CineTrailer - Privacy Policy

In this section, we inform you in what way CHILI S.p.A (hereinafter “CHILI” or the “ Company) processes your personal data collected through the use of the Application “CineTrailer” available on Android, iOS, Windows Phone e Blackberry 10 (hereinafter, the “App ”), to allow you to use or purchase products and/or service (amongst which, for example, vote a film or purchase a ticket to see a film at a cinema) offered there (hereinafter, together the “ Services”).

The present notice allows you to know the type of personal data in our possession, the purposes and the methods of processing them, any recipients thereof, as well as of your rights.

The information and data provided or acquired during the use of the App, along with the Services offered through them shall be subject of processing in compliance with Regulation (EU) 679/2016 (hereinafter referred to as the “GDPR”) and any other provisions applicable for the protection of personal data, as well as of the confidentiality undertakings which inspire CHILI’s activities.

Before using the App or accessing the Services, we invite you to read the present notice and the “Terms of Service of CineTrailer” made available by CHILI.

We remind you that the Services can be used only after the acceptance of the “Terms of Service of CineTrailer” and upon the relative consent to the processing of personal data, after having acknowledged the present notice. In order to register and activate the Services, we ask you to flag the appropriate areas in the App.

1. Who processes your personal data collected through the App?

The Data controller for the data provided is Chili S.p.A., in the person of its legal representative pro tempore, with registered office at 21 Via Colico, 20158 Milan. You can contact the data controller by email at privacy@chili.com.

The Data Protection Officer (“DPO”), responsible for the data protection within CHILI, is Mr Guido Zucchini Solimei. You may contact the DPO by email at the address dpo.privacy@chili.com.

2. For what purposes and on what basis does CHILI process your personal data?

CHILI informs you that the data you have provided may be used for the following purposes:

a) registration on the App and management of your account to allow you to use the Services available on the same;

b) management of the Services requested by you, in accordance with the Terms of Service of CineTrailer;

c) fulfil of the specific obligations from contractual or precontractual agreements, or legal, fiscal administrative or regulatory obligations foreseen by Community legislation, laws connected or instrumental to the use of the App and relevant Services;

d) with your prior consent, for marketing and promotional purposes, including market research and distribution of information regarding programmes and promotions, carried out directly by CHILI and/or third-party companies operating in collaboration with the same, automatically (e.g. by push email, sms, mms, whatsapp, etc.);

e) with your prior consent, for profiling purposes regarding the analysis of your purchase habits or choices in order to offer you a navigation experience more in line with your preferences.

We also inform you that, upon activating the function on your electronic device, you can use the geo-localisation function available through the App so that CHILI can recognise the position from where you are using the Services. This function is necessary to allow you receive the programming of the cinema nearest to you. In its absence you will be asked to manually input the location upon each use of the App. This information may be used by CHILI for marketing or profiling purposes, as mentioned under points d) and e) above.

Processing of personal data communicated by you for the above-mentioned purposes will be carried out with your prior express, free and informed consent. Processing will be carried out to execute contractual obligations or to allow us to execute precontractual measures to be adopted upon your request, and to fulfil legal obligations (art. 6, par. 1, lett. b). and c) of the GDPR).

We inform you that non-consent for marketing and profiling purposes at the above letters d) and e) will not impact your use of other Services made available by CHILI through the App.

3. What type of data are processed by CHILI?

During your time browsing the App and your use of the Services offered there, the following types of data may be obtained.

Web browsing data

The information systems and software procedures used to operate the App acquire some personal data during their normal operations whose transmission is implicit in the use of internet communication protocols. This regards information which is not collected to be associated to specifically identified subjects, but which, for their nature, could, through processing and association with data held by third parties, allow to identify the user. This data category includes:

· your computer or device IP addresses used to connect to the App;

· the URI (Uniform Resource Identifier) addresses of requested resources;

· the time of the request, the method used to submit the request to the server;

· the size of the file obtained in response;

· the server response HTTP code;

· other parameters of your browser and/or operating system.

These data are used solely to compile anonymous statistics on the use of the App and to verify the correct operation. These data are deleted immediately after processing.

The data could be used to ascertain responsibility in case of any computer crimes committed to the detriment of the App or other Internet users and/or for the prevention of crimes. With the exception of this case, for the time being, data concerning web contacts are not preserved for longer than the time strictly necessary to achieve such purposes and according to the decisions of the Administrative Authority and of Public Safety.

Dati Data provided voluntarily by the user

Registration on the App involves the acquisition of your personal data (including, for example, name, surname, date and place of birth, sex and e-mail) which will be used to allow access to your personal profile and to use the Services offered on the App.

If you decide to use a Service requiring payment available on the App, we will ask you to provide your credit card details or other electronic payment methods, and further personal data (for example, fiscal code or shipping address) necessary to complete the purchase process.

4. How do we use your personal data?

Processing of your personal data, in accordance with Article 5 of the GDPR, is carried out for the purposes mentioned under Point 2 above, primarily by electronic, or, in any case, automated means, in compliance with the regulations in effect with regard to personal data confidentiality and protection.

Personal data collected may be processed by the individuals named as Data Processors pursuant to article 28 of GDPR, if they are responsible for the management of the Service required by you. The updated list of the Data Processors may be required by writing to the DPO address dpo.privacy@chili.com.

Data processing related to the App will be carried out only by technical personnel expressly authorised by CHILI, or by persons in charge of occasional maintenance. Such processing may also be carried out by persons who provide services for the management of CHILI’s information system, and who act as Data Processors or independent Data Controllers. Personal data is stored on the servers of the provider of hosting services to CHILI (Azure), with registered offices in Western Europe.

We inform you that CHILI, for the purposes of profiling and collection of your purchase habits at point 2 , letter e) of the present notice, will process your personal data through automatic means to improve your use of the App and the enjoyment of relevant Services. These means use personal data, also in aggregated form, in accordance with predefined parameters connected to your personal profile, collecting your consuming habits. Under this procedure, data communicated by you whilst registering, or supplied during use of the Services will be used.

The above-mentioned personal data will be used by CHILI to analyse your interests and purchase habits, also to offer you a service better tailored to your preferences and use habits. The use of this data has no consequence for you but allows CHILI to adapt its activities on the basis of your interests. This data will not be transmitted to third-parties but will be used internally by CHILI.

We inform you that, in consideration of the of the processes carried out and the systems used by CHILI, the same has adopted adequate security measures to monitor the systems, verifying the correct and impartial processing treatments.

5. Cookies

CineTrailer is a native app and does not use cookies technology. Occasionally, however, some of the software used by the App or the external links contained within it may contain cookies. Cookies have the main purpose of facilitating the navigation of the user (if, for example, you register or log-in using a different app, or website to purchase cinema tickets, this will send cookies to your browser to save your credentials to allow you complete the operation).

Cookies may provide information regarding the use of the App and allow the use of some services which require the identification of the user’s path. Cookies present in applications used are anonymous and cannot lead back to personal data of the user.

Through the use of the App, regardless of the presence of cookies, the type of browser (e.g. Internet Explorer, Netscape, etc.) the operating system (es. Macintosh, Windows, Linux), the host and the URL from where the user comes, and information on the page required will be registered. This data is sent completely anonymously and is processed to obtain information regarding errors of the App, (crash, bug etc.) or statistics (e.g. to understand which sections of the App are less attractive for the users).

You can configure your browser so as to be informed when you receive a cookie, so as to be able to cancel it more easily. Further information regarding cookies is available on the websites of browser producers. For more information, use the “Help” option available on your browser, or click on this link: http://cookiepedia.co.uk/how-to-manage-cookies .

6. Is the provision of your personal data mandatory?

Provision of data for the purposes indicated at point 2 , letters a), b) and c) is not mandatory; however, lack of, partial or incorrect provision of the same may make it impossible, for CHILI, to use your data for the purposes indicated, and render impossible interaction with the App or the Services offered there.

Personal data provided for the purposes of marketing, promotions and profiling at point 2 letter d) and e) is optional. In this case, without prejudice to the possibility of registering and using the Services available through the App, we inform you that denial to the processing will lead to the impossibility for CHILI, to carry out the abovementioned activities of marketing, promotions and profiling.

7. To whom may your personal data be disclosed and/or transferred?

Your personal data may be disclosed, within the limits strictly relevant to the obligations, duties and purposes mentioned in paragraph 2 above and in compliance with relevant current legislation, to the following categories of entities:

a) CHILI's controlling companies and/or affiliate companies;

b) subcontractors, sub-suppliers and those who are involved in the sale network of CHILI (among whose, by means of example and without limitations, concessionaries, distributors, suppliers etc);

c) commercial promotion companies, commercial partners, operating in the multimedia market, with whom CHILI works for marketing and commercial promotion purposes or marketing campaigns used by the same CHILI;

d) professionals or professional firms entrusted to defend CHILI in administrative and/or litigation proceeding;

e) entities entrusted by CHILI to carry out services related to the management and maintenance of the Site, of the APP and of the relevant Services and/or IT solutions (e.g. cloud services) and software;

f) public safety and judicial authorities;

g) persons, entities or authorities to which the communication of your personal information is mandatory pursuant to the applicable laws or any authorities’ orders.

Personal data communicated will concern only the data necessary for the specific purposes for which it is intended. These aforementioned parties shall process your data as independent Data Controllers or Data Processors. The updated list of these parties may be requested by writing to the DPO at dpo.privacy@chili.com.

Your personal data is not subject to public disclosure.

8. To whom do we transmit your data abroad?

The personal data provided by you to us may be transferred abroad, within the European Union or the European Economic Space, for the fulfilment of obligations imposed by laws, regulations or European legislation, as well as to allow you use the Services offered by CHILI through the App.

CHILI undertakes to constantly monitor the correctness of the data subject of the transfer for the purposes of ensuring the lawfulness and regularity of the processing made on your personal data.

9. For how long do we retain your personal data?

Your personal data will be retained for a period of time no longer than that necessary for the purposes for which they were collected, or subsequently processed, pursuant to legal obligations.

In particular, data will be processed for the purposes of point 2 letters a), b) and c) and will be retained only for the period of duration of the contractual relationships established and, following the ceasing of the same, only for the time necessary in order to ensure the fulfilment of law obligations.

The data processed for marketing and promotional purposes pursuant to point 2 letter d) (including geo-localization data) shall be retained for a period not longer than 12 months, after which they will be deleted or anonymized in a permanent and non-reversible manner.

The data processed for profiling purposes pursuant to point 2 letter e) (including geo-localization data) shall be retained for a period not longer than 12 months, after which they will be deleted or anonymized in a permanent and non-reversible manner.

10. What are your rights regarding the processing of your personal data by CHILI?

At any time, you may ask CHILI to obtain full clarity about the operations that we have described, and to exercise the rights recognized to you under Art. 15 and following of the GDPR, in the manner and to the extent permitted under such pieces of regulation. In particular, as an example, without limitations, you may request from CHILI at any time, with the modalities and the limits set out by the above-mentioned Regulation:

  1. confirmation of whether or not processing is ongoing regarding your personal data, and, if so, to gain access to this data;
  2. the correction of inaccurate and/or incomplete data retained by CHILI and supplied, for example, at the moment of registration or in order to benefit from specific services made available through the App (so-called “right of correction”);
  3. the deletion of the data you have provided to CHILI (the so-called “right to be forgotten”);
  4. the limitation of the data processing (the so-called “right to limitation”);
  5. to receive in a structured format readable from an automatic device the personal data referable to you and to transfer such data to another Data Controller (the so-called “right to portability”).

Furthermore, at any time, you can revoke consent or oppose to CHILI’s processing of your personal data, also limited to marketing and/or profiling purposes as at point 2 , letter d) and e) of the present notice. We inform you also that you may oppose to the processing of your personal data for these purposes by writing to the DPO at the address specified below.

Finally, we inform you that you have also the right to file a claim with the Data Protection Authority.

Any requests made in connection with the exercise of your rights must be sent to CHILI in writing to the DPO at the e-mail address dpo.privacy@chili.com.

11. Links to other websites

The App may contain links to other websites accessible to the user by selecting the appropriate links made available while browsing. The access and consultation of such sites remains extraneous to the activities, checks and/or security measures taken by CHILI.

We wish to inform you that CHILI assumes no responsibility with regard to the processing of personal data carried out by third party sites that may be accessed through the App.

12. Updates to this privacy notice

Please be aware that CHILI, at any time and without being required to provide notice, may modify this policy in order to comply with national and European laws on personal data processing and/or adapt to the adoption of new systems or internal procedures, or for any other reason that would make it appropriate and/or necessary.

The aforementioned changes will be published promptly on the App and shall become immediately binding upon being communicated. Therefore, we encourage you to check this page periodically.

Last update: 25 May 2018