Privacy Policy

Last updated: 1 March 2020

This Privacy Policy describes the privacy practices of Rooftop Film Club Limited and its subsidiary companies, including the businesses operating under the Rooftop Film Club brands (“our”, “us”, “we”, “Rooftop” or “Rooftop Film Club”), and how we collect, use, disclose and transfer the information you provide when you interact with us via our websites, applications, emails and other communications that link to or reference this policy (the “Online Services”); this privacy policy does not apply to other communications that you may have with us outside of the Online Services or information that we obtain from third parties.

CONTROLLER

Rooftop is the controller and responsible for your personal data. We have appointed a who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, please contact the data privacy manager using the details set out at the end of this policy.

1. TYPES OF INFORMATION WE COLLECT ABOUT YOU

There are two main types of information we collect about users of the Online Services:

Personal data, or personal information, or “Personally Identifiable Information” means any information about an individual from which that person can be identified and may include, for example, your full (i.e., first and last) name, phone number, email address, postal address, or credit or other payment card number, and photos of you or other individuals. It does not include data where the identity has been removed (anonymous data).

“Non-Personally Identifiable Information” or “aggregated data” is information that relates to you or your computer or device but does not on its own identify you. Non-Personally Identifiable Information relates to information about you, or the computer or mobile device you use to access the online Services, but doesn’t identify you personally. This information may include, for example, information about your use of the Online Services, including web pages you have visited, apps you have downloaded, parts or functions of the Online Services you have used or viewed, gameplay data, content you have accessed or viewed, advertising sent to you or that you have viewed, transaction history, IP address and device identifiers, information about your Internet connection, information about the equipment or software you use to access the Online Services, and information you provide to or post on message boards or chat rooms that are part of the Online Services.

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.

Where we need to collect personal data by law, or under 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 our services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

2. HOW WE COLLECT INFORMATION FROM YOU

We collect information about you in three main ways:

Directly from you, when you provide it to us: for example, when you register with the website, download an app, sign up for email or text alerts, buy movie tickets or make other purchases via the Online Services, request products or services, respond to surveys, contact us or otherwise interact with us. Please remember that if others use devices into which you remain logged in, they may share information with us as if they were you, and they may have access to information that you have previously provided us. To protect your privacy, please log out from the Online Services you use on shared devices.

Automatically, when you use our Online Services: we collect information through the use of cookies and similar technologies, through logging your activities on the Online Services, and when you download our mobile applications. Please see our Cookies and Tracking Technologies Information Center, and Mobile Apps Information  for further information, including your choices in relation to the use of these technologies.

From third parties: we may obtain information about you from third parties outside of the Online Services—this Privacy Policy will not apply to that information. Information supplied by third parties is subject to the terms of use you have agreed to and privacy policies of those third parties.

When you sign-on to the Online Services or otherwise interact with social networks or if you interact with us through a social media function such as a plug-in (for example, a Facebook “like” button) then you may be permitting us to have on-going access to some information from your social network profile (such as your name, email address, your friend list, photo, age, gender, location, birthday, social networking ID, current city, the people/sites you follow, and so forth). We may also obtain information about you from a third party data aggregator, cookie technology operator, advertising network, or another type of data company.

3. HOW WE USE INFORMATION ABOUT YOU

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party).
• Where we need to comply with a legal obligation.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending first party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us – please see the options at section 5.

Specifically, we may use your identity, contact, technical, usage and profile  information to:

• Provide the services and products you have requested;
• Create an account on the Online Services if you have requested one;
• Personalize the services we offer and the advertising displayed through the Online Services 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 products, services and offers may be relevant for you (we call this marketing). ;
• Respond to your inquiries, requests, and comments;
• Allow you to participate in the interactive features of our Online Services, where you choose to do so;
• Provide technical support for the Online Services;
• Understand how the Online Services are used so that we can continuously improve the services we provide to you;
• Send you service-related communications, including announcements and administrative messages;
• Send you newsletters and information about products, services and promotions relating to us or other companies or organizations that we work with.
• Use technology (such as Facebook Custom Audiences) to deliver advertising to you on other sites based on the email address or other Personally Identifiable Information you provided to us or through the use of information we received from third parties. Please see Your Rights and Choices (Section 8 below) for further information about how you can control these updates ;
• Send gifts to your requested recipients, provide other communications relating to those sorts of transactions, as well as any further communications as may be authorized by the recipients; and
• Combine all the information we collect or receive about you for any of the foregoing purposes.

4. HOW WE SHARE INFORMATION ABOUT YOU

We may share Non-Personally Identifiable Information, such as aggregate data and information about your use of the Online Services with third parties. We may also share Personally Identifiable Data as disclosed at the time you provide that information, in the following circumstances:

Rooftop’s Owners and Subsidiaries: As stated at the beginning of this Privacy Policy, when the Online Services receive or collect information from you, that information is received and collected by Rooftop under this Privacy Policy.

Service Providers that We Have Retained To Perform Certain Business-Related Functions on Our Behalf: For example, our service providers may offer services such as research, analytics, hosting websites, fulfilling transactions, maintaining databases, administering contests, providing technology services and platforms, deliveries, and processing payments. We may also need to share information with other companies in order to enable the uses described above in “How We Use Information About You” or elsewhere in this Privacy Policy. When these companies are provided with Personally Identifiable Information they are only provided with that Personally Identifiable Information they need to perform their functions and that Personally Identifiable Information can only be used as is necessary to perform the services on our behalf, or to comply with legal requirements. Similarly, where appropriate, we take reasonable steps to require third-party service providers to protect Personally Identifiable Information in accordance with applicable data protection legislation.  .

Third Parties who Separately Have Your : We may share information about your use of the Online Services with third parties to whom you separately provide (or to whom you already separately have provided) your Personally Identifiable Information (e.g., if you establish or have established accounts with them enabling those parties to share such data with us). In these instances, we may enhance the data they have about you by using or sharing a common identifier that itself is not Personally Identifiable Information.

Theatres, Venue Operators, Event Promoters: We may provide information (including Personally Identifiable Information) to theaters, venue operators and event promoters so that they can admit you to their premises (or to the premises of their events), or be prepared to handle issues relating to your attendance or planned attendance.

Loyalty Program Operators: Our services offer the ability for consumers to link their Rooftop account with the loyalty rewards programs of certain theaters, venue operators, event promoters, movie studios or other companies offering loyalty reward programs. When you indicate that you’d like such a link to occur, we may share transaction information or other information (including Personally Identifiable Information) pertaining to you with the applicable program operator.

Social Networks: You may interact with certain features of the Online Services that cause information to be published to your social networks. Or, you may sign up for features on the Online Services or a social network that are designed to require that we provide to the social network, or the social network provide to us, information, which may include Personally Identifiable Information, to associate our records relating to you in our data base with the records that social network has relating to you in their database, so that they or we can contact you or tailor messages to you, or otherwise. On pages of the Online Services that contain social network functionality, the social network providing the functionality may be able to collect information about you, even if you don’t use that functionality.

Message Boards and Other Public Areas: Information you provide to or post on message boards, chat rooms or other public areas that are part of the Online Services may be freely used and disclosed by us.

For Mobile, Consumer Electronics or Other Device Apps: We may share information (including Personally Identifiable Information and how you use mobile apps, consumer electronics device apps or other device apps) with mobile carriers, technology providers, analytics providers, device makers or operators, or the operators of platforms, operating systems or other mobile, consumer electronics or other device apps. Please see our Mobile Apps Information Center for additional details about mobile apps.

Opt-Ins: In some places on our Online Services we may place opt-ins where you can select to receive communications from companies with whom we have promotional relationships. If you opt-in to receive those communications, or opt-in to consent to share Personally Identifiable Information with them, we may disclose Personally Identifiable Information to them.

Sale of Our Business or Assets: If we sell all or part of our business or assets or are otherwise involved in a merger or business transfer, we may, in our sole discretion, transfer, sell or assign any or all information to a third party as part of or in connection with that transaction.

Legal Reasons: In accordance with the requirements of data protection legislation, we may use or disclose information to cooperate with or enlist the support of law enforcement, government or regulatory bodies, content protection organizations or judicial processes with respect to, or to prevent, suspected or possible fraud or other suspected or possible illegal activities. We may also use or disclose information as we determine appropriate to the extent that records have been subpoenaed or otherwise in connection with pending or potential litigation, or to enforce or protect the rights or safety of Online Services users, us or others, or for risk management purposes.

A Special Note About Sharing Video Viewing Information: By using the Online Services, you are agreeing that we may share information about the video content viewed on your device through the Rooftop Services with the analytics providers, advertising companies, third-party social media sites, and the other service providers we work with (as described in this Privacy ). If you have registered, you may withdraw your consent to sharing of personally identifiable viewing information associated with content viewed by sending an email to [email protected].  You may also be able to control information shared with third parties, such as social media sites, through your privacy settings on those services.

Marketing and Advertising: We may work with third party ad networks and consumer data companies to help present ads through the Online Services or to help us evaluate and provide us with information about the use of the Online Services and viewing of our ads and other content.. These third parties may view, edit or set their own tracking technologies/cookies, which will allow them to collect information about how you interact with content and advertising while you are using the Online Services and while you are on other third party platforms where their tracking technologies are located in order to increase the relevance of those services

5. YOURS RIGHTS TO MANAGE YOUR DATA

[We have established [a privacy centre] [Cookies and Tracking Technologies Information Centre] where you can view and make certain decisions about your personal data use: [PRIVACY CENTRE LINK] OR the following personal data control mechanisms] Please note that even if you choose to remove your information (opt out), you will still see advertisements while you’re browsing online. However the advertisements you see may be less relevant to you. Even if you opt-out of targeted advertising, we may still track your visits to the Online Services for our own analytics, operations and security purposes

THIRD-PARTY MARKETING  We will get your express opt-in consent before we share your personal data with any third party for marketing or advertising purposes.

OPTING OUT  

If you have subscribed to one or more of our email newsletters or are receiving them from us and you don’t want them anymore, or have opted in to receive marketing or promotional emails or advertising from us or any third parties, you can unsubscribe at any time. Select the “unsubscribe” link at the bottom of any message, use other means provided to unsubscribe or change communication preferences, or use the contact details below, to unsubscribe from marketing and promotional e-mails.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

COOKIES  

[You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see the Cookies and Tracking Technologies Information Center. Through our Cookies and Tracking Technologies Information Center. The effect of an opt-out for some advertisers will be to stop targeted advertising, but it will still allow the collection of usage data for certain purposes (e.g., research, analytics and internal Online Services operation purposes)

MOBILE APPS

For more information about our information collection and use practices with respect to our mobile applications, including information on how to opt out of targeted advertising, see the Mobile Apps Information Center.

ACCESS AND CORRECTION

To object to personalisation you can change your preferences within your user account. If this option is not available you can contact us and we will do it for you. In addition to the preferences provided to you via the Online Services (such as using “account settings” for registered users), where legally required we provide online visitors with access to their Personally Identifiable Information and the ability to review, update and correct it.

6. CHILDREN

The Online Services are not designed or intended for use by children, and thus if you are under 16 we ask that you do not use the Online Services or provide us with any information. If we discover that we have inadvertently gathered any such information then we will make reasonable efforts to delete such information from our records. If a parent or guardian becomes aware that his or her child under 16 has provided us with information without his or her consent, he or she should contact us at [email protected]

7. HOW WE PROTECT INFORMATION

We maintain procedural, technical and physical safeguards for the Online Services to help protect against loss, misuse or unauthorized access, disclosure, alteration or destruction of the Personally Identifiable Information you provide via the Online Services. Unfortunately, no transmission of data is guaranteed to be completely secure. It may be possible for third parties not under our control to intercept or access transmissions or private communications unlawfully. Therefore, any transmission of Personally Identifiable Information to us is made at your own risk. If you believe that your interaction with us is no longer secure, please notify us using the contact details below.

Usernames & Passwords

It is important that you protect and maintain the security of any account and that you notify us immediately of any unauthorized use of any Rooftop account. Do not disclose your password to anyone else.

8. YOUR RIGHTS AND CHOICES

Under certain circumstances, you have rights under data protection laws in relation to your personal data to:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, [please contact].  Some access requests may be subject to a small fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. To help your privacy and security, we will take reasonable steps to verify your identity, such as requiring a password and user ID, and possibly photo ID before granting access to Personally Identifiable Information about you. Please contact [email protected] for more information about exercising these rights.

Data Retention and Deletion

We may retain your data for as long as you use the Online Services and for a reasonable time thereafter. If you’d like to delete, modify or update the Personally Identifiable Information that you provided via the Online Services please use the settings on the Online Services or contact us at [email protected] and we will respond in a reasonable time. Please note that some or all of this data may be required in order for the Online Services to function properly, and we may be required to retain certain information by law.

9. INTERNATIONAL TRANSFER OF INFORMATION ABOUT YOU

Whenever we transfer your personal data out of the European Economic Area or the United Kingdom, we use reasonable efforts to ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is :

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

If you are located outside of the United Kingdom, please be aware that information we collect, including Personally Identifiable Information, may be transferred to, processed, stored and used in the United Kingdom and in accordance with English law.

10. LINKS TO OTHER WEBSITES AND SERVICES

The Online Services may contain links to third-party websites or services. In some cases, we may embed a content feed, video player or other application from a third party into the Online Services, and those feeds, players or other applications may appear to be part of the Online Services, even though they are provided or served by a third party. If you access another website, or any such services, even ones that may contain the Rooftop logo or are framed by the Online Services, please understand that the operators of these websites or services may collect information from you, or place or read cookies or other tracking devices, which will be used by them in accordance with their own privacy practices, which may differ from ours. We are not responsible for, and we do not endorse or control, the policies or practices of any such website or services. You should always read the Privacy Policy of any website or services you access carefully in order to understand their information usage practices

11. UPDATES TO OUR PRIVACY POLICY

From time to time, we may revise this Privacy Policy. If we make material revisions to the way we collect or use your Personally Identifiable Information, we will provide you with notice of those changes by either: (1) announcing the change on our Online Services or (2) taking other actions as we deem appropriate under the circumstances, including without limitation, posting the revised version of this Privacy Policy online. You should check our Online Services frequently for updates.

You can determine when this Privacy Policy was last revised by referring to the “Last Updated” or similar legend at the top of this page.

12. CONTACT US

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Email address:  [email protected]

Postal address: Unit B3.1, Office Club, 133 Copeland Road, SE15 3SN

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.