Defined terms are in bold. They are defined where they are introduced in ‘quotes’.
We are Cinegi Media Limited (‘we’, ‘us’, ‘our’, ‘Cinegi’, ‘the company’) a company:
- registered in England and Wales under company number 5370952 with registered office is at 727-729 High Road, London N12 0BP, United Kingdom and
- trading from Exchange at Somerset House, South Wing, Somerset House, Strand, London WC2R 1LA.
EITHER You are using some combination of:
- the website at http://cinegi.com (‘site’)
- the Cinegi player application (‘player’)
- our support service by phone and email (‘support’)
Together, these make up the Cinegi ‘service’ which enables people to book, pay for and report back on public screenings of filmed media in your own or someone else’s venue. By ‘public screenings’ we mean events at which filmed media is exhibited to an audience in a public place or to which members of the public are admitted.
OR You have contacted us to express an interest in or enquire about using the service
OR You are a professional identified on a publicly available website as having a role in an organisation which does (or appears likely in the future to do) public screenings, or for which public screenings falls into its policy, funding, public benefit or commercial interests
OR Your information has been passed to us by a network of cultural, film or community organisations and you appear to be a professional with a role as a in an organisation in their network which does (or appears likely in the future to do) public screenings, or for which public screenings falls into its policy, funding, public benefit or commercial interests
By ‘professional’, we mean someone who has a role in an incorporated body, like a limited company or charity.
We are bound by ‘data protection and privacy legislation’ by which we mean the Data Protection Act 1998, General Data Protection Regulations (GDPR), Privacy and Electronic Communications Regulations (PECR) and any later legislation enacting, re-enacting, amending or consolidating these regulations.
We are the ‘data controller’ of information about you (as this term is defined in data protection and privacy legislation). This means we are responsible for deciding how that information is processed and for what purposes.
Under data protection and privacy legislation, we are also responsible for information about you being processed lawfully, fairly and responsibly – to keep records of how we are doing that and to ensure you are aware what data about you we are processing, and how.
Information we may hold about you
We may collect and process the following data about you:
- Information that you provide when you register, including your contact details, address and the organisation you work with
- Details you give us when you make a booking, including the programme, screening location, date and time and other information
- Details of other programmes you have created on the site
- Details of other potential screening locations you enter into your profile
- Details of public screenings you have put on that you give us when you do your ‘return’ including the number of tickets sold, amount of money taken and your feedback
- The invoices we issue you
- Details of how many times and when you have played and test played content within the player
- Details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data and the resources that you access
- Email and postal correspondence between you and us and/or our notes of phone calls with you
- Information about IT systems you are using that you give us or allow us to collect when you use our support
- Details of payments you make to us (excluding your credit card information, see below).
Data that we or our research partners collect for research purposes are covered a by separate privacy policies (see ‘Research’ section below).
If your contact details change, please update them at http://cinegi.com/account_details.
How we will use your data
We will use information about you for the purposes of:
- providing you with the service
- fulfilling our obligations to you for a screening you have booked
- managing and improving the service and the company
- reporting to organisations that fund us to demonstrate the impact of their funding and to fulfil our other obligations under our legal agreements with them
- maintaining company, financial and tax records as required by law
- protecting the filmed media content within the service and rights in it held by us and other rightsholders from use which is unlawful or outside the bounds of any licence we may grant you – or otherwise enforcing the rights we or our rightsholders may have under the terms and conditions of the service – including preventing fraud and copyright theft.
Any feedback you give us we can use in public communications. But we won’t do so in such a way that people would know it was from you – unless we get your permission.
We would like to be able to contact you with marketing communications by email or phone for the purpose of promoting the service and its catalogue. These will, for example, let you know about our latest content, suggested programmes and any promotions – together with news about and details of enhancements to the service.
When you register your interest in doing public screenings by signing up for a Cinegi account, you can opt out from marketing communications by email and opt in to marketing communications by phone.
If you do not wish to receive such marketing communications, you can opt out at any time by changing your preferences at http://cinegi.com/account_details, for emails by using the unsubscribe feature in any marketing email we send you – or send us an email at email@example.com.
Even if you have opted out from marketing communications, as long as you are signed up to the service, we will still keep on sending you emails necessary for us to provide the service to you, for example, about changes to the service or your account.
While you are opted in to receive marketing communications, we will store records of what emails we have sent you and phone calls we have made and how you have engaged with them.
We are conducting an action research project – called ‘Cinegi Arts&Film’ – to test how a digital distribution service such as this can bring filmed arts and cultural content to new and wider audiences as a shared experience in non-traditional venues. It is supported by Arts Council England, in partnership with the British Film Institute.
It is a condition of the funding of the project that we conduct research with organisations and individuals using the service and people attending public screenings (‘audiences’). We are working with the Audience Agency and Nesta (our ‘research partners’) to do this. Where you can, we would like you to help us and our research partners conduct that research.
More detail on the research we would like to do with you and your audiences, how we would like you to help and related guidance is available at http://cinegi.com/arts_and_film/research_guidance.
Where we will store your data
The information about you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers:
- our web hosting sub-processor, Amazon Web Services (although our actual hosting with them is based in the EU in Ireland)
All information you provide to us is stored on our secure servers. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We may also store it to, either to include you in marketing communications if you have opted in to those, or to ensure you are not contacted for marketing communications if you have opted out.
Technical data collected
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
Disclosure of your information
We will only share any of your personal information with law enforcement agencies or other organisations or individuals if we are obliged to by law or if this is required in order to enforce or protect any of our rights, property or safety (or those of rightsholders providing content to us or other users of the service).
If we need to transfer your personal information to countries which do not provide the same level of data protection as the UK we will put a contract in place to ensure that your information is adequately protected.
Cookies are text files placed on your computer by a website when you use it to collect standard internet log information and information about the behaviour of visitors to that website. They are also often used by many websites when you are logged into them to remember as you move between pages what you are in the middle of doing (eg shopping baskets, or what you were looking at).
We will use the information we collect as a result of you accepting a cookie from our site to track your use of the site and to compile reports on the use of the site overall by all visitors.
You can set up your browser not to accept cookies – and the websites above tell you how to remove cookies from your browser. However, if you do this, many features of the site once you are logged in – like booking screenings or creating programmes – will not work properly.
How long we keep your information
Information about your registration, bookings, returns, programmes, locations and support issues – and other information you provide via the service or which is generated by your use of the service – we will keep as long as you are signed up to the service. We will normally then keep it until the end of the financial year after when you stopped, in case you want any of that information or want to reactivate your account and to fulfil our obligations to rightsholders in the content within the service to audit the use of their content in screenings. We would only keep it longer if it were necessary to enforce our or our rightsholders rights under the terms and conditions of the service through an ongoing investigation.
We will keep financial information arising from you using the service – including invoices, payment details and email correspondence relating to finance – for as long as we are obliged to by law, which is currently for 6 years after the end of the financial period in which they fall.
If you opt out of marketing communications from us, we will keep only enough information to identify you and that decision, to enable us to ensure that you do not receive any further marketing communications from us.
The legal bases for us to process your personal data
Information about your registration, bookings, returns, programmes, locations and support issues we process in order to fulfil our obligations to you under the terms and conditions to deliver the service.
Your answers to research questions in your registration, bookings and returns we process under our legitimate interest to manage and improve the service and company and to provide information which supports funders and organisations producing filmed media content in their work with the ultimate benefit of the public having access to a greater variety of filmed media. On occasion, we may also phone you to conduct research. You have the right to object to either of these uses of your data.
If you are a professional, we will send you marketing communications by email under our legitimate interests to encourage venues or event promoters to book content for screenings, the interests of rightsholders to have their content been seen by audiences and in the interests of audiences to have a variety of content to see at screenings. If the email address we’re using is clearly associated with you as an individual, you have the right to object to us using it for direct marketing.
We may – on occasion – as a professional phone you to promote the service, under our legitimate interests to encourage venues or event promoters to book content for screenings and the interests of our rightsholders to have their content been seen by audiences. You have the right to object to such calls. We will not contact you again for that purpose if you have objected.
If you are a ‘private individual’ (that is, not a professional by our definition above), we will send marketing communications to you by email where we have your consent. You have the right to withdraw this consent at any time. If we are mistakenly treating you as a professional, but in fact you don’t have a role in a relevant organisation or that organisation is not incorporated – for example, it’s just a name you use as a sole trader, you trade through a partnership or you involved in an unincorporated association – let us know and we will ensure we have your consent for any marketing communications.
Under data protection and privacy legislation you have various rights.
You have the right to request a copy of the information that we hold about you. In that case, please send a copy of your ID (passport or driving licence) to us at firstname.lastname@example.org, with ‘subject access request’ in the subject line of the email.
We want to make sure that the information we hold about you is accurate and up to date. You have the right to ask us to correct, complete or remove information you think is inaccurate or incomplete. In that case please send a copy of your ID (if we haven’t got it already) to us at email@example.com, with details of what amends you propose and evidence that these are accurate – and ‘personal data rectification’ in the subject line of the email.
In certain circumstances you may have the right to ask us to delete information we hold about you, or suspend or restrict its processing or object to its processing. In these cases, please contact us at firstname.lastname@example.org explaining what you want us to do – and why.
You may have the right to request information about you in a portable format. This applies to only to data you have provided us which we process in automated systems either with your consent or in able to fulfil our responsibilities under a contract with you.
We will do everything we reasonably can to ensure that you are satisfied with the way we have responded to you about your personal data and privacy. So, please do tell us if you are not so we can rectify the any outstanding issue. If you are still not satisfied, you have the right to complain to the Information Commissioner’s Office (ICO) – see https://ico.org.uk/concerns/handling/.