At Cineflix Media Inc. we are committed to protecting and respecting your privacy.
This Privacy Statement will let you know how we look after the personal data which we collect from you in connection with your use of our website (the “Site”), and any related content, products and services. This Privacy Statement also informs you as to our obligations and your rights under data protection law.
Who is responsible for your personal data?
For the purposes of the EU General Data Protection Regulation (EU Regulation 679/2016) (the “GDPR”) and Quebec’s Act respecting the protection of personal information in the private sector (ARPPIPS), as amended by Quebec’s Bill 64 (Act to modernize legislative provisions as regards the protection of personal information), Cineflix Media Inc. (“Cineflix”) is the data controller with regard to the personal data described in this Privacy Statement.
“Data controllers” are the people who or organisations which determine the purposes for which, and the manner in which, any personal data is processed, who/which make independent decisions in relation to the personal data and/or who/which otherwise control that personal data.
In particular, we have appointed a Data Protection Team within Cineflix to monitor compliance with our data protection obligations and with this Privacy Statement and related policies. If you have any questions about this policy or about our data protection compliance please contact our Privacy Officer at firstname.lastname@example.org
What personal data do we collect?
“Personal data” means any information relating to an identified or identifiable natural person. Personal data can be factual (for example, a name, or email address) or it can be an opinion about that person, their actions and/or behaviour.
We will collect and process the following personal data from people submitting comments and questions to us on our Site:
We may collect, use, store and transfer different kinds of personal data about people using our Site which we have grouped together as follows:
Technical Data includes internet protocol (IP) address, 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 Site.
Usage Data includes information about how you use our Site, products and services.
We do not collect any special categories of personal data from you.
How do we collect your personal data?
For what purposes do we process your personal data and what is our legal basis?
We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.
Type of data: Name, email address, phone number
Purpose of processing: Communication So that we can communicate with you regarding any comments and/or questions you have submitted via the Site.
Lawful basis for processing:
Processing necessary to enter into a contract at the request of the data subject
Type of data: Technical Data and Usage Data
Purpose of processing: To make our Site function more efficiently and effectively in order to improve your online experience with us.
Lawful basis for processing: Legitimate interests
You will see that we rely on legitimate interests as our legal basis for some of the processing we have carried out. We have carried out a balancing test, weighing the interests of ourselves, yourself and the general public against any potential risks arising from the processing of personal data. We will not process any personal data if the risks to that data outweigh the legitimate interests in favour of processing it. If you require further information about our legitimate interests balancing test please contact us at email@example.com.
In Canada, we rely on consent to process your personal data, unless otherwise permitted under applicable laws. In some cases, your consent may be “implied”, meaning that your agreement is assumed based on your action or inaction at the point of processing your personal data. Where we rely on consent as a legal basis, you may withdraw consent at any time, subject to contractual and legal restrictions, by contacting us at firstname.lastname@example.org. Please note that withdrawal of consent shall be without effect to the lawfulness of processing based on consent before its withdrawal and that if you withdraw your consent to certain uses of your personal information, we may no longer be able to provide you with certain of our products or service.
Do we share your personal data with anyone else?
We may share your personal data with the following parties in connection with our processing of your personal data:
Cineflix’s parent, subsidiaries and/or affiliated companies (collectively, the “Cineflix Group”);
If required; services providers that perform services or functions on our behalf,
Or as may otherwise arise in the course of our providing of services to you.
We require all third parties to enter into a data processing agreement with us which complies with our obligations under applicable data protection laws. This agreement requires third parties to have appropriate security systems in place and only to use your personal data on our instructions and in accordance with applicable data protection laws.
Links to third party websites
Our Site may contain links to and from websites operated by third parties unaffiliated with the Cineflix Group. We do not control these third party websites and we make no endorsements, warranties, or representations whatsoever regarding, nor do we assume any responsibility whatsoever, in respect of such third party websites or the materials, information and content contained therein (collectively, the “Third Party Content”). We strongly advise that you carefully review the terms and conditions and privacy policies of all linked third party websites. We also reserve our right to discontinue any and all links to our Site from third party websites, at any time, at our sole and exclusive discretion.
Keeping your personal data secure
We take appropriate security measures against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data. We limit access to your personal data to those employees, agents and other third parties who are required to have access to your personal data and where they have agreed that they are subject to a duty of confidentiality.
We have put in place procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction. We have procedures in place to deal with actual and suspected data breaches which include an obligation on us to notify the supervisory authority and/or you, the data subject, where legally required to do so.
International transfers of personal data
There are circumstances in which we will have to transfer your personal data out of the country in which you reside, including outside of Canada and the European Economic Area for the purposes of carrying out the services we provide to you. Where the need for such a transfer arises we will always ensure that there are appropriate safeguards in place to protect your personal data such as:
the European Commission has issued a decision confirming that the country to which we transfer the personal data ensures an adequate level of protection for the data subjects’ rights and freedoms;
appropriate safeguards are in place such as binding corporate rules (BCR), standard contractual clauses approved by the European Commission, an approved code of conduct or a certification mechanism, a copy of which can be obtained from us on request;
you have provided explicit consent to the proposed transfer after being informed of any potential risks; or
the personal data is being transferred to a company in the US which has self-certified its compliance with the EU-US Privacy Shield which has been found by the European Commission to provide an adequate level of protection to the personal data of EU citizens.
Please note that when your personal data is transferred outside your country of residence, it may be subject to the laws of the jurisdiction in which it is situated, including laws enabling government authorities, courts and law enforcement to access information in that jurisdiction.
For how long do we keep your personal data?
Your personal data will be deleted when it is no longer reasonably required for the purposes described above or you withdraw your consent (where applicable) and we are not legally required or otherwise permitted to continue storing such data.
Where you ask to be unsubscribed from marketing communications we may keep a record of your email address and the fact that you have unsubscribed to ensure that you are not sent any further emails in the future.
In determining our retention period for categories of personal data we at all times will consider our obligations under the data protection legislation, guidance from the Data Protection Commission, any other specific legislative requirements as well as the amount and nature of the data itself.
Your data protection rights
Under certain circumstances, by law you have the right to:
Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it.
Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
Request correction of the personal information 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 information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
Object to processing (restrictive to GDPR) of your personal information where we are relying on a legitimate interest (or those of a third party) 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 information for direct marketing purposes.
Object toautomated decision-making including profiling, that is not to be the subject of any automated decision-making by us using your personal information or profiling of you. We do not engage in any automated decision making.
Request the restriction of processing (restrictive to GDPR) of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it.
Request transfer of your personal information in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format.
In the event that you wish to make a complaint about how your personal data is being processed by Cineflix, or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority who can be contacted as follows:
Our Privacy Statement may change from time to time, and any changes to this Privacy Statement will be posted on the Site and will be effective when posted. As your use of the Site is subject to your acceptance of this Privacy Statement, and any amendments thereto, please check back regularly.
What is a cookie?
A cookie is a small file of letters and numbers containing information that we store on your browser or the hard drive of your computer, if you agree. Cookies allow us to ‘remember’ you and amend the website to your preferences so that we can display content that is relevant to you, enabling you to navigate more easily between pages.
These cookies collect information about how visitors use a website, for instance, which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how the website works.
The Cineflix Media website uses Google Analytics to track user interaction with the website. This data is used to better understand user journeys within the website and allows us to understand where we can improve your experience.
Google Analytics does record your computer’s IP address (which can be used to identify you), Google does not grant us permission to view it. This makes visitors completely anonymous in terms of personal data to us and our partners. Google Analytics is considered a third party data processor.
Third party cookies
We use share buttons on our websites to enable visitors to share content through social networks. When you click on a share button, a cookie may be placed in the memory of your computer and/or device by the web server of the social network you have chosen to share content through.
We do not control the use of or have access to these cookies. For more information, you should refer to the relevant third party’s website.
You can turn off these cookies in your browser settings as well.
You can contact us with any questions, complaints or requests to exercise your data protection rights at email@example.com, thank you.
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