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PRIVACY POLICY

Privacy Policy

Empire Cinemas Limited (“we” or “us”) is committed to protecting and respecting your privacy.

This Policy (together with other documents referred to herein) describes what personal information we collect from you and how we process your personal information when you use the empirecinemas.co.uk website (“Website”) or mobile applications (“Apps”).

Personal information we may collect from you;

• We may collect personal information on your visits to the Website including, but not limited to, your IP address, browser, timestamp, traffic data, location data, weblogs, content from surveys and contact forms and other communication data and the resources that you access. Our collection of this personal information will make your visit to the Website easier in the future as we will be able to suggest content that is relevant to you based on the location you access the Website from.

• We may also collect information for marketing purposes and analysis, including information on how you respond to email, phone and other marketing campaigns.

• We will collect any information you provide to us when you use our contact forms (for example “Contact us”, “Contest Entry Forms”). The provision of your personal information via our contact forms is not a statutory or contractual requirement; however, please note that fields marked with an asterisk (*) are mandatory fields, because we need this information to comply with or respond to your request, or to improve your future experiences with us and our Website. Other information or personal information you share with us when completing our contact forms is at your sole discretion. If you contact us, we will keep a record of that correspondence.

• Fields we may request include but are not limited to: your First name, Last name, Email Address, who you’ll like to contact and your local Empire Cinema.

• We use your personal information to send you direct marketing via email and other communication means when you opt-in for this during the ‘MyEmpire’ sign up. You may opt-out of receiving future marketing communications at any time by amending your communication preferences within your ‘MyEmpire’ profile.

• Any debit/credit card data entered into our website is transmitted directly to our card processing acquirer and no card data is passed through or retained by any internal Empire Cinema’s systems. This is to ensure that we remain compliant to PCI-DSS specification 3.2.1

• We may also store cookies as set out in more detail in our Cookie Policy

How we use your personal information

Your personal information will be collected and handled by us for the following purposes:

• to best tailor content and resources according to your preferences.
• to respond to your request or questions when you contact us.
• with your consent, we may also use your contact data for direct marketing to inform you about local promotions, details of film schedules at your favourite Empire cinema or to notify you of contest results (we will communicate by email, telephone, mail and/or other communication methods).
• to send to you other information – such as Empire Cinemas upcoming events or newsletters – that may be of interest to you.
• to help us create, publish, and improve content most relevant to you.
• to ensure that the content provided through the Website is presented in the most effective manner for you and for your device.
• to allow you to participate in interactive features of our Website, when you choose to do so.
• to further develop and improve the Website and systems to better serve you. This mainly takes place in the context of new IT systems and processes so that information about you may be used in the testing of those new IT systems and processes where dummy data cannot fully replicate the operation of the new IT system.
• to perform analytical research on our customer base, including the content, and the films/retail offerings they are interested in
• to share data with third parties (see below)

In all instances, Empire Cinemas will only undertake the processing of your data where it’s necessary for the performance of a contract; to process your online purchase or where processing is necessary for the purposes of legitimate interests pursued by Empire Cinemas, allowing us to provide you with the best products and service in the most secure and appropriate way.

Do you have to give us the personal information we ask for?

You are not obliged to provide your personal information to us when generally navigating our website, however we will be unable to fulfil any ticket purchases if personal information isn’t given.
Do we process information about you without any human intervention at all?

Yes, at times we may use automated systems/processes and automated decision-making (like profiling) to ensure you have a bespoke experience.

How long do you keep my personal information for?

We will keep your information for as long as you wish to receive our communications and thereafter for the longer of the period required in order to meet our business, legal or regulatory responsibilities. For the purposes of ‘MyEmpire’, data is only retained whilst your account remains active. Upon closure, all data is purged from our databases and is not thereafter recoverable.

Sharing with third parties.

We may also share your data with the following categories of selected trusted third parties in accordance with this Privacy Policy:

• Service providers (for example, IT services), business partners, suppliers and sub-contractors for the performance of any contract we enter into with you (such as, but not limited to, Website operations, payment services, fraud investigations and affiliate and rewards programs);
• Analytics and Search engine providers that assist us in the improvement and optimisation of the Website;
• law enforcement or regulatory agencies, or authorised third parties, in response to a verified request relating to a criminal investigation or alleged illegal activity or any other activity through the Website that may expose us and/or the user or any third party to legal risks or liability; and these third parties who may receive your data will process that data for the purposes specified above and in accordance with applicable law. We will retain a list of the third parties with whom data is shared, which will be available upon request.

Data Security

Although we will do our best to protect your personal information, you should be aware that the transmission of information via the internet is not completely secure and we cannot guarantee the security of your personal information transmitted to the Website or any third party; for this reason, any transmission is at your own risk. We will use strict operational procedures and adequate, technical and organisational security measures to prevent any unauthorised access, change, deletion or transmission of this personal information.

What are your rights?

Under applicable data protection laws, you have the following rights:

• Access. You have the right to access data we hold about you as well as an updated list of the individuals who can access your data. You will need to prove your identity before we release any personal data to you.
• Rectification. You have the right to request that we rectify any data which we hold about you. Where applicable, this can be done via a self-serve basis via ‘MyEmpire’ or by contacting us.
• Erasure. You have a right to have your personal data erased. Upon closing your ‘MyEmpire’ account, all data is destroyed and un-recoverable. Any data received as a result of a transaction occurring on the Empire Cinemas website will be kept as long as legally required to do so.
• Restriction. You have the right to restrict our use of personal information if the data is inaccurate, our use of the information is unlawful or if we no longer need to use the data for the purposes for which we hold it.
• Data Portability. You have the right to have your personal data presented in an electronic format and to transmit such data to another data controller, where this is (a) personal data which you have provided to us and (b) if we are processing that data on the basis of your consent (such as your marketing preference information)

To exercise any of your rights, please contact our Data Protection Officer.

Marketing communications

We will only send marketing communications to you via email or other means where you have consented that we may do so.

We will usually offer a check box on the forms we use to collect your personal information where, if you agree to receive marketing communications, you have to click the box. Where we send marketing communications to you via email, you may opt out of receiving any further marketing communications by clicking the ‘unsubscribe’ or ‘opt-out’ function in the email.

In addition, you can also exercise your opt-out right at any time by amending your communication preferences in your ‘MyEmpire’ account.

Changes to this Policy
The terms of this Policy may change from time to time. Any changes will be published on this page so that you are always aware of what information we collect, how we use it and under what circumstances we disclose it.

Contact
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to our Data Protection Officer.

Empire Cinemas Limited
Updated May 22nd 2018