Last updated: December [ ], 2019
As one of the world’s leading media and entertainment companies, we offer NBCUniversal Services through a wide range of businesses and under many different brands. The data controller of your personal information will be the NBCUniversal company which provides services to you or does business with you. You can find out more information about NBCUniversal, including a list of our NBCUniversal Affiliates, here.
- PERSONAL INFORMATION WE COLLECT AND PURPOSES
The tables below explain the categories of information we collect and the purposes for which we use them. Each NBCUniversal Service’s collection and use may vary. Please note that we may use any or all of this information to comply with the law, detect or prevent fraud, and to defend our legal rights. Further detail about each of the purposes is set out in the “Additional Information on Purposes” table below.
|Categories of personal information we collect||Purposes of use|
|Information you provide to us:|
|Contact information and account registration
For example: name, email, postal address, telephone number, account user name and password, business contact information, and any information you may provide to us at an event or in person.
|Identification and demographics
For example: date of birth, gender, nationality, ethnicity, interests, lifestyle information, photos, social media credentials, including identification information about friends, contacts or referrals you provide.
For example: credit/debit card details, purchase history, delivery address, membership information, reservations, and the personal details of any of your guests.
For example: photos, videos, audio, and other information you may submit to us, such as comments on our forums.
|Research and feedback
For example: comments that you send us through online forms and social media platforms, by email, over the phone, by mail, or in surveys.
For example: facial scans or fingerprints we collect at some of our theme parks, studios, or our offices.
|Audio and video
For example: audio recordings of a customer service call or security video footage if you visit one of our properties.
|Categories of personal information we collect||Purposes of use|
|Information we collect automatically from you and/or your device:|
|Device information and identifiers
For example: IP address, cookie IDs, browser type and language, operating system, platform type, device type, and advertising and app identifiers.
|Connection and Usage
For example: domain names, browsing activity, scrolling and keystroke activity, advertisements viewed, forms or fields you complete or partially complete, search terms, whether you open an email, content you view and duration, quality of the service and interaction with the content, logs, and other similar information. If these events occur while you are offline, they may be logged and uploaded to us when you next connect.
For example: city, state and ZIP code associated with your IP address or derived through Wi-Fi triangulation.
We will ask for your permission before using your precise location from GPS-based functionality on your mobile devices.
|Categories of personal information we collect||Purposes of use||Sources of Information|
|Information we collect from third parties:|
|Information from public and commercial sources
For example: demographic including at a household level, contact information, inferences about your preferences, loyalty program membership, and purchasing data.
|Social Media Information
For example: if you interact with us through a social media service or log in using social media credentials, depending on your social media settings, we may have access to your information from that social network such as your name, email address, friend list, photo, age, gender, location, birthday, social networking ID, current city, your comments about our Services, and the people/sites you follow.
|Additional information that we collect for business relationships only|
|Categories of personal information we collect||Purposes of use||Sources|
|Business contact information,
For example: company name, your name, email address, and job.
|Due diligence information
For example: contact information, nationality, job title, age, date of birth, gender, country of residence, employment and education information, public, religious, political or trade union roles, personal and professional affiliations, connections to criminal activities or offences related to money laundering.
|Additional information on purposes of use|
|Provide the NBCUniversal Services, for example:
|Personalize the experience, for example:
|Send marketing communications (with consent if required), for example:
|Provide a seamless experience across platforms and devices, for example:
|Build and manage business relationships, for example:
|Market and advertise for third parties, for example:
create profiles about you, including adding and combining information we obtain from third parties and matching your interests across devices, which may be used for third-party marketing and advertising on the NBCUniversal Services, television, third party services and platforms, mobile apps and/or websites, connected devices and offline
|Compliance and risk management activities for business relationships, for example:
|Protect our users, Services and properties, for example:
- WHEN WE SHARE YOUR INFORMATION
We may share your information with:
- Related Companies: NBCUniversal Affiliates, such as Sky, as well as our parent company Comcast Corporation and its affiliate, Comcast Cable, to help better tailor services, products, marketing, and advertising to you and to other existing and potential customers. We may share identification and demographics, device information and identifiers, and research and feedback for purposes such as improving and tailoring services. In addition business information may be shared for business operational purposes.
- Advertisers, Advertising Networks, and Other Third Parties: We may share information about how you use the NBCUniversal Services and interact with content or ads to better tailor services, products, marketing and advertising on our Services and on third-party platforms. To enable these purposes, we may share certain demographics information, user-generated content, device information and identifiers, connection and usage data, geolocation data, public and commercial information, and social media information. These third parties may use their own tracking technologies to collect or request information about you, please see our Cookie Notice.
- Partners: We may share your information with third party partners. For instance, if you enter a contest or sweepstakes sponsored by a third party, we may share the information you provide for that entry with the sponsor. Depending on the partnership, we may share certain information including contact information (at your direction), identification and demographic information, transactional information, user-generated content that you provide, research and feedback, device information and identifiers, connection and usage information, public and commercial information, and social media information.
- Social Networks: We may share your information with social media platforms for example, if you click on a Facebook “like” button on an NBCUniversal Service, the “like” may appear on your Facebook account. To control this sharing of information, please review and adjust your privacy settings for the relevant social network. Depending on your privacy settings and actions on such network, we may share contact information, identification and demographic information, user-generated content, device information and identifiers, connection and usage data, and social media information.
- Service Providers: We engage vendors to perform business purposes on our behalf and share information with them to enable them to provide us with such business purposes, including research and analytics, hosting, transaction and payment processing, promotion administration, fraud prevention, identity management, acquisition and other services. Service providers may use such information for their operational purposes in order to provide their services to us.
- Search Engines: Depending on the NBCUniversal Service, you may be able to engage with other members of the Service or the public. This may make the name and photo associated with your profile and any comments or user-generated content you provide visible to other members of that Service or the general public. If the information is available to the general public, it may also be searchable by search engines.
- Law Enforcement, Regulators, Anti-fraud Coalitions and other groups: We share any of the categories of information we collect, as appropriate, with these third parties in order to: protect and enforce the legal rights, privacy, and safety of ourselves and our visitors; protect against possible fraud or other illegal activity; respond to requests from government and other authorities; and otherwise comply with legal process.
We may share information about you along with a hashed or masked identifier, with third parties so they may better personalize your experience with them and the offers they send you. With your appropriate consent when required, and consistent with applicable law, we may share your video viewing behavior with third parties including service providers, advertising companies, analytic partners, and social media sites.
Sale or transfer of all or part of our business or assets
- LEGAL BASES FOR USE OF YOUR INFORMATION
The laws of some jurisdictions, such as the European Union, require companies to tell you about the legal basis for using, sharing, or disclosing your information. To the extent those laws apply, we may rely on the following legal bases:
- Performance of a contract: where use of your information is necessary to provide you with NBCUniversal Services under a contract, for example the relevant Terms of Service.
- Legitimate interest: where use of your information is necessary for our or others legitimate interests and where the use is not outweighed by your rights and interests. Below are some examples of such interests:
- providing NBCUniversal Services
- improving our Services and developing new ones
- recognizing and better understanding our users, including across platforms
- conducting security and fraud prevention activities
- marketing and promoting our content and services
- building and managing business relationships
- conducting compliance and risk management activities
- providing and managing access to our systems
- Legal obligation: where use of your information is necessary to comply with laws and regulations such as those relating to anti-bribery and corruption and anti-money-laundering, complying with requests from government bodies or courts, or responding to litigation.
- With consent: we may ask for your consent to process your information in a certain way. Where we rely on this basis, you have the right to withdraw your consent at any time – please see the Your Rights and Your Choices sections below to do this.
Most of our online services are intended for users of all ages. This section outlines NBCUniversal’s information practices in the United States with respect to personal information (as defined by the Children’s Online Privacy Act (“COPPA”)) collected on online from services directed to children under the age of 13 or from children who we have actual knowledge are under the age of 13 (“child” or “children”). For more information about COPPA see FTC – Children’s Privacy.
If we knowingly collect personal information on a child-directed service or from a user we have actual knowledge is a child, we will retain that information only so long as reasonably necessary to 1) fulfill the request or allow the child to participate in the activity, 2) ensure the security of our users and our online services, and/or 3) as required by law. If we learn we have collected personal information from a child in a manner inconsistent with COPPA’s requirements, we will either delete that personal information or seek parental consent.
Collection and Use of Personal Information from Children
If an online service seeks to collect personal information from a child that is not subject to an exception under COPPA, we will first ask for a parent or guardian’s consent to that collection as required by law.
Our online services directed to children may collect the following information from children for the purposes described:
- Registration Information: Children may be able to register with an online service to view content, participate in contests, play games and more. We may ask the child to provide a screen name (that does not include the child’s name) and password. We may also request information for notification purposes, such as a parent or guardian’s email address, the child’s first name and gender, and birth date. We may ask for a child’s email address for purposes of generating a password reminder. In such cases, unless we otherwise obtain consent or notify the parent of ongoing communications (as discussed below), we will hash such email address such that it can only be used as a password reminder and cannot be used to contact the child.
- Email Address for One-Time Response: We may ask for a child’s email address or other online contact information in order to respond to a question or request from a child. We will delete this information after responding to the question or request. If an online service allows children to create accounts by providing name and email address, we will first seek parental consent as required by COPPA.
- Email Address for Newsletters or Other Ongoing Communications: Our online services may offer ongoing communications to our users, such as newsletters or show updates. In such circumstances, we may collect a child’s email address or other online contact information, along with a parent’s email address. We will notify the parent via email about the collection and use of the child’s information and provide the parent an opportunity to prevent further contact with the child.
- Content: We may allow children to submit content to us. If a child includes personal information in such content, we will take reasonable measures to delete the personal information or first seek parental consent.
- Contests and Sweepstakes Entry Information: Our online services may feature contests or sweepstakes and seek information necessary for a child to participate in such contest, including the child’s first name and parent’s email address to notify the parent (as required by law). If the child wins the contest, we may contact the parent via email to request information for prize fulfillment.
- Information to Obtain Parental Consent: We may ask a child for a parent’s or guardian’s email address or other permissible contact information in order to request consent. If we do not receive parental consent within a reasonable time, we will delete the contact information and any other related information collected from the child. We may conduct other methods of parental consent permitted by COPPA, including obtaining a credit card number and charging a fee (which may be nominal), asking a parent to speak to a customer service representative by phone or video, or requiring submission of a signed consent form.
- Persistent Identifiers: Our online services may automatically collect persistent identifiers for internal operations, including to provide and improve our online services, conduct analytics, authenticate users, personalize content, maintain the security and integrity of the service, and to ensure legal or regulatory compliance. Specifically, we may collect Internet protocol or IP address, pages and content visited, the type and version of operating system or web browser, device ID. We, or our third party service providers, may collect this information using HTTP cookies, flash cookies, HTML5 and Flash local storage, web beacons/GIFs, embedded scripts, and ETags/cache browsers (“Cookies”).
Disclosure of Personal Information from Children
We may share or disclose personal information collected from children in the following circumstances:
- With our service providers in order for them to perform service on our behalf;
- As permitted or required by law, including in response to a court order or a subpoena.
- To protect the safety of a child, to prevent a crime, or to facilitate a public safety investigation;
- To take precautions against liability; or
- To protect the security or integrity of our online services.
In addition, personal information collected from a child may be shared or publicly posted if we first obtain parental consent.
Parents or guardians may contact firstname.lastname@example.org to review personal information provided by his or her child, have such information deleted, and/or refuse to allow further collection or use of such information. You may send mail inquiries to: 30 Rockefeller Plaza, New York, NY 10112, ATTN: NBCUniversal Legal Department, Chief Privacy Officer.
- YOUR RIGHTS
Depending on where you live, you may have certain rights with respect to your information. For example, under local laws, including in the European Union, you may be able to ask us to:
- provide access to certain information we hold about you, in some cases in a portable format, if technically feasible
- update or correct your information
- delete certain information
- restrict the use of your information
We will respond within the time period prescribed by applicable law. Please note that many of the above rights are subject to exceptions and limitations.
Some NBCUniversal Services can only be provided if we have your information, therefore deletion of your information will result in termination of such Services.
We will take reasonable steps to verify your identity, including authenticating you through the email address. We may require further documentation such as a password and user ID before granting access to your information.
California residents with rights under the CCPA, or their authorized agents, may click here for access or deletion requests or may call 1-800-447-0663.
U.S. residents who wish to learn more about access or deletion requests may click here.
If you are based outside the U.S. and would like to exercise any individual right you may have please contact us at email@example.com. Please include “My Rights” in the subject line and provide a clear explanation of which right you are exercising and your country of residence in the body of the email.
Your rights and our responses will vary based on your state or country of residency. Please note that you may be located in a jurisdiction where we are not obligated, or are unable, to fulfill a request. In such a case, your request may not be fulfilled.
If you have any unresolved concerns, you may have the right to complain to your local data protection authority.
“Do Not Sell My Personal Information” (California Residents only)
California residents may opt out of the “sale” of their personal information. California law broadly defines “sale” in a way that may include allowing third parties to receive certain information such as cookies, IP address and/or browsing behavior to add to a profile about your device, browser, or you. This profile enables delivery of interest-based advertising on the NBCUniversal Services or other sites. Advertising, including interest-based advertising, enables NBCUniversal to provide you certain content for free and provide relevant offers to you.
Depending on what Services you use, we may share the following categories of information for such advertising which may be considered a sale (as defined by California law):
- identification and demographics; device information and identifiers, such as IP address, and unique advertising identifiers and cookies; connection and usage information, such as browsing history or app usage; geolocation information, such as city; and inference data.
If you would like to opt out of NBCUniversal’s use of your information for such purposes (to the extent this is considered a sale), you may do so as outlined on the following page: Do Not Sell My Personal Information.
Third Parties’ List – Shine the Light (California Residents only)
California residents can also request a list of all the third parties to which we have disclosed certain personal information (as defined by California’s Shine the Light law) during the preceding year for those third parties’ direct marketing purposes. California residents may contact us at 30 Rockefeller Plaza, New York, NY 10112, US, NBCUniversal Legal Department Attn: Chief Privacy Officer. In the body of your request, you must include: “California Shine the Light Request”, your name, a current California address including, street address, city, state, and zip code, as well as sufficient information for us to determine if the law applies to you. You will need to attest to the fact that you are a California resident. We will not accept requests by telephone, email, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.
NBCUniversal does not engage in the following activity, however Nevada law requires us to post the following: certain Nevada consumers may opt out of the sale of “covered information” for monetary consideration to a person for that person to license or sell such information. “Covered information” includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online.
If you are a Nevada resident who has purchased goods or services from NBCUniversal, you may submit a request to opt out of any potential future sales under Nevada law by emailing us at firstname.lastname@example.org. Please use “Nevada Do Not Sell” in the subject line. Note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.
Notice to Customers of Universal Studios Japan
For customers of Universal Studios Japan, NBCUniversal and Universal Studios Japan may use your personal information jointly as follows:
For questions, requests, or complaints related to the jointly-used personal information, you may contact USJ, LLC, who is responsible for the management of the jointly used personal information, at email@example.com.
For customers of Universal Studios Japan who have questions or complaints related to Universal Studios Japan’s privacy practices, you may contact Universal Studios Japan directly by emailing firstname.lastname@example.org,or calling 0570-20-0606, or writing to 2-1-33 Sakurajima, Konohana-ku, Osaka 554-0031 Japan, USJ LLC. For issues related to Club Universal please visit the Club Universal Inquiry page.
- YOUR CHOICES
Cookies and Similar Technologies
Mobile App and Connected Devices
Depending on the device you use, you may be able to manage your advertising and location preferences through your device settings and as outlined in our Cookie Notice. Many operating systems provide their own instructions on how to prevent the delivery of tailored in-application advertisements. We do not control how the applicable platform operator allows you to manage personalized in-application advertisements. You should review your device manufacturer’s support materials and/or the device settings for the respective operating systems for more detail on how to manage such preferences.
You can stop all collection of information by a mobile app by uninstalling the app.
Opt-out of Video Measurement Research by Nielsen
NBCUniversal video services may feature Nielsen proprietary measurement software that will allow you to contribute to market research, like Nielsen’s TV Ratings.
To learn more about Nielsen digital measurement products and your choices in regard to them, including in mobile apps and connected devices, please visit http://www.nielsen.com/digitalprivacy for more information.
Third-Party Online Services
- HOW WE PROTECT YOUR INFORMATION
We maintain organizational, technical, and physical safeguards to help protect the information we collect and use. These safeguards vary depending upon a variety of factors including the sensitivity of the information we collect and use. Despite all reasonable practices, no security method is infallible.
- 8. HOW LONG WE KEEP YOUR INFORMATION
We will keep your information only for as long as it is necessary to fulfill the purposes described above, unless a longer retention is required or permitted by law. We may delete or de-identify your information sooner if we receive a verifiable deletion request, subject to exemptions under applicable law. The retention period that applies to your information may vary depending on the NBCUniversal Services you use and how you interact with them. Some NBCUniversal Services may provide additional details on their data retention practices, so we encourage you to consult their website and/or FAQs.
- INTERNATIONAL TRANSFERS
- CONTACT US
The UK Representative of our US-based NBCUniversal Affiliates is NBCUniversal International Limited. To contact the UK Representative, please email email@example.com and include the text “For the UK Representative” in the subject line. Alternatively, you can write to: Privacy Legal Department, NBCUniversal International Limited, 1 Central St Giles, St Giles High Street, London WC2H 8NU, United Kingdom.
The EU Representative of our US-based NBCUniversal Affiliates is Universal Studios International B.V. To contact the EU Representative, please email firstname.lastname@example.org and include the text “For the EU Representative” in the subject line. Alternatively, you can write to: Privacy Legal Department, Moermanskkade 421, 1013 BC Amsterdam, The Netherlands.
Germany: If you are using NBCUniversal Services provided by Universal Pictures Germany GmbH or Universal Pictures International Germany GmbH, you can contact our German Data Protection Officer by emailing email@example.com and including the text “For the German DPO” in the subject line.
You can contact the Data Protection Officer for NBCUniversal Global Networks Deutschland GmbH by emailing firstname.lastname@example.org or by writing to Sky Deutschland Fernsehen GmbH & Co.KG, Datenschutz, Medienallee 26, 85774 Unterföhring erreichen, Deutschland.
We have separate policies for workforce data. For example, please see our Candidate Privacy Statement to find out more about the information we collect during our recruitment process.