Privacy Policy 2018

Spanner Films Limited - Privacy Policy

Last updated: 24 May 2018

Introduction
Spanner Films Limited & Undercovers TV Limited (“we”, “our”, “us”) are committed to protecting and respecting your privacy. We are two Private Limited Companies established in England and Waleswith a registered office at Herston Cross House, High Street, Swanage, England, BH19 2PQ, and for the purpose of the General Data Protection Regulation (the “GDPR”), we are the data controller.

This policy sets out the basis on which we will process any personal data or usage information we collect from you, or that you provide to us, in connection with your use of our websites at www.spannerfilms.net, www.indiescreenings.net and www.scruffysquad.tv (the “Websites”). Please read this policy carefully so that you understand your rights in relation to your personal data, and how we will collect, use and process your personal data. If you do not agree with this Privacy Policy in general or any part of it, you should not access the Websites. 

What types of information do we collect and how do we use it?

  • Information you give us. You may provide information by contacting us via our Websites or email, telephone, social media or otherwise, or signing up for our newsletter or alerts.

As it is in our legitimate interests to be responsive to you and to ensure the proper functioning of our products and organisation, we will use your information to:

  • communicate with you;
  • sign up for our newsletters or alerts;
  • contact you via email, text, or via your social media accounts;
  •  identify our users;
  •   administer and provide services;
  •  personalise our services for you;
  • enforce our Websites terms and conditions; or
  •  if you have opted in to marketing, communicate with you about our films, campaigns, fundraising, events, parties and other news and information relating to Spanner Films or others, which we think and hope will be of interest to you.

Technical usage information
When you visit the Websites, we automatically collect the information sent to us by your computer, mobile phone, or other access device. This information includes:

  •  your IP address and time of access;
  • device information including, identifier, name, browser agent string and type of operating system;
  • mobile network information; and
  • standard web information, such as your browser type and the pages you access on our Websites.

When you register with our website to, for example, buy a product in our shop or hold a screening of one of our films, we collect the information you provide. This includes: name, email address and postal address. When you make a purchase through our website, your credit card details are handled by PayPal.

As it is in our legitimate interests to process your data to provide effective services and useful content to you we collect this information in order to:

  •  personalise our Websites to ensure content from the Websites are presented in the most effective manner for you and your device;
  •  monitor and analyse trends, usage and activity in connection with our Websites and services to improve the Websites;
  •  administer the Websites, and for internal operations, in order to conduct troubleshooting, data analysis, testing, research, statistical and survey analysis;
  •  keep the Websites safe and secure; or
  •  measure and understand the effectiveness of the content we serve to you and others.

Do we use cookies?
We use cookies to collect information about your browsing activities over time and across different websites following your use of our services. They allow us to recognise and count the number of users and to see how users move around the Websites when they are using it. This helps us to improve the services we provide to you and the way the Websites works. You can find more information about cookies and how to manage them at www.allaboutcookies.org.

We use Google Analytics, which is a web analytics tool that helps us understand how users engage with the Websites. Like many services, Google Analytics uses first-party cookies to track user interactions, as in our case, where they are used to collect information about how users use our site. This information is used to compile reports and to help us improve our Websites. The reports disclose website trends without identifying individual visitors. You can opt out of Google Analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout.

How do we share your personal data?
We do not sell, rent or lease your personal information to others except as described in this Privacy Policy. We share your information with selected recipients. These categories of recipients include:

  • Cloud storage provider, namely Mailman, located in the UK to store the personal data you provide and for disaster recovery services, as well as for the performance of any contract we enter into with you; and
  • IT Services providers, including Bytemark, Afaik and Rackspace, that provide us with hosting services in which the servers on which our information is stored are based in the UK.

We will share your information with law enforcement agencies, public authorities or other organisations if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:

  • comply with a legal obligation, process or request;
  •  enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
  • detect, prevent or otherwise address security, fraud or technical issues; or
  • protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

We will also disclose your information to third parties:

  • in the event that we sell any business or assets, in which case we will disclose your data to the prospective  buyer of such business or assets; or
  •  if we or substantially all of our assets are acquired by a third party, in which case information held by us about our users will be one of the transferred assets.

Where do we store your personal data?
We do not transfer data outside of the EEA.

The security of your personal data
Unfortunately, the transmission of information via the internet or email is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted through the Websites or over email; any transmission is at your own risk. Once we have received your information, we will take appropriate technical and organisational measures to safeguard your personal data against loss, theft and unauthorised use, access or modification.

We will, from time to time, host links to and from the websites of our affiliates or third parties. If you follow a link to any of these websites, these websites will have their own privacy policies and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to those websites.

How long do we store your personal data?
We will retain your information until you “opt-out” or unsubscribe. Once you have done this and/or terminated your use of the services and our Websites, we will store your information in an aggregated and anonymised format.

Your rights
You have the right to ask us to access the personal data we hold about you and be provided with certain information about how we  use your personal data and who we share it with. You also have the right to ask us to correct your personal data where it is inaccurate or incomplete.

In certain circumstances, you have the right to ask us to delete the personal data we hold about you:

  • where you believe that it is no longer necessary for us to hold your personal data;
  • where we are processing your personal data on the basis of legitimate interests and you object to such processing  and we cannot demonstrate an overriding legitimate ground for the processing; or
  • where you believe the personal data we hold about you is being unlawfully processed by us.

In certain circumstances, you have the right to ask us to restrict (stop any active) processing of your personal data:

  • where you believe the personal data we hold about you is inaccurate and while we verify accuracy; or
  • where you have objected to us processing your personal data based on our legitimate interests and we are considering your objection.

In addition, you can object to our processing of your personal data based on our legitimate interests and we will no longer process your personal data unless we can demonstrate an overriding legitimate ground.

To exercise any of these rights above, please contact our Data Protection Officer  at dataprotectionofficer@spannerfilms.net.

Please note that these rights are limited, for example, where fulfilling your request would adversely affect other individuals or Company trade secrets or intellectual property, where there  are overriding public interest reasons or where we are required by law to retain your personal data.

Withdrawal of Consent
Where you have provided your consent for us to process your personal data, you can withdraw your consent at any time by clicking on the opt-out button here at: www.spannerfilms.net/opt-out.

Objection to Marketing
At any time you have the right to object to our processing of data about you in order to send you promotions, special offers and marketing, including where we build profiles for such purposes, and we will stop processing the data for that purpose.Complaints
In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at dataprotectionofficer@spannerfilms.netand we will endeavour to deal with your request. This is without prejudice to your right to launch a claim with the data protection supervisory authority in the EU country in which you live or work where you think we have infringed data protection laws.

Changes
Any changes we will make to this policy in the future will be posted on this page. Please check back frequently to see any updates or changes to this policy.

Contact
Questions, comments and requests regarding this policy are welcomed and should be addressed to admin@spannerfilms.net. You can also write to our Data Protection Officer at dataprotectionofficer@spannerfilms.net.