About This Policy
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Who We Are
Our legal status under applicable data protection law is that of a “data controller” (meaning that we decide the purposes for which and the ways in which your personal information is collected and used) and in this capacity we will securely store and process your personal information.
Please be aware that some of the services provided on the LesFlicks platform are only accessible to registered users via a password. It is your responsibility to keep your password secure at all times.
The Information We Collect
The better we know you the better we can make LesFlicks’ digital products and services work for you and give you a more personalised experience.
Information provided by you
We may collect the personal information stated below, when, for example, you register for an account with LesFlicks; subscribe to one of our newsletters or other digital services; enter a competition; vote or post comments or other material on LesFlicks website or social media channels; complete the contact us form; or respond to any other specific requests we make on our LesFlicks site:
(ii) user name;
(iv) date of birth;
(vii) email address; and
(viii) any queries, comments or material that you submit via LesFlicks website or social media channels.
Information about your use of LesFlicks Services
During your visit to, or use of, LesFlicks, we will also collect information about:
- Your visit (e.g. time, date, duration, pages viewed);
- The resources that you access or online services that you use; and
- How you access LesFlicks (e.g. IP address, operating system, browser type).
If you use our live or video on-demand programme services, we also collect information about:
- The programmes that you watch and any interaction with them;
- The adverts which are displayed to you and any interaction with those adverts (e.g. clicking to view further information);
- Quality of service and diagnostic information concerning video streams; and
- The time, date and duration of your viewing session.
We also receive lifestyle and demographic insight information about you from our trusted advertising partners which we use to provide you with tailored advertising (see the How We Use Your Personal Information section below for more information about this).
How We Use Your Personal Information
We will use your personal information:
(i) Where it’s necessary to fulfil a contract with you: in particular, in providing and delivering the LesFlicks Services (including, enabling participation in interactive features such as competitions and votes);
(ii) When it’s in our legitimate interests to do so and when these interests are not overridden by your data protection rights: in particular:
- facilitating the creation of, and securing users’, accounts on LesFlicks;
- communicating with you;
- monitoring and improving LesFlicks’ Services and for statistics and analytics purposes, which may include analysing the effectiveness of our marketing campaigns;
- resolving disputes and/or troubleshooting problems;
- for system administration purposes (please note that the information used for these purposes is limited to statistical data about your browsing actions and patterns); and
- to help us personalise the services and communications you receive (including tailored advertising), which means that, in turn, (i) we are able to maximise the revenue that we generate from advertising to help us to cover the costs of the free services which we provide to you and (ii) bring you relevant adverts on third party services. Personalisation is automated and may be based on various factors such as your age, postcode or gender, your device details or your inferred interests (which may come from the programmes you watch, preferred channels or time of viewing or other information which we learn about you from other sources). We will enable our advertising partners to display more tailored advertising to you. By interacting with, or viewing, an advert, you should be aware that that third party may make the assumption that you meet the targeting criteria used to display the advert.
(iii) Consent: We will ask you for your consent to collect or process your personal information on certain occasions, in particular:
- In order to send you information about the latest LesFlicks news, and / or the digital products and services offered by LesFlicks. We may contact you by various methods (including by post, email, telephone or SMS) where you have indicated that you wish to receive marketing via such channels. We will make the method(s) of communication clear at the point at which we ask for your consent. You are able to manage the way we contact you by editing the ‘Manage my Preferences’ section under your profile on LesFlicks, and can also opt out of receiving marketing emails from us by clicking on the unsubscribe link included in those emails. In addition to or in combination with the details which you have provided (such as your gender, postcode or date of birth), we may use other information about your use of our LesFlicks Services (such as programmes watched, preferred channels, time of viewing) to identify products and services which are more likely to be of interest to you.
Please note that whenever we ask for your consent in order to process your personal data, you may withdraw this consent at any time by contacting us using the contact details provided below; and
(iv) Where we’re required to do so by law: For example, if we receive a request from law enforcement or other government officials.
You control the data we hold on you:
When you register you will be given the opportunity to indicate whether or not you are happy for us to use your personal information in order to tell you about our offers, products or services. You can control the way in which we contact you by editing your marketing preferences information in the ‘Manage my Preferences’ section of your LesFlicks Profile.
If you would like us to stop using your personal information for targeted advertising purposes, you can send us an email at email@example.com. Please note that if you opt out of profiling and targeted advertising, this does not mean that you will receive less advertising when you use our LesFlicks Services. This just means that the advertising you see may not be as relevant to you.
Where We Store Your Personal Information
How We Keep Your Personal Information Secure
We take privacy issues very seriously and we understand that keeping your personal information secure is very important to you. When handling personal information, security is paramount and we use all reasonable measures to safeguard your information and to ensure it is adequately protected.
Our system is hosted by service providers whom we consider to have good reputations for security, but please note that we cannot guarantee that any personal information transmitted over the internet is completely secure.
Disclosure of Your Personal Information
We will disclose your data to our suppliers to the extent that they need access to your data in order to provide us with their services. We will only use suppliers who provide sufficient guarantees as to the processing of your data, including in relation to keeping it secure.
You should be aware that if we are requested by the police or any regulatory or government authority investigating suspected illegal activities to provide to them your personal information and/or information concerning your activities whilst visiting the site, we shall be entitled to do so.
We are also entitled to disclose your personal information to third parties if we are under a duty to disclose or share your personal information in order to enforce or apply our Terms and Conditions and other agreements; or if we reasonably consider this necessary; or to protect the rights, property, or safety of us, our customers, or others.
If our business is sold or integrated with another business, your personal information will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.
We will disclose your personal information to our trusted advertising partners for the purpose of assisting us in delivering tailored advertising, as more fully described above.
You have various rights with respect to our use of your personal information:
- Access: You have the right to request a copy of the personal information that we hold about you. Please note that there are exceptions to this right, so that access may be denied if, for example, making the information available to you would reveal personal information about another person, or would reveal trade secrets, or if we are legally prevented from disclosing such information. If we have deleted or anonymised your data then we won’t be able to provide you with a copy of that data. If you wish to exercise this right, please contact us using the contact details provided below.
- Accuracy: We aim to keep your information accurate, current, and complete. We encourage you to contact us using the contact details provided below to let us know if any of your personal information is not accurate or changes, so that we can keep your personal information up-to-date. You can also review and correct/update some of your personal information by logging-in to your account and going to your Profile, if you have registered on one of the LesFlicks Services.
- Objecting: In certain circumstances you also have the right to object to processing of your personal information: (i) which is based on our legitimate interests; (ii) for direct marketing purposes; and (iii) for profiling to the extent that it is related to direct marketing. If you would like to object to (i), please contact us using the contact details provided below. Please see the How We Use Your Personal Information section above for information on how to object to (ii) and (iii).
- Erasing and Restricting: You have the right to ask us to erase or restrict your personal information. If you would like us to stop using your personal information, please contact us using the contact details provided below. Please note that there are exceptions to these rights, if, for example, we are under a legal obligation to continue to process your personal information.
- Porting: You have the right to request that your personal information is ported to you.
- Complaints: If you believe that your data protection rights may have been breached, you have the right to lodge a complaint with the supervisory authority in the country of your habitual residence, place of work or of the potential breach, or to seek a remedy through the courts. The supervisory authority in the UK is the Information Commissioner’s Office, whose website at ico.org.uk provides information on how you can lodge a complaint.
When we ask you to supply us with information we will make it clear whether the information we are asking for must be supplied so that we can provide the products and services to you, or whether the supply of any information we ask for is optional. For example, registration is mandatory to use LesFlicks on most platforms, and certain minimum details must be submitted in order to enter our competitions.
How Long We Keep Your Personal Information For
We will retain your personal information, whether or not your account is active, for as long as we reasonably believe it necessary to fulfil our business purposes or to comply with applicable law, audit requirements, regulatory requests or orders from competent courts. We will then delete or anonymise it. For example, we will normally delete or anonymise your LesFlicks account after 3 years of inactivity, but we will email you to warn you first.
The LesFlicks Services may contain links to other websites over which we have no control. We are not responsible for privacy policies or practices of other websites to which you choose to link from LesFlicks. We encourage you to review the privacy policies of those other web sites so you can understand how they collect, use and share your personal information.
You may contact us as follows:
- Email: firstname.lastname@example.org
- Post: 16 Falkland House, Bromley Road, London SE6 2RN
Last updated: 1 March 2019