Privacy Policy

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Privacy Policy

What does this Privacy Policy Cover?

Glasgow Film respects your privacy and is committed to protecting your Personal Data. We want to be transparent with you about how we collect and use your Personal Data where we may collect it through our various points of interaction with customers (be this through our website, our box office system and our mailing processes), and tell you about your privacy rights and how the law protects you.

With that in mind, this Privacy Policy is designed to describe:

Who we are and how to contact us
Your rights relating to your Personal Data
Marketing communications preferences
What Personal Data we collect
How we use your Personal Data and why
What happens when you do not provide necessary Personal Data
How we use cookies and other tracking or profiling technologies
Who we share your Personal Data with
How we keep your Personal Data secure
How long we store your Personal Data
Our policy on children
Third-party links

This Privacy Policy aims to give you information on how Glasgow Film collects and processes your Personal Data which you may provide to us. This covers any data you may provide through this website, by email, in person or by phone.

The Privacy Policy is intended to meet our duties of Transparency under the “General Data Protection Regulation” or “GDPR”.

We will post any modifications or changes to this Privacy Policy on this page.

Who we are and how to contact us

Glasgow Film is the Controller (for the purposes of the GDPR) of your Personal Data (referred to as either Glasgow Film, “we”, “us” or “our” in this Privacy Policy).

Our address is: 12 Rose Street, Glasgow G3 6RB.

Glasgow Film is the trading name of The Glasgow Film Theatre (company registration number SC097369, Scottish charity registration number SC005932). Within this entity, we also operate Glasgow Film Festival, Glasgow Youth Film Festival and Film Hub Scotland.
This Privacy Policy covers all areas of operation within Glasgow Film.

You can contact us with any questions regarding personal data by emailing: finance@glasgowfilm.org or in writing to us at:

Data Protection
Glasgow Film
12 Rose Street
Glasgow
G3 6RB

Your rights relating to personal data

By law, you have the right to:

Request access to your Personal Data: This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

Request correction of the Personal Data that we hold about you: This enables you to have any incomplete or inaccurate information we hold about you corrected.

Request erasure of your Personal Data: This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).

Object to processing of your Personal Data: This right exists where we are relying on a legitimate Interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.

Request the restriction of processing of your Personal Data: This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.

Request the transfer of your Personal Data: We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent: This right only exists where we are relying on consent to process your Personal Data (“Consent Withdrawal”). If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of our Site. We will advise you if this is the case at the time you withdraw your consent.

How to exercise your rights

If you want to exercise any of the rights described above, please contact us at finance@glasgowfilm.org.

Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, in relation to Consent Withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Instead of applying a fee in such circumstances, we may refuse to comply with your request.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Complaints

If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your Personal Data, please email us at feedback@glasgowfilm.org or in writing to us at:

Data Protection
Glasgow Film
12 Rose Street
Glasgow
G3 6RB

We will reply to your complaint as soon as we can.

If you feel that your complaint has not been adequately resolved, please note that the GDPR gives you the right to contact your local data protection supervisory authority, which for the UK is the Information Commissioner’s Office.

Marketing Communications Preferences

You can ask us to stop sending you marketing messages at any time by logging onto our website and unchecking the relevant boxes to adjust your marketing preferences, by following the “unsubscribe from this list” or “update subscription preferences” links on any marketing message sent to you or by contacting us at any time using the contact details shown above.

Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of purchasing tickets (such as booking confirmation emails or correspondence regarding the purchase or renewal of a CineCard membership).

What Personal Data we collect

All the Personal Data we collect, both from you and from third parties about you, is outlined below.

Before proceeding, it might be useful to explain what “Personal Data” is. The GDPR definition of Personal Data can be found here. Essentially, it boils down to: information about an individual, from which that individual is either directly identified or can be identified.

It does not include ‘anonymous data’ (that is, information where the identity of individual has been permanently removed).

However, it does include ‘indirect identifiers’ or ‘pseudonymous data’ (that is, information which alone does not identify an individual but, when combined with certain additional and reasonably accessible information, could be attributed to a particular person).

Category of Personal Data which may be collected	What this means
Identity Data	First name, surname, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender.
Contact Data	Your home address, work address (for corporate customers, schools and suppliers), billing address, email address, telephone numbers.
Financial Data	Your bank account and payment card details.
Transaction Data	Any details about payments to and from you and other details of subscriptions and services you have purchased from us. Data in respect of your transactions with third parties (including your credit history).
Marketing and Communications Data	Your preferences in receiving marketing from us and our third parties and your communication preferences.
Behavioural Data	Inferred or assumed information relating to your behaviour and interests, based on your online activity. This is most often collated and grouped into “segments” (for example, there may be a segment for women, who like films from a particular country).
Technical Data	Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website or use our services.

We record static or moving imagery of customers and staff via our CCTV system for the prevention and detection of crime, and for safety and security reasons.

Personal data (including CCTV imagery) will be shared with government authorities and/or law enforcement officials for the prevention or detection of crime, if required by law or if required for a legal or contractual claim.

Aggregated Data

We also collect, use and share “Aggregated Data” such as statistical or demographic. Aggregated Data may be derived from your Personal Data, but once in aggregated form it will not constitute considered Personal Data for the purposes of the GDPR as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

Special Categories of Personal Data

We do not collect any “Special Categories of Personal Data” about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). We do not collect any information about criminal convictions and offences.

Gender and date of birth do not fall under these “special categories”. So when we ask for an appropriate form of ID for proof of age to ensure eligibility for a 15-25 Card or to allow admission to an age-restricted screening, we may record this information.

How we use your Personal Data and why

We will only use your Personal Data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your Personal Data for an unrelated purpose, we will update this Privacy Policy and we will explain the legal basis which allows us to do so.

Our “legal basis” for processing your Personal Data

In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases:

Contractual Necessity: Where we need to perform a contract we are about to enter into or have entered into with you

Legitimate Interests: Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests. More detail about the specific legitimate interests pursued in respect of each Purpose we use your Personal Data for is set out in the table below

Compliance with Law: Where we need to comply with a legal or regulatory obligation

Consent: Where we have your specific consent to carry out the processing for the Purpose in question

Generally we do not rely on your Consent as a legal basis for using your Personal Data other than in the context of direct marketing communications.

Set out below are legal bases we rely on in respect of the relevant Purposes for which we use your Personal Data:

Purpose	Categories of Personal Data involved	Why do we do this	Our legal basis for this use of data
Account Creation	Identity Data Contact Data	To register you as a new customer.	Contractual Necessity
To process payments for tickets and CineCard memberships (and their associated services and functionalities), and online donations.	Identity Data Contact Data Finance Data Transaction Data	To process and deliver your order including manage payments, fees and charges.	Contractual Necessity
Fraud Prevention	Identity Data Contact Data	To keep our website, our services and associated systems operational and secure.	Legitimate Interests We have a legitimate interest in ensuring the ongoing security and proper operation of our services, website and associated IT services and networks.
Troubleshooting	Technical Data	To track issues that might be occurring on our systems.	Legitimate Interests It is in our legitimate interests that we are able to monitor and ensure the proper operation of our Sites and associated systems and services.
Marketing	Identity Data Contact Data Marketing and Communications Data	To form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.	Legitimate Interests We have a legitimate interest in providing you with updates on our Sites and related offers where you have purchased or shown interest in similar services from us.

What happens when you do not provide necessary Personal Data

Where we need to process your Personal Data either to comply with law, or to perform the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the functionalities of the website).

In this case, we may have to stop you using our website but we will notify you if this is the case at the time.

Personal Data from Third Party Sources

In addition to the Personal Data that we collect directly from you (as described in the section immediately above this one), we also collect certain of your Personal Data from third party sources. These sources are broken down in the table below, together with a description of whether they are publicly available or not.

Third-party data source	Publicly available?	Categories or other types of personal data received
Social Media sites	Yes	Identity Data Contact Data
Analytics Providers	No	Behavioural Data Technical Data
Advertisers	No	Behavioural Data Technical Data

How we use cookies & other tracking or profiling technologies

Cookies

What are cookies?

We collect information using “cookies”. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Site.

We use two broad categories of cookies:

first-party cookies, served directly by us to your computer or mobile device; and
third-party cookies, which are served by service providers on our Site [eg. embedded Youtube videos].

Cookies we use

Our Site uses the following types of cookies for the purposes set out below:

Type of cookie	Purpose
[Essential Cookies]	These cookies are essential to provide you with services available through our Site and to enable you to use some of its features. For example, they allow you to log in to secure areas of our Site and help the content of the pages you request to load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
[Functionality Cookies]	These cookies allow our Site to remember choices you make when you use our Site, such as remembering your login details and remembering the changes you make to other parts of our Site which you can customise. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our Site.
[Analytics and Performance Cookies]	These cookies are used to collect information about traffic to our Site and how users use our Site. The information gathered via these cookies does not “directly” identify any individual visitor. However, it may render such visitors “indirectly identifiable”. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our Site. The information collected is aggregated and anonymous. It includes the number of visitors to our Site, the websites that referred them to our Site, the pages they visited on our Site, what time of day they visited our Site, whether they have visited our Site before, and other similar information. We use this information to help operate our Site more efficiently, to gather broad demographic information and to monitor the level of activity on our Site. We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how our Site works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies. You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.
[Social Media Cookies]	These cookies are used when you share information using a social media sharing button on our Site. The social network will record that you have done this.

Disabling cookies

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings”, “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings.

If you do not accept our cookies, you may experience some inconvenience in your use of our Site. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our Site.

Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com/uk.

You can also prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB

Who we share your Personal Data with

Described below are external organisations who we may share your Personal Data with, what we share and why we share it:

Recipients	Categories of Personal Data we may share	Why we may share it	Location
Service Providers	Identity Data Contact Data Technical Data	Our service providers provide us with IT and system administration services.	Within Europe United States
Professional Advisers	Identity Data Contact Data	Our auditors, lawyers, bankers and insurers provide accounting, consultancy, banking, legal and insurance services.	Within Europe
HM Revenue & Customs, regulators and other authorities	Identity Data Contact Data	Authorities may require reporting of processing activities in certain circumstances	Within Europe

Presently, Glasgow Film works with two third parties which handle Personal Data from outwith the European Economic Area (being the European Union plus Norway, Liechtenstein and Iceland) (“Europe”). These are:

MailChimp, based in the United States, which is the platform we use to send direct emails from the Education Team to customers or subscribers.
INDY Cinema Group, based in the United Kingdom and the United States, which provides our website, box office platform, and is the platform we use to send promotional emails and e-newsletters.

Our use of these services does mean that email information will at times be sitting on servers outside of the EEA. We have appropriate contracts in place with these organisations to ensure your information is stored securely and used appropriately.

Data transfers

As you can see from the above, we share your Personal Data with two external third parties based outside the EEA. Any processing of your Personal Data by this party will involve an export of your Personal Data outside of Europe.

We endeavour to ensure that people to whom we provide Personal Data hold it subject to appropriate safeguards and controls. If there becomes any further need to transfer your Personal Data out of Europe if we choose to work with other third parties, we will ensure a similar degree of protection is afforded by ensuring at least one of the following safeguards is implemented:

We may transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission. For further details, see European Commission: Adequacy of the protection of Personal Data in non-EU countries.
Where we use service providers outside Europe, we may use specific contracts approved by the European Commission, which give Personal Data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of Personal Data to third countries.
Where we use service providers based in the U.S., we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to Personal Data shared between Europe and the U.S. For further details, see European Commission: EU-U.S. Privacy Shield.

How we keep your Personal Data secure

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.

We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.

We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (for example, where we are legally required to do so) we may notify you of breaches affecting your Personal Data.

How long we store your Personal Data

We will only retain your Personal Data for so long as we reasonably need to use it for unless a longer retention period is required by law (for example for regulatory purposes).

Our policy on children

This website is not intended for children below the age of 15 and we do not knowingly collect data relating to such children.

Third-party links

This Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share your Personal Data. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every site you visit.

GLASGOW FILM

Policy updated: December 2023

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