- I. PURPOSE OF THIS POLICY
- II. WHO ARE WE, AND WHAT DO WE DO?
- III. HOW TO CONTACT US?
- IV. WHAT PERSONAL INFORMATION DO WE COLLECT AND HOW DO WE USE IT?
- 4.1. Processing orders for products and services.
- 4.2. Verify the age of persons using our products and services
- 4.3. Online Account
- 4.4. Customer Services
- 4.5. Competitions, prize draws and other events and promotions
- 4.6. Your feedback about our products and services.
- 4.7. Customer insight and analysis.
- 4.8. Marketing communications
- 4.9. Business administration and legal compliance.
- 4.10. Health and Safety
- 4.11. Other purposes
- V. HOW DO WE OBTAIN YOUR CONSENT?
- VII. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
- VIII. TRANSFERS OF YOUR PERSONAL INFORMATION OVERSEAS
- IX. THIRD PARTY LINKS AND SERVICES
- X. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?
- XI. CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION
- XII. HOW TO ACCESS YOUR INFORMATION AND YOUR OTHER RIGHTS
CINEMA CITY ROMANIA SRL
We respect the privacy of every person who visits or registers with https://www.cinemacity.ro/ or uses the Cinema City mobile applications for iOS and Android (the “Sites”) and who uses the services that we make available from the Site, in our cinemas and through our customer services facilities (our “Services”) and we are committed to ensuring a safe online experience.
I. PURPOSE OF THIS POLICY
II. WHO ARE WE, AND WHAT DO WE DO?
Cinema City Romania operates the Sites and our Services – Cinema City România S.R.L.,(“we”, “us” or “our”).
We are the data controller responsible for your personal information obtained in connection with the provision of our Sites and Services.
Cinema City România S.R.L. is a company with its registered office in Bucharest, Doctor Boicescu Street no. 10A, office no. 1, second floor, district 5, registered in the Romanian Trade Registry kept by the Court of Bucharest under number: J40/16742/2006 and fiscal code RO19123195
III. HOW TO CONTACT US?
• sending an e-mail to: [email protected] or
• post at: Cinema City Romania S.R.L., 10A Alexandru Boicescu Street, Sector 5, Bucharest, postal code 050484, to the attention of the Marketing Director.
Please note that the e-mail: [email protected] is dedicated only to your data inquiries. It is not devoted to any other questions (in particular – your complaints about the experience in the cinema).
Please be informed that when you have an e-mail account, all correspondence related to personal data protection will be handled electronically (via e-mail). This allows us to communicate with you in a documented and fast way.
IV. WHAT PERSONAL INFORMATION DO WE COLLECT AND HOW DO WE USE IT?
We obtain your personal information from the following sources:
• Directly from you, either in person (at our cinemas or otherwise), via our Sites, on our social media pages or when you contact us, or someone contacts us on your behalf;
• Automated technologies, such as cookies, server logs and other similar technologies;
• Use of CCTV or other recording systems in and around our cinemas and cinema car parks - in relevant locations,
• From our group companies and third-party service providers in providing their services to us in connection with your use of our Sites and Services; Please see section VII. - Who do we share your personal information with? - to find out more about these group companies and third-party service providers;
• Providers of social media platforms (such as Facebook, Youtube, and Instagram) where you share our content through social media, by liking us on Facebook, following;
• Otherwise, as explained below in this section IV. What Personal Information do we collect, and how do we use it?
If you contact us via social media platforms or instant messengers (such as Facebook, Instagram or Messenger), do not give us any personal information about you or other persons in your messages. If your inquiry is supposed to contain personal data, send it to us via officially provided contact details or using a contact form available online.
Please remember that the data you provide should be of minimum scope, i.e. only those necessary for us to contact you for identification purposes.
If we use night vision cameras in some locations (cinema rooms), we do so to counteract attempts of unlawful recording of films displayed in our cinemas. When using night vision cameras, we do not process your personal data. The night vision device only detects the light emitted by a potential video recorder. We record the material only to preserve the evidence and only in the event of suspicion of illegal recording.
Our primary goal in collecting personal information about you is to: (i) verify your identity and age; (ii) provide our Services to you and carry out requests made by you on the Sites or in our cinemas; (iii) help us improve our products and services and develop and market new products and services; (iv) investigate or settle inquiries or disputes; (v) comply with any applicable law, court order, other judicial processes, or the requirements of a regulator; (vi) enforce our agreements with you; (vii) protect the rights, property or safety of us or third parties, including our other customers and users of the Sites and at our cinemas; (viii) provide support for the provision of our Services; and (ix) use as otherwise required or permitted by law. In particular, we use your personal information for the following purposes:
4.1. Processing orders for products and services.We collect and maintain personal information that is voluntarily submitted to us during the use of the Sites and/or our Services. We use the contact and payment details provided to fulfil the supply of products and services ordered from our Sites or in our cinemas. We will use contact information to send you service-related communications relating to these orders. This includes your purchase of products and services, registration for an account with us, your attendance at events hosted by our third-party partners or us, use of our app, , hire of our cinemas for your events and the processing of returns and refunds.
For example:other online purchases.
If you wish to purchase through our Sites, we will need to know your name and email address, and we may ask you for your mobile phone number. We may also need this information when you make other purchases via our Sites. Please note that the payment card details you always provide to a chosen payment service provider (e.g., PayU). You may provide your mobile phone number to make it easier for us to contact you in case of emergencies (for example, cancellation of the show, lost items) or any other contact related to another service you use.
If you request one of our discounted tickets, such as a student ticket or senior ticket, we may ask for proof of age or another appropriate form of ID, and we may process the number of the ID card you give to us. Where you have shown us your ID in connection with your request for a discounted ticket, we use this to validate your request and ensure that you meet the criteria for the relevant ticket. Where we scan and process your ID card number we do this to ensure that the same card is not used multiple times for purchasing tickets for overlapping time-slots. No other data from your ID is stored or otherwise processed in connection with this verification. Therefore we cannot use the ID card number to identify you or any other natural person. Your ID number will be deleted from our systems according to our usual business processes (usually within one month).
If you want to make a purchase in the „Gifts” section on our Sites, we need your first name, last name, and payment card details (yet please note that payment card details you always provide to a chosen payment service provider (e.g. payU)), your e-mail address. If a gift is to be sent directly to the recipient of the gift, it is necessary to provide us with the recipient's first and last name and e-mail address.
We always mark which data we need to know (as required) and which data is not required to provide, yet adequate to fulfil our goals. We use this information to process and fulfil your orders, send you service-related emails for your purchase, and text messages to complete the purchase upon request. The data we collect might also be used to send you service communication after you visit the cinema.
You may pay for products and services on our Sites using a credit/debit card (Visa, Visa Electron, Mastercard/Eurocard, Maestro, including virtual Visa or MasterCard), or voucher.
You can also ask for your payment card details to be securely stored by our payment services providers, who process payments and keep all credit and debit card details on our behalf to help speed up the process for you.
What is our legal basis?
It is necessary for us to use your personal information to perform our obligations and exercise our rights following any contract that we may have with you, such as your contract with us for your ticket or purchase of a gift. We also have a legitimate interest in personal processing data, which is receiving the data of the gift recipient to deliver a purchased gift to such recipient.
It is in our legitimate interest to use your ID card number to ensure that we issue customers with the correct tickets and protect our business from fraud and other illegal activities.
4.2. Verify the age of persons using our products and services
We welcome children and young people to our cinemas. However, some of our Services and features available on our Sites (including access to certain films, registering for and using an online account) have age restrictions attached to their use. These age restrictions are explained in the terms and conditions of our services located here. Persons with limited legal capacity (aged 14 to 18 years) may use Services with the consent of a parent or legal guardian to take actions to conclude a contract and make statements and provide consent (this is the consent to perform such acts and should be delivered in writing to Cinema City upon request). Some of our Services are restricted only to persons with full legal capacity or aged 16 or older with limited legal capacity (with the provision that such person is acting with the consent of a parent or legal guardian to take actions to conclude a contract and submit declarations and consents) - in accordance with the relevant terms and conditions of that specific service.
Children under 14 may not use the Services.
This means that we may need to ask you to provide your date of birth and, where our products or services are being purchased by you on behalf of a Juvenile as a parent or legal guardian, the date of birth of the Juvenile.
What is our legal basis?
Where we use your personal information to verify you or the person receiving our Services meets any age restrictions which we have set or to verify the legal capacity set by the relevant provisions of law, it is in our legitimate interests to do so. Where we use your date of birth to prevent you from accessing age-restricted films or purchasing alcohol, we do so because this is necessary to comply with the legal obligations to which we are subject. It is also in our legitimate interest to check your ID card to verify if you are legally allowed to purchase alcohol, to check that you qualify for any reduced price or free ticket you request and to help us ensure these types of concessions schemes are used fairly and for fraud detection and prevention purposes.
When you use our Services, it is also necessary for us to process your data for the purpose of performance of the contract or in order to take steps at your request prior to entering into a contract, which gives us yet another legal basis to process your personal data.
4.3. Online Account
If you register and create an online account on our Sites, we will ask you for your first name, family name, email address and optionally telephone number. We will also ask you to enter your password to log in to your online account. You can also voluntarily provide us with additional information when using your online account – date of birth and favourite cinema. You can update some of your contact details and other data we have about you at any time via your online account. If you wish to update your data which are not editable from the level of your account, you can do so by contacting us/our customer service centre via: [email protected].
When you create your online account make sure that the e-mail address you provide is correct. This e-mail will be used to send you an activation link in order to validate the e-mail address provided during the registration process. You have 7 (seven) days to activate your account (by clicking the link we sent to you). If you do not validate the creation of the account, the data you provided during registration process will be anonymized after 7 days.
We use your personal data to provide you with available online account functionality, including facilitating the purchase of our products and services via your account. Personal data is also used to identify the user when visiting and interacting with other areas of our Services (for more information on how we use personal data for this purpose, see section 4.8 Customer Insight and Analysis).
When at the time of creating your online account, you use our other Services which: a) have not been entirely executed yet or b) are in the process of its use by you or you have provided us with your marketing consent(s) connected to your e-mail address used to create your on-line account, we grant you the access to information and your personal data related to these activities via your online account. Therefore, such online account will serve for you as a centralized place to individually display and manage (where feasible) your data, consents and other information related to the Services you use. IF YOU HAVE ANY QUESTIONS, PLEASE CONTACT OUR CUSTOMER SERVICE
If you provide us voluntarily with your date of birth and favourite cinema, when using your account, this data might be used for other, additional purpose – our marketing activities, such as sending you birthday surprises, commercial information about news in the cinema based on the favourite cinema you choose (to focus on the area which we believe is most suitable for you based on your chosen cinema). However, we will do so only if you give us your separate marketing consent when signing-up for newsletter or creating an on-line account or at other occasion (e.g., when you take part in the promotion or manage your preferences with available tools). Please see the Marketing Communications section for further information.
You can also ask for secured storage of payment card details by our payment service providers who process payments and store your payment card details to speed up the process of purchasing products and services online. Please note that payment card details you provide, and choose to store, are always provided directly by you to the chosen payment service provider and they will store the payment card details for you.
What is our legal basis?
It is imperative that we use your personal data to perform our obligations and exercise our rights in accordance with the contracts we can conclude with you, including the contract for the use of an online account. The legal basis for data processing is the necessity for the performance of a contract with the user.
Close account: If you close your account, and we have no other purpose for processing your data, your personal data held for the account will be anonymized in the database.
You should know that after closing your account we might continue processing your personal data for other purposes e.g.: for continuing to send you the newsletter if you have not unsubscribed.
4.4. Customer Services Our Sites and our cinemas use various user interfaces to allow you to request information about our products and services: these include printed and electronic enquiry forms, dedicated email addresses, our social media pages,. Contact information may be requested in each case, together with details of other personal information that is relevant to your customer service enquiry. This information is used in order to enable us to respond to your requests.
As we wrote in the section IV above, if you contact us via social media platforms or instant messengers (such as Facebook or Messenger) do not give us any personal information about you or other persons in the messages you send. If your inquiry is supposed to contain personal data send it to us via officially provided contact details or using a contact form available on-line.
For us your e-mail address is a primary identifier, therefore any inquiries that are sent to us we process only if received from the e-mail address that was used for the service in question (e.g., a question regarding an on-line account should be sent from the same e-mail address which is used to log-in to the account). In some specific cases we may use additional verification to process your inquiry (i.e. to identify if the person is authorized to be part of this proceeding). In such cases we may ask you for additional information which we already process.
What is our legal basis? It is in our legitimate interest to use your personal information in such a way to ensure that we provide you the very best customer service we can.
4.5. Competitions, prize draws and other events and promotions
From time to time, we may run prize draws, prize competitions and other promotions on our Sites, on our social media accounts and/or in our cinemas. We may also run events at other locations. For the purposes of administering such promotions and events, we may process your name, contact details (including email address, postal address and/or telephone number), social media handle (if relevant) and any other personal information volunteered by you in your promotion entry. For certain competitions and events, we may process and publicize images, videos or sound recordings that you volunteer to us.
What is our legal basis?
It is necessary for us to use your personal information to perform our obligations and exercise our rights in accordance with any contract that we may have with you (e.g. the terms and conditions applicable to the promotion) or it is in our legitimate interest to use your personal information to enable you to participate in any prize draws, prize competitions and other promotions. We will only use photographs we take of you at events or we publish the information about the winners of the competitions where we have your consent to do so.
If by providing a prize in a specific competition we are obliged by tax law to send a tax declaration to the applicable tax authority, we will collect from your additional information (such as date of birth, residence address) to fulfill such declaration. The basis of processing this data is our legal obligation derived from tax law.
4.6. Your feedback about our products and services.
From time to time, we will contact you to invite you to provide feedback about our products and services in the form of online surveys. We use this information to help us improve the quality of service provided by our staff and in our cinemas. We also use your feedback to monitor the quality of our products and services, to develop our business and to assist with the selection of future product and service lines.
What is our legal basis?
It is in our legitimate business interests to use the information you provide to us in your feedback for the purposes described above.
4.7. Customer insight and analysis.
o an IP address to monitor Site traffic and volume;
o a session ID to track usage statistics on our Sites;
o information regarding your personal or professional interests, demographics, buying habits, experiences with our products and contact preferences.
Our web pages, mobile applications and e-mails messages contain “cookies”, "web beacons" or “pixel tags.” (“Tags”). Tags allow us to track receipt of an e-mail to you, to count users that have visited a web page or opened an e-mail and collect other types of aggregate information. Once you click on an e-mail that contains a Tag, your contact information may subsequently be cross-referenced to the source e-mail and the relevant Tag.
In the cases we have relevant consent, we also use the data regarding location to analyze the client’s needs.
We may also use your location data to offer you services available in your location, by displaying a notification in the mobile application.
By using this information, we are able to measure the effectiveness of our content and how visitors use our Sites and our Services. This allows us to learn which pages of our Sites are most attractive to our visitors, which parts of our Sites are the most interesting, how customers use our Services and what kind of offers our customers like to see.
We also use this information to help us with the selection of future product and service lines, cinema, website and app design and development, to identify appropriate partners whose offers we might obtain for you as a Cinema City customer and to remember your customer preferences.
Some of your data may be used for profiling, to support our marketing activities, for example, to let you know about upcoming films, events and available services best matched to your film and cinema preferences. Please see the Marketing Communications section below for further details about how your personal information may be used for marketing purposes.
Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best products and services to you and our other customers.
Where we process your data for marketing purposes we do so based on our legitimate interest. We will only undertake profiling of your personal data where it is in our legitimate interests to do so (and you have not asked us to stop) or, where the law requires us to obtain your consent, in line with the consent you have given to us.
Data regarding your location will be used in order to obtain information about you and to offer you the services available within your location, provided we have been granted your consent to do so.
4.8. Marketing communications
We carry out the following marketing activities using your personal information:
o Email, text and push notifications marketing.
We use information that we observe about you from your interactions with our Sites, our email communications to you and/or with our products and services in our cinemas (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected) and/or your email address and mobile phone number to send you marketing communications by email or text message, where you have consented to receive such marketing communications, or where we have another lawful basis to do so.
Where you have enabled push notifications for our mobile application on your mobile device, we will also present marketing content via push notification on your mobile device.
What is our legal basis?
Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes. We will only send you marketing communications via email and text message and push notification where you have consented to receive such marketing communications, or where we have a lawful right to do so.
When you provide us with your personal information such as name, date of birth, favourite cinema, phone number, or e-mail address we will use this information for marketing purposes only if you give us your consent to do so. Within our marketing activities using this data we include: sending you birthday surprises or commercial information about news in the cinema based on the favourite cinema you choose (to focus on the area which we believe is most suitable for you based on your chosen cinema). You might give us your separate marketing consent when signing-up for newsletter or creating an on-line account or at other occasion (e.g., when you take part in the promotion or manage your preferences with available tools).
If you agree to process your given data within the scope of: name, date of birth, favourite cinema, phone number, or e-mail address for marketing purposes we will realize this purpose using this data for as long, as we have our legal basis to do so (i.e., your consent). Deleting your on-line account resulting in our obligation to cease processing your data for the purposes of executing our contract related to these services does not affect processing your data by us further for separate, marketing purposes, on a separate legal basis (your consent). We have the legal basis (consent) until you withdraw your consent or until our internal retention period to store your data processed upon your consent has expired (if earlier).
o Online personalised advertising.
We may use information that we observe about you from your interactions with our Sites, our email communications to you and/or use of our products and services (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected) to provide you with personalized online advertising.
What is our legal basis? Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes as described in this section.
o Social media remarketing
We may use information that we observe about you from your interactions with our Sites, our email communications to you and/or with our products and services in our cinemas (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected) to provide you with personalized advertising on social media channels operated by Facebook and/or Google where you are a registered user of such services.
We may do this using Facebook Customer Audiences and/or Google Customer Match respectively. Please note that such activity requires that we share your encrypted email address with Facebook and/or Google and is also subject to the privacy choices you have selected to make on such services.
What is our legal basis?
Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.
• Social media insight
Where you are a registered user of Facebook, or of a Google service, we may use your email address in an encrypted format to enable Facebook and Google to find other registered users of their services that share similar interests to you based on:
information that we observe about you from your interactions with our Sites, our email communications to you and/or with our products and services in our cinemas (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected); and
the information Facebook and/or Google hold about you.
We may do this using Facebook Lookalike Audiences and/or Google Similar Audience respectively. Please note that such activity is subject to the privacy choices you have selected to make on such services.
What is our legal basis?
Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.
• Use of Anonymized Personal Information
4.9. Business administration and legal compliance.
We use your personal information for the following business administration and legal compliance purposes:
o to comply with our legal obligations;
o to protect our business and your accounts from fraud and other illegal activities;
o to protect our property;
o to ensure fair offers for reduced price tickets and other promotions we may offer;
o to enforce our legal rights or obligations;
o protect rights of third parties; and
o in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.
Some of the personal information we may use for these purposes may be obtained from our use of CCTV systems in and around our cinemas and customer car parks. For further details about our use of CCTV, please pay attention to our CCTV notifications which are available to you at our cinema lobbies.
What is our legal basis?
Where we use your personal information in connection with a business transition, enforce our legal rights, protection of our property, ensuring fair use of our Services, or to protect the rights of third parties it is in our legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us such as a court order.
4.10. Health and Safety
We may use your personal information to help ensure we provide a safe and secure environment for our customers, staff and others when visiting our cinemas. This may include personal information which is gathered for health and safety purposes including any accident report, claim log and/or CCTV images recorded in respect of an accident or incident which occurs in one of our cinemas. The scope of personal data we collect for health and safety reasons might vary depending on the actual legal obligations. As this may be data relating to your health it could fall within special categories of data which is defined under relevant data protection legislation as including personal data revealing racial or ethnic origin, religious beliefs and data concerning health (as well as various others). We may also use this information to establish, exercise or defend any legal claim in relation to the accident or incident, including sharing this information with our insurance providers. We may use data concerning health also when it is necessary to establish, exercise or defend any legal claim (yours or ours) in relation to specific terms and conditions of dedicated services.
What is our legal basis?
Where we use your personal information in connection with an accident or incident as described above it is in our legitimate interest to do so and to comply with our legal obligations. Where this includes use of special categories of data it is necessary for us to process the data for the purposes of establishing, exercising or defending any legal claim and in some cases it may also be necessary to protect the vital interests of the data subject or of another person (in case where the data subject is physically or legally incapable of giving consent).
4.11. Other purposes
Any other purposes for which we wish to use your personal information that are not listed above, or any other significant changes we propose to make to the existing purposes will be notified to you using your contact details or it will be presented to you individually where we collect your data for the purposes not specified hereinabove.
V. HOW DO WE OBTAIN YOUR CONSENT?
Where our use of your personal information requires your consent, you can provide such consent:
• at the time we collect your personal information following the instructions provided; or
The legal basis of consent is only used by us in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way.
When we use your consent as a legal basis we rely on this consent from the moment you gave it to us until you explicitly revoke it. You may at any time withdraw the specific consent you give to our processing your personal data. Please see How to access your information and your other rights section below for more details. Please note even if you withdraw consent for us to use your personal data for a particular purpose we may continue to rely on other bases to process your personal data for other purposes.
VII. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
• internally with our employees;
• internally with other companies in our group (which means our subsidiaries and our ultimate holding company (Cineworld Group PLC) and its subsidiaries); and
• externally with third party service providers.
The categories of third party service providers that we share your personal information with are:
• providers of ticketing systems;
• providers of systems that help us provide and administer our gift products;
• our agency that provides us with cinema staff members;
• payment processors - please note that payment card details you provide always to a chosen payment service provider (e.g. PayU), and we do not collect them or store them;
• printing and delivery companies;
• suppliers who host, provide, manage, support or administer certain aspects of our websites, and customer services facilities,
• suppliers who host, provide, manage, support or administer certain aspects of our IT and business administration systems and data centres;
• providers of customer surveys and customer insight analytics;
• suppliers of email, online and social media advertising and other marketing services and systems;
• third parties who help us to run or administer competitions or deliver prizes;
• third parties who host our events;
• our professional advisers such as our lawyers, accountants, health and safety consultants and insurance brokers for our business administration and legal purposes;
• third parties who help us to professionally store the documents or destroy the documents;
• third parties who help us to secure our cinema sites, including managing CCTV systems;
• any other third party where we are obliged to, or permitted to do so, by law, court order or to comply with any search warrant or similar instrument presented to us by any law enforcement, government officer or regulatory authority;
• in the event that our business is sold or integrated with another business, our lawyers, and other professional advisers, any prospective purchasers' lawyers and professional advisers, and any prospective purchaser (subject to duties of confidentiality).
VIII. TRANSFERS OF YOUR PERSONAL INFORMATION OVERSEAS
1. Internally within our group
The use of your personal information is governed by intra-group agreements. Some of our group companies who are based outside of the EEA, such as Regal Entertainment Group (a company based in the US), which provide various hosting and support services to Cinema City or Cineworld Cinemas (based in the UK),, so your personal data may be transferred from the EEA to the US or other non-EEA jurisdictions respectively. Where this happens, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA and use EU ‘model clauses’, which have been approved by the European Commission, as the lawful basis for transferring personal information outside of the EEA. A copy of the EU Model clauses, which protect certain rights of data subjects, can be found at
2. To external third parties
In respect of transfers of your personal information outside of the EEA, this means that we will ensure that there is a lawful basis for transferring personal information outside the EEA. Our standard practice is to use ‘model clauses’ which have been approved by the European Commission for such transfers.
IX. THIRD PARTY LINKS AND SERVICES
Your browsing and interaction on any other websites, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies.
We do not monitor, control, or endorse the privacy practices of any third parties.
We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.
2. Payment services
Please see section 4.1 for details about use of online payment services to pay for goods and services ordered on our Sites.
X. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?
Whenever we collect or process furtherly your personal data we will usually keep it for 18 months after our last interaction with you or otherwise in accordance with our data retention policy (depending on the type of service you used), pursuant to which we do not retain personal data for longer than is necessary for the purposes for which it is collected.
We will keep personal data you give us in relation to any contract that we have with you for five years, or until the end of the limitation period, whichever is longer. If your information is only useful for a short period e.g., for specific marketing campaigns we may delete it. At the end of that retention period, your data will either be deleted or anonymized, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning. We keep the length of time that we hold your personal data for under review.
We want to clarify to you, that for example in case you have an on-line account and you want to delete it, in practice, according to our retention policy, we deactivate it. Therefore, it does not result in immediate deletion/anonymization of your data by us processed for the purpose of maintaining your account. According to our retention policy we will store your data for the period of 18 months since your account is set as inactive.
If when using your account, you gave us additionally your consent to process your data for marketing purposes, your data provided in your account, such as: name, date of birth, favorite cinema, phone number, or e-mail address will be continued to be processed by us for marketing purposes even after your account is set as inactive or deleted. This is the result of the fact, that we realize marketing purposes separately from handling your on-line account, and we have for this a separate legal basis – your consent. We have the legal basis to do so (consent) until you withdraw your consent or until our internal retention period to store your data processed upon your consent has expired (if earlier).
XI. CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION
We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions (including appropriate technical and organizational measures) to protect your personal information from loss, misuse or alteration. We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from in particular:
• unauthorised access;
• improper use or disclosure;
• unauthorised modification; and
• unlawful destruction or accidental loss.
All of our employees and data processors (i.e., those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of our Services.
XII. HOW TO ACCESS YOUR INFORMATION AND YOUR OTHER RIGHTS
• Your right of access.
If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
• Your right to rectification.
If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
If you have an online account, you can log in and amend your contact details and email and text marketing preferences whenever you like. If you wish to update your data which are not editable from the level of your online account, you can do so by contacting us/our customer service centre via [email protected].
• Your right to erasure.
You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly. If you wish to delete your data which are not editable from the level of your account, you can do so by contacting us/our customer service centre via: [email protected].
• Your right to restrict processing.
You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
• Your right to data portability.
You have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
• Your right to object.
You can ask us to stop processing your personal information, and we will do so, if we are:
o relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
o processing your personal information for direct marketing if conducted in traditional (paper) form and is related to our own Services.
You can ask us to stop sending you marketing communications sent to you by email or text at any time by using the ‘opt-out’ or ‘unsubscribe’ link that we will present to you in the marketing communication. This will be considered however as withdrawal of your consent, as our legal basis to contact you in electronic way for marketing purposes is consent. You can stop receiving push notifications in the mobile app at any time by changing the settings on your mobile device. Please note that it may take us a few days (but usually no longer than 14 days) to ensure our marketing systems are updated and during this period you may still receive marketing communications from us.
• Your rights in relation to automated decision-making and profiling.
You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such decision is necessary for entering into, or the performance of, a contract between you and us
• Your right to withdraw consent.
If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time, by: managing your preferences with available tools or contacting the customer service [email protected]. When we rely on your consent we do so until you explicitly revoke it in one of the abovementioned ways. When we have your consent from you and on the next interaction with us, for example when visiting our Sites, you omit the checkbox (leaving it blank) it is not deemed as the consent withdrawal. For this reason, we rely on the specific, explicit action (in one of the abovementioned ways).
• Your right to lodge a complaint with the supervisory authority. For more information, click here.
Suppose you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information. In that case, you can report it to the National Supervisory Authority for Personal Data Processing.
You can find more details on how to do this on the National Supervisory Authority for Personal Data Processing website at www.dataprotection.ro or by calling the helpline (031) 805 9211 provided by the National Supervisory Authority for Personal Data Processing.
If your requests related to your rights are manifestly unfounded or excessive, in particular, because of their repetitive character, we may either:
1. charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking action requested; or
2. refuse to act on the request.