Short Film Reviews Website Privacy Policy

Short Film Reviews respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after any personal data we may collect when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

PURPOSE OF THIS PRIVACY NOTICE

This privacy notice aims to give you information on how Short Film Reviews collects and processes your personal data through your use of this website, including any data you may provide through this website when you submit a film or sign up to our newsletter.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

CONTROLLER

Short Film Reviews is the controller and responsible for your personal data (referred to as “SFR”, “we”, “us” or “our” in this privacy notice).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us.

CONTACT DETAILS

DPO: info@shortfilmreviews.video

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.

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on 3rdSeptember 2018. Historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

  1. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We do not collect any personal data from visitors using the site for finding and viewing films, and reading blogs and other content.

We may collect, use, store and transfer some or all of different kinds of personal data about you which we have grouped together follows:

  • Identity Dataincluding first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Dataincluding billing address, delivery address, email address and telephone numbers.
  • Financial Dataincluding bank account and payment card details.
  • Transaction Dataincluding details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Dataincluding internet protocol (IP) address, your login data, 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 website.
  • Profile Data including your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Dataincluding information about how you use our website, products and services.
  • Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.

We also may 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 is not considered personal data in law as this data does notdirectly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 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 notice.

We do not collect any Special Categories of Personal Dataabout 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. We do not knowingly collect data relating to children.

IF YOU FAIL TO PROVIDE PERSONAL DATA

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 goods or 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.

  1. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

  • Direct interactions.You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you submit a film; apply for any products or services we may offer; create an account on our website; subscribe to our service or publications; request marketing to be sent to you; enter a competition, promotion or survey; or give us some feedback.
  • Automated technologies or interactions.As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We do not utilise cookies.
  • Third parties or publicly available sources.We may receive personal data about you from various third parties including but not limited to Film Freeway; analytics providers such as Google; advertising networks; search information providers; Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as banks and PayPal; Identity and Contact Data from data brokers or aggregators or from publicly availably sources such as Companies House.
  1. HOW WE USE YOUR PERSONAL DATA

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) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third 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.

  1. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, 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. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer

 

(a) Identity

(b) Contact

Performance of a contract with you

 

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

 

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a festival, prize draw, competition or complete a survey (a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Profile

(f) Usage

(g) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

 

  1. MARKETING

6.1 PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data 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.

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us, or if you provided us with your details when you entered a competition or registered for a promotion, and, in each case, you have not opted out of receiving that marketing.

6.2 THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any company outside the Short Film Reviews group of companies for marketing purposes.

6.3 OPTING OUT

You can ask us or third parties to stop sending you marketing messages by checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you,  or] by contacting us directly at any time].

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, or other transactions.

  1. COOKIES

See Appendix 1 for details of SFR’s use of cookies.

  1. CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  1. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with other parties set out below for the purposes set out in the table in paragraph 4 above. These third parties may include event hosts and venues, online screening platforms.

They may also include third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

In the event that we transfer your personal data out of the EEA, 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 providers based in the USA, 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 the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

  1. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  1. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for [six] years after they cease being customers for [tax] purposes.]

In some circumstances you can ask us to delete your data: see [Request erasure] below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

  1. YOUR LEGAL RIGHTS

Under certain circumstances, you have legal rights in relation to your personal data. You have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). 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 data we hold about you corrected. We may need to verify the accuracy of any new data you provide.
  • 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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. 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 at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, 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 a number of requests. In this case, we will notify you and keep you updated.

  1. GLOSSARY

Legitimate Interestmeans 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 Contractmeans 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 or regulatory obligationmeans processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Internal third parties means other companies in the Short Film Reviews Group acting as joint controllers or processors.

External third parties means:

  • Service providers acting as processors who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, auditors, insurers and marketing advisors who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities based [in the United Kingdom who require reporting of processing activities in certain circumstances.
  • Partners and agents including film festival portals (such as Film Freeway), film screening sites, live screening venues and other festival, conference and entertainment venues.

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APPENDIX 1

Cookies In Use on This Site

Our website uses cookies, as almost all websites do, to help provide you with the best experience we can. Cookies are small text files that are placed on your computer or mobile phone when you browse websites.

Now and/or in the future, cookies help us:

  • Make the website work as you’d expect
  • Save you having to login every time you visit the site
  • Remember your settings during and between visits
  • Improve the speed/security
  • Continuously improve our website for you
  • Make our marketing more efficient (ultimately helping us to offer the service we do at the price we do)

We do not use cookies to:

  • Collect any personally identifiable information (without your express permission)
  • Collect any sensitive information (without your express permission)
  • Pass data to advertising networks
  • Pass personally identifiable data to third parties
  • Pay sales commissions

You can learn more about all the cookies we use below

GRANTING US PERMISSION TO USE COOKIES

If the settings on your software that you are using to view this website (your browser) are adjusted to accept cookies we take this, and your continued use of our website, to mean that you are fine with this. Should you wish to remove or not use cookies from our site, you can learn how to do this below, however doing so will probably mean that our site will not work as you would expect.

OUR OWN COOKIES

Now and/or in the future, we use cookies to make our website work, including:

  • Determining if users are logged in or not
  • Remembering search settings
  • Remembering if users have accepted our terms and conditions, where required
  • Allowing you to add comments to our site

There is no way to prevent these cookies being set other than to not use our site.

THIRD PARTY FUNCTIONS

Our site, like most websites, includes functionality provided by third parties. A common example is an embedded YouTube video. Our site includes the following which use cookies:

  • YouTube – used for embedded videos
  • Vimeo – used for embedded videos
  • PayPal – used for financial transactions
  • WordPress – our underlying website platform

Disabling these cookies may break the functions offered by these third parties

ANONYMOUS VISITOR STATISTICS COOKIES

We use cookies to compile visitor statistics, on an anonymous basis. These so called “analytics” programs help us to continuously improve our website, and give data including:

  • How many people have visited our website and whether they have been here before
  • How long they spend on the site, what pages they look at
  • How they reached this site (e.g. from a search engine)
  • What type of technology they are using (e.g. Mac or Windows which helps to identify when our site isn’t working as it should for particular technologies.

We use Google Analytics for this function.

TURNING COOKIES OFF

Cookies are a standard part of most of the world’s websites. However you can usually switch cookies off by adjusting your browser settings to stop it from accepting cookies (learn how here). Doing so however will probably limit the functionality of the site. It may be that you concerns around cookies relate to so called “spyware”. Rather than switching off cookies in your browser you may find that anti-spyware software achieves the same objective by automatically deleting cookies considered to be invasive. Learn more about managing cookies with antispyware software.

The cookie information text on this site was derived from content provided by Attacat Internet Marketing http://www.attacat.co.uk/, a marketing agency based in Edinburgh. If you need similar information for your own website you can use their free cookie audit tool.

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