Privacy Policy Contents



Privacy Policy


Last updated November 2023

We respect the privacy of every person who visits or registers with picturehouses.com, spotlight.picturehouses.com/ or uses the Picturehouse mobile applications for iPhone and Android (the "Sites") and who uses the services that we make available from the Sites, in our cinemas, on our telephone booking line or through our customer services facilities (our "Services") and we are committed to ensuring a safe online experience.


1. PURPOSE OF THIS POLICY

This privacy policy ("Privacy Policy") explains our approach to any personal information 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 basis upon which we process your personal information. This Privacy Policy also sets out your rights in respect of our processing of your personal information.

This Privacy Policy will inform you of the nature of the personal information 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 & Conditions and our Terms of Admission

Please also note that this Privacy Notice only applies to the use of your personal information obtained by us, it does not apply to your personal information collected during your communications with third parties.

This Privacy Notice may vary from time to time so please check it regularly. Please see Changes to this Privacy Notice below for further details.

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2. WHO ARE WE AND WHAT DO WE DO?

The Sites and our Services are operated by Picturehouse Cinemas Limited ("we", "us" or "our").

We are a controller of your personal information obtained in connection with the provision of our Sites and Services and your personal information will be used in accordance with this Privacy Notice.

Picturehouse Cinemas Limited is an English company with registered company number: 2310403 and whose registered office is at 8th Floor, Vantage London, Great West Road, Brentford, TW8 9AG, United Kingdom

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3. 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 to: enquiries@picturehouses.co.uk;
  • calling us on: 020 7326 2649;
  • writing to us by post to: Head of Customer Services, 7th Floor, St Vincent House, 30 Orange Street, London, WC2H 7HH.
Our Data Protection Officer may be contacted by email at: dpo@cineworld.co.uk or by post at: F.A.O. Data Protection Officer, Picturehouse Cinemas, 8th Floor, Vantage London, Great West Road, Brentford TW8 9AG.


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4. WHAT PERSONAL INFORMATION DO WE COLLECT AND HOW DO WE USE IT?

We obtain your personal information 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, such as CCTV or other recording systems, cookies, server logs and other similar technologies;
  • 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 information 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 Information do we collect and how do we use it? section.

Our primary goal in collecting personal information about you is to: (i) provide our Services to you and carry out requests made by you on the Sites or in our cinemas; (ii) verify your identity and age; (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 or permitted by law.

In particular, we use your personal information for the following purposes:




4.1 FULFILMENT OF PRODUCTS AND SERVICES

We collect and maintain personal information 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 registration for an account with us, your attendance at events hosted by us or our third-party partners, your 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 and your email address. We may also need this information when you make any other purchases via our Sites, such as ordering food, drink, or 3D glasses.

If you wish to purchase a gift 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.

We use this information to process and fulfil your orders and to send you service-related emails 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.

If you choose to pay for your purchases on our websites:
  • by credit, debit or charge card those payments will be processed by our payment provider, PayPal (t/a Braintree), rather than by us. When processing your payments on our behalf, PayPal acts as an independent data controller of your personal information and its own privacy statement, available at www.braintreepayments.com/gb/legal/braintree-privacy-policy, will apply. This also applies where you make purchases by phone via our customer services team.
  • by Picturehouse gift card, e-gift code or other promotional code to pay for your purchases those payments may be processed by our gifts and promotions service providers, rather than by us.
  • using your PayPal account or, where available, your Google Pay or Apple Pay account you will be transferred to the payment provider's platform and the payment information and processing activities will be subject to the payment provider's privacy notice as they will be the controller of your personal information, not Picturehouse. The PayPal privacy notice is available at www.paypal.com/myaccount/privacy/privacyhub.

We may also receive part of the payment details such as your name, email address and some of the digits of your payment card number from our payment processor. These will be used to help connect your payment with your booking on our Site and may also be used by us if we provide you with a refund.


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 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.

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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 online ticket booking, Picturehouse membership and subscription to our newsletter and marketing emails) have age restrictions attached to their use. These age restrictions are explained in the terms and conditions relating to Picturehouse Membership Terms and Conditions and our Terms of Admission (Online Purchases section).

This means that we may need to ask you to provide your date of birth.

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 information 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, we do so because this is necessary for us to comply with legal obligations to which we are subject. When you use our Services, it is also necessary for us to process your personal information for the purpose of performing our contract with you.

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4.3 PROVIDING AND ADMINISTERING ACCOUNTS

If you register for an account (such as a MyPicturehouse account) on our Sites, we may ask you to provide your name, gender, e-mail address, home address and your favourite or local cinema. We will also ask you to provide a password for your account. You can also voluntarily provide us with additional information when using your account, for example your phone numbers. You can update and amend the contact details and some other personal information we hold about you at any time through your account.

We will use this personal information to provide you with the online functions available within the account, including facilitating your purchase of our products and services via your account. This personal information 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 information 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 account.

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4.4 PROVIDING OUR PICTUREHOUSE MEMBERSHIP SCHEME

If you purchase Picturehouse membership for yourself, we will collect and use personal information about you in accordance with the purposes described in Sections 4.1 to 4.3 of this Privacy Policy. If you choose to set up automatic renewal by paying the membership subscription fee by recurring card payment or (where available) annual direct debit, we will need your payment card details to set up your continuous payment authority or your bank details to set up your direct debit and take payment from you.

When you register for Picturehouse membership we will set up an online My Picturehouse account for you. You can use your My Picturehouse account to access your Picturehouse membership, for example when booking online, and also manage your membership details such as updating your personal details, changing your saved payment card and subscribing/unsubscribing to our newsletter, special announcements and other email communications. Please see the 'Providing and administering accounts' section for further details.

As a part of your membership service, we will use your contact details to send you service communications, including information about your membership such as renewal reminders, account information, changes to Membership benefits and sometimes details of new cinema openings or changes or additions to our selection of Local and National Partners. 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, special announcement emails and other news and offers emails from Picturehouse which may include details of offers from our sister company Cineworld Cinemas Limited and other Picturehouse partners. Please see the Marketing Communications section for further information.


What is our legal basis?

Where you have purchased a Picturehouse membership, 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 purchase, automatic renewals or use of Picturehouse membership. Please see the Marketing Communications section for the legal basis upon which we may send you marketing communications.

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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 may 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.

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4.6 COMPETITIONS, PRIZE DRAWS AND THE 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 information volunteered by you in your promotion entry. 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 information 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 information 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.

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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.

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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, or from your use of our in-cinema wifi.

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 (below) 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 consent to do so, we will also use your location data for customer insight purposes.

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, websites and app design and development, to identify appropriate partners whose offers we might obtain for you as a Picturehouse customer and to remember your customer preferences.

We also use this information for marketing purposes (see the marketing section below for further details)


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 information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy (below) for further details.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best products and services to you and our other customers.

We will only use your location data for customer insight purposes where we have your consent to do so.

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4.9 MARKETING COMMUNICATIONS

We carry out the following marketing activities using your personal information:


Postal marketing.

We use your contact details to send you the Picturehouse newsletter and other marketing communications by post, but usually only where you have asked us to do so.

What is our legal basis?

Where your personal information is not in an anonymous form, such as your postal address, it is in our legitimate interest to use your personal information for postal marketing if you have requested this. You can unsubscribe from receiving such marketing by amending your preferences online in your My Picturehouse account or by contacting our customer services department using the contact details in the How to Contact Us? section above.


Email 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 to send you marketing communications by email, 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 information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

We will only send you marketing communications via email where you have consented to receive such marketing communications, or where we have a lawful right to do so. If you are an existing current member of Picturehouse Cinemas prior to 25th May 2018 then you may have been asked to consent to receive marketing communications from us when registering with us. As you are an existing member we will not be relying on this consent instead we will be relying on our legitimate interest to continue to send you marketing communications as an existing member. You can unsubscribe at any time by clicking on the unsubscribe button on the marketing communication or visiting the "preferences' section of your My Picturehouse account on our Site here.

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 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) to provide you with personalised advertising on social media channels operated by Meta 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 Meta 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 information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.


Social media insight.

Where you are a registered user of Facebook, or of a Google service, we will 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:
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 information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.


Use of Anonymised Personal Information

Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

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4.10 BUSINESS ADMINISTRATION AND LEGAL COMPLIANCE

We use your personal information 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.

What is our legal basis?

Where we use your personal information 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 information to comply with any legal obligations imposed upon us such as a court order.

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4.11 PUBLIC HEALTH AND CONTACT TRACING

Where we participate in government contact tracing schemes operated by public health authorities, we may need to collect additional information from you when you book a ticket online or visit one of our cinemas.  This may include us asking you to provide certain contact details which we may then share, together with details about the time and date of your visit to our cinema, with public health authorities. We'll let you know when we're participating in these contact tracing schemes by notices on our Sites and in our cinemas. We'll provide information about the measures we are taking and how your personal information may be collected and used for this purpose by providing information about the scheme(s) on our Sites, in this Privacy Policy and, where appropriate, when you book a ticket. If you have a MyPicturehouse account or Picturehouse membership, we may also send you service updates about these schemes. 

We will only retain the data that we collect for this purpose in line with government guidance. Please see the How long do we keep your personal information for? section for further information.

What is our legal basis?

It is in our and our customers' legitimate interests to contribute to the public health efforts to tackle threats to public health posed by epidemics, pandemics and other public health emergencies. In some cases, we may also be under a legal obligation to collect your contact details.

You can object to our use of your personal information for this purpose by contacting us by email at enquiries@picturehouses.co.uk or telephone (020 7326 2649), but we may not give effect to your request if we have decided that the use of your personal information for this purpose is mandatory as a result of measures and/or guidance applicable to your area or country. You can also exercise your rights (including your right of objection) in respect of this activity as set out in the How to access your information and your other rights section.



4.12 HEALTH AND SAFETY

We may use your personal information which is gathered for health and safety purposes, including any accident report or claim log in respect of an accident or incident which occurs in one of our cinemas.  As this may be data relating to your health it could fall within special categories of data 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 information 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 information in connection with an accident or incident as described above it is in our legitimate interest to do so and to comply with our legal obligations. Where this includes use of special categories of data it is necessary for the purposes of carrying out our obligations and exercising specific rights relating to relevant social protection law which may include health and safety and/or occupier's liability legislation. In addition, where we also process special categories of data to establish, exercise or defend any legal claim we do so because it is necessary to process it for these purposes.

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4.13 OTHER PURPOSES

Any other purposes for which we wish to use your personal information that are not listed above, or any other significant changes we propose to make to the existing purposes will be notified to you using your contact details. Alternatively, we may provide details to you of the new or amended purpose and our legal basis for processing it at the time of collecting your personal information for that particular purpose.

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5. HOW DO WE OBTAIN YOUR CONSENT?

Where our use of your personal information requires your consent, you can provide such consent:

  • at the time we collect your personal information 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 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, where we have a legal right to do so.

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6. 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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7. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

We may share your personal information for the purposes described in section 4 of this Privacy Policy:

  • internally with other companies in our group (which means our subsidiaries and our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006); and
  • externally with third-party service providers.
  • The categories of third-party service providers that we share your personal information with are:
  • providers of online ticketing systems;
  • providers of systems and services that help us operate our membership scheme, including membership card manufacturers and providers of specialist IT Systems;
  • suppliers of systems and services that help us provide and administer our gift products;
  • payment processors and providers of direct debit facilities;
  • printers, delivery and postal companies;
  • suppliers who host, provide, manage, support or administer certain aspects of our websites, and telephone booking service, IT systems and data centres;
  • providers of customer surveys and customer insight analytics;
  • suppliers who host, provide, manage, support or administer certain aspects of our IT and business administration systems and data centres;
  • providers of Wi-Fi access for customers in our cinemas;
  • suppliers of email, online and social media advertising and other marketing systems and services;
  • third parties who help us to run or administer competitions or deliver prizes;
  • third parties who host our events;
  • with our professional advisers such as our lawyers, accountants, 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;
  • 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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8. TRANSFERS OF YOUR PERSONAL INFORMATION OVERSEAS


8.1 Internally within our group

We transfer your personal information within our group as described in section 7.
The use of your personal information is governed by an intra-group agreement and although we do not routinely transfer your personal data from the EEA to a non-EEA jurisdiction if we do so in the future we will ensure that there is a lawful basis for transferring personal information outside the EEA, this may include use of EU 'model clauses' which have been approved by the European Commission.




8.2 To external third parties

Some of the third parties that we describe in section 7 may be located outside of the EEA or may otherwise transfer your personal data outside of the EEA.
Where we transfer your personal data to external third parties, we take appropriate steps to ensure that your personal information is treated securely and in accordance with this Privacy Policy and all applicable laws.
In respect of transfers of your personal information outside of the EEA, this means that we will ensure that there is a lawful basis for transferring personal information 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.

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9. THIRD PARTY LINKS AND SERVICES

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 information collected by us through our Sites and Services and does not apply to these third party websites and third party service providers.

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10. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION 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, pursuant to which we do not retain personal data for longer than is necessary for the purposes for which it is collected. We will keep personal data you give us in relation to any contract that we have with you for seven years. If your information 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.

If your information is only useful for a short period e.g. for specific marketing campaigns or for coronavirus (Covid-19) contact tracing, we may delete it after a shorter period (e.g. 21 days for contact tracing).

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11. CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION

We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration.

We have implemented information security policies, rules and technical measures to protect the personal information 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 information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of our Services.

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12. HOW TO ACCESS YOUR INFORMATION AND YOUR OTHER RIGHTS

You have the following rights in relation to the personal information 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 information and, if so, provide you with a copy of that personal information (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 information we hold about you is inaccurate or incomplete, you're entitled to have it rectified. If we've shared your personal information 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 information with so that you can contact them directly.
    If you have a MyPicturehouse account, you can log in and amend your contact details and marketing preferences whenever you like.
  • Your right to erasure.
    You can ask us to delete or remove your personal information 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 information 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 information 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 information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it. It won't stop us from storing your personal information though. We'll tell you before we lift any restriction. If we've shared your personal information 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 information with so that you can contact them directly.
  • Your right to data portability.
    You have the right, in certain circumstances, to obtain personal information 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 information, and we will do so, if we are:
    1. relying on our own or someone else's legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
    2. processing your personal information for direct marketing.
  • You can ask us to stop sending you marketing communications sent to you by email at any time by using the 'opt-out' or 'unsubscribe' link that we will present to you in the marketing communication. 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 rights in relation to automated decision-making and profiling.
  • You have the right not to be subject to a decision when it's based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.
  • Your right to withdraw consent.
    If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, 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 information, you can report it to the UK Information Commissioner's Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ by calling their helpline on 0303 123 1113.

To exercise any of your rights in relation to personal information you have shared with Braintree/PayPal when making payments on our Sites during the payment process (see section 4.1 above), you will need to contact Braintree/PayPal directly. More information is available in their Privacy Notices which can be found at  www.braintreepayments.com (payment made using debit/credit/charge cards) and www.paypal.com/myaccount/privacy/privacyhub (payment made using a PayPal account). 

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13. CHANGES TO THIS PRIVACY POLICY

To ensure that you are always aware of how we use your personal information we will update this Privacy Policy from time to time to reflect any changes to our use of your personal information. 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 a Picturehouse member or have a MyPicturehouse account 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 information.

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Cookies

Cookies on www.picturehouses.com
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the site. 'First-party' cookies are set by the site domain listed in the address bar. 'Third-party' cookies come from other domain sources that have items such as adverts or images embedded on the page.The information below explains the cookies we use and why.

Ticket Purchasing
Our ticket purchasing process sets a session cookie which expires when your browser is closed. The cookie is called session_id, and it is required to remember details of your choices as you proceed through the booking process.
This is a first-party cookie, as it is part of the picturehouses.co.uk domain. No data or personal information is held.

Our website also has a cookie called accepted, and its purpose is to remember people who have clicked on 'Do not show this message again' in response to the following statement: 'this site uses cookies to help make it more useful and reliable. By using the site or by dismissing this banner you are consenting to their use.' It is a first-party, persistent cookie, lasting for 13 months. No data or personal information is held.

Our website also has a cookie called user, and its purpose is to track the names of customers who have logged into My Picturehouse. It is a first-party, persistent cookie, lasting for three years. The only personal information held is the customer's full name.

Google Analytics 
We use Google Analytics to collect information about how visitors use our website. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from, and the pages they have visited.

Google Analytics uses the following cookies on our site:
_utma (persistent cookie, lasts for two years)
_utmb (session cookie)
_utmc (session cookie)
_utmz (persistent cookie, lasts for six months)
_ga (persistent cookie, lasts for two years)
_ga_ (persistent cookie, lasts for two years, used to persist session state)

These are all first-party cookies. No data or personal information is held. More info.

Webtrends
Our trailer providers, MyMovies, use a cookie called WT_FPC, which enables them to use Webtrends to track anonymous data like return visits and session length. WT_FPC is a persistent cookie lasting ten years. MyMovies inform us: 'it does not retain any personal information, simply unique ID values attributed to xx user, and unique ID values for xx session so that it can monitor duration.'

AddThis
We use AddThis to enable users to share content from our website. AddThis uses the following cookies on our site:
_atuvc (persistent, two years)
di (persistent, one day)
dt (persistent, one month)
uid (persistent, two years)
uit (persistent, two days)
xtc (persistent, two years)

These are first-party cookies, and you can find out about the data they handle here.

Smart AdServer
We use Smart AdServer to provide advertising on our website. They use the following cookies:
dyncdn (persistent, one day)
pbw (persistent, two years)
pbwmaj6 (persistent, three days)
pdomid (persistent, two years)
pid (persistent, two years)
sasd (session)
TestIfCookie (session)
TestIfCookieP (persistent, two years)
vs (session)

These are third-party cookies, and information about the data they handle can be found here. From that page you can also opt out of having Smart AdServer cookies on your computer.