1. Introduction

    We are Marjan Television Network Limited (Marjan, we, our, us). We are registered in England and Wales under company registration number 07020659, registered office at 10th Floor The Met Building, 22 Percy Street, London W1T 2BU.

    We make Persian language programmes. We also operate Manoto TV and the Marjan Television Network.

    This notice explains how and why we use personal data (also known as personal information, personally identifiable information or PII). We mainly use personal data to film, produce, promote and broadcast our programmes. We also use personal data for the purposes of our wider business.

    In addition to the above, below we also provide contact details and important information about data protection rights under the General Data Protection Regulation (GDPR).

    This notice was last updated November 2020. We will periodically make further amends so please check back for updates.


  2. What personal data do we collect?

    Manoto TV App

    We operate the Manoto TV App and streaming service (Our App). We collect personal data directly from users of Our App (App Users) via registration and App use. If App Users link their accounts to or access them via a third-party service (for example, Facebook, Google and Twitter) we may collect personal data from that service.

      The personal data we collect and generate relating to App users includes -

    • Username and account details
    • Analytics and advertising IDs
    • Third-party ID (if you link your account to or access it via a third-party service)
    • Device information (including ID, type, time zone setting and location, IP address)
    • Marketing and communications data (including preferences)
    • Episode alert settings
    • Notification alert settings
    • Downloaded videos
    • Favourite videos
    • Purchase and order history
    • Personal data in correspondence

    Website Visitors

      The information we collect from individuals that visit Our Websites (Website Visitors) includes -

    • Device information (including ID, type, browser type and version, plugins, operating system and platform, time zone setting and location, IP address)
    • Website usage
    • Personal data entered into webforms
    • Personal data in correspondence
    • Purchases and order history
    • Marketing and communications data (including preferences)
    • Cookie data (please see Cookies section below)

    Contributors and Talent

    We collect personal data directly from individuals who contribute to or star in our programmes (Contributors and Talent). We also collect personal data relating to Contributors and Talent from agents, other networks, industry resources, family, friends, professional contacts and public sources.

      The personal data we collect relating to contributors and talent includes, where necessary -

    • Name
    • Address
    • Contact details (including telephone and email)
    • Social media
    • Footage
    • Information about interests, opinions, personality, previous appearances on television, family life, job and general knowledge
    • Information relating to ethnicity, political opinions or religious belief, trade union membership, physical or mental health and sexual orientation (Special Category Personal Data)
    • Professional, financial, tax, payment and employment details
    • Passport and official ID
    • Health data, including any relevant information about disabilities
    • Criminal convictions
    • Personal data in correspondence

    People we work with

    We collect personal data directly from individuals we work with and from their employers or the organisations they represent. We also collect personal data relating to people we work with from other organisations we work with (for example, industry conferences, industry media, social media, platforms and stores).

      The personal data we collect relating to people we work with includes -

    • Name
    • Address
    • Contact details (including telephone and email)
    • Social media
    • Professional and employment details
    • Personal data in correspondence

  3. How we use personal data

    App Users

      We mainly use personal data relating to App Users to provide, develop and promote Our App and wider business. More specifically, we may use personal data relating to App Users to -

    • Improve Our App (including by providing personalised content, language, help and instructions)
    • Allow App Users to participate in certain online features
    • Account verification and clearance
    • Notifications to let App Users know about relevant programmes, episodes, news and events
    • Direct marketing to let App Users know about relevant programmes, episodes, news and events
    • Provide customer service and assistance
    • Administer surveys and opinion polls
    • Manage alpha, beta or early access tests (including collecting feedback)
    • Administer promotions for programmes, products, services, news and events
    • Better understand how Our App is used (including checking traffic patterns and what types of content are most popular)
    • Receive and respond to correspondence
    • Engage with third parties such as social networks (please check the privacy notices of any third parties)
    • Marketing
    • Detect and address hacking and other harmful activities
    • Detect and address security risks
    • Detect fraud and other unlawful activity
    • Exercise legal rights and comply with legal obligation

    Website Visitors

      We use personal data relating Website Visitors mainly to provide, develop and promote our websites, programmes, App and wider business. More specifically, we may use personal data relating to website users to -

    • Provide customer service and assistance
    • Better understand how our websites are used (including checking traffic patterns and what types of content are most popular)
    • Website analytics and improvements
    • Marketing
    • Detect and address security risks
    • Detect fraud and other unlawful activity
    • Exercise legal rights and comply with legal obligations

    Contributors and Talent

      We use personal data relating to Contributors and Talent to make, develop and promote our programmes and wider business. More specifically, we may use personal data relating to Contributors and Talent to -

    • Film, produce, broadcast and promote our programmes
    • Audition and check suitability for programmes
    • Monitor balance, inclusion and diversity
    • Produce publicity materials and advertise our programmes
    • Check right to work, visas and any other applicable permit
    • Obtain and administer insurance
    • Provide or commission medical support
    • Manage business and professional relationships
    • Exercise legal rights and comply with legal obligations

    People we work with

      We use personal data relating to people we work with mainly to film, produce and promote our programmes and administer our wider business. More specifically, we use personal data relating to people we work with to -

    • Manage services provided by our suppliers
    • Arrange meetings, calls and events
    • Manage business and professional relationships
    • Provide, develop and promote Our Websites and App
    • Exercise legal rights and comply with legal obligations

  4. Our legal grounds to use personal data

    App Users
    Contract

    Our main legal ground for the use of personal data relating to App Users is for the performance of our contract with them under the terms of use.


    Legitimate interests

    We also use personal data relating to App Users where necessary for the purposes of legitimate interests pursued by us or the organisations we work with.

    Our legitimate interests include for the filming, producing, broadcasting and promoting our programmes as well as providing, developing and promoting Our App, Our Websites and our wider business.


    Consent

    Our legal ground for sending App Users direct marketing is consent. Our legal ground for non-essential cookies is consent. Consent for direct marketing or non-essential cookies may be withdrawn at any time.


    Website Visitors
    Legitimate interests

    We use personal data relating to Website Visitors where necessary for the purposes of legitimate interests pursued by us or the organisations we work with. Our legitimate interests include providing, developing and promoting Our App, Our Websites and our wider business.


    Consent

    Our legal ground for sending Website Visitors direct marketing is consent. Our legal ground for non-essential Cookies is consent.

    Consent for direct marketing or non-essential Cookies may be withdrawn at any time.


    Contributors and Talent
    Contract

    Where we have a contract in place with Contributors or Talent, our legal ground for the use of personal data is mainly the performance of the contract.


    Legitimate interests

    We also use personal data relating to Contributors or Talent where necessary for the purposes of legitimate interests pursued by us or the organisations we work with.

    Our legitimate interests include filming, producing, broadcasting and promoting our programmes. Our legitimate interests also include the provision, development and promotion of Our App, Our Website and our wider business.


    Special Category Personal Data

      We will only use Special Category Personal Data relating to Contributors and Talent where -

    • Necessary for our rights and obligations as an employer, including health and safety
    • The individual concerned has deliberately made the information public, including by voluntarily appearing in one of our programmes
    • Necessary for legal claims
    • We have explicit consent
    • The Special Purposes apply (please see below)

    People we work with
    Contract

    Where we have a contract in place with an individual we work with, our legal ground for the use of personal data relating to that individual is mainly the performance of the contract.


    Legitimate interests

    Where we do not have a contract directly with an individual or we need to use personal data outside the performance of a contract, we use personal data where necessary for the purposes of legitimate interests pursued by us or the organisations we work with.

    Our legitimate interests include filming, producing, promotion and broadcasting our programmes. Our legitimate interests also include the provision, development and promotion of Our App, Our Website and our wider business.


  5. Automated decision-making

    We do not make any legally significant decisions about individuals based solely on automated decision-making.


  6. Sharing personal data

    App Users

      We share personal data relating to players with other players, our staff and the following types of service providers -

    • Payment processors
    • Marketing and advertising partners
    • Analytics service providers
    • IT providers and developers
    • Group companies
    • Business partners
    • Professional service providers (for example, accountants and lawyers)

    Website users

      We share personal data relating to website users with our staff and the following types of service providers -

    • Payment processors
    • Marketing and advertising partners
    • Analytics service providers
    • IT providers and developers
    • Group companies
    • Business partners
    • Professional service providers (for example, accountants and lawyers)

    Contributors and Talent

    Importantly, Contributors and Talent should be aware that where personal data relating to them is contained in one of our programmes, that personal data will be broadcast publicly and worldwide.

      We also share personal data with our staff and the following types of service providers -

    • Online stores and platforms
    • Agents
    • Production crew
    • Networks, production houses, studios and other industry organisations
    • Payment processors
    • IT providers
    • Marketing partners
    • Group companies
    • Business partners
    • Professional service providers (for example, accountants and lawyers)

    People we work with

      We share personal data with our staff and the following types of service providers -

    • Online stores
    • Payment processors
    • IT providers
    • Marketing partners
    • Group companies
    • Sister studios
    • Business partners
    • Professional service providers (for example, accountants and lawyers)

    Reorganisation and legal

    We may share any personal data we hold with potential buyers, group companies and/or business partners where necessary and appropriate for a reorganization, restructuring, merger, sale or transfer of assets involving Marjan or our programmes.

    We will share personal data where necessary to establish, exercise or defend our legal rights. We will also share personal data where required by the courts, regulators or law.


  7. Cookies and similar technologies

    Cookies and similar technologies (Cookies) allow us to track users on Our App and Our Websites.

    The types of Cookies we use are described below -


    Essential cookies

    Our App and Our Websites will not work properly without essential Cookies. For example, we and our service providers may use essential Cookies to identify and authenticate App Users. We also use essential Cookies to enforce our terms of use and maintain security.

    We use essential Cookies provided by Adobe and Cloudflare.


    Non-essential performance or analytics cookies

    Non-essential performance or analytics Cookies collect information and analytics about how people use our website. For example, we track which pages users visit most often and error messages received by users from web pages.

    We use non-essential Cookies provided Adobe Analytics and Google Analytics.


    Advertising cookies

    Advertising Cookies are used to deliver advertisements relevant and measure the effectiveness of advertising campaigns. These Cookies are usually placed by advertising networks with our permission. They remember that you have visited the website and this information is shared with other organisations such as advertisers.

    We use advertising Cookies provided Adobe and Google DoubleClick.

    We always seek consent for advertising Cookies on Our App and Website.


  8. Children

    We do not knowingly collect or use any personal data relating to App Users or Website Visitors under the age of 13.

    Where we collect personal data relating to Contributors and Talent under the age of 13, we will follow an enhanced data protection process.


  9. International transfers

    We routinely transfer personal data outside the UK. Where we transfer personal data outside the UK to a country that has not been recognised as providing an adequate level of data protection we use the standard contractual clauses unless we have identified another appropriate safeguard, a relevant exemption or the Special Purposes exemption applies (please see below).


  10. Data retention

    We keep personal data for as long as necessary for our business purposes and for a further seven years where necessary to protect our legal interests.

    App users can delete their accounts at any time.


  11. Rights

      Everyone has the right to –

    • Information about how we use personal data (which is what this notice is for)
    • Access to personal data
    • Object to the use of personal data (including the sale of personal data to other companies)
    • Erasure of personal data
    • Portability of personal data
    • Withdraw consent where our use of personal data is based on consent
    • Rectification of personal data
    • Restriction of personal data
    • Complain to a supervisory authority

    Please be aware that these rights are not absolute and there may be some situations in which they cannot be exercised or are not relevant. The Information Commissioner’s Office provides more information about data protection rights -  www.ico.org.uk.

    You will not be treated differently or discriminated against for exercising any of your rights.


  12. If you do not provide personal data

    Where we need personal data for an agreement with you or we need consent to use personal data and you do not provide the required personal data or consent, we may not be able to perform out agreement or provide you with relevant services. In some cases, we may have to cancel your access to our services.


  13. Special purposes

    The GDPR and the Data Protection Act 2018 (the Act) require us to use your personal data within the legal framework set out in this privacy notice and in accordance with the above rights.

    However, the GDPR and the Act contain an exemption which allows us (and other organisations we work with) not to apply aspects of the legal framework and rights if they are incompatible with the academic, artistic, journalistic or literary purposes of our programmes. This exemption is known as the Special Purposes exemption.

    Consequently, please be aware that aspects of the legal framework explained in this notice and rights under the GDPR may not apply where they are not compatible with the Special Purposes.


  14. Our contact

    If you would like to contact us regarding any data protection issue, please email -

    [email protected]
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