Privacy Policy
This Privacy Policy explains what personal information Kino Club, a platform under the company Sandrew Metronome Danmark A / S ("SMDK"), collects, uses, passes on, and otherwise processes about individuals (hereinafter referred to as "you"), who is interacting with our platform (hereinafter referred to as "information").
In this Privacy Policy, the "data controller" for your information is the company Sandrew Metronome Danmark A / S, which decides for what purposes, what information is to be processed and how.
If you have any questions regarding the data controller, please contact us using one of the ways we have listed below.
Under the laws of some of the countries outside Europe's economic territory, we may need your consent to process your information as described in this data protection policy. Subject to any expressions, you give us, that is misleading, such as to opt out or not sign up for, when prompted and, where permitted by law, you agree that we may use your information in accordance with this Privacy Policy by providing your information or by otherwise interacting with our platform.
SCOPE OF THIS PRIVACY POLICY
Read this Privacy Policy carefully. It explains the types of information we collect about you, the purposes and methods we collect for and on, and (where applicable) the legal basis on which we do so, as well as information regarding the storage of your information, your rights, and how to contact us. This Privacy Policy covers both our online and offline data processing activities, including information that we collect through various offers, such as those listed below:
Digital services:
• Kino Club’s websites, including activities taking place on our websites, such as promotions, contests, purchases made on our services, calls for actions for user-generated content (hereinafter "BGI") and subscription to newsletters.
• Mobile apps, including activities that take place through our apps, such as those listed on our websites.
• Subscription services or other streaming services offered by Kino Club to consumers and services, where you receive our audiovisual content through our websites, mobile apps, etc. and / or through a service provided by a third party, such as an Internet service provider, TV platform or mobile phone provider.
• Our fan pages / channels / accounts on third party social networks (e.g. official pages on Facebook, Instagram, Twitter, etc.).
Please note that we may combine the information we collect through one source (such as a Kino Club website) with information we collect through another source (such as a mobile app), including information that may have been collected. by a third-party licensee or app store. Any processing of your personal information by such licensee or app store is not part of this Privacy Policy. So please check carefully whether the terms and conditions in question refer to Sandrew Metronome Danmark A / S (Kino Club) or not.
THE INFORMATION WE COLLECT
We collect, use, share and otherwise process the following categories of information:
1) Information we collect from you:
• Registration, account, and registration information, including information about when you register or register with Kino Club (e.g., name, username, password, e-mail, contact information, date of birth or age, interest in our content, etc.)
• Information about your purchase of an offer, including relevant payment information (e.g., credit card information). We can also process information regarding trial periods, periods without an active enrolment, payment history and any forgotten payment.
• Information about your use of an offer, including information about whether you have opened an email we have sent you, how you (including any account you use) interact with the platform, content you have seen or written about, advertisements and more content you have interacted with, your preferences and interest in and use of various features, programs, services, and content available on the platform. It may also include demographic information.
• Information you provide when participating in consumer surveys, including online or written responses.
• Entries for contests or invitations to action, including photos, videos, and text.
• Information about your use of social media, including interactions on our fan sites / channels / accounts with third-party communities, forums, and social media sites, services, plug-ins, and applications (hereinafter referred to as "social media sites"). This may include postings, your "likes" and other user-generated content that you may provide, as well as details about yourself such as your name, user ID, profile photo and birthday. For information on how to customize your privacy settings on social media websites, and how the social media pages process your personal information and content, we refer to their Privacy Guidelines, Privacy Policy, and Terms of Use.
• Information shared on Kino Club's public forums, including where you share photos, videos or comments while participating in online forums. Depending on your privacy settings, this information or content and your username may become public on the Internet or in a user community. We cannot prevent further use of this information once you share it in a public space or in a community forum. We refer to the specific forums privacy policy for more information on how they process your information.
• Information about your location, including device information about where your device originates (such as IP address or country code), your device's interactions with our digital Service or our content, information about your device's exact location (e.g., geographic location via mobile devices).
• Event information, including photos and clips, whether recorded through a booth or otherwise by us or a third party on our behalf.
• Technical information / usage information from your device, including device type, browser, unique device identifier, operating system, ISP, mobile phone identifier and / or mobile ad identifier, IP address, network properties, TV device and application properties and settings, and other devices or browser properties and settings.
• Information about your customer requests, including when you contact us through our contact forms, email addresses, or otherwise.
2) Information we may collect about you from other sources, including friends:
Information from other sources. We supplement or combine information from a variety of other sources or outside records, including third-party data providers that provide us with information such as demographics, transactions and purchase history, or information about content and advertisements you interact with. We may also receive information from third parties with whom you have a subscription agreement that includes access to our content or services.
HOW WE USE THE INFORMATION
We may use the information described in this Privacy Policy, or which has been disclosed at the time of collection. Below we explain our various purposes, any processing activity that needs further explanation and, where necessary, the "legal basis" that we have for processing your information.
Please note that while information may be processed for more than one purpose (e.g., the information we receive when we deliver our offers may also be used to improve and develop our offers and / or for marketing and personal advertising), not all purposes or treatment activities below will necessarily apply in all cases. Our particular use of your information depends on the offer you have chosen to take advantage of and the way you interact with us, including the permissions you give us (e.g., whether or not you consent to certain types of use, such as direct marketing and other rights that you exercise regarding our processing of your information .Your ability to control some of the purposes for which your information is processed is described in INDIVIDUAL REQUESTS FOR RIGHTS and COOKIES AND OTHER TECHNICAL INFORMATION sections below.
Delivery of our offer
We use your information for the purpose of creating your account with us, to register you for an offer, to enable you to pay for it, to deliver the offer, to give you permission to participate in offers, competitions, to encourage you to act or to maintain the offer and resolve any issues. This may include enforcing applicable terms and conditions (e.g., for our subscription services, limiting the number of devices and displaying the correct content based on location) and optimizing the delivery of the offer to each specific device used to access it and to provide the "keep watching" feature on our subscription services.
In countries where our processing of information requires a legal basis, we rely on the following:
• Much of our processing, such as the delivery and maintenance of our offerings, is necessary to enter into or comply with the contract we have with you, including enabling new customers to sign up or register with us and existing customers to log in to our Service.
• Other types of treatment are necessary for our (and others') 'legitimate interests', including:
• Run our business, deliver our offerings and serve our customers;
• Contact customers with important announcements or updates;
• Contact customers about their transactions and purchases;
• Personalize content and make content recommendations;
• Use and / or enforce the rights granted to us under the terms and conditions of the offer.
• Make payment easier for our offers.
Improvement and development of our offer
We use your information for the purpose of analyzing, improving, personalizing and evaluating our offers and your use of them, as well as developing new offers.
In countries where our processing of information requires a legal basis, we rely on the following:
• Other types of treatment are necessary for our (and others') legitimate interests, including:
• Improvement and development of our offer.
• Create efficiency in our business.
• Understand consumer trends and interests, including consumer insights, market research and content performance measurement.
• Compile statistics on the use of our offers.
Marketing and personal advertising
We use your information for marketing purposes and / or to advertise our offers, including offers from our partners. SMDK may use AdTech technologies to monetize digital services and / or to create a 'profile' based on information about your interactions with us, including our offers, our service providers, and our partners and their websites, apps, and online advertising, which is used to provide personalized advertising and marketing to you. We may also collect information about users to create groups or categories of users, such as' segments ', to communicate with you about our offers and tell you about our clients and partners' offers, including on social media pages.
The processing of your details for this purpose may include an algorithm that automatically selects advertising that is designed to be of interest to you, but we shall not make automatic decisions, which may have a legal or material effect on you without your expressed consent, or where otherwise permitted by applicable law.
In countries where our processing of information requires a legal basis, we rely on the following:
• Other types of processing of marketing and personal advertising are necessary for our legal interests (and others), including:
• To promote our commercial interests with marketing and by advertising our offers, including engagement in contextual (non-data-driven) advertising, analysis, and measurement of ad effectiveness.
• To expand our customer base by deepening the relationship with existing customers and attracting new customers.
• To promote the Kino Club brand both online and offline.
• In certain jurisdictions, for certain types of processing, such as interest-based advertising, or where we send direct marketing via email, text messages, or SMS, messages on social media pages, we rely on your consent (where given).
Customer Service Delivery
We may use your information for the purpose of providing customer service, including handling your inquiries and complaints (including troubleshooting), whether you contact us by phone, email, chat boxes, forms, letter, website, or via social media pages.
In countries where our processing of information requires a legal basis, we rely on the following:
• Some types of processing activities are necessary for us to fulfill our contract with you to provide one of our offers.
• Some types of processing activities are necessary to fulfill our legal obligations.
• Some types of processing are necessary for our (and others') legitimate interests, including:
• Responding to our customer inquiries and complaints.
• Monitoring the development and effectiveness of our responses.
• Improving our customer service.
Detection, prevention, and investigation of criminal and other illegal activities
We may use your information for the purpose of detecting, preventing, or investigating criminal activities (including fraud and copyright infringement), protecting the safety of our users, and enforcing our rights in court. For example, we may, where necessary, share your information with law enforcement agencies or use them to bring a case against you to enforce our rights.
In countries where our processing of information requires a legal basis, we rely on the following:
• Some types of processing activities are necessary to fulfill our legal obligations.
• Some types of processing activities are necessary for our (and others') legitimate interests, including:
• Protecting our - or our customers' and users' - business interests and rights, privacy, security, and property.
• Establishing, exercising, or defending legal claims.
• Sharing your information with third parties to obtain permission to proceed with the available remedies or limit damages we may suffer.
Compliance with Legal Obligations
We may use your information for the purpose of complying with our legal obligations, including accounting rules, responding to individual rights requests, and responding to requests from regulatory authorities, judicial authorities, or law enforcement or government agencies.
In countries where our processing of information requires a legal basis, we rely on the following:
• These types of activities are necessary to fulfil our legal obligations.
SHARING AND DISTRIBUTING INFORMATION
We share and disclose information with the following parties for the purposes below:
Within the Sandrew Metronome Group
SMDK is part of the companies in the Sandrew Metronome Group. Sandrew Metronome companies support and interact with each other to conduct their business. As a result, a Sandrew Metronome company may receive your information for processing for the purposes described in this Privacy Policy, where there is a legal basis for doing so, and it is done in accordance with the permissions you have given (e.g., whether you want or do not want to receive marketing material), and other controls you apply regarding our processing of your information (e.g., where you have chosen to opt out of a particular processing), as described in the section INDIVIDUAL REQUESTS ABOUT RIGHTS and COOKIES AND OTHER TECHNICAL INFORMATION below.
Outside the Sandrew Metronome Group
Third-Party Service Providers. Our subcontractors have access to information to help perform the services they perform for us, such as, but not limited to, fulfilment, creation, maintenance, hosting, delivery of our offers, making marketing, providing IT services and security, managing payments, sending emails and order fulfillments, administering contests, conducting research, measurements, and analysis, deriving insights, or providing customer service.Affiliated Third-Party Social Media Sites. Some of our digital services may contain links to other websites, including social media sites, for customer interaction and marketing purposes. The information practices on social media sites may differ from ours, so you should read their privacy policies and terms before submitting your personal information, as we do not control the personal information sent to or collected by these third parties.
Third-Party Partners. We sometimes offer digital services and offline services that are sponsored by or co-branded with identified third parties. By virtue of these relationships, third parties may collect or obtain information from you during the activity - either personal information or information in an aggregated or non-identifiable form. We do not control the use of personal information by these third parties. We encourage you to read their privacy policies to learn about their practices for processing personal information.
AdTech Providers. We sometimes share certain information with third parties (e.g., other companies, retailers, research organisations, advertisers, advertising agencies, advertising networks and platforms, participating databases, publishers, and nonprofit organisations) for processing generally in an aggregated or non-identifiable form to deliver advertising to you based on your interests. In some cases, we may also share segments or custom audience data with third parties for marketing purposes. For more information, please see the sections (i) Marketing and Personal Advertising above (ii) Cookies and Other Technical Information and (iii) Additional Choices below.
Other Third Parties. In the event of a potential change of control of the Sandrew Metronome Group (or part thereof), or in the event of a merger, acquisition, or other transfer of the business, we reserve the right to transfer or assign the information we collect in connection with such corporate transactions, subject to the applicable law.
Third-Party Payment Services Providers. We use third-party payment service providers to process payments made to us. For more information about the payment process and the data collected as part of this process, please see the third-party payment service provider's privacy policy and terms of service.
Professional Advisors. We may also share your information with our professional advisors, such as lawyers, accountants, and auditors.
Regulators, Authorities, and Law Enforcement. We may share your information with regulatory authorities, judicial authorities, or law enforcement or government agencies as required by law, regulation, or legal process, or when we believe that disclosure is necessary to protect our rights, or the rights of others, including in the context of a criminal or regulatory investigation, or to protect the safety, property, or rights of any person.
YOUR CHOICES AND RIGHTS
You have certain rights and choices concerning the processing of your information, including:
Access and Correction Rights. You can request access to and correction of your personal information processed by us. Some of our digital services allow you to correct, change, or delete personal information that you have provided to us.
Communication Preferences. You can manage your communication preferences (e.g., opt-in or opt-out from receiving certain communications) through your account settings, where applicable.
Cookies and Other Technical Information. You can manage your cookie preferences and other technical information by adjusting your browser or device settings to accept or reject cookies, or to notify you when a cookie is set. However, if you choose to reject cookies or similar technologies, some parts of our digital services may not function properly.
Marketing Preferences. You can manage your marketing preferences (e.g., opt-in or opt-out from receiving marketing communications) by following the instructions provided in the communication or by contacting us as described in the section CONTACT US below.
Withdraw Consent. If you have given us your consent to process your information for certain purposes (e.g., for marketing purposes), you can withdraw your consent at any time by contacting us as described in the section CONTACT US below. Please note that the withdrawal of your consent will not affect the lawfulness of processing based on consent before its withdrawal.
Objection to Processing. You can object to certain types of processing of your information, such as processing for marketing purposes, by contacting us as described in the section CONTACT US below. In some cases, you may have the right to object to processing on grounds relating to your particular situation.
Data Portability. In certain circumstances, you may have the right to receive your personal information in a structured, commonly used, and machine-readable format and to request the transfer of your personal information to another data controller.
Complaints. If you believe that we have not complied with applicable data protection laws, you have the right to lodge a complaint with a supervisory authority in the country where you reside, work, or where the alleged violation occurred.
To exercise your rights and choices, or if you have any questions or concerns about our Privacy Policy or our practices regarding your information, please contact us using the contact information provided in the section below.
Please note that we may require you to provide additional information to verify your identity before responding to your request. We will respond to your request within the timeframes required by applicable law.
RETENTION OF INFORMATION
We will retain your information for as long as necessary to fulfil the purposes for which it was collected, for as long as necessary to comply with our legal obligations, resolve disputes, protect our assets, and enforce our agreements, or for as long as necessary to defend legal claims. The criteria we use to determine the retention periods for different types of information include the nature and sensitivity of the information, the potential risk of harm from unauthorised use or disclosure of the information, the purposes for which we process the information, and whether we can achieve those purposes through other means, as well as applicable legal requirements.
INTERNATIONAL TRANSFERS OF INFORMATION
We may transfer your information to other countries, including countries outside the European Economic Area (EEA), which may have different data protection laws than your country. When we transfer your information to other countries, we will protect that information as described in this Privacy Policy, and we will take appropriate safeguards to ensure that your information is adequately protected in accordance with applicable law.
For transfers from the EEA to countries that have not been recognised by the European Commission as providing an adequate level of protection for personal information, we use standard contractual clauses approved by the European Commission or other appropriate safeguards to ensure an adequate level of protection for your information. You can request a copy of the appropriate safeguards by contacting us as described in the section CONTACT below.
CHILDREN'S PRIVACY
Our digital services are not directed to children under the age of 16, and we do not knowingly collect personal information from children under the age of 16. If you are under the age of 16, please do not use our digital services or provide us with any personal information. If we become aware that we have collected personal information from children under the age of 16 without verification of parental consent, we will take steps to remove that information from our servers.
UPDATES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time in response to changing legal, technical, or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material changes to this Privacy Policy that affect your rights or obligations under this Privacy Policy if and where required by applicable law. We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the ways you can help protect your privacy.
CONTACT US
If you have any questions or concerns about our Privacy Policy or our practices regarding your information, please contact us at:
Data Protection Officer
Sandrew Metronome
Boulevarden 6 – 2 sal
9000 Aalborg
Denmark
Email: dpo@sandrewmetronome.com
Please include your name, address, and/or email address when you contact us so that we can handle your request properly.
Updated: February 26th, 2024
