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Welcome to Savoy Cinemas Ltd.’s Privacy Policy.

What does this Privacy Policy Cover?

Savoy Cinemas Ltd respects your privacy and is committed to protecting your Personal Data. We want to

be transparent with you about how we collect and use your Personal Data in making available our apps

and websites (“Site”) and tell you about your privacy rights and how the law protects you.

With that in mind, this Privacy Policy is designed to describe:

 Who we are and how to contact us.

 Your rights relating to your Personal Data.

 Marketing communications preferences.

 What Personal Data we collect.

 How we use your Personal Data and why.

 What happens when you do not provide necessary Personal Data?

 [Personal Data from Third Party Sources.]

 How we use cookies and other tracking or profiling technologies.

 Who we share your Personal Data with.

 How we keep your Personal Data secure.

 How long we store your Personal Data.

 Our policy on children.

 Third party links.

This Privacy Policy aims to give you information on how Savoy Cinemas Ltd collects and processes your

Personal Data through your use of this Site, including any data you may provide through this Site.

The Privacy Policy is intended to meet our duties of Transparency under the “General Data Protection

Regulation” or “GDPR”.

We will post any modifications or changes to this Privacy Policy on this page.

Who we are and how to contact us.

Who we are.

Savoy Cinemas Ltd is the Controller (for the purposes of the GDPR) of your Personal Data (referred to as

either “COMPANY”, “we”, “us” or “our” in this Privacy Policy).

Our address is: 233 Derby Road, Nottingham, NG7 1QN.

How to contact us.

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You can contact us by emailing: office@savoyonline.co.uk.

Your rights relating to your Personal Data.

By law you have the right to:

 Request access to your Personal Data. This enables you to receive a copy of the Personal

Data we hold about you and to check that we are lawfully processing it.

 Request correction of the Personal Data that we hold about you. This enables you to have

any incomplete or inaccurate information we hold about you corrected.

 Request erasure of your Personal Data. This enables you to ask us to delete or remove

Personal Data where there is no good reason for us continuing to process it. You also have the

right to ask us to delete or remove your Personal Data where you have exercised your right to

object to processing (see below).

 Object to processing of your Personal Data. This right exists where we are relying on a

Legitimate Interest as the legal basis for our processing and there is something about your

particular situation, which makes you want to object to processing on this ground. You also have

the right to object where we are processing your Personal Data for direct marketing purposes.

 Request the restriction of processing of your Personal Data. This enables you to ask us to

suspend the processing of Personal Data about you, for example if you want us to establish its

accuracy or the reason for processing it.

 Request the transfer of your Personal Data. We will provide to you, or a third party you have

chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that

this right only applies to automated information which you initially provided consent for us to use

or where we used the information to perform a contract with you.

 Withdraw consent. This right only exists where we are relying on consent to process your

Personal Data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to

provide you with access to the certain specific functionalities of our Site. We will advise you if this

is the case at the time you withdraw your consent.

How to exercise your rights

If you want to exercise any of the rights described above, please contact us using the contact details

shown here.

Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other

rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your

request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in

these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your

right to access your Personal Data (or to exercise any of your other rights). This is a security measure to

ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also

contact you to ask you for further information in relation to your request to speed up our response.

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We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a

month if your request is particularly complex or you have made a number of requests. In this case, we will

notify you and keep you updated.

Complaints

If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your

Personal Data, please contact us at: office@savoyonline.co.uk

We will reply to your complaint as soon as we can.

If you feel that your complaint has not been adequately resolved, please note that the GDPR gives you

the right to contact your local data protection supervisory authority, which for the UK, is the Information

Commissioner’s Office.

Marketing communications preferences.

You can ask us to stop sending you marketing messages at any time by logging into the Site and

checking or unchecking relevant boxes to adjust your marketing preferences] AND/OR [by following the

opt-out links on any marketing message sent to you.

Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided

to us as a result of service emails” – e.g., a transaction confirmation email.

What Personal Data we collect.

All the Personal Data we collect, both from you and from third parties about you, is outlined in the table

below.

Before you read that table, it might be useful to explain what “Personal Data” is. The GDPR definition of

Personal Data can be found here. Essentially, it boils down to: information about an individual, from which

that individual is either directly identified or can be identified.

It does not include ‘anonymous data’ (i.e., information where the identity of individual has been

permanently removed).

However, it does include ‘indirect identifiers’ or ‘pseudonymous data’ (i.e., information which alone

doesn’t identify an individual but, when combined with certain additional and reasonably accessible

information, could be attributed to a particular person).

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Category of

Personal Data

collected

What this means

Identity Data

Name, title, date of birth.

Contact Data

Given address, email address and telephone number.

Financial Data

Partial payment card details.

Transaction Data

Any details about payments to and from you and other details of subscriptions

and services you have purchased from us. Data in respect of your transactions

with third parties.

Marketing and

Communications Data

Your preferences in receiving marketing from us and our third parties and your

communication preferences.

Behavioural Data

Inferred or assumed information relating to your behaviour and interests, based

on your online activity. This is most often collated and grouped into “segments”

(e.g., there may be a segment for men, living in London and aged under 25, who

like sports).

Technical Data

Internet protocol (IP) address, your login data, browser type and version, time

zone setting and location, browser plug-in types and versions, operating system

and platform and other technology on the devices you use to access this

website or use our services.

Aggregated Data

We also collect, use and share “Aggregated Data” such as statistical or demographic data for any

purpose. Aggregated Data may be derived from your Personal Data, but once in aggregated form it will

not constitute considered Personal Data for the purposes of the GDPR as this data does not directly or

indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal

Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which

will be used in accordance with this Privacy Policy.

No Special Categories of Personal Data

We do not collect any “Special Categories of Personal Data” about you (this includes details about your

race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade

union membership, information about your health and genetic and biometric data). Nor do we collect any

information about criminal convictions and offences.

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How we use your Personal Data and why.

We will only use your Personal Data for the purposes for which we collected it as listed below, unless we

reasonably consider that we need to use it for another reason and that reason is compatible with the

original purpose.

If we need to use your Personal Data for an unrelated purpose, we will update this Privacy Policy and we

will explain the legal basis which allows us to do so.

What is our “legal basis” for processing your Personal Data?

In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure

that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases:

 Where we need to perform a contract we are about to enter into or have entered into with you

(“Contractual Necessity”).

 Where it is necessary for our legitimate interests and your interests and fundamental rights do not

override those interests (“Legitimate Interests”). More detail about the specific legitimate interests

pursued in respect of each Purpose we use your Personal Data for is set out in the table below.

 Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).

 Where we have your specific consent to carry out the processing for the Purpose in question

(“Consent”).

Generally we do not rely on your Consent as a legal basis for using your Personal Data other than in the

context of direct marketing communications.

We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes

for which we use your Personal Data.

Purpose

Category(ies) of

Personal Data

involved

Why do we do this

Our legal basis for

this use of data

Account Creation

 [Identity Data

 Contact Data]

To register you as a new

customer.

Contractual Necessity.

To process payments

for subscriptions to the

Sites (and their

associated services

and functionalities)

 Identity Data

 Contact Data

 Finance Data

 Transaction Data

To process and deliver your

order including manage

payments, fees and charges.

Contractual Necessity.

Fraud Prevention

 Identity Data

 Contact Data

 Technical Data

To keep our website, our

services and associated

systems operational and

Legitimate Interests.

We have a legitimate

interest in ensuring

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secure.

the ongoing security

and proper operation

of our services,

website and

associated IT services

and networks.

Troubleshooting

 Identity Data

 Contact Data

 Technical Data

To track issues that might be

occurring on our systems.

Legitimate Interests.

It is in our legitimate

interests that we are

able to monitor and

ensure the proper

operation of our Sites

and associated

systems and services.

Marketing

 Identity Data

 Contact Data

 Marketing and

Communications

Data

To form a view on what we

think you may want or need,

or what may be of interest to

you. This is how we decide

which services and offers

may be relevant for you.

Legitimate Interests.

We have a legitimate

interest in providing

you with updates on

our Sites and related

offers where you have

purchased or shown

interest in similar

services from us.

What happens when you do not provide necessary Personal

Data?

Where we need to process your Personal Data either to comply with law, or to perform the terms of a

contract we have with you and you fail to provide that data when requested, we may not be able to

perform the contract we have or are trying to enter into with you (for example, to provide you with the

functionalities of the Site).

In this case, we may have to stop you using our Site have with us but we will notify you if this is the case

at the time.

[Personal Data from Third Party Sources]

[In addition to the Personal Data that we collect directly from you (as described in the section immediately

above this one), we also collect certain of your Personal Data from third party sources. These sources are

broken down in the table below, together with a description of whether they are publicly available or not.]

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Third party data

source

Publicly

available?

Category(ies) or other types of

personal data received.

Social Media sites

Yes

 Identity Data

 Contact Data

Our Affiliates

 Identity Data

 Contact Data

 Marketing and Communications Data

Analytics Providers

 Behavioural Data

 Technical Data

Advertisers

 Behavioural Data

 Technical Data

How we use cookies & other tracking or profiling

technologies.

Cookies.

What are cookies?

We may collect information using “cookies”. Cookies are small data files stored on the hard drive of your

computer or mobile device by a website. We may use both session cookies (which expire once you close

your web browser) and persistent cookies (which stay on your computer or mobile device until you delete

them) to provide you with a more personal and interactive experience on our Site.

We use two broad categories of cookies:

 first party cookies, served directly by us to your computer or mobile device; and

 third party cookies, which are served by our partners or service providers on our Site.

Cookies we use

Our Site uses the following types of cookies for the purposes set out below:

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Type of cookie

Purpose

Essential

These cookies are essential to provide you with services available through our Site

and to enable you to use some of its features. For example, they allow you to log in

to secure areas of our Site and help the content of the pages you request to load

quickly. these cookies, the services that you have asked for cannot be provided, and

we only use these cookies to provide you with those services.

Functionality

These cookies allow our Site to remember choices you make when you use our Site,

such as remembering your language preferences, remembering your login details

and remembering the changes you make to other parts of our Site which you can

customise. The purpose of these cookies is to provide you with a more personal

experience and to avoid you having to re-enter your preferences every time you visit

our Site.

Analytics and

Performance

These cookies are used to collect information about traffic to our Site and how users

use our Site. The information gathered via these cookies does not “directly” identify

any individual visitor. However, it may render such visitors “indirectly identifiable”.

This is because the information collected is typically linked to a pseudonymous

identifier associated with the device you use to access our Site. The information

collected is aggregated and anonymous. It includes the number of visitors to our

Site, the websites that referred them to our Site, the pages they visited on our Site,

what time of day they visited our Site, whether they have visited our Site before, and

other similar information. We use this information to help operate our Site more

efficiently, to gather broad demographic information and to monitor the level of

activity on our Site.

We use Google Analytics for this purpose. Google Analytics uses its own cookies. It

is only used to improve how our Site works. You can find out more information about

Google Analytics cookies here:

https://developers.google.com/analytics/resources/concepts/gaConceptsCookies

You can find out more about how Google protects your data here:

www.google.com/analytics/learn/privacy.html.

Targeted and

advertising

These cookies track your browsing habits to enable us to show advertising which is

more likely to be of interest to you. These cookies use information about your

browsing history to group you with other users who have similar interests. Based on

that information, and with our permission, third party advertisers can place cookies

to enable them to show adverts which we think will be relevant to your interests

while you are on third party websites.

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Social Media

These cookies are used when you share information using a social media sharing

button or “like” button on our Site or you link your account or engage with our

content on or through a social networking website such as Facebook, Twitter or

Google+. The social network will record that you have done this.

Disabling cookies

You can typically remove or reject cookies via your browser settings. In order to do this, follow the

instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility).

Many browsers are set to accept cookies until you change your settings.

If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For

example, we may not be able to recognise your computer or mobile device and you may need to log in

every time you visit our Site.

Further information about cookies, including how to see what cookies have been set on your computer or

mobile device and how to manage and delete them, visit www.allaboutcookies.org and

www.youronlinechoices.com.uk.

In particular, you can disable cookies which remember your browsing habits and target advertising at you

by visiting http://www.youronlinechoices.com/uk/your-ad-choices. If you choose to remove targeted or

advertising cookies, you will still see adverts but they may not be relevant to you. Even if you do choose

to remove cookies by the companies listed at the above link, not all companies that serve online

behavioural advertising are included in this list, and so you may still receive some cookies and tailored

adverts from companies that are not listed.

You can also prevent the use of Google Analytics relating to your use of our Site by downloading and

installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB]

Who we share your Personal Data with.

The table below describes who we share your Personal Data with, what we share and why we share it.

Recipients

Category(ies) of Personal Data

we share.

Why we share it

Location(s)

Service

Providers

 Identity Data

 Contact Data

 Technical Data

Our service providers

provide us with IT and

system administration

services.

 Within the UK

Professional

advisers

 Identity Data

 Contact Data

Our lawyers, bankers,

auditors and insurers

provide consultancy,

banking, legal, insurance

 Within the UK

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and accounting services.

HM Revenue &

Customs,

regulators and

other authorities

 Identity Data

 Contact Data

Authorities may require

reporting of processing

activities in certain

circumstances

 Within the UK

Film Distributors

 Identity Data

 Contact Data

Competition Winners

For the purposes of prize

fulfilment only

 Within the UK

Data transfers

As you can see from the above, we do not transfer your Personal Data to any parties located outside the

European Economic Area. This is includes our staff, representatives and advisors.

How we keep your Personal Data secure.

We have put in place appropriate security measures to prevent your Personal Data from being

accidentally lost, used or accessed in an unauthorized way, altered or disclosed.

We limit access to your Personal Data to those employees and other staff who have a business need to

have such access. All such people are subject to a contractual duty of confidentiality.

We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event

of any such breach, we have systems in place to work with applicable regulators. In addition, in certain

circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your

Personal Data.

How long we store your Personal Data.

We will only retain your Personal Data for so long as we reasonably need to use it for the purposes set

out above, unless a longer retention period is required by law (for example for regulatory purposes).

The table below shows our standard retention practices:

Category of Personal Data

Retention period

Behavioural Data

36 months from the date of last purchase.

Marketing and Communications Data

For so long as you remain a customer of ours.

Contact Data

For so long as retention is necessary to fulfil the Purposes/Use

for which it is used (see here).

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Our policy on children.

This Site is not intended for children below 16 and we do not knowingly collect data relating to such

children.

Third party links.

This Site may include links to third-party websites, plug-ins and applications. Clicking on those links or

enabling those connections may allow third parties to collect or share your Personal Data. We do not

control these third-party websites and are not responsible for their privacy statements. When you leave

our Site, we encourage you to read the privacy policy of every site you visit.

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