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Privacy Policy – Screen Moguls Limited

Introduction

We aim to make this policy as easy for everybody to understand as possible. If it isn't, please let us know. Everything in this introduction is explained in more detail in the policies below. You can email us about anything in this policy at privacy@screenmoguls.com

Screen Moguls is a data intelligence company. We help organisations in the entertainment industry understand cinema going behaviour. We buy location visit information and sell the insights we find to other companies. Our customers are typically movie studios, movie distributors, cinema chains and other organisations interested in cinema goers.

In practise this means our customers can log into our web portal and search that summary data. We never hold any kind of PII (personally identifiable information) on consumers. For example a movie studio might use our service to find out how many people went to see a particular movie, in a particular cinema chain on a particular day. Our service will tell them how many people did, but does not hold personal information about the individuals concerned (i.e. you).

Our customers can also use our service to advertise to consumers. So a cinema chain may ask our service how many people visited their cinemas last month, and we will then give them the information they

need to show adverts to those people through services like Google and Facebook.
Again that information allows them to send adverts. It doesn't tell them which phone went to which cinema on a particular day. It is just an advertising identifier they need to make sure you see the advert.

We get all our location visit data from apps. For example you may be using an app that asked you if it could record your location. In the agreement you signed up to, it also asked you if that information could be shared with companies like ours. If you agreed, then that information was available for us to buy.

If you didn't agree to a clear and simple agreement like that, we can't buy your data.
If anything you have just read makes you feel uncomfortable, you want to find out what app we got the data from, want to know what information we hold or you are just curious; you can contact us with your device ID and we can:

● Tell you where we acquired your mobile phone's data
● Show you all the data we have about your mobile phone's
location visits
● Remove your mobile phone's data from our database if you
request
● Help you reset the advertising identifier on your mobile phone or device

You can contact us at ​privacy@screenmoguls.com

Your right to privacy is very important to us. We follow FTC COPPA guidelines to protect you. You can find out more here: https://www.ftc.gov/tips-advice/business-center/privacy-and-security /consumer-privacy

We also ensure we are fully EU GDPR (General Data Protection Regulation) compliant, and require the same from any organisation we work with, whether they are a supplier or customer. You can find out more about GDPR here: https://ico.org.uk/for-organisations/guide-to-the-general-data-protecti on-regulation-gdpr/

There is a great guide here about how to request your information from any organisation (not just ours): https://ico.org.uk/for-the-public/personal-information/

Here is the detail on our policies:
● End user privacy
● Privacy Statement
● Data Screen Moguls may collect
● What do we do with the data we collect?
● How does Screen Moguls disclose the data to third parties?
● Storing data
● Variation of this statement
● Contact
● Screen Moguls website
● Data protection and Privacy Policy

End user privacy
Screen Moguls' privacy policies and procedures cover the use of proximity and location data from the point of collection to ours and our customers' platforms.

Screen Moguls takes data privacy very seriously. It forms the backbone of the proximity and location based digital industry and as a result we must ensure we are always compliant with the data we manage and handle across all applicable privacy laws and industry privacy regulations.

This includes:

● Transparent and clear disclosures on the collection of proximity and location data;
● User opt-in consent for the collection of location data from mobile devices
● Respecting and implementing users' choices and their device settings.
● In addition, we insist that our suppliers and customers treat and process location and proximity data received from us in compliance with all applicable privacy laws, regulations and their own policies.

Privacy Statement

Last updated: 15th May 2018
We are concerned about privacy issues and want you to be familiar with how we collect, use and share information we receive about our clients and users and the options available to you. If you have any questions you may contact us (see the "Contact Us" section of our website).

Screen Moguls Limited ("we," "our," "Screen Moguls"), and its subsidiaries offer an aggregation platform service, where we collect Proximity and Location data ("the Data") which we buy from third parties, and then store.

With your consent, we collect information to identify locations near you and to appropriately enable the services. This information may be gather location information through your mobile phone or devices' geolocation, GPS or similar capabilities.

Furthermore as part of the Service, we may collect information about your location within participating locations through your mobile phone or device's Bluetooth, Wi-Fi or similar capabilities in combination with technology implemented by our partners.

We refer to the location information collected through your mobile device's applicable geolocation, GPS, Bluetooth or similar capabilities simply as "Location Information".

They will only gather these kinds of Location Information if you agree by opting-in to the Services from one or more of our suppliers (either during your initial app download, login or later.) to receive the Services and by enabling these capabilities on your mobile device. Once you have opted-in to receive the Services and consented to their gathering of Location information, their Service will continue to collect Location Information about you until you log off (they will continue to gather information if they are running in the background) or use your phone's or other device's setting to disable your mobile device's applicable geolocation, GPS, Bluetooth, Wi-Fi or similar capabilities for the Services.

Information they collect automatically: When you utilise the Service or they are enabled, they may automatically collect certain information about your use of the Services such as the page you requested, where you click on the page and other information ("Information Collected
Automatically").

Aggregation of Personal Information: We do not aggregate personal information. This means we won't buy information about you from multiple sources in an effort to find out more about you, or who you are.

Screen Moguls may collect the following types of data:
● IDFA, Android Advertiser ID or other type of advertising identifier ("Advertising ID");
● Date and Time stamp information on engagement with the Service;
– Latitude and longitude of the mobile device when the interaction with the Service occurred;
– Mobile device operating system,Mobile Device Make and Model; – The name and version of the mobile application through which the interaction with the Service occurred;
– The duration of an interaction with the Service and;
– Device state and locale.

Our Suppliers do not provide us with data that can be directly used to identify you, such as your name, mobile phone number or email address.

What do we do with the data we collect?
We analyse, segment, categorise and summarise the data provided by our customers, clients and partners for the purposes of providing accurate and relevant content and advertising across
devices and to analyse the effectiveness of these advertising campaigns. The data is also used to provide relevant advertising to mobile devices.

In what ways can I control the Data collected?
a) Privacy Policies:​ Check the privacy policy of any app you download and make sure you understand what it is asking for and why it is asking for it. In particular, check the types of data the application collects from or about your device(s). Do not download, or continue
the use of, a mobile application if you do not feel comfortable with the data collection practises described in their privacy policy.
b) Device Settings:​ All major mobile device operating systems enable users of mobile
devices to control the types of data collected in and through mobile applications.
a. iOS (Apple)
Instructions on how to control location settings can be found here: https://support.apple.com/en-us/HT203033d​
b. iOS (Apple)
Instructions on how to limit ad tracking can be found here:
https://support.apple.com/en-us/HT202074
For other privacy-related settings on iOS please go to Settings from your mobile device's home screen and select "Privacy".
c. Android (Google)
Instructions on how to control device location settings can be found here: https://support.google.com/nexus/answer/6179507?hl=en&ref_topic =617​9522
Instructions on how to limit ad tracking on Android devices can be found here: https://support.google.com/nexus/answer/3118621?hl=en.​

How does Screen Moguls disclose the data to third parties?
We may disclose the data provided by our clients and partners with third parties such as advertising networks, publishers and advertisers in accordance with the terms of the agreements, and only for the purposes of performing such agreements, that we have in place with such third parties. Such disclosures do not include any data that can directly identify a user such as a name, mobile phone number or an email address.

We may also disclose data provided by our suppliers to:
● Our service providers (e.g. Our server and data storage providers); – Public authorities such as law enforcement, if we are legally required to do so or if we need to protect our rights and those of third parties and;
● Our subsidiaries or affiliates; or a subsequent owner, co-owner or operator of our services and their advisors in connects with a merger, consolidation, restructuring, sale or in connection with bankruptcy proceedings or other type of professional reorganization.

Storing data
Screen Moguls retains data for a limited period as follows;
● Data segments. Data received by the Service may be categorised into non-personal,non-sensitive demographic segments such as "movie goers" or "fashion shoppers".
We retain such segmented data sets for a period of 24 months from the date they were created.
● Location data. We retain a device (or Advertising ID's) association with a certain location or "venue" such as a sports stadium, for a period of 24 months from the date we receive such data from our partners.
● Proximity interactions. We retain an individual mobile device's interaction with a specific proximity sensor such as a Wi-Fi router or Bluetooth Beacon located in a certain area of a "venue" such as an an airport, for a period of 24 months.

Variation of this statement
From time to time we may change or vary this statement. You can tell when changes have been made to the statement by referring to the "Last Updated" line at the very top of the statement. Please check this statement regularly to ensure you are aware of any changes.

Contact
If you have any further queries, questions or comments about this privacy statement, please contact us at privacy@screenmoguls.com. We will aim to respond to your enquiry as quickly as possible.
Screen Moguls Website – Users and Clients

The Screen Moguls. Data Protection and Privacy Statement (May 2018).

Screen Moguls Ltd. ("Screen Moguls.") incorporated company based in the United Kingdom.
Our principal activity is the supply, creation and provision of Proximity Marketing products, software and services.
The legal entity that operates www.screenmoguls.com is Screen Moguls Ltd.

Our contact details are as follows:
Screen Moguls Ltd.
20-22 Wenlock Road, London
N1 7GU
United Kingdom
Tel: +44 (0)203 3287 8438
http://www.ScreenMoguls.com
Data Protection and Privacy Policy
This policy sets out the basis on which any personal data we collect from you or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

1. Your Personal Information
Screen Moguls is committed to the protection of your personal information in accordance with the principles of the United Kingdom of Great Britain and Northern Ireland's Data Protection Act 1998 ("the Act"). These provide that personal data must be:
● Processed fairly and lawfully
● Processed for limited purposes and in an appropriate way
● Adequate, relevant and not excessive for the purpose
● Accurate
● Not kept longer than necessary for the purpose
● Processed in line with data subjects' rights
● Secure.

2. Use of your Personal Information
Screen Moguls may use information about you for the following purposes:

2.1 Administration
Contact information will be used for general administration purposes. Such purposes include the physical mailing of Screen Moguls deliverables and ad hoc communications; sending e-mails about Screen Moguls events and other initiatives; and distribution of the Screen Moguls newsletter and other electronic publications by e-mail.

2.2 Service monitoring and professional education Screen Moguls will retain information about how individuals and organisations make use of the Screen Moguls service – both for service monitoring and improvement purposes. The main example of this type of information is a record of the purchases individuals or organisations have made, however other examples include the retention of information gathered from individuals and organisations about the level of satisfaction they have with Screen Moguls and its services, along with suggestions for how Screen Moguls should develop in the future.

2.3 Research and Development
From time to time Screen Moguls will ask individuals for input into the organisation's ongoing services. This input may take the form of a questionnaire response, e-mail or a written record of opinions, suggestions and ideas or conversation with Screen Moguls staff.
Screen Moguls may also record information about individuals' areas of expertise, enabling Screen Moguls to seek input from these individuals as appropriate or in order to facilitate service improvements.

3. Information collected automatically and Cookies

3.1 We may collect information about your computer, including available IP addresses, operating system and browser type, for system administration and to report aggregate information. This is statistical data about browser usage and patterns, and does not identify any individual.

3.2 For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to a computer's hard drive. They help us to improve our site and to deliver a better and more personalised service.

3.3 You may refuse to accept cookies by activating the relevant setting on your browser. However, if you select this setting you may be unable to access certain parts of our site.

4. Links
The Screen Moguls website contains links to other websites and this data protection policy does not apply to those websites. If you transfer to another website you should read their data protection statement for their policy on the use of personal information. For the purpose of the Data Protection Act 1998 (the Act), the data controller is Screen Moguls. Ltd. of 20-22 Wenlock Road, London N1 7GU, United Kingdom.

5. Disclosure of Information
We may disclose personal information about you to third parties if we are under a duty to disclose or share personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of Screen Moguls. employees, Screen Moguls. or its customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

6. Your Rights
You have the right to ask us not to process personal data for marketing purposes. We will usually inform you (before collecting the data) if we intend to use that data for such purposes or if we intend to disclose their information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at privacy@screenmoguls.com.

7. Access to Information
The Act gives you the right to access information held about you. That right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.

8. Changes to our Privacy Policy
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.

9. Contact
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to privacy@screenmoguls.com.
This portal allows you to find out what information we hold about your device, download or print that information and if required delete it. If you choose to delete your information, we commit to delete it within 24 hours and stop using information for your device in the future. For more information about our company and what we do, see the privacy policy below.