The Light Cinemas Privacy Policy

What our Privacy Policy Covers.

Light Cinemas is committed to protecting your Personal Data and respecting your privacy. We strive to be transparent with you about how we collect and use your Personal Data in making our website (“Site”) available to you. This Privacy Policy tells you about your privacy rights and how the law protects you. Our website is not intended for children under the age of 16 and we do not knowingly collect data relating to children under the age of 16.

Our Privacy Policy is designed to describe:

Who we are and how to contact us.
Your rights relating to your Personal Data.
Marketing communications and preferences.
What Personal Data we collect.
How we use your Personal Data and why.
Personal Data from Third Party Sources.
How we use cookies and other tracking or profiling technologies.
Who we share your Personal Data with.
How we keep your Personal Data secure.
How long we store your Personal Data.
Third party links.

This Privacy Policy aims to give you information on how Light Cinemas collects and processes your Personal Data through your use of our Sites, including any data you may provide through this Site.

The Privacy Policy is intended to meet our duties of Transparency under the “General Data Protection Regulation” or “GDPR”.

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

Our Details and How to Contact Us.

The Light Cinemas Group is made up of a number of different legal entities, all of which are wholly owned subsidiaries of Light Cinemas (Holdings) Limited. Our main trading entity is Light Cinemas Limited, company number SC330332 and both these companies have a registered trading address at Floor 4, 22 Golden Square, London W1F 9AD.

The only companies within the Light Cinemas Group that process your Personal Data are Light Cinemas (Holdings) Limited and Light Cinemas Limited. So, when we mention “Light Cinemas”, “we”, “us” or “our” in this Privacy Policy, we are referring to Light Cinemas (Holdings) Limited and/or Light Cinemas Limited, depending on the context.

We will let you know which entity will be the Controller(s) (for the purposes of the GDPR) of your Personal Data if you ask us to give you this information by contacting us at the email address below.

You can contact Light Cinemas by emailing privacy@lightcinemas.co.uk.

Your rights relating to your Personal Data.

By law you have the right to:

Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
Object to processing of your Personal Data. This right exists where we are relying on a Legitimate Interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your Personal Data. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent. This right only exists where we are relying on consent to process your Personal Data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Site. We will advise you if this is the case at the time you withdraw your consent.

How to exercise your rights

If you want to exercise any of the rights described above, please contact us using the contact details in the “Our Details and How to Contact Us” section.

Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, except in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

Complaints

If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your Personal Data, please use the contact details in the “Our Details and How to Contact Us” section. We will reply to your complaint as soon as we can and will use best endeavours to respond within 5 working days.

If you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right to contact your local data protection supervisory authority, which for the UK, is the Information Commissioner’s Office.

Marketing communications and preferences.

To receive any marketing communications from us you will need to be a myLight Member which requires you to create an account our Site. The marketing communications you receive are determined by the preferences you select on your account.

You can adjust your preferences at any time by logging into your account and checking or unchecking the relevant options. All marketing communications you receive will also contain a link at the bottom to unsubscribe. If you click on the unsubscribe link, you will stop receiving these communications and your account preferences will be automatically updated to reflect this.

All emails will come directly from a domain which is registered to Light Cinemas i.e. it will contain @lightcinemas.co.uk. You will never receive an email from a third party as result of your association with Light Cinemas.

If you have any concerns about any communication you receive, please contact us straight away using the contact details in the “Our Details and How to Contact Us” section.

We will still use your Personal Data to send communications to you where we have a legitimate interest to do so (other than for marketing purposes) or where it is necessary to do so in order to provide our products or services to you.

What Personal Data we collect.

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

Before you read that table, it might be useful to explain what “Personal Data” is. The GDPR definition of Personal Data can be found here. Essentially, it boils down to: information about an individual, from which that individual is either directly identified or can be identified.

It does not include ‘anonymous data’ (i.e., information where the identity of individual has been permanently removed). However, it does include ‘indirect identifiers’ or ‘pseudonymous data’ (i.e., information which alone doesn’t identify an individual but, when combined with certain additional and reasonably accessible information, could be attributed to a particular person).

The following table shows the Personal Data which we may collect about you as part of you interacting with our Sites, purchasing goods and services from us and/or being part of our membership and loyalty schemes. In latter sections of this Policy, we describe how we use this Personal Data.

It is important that the Personal Data we hold about you is accurate and we ask that you ensure that keep the Personal Data you provide to us (e.g. in your account) up-to-date. Your details and/or preferences can be updated at any time by accessing your account on our Site.

Identity Data
Your name, date of birth, gender, photo (for Infinity members only)
Contact Data
Email address, phone number, address, postcode
Financial Data Direct Debit Mandate Number (provided by a third-party direct debit processor), direct debit payment history, last four digits of your card (we use a secure token system for payments and do not hold any banking information), last two digits of bank account number (Infinity members only)
Transaction Data Booking information (myLight members can access this through their account)
Marketing and Communications Data Your marketing preferences held in your myLight Account, your home cinema location, whether you have received and opened marketing communications from us, the communications you have sent in response to our marketing communications, your other communications history with us (including transcripts of your email, online chat and phone conversations with us)
Technical Data Internet protocol (IP) address, your login data, time, browser type and version, your home cinema location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website or use our services.

Aggregated Data

We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data, but once in aggregated form it will not constitute considered Personal Data for the purposes of the GDPR as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

No Special Categories of Personal Data

We do not collect any “Special Categories of Personal Data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How we use your Personal Data and why.

We will only use your Personal Data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your Personal Data for an unrelated purpose, we will update this Privacy Policy and we will explain the legal basis which allows us to do so.

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

In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases:

Where we need to perform a contract we are about to enter into or have entered into with you (“Contractual Necessity”).
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your Personal Data for is set out in the table below.
Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).

Generally, we do not rely on your consent as a legal basis for using your Personal Data other than in the context of sending your direct marketing communications.

We have set out below the legal bases we rely on in respect of the relevant Purposes for which we use your Personal Data.

Purchases as a guest

Categories of Personal Data involved
Identity Data, Contact Data, Financial Data
Why we do this
To purchase a product or service from us without needing to create an account.
Our legal basis for this use of data
Contractual Necessity

myLight and Infinity Membership

Categories of Personal Data involved
Identity Data, Contact Data, Marketing and communications data
Why we do this
To register you as a myLight and/or Infinity member, to provide a more efficient and personalised experience, to provide communications based on marketing preferences and operate our subscription and loyalty schemes.
Our legal basis for this use of data
Your Consent (to send marketing communications to you), our Legitimate Interests (in providing a more efficient and personalised experience to you), and
Contractual Necessity (to perform the terms of our membership schemes).

Payments, Refunds and Direct Debits

Categories of Personal Data involved
Identity Data, Contact Data, Financial Data
Why we do this
To process credit card payments through a secure third-party provider. No data, other than the last four digits of the card numbers are kept for the purpose of refunds. To submit direct debit applications via a specialist provider through whom all applications for recurring payments are processed. The last two digits of your bank account number are held for security purposes.
Our legal basis for this use of data
Contractual Necessity (to enable customers to complete payments, to provide refunds to customers and to process direct debits) and Legitimate Interests (to help us prevent fraud, verify our customers and chase outstanding payments).

Customer Services

Categories of Personal Data involved
Identity, Contact Data, Marketing and Communications Data
Why we do this
To provide you with a prompt and efficient service to answer customer queries. Note: Where calls are made to our central customer services line, these will be recorded and you will be made aware of this.
Our legal basis for this use of data
Legitimate interests (to provide a consistent, high quality support service to our customers and to assist with the administration of our membership schemes).

Web browsing

Categories of Personal Data involved
Technical Data
Why we do this
To provide a more efficient and user-friendly online experience which takes into account your location preferences and other settings supported by our cookies (on which see the “How we use cookies & other tracking or profiling technologies” section) and to maintain a safe online environment including detecting and preventing unauthorised use of the Site.
Our legal basis for this use of data
Legitimate Interests (to enable us to provide a more efficient and user-friendly online experience and to monitor and maintain the security of our systems and sites) and Compliance with Law (relating to our legal obligations to provide appropriate levels of security).

Data Analytics

Categories of Personal Data involved
Identity Data, Contact Data, Marketing and Communication Data, Transaction Data
Why we do this
To understand the profile, needs and preferences of our customers. We may capture data as to how you use our services and respond to marketing communications to assess our effectiveness and improve our offering.
Our legal basis for this use of data
Legitimate Interests (to build brand loyalty, understand how customers use our products and services, develop campaign strategies and grow our business).

Compliance

Categories of Personal Data involved
All Data
Why we do this
To comply with legal obligations to which we are subject and to comply with requirements of HM Revenue & Customs, regulators and other authorities which may require reporting of our processing activities in certain circumstances.
Our legal basis for this use of data
Compliance with Law.

What happens when you do not provide necessary Personal Data.

Where we need to process your Personal Data either to comply with law, or to enter into a contract with you or to perform the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have with you. We will notify you If this is the case at the time.

Personal Data from Third Party Sources.

In addition to the Personal Data that we collect directly from you (as described above), we also collect certain of your Personal Data from third party sources. These sources are broken down below, together with a description of whether they are publicly available or not.

Social Media Sites including platforms such as Facebook, Twitter, Instagram

Publicly available: Yes
Category(ies) or other types of personal data received: Identity Data, Contact Data

Google Analytics

Publicly available: No
Category(ies) or other types of personal data received Technical Data

Competition Partners

Publicly available: No
Category(ies) or other types of personal data receivedIdentity Data, Contact Data

How we use cookies & other tracking or profiling technologies.

Cookies.

What are cookies?

We may collect information using “cookies”. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site.

We use two broad categories of cookies:

first party cookies, served directly by us to your computer or mobile device; and
third party cookies, which are served by Google on our Site in order to provide us with “Google Analytics” services and for advertising purposes (as described in more detail below).

Cookies we use

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

Essential Cookies

These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. These include, for example, cookies which identify you and your shopping basket to ensure a consistent experience during your session.

Functionality Cookies

These cookies allow our Site to remember choices you make when you use our Site. The purpose of these cookies is to tailor your experience based on the preferences you share with us. For example, we use cookies to determine your home cinema location and to remember whether you have asked us not to alert you when you browse a Light Cinema location that isn’t your home cinema. These types of cookies avoid you needing to re-enter your preferences each time you visit our Site.

Analytics and Performance Cookies

These cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered via these cookies does not “directly” identify any individual visitor. However, it may render such visitors “indirectly identifiable”. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our Site. The information collected is aggregated and anonymous. It includes information such as page views, user actions and response rates.

We use Google Analytics for this purpose which uses its own cookies. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies

You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.

You can also prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB

Targeted and advertising cookies

These cookies track your browsing habits in order to show advertising which is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third party advertisers can place cookies to enable them to show adverts which we think will be relevant to your interests while you are on third party websites. If you choose to remove targeted or advertising cookies, you will still see adverts but they may not be relevant to you. You can manage observe, manage and delete advertising cookies on your computer by visiting: http://www.youronlinechoices.com/uk/your-ad-choices. Even if you do choose to remove cookies by the companies listed at the above link, not all companies that serve online behavioural advertising are included in this list, and so you may still receive some cookies and tailored adverts from companies that are not listed.

Disabling cookies

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.

If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our Site.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com/uk.

Who we share your Personal Data with.

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

Customer Service Providers

Category(ies) of Personal Data we share
Identity Data, Contact Data, Marketing and Communications Data, Financial Data
Who are they and why we share it
Organisations which provide direct support to customers on our behalf. This includes assistance with Infinity membership and direct debit issues. Support may be provided by email or telephone. Support provided by email will only ever come from a Light Cinema email address.

IT Service Providers

Category(ies) of Personal Data we share
All data
Who are they and why we share it
Third party providers who provide and maintain our systems such as servers, websites, ATMs, Tills etc. which are required to provide the full range of products and services at Light Cinemas.

Analytics Providers

Category(ies) of Personal Data we share
Transaction Data, Identity Data, Contact Data, Technical Data
Who are they and why we share it
Third parties who help manage and analyse customer information, create customer communications and campaigns, analyse and develop our products and Services, and support our loyalty and membership schemes.

HM Revenue & Customs, regulators and other authorities

Category(ies) of Personal Data we share
All data
Who are they and why we share it
HM Revenue & Customs, regulators and other authorities may require reporting of our processing activities in certain circumstances.

Data location and transfers.

Except for the Personal Data we share with Google Analytics, all Personal Data you provide to us is held within the European Economic Area (“EEA”) and we do not transfer your Personal Data to any parties located outside of it. This includes our staff, representatives and advisors.

Google may process your Personal Data outside the EEA, in the United States. To ensure that your Personal Data is given equivalent protection to the protection it would receive in the EEA when it is processed in the United States, Google has self-certified that it is compliant with the EU-U.S Privacy Shield. For further details, see European Commission: EU-U.S. Privacy Shield.

How we keep your Personal Data secure.

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.

We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.

We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.

How long we store your Personal Data.

We will only retain your Personal Data for so long as we reasonably need to use it for the purposes set out in this Policy including satisfying any legal, accounting and reporting requirements.

For example, where we have specific responsibilities under applicable laws to retain Financial Data and Transaction Data, we will retain the data for a period of 7 years from the date of the relevant transaction.

When we no longer need your Personal Data for the purposes for which we process it, we may anonymise your Personal Data so that it can no longer be used to identify you. We may use this anonymised data for analytical, technical or reporting purposes. There is no limit on the time for which we may hold anonymised data.

Third party links.

This Site may include links to third-party websites, plug-ins and applications. This includes links to our social media pages on third party websites. Clicking on those links or enabling those connections may allow third parties to collect or share your Personal Data. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every site you visit.

Policy Last Updated: 14th June 2018
Light Cinemas (Holdings) Limited