Thank you for visiting this website (“Site”) which is controlled and operated by Whirled Cinema LTD. Whirled Cinema LTD is a company incorporated under the laws of England and Wales with company number 4173799 and with its registered address at 259 Hardess Street, London, SE24 0HN, England (“we”, “us”, “our”). We are committed to protecting the personal data that we hold and use about you and to respecting your privacy. We are confident that you will find the information that you need set out in this privacy notice, but if you need to know more about the personal data that we hold or the way that we use it, you can contact us by emailing firstname.lastname@example.org.
1. About this privacy notice
2. The way that we use your personal data
a. What personal data do we collect?
b. How do we collect personal data?
c. How do we use personal data, and what is our justification for doing so?
d. How do we share your personal data?
4. Security and retention of your personal data
5. Your rights and how to contact us
6. Changes to this privacy notice
1. About this privacy notice
The "data controller" of your personal data (in other words, the organisation that determines how your personal data is used) is Whirled Cinema Ltd (details are set out above).
2. The way that we use your personal data
A. What personal data do we collect?
This privacy notice gives you information about the way that we use your "personal data". Personal data is any information that could be used to identify you in some way (even if, in some scenarios such as online advertising, we don't know your name). The personal data that we collect from or about you will include the following, depending on the way that you use the Site:
Whenever you visit the Site, we will collect the following personal data:
• technical information about the way that you use our web or mobile services, including the internet protocol (IP) address used to connect your computer to the internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, device information;
• information about your visit to the Site and our other websites, including information about how and when you came to visit the Site, how you interacted with the Site and where you went next (including full URLs and methods used to browse away from the Site).
To help us personalise your experience on the Site, we will also collect other personal data such as:
• information collected from our websites (including the Site) and elsewhere across the internet through cookies, pixel tags, device identifiers and other technologies including information about your habits and behaviour online;
• information about your interests, preferences and demographics (such as age and gender);
• location information related to the device that you use to visit the Site.
If you register on the Site, we will also collect the following information:
• e-mail address;
• phone number;
• other login information.
B. How do we collect personal data?
We (and other organisations that we work with, such as our suppliers and service providers) may collect personal data in a variety of ways including:
• Directly from you:
o Information such as your Site registration details, preferred means of communication and information about services that you request or provide may be collected when you voluntarily provide this information to us (for example when you register as a user of the Site);
o In some cases, (for example when you register to become a member) t will be mandatory for you to provide this information in order for us to respond to your query or provide the information or service that you have requested. Mandatory data fields will be clearly identified on the Site.
• Through your browser or device or through our servers:
Certain information is collected by most browsers or automatically through your device, and we also collect your IP address (this enables us to recognise your computer or device when you use the Site) via our server log files.
• Collecting data from you about other people:
You may be given the opportunity on this Site to submit personal data about other people. For example when applying for a joint membership, we ask that you provide details of the joint member. The types of personal data that you may be given the opportunity to provide about other people may include: their name, age, gender, phone number, address and e-mail address. You must obtain permission from such other people (including by telling them that you will give their personal data to us) before you submit their personal data. When contacting them, we may disclose your identity to them.
C. How do we use personal data, and what is our justification for doing so?
We use your personal data for a variety of purposes related to the products and services that we provide to you or procure from you. From a legal perspective, there are various reasons for doing so. We have set out an explanation of this below.
For purposes related to our business relationship:
• to provide you with the information and services that you request or purchase from us or that you provide to us, to communicate with you regarding those services and respond to your questions and comments;
• to send you by email or other electronic means information about films or services in which you express an interest;
• to send service related information to you and to send you administrative information such as changes to our terms, conditions and policies. It's really important that we are able to send you this kind of information and so we do not give you the option to opt-out of receiving these communications (but we will keep such communications to a minimum);
• to allow you to participate in interactive features of the Site or of our service, when you choose to do so;
• where you choose to receive mobile services and content via SMS, MMS and other mobile services, we use the information collected to deliver such mobile services and content to you, to anticipate and resolve problems with our mobile services and content, to carry out market research, to record sales data and to plan other promotional activities which may be of interest to you. We use your personal data in this way either because we have a contract with you (for example, a contract to provide services to you or procure services from you) or because it is in our legitimate interests to do so (for example, it is in our interests to be able to communicate with certain groups of people in a 'business to business' capacity in order to promote our products and services) but we will always ensure that your rights are protected.
For advertising and marketing purposes, including to measure how effective our marketing is:
• to contact you and let you know about other products and services we offer that we believe you might want to hear about (i.e. to send you marketing materials that we believe will be of interest to you). If you would prefer us not to use your personal data in this way please contact us at email@example.com;
• to measure the effectiveness of our marketing campaigns and our advertising (i.e. so that we can tell what interests people and what doesn't);
• to conduct surveys or obtain your feedback;
• to make suggestions and recommendations to you and other users of our Site about products, services, promotions and offers that may interest you or them;
• to develop a more direct relationship with you for the purposes described in this privacy notice and to develop an online profile of you;
In order to contact you directly with marketing (particularly electronically), we may in some cases need to obtain your consent. In other scenarios (for example, where we send direct
marketing to anyone in a 'business to business' capacity, serving online adverts to you, creating a profile of you to understand more about your interests and preferences; or measuring the effectiveness of our marketing), we will rely on our legitimate interests as a business, always ensuring that your rights are protected.
For administrative and internal business purposes:
• to ensure that content on the Site is presented in the most effective and relevant manner for you and for your device and to tailor the Site’s experience and content based on the way that you use the Site;
• to administer, monitor and improve the Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• for our internal business purposes, such as analysing and managing our businesses, audits, developing new products or services, enhancing the Site, improving our services and products and identifying usage trends.
It is in our legitimate interests as a business to use your personal data in this way. For example, we have a clear interest in ensuring that our Site works properly and that our products and services are high quality and efficient. We will always ensure that your rights are protected.
For security and legal and compliance purposes:
• as part of our efforts to keep the Site safe and secure;
• to detect or prevent fraud or other illegal activity;
• as we believe to be necessary or appropriate in each case in order to comply with laws or legal processes (including laws or legal processes in other countries);
• to protect our rights or property (or the rights or property of others) and to enforce our rights and pursue available remedies.
In some cases, we will need to use your personal data to fulfil a legal obligation (for example, if we receive a legitimate request from a law enforcement agency), and in other cases (such as the detection of fraud or ensuring the security of the Site) we will rely on our legitimate interests as a business to use your personal data in this way.
International transfer of your personal data:
• some of the processes involved in our use of your personal data will require your personal data to be stored or processed in countries outside of the European Economic Area. In particular, your personal data will be transferred to and processed in the United States.
Whenever we send (or permit a third party to send) your personal data outside of the European Economic Area, we will make sure that we take steps necessary to protect your personal data as required by applicable laws. We will ensure that appropriate safeguards are in place by using EU Standard Contractual Clauses or by relying upon the service providers’ participating in an EU approved international data transfer mechanism, including the EU-U.S. Privacy Shield Framework, the adoption of Binding Corporate Rules or another EU approved data transfer mechanism.
Third party links, sponsors and advertisers:
The Site may contain links to other sites that are not covered by this privacy notice and where information practices may be different from ours. We do not own or operate these sites. If you click on any of the links on the Site, you should consult the privacy policies on such third party sites before submitting any personal data, as we are not responsible for and have no control over the manner in which such sites collect, use, disclose, or otherwise process your personal data.
We may offer content or programs on the Site that are sponsored by or co-branded with identified third parties (e.g., competitions, sweepstakes, or promotions). These third parties can obtain personal data that you voluntarily submit to them to make use of the offer. We are not responsible for the collection and use of your personal data by these third parties. However, you will be informed at the point of collection of such personal data, if these third parties will obtain such information, how it will be processed and to whom it will be transferred.
D. How do we share your personal data?
We will never sell your personal data or give it to anyone else for them to use for their own purposes without making that clear to you and obtaining your consent where necessary. There are, however, various ways in which we will share your data, as set out below:
(i) Sharing with organisations providing services to us:
We engage various third parties to provide services to us, and this will often mean that we need to share your personal data with them (it is in our legitimate interests to do so, since we may not have the capabilities or commercial reasons to provide these services ourselves). In each case, we will ensure that these third parties are only allowed to use your personal data in order to provide the relevant services to us. We will always make sure that we use organisations that we trust to look after your personal data appropriately and as required by applicable laws.
By way of example, we may engage service providers to: manage the booking/ payment process for memberships, host the Site or other content or services, operate certain of the Site's features, serve advertisements, send emails on our behalf, run our promotions, conduct customer research, manage and analyse our network status, the responsiveness of our services, and the effectiveness of our advertising, process any online transactions, auditing, and other similar services.
We may also from time to time work with online advertisers, social media platforms and advertising networks to deliver, tailor and measure advertising to you and others both on the Site and elsewhere on the internet (including on social media platforms such as Facebook and Twitter).
((i) Sharing data in connection with changes to our group structure or the ownership of our business:
If we sell or propose to sell our business, we may need to disclose your personal data to prospective buyers. Similarly, if there are changes to our group structure or if our ownership changes, we may need to disclose your personal data to the new owners or operators of the Site as part of that process.
(iii) Sharing data to comply with laws:
There may be scenarios where we are subject to a legal obligation to disclose or share your personal data, such as with law enforcement agencies or public authorities in order to prevent or detect crime.
We, our third party service providers, and trusted partners send "cookies" to your device or use similar technologies to understand and enhance your online experience with us.
Cookies are small text files placed in your browser. We also use pixels or "web beacons" that monitor your use of our Site. Web beacons are small strings of code that provide a method for delivering a graphic image on a webpage for the purpose of transferring data, such as the IP address of the device that downloaded the page on which the web beacon appears, the URL of the page on which the web beacon appears, the time the page containing the web beacon was viewed, the type of browser that fetched the web beacon, and the identification number of any cookie on the device previously placed by that server.
Managing cookies and other technologies. Websites and mobile applications
These cookies are required to enable core site functionality
Strictly necessary cookies or similar technologies:
they are essential in order to enable you to move around our sites or apps and use its features, such as accessing secure areas. Without them, services like enabling appropriate content based on your type of device cannot be provided.
Consent Preferences N/A
These cookies allow us to analyse site usage so we can measure and improve performance
Performance cookies or similar technologies:
they collect information about how you use our sites or apps, so that we can analyse traffic and understand users' interactions. We may use third party service providers such as Google Analytics for this purpose who may use their own cookies or similar technologies. The information is used to improve our Site or apps.
Consent Preferences See your browser settings.
You can avoid the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available via this link (https://tools.google.com/dlpage/gaoptout?hl=en-GB)
Functionality cookies or similar technologies:
they allow our Site or apps to remember choices you make (such as your user name, or the region you are in) and provide enhanced, more personal features. They can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog.
Consent preferences See your browser settings
We do not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.
4. Security and retention of your personal data
(i) Security of your personal data:
We take the security of your personal data very seriously. We have implemented various strategies, controls and measures to keep your data secure and we keep these measures under close review in line with legal and technological developments.
There are ways that you can help – for example, where we have given you (or where you have chosen) a password which enables you to access certain parts of the Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
(ii) Retention of your personal data:
In broad terms, we will only retain your personal data for as long as is necessary for the purposes described in this privacy notice. This means that the retention periods will vary according to the type of personal data and the reason that we have the personal data in the first place. For example, some personal data related to the provision of services to you or by you will be kept for a number of years in order to comply with various finance and tax related legal obligations. Other service related personal data may be kept for a different period because it is in our legitimate interests to do so in order to provide or receive appropriate follow up service.
We have a detailed internal retention policy that sets out varying retention periods for different categories of personal data depending on our legal obligations and whether there is a commercial need. After a retention period has elapsed, the personal data is securely deleted.
5. Your rights and how to contact us
Applicable data protection laws give you a number of rights in relation to your personal data and our use of it. You have the right:
(a) to ask us not to use your personal data for direct marketing purposes;
(b) to ask to see what personal data we hold about you and to find out about the way that we process your personal data (and in some circumstances, you can ask us to provide a copy to a third party);
(c) to ask us to correct or update any personal data which is inaccurate;
(d) to ask for personal data to be deleted in some (but not all) circumstances where there is no good reason for us to continue to use it;
(e) to ask us to temporarily stop using your personal data if you don't believe that we have a right to use it, or to stop us from using your personal data where there is no good reason for us to continue to use it;
(f) not to be subject to decisions made solely on the basis of 'automated processing' (i.e. the right not to be subject to decisions made solely by algorithms or computers without input from a human) in certain circumstances.
If you would like to exercise any of the rights listed above, or if you have any queries or concerns about the way that we use your personal data (or any questions about this privacy notice), you can contact us at admin@whirled cinema.com.
You also have the right to complain about our use of your personal data. You can contact the Information Commissioner's Office.
6. Changes to our privacy notice
Any changes we may make to our privacy notice in the future will be posted on the Site. We may also email you with any changes if we have your email address. Please check back frequently to see any updates or changes to our privacy notice. You can request a copy of the most up to date version of the privacy notice by contacting firstname.lastname@example.org.