A. This Notice

This Notice is issued by Palestinian Broadcast Corporation (PBC) on behalf of itself, its subsidiaries and its affiliates (together, “PBC”, “we”, “us” and “our”) and is addressed to individuals outside our organisation with whom we interact, including customers, visitors to our Sites, users of our Apps, and other users of our services (together, “you”). Defined terms used in this Notice are explained in Section (S) below.

For the purposes of this Notice, PBC is the Controller. Contact details are provided in Section (R) below.

This Notice may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Notice carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Notice.

B. Collection of Personal Data

Collection of Personal Data:We may collect Personal Data about you from the following sources:

Data you provide:We may obtain your Personal Data when you provide it to us (e.g., where you contact usviae mail or telephone, or by any other means).
Relationship data:We may collect or obtain your Personal Data in the ordinary course of our relationship with you.
Data you make public:We may collect or obtain your Personal Data that you manifestly choose to make public, includingvia social media
App data:We may collect or obtain your Personal Data when you download or use any of our Apps.
Site data:We may collect or obtain your Personal Data when you visit any of our Sites or use any features or resources available on or through a Site.
Registration details:We may collect or obtain your Personal Data when you use, or register to use, any of our Sites, Apps, or services.
Content and advertising information:If you choose to interact with any third party content or advertising on a Site or in an App, we may receive Personal Data about you from the relevant third party.

C. Creation of Personal Data

We may also create Personal Data about you, such as records of your interactions with us where applicable.

D. Categories of Personal Data we may Process

We may Process the following categories of Personal Data about you:

Personal details:given name(s)، preferred name,and photograph.
Demographic information:gender; date of birth, age; nationality; title; and language preferences.
Contact details:correspondence address; telephone number; email address; and details of your public social media profile(s).
Consent records:records of any consents you may have given, together with the date and time, means of consent and any related information.
Data relating to our Sites and Apps:device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Site; App usage statistics; App settings; dates and times of connecting to an App; location data, and other technical communications; username; password; security login details; usage data; aggregate statistical information.
Content and advertising data:records of your interactions with our online advertising and content, records of advertising and content displayed on pages or App screens displayed to you, and any interaction you may have had with such content or advertising.
Views and opinions:any views and opinions that you express and/or choose to send to us, or publicly post about us on social media platforms.

E. Lawful basis for Processing Personal Data

In Processing your Personal Data in connection with the purposes set out in this Notice, we may rely on one or more of the following legal bases, depending on the circumstances:

Consent:We may Process your Personal Data where we have obtained your prior, express consent to the Processing, related only to Processing that is entirely voluntary.
Contractual necessity:We may Process your Personal Data where the Processing is necessary in connection with any contract that you may enter into with us.
Compliance with applicable law:We may Process your Personal Data where the Processing is required by applicable law.
Vital interests:We may Process your Personal Data where the Processing is necessary to protect the vital interests of any individual.
Legitimate interests:We may Process your Personal Data where we have a legitimate interest in carrying out the Processing for the purpose of managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms.

F. Sensitive Personal Data

We do not seek to collect or otherwise Process your Sensitive Personal Data in the ordinary course of our business. Where it becomes necessary to process your Sensitive Personal Data for any reason, we rely on one of the following legal bases:

Compliance with applicable law:We may Process your Sensitive Personal Data where the Processing is required or permitted by applicable law.
Detection and prevention of crime:We may Process your Sensitive Personal Data where the Processing is necessary for the detection or prevention of crime (including the prevention of fraud).
Establishment, exercise or defence of legal rights:We may Process your Sensitive Personal Data where the Processing is necessary for the establishment, exercise or defence of legal rights; or

G. Purposes for which we may Process your Personal Data

The purposes for which we may Process Personal Data, subject to applicable law, include:

Provision of services to you:providing our Sites, Apps, or services to you; providing you with services that you have requested; providing you with promotional items at your request; and communicating with you in relation to those services.
Journalistic purposes:Creation, selection and rendering of content and media in audio, video, print, online, broadcast and other formats, in connection with news, current affairs, education and entertainment purposes; news gathering purposes; and editorial purposes.
Our Sites and Apps:operating and managing our Sites and our Apps; providing content to you; displaying advertising and other information to you; communicating and interacting with you via our Sites and our Apps; and notifying you of changes to any of our Sites, our Apps, or our services.
Communications:communicating with you via your contact details, sending news items and other information in which you may be interested, subject to ensuring that such communications are provided to you in compliance with applicable law.
Health and safety:health and safety assessments and record keeping; and compliance with related legal obligations.
Surveys:engaging with you for the purposes of obtaining your views on our services or other matters, on the products and services of third parties, and on other topics including news and current affairs.
Investigations:detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law.
Legal proceedings:establishing, exercising and defending legal rights.
Legal compliance:compliance with our legal and regulatory obligations under applicable law.
Improving our Sites, Apps, services:identifying issues with our Sites, our Apps, or our services; planning improvements to our Sites, our Apps, or our services; and creating new Sites, Apps, or services.

H. Disclosure of Personal Data to third parties

We may disclose your Personal Data to other entities within the PBC group, for legitimate business purposes (including operating our Sites and our Apps, and providing services to you), in accordance with applicable law. In addition, we may disclose your Personal Data to:

legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation.
Any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights.
Any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security.

I. Data security

We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.

Because the internet is an open system, the transmission of informationviathe internet is not completely secure. Although we will implement all reasonable measures to protect your personal data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.

J. Data accuracy

We take every reasonable step to ensure that:

your Personal Data that we Process are accurate and, where necessary, kept up to date.
Any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay.

From time to time we may ask you to confirm the accuracy of your Personal Data.

K. Data minimization

We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Notice.

L. Data retention

We take every reasonable step to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Notice. The criteria for determining the duration for which we will retain your Personal Data are as follows:

we will retain copies of your Personal Data in a form that permits identification only for as long as: we maintain an ongoing relationship with you,or your Personal Data are necessary in connection with the lawful purposes set out in this Notice, for which we have a valid and continuing legal basis.
Any applicable limitation period under applicable law.
An additional two-month period following the end of such applicable limitation.
If any relevant legal claims are brought, we may continue to Process your Personal Data for such additional periods as are necessary in connection with that claim.

During the periods noted above, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.

Once the periods above, each to the extent applicable, have concluded, we will either:

permanently delete or destroy the relevant Personal Data; or
anonymize the relevant Personal Data.

M. Your legal rights

Subject to applicable law, you may have a number of rights regarding the Processing of your Relevant Personal Data, including:

the right not to provide your Personal Data to us (however, please note that we may be unable to provide you with the full benefit of our Sites, our Apps, or our services, if you do not provide us with your Personal Data);
the right to request access to, or copies of, your Relevant Personal Data, together with information regarding the nature, Processing and disclosure of those Relevant Personal Data.
the right to request rectification of any inaccuracies in your Relevant Personal Data.
the right to request, on legitimate grounds:
- erasure of your Relevant Personal Data.
- restriction of Processing of your Relevant Personal Data.
the right to object, on legitimate grounds, to the Processing of your Relevant Personal Data by us or on our behalf.

This does not affect your statutory rights.

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Notice, or about our Processing of your Personal Data, please use the contact details provided in Section (R) below. Please note that:

we may require proof of your identity before we can give effect to these rights; and
where your request requires the establishment of additional, we will investigate your request reasonably promptly, before deciding what action to take.

N. Cookies and similar technologies

When you visit a Site or use an App we may place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We may Process your Personal Data through Cookies and similar technologies, in accordance with our Cookie Policy.

O. Direct marketing

We may Process your Personal Data to contact youviaemail, telephone, direct mail or other communication formats to provide you with information regarding services that may be of interest to you. If we provide services to you, we may send information to you regarding our services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law.

You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional email we send. After you unsubscribe, we will not send you further promotional emails, but we may continue to contact you to the extent necessary for the purposes of any services you have requested.

P. Contact details

If you have any comments, questions or concerns about any of the information in this Notice, or any other issues relating to the Processing of Personal Data carried out by us, or on our behalf, please contact:

Legal Department

PBC

28, Omar Al mukhtar ST.

Ramallah – Palestine

Q. Definitions

“App” means any application made available by us (including where we make such applications availablevia third party stores or marketplaces, or by any other means).
“Cookie” means a small file that is placed on your device when you visit a website (including our Sites). In this Notice, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs.
“Data Protection Authority” means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.
“Personal Data” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
“Process”, “Processing” or “Processed” means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“Processor” means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).
“Relevant Personal Data” means Personal Data in respect of which we are the Controller. It expressly does not include Personal Data of which we are not the Controller.
“Sensitive Personal Data” means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that may be deemed to be sensitive under applicable law.
“Site” means any website operated, or maintained, by us or on our behalf.

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