Privacy Policy

CONSUMER PRIVACY POLICY

DJM PICTURES ENTERTAINMENT

Updated: December 12, 2020DJM PICTURES ENTERTAINMENT (“we”, “us”, “our”) is a leading media and entertainment group of companies. This Privacy Policy explains what personal information DJM PICTURES ENTERTAINMENT companies collect, use, share and otherwise process about individuals (“you”) interacting with our Offerings (“Information”). Also, this Privacy Policy does not apply to Digital Services that are online services targeted at children. The DJM PICTURES ENTERTAINMENT family is made up of a number of different legal entities and business units. In this Privacy Policy, the “Controller” of your Information means the company that decides the purposes for which it is processed and how it is processed. Which DJM PICTURES ENTERTAINMENT company is the Controller in relation to the processing of your Information will depend on which Offering you are using; it will often be the DJM PICTURES ENTERTAINMENT company responsible for providing that Offering, as may be set out in our terms and conditions.In some circumstances, more than one Controller may be responsible for processing your Information, for example, where Information is shared with other DJM PICTURES ENTERTAINMENT companies for a purpose set out in this Privacy Policy. Please navigate to our Controller List for more details. If you still have questions about the relevant Controller, please contact us using one of the methods set out below.Under the laws of some countries outside the European Economic Area, we may need your consent to our processing of your Information set forth in this Privacy Policy. Subject to any indications you may give us to the contrary, such as opting out or not opting in if asked, and where permitted by law, by providing Information or otherwise interacting with our Offerings, you consent to our use of Information in accordance with this Privacy Policy.

Please read this policy carefully. It explains the types of Information we may collect about you, the purposes for and methods by which we collect it, and (where applicable) the lawful basis on which we do so, as well as information about data retention, 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 our various Offerings such as those set out below: 
Digital Services:

• DJM PICTURES ENTERTAINMENT websites, including activities run through our websites, such as surveys, research studies, focus group tests, promotions, competitions and prize-draws, purchases within our services, calls to action for user-generated content and subscribing for newsletters;
• Mobile apps, including activities run through our apps, such as those listed for our websites;
• Subscription services or other streaming services offered by DJM PICTURES ENTERTAINMENT to consumers and services where you receive our audio-visual content through our websites, mobile apps and/or via a service provided by a third party, such as an internet service provider, pay TV platform or mobile phone operator;
• Console games;
• Our fan pages/channels/accounts on third party social networks (e.g. official pages on Facebook, Instagram, Twitter).

Offline Services:

• Attractions and exhibitions (e.g. theme parks, marketing activations at conventions or other public places, in person VR experiences) operated by a DJM PICTURES ENTERTAINMENT company; 
• Events you attend as a consumer or guest (as opposed to in a business capacity) such as film premieres, marketing and influencer events, focus group or user tests and private events held at our premises or studios under hire.

Please note that we may combine Information that we collect via one source (e.g. a DJM PICTURES ENTERTAINMENT website) with Information we collect via another source (e.g. a mobile app), including with Information possibly collected by a different DJM PICTURES ENTERTAINMENT company or a third party (as further described below). Please also note our Offline Services may involve you interacting with our Digital Services and vice-versa, for example, where your participation to a marketing event through a DJM PICTURES ENTERTAINMENT website. Certain DJM PICTURES ENTERTAINMENT Offerings (for example, some DJM PICTURES ENTERTAINMENT branded online stores, and in-app purchases) are not operated by DJM PICTURES ENTERTAINMENT but by a third party licensee or the app store; any processing of your personal information by such a licensee or app store is not subject to this Privacy Policy, so please check carefully whether the relevant terms and conditions refer to a DJM PICTURES ENTERTAINMENT company or not. 

We collect, use, share and otherwise process the following categories of Information:1) Information we may collect from you:

• Registration, account, and sign-up Information, including information about you when you register or sign up with us for one of our Offerings (e.g. name, username, password, email, contact details, date of birth or age, interest in our content, etc.) 
• Information about your purchase of an Offering, including relevant payment information (e.g. credit card information). We may also process Information about trial periods, redemptions of rewards or promotions, periods without an active subscription, payment history and any missed payments.
• Information about your use of, or participation in an Offering, including information about whether you have opened an email we have sent you, how you (including any account you use) interact with a Digital Service, content that you have viewed or posted, advertisements you have interacted with, games you have played and the level you reached, your preferences and interest in and use of various features, programs, services and content available on a Digital Service. This may also include demographic information, including at an individual or household level.
• Information you provide when participating in consumer surveys, research studies or focus group tests, including online or written replies and where applicable the recording of your audio or video interviews.
• Entries to promotions, competitions, prize-draws or calls to action, including images, videos and text.
• Camera access, including where for some Digital Services, we ask for permission to access your device’s camera. If you grant permission, you may be able to take pictures or video within the app experience, to send them to us, or to access certain augmented reality (“AR”) features. Some of these features may rely on camera systems to track movements of your eyes and other facial features or your immediate surroundings to apply AR effects.
• Sensitive data, including where you choose to share Information as part of one of our Offerings, or where you provide Information during one of our surveys or feedback sessions, including, where permitted by applicable law, information relating to your physical or mental health, race or ethnicity, religious or philosophical beliefs, sex life or sexual orientation, or your political beliefs. In some Offerings that include dynamic entertainment features, we may with your consent and in accordance with applicable law, collect information such as via facial scanning, eye tracking, or skin response that may be considered biometric.
• Information about your social media engagement, including your interactions with our fan pages/channels/accounts in third party communities, forums, and social media sites, services, plug-ins, and applications (“Social Media Sites”). This may include posts, 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, birthday, and, where you allow us to, lists of friends and people you follow. For information about how you can customize your privacy settings on Social Media Sites, and how those Social Media Sites handle your personal information and content, please refer to their privacy help guides, privacy policies, and terms of use.
• Information shared on DJM PICTURES ENTERTAINMENT public or community forums, including where you share photos, letters, 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 within a community of users. We cannot prevent further use of this Information once you share it in a publicly available or community forum. Please refer to the specific forum’s privacy policies for further information on how they handle your Information. 
• Information about your location, including where it is derived from device information (such as an IP address or country code), your device’s interactions with our Digital Services, or, with your consent, Information about your device’s precise location (e.g. geolocation via mobile devices).
• Event Information, including images and clips, whether captured via a booth or by other means by us or a third party on our behalf, and other Information relating to the organisation and management of an event, such as food allergies and other individual requirements. 
• Technical/usage Information from your device, including the type of device, browser, unique device identifier, operating system, internet provider, mobile device identifier and/or mobile advertising identifier, connected device identifier (including that of a connected television), IP address, network attributes, television device and application attributes and settings, and other device or browser attributes and settings. 
• Information about your customer queries, including when you contact us through one of our customer helpdesks, email addresses, customer service chat boxes, forms or ticketing systems, Social Media Sites and customer call-centres, where calls may be recorded. 

2) Information we may collect about you, from other sources, including friends:
Information from other sources. On occasion, we combine Information with other online information we receive, including usage information about your interactions with other websites and with online advertising and media. We also supplement or combine Information with Information from a variety of other sources or outside records, including third-party data providers that provide us with Information such as demographics, transaction and purchase history; Information about the content and advertisements you interact with. We may also receive Information about you from your friends who invite you to interact with any of our Digital Services. We may receive Information from third parties with which you have a subscription agreement that includes access to our content or services.Information from friends. In certain situations, we may enable friends using our Offerings to provide Information about you. For example, someone can submit Information on our websites to invite you to participate in an Offering, make recommendations or share content through one of our apps, or have multiple players sharing the same game session. By processing these requests, we may receive your Information, including your name, contact details, or information about your interest in and use of our Offerings. 

We may use Information for the purposes described in this Privacy Policy, or as otherwise disclosed at the time of collection. Below, we explain our various purposes, any processing activities that we believe may need further explanation and, where necessary, the ‘lawful basis’ on which we rely to process your Information. Please note that while Information may be processed for more than one purpose (e.g. Information we obtain when Providing Our Offering may also be used for Improving and Developing Our Offering and/or for Marketing and Personalized Advertising), not all of the purposes or processing activities below will necessarily apply in every case. Our particular use of your Information will depend on the Offering you engage with and the manner in which you interact with us, including the permissions you give us (e.g. whether or not you consent to certain uses, such as direct marketing) and other controls you exercise regarding our processing of your Information (e.g. whether or not you choose to opt-out, where this is offered). Your ability to control some of the purposes for which your Information is processed is described in the INDIVIDUAL RIGHTS REQUEST and COOKIES AND OTHER TECHNICAL INFORMATION sections below. 
Marketing and Personalized AdvertisingWe may use your Information for the purpose of marketing and/or advertising our Offerings and those of our clients and partners. DJM PICTURES ENTERTAINMENT uses AdTech technologies, such as real-time bidding, to monetize advertising space within its Digital Services and/or to create a ‘profile’ based on Information about your interactions with us, including our Offerings, our service providers, and our partners and their websites, apps and online advertising, which is used to provide you with personalized advertising and marketing. We may also aggregate information about users to create groups or categories of users, such as ‘segments’, to communicate with you about our offerings and let you know about our clients’ and partners’ offerings, including on Social Media Sites. While processing of your Information for this purpose may involve an algorithm automatically selecting advertising which is intended to be of interest to you, we do not make fully-automated decisions that may have a legal or significant effect on you without either your explicit consent, or where otherwise permitted by applicable law.We may also use UGC for marketing or advertising purposes, subject to the relevant terms and conditions of the Offering.In countries where our processing of Information requires a lawful basis, we rely upon the following:  

• To use UGC you have submitted, we will rely on the rights granted to us under the terms and conditions of the Offering and the performance of our contract with you.
• Other types of processing for Marketing and Personalized Advertising are necessary for our legitimate interests (or those of others), including:
  • Furthering our commercial interests by marketing and advertising Our Offerings, including engaging in contextual (non-data driven) advertising, analytics, and measurement of ad performance; 
  • Expanding our customer base by deepening relationships with existing customers and developing new customers;
  • Promoting the DJM PICTURES ENTERTAINMENT brand both online and offline.
• In certain jurisdictions, for certain types of processing, such as interest-based advertising or where we send direct marketing communications by email, text message or SMS, messages on Social Media Sites, we rely on your consent (where given). 

Providing Customer Services We may use your Information for the purpose of providing Customer Services, including dealing with your queries and complaints (including troubleshooting), whether you contact us by telephone, email, chat boxes, forms or ticketing services, letter, website or via a Social Media Site.In countries where our processing of Information requires a lawful basis, we rely upon the following:  

• Some types of processing activities will be necessary for us to perform our contract with you to provide an Offering. 
• Some types of processing activities will be necessary to comply with our legal obligations.
• Some types of processing will be necessary for our legitimate interests (or those of others), including:
  • Responding to our customer queries and complaints;
  • Tracking the progress and effectiveness of our response; and
  • Improving our Customer Services.

  Detecting, preventing and investigating criminal and other illegal activitiesWe may use your Information for the purpose of detecting, preventing or investigating criminal activities (including fraud and copyright infringement), protecting user safety and enforcing our civil rights in the courts. For example, where necessary, we may share your Information with law enforcement bodies or use it to take legal action against you to enforce our rights.In countries where our processing of Information requires a lawful basis, we rely upon the following:  

• Some types of processing activities will be necessary to comply with our legal obligations.
• Some types of processing will be necessary for our legitimate interests (or those of others), including:
  • Protecting our business interests and rights, privacy, safety and property, or that of our customers and users;
  • Establishing, exercising or defending legal claims; 
  • Sharing your Information with third parties in order to permit us to pursue available remedies or limit damage that we may sustain.

  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 regulators, judicial authorities and law enforcement or governmental bodies.In countries where our processing of Information requires a lawful basis, we rely upon the following:

• These types of activities are necessary to comply with our legal obligations.

We share Information with and disclose it to the following parties, for the purposes set out below:
Linked Third Party Social Media Sites. Some of our Digital Services contain links to other sites, including Social Media Sites, for the purposes of customer interaction and marketing. The information practices of the Social Media Sites can be different from ours so you should consult their privacy policy and terms before submitting your personal information, as we have no control over personal information that is submitted 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, the third parties collect or obtain personal information from you during the activity. We do not control these third parties' use of personal information. We encourage you to read their privacy policies to learn about their data practices. AdTech Providers. We share certain Information with third parties (e.g. other companies, retailers, research organisations, advertisers, ad agencies, advertising networks and platforms, participatory databases, publishers, and non-profit organisations) for processing generally in a hashed or de-identified form, to provide advertising to you based on your interests, including where applicable, through real-time bidding. In some instances, we may also share segments or custom audience data with third parties for marketing purposes. For more information, please see our Marketing and Personalized Advertising purpose above Cookies and Other Technical Information and Ad Choices sections below.Other third parties. In the event of a likely change of control of the business (or a part of the business) such as a sell, a merger, and acquisition, or any transaction, or reorganisation, we may share your Information with interested parties, including as part of any due diligence process with new or prospective business owners and their respective professional advisers. Law enforcement bodies, the authorities and courts. We disclose Information where necessary for the prevention, investigation or prosecution of criminal activities, and also in response to legal process, e.g. in response to a court order or a subpoena, or in response to a regulator, government authority or law enforcement body's request. Public forums. If you post or share Information while interacting with one of our Digital Services, or through a Social Media Site, depending on the nature of the service or your privacy settings this Information can become public, after which, we cannot prevent further use or sharing of this Information. For information about how you can customize your privacy settings on Social Media Sites, please refer to their privacy help guides and terms of use.

In broad terms, we will only retain your Information for as long as is necessary for the purposes described in this Privacy Policy. This means that the retention periods will vary according to the type of Information and the reason that we have collected the Information in the first place. For example, some Information related to the provision of our Offerings to you will be kept for a number of years in order to comply with various finance and tax related legal obligations. We have detailed internal retention policies that set out the various retention periods for different categories of Information, depending on our legal obligations and whether there is a commercial need to retain the Information. After a retention period has lapsed, the Information is securely deleted, unless it is necessary for the establishment, exercise or defence of legal claims. For further information regarding applicable retention periods, you should contact us using the contact methods set out below.

Under certain conditions, you have the right to ask us to fulfil one or more of the following requests. We may ask you for proof of identity or other additional information before doing so.

• Right to access and rectification: You can request details of the Information we hold, along with a copy of your Information, and the correction of any errors in your Information. 
• Right to erasure (“right to be forgotten”): The right, in certain circumstances, to ask for your Information to be deleted. In specific cases, we may not be able to delete some types of Information, in particular, where we have a legal obligation to keep that Information (e.g. for regulatory reporting purposes) or, for example, where you want us to continue to provide you with an Offering and the processing of the Information is necessary for the provision of that Offering.
• Marketing communications and sharing with third parties. We provide you with an opportunity to express your preferences with respect to receiving certain marketing communications from us, and our sharing of Information with trusted partners for their direct marketing purposes. Please see the “Ad Choices” section below for more information. 
• Right to portability: The right in some cases to receive your Information in a digital format or to have it transmitted directly to another controller (where technically feasible).
• Right to object: The right to object (on grounds relating to your particular situation) to the processing of your Information on the basis of our legitimate interests, including for direct marketing purposes. 
• Right to withdraw consent: You can withdraw your consent at any time in respect of any processing of Information which is based upon a consent. 

We will assess any request to exercise these rights on a case by case basis. There may be circumstances in which we are not legally required to comply with a request because of relevant exemptions provided for in applicable data protection legislation. In some instances, this may mean that we are able to retain your Information even if you withdraw your consent. To exercise these rights, or to contact our Data Protection Officer, please submit a request by navigating to the Individual Rights Request Portal.  

When you visit our Digital Services, we, third party service providers, and partners may use "cookies" or similar technologies, such as pixels to provide, develop, maintain, personalize, protect, and improve our Digital Services and their content perform analytics, including to analyse and report on usage and performance of our Digital Services and any advertisements displayed on or delivered by or through them protect against, identify, and prevent fraud and other unlawful activity create aggregate data about groups or categories of our users (including advertising audiences), and for us, our partners and third party service providers to deliver, target, offer, market, or personalise advertising relating to our Offerings or the offerings of our clients and partners (including limiting how often you see an advertisement). 
Cookie Description 
1. Required cookies These cookies are required to enable core website functionality Strictly necessary cookies or similar technologies: They are essential in order to enable you to move around our Digital Services and use their features, such as accessing secure areas. If you disable these cookies, some or all of the Digital Services’ features may not work. 2. Performance cookies These cookies allow us to analyze usage of our Digital Services so we can measure and improve performance Performance cookies or similar technologies: They collect information about how you use our Digital Services, so that we can analyze traffic, understand users' interactions, and improve the relevant Digital Service. Our emails and newsletters may contain a ‘web pixel’ to let us know how you have interacted with what we have sent you. For games, these technologies collect information about your gameplay, including accomplishments, use of features and other in-game activities. We may use third party service providers such as Google Analytics for this purpose who may use their own cookies or similar technologies. You can find out more information by clicking on the Google Analytics cookies usage resource link: https://tools.google.com/dlpage/gaoptout?hl=en 3. Functionality cookies  Functionality cookies or similar technologies: These allow our Digital Services to remember choices you make (such as your username or the region you are in) and provide enhanced, more personalized features, including personalized content. They may also be used to provide Digital Services you have asked for, such as watching a video or commenting on a blog. 4. Advertising cookies These cookies are used by advertising companies to serve ads that are relevant to your interests Social media cookies or similar technologies: These are used when you share Information using a social media sharing button or ‘like’ button via our Digital Services, or when you link your account or engage with our content on or through a Social Media Site, such as Facebook or Twitter. The Social Media Site will record that you have done this, and this Information may be linked to targeting/advertising activities, including building custom audiences. 
Advertising cookies or similar technologies: Some of our Digital Services may use a third-party advertising network, or DJM PICTURES ENTERTAINMENT company, to deliver targeted advertising. They may also have the capability to limit the number of times you see an advertisement and track your browsing or usage across our Digital Services and Social Media Sites.  Managing cookies and other technologies. For Digital Services in some jurisdictions, including the EEA, you may learn more information about our use of cookies and other technologies, and provide or withdraw consents, or set your cookie preferences and in some cases object legitimate interest purposes for processing your personal information, by clicking Manage Cookies+ or otherwise adjusting cookie preferences. These settings are accessible on a site or app specific basis, at any time through the ‘Manage Cookies+’ link or a similar link located on webpages or in application settings. You may also use your app/browser settings to set your cookie preferences.  Marketing communications. We provide you with an opportunity to express your preferences with respect to receiving certain marketing communications from us. If you would like to update these preferences, you can log in to an account you may have created with us to adjust your settings (where the feature is available) or otherwise submit a request by navigating to our Individual Rights Request Portal. You can also follow the ’unsubscribe’ instructions provided in any marketing email you receive.Ad choices. On our own or working with affiliates or third parties, we may present advertisements and engage in data collection, reporting, ad response measurement, and site analytics on our Digital Services and on third party websites across the Internet and applications over time. We, our affiliates, or third parties may use cookies, web beacons, pixels, SDKs, or similar technologies to perform this activity. They obtain information about applications you use, websites you visit, and other information from across your devices and browsers and across websites, services, and apps over time, in order to help serve advertising that will be more relevant to your interests on and off our Digital Services and across your devices and browsers. This type of advertising is known as ‘interest-based advertising’. We, our affiliates, or third parties may also use this information to associate your different browsers and devices together for interest-based advertising and for other purposes like research, analytics, internal operations, fraud prevention, and enhancing consumer experiences.
To learn more about interest-based advertising on mobile apps and to opt out of this type of advertising by third parties that participate in the DAA’s AppChoices tool, please visit the Ad choice link to download the version of AppChoices for your device. Please note that any opt-out choice you exercise through these programs will apply to interest-based advertising by the third parties you select but will still allow the collection of Information for other purposes, including research, analytics, and internal operations. You can therefore continue to receive advertising, but that advertising may be less relevant to your interests.Important things to note about cookie-based web browser opt outs (such as those utilized by the EDAA, APDA and DAAC):

• Blocked cookies: The opt out cookie may not work if your browser is configured to block third-party cookies.
• Deleting or protecting opt outs: If you delete your cookies, you will need to opt out again. There are browser plugins to help you preserve your opt out cookies.
• Only this browser: The opt out only applies to the browser profile in which you set it. For example, if you set the opt out while using Firefox, but then use Chrome, the opt out will not be active in Chrome. To opt out in Chrome, you will need to repeat the opt out process. This is because the cookies cannot be read between different browsers or browser profiles.

The opt out does not block or delete cookies: It also does not prevent the use of cookies or other technologies for purposes other than selecting ads based on your interests as inferred by your online behavior. If you opt out, data may still be collected about your web browsing activities and you will still see advertising. Ads may be selected, for example, based on the content of the web page in which they are shown. If you wish to block or delete cookies altogether, you can use web browser settings to do so.You may have more options depending on your mobile device and operating system. For example, most device operating systems (e.g., iOS for Apple phones, Android for Android devices, and Windows for Microsoft devices) provide their own instructions on how to limit or prevent the delivery of tailored in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating systems to learn more about these features and how they apply to tailored in-app advertisements.Precise location information. To enable or disable the collection of precise location information from your mobile device through our mobile apps, you can access your mobile device settings and choose to limit that collection. You may also limit the collection of precise location information from websites through browser settings.

We operate internationally, and some of the processes involved in our use of your Information will require your Information to be stored or processed in countries outside the country where you are located, including countries where the level of legal protection for your Information may be different and where you may have fewer legal rights in relation to it. In particular, your Information may be transferred to, and processed in the United States, where some of our systems are located.However, whenever we transfer your Information outside of a country or region, such as the European Economic Area, we will make sure that we take steps necessary to comply with applicable legal requirements. Therefore, where required, we will ensure that appropriate safeguards are in place by using appropriate contractual mechanisms, such as the EU Standard Contractual Clauses, or by relying upon the service providers participating in an approved international data transfer mechanism, including the adoption of Binding Corporate Rules. For further information about the documents we use to protect your Information when it is transferred outside of your country or region, please submit a request through our Individual Rights Request Portal.

From time to time, we may update this Privacy Policy. We will notify you about any material changes by placing a notice on our sites. We encourage you to periodically check back and review this policy so that you are up to date.

If you have any questions about this Privacy Policy, you can contact us and our Data Protection Officer at djmpictures.entertainment@gmail.com

If you are unhappy with how we have dealt with your query, in the first instance please contact us at djmpictures.entertainment@gmail.com. If you are still unhappy with our response, you may have the right to complain to your Data Protection Authority. Please contact us at djmpictures.entertainment@gmail.com to obtain details of how to contact them.