data generated via usage of Telia TV Application used through the internet browser, mobile device or other smart device. It is possible to have several Telia TV accounts for different devices. In case of multiple users for example of a computer and internet browser application, the usage data of possible several users of that computer cannot be separated. In case of multiple users, the usage data of a user of the service cannot be linked back to an individual user. Please note that this means that incase of several users using the same device, for example computer, in the household, all users of the service may access to the information visible from the user interface of the Telia TV Application, such as the viewing details for example.

If you have subscribed services on both set-top-box and app, the usage data are combined to allow the seamless viewing experience when you switch between devices. In this case the usage data of possible several users in a household or of the different devices cannot be separated. In case of multiple users of combined service covering services on both set-top-box and app, the usage data of users cannot be linked back to an individual user. Please note that this means that incase of several users or several Application devices using the same combined service in the household, all users of the service may access to the information visible from the user interface of the service, such as the viewing details in the set-top-box user interface for example.

The additional Applications supplementing the set-top-box: remote control application and/or remote scheduling application for personal video recording related to the personal video recording functionality, do not collect any usage data, but only serve their primary function and therefore connect the supplementing Application to Telia TV service.

Your Telia TV Service may include different functionalities, dependent on the platform you use and also e.g. on the age of the set-top-box or the version of your Application. Your Telia TV Service may have some or all of the following functionalities, for which we process your personal data for:

• Watched programmes, where watched programmes are visible on the TV interface,
• Continue watching list to continue watching a programme from the spot where you stopped earlier also including rental movies until they are available for you
• Recorded programmes list, connected to Network personal video recording feature to watch a recorded programme later
• Local news, which are provided to you based on your local area to provide local news

The following features also enrich and personalize your user experience and we process your personal data for:

• Most popular recommendations, which are general recommendations
• Personalized recommendations ‘Recommended for you’ and ‘Because you watched’, which are based on the viewing history created by you via the set-top-box or via an app through an internet browser, mobile device or other smart device.

5. How do we use your personal data?

When providing you the Telia TV Services Telia primarily relies on performance of contract and legitimate interest as legal grounds for its processing activities. When providing you additional applications which supplement the set-top-box: remote control application and/or remote scheduling application for personal video recording Telia relies on performance of contract as legal ground for its processing activities.

Telia processes your personal data for performance of contract e.g. for:

• Customer Administration; e.g. to administrate your contractual customer relationship with us and across Telia.
• Product and service delivery; e.g. to provide and deliver you the services based on your contract with Telia.
• Problem solving and fault detection; e.g. to solve any problems or faults and to ensure the quality of your service in your Telia TV service delivery.
• Pre-contractual relationship management; e.g. to fulfil pre-contractual activities, when you e.g. make purchases via TV interface
• Service transmission; e.g. to provide and deliver you the services based on your contract with Telia and to provide you the online content service also if you take your service with you, while temporarily travelling within the EU Member States in the course of the duration of your Telia TV service contract.

Telia processes your personal data based on legitimate interest. Telia has legitimate interest to processes your personal data e.g. for:

• Customer Care; e.g. to provide you customer care operations related to Telia TV services and products and to reach better services and products
• Basic Profiling; e.g.to offer you better customized services e.g. to provide you personalized TV content recommendations based on the programmes you have watched recently
• Marketing purpose; e.g. to up-date and inform you about and to offer you appropriate marketing about Telia TV products and services
• Service Improvement; e.g. to analyse the TV service usage to better understand our customers’ needs and to improve Telia TV services and products
• Statistical purposes; e.g. to provide you the general TV content recommendations based on most popular programmes and to create other TV service related statistics of our Services
• Customer relationship; e.g. to perform other processing activities to support your customer relationship and to comply with Telia’s contractual obligations to its stakeholders.

In addition, Telia may also transform your personal data into aggregated and anonymized form, where your individual personal data can no longer be distinguished from others data.

In all of the above cases, we process any personal only to the extent necessary for the purpose, always taking into account the protection of your privacy. Your personal data will be used by Telia only in a manner consistent with the purpose for which we obtained it.

6. How do we safeguard you data?

Safeguarding your personal data is of the utmost importance to us.

Telia continuously works to protect our customers’ interests. Our security work embraces protection for personnel, information, IT infrastructure, internal and public networks, as well as office buildings and technical facilities. Special attention is given to information such as your personal data.

Information security and ensuring appropriate protection of customer information is vital for us. We strive to implement security measures to set appropriate level of protection of information and to prevent and detect disclosure of personal data to unauthorized parties.

Our security work balances risk exposure, business value, available technology, vulnerabilities, and threats in order to comply with applicable laws, regulations as well as with contractual demands.

7. With whom do we share your information?

We share your information with:

• Telia group companies within the limits of applicable law. Our subsidiaries may use your information for the purposes indicated in this document, including to market their products and services to you.
• Subcontractors i.e. data processors, working for us and processing personal data on behalf of Telia. These processors process your personal data on behalf of us, when we have contracted them to assist us in the data processing, when providing Telia TV services, e.g. service supporting activities and analytical processing activities. These third parties may not use the personal data for any other purpose than for providing the service agreed with us. When using subcontractors, we take appropriate care to ensure that also our subcontractors operate in accordance with this Policy.

Data processor companies that perform services for us may be located outside the European Union or the European Economic Area. If we transfer your personal data this way, we take the appropriate steps in line with applicable laws to ensure that your rights to privacy and data protection are ensured. Depending on the situation, Telia may rely on an adequacy decision of the European Commission (providing that the country of location of the relevant service provider offers an adequate level of data protection) or if no such decision exists, Telia may use safeguards such as e.g. standard data protection clauses. To obtain a copy of the relevant safeguards (if applicable), please contact Telia customer services using the contact details determined in this Privacy Policy.

When you leave our Telia TV Service and use any other company’s applications, services or websites, even if accessed through Telia’s network or services, this Privacy Policy does not apply those external service providers’ applications, services or website. Any data processing and collecting taking place in external service provider’s service will be subject to the privacy policies and terms and conditions of those third party service providers. We encourage you to learn about the privacy practices of those external service providers.

We may also share your information:

• In response to legal process or authority request in order to comply with applicable law or court order or in connection with judicial proceedings or other legal process.
• To competent authorities, when required or otherwise authorized by law and always in accordance with strict predefined processes.
• In connection with business transfers such as part of any merger, acquisition, sale of assets or transition of service to another company.

We may also process anonymized or aggregated data, which does not relate to you as an individual. Such data can be shared for other purposes and parties.

8. How long do we retain your data?

We will retain your personal data for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by applicable law.

The guiding maximum periods of storage of data for the following purposes are as listed below. However, we may store the data less that the guiding period of storage shows, when the data is only needed to be stored for shorter period of time for the processing activity and purpose in question.

We store data for the above mentioned processing purposes, which we perform in order to fulfil our contractual relationship with you for maximum of two years from the end of customer relationship, except for the personal data that is processed and stored for Customer Administration purposes and for fault detection and problem solving purposes for maximum of three years from the end of customer relationship.

We store data for the processing purposes, which we perform base on our legitimate interest for maximum of two years from the end of customer relationship, except for the personal data that is processed and stored for Customer Relationship Support purposes and for Statistical and Marketing purposes for maximum of three years from end of customer relationship.

Retention times of anonymized data is not governed by these limitations or requirements.

9. How do we use cookies?

Telia TV services use ‘cookies’ technology. We use information collected by means of cookies for the following purposes:

Functional cookies and service provision: These cookies are important for the operation of the service and they also enable a smooth user experience. For example, when you log in to Telia TV Service, the cookies authenticate you to Telia’s systems, cookies may also help to detect service error situations. Also if you so desire, you do not have to enter the username, password and personalization options every time you log in to the Service.

Service development and Usage analysis: By monitoring the use of cookies, we can improve the operation of Services. We receive information, for example, on what the most popular sections of our Services are and we can compile statistics to evaluate the efficiency of different Service functionalities.

We may, within the scope of the law, combine information received by means of cookies with information received on the user in other connections, such as information on the Services used.

You can adjust your cookie settings in the browser settings and also disable the cookies there. We would like to remind you, however, that in some cases this may slow down the Service provision or reduce the functionality of or even prevent access to the Service.

Telia TV Services contains some links to third-party applications, services or websites. Third-party services or third-party applications found on Telia TV Service platforms are subject to the third party’s privacy policies. We encourage you to learn about the privacy practices of those third parties.

10. What are your choices and rights?

As a data subjects you have different rights regarding your personal data processing depending on the processing purposes and the situation. You have

• Right to object. You are entitled to object processing of the personal data, including profiling, when your personal data is processed based on Telia’s legitimate interest. Telia may decline the request on the compelling legitimate interests Telia derives from the processing. You can always object to direct marketing purposes also including profiling related to such direct marketing.
• Right to give and withdraw your consent. You are entitled to give and withdraw your consent at any time, if your personal data is processed based on consent from you.
• Right of access. You are entitled to obtain confirmation as to whether or not your personal data is processed and, where that is the case, access your personal data.
• Right to be forgotten. You are entitled to obtain the erasure of your personal data concerning you e.g. when you withdraw you consent of you have successfully objected to processing conducted based on legitimate interest.
• Right to rectification. You are entitled to obtain the rectification of inaccurate personal data concerning you or in some cases to have incomplete data completed.
• Right to restriction. You are entitled to obtain restriction of personal data processing when certain conditions apply.
• Right to portability. You are entitled to receive personal data concerning you that you have provided to us when processing of such data is based on consent or on fulfillment of contract. You have a right to receive such data in in a structured, commonly used and machine-readable format and have the right to also have this information transferred to another data controller.

11. How to use your rights?

You can use all your rights by loging in at Telia.fi and in My Telia app.

Please log into the service via the link or at the website on www.telia.fi. You can also contact Telia customer care or via telephone 020 690 400 for more information. You can also get more information from Telia Stores.

If you are concerned that Telia has not complied with this Privacy Policy or applicable privacy laws you may make a complaint to Telia. You also have the right to lodge a complaint with a supervisory authority of the member state of your habitual residence or the place of the alleged infringement e.g. with the Data Protection Ombudsman, which is the competent authority for privacy in Finland.

12. How to find out about changes to this Policy?

We may need to update this Policy as our operations, services and products develop, and therefore we encourage you to check for the latest version of this Privacy Policy regularly on our website. If we make any material changes to this Policy, we will notify you in Telia TV Service’s interface and by providing an up-dated Privacy Policy on our website.

13. How to contact us?

We encourage you to contact us using the contact information provided above for any questions about this Privacy Policy or processing of your personal data.