Privacy Policy

DiO is committed to protecting the privacy of our PressPlay Audience Members. Please take the time to review this notice which explains what personal data (also known as "personal information") we collect about you, how and why we use it, and your rights in relation to it. Dragonfly Media Limited (“DiO”, “we”, or “us”) is the data controller of the personal data collected via or in connection with the PressPlay platform (“PressPlay”). This means that we are responsible for processing your personal data in accordance with applicable data protection laws.

What personal data do we collect about you and why?

We collect personal data from you when you provide it to us directly and through your use of PressPlay. If you wish to obtain full access to the PressPlay platform, and have the chance to view [the wealth of content available on it], you will be required to provide us with the personal data set out below.

The table below sets out the different categories of your personal data which we will process, our purposes for processing that personal data and some examples of the personal data collected.

Please note that the examples given are not exhaustive, as the personal data we collect from you directly may change over time (e.g. we may add additional questions to our surveys).

Category of data	Purpose	Examples of personal data
Account profile information	When you register for a PressPlay account we will collect basic information to enable you to access your account securely and to provide our services to you.	Name, email address, username, password, and multi-factor authentication details.
Responses to surveys	Before we show you any content, we need to build a profile for you so that we can work out which content to show you, and so we can better understand your feedback on, and reaction to, that content. We will therefore collect some detailed information about you and your interests, habits and preferences through online surveys. Separately, we will also ask you for feedback on the specific content you have watched (both during and after your viewing of it).	Name, date of birth, gender identification, regional location, postal address, sexual orientation, ethnic group, living arrangements, education history, relationship status, disability status, information on children or dependents, employment status, employment role, information about the industry in which you work, household income, entertainment viewing habits and preferences, information on available media and computing equipment, personal characteristics and attitudes, personal goals and views on self, hobbies and interests, information on social media use, information on shopping habits and preferences, and any other information or feedback you provide to us in relation to the content you watch.
Identity information (including facial recognition data)	We collect and verify your ID to ensure that only authorised PressPlay Audience Members have access to the content allocated to them, and to ensure that DiO can maintain the security and confidentiality of the content made available to you. We do this to protect the TV and film-makers’ interests.	When you sign up with PressPlay we will ask you for certain ID documents (e.g. passport, driving licence or other recognised forms of ID). We will use a third party ID verification partner who will use facial recognition technology to verify that your image (collected through your camera) matches your ID documents. Before you can watch any content, we will use facial recognition technology to compare the image of you on your device's camera with the ID documents we hold for you. This verification will also be carried out using a third party verification partner.
Content reaction	As you’re watching the film and video content we make available to you, we will use the camera on your device, or the wearable tech you have been sent, to analyse your emotions and reactions. We do this so that we can obtain insights into how audiences are reacting to the content they view.	From device cameras: photographs, video images, facial recognition scans. From wearable tech: Heart rate, breathing rate and electrodermal activity (i.e. the electrical characteristics of your skin). The data we collect will be translated into Emotional and Physiological Response Scores
General Geo-location data	We may use geolocation data to verify that you are watching content from the postal area, country or region which you provided to us on sign-up. This is to ensure the security and confidentiality of the content made available to you.	Location data
Viewing history and rewards points	By viewing content and providing feedback on it you will have the opportunity to accrue reward points. We track your viewing history and reward points to determine what rewards they can be converted to. We use a third party service provider to manage the rewards points.	Viewing history, rewards points.
Device information	We collect your device information to ensure you receive the best user experience on our website [and app], to improve and develop our services, and to tailor and personalise content to you.	Information about the device you use to access PressPlay, which may include your IP address and the make and model of your device.
Marketing Partners	From time to time PressPlay will work with marketing partners to help generate awareness of the platform and recruit new audience panel members.	Data provided from marketing partners may include name, address, email and telephone information, as well as information on the marketing activity you engaged with.

Our lawful basis for processing the personal data described above is that we have your consent to do so. You are free to withdraw that consent at any time, in which case we will cease processing your personal data. However, in the event that you do withdraw your consent please note that: (i) we will not be able to make further content available to you to watch through PressPlay; and (ii) we will continue to process, in anonymised form, the data associated with your reactions to the content you previously watched.

Further purposes

In addition to the specific purposes identified above, we may also process the above personal data for the following general purposes:

• Product improvement. To improve and develop PressPlay, to ensure the best user experience.
• Maintenance & analysis. To maintain PressPlay, and monitor its usage.
• To respond to you. If you contact us with a specific query we will process your personal data when handling your request.
• Security & fraud prevention. For security purposes, to investigate fraud and where necessary to protect ourselves and third parties.
• Legal reasons. To comply with our legal and regulatory obligations, and protect ourselves in the event of a legal complaint or claim.

Our lawful bases for the above general purposes may be as follows:

• Because it is in our legitimate interests to maintain and promote DiO, to improve our services and to ensure the security of our users.
• Because we are under a legal obligation to process your personal data (e.g. if we receive a court order for disclosure of your personal data).

 

 

Special Category / Sensitive Personal Data

Some of the personal data described above constitutes "special categories" of personal data or "sensitive" personal data, which are subject to additional protection under applicable data protection law. In particular:

• The survey questions will ask you to provide personal data which reveals your racial or ethnic origin, religious or philosophical beliefs, and your sexual orientation as well as data which concerns your health (e.g. concerning disabilities).
• We will process biometric data when we (and our third party ID verification partners) use facial recognition technology and/or voiceprint technology to verify your identity at sign-up and when you watch content.
• We may also collect information which relates to your health when we monitor your reactions to content (e.g. heart rate and electrodermal activity).

We process the above special/sensitive categories of personal data on the basis that we have your explicit consent to do so, which we obtain by asking you to confirm you agree to this processing at the sign-up stage. As stated above, you can withdraw your consent at any time.

Who do we share this personal data with?

We share your personal data with third parties in the following circumstances:

• With our suppliers and service providers working for us, e.g. IT and data storage providers, rewards points providers and ID verification partners.
• Professional advisors. With our professional and legal advisors.
• Law enforcement. When in good faith we believe that disclosure is necessary or required by law, with law enforcement or other governmental authorities, e.g. to report a fraud or in response to a lawful request.
• Business sale. In the event that we sell all or a portion of our business assets, the personal data of our users may be disclosed to a potential buyer, either in the course of diligence or after such transaction. In this event, we will make reasonable attempts to ensure the buyer will be bound by the terms of this Privacy Notice.
• Otherwise where we have your consent or are otherwise legally permitted to do so.

Please note that we use your content reaction data to create "insights" for our customers and clients (e.g. film and TV studios). However, the insight data which is shared with them is in an anonymised and aggregated form, which means you cannot be identified from it.

International transfers

We use service providers based around the world. Consequently, your personal data may be processed in countries outside of the UK, including in countries where you may have fewer legal rights in respect of your data than you do under local law. If we transfer personal data outside the UK we will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate safeguards, in particular through the use of standard contractual clauses. You can contact us if you would like more information about these safeguards.

Storage and Deletion

We will keep your personal data for as long as we need it for the purposes set out above, and so this period will vary depending on your interactions with us. In general, we will retain all the personal data you provide to us for as long as you have an active Audience Member account. You can delete your account at any time by emailing us at support@wearedio.com. If you delete your account, we will also delete it from our servers as soon as reasonably practicable. Please note, however, that if you delete your account we may retain some information we need to keep for legal or reporting reasons.

Your reaction data in relation to specific content will be deleted once it has been analysed and we have obtained the anonymised insight data from it. This will typically be two years after you have watched the content.

Children

You must be at least 16 years old to use PressPlay. We do not knowingly collect personal data from children under 16.

How we secure information

We take appropriate technical and organizational measures to protect your personal data from and against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, and access. However, please note that no internat transmission can be guaranteed to be secure

Your rights

Depending on your jurisdiction of residence, you have certain rights in respect of your personal data, including the right to access (including in a commonly used, machine readable format), rectify, and request the erasure or restriction of your personal data. In some cases, you should be able to exercise these rights by  editing your profile or deleting your account.  

We will comply with any requests to exercise your rights in accordance with applicable law. Please be aware, however, that there are a number of limitations to these rights, and there may be circumstances where we are not able to comply with your request. To make any requests regarding your personal data, or if you have any questions or concerns regarding your personal data, you should contact us using the details below. You are also entitled to contact the UK Information Commissioner’s Office or other applicable regulator if you have concerns about our handling of your rights requests.

Please note that we  need to take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address. You may also be permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent's request. 

Depending on applicable law, you may have the right to appeal our decision to deny your request. If we deny your request, we will provide you with information on how to appeal the decision, if applicable, in our communications with you.

Additional Privacy Information for Texas and Nebraska Residents

If you are a Texas resident or a Nebraska resident, the Texas Data Privacy and Security Act (“TDPSA”) and Nebraska Data Privacy Act (“NDPA”), respectively, require us to provide you with the additional information about your rights.  You have the following rights under the TDPSA and the NDPA: (1) you have access rights, including the right to confirm whether we process your personal data, and the right to access your personal data, (2) you have correction rights, include the right to correct any inaccuracies in your personal data, considering the personal data’s nature and the processing purposes identified herein for which we use such data, (3) you have deletion rights, including the right to seek the deletion of your personal data from our collections, except to the extent such data is otherwise permitted to be retained by law, (4) you have data portability rights, including the right to receive your data, when requested, in a portable format that is readily usable for transmission without hinderance, to the extent technically feasible; (5) you have sales opt-out rights, including the right to opt out of personal data sales, which as of this time, we are not engaged in, (6) you have targeted advertising opt-out rights, including the right to opt out of personal data processing for targeted advertising purposes by making such a request in accordance with this policy, noting that as of this time, we are not engaged in targeted advertising, (7) you have automated decision-making rights, including the right to opt out of any profiling activity that furthers a decision producing legal or similarly significant effects for you, including automated decisions, and (8) you have non-discrimination rights, including the right to be free from our processing of personal data in violation of state and federal laws against unlawful discrimination.

To exercise these rights, please contact us by emailing support@wearedio.com or in writing to suite 1, 42 Jamaica Street, Liverpool, L1 0AF.  We will respond to your requests without undue delay and within 45 days.  We may extend the response period by up to 45 more days if reasonably necessary considering the complexity and number of your requests, but if we do so, we will promptly inform you about any extension and its reason within the initial 45 day period.  If, for any reason, we cannot comply with your request, we will provide the information required by the TDPSA and the NDPA with instructions on how to appeal the decision. 

Note that we only process your personal data because we have your consent as separately provided, and that such consent extends to the collection of “sensitive” data as defined in the TDPSA and the NDPA, including data about racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexuality, citizenship or immigration status, and genetic or biometric data processed to uniquely identify an individual.  We do not collect personal data from any child, as defined in the TPDSA and the NDPA, or on any precise geolocation data.  You may withdraw this consent at any time by so informing us using the methods contained in this policy. 

Additional Privacy Information for California Residents

If you are a California resident, the California Consumer Privacy Act (“CCPA”) requires us to provide you with the following additional information about: (1) the purpose for which we use each category of “personal information” (as defined in the CCPA) we collect; and (2) the categories of third parties to which we (a) disclose such personal information for a business purpose, (b) “share” personal information for “cross-context behavioral advertising,” and/or (c) “sell” such personal information. Under the CCPA, “sharing” is defined as the targeting of advertising to a consumer based on that consumer’s personal information obtained from the consumer’s activity across websites, and “selling” is defined as the disclosure of personal information to third parties in exchange for monetary or other valuable consideration.  We do not currently sell or share your personal information under California law.

The following chart details these activities:

Category of personal information	Purposes of use	Categories of Third Parties to Which We Discloses this Personal Information
Identifiers  (e.g., name, email address, IP address, phone number, driver’s license number)	Verify your identity Ensure security and confidentiality of the services Provide the platform Improve and develop the platform Maintenance and analysis Respond to your requests Security & fraud prevention Legal reasons	Suppliers Professional advisors Law enforcement Business Sale With your consent
Internet or other electronic network activity information (e.g., browsing and viewing history, information regarding your interactions with the platform, device information, etc.)	Determine your rewards Provide the platform Personalize the platform Improve and develop the platform Maintenance and analysis Respond to your requests Security & fraud prevention Legal reasons	Suppliers Professional advisors Law enforcement Business Sale With your consent
Geolocation data (general, not precise)	Improve and develop the platform Maintenance and analysis Respond to your requests Security & fraud prevention Legal reasons	Suppliers Professional advisors Law enforcement Business Sale With your consent
Audio, electronic, visual, thermal, olfactory, or similar information (e.g., photos, audio, and content reactions)	Analyze your feedback Improve and develop the platform Maintenance and analysis Respond to your requests Security & fraud prevention Legal reasons	Suppliers Professional advisors Law enforcement Business Sale With your consent
Professional or employment-related information (e.g., employment status)	Personalize the platform Analyze your feedback Improve and develop the platform Maintenance and analysis Respond to your requests Security & fraud prevention Legal reasons	Suppliers Professional advisors Law enforcement Business Sale With your consent
Education information (e.g., education history)	Personalize the services Analyze your feedback Improve and develop the platform Maintenance and analysis Respond to your requests Security & fraud prevention Legal reasons	Suppliers Professional advisors Law enforcement Business Sale With your consent
Sensitive personal information (e.g., race, ethnic origin, religious or philosophical beliefs, health, biometric information)	Analyze your feedback Improve and develop the platform Maintenance and analysis Respond to your requests Security & fraud prevention Legal reasons	Suppliers Professional advisor Law enforcement Business Sale With your consent

 

For more information about each category of personal information, purpose of use, and third parties to which we disclose personal information, please see the "What personal data we collect about you and why" and "To whom do we disclose personal data" sections of our Privacy Notice.

Other CCPA Rights.  If we ever offer any financial incentives in exchange for your personal information, we will provide you with appropriate information about such incentives.

The CCPA also allows you to limit the use or disclosure of your “sensitive personal information” (as defined in the CCPA) if your sensitive personal information is used for certain purposes.  Please note that we do not use or disclose sensitive personal information other than for business purposes for which you cannot opt out under the CCPA.

Please see the “Your Rights” section above for information about the additional rights you have with respect to your personal information under California law and how to exercise them.

Links to other sites 

The PressPlay platform may contain links to third-party websites and services. However, we are not responsible for the privacy practices employed by those websites or services, nor are we responsible for the information or content they contain.  Please see their terms and privacy policies for more information.

Changes to this Privacy Notice 

We reserve the right to change this Privacy Notice at any time. When required by applicable law, we will notify you of material changes to this Privacy Notice via a notice on the PressPlay Platform or by sending you an email to the address you have registered with us. 

Contact Us

If you have any queries on any aspect of our Privacy Notice, please contact our Data Protection Officer at  DPO@wearedio.com. Please include ‘Privacy Notice’ and your username in the subject line. Our registered address is Dragonfly Media Limited, Suite 1, 42 Jamaica Street, Liverpool, L1 0AF.

Last updated March 16th 2025