PRIVACY POLICY & COOKIE POLICY
- Purpose of this policy
- Who are we and what do we do?
- How to contact us?
- What personal data do we collect and how do we use it?
4.1 Fulfilment of products and services
4.2 Verify the age of persons using our products and services
4.3 Providing and administering accounts
4.4 Providing our E-Club scheme
4.5 Customer Services
4.6 Competitions, prize draws and other promotions
4.7 Your feedback about our products and services
4.8 Customer insight and analysis
4.9 Marketing communications
4.10 Business administration and legal compliance
4.11 Other purposes
- How do we obtain your consent?
- Our use of cookies and similar technologies
- Who do we share your personal data with?
- Transfers of your personal information overseas
- Third party links and services
- How long do we keep your personal data for?
- Confidentiality and security of your personal data
- How to access your personal data and your other rights
- Changes to this privacy policy
- Cookie Policy
CINEMA CITY CZECH S.R.O
PRIVACY POLICY
Last updated April 2024
We respect the privacy of every person who visits or registers with www.cinemacity.cz (the “Sites”) and who uses the services that we make available from the Sites, in our cinemas or through our customer services facilities (our “Services”) and we are committed to ensuring a safe online experience.
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PURPOSE OF THIS POLICY
This privacy policy (“Privacy Policy”) explains our approach to any personal data that we might collect from you or which we have obtained about you from a third party, including someone who has purchased a gift for you, and the purposes for and the basis on which we process your personal data. This Privacy Policy also sets out your rights in respect of our processing of your personal data.
This Privacy Policy will inform you of the nature of the personal data about you that is processed by us and how you can request that we delete, update, transfer it and/or provide you with access to it.
This Privacy Policy is intended to assist you in making informed decisions when using the Sites and our Services. Please take a moment to read and understand it. Please note that it should be read in conjunction with our Terms of Use, General Terms and Conditions and (where applicable) the General Terms and Conditions of the Cinema City Loyalty Club (E-Club) and Terms And Conditions for Cinema City Online Account.
Please also note that this Privacy Policy only applies to the use of your personal data obtained by us, it does not apply to your personal data collected during your communications with third parties.
This Privacy Policy may vary from time to time so please check it regularly. Please see Changes to this Privacy Policy below for further details.
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WHO ARE WE AND WHAT DO WE DO?
The Sites and our Services are operated by Cinema City Czech s.r.o.,(“we”, “us” or “our”).
Cinema City Czech s.r.o., is the data controller responsible for your personal data obtained in connection with the provision of our Sites and Services.
Cinema City Czech s.r.o., is a company with Identification No. 26449242, with its registered office at Arkalycká 951/3, 149 00 Prague 4 – Háje, registered in the Commercial Register maintained by the Municipal Court in Prague, Section C, Insert No. 82991
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HOW TO CONTACT US?
If you have any questions about this Privacy Policy or want to exercise your rights set out in this Privacy Policy, please contact us by:
• sending an e-mail; or.
• calling us on: +420 255 742 021
• post at: Cinema City Czech s. r. o., Arkalycká 951/3, Praha 4 - Háje 149 00
Our Data Protection Officer's contact details are as follows: [email protected], correspondence address: Cinema City Czech s.r.o., Arkalycká 951/3, Praha 4, 140 00.
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WHAT PERSONAL DATA DO WE COLLECT AND HOW DO WE USE IT?
We obtain your personal data 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, cookies, server logs and other similar technologies;
• Use of CCTV or other recording systems in and around our cinemas;
• From our group companies and third party service providers in the course of providing their services to us in connection with your use of our Sites and Services. Please see section 7 ‘Who do we share your personal data with?' to find out more about these group companies and third party service providers;
• Providers of social media platforms (such as FaceBook, Twitter and Instagram) where you share our content through social media, by liking us on Facebook, following or tweeting about us on Twitter; and
• Otherwise as explained below in this What Personal data do we collect and how do we use it? section.
Our primary goal in collecting personal data 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 process, 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 by law.
In particular, we use your personal data for the following purposes:
4.1 Fulfilment of products and services
We collect and maintain personal data that is voluntarily submitted to us during the use of the Sites and/or our Services. We use the contact and payment details which are provided to us so that we can fulfil the supply of products and services which have been 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, your attendance at events hosted by us or our third party partners, your group reservations, hire of our cinemas for your own events and the processing of returns and refunds. For example:
- Ticket bookings, gifts and other online purchases.
If you wish to book tickets through our Sites we will need to know your name, payment card details, email address and/or phone number. We may also need this information when you make any other purchases via our Sites.
If you wish to purchase from the Gifts section of our Sites we will need to know your name, payment card details and email address and where you ask us to send the gift to you by post, your delivery address. Where you ask us to send the gift directly to the gift recipient, we will also need to know the name of the recipient and the delivery address for gifts sent by post or the name and email address of the recipient where gifts are sent by email.
If you request one of our reduced price or free tickets (such as a student ticket, senior ticket, or ticket for holders of ZTP/P cards) we may ask to see an appropriate form of identification to confirm your eligibility to purchase the reduced price or free ticket. In some cases we may need to verify the validity of your ID against third party databases, but we will not take or keep a copy of your ID on any of our systems. We may process information relating to your physical health when you book a wheelchair accessible seat or a companion seat or when you provide us with food allergy information for catered hosted events, which may imply or suggest health issues.
We use this personal data to process and fulfil your orders and to send you service related emails (and where requested, text messages) for your booking or purchase. We may also use these details to send you a follow-up service email after your cinema visit, to check that you were satisfied with our service.
o Payment methods
You may pay for products and services on our Sites using credit/debit card, an online payment account such as Paypal, online bank transfer (such as Fast Pay), Masterpass, saved credit/debit card or gift card/e-code or voucher. When you select any of these payment methods on the payment page on our Sites, you will leave our Sites and be transferred to the chosen payment service provider’s websites (including via Widget), where you will provide the payment details directly to the relevant payment service provider. Any personal information you provide in connection with your payment will be collected, processed and stored in accordance with the payment processor’s own privacy policy (not our privacy policy).
We may receive payment details from payment providers, such as your name, family name, email address and some digits of the payment card number (or payment account), which will be used to pre-fill the relevant fields when shopping using our Services, can help us connect your payment with your booking on our Sites and also be used to effectively refund your payment in case of cancellation or return of ordered products or services.
What is our legal basis?It is necessary for us to use your personal data (including checking your ID or ZTP/P card when you request a discounted or free ticket) to perform our obligations in accordance with any contract that we may have with you such as your contract with us for your ticket or gift purchase. It is in our legitimate interest to use personal data of a gift recipient in order to provide them with the gifts purchased for them. It is also in our legitimate interest to check your ID or any other required document to check that you qualify for any reduced price or free ticket and to help us ensure these type of concessions schemes are used fairly and for fraud detection and prevention purposes. Where we process information concerning your health for the above purposes, we rely on your explicit consent because we are processing this information to provide a service that you have voluntarily requested.
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, online accounts and E-Club membership) have age restrictions attached to their use. The age restrictions are explained in the terms and conditions relating to our Services which are located here. For example you must be at least 13 years old to access and use our Sites and at least 16 years old to register for the Cinema City E-Club or an online account. Persons with limited legal capacity (aged 13 to 17 years) may only use our Services (and provide any confirmations or consents in connection with their use of the Sites) with the consent of a parent or legal guardian (and the parent/guardian’s consent should be provided in writing to Cinema City upon request). Children aged 12 or younger may not use the Services.
This means that we may need to ask you to provide evidence of your date of birth and, where our products or services are being purchased as a gift, the date of birth of the recipient of the gift. We may also request you provide other documents, for example, school ID or student ID to verify the right to purchase a reduced price or free ticket.
This means that we may need to ask you to provide your date of birth and, where our products or services are being purchased as a gift, the date of birth of the recipient of the gift.
We may also use your date of birth to understand more about our customers (see the Customer Insight and Analysis section for more details about our use of your personal information for this purpose).
What is our legal basis?
Where we use your personal data to verify you or the person receiving our Services meets any age restrictions which we have set, 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 for us to comply with legal obligations to which we are subject. It is also in our legitimate interest to check your ID card to check that you qualify for any reduced price or free ticket you request and to help us ensure these type of concessions schemes are used fairly and for fraud detection and prevention purposes.
Also, when you use our Services, we may need to process your personal data for the purpose of fulfilling our obligations under our contract with you (or taking steps at your request prior to entering into a contract).
4.3 Providing and administering accounts
If you register for an account (including an E-Club account), we will ask you to provide your name and e-mail address. We will also ask you to provide a password for your account. You can also voluntarily provide us with additional information during the registration process or when using your account, for example your postal address, phone number, date of birth and gender. You can update and amend the contact details and some other personal data we hold about you at any time through your account.
We will use this personal data to provide you with the online functions available within the account, including facilitating your purchase of our products and services via your account (where this function is available) and service communications. This personal data is also used to identify you when you visit and interact with other areas of our Sites (see the Customer Insight and Analysis section for more details about our use of your personal data for this purpose).
What is our legal basis?
It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you such as your contract with us for your use of an E-Club account.
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 necessary for us to use your personal data to perform our obligations and exercise our rights in accordance with any contract that we may have with you such as your contract with us for your use of a Cinema City online account.
4.4 Providing our E-Club scheme.
If you purchase E-Club membership we will collect and use personal data about you in accordance with the purposes described in Sections 4.1 to 4.3 of this Privacy Policy. We will also set up an online E-Club account for you. You can use your E-Club account to access your E-Club membership, for example when booking online, and also manage your membership details such as updating your personal details and subscribing/unsubscribing to our newsletter and other email communications. Please see the ‘Providing and administering accounts’ section for further details. You must be aged at least 16 years old to be an E-Club member. Persons with limited legal capacity (aged 16 and 17 years) may only register for E-Club membership (and provide any confirmations or consents in connection with the E-Club membership) with the consent of a parent or legal guardian (and the parent/guardian’s consent should be provided in writing to Cinema City upon request).
As a part of your E-Club membership, we will use your contact details to send you service communications, including information about your membership such as renewal reminders, account information and membership summaries and details of new cinema openings. You can find out more about what’s included with the E-Club membership service here. We will also use your personal data to provide the functions available within the online account. In addition, where we have a lawful right to send you marketing communications or where you have asked us to we will also send you our newsletter and other news and offers by email and SMS. Please see the Marketing Communications section for further information.
What is our legal basis?
Where you have purchased an E-Club membership, it is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you such as your contract with us for your purchase or use of E-Club membership. Please see the Marketing Communications section for the legal basis upon which we may send you marketing communications.
4.5 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 and a telephone enquiry service. 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.
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 the very best customer service we can to you. If you voluntarily provide us with information concerning your health, we typically rely on your explicit consent to process that personal data. If you voluntarily provide us with personal data concerning the health of another person, we may ask for that person to provide their explicit consent to our processing.
4.6 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 data volunteered by you in your promotion entry or registration for or participation in our events. For certain competitions and events, we may process and publicise images, videos or sound recordings that you volunteer to us.
What is our legal basis?
It is necessary for us to use your personal data to perform our obligations 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 data 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 where we have your consent to do so.
4.7 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 or in-cinema 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.
4.8 Customer insight and analysis.
We analyse your contact details and other information provided by you during your use of the Sites and our Services, including your date of birth, with other personal information that we collect or observe about you from your interactions with our Sites, our email communications to you and/or with our products and services in our cinemas, such as the products and services you have purchased or viewed.
Where you have given your consent (where lawfully required), we use cookies, log files and other technologies to collect personal information from the computer hardware and software you use to access the Sites, or from your mobile. This includes the following:
• an IP address to monitor Sites traffic and volume;
• a session ID to track usage statistics on our Sites;
• information regarding your personal or professional interests, demographics, buying habits, experiences with our products and contact preferences.
Our web pages and e-mails 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 some of our e-mail messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications. Please see our Cookie policy for further information.
This information is used to create profiles and insights about your cinema habits and the cinema habits of our other customers and helps us to get to know our customers better. Where we have your permission to use information about your location, we may use it for customer insight purposes and to provide you with information about the services available within your local area.
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 personal information 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 data may be used for marketing purposes.
What is our legal basis?
Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute personal data that is regulated under data protection laws. However, our collection and use of such anonymised personal data may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.
Where your personal data is not in an anonymous form, it is in our legitimate interest to use your personal data in such a way to ensure that we provide the very best products and services to you and our other customers (though we will not do so if you have asked us to stop processing your personal data in this way). Where the law requires us to obtain your consent for any particular processing activity, we will do so.
4.9 Marketing communications
We carry out the following marketing activities using your personal data:
- Email and text 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 and text message, where you have consented to receive such marketing communications, or where we have another lawful basis to do so.
What is our legal basis?
Where your personal data is not in an anonymous form, it is in our legitimate interest to use your personal data for marketing purposes.
We will only send you marketing communications via email and text message where you have consented to receive such marketing communications, or where we have a lawful right to do so.
- Online personalised advertising. 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) to provide you with personalised 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.
- Social media remarketing. 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) to provide you with personalised advertising on social media channels operated by Facebook and/or Google where you are a registered user of such services. We 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 elected to make on such services.
What is our legal basis?
Where your personal data is not in an anonymous form, it is in our legitimate interest to use your personal data 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 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 elected to make on such services.
What is our legal basis?
Where your personal data is not in an anonymous form, it is in our legitimate interest to use your personal data for marketing purposes.
- Use of Anonymised Personal data. Where your personal data is completely anonymised, we do not require a legal basis to use it as the personal data will no longer constitute personal data that is regulated under data protection laws. However, our collection and use of such anonymised personal data may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.
4.10 Business administration and legal compliance.
We use your personal data for the following business administration and legal compliance purposes:
• to comply with our legal obligations;
• to protect our business and your accounts from fraud and other illegal activities
• to enforce our legal rights;
• protect rights of third parties; and
• 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 data we may use for these purposes may be obtained from our use of CCTV systems in and around our cinemas.
What is our legal basis?
Where we use your personal data in connection with a business transition, enforce our legal rights, 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 data to comply with any legal obligations imposed upon us such as a court order.
4.11 Health and Safety
We may use your personal data to help ensure we provide a safe and secure environment for our customers, staff and others when visiting our cinemas. This may include personal data 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. As this may include information relating to your health it could fall within special categories of information 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 data to establish, exercise or defend any legal claim in relation to the accident or incident, including sharing this information with our insurance providers.
What is our legal basis?
Where we use your personal data in connection with an accident or incident as described above it is in our legitimate interest to do so and, in some cases, we may also need to process it to comply with our legal obligations, including health and safety related obligations. Where we process personal data relating to your health for this purpose, we may process this data to establish, exercise or defend any legal claim (for example, a claim relating to an accident or incident) and in some cases it may also be necessary to protect the vital interests of the data subject or of another person (in cases where the data subject is physically or legally incapable of giving consent).
4.12 Other purposes
Any other purposes for which we wish to use your personal data that are not listed above, or any other significant changes we propose to make to the existing purposes which involve the use of your personal data will be notified to you using your contact details or presented to you individually where we collect your personal data for the purposes not specified above in this section 4.
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HOW DO WE OBTAIN YOUR CONSENT?
Where our use of your personal data requires your consent, you can provide such consent:
- at the time we collect your personal data following the instructions provided; or
- by informing us by e-mail, post or phone using the Contact Details set out in this Privacy Policy.
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.
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.
Please note that if you withdraw your consent to receive marketing communications, for example, there is a risk that you may receive another marketing communication not long after you have withdrawn it. This is because our systems take a while to update and record changes to the consents you have given. This is not an intentional action on our part, merely a consequence of the functionality of our IT systems. We make every effort to ensure that the exercise of your rights goes smoothly!
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OUR USE OF COOKIES AND SIMILAR TECHNOLOGIES
Our Sites use certain cookies, pixels, beacons, log files and other technologies of which you should be aware. Please see our Cookie Policy to find out more about the cookies we use and how to manage and delete cookies.
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WHO DO WE SHARE YOUR PERSONAL DATA WITH?
We may share your personal data for the purposes described in section 4 of this Privacy Policy:
- Internally with our employees who are authorized by us to use your personal data for the purposes detailed above;
- 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 data with are:
- • providers of our ticketing systems;
• providers of systems that help us operate our E-Club scheme and online accounts;
• providers of systems that help us provide and administer our gift products;
• payment processors, although please note that payment card details you provide are always provided directly by you to a chosen payment service provider (e.g. PayU), and we do not collect them or store them;
• printing and delivery companies;
• suppliers of services who host, provide, manage, support or administer certain aspects of our websites and customer services facilities,
• suppliers of services who host, provide, manage, support or administer certain aspects of our IT and business administration systems and data centres and who provide related consultancy services;
• providers of customer surveys and customer insight analytics;
• suppliers of email, online and social media advertising and other marketing services and systems such as Salesforce and related consultancy services;
• 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, auditors, health and safety consultants and insurance brokers for our business administration and legal purposes;
• debt collection agencies and others for the purposes of enforcing any agreements that we have with you;
• third parties who help us to professionally store and/or destroy documents;
• social media sites and platforms such as Facebook for marketing purposes (although we will only share your email address in encrypted form – for further information please see the Marketing Communications section above);
• 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).
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TRANSFERS OF YOUR PERSONAL INFORMATION DATA
8.1 Internally within our group
We transfer your personal data within our group as described in section 7 Who do we share your personal data with?
The sharing and use of your personal data by Cineworld Group companies 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), provide various hosting and support services to Cinema City, so your personal data may be transferred from the EEA to the US or other non-EEA jurisdictions. Where this happens, we have procedures in place to ensure your personal 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 data outside of the EEA. A copy of the EU Model clauses, which protect certain rights of data subjects, can be found at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en and a copy of these can be provided on request.
8.2 To external third parties
Where we transfer your personal data to external third parties, we take appropriate steps to ensure that your personal data is treated securely and in accordance with this Privacy Policy and all applicable laws.
In respect of transfers of your personal data outside of the EEA, this means that we will ensure that there is a lawful basis for transferring personal data outside the EEA. Our standard practice is to use ‘model clauses’ which have been approved by the European Commission for such transfers. We may also rely on other mechanisms where appropriate, including reliance on a third party’s ‘binding corporate rules’ or ‘EU-US Privacy Shield’ certification.
One or more of the third parties that we describe in section 7 Who do we share your data with? are located outside of the EEA or may otherwise transfer your personal data outside of the EEA, namely the supplier(s) detailed below.
• The provider of our internal IT support management system who is based in the USA and we rely on the supplier’s certification to the EU-US Privacy Shield as the lawful basis for transferring your personal data outside of the EEA to the USA. This supplier has agreed to comply with the EU-US Privacy Shield, which requires them to protect the fundamental rights of anyone in the EU whose personal data is transferred to the United States for commercial purposes. (Further details in respect of such safeguards are available from: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en).
• The provider of our Health & Safety reporting and administration system who is based in the USA and we rely on the EU ‘model clauses’ (as mentioned above) as the lawful basis for transferring personal data outside of the EEA.
• The provider of our email, online and social media advertising and other marketing services and systems, who is based in the USA and some of whose affiliates and sub-processors are based in Canada, Australia and the USA. When we share your Personal Data with this supplier, we rely on the following lawful bases for transferring Personal Data outside of the EEA: (i) the supplier’s Binding Corporate Rules, which are data protection policies for transfers of personal data outside the EU, which have been approved by the EU data protection authority and are adhered to by the supplier and its affiliates (further details of such safeguards are available from: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/binding-corporate-rules-bcr_en), (ii) EU-US Privacy Shield, with which the supplier has agreed to comply (please see above for further details), (iii) EU ‘model clauses’ (please see above for further details), and (iv) EU Commission’s decision that Canada offers an adequate level of data protection to ensure the protection of fundamental rights of EU citizens.
A copy of the EU Model clauses, which protect certain rights of data subjects, can be found at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en and a copy of these can be provided on request.
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THIRD PARTY LINKS AND SERVICES
9.1 Generally
Our Sites contain links to third party websites and services, including those of our third party partners. Please remember that when you use a link to go from our Sites to another website or you request a service from a third party, this Privacy Policy no longer applies.
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.
This Privacy Policy applies solely to personal data collected by us through our Sites and Services and does not apply to these third party websites and third party service providers.
9.2 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.
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HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?
Whenever we collect or process your personal data we will usually keep it for one year after our last interaction with you or otherwise in accordance with our data retention policy. We will keep personal data you give us in relation to any contract that we have with you for three years and in some circumstances such as in relation to damages caused to you, us or any third party for ten years. If your data 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 anonymised, 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.
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CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL DATA
We are committed to keeping the personal data you provide to us secure and we will take reasonable precautions to protect your personal data from loss, misuse or alteration.
We have implemented information security policies, rules and technical measures to protect the personal data that we have under our control from:
- 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 data on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal data, are obliged to respect the confidentiality of the personal data of all users of our Services.
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HOW TO ACCESS YOUR PERSONAL DATA AND YOUR OTHER RIGHTS
You have the following rights in relation to the personal data we hold about you. You can exercise these rights by contacting us using the contact details set out in Section 3 of this Privacy Policy or using any other method described below:
- Your right of access. If you ask us, we’ll confirm whether we’re processing your personal data and, if so, provide you with a copy of that personal data (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 data we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal data 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 data 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.
- Your right to erasure. You can ask us to delete or remove your personal data 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 data 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 data with so that you can contact them directly.
- Your right to restrict processing. You can ask us to ‘block’ or suppress the processing of your personal data in certain circumstances such as where you contest the accuracy of that personal data or you object to us processing it. It won’t stop us from storing your personal data though. We’ll tell you before we lift any restriction. If we’ve shared your personal data 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 data with so that you can contact them directly.
- Your right to data portability. With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal data 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 data, and we will do so, if we are:
- relying on our own or someone else’s legitimate interests to process your personal data, except if we can demonstrate compelling legal grounds for the processing; or
- processing your personal data for direct marketing. 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 as withdrawal of your consent for us to send you marketing communications, as our legal basis to contact you by email or text for marketing purposes is ‘consent’. 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 right to withdraw consent. If we rely on your consent (or explicit consent) as our legal basis for processing your personal data, you have the right to withdraw that consent at any time.
- Your right to lodge a complaint with the supervisory authority. If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal data, you can report it to the Office for Personal Data Protection, seated at Pplk. Sochora 727/27, 170 00 Prague 7-Holešovice. You can find details about how to do this on the website or by calling their helpline on +420 234 665 111, or by email.
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CHANGES TO THIS PRIVACY POLICY
To ensure that you are always aware of how we use your personal data we will update this Privacy Policy from time to time to reflect any changes to our use of your personal data. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will post any changes on our Sites to keep you aware and if you are an E-Club member we will notify you by e-mail of any significant changes. However, we encourage you to review this Privacy Policy periodically to be informed of how we use your personal data..
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COOKIES POLICY
INTRODUCTION
All Cinema City websites use cookies. Cinema City Czech s.r.o., IČO: 264 49 242 as the controller of personal data, processes your personal data using cookies to ensure the proper functioning of the website. It may also, together with partners, after your consent, use cookies for analytical and marketing purposes, particularly to match advertising content to your preferences. You can manage your preferences by clicking "Accept All" or "Cookie Settings". By accepting our Cookies Policy or consenting to the use of cookies while managing settings of your own browser, you agree that Cinema City uses cookies in accordance with the terms of this policy.
What are cookies and how do they work?
Cookies are small text files with information that are saved on your end device (e.g. telephone, computer). They save information about your behavior when visiting our website and using our online store. The cookies we use are safe for your device. In particular, it is not possible for viruses or other unwanted software or malware to enter this way.
Cookies are sent by web servers to web browsers that store these files. Then, each time the browser requests access to the given website, the information will be sent back to the server. In this way, the web server can identify and track the activity of internet search engines.
How to manage or block cookies
You can manage your preferences, click "Allow All" or "Confirm My Choices". To change your cookie preferences, move the slider next to the selected category. You have the right to inspect your settings and to change them at any time. Detailed information on how we and our partners use cookies and process your data, as well as your rights, can be found in our Privacy Policy.
In relation to the non-essential cookies that are used by the Sites, you can manage your cookie preferences by clicking "Manage Cookies" on the bottom of the website.
Cookie settings
You can stop providing this information to our website at any time by deleting cookies stored on your end device (computer, telephone) and by managing settings of your own preferences regarding the use of cookies by the websites you visit.
You can do this by changing the cookie settings in the options of the web browser which you use on your device.
Configuring your browser in a way that will block the installation of cookies for certain websites selected by you or for all websites, may result in the loss of certain functionalities and make it difficult or impossible to fully use our website.
More information on cookies you can find on this website: www.allaboutcookies.org
Necessary Cookies
These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.
Cinema City uses necessary cookies to provide Users the services and functionalities of the Website that User wants to use.
Necessary cookies may only by installed by the Controller through the Website. The legal basis for data processing in connection with the using necessary cookies is the necessity of the processing to perform the contract (art. 6 (1)(b) GDPR).
Functional Cookies
These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.
Functional cookies are used to remember and adapt the Website to User's choices regarding, inter alia, language preferences. Functional cookies may be installed by the Cinema City and its partners through the Service.
Performance cookies make it possible to obtain information such as the number of visits and sources of traffic on the Website. They are used to determine which pages are more and which are less popular pages, and to understand how visitors move around the site by keeping statistics on traffic on the Website.
The legal basis for the processing of Personal Data in connection with the use of functional and analytical cookies by the Cinema City for this purpose, is its legitimate interest (Art. 6(1)(f) GDPR consisting in ensuring the highest quality of the services provided on the Website.
The processing of Personal Data in connection with the use of functional and analytical cookies is subject to the User's consent to the use (separately) of functional and analytical cookies via the cookie consent management platform. This consent may be withdrawn at any time via this platform.
Targeting Cookies
These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.
These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages.
The legal basis for the processing of Personal Data in connection with the use of targeting cookies by Controller is it legitimate interest (art. 6 (1)(f) GDPR) consisting in ensuring the highest quality of services provided on the Website.
Performance Cookies
These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.
The legal basis for the processing of Personal Data in connection with the use of performance cookies by the Cinema City for this purpose, is its legitimate interest (Art. 6(1)(f) GDPR consisting in ensuring analysis of user traffic on the website.
Social Media Cookies
We use cookies to personalise your interaction with social media, such as Twitter, Facebook, and Google. Such cookies recognise users of those social media sites when you view social media content on our Sites. They also allow you to quickly share content across social media, through the use of simple ‘sharing’ buttons.
Our Sites also contains features that enable you to use your Facebook, Google and Twitter accounts to sign in and create/maintain an account with us and to enable us to store your content. This involves the use of cookies.
Read the privacy statement of these social networks (which may change regularly) to find out what they do with your (personal) data that they process with these cookies.
WHAT HAPPENS WHEN YOU REFUSE, BLOCK OR DELETE COOKIES?
In order to use some parts of our Sites you will need to accept cookies. If you choose to withhold consent to our use of cookies, or you subsequently block or delete cookies, some aspects of our Sites may not work properly and you may not be able to access all or part of our Sites.
