C-Screens PRIVACY POLICY

CScreens Limited (“C-Screens” / “we” / “our” / “us“) is committed to protecting and respecting your privacy. This policy, together with any other documents referred to in it, sets out the basis on which any personal data that we collect from you, or that you provide to us, when using our website located at c-screens.com/ (the “Website”) and otherwise interacting with us, will be processed.

Please read the following carefully to understand how we will treat your personal data.

  1. ABOUT US

CScreens Limited is a company registered in England and Wales under company number 08303558 whose registered office is at 8 Domingo Street, London EC1Y 0TA. We are the data controller in respect of your personal data. This means that we are responsible for deciding how we hold and use personal data about you. We are registered with the UK Information Commissioner’s Office with registration number A8408363.

  1. WHAT INFORMATION WE COLLECT AND HOW WE WILL USE IT

2.1                    We collect personal data so that we can operate effectively and provide you with the best possible service. The information we collect depends on the context of your interactions with us (for example, your use of our Website or of our products and services) and the choices you make. We will only use your personal data where we have a valid lawful basis to do so.

2.2                    The table below summarises what information we collect about you, explains how we intend to use it and what our legal basis is for using it.

What information will we collect about you? How will we collect information about you? Why are we processing information about you? What is our legal basis for processing information about you?
All Website Users
Feedback, questions and other information you provide when you contact us (e.g. for customer support) Collected when you contact our customer services team. To provide and improve our services

To provide customer support, including dealing with enquiries, correspondence and complaints

To enable us to pursue our legitimate interests to respond to your query and improve our products and services.
Cookies and similar technologies

 

For further information on our use of cookies, see the section on Cookies below. To analyse the traffic to our website and improve the user experience of our site. Consent
Employees of our Marketing Customers
Name, email address, job title and employer Either collected when you sign up to use our products and services or contact our customer services team, or provided to us by your employer. To communicate with you regarding the services being provided to your employer and to send you marketing communications. For further information on our marketing policy, see the section on Marketing below. To enable us to pursue our legitimate interest to provide our services, expand our business and engage with our customers.
End Users of our Advertising Services
Device and usage data including IP addresses and device identifiers

Location information

 

 

Collected by our third party service providers when you approach or interact with our advertising screens

We do not have direct access to this data, but it may be processed on our behalf by our third party service providers.

For more information, see the section on Sharing Your Information below.

To improve the customisation and relevance to end users of the advertising that is presented via our screens.

To analyse the effectiveness of our screen advertising and the demographics of advertising subjects on an anonymised basis.

To enable us to pursue our legitimate interests to deliver our advertising services, analyse their effectiveness and improve our customers’ experience.

 

2.3                    We and/or our third party service providers use facial recognition technology to assess the impact and effectiveness of our advertising services, including analysing the gender and dwell time of individual advertising subjects. All data is collected anonymously. No personal data or images / videos relating to advertising subjects are stored at any time.

2.4                    We also process inferred/modelled demographic characteristics (such as age) of advertising subjects who interact with our screens, and may share this information with our advertising customers where appropriate. This data is generated by our third party service providers. Such information is provided on an anonymised and aggregated basis, and does not constitute personal data.

2.5                    We have a duty to process personal data fairly, lawfully and in a manner that you would expect given the nature of our relationship with you. Where we have a legal basis to use your personal data without consent (as set out in the table above), this policy fulfils that duty by giving you appropriate notice and explanation of the way in which your personal data will be used.  Where consent is required for our use of your personal data we will ask you to positively opt-in.

2.6                    If you have any questions or require any further information regarding our use of your personal data please contact us.

  1. CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  1. SHARING YOUR INFORMATION

4.1                    You acknowledge that we may share your personal data with your consent or as necessary with selected third party service providers that support us in the performance of the activities set out in the table above.

4.2                    When you interact with our advertising screens, our third party service provider, Blis Media Limited (“Blis”), may process certain information (such as device identifiers and IP addresses) that may be regarded as “personal data” for the purposes of EU data protection legislation. Where this is the case, neither we nor Blis will have access to any information that directly identifies you, such as your name or address. To learn more about how Blis may process your personal data, see their Privacy Policy here.

4.3                    We may also share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or otherwise to comply with the law.

4.4                    We require all our third party service providers to take appropriate and stringent security measures to protect your personal data in line with our policies. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes in accordance with our instructions.

4.5                    We do not share personal data relating to specific advertising subjects with any third parties, save where otherwise stated in this policy.

4.6                    We may share your personal data with third parties where required by law or where we have a legitimate interest in doing so that is not overridden by your interests and fundamental rights. For example, to protect our customers or to operate and maintain the security or our computer systems).

  1. STORING YOUR INFORMATION

5.1                    We may store or transfer your personal data outside the European Economic Area (EEA). If we do so we will take all steps reasonably necessary to ensure that your personal data receives an adequate level of protection and is treated in a way consistent with EU and UK laws on data protection.

5.2                    We will only retain your personal data for as long as is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting obligations. We may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you.

  1. CHILDREN’S INFORMATION

We do not knowingly collect information from children under the age of 16. If you become aware that your child or any child under your care has provided us with information without your consent, please contact us using the details below.

  1. KEEPING YOUR INFORMATION SECURE

7.1                    All information that you provide to us is stored on secure servers. We have put in place appropriate measures to protect the security of your information.

7.2                    The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of the information transmitted to our site and you acknowledge that any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access or inadvertent disclosure.

  1. YOUR RIGHTS

8.1                    You have the right under data protection laws to access information held about you, subject to certain conditions, and to request its rectification or deletion.

8.2                    If you would like to access, update or amend the information which we hold about you or would like us to stop using your personal data please contact us using the details below.

8.3                    By law you have the right to:

  • request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. This right is subject to a number of exemptions which allow information to be withheld in certain circumstances. For example, subject access rights are excluded where compliance would involve disclosing information relating to another individual or which is subject to legal professional privilege.
  • request correction or erasure of your personal data (unless we have the legal right to retain 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 where we are relying on a legitimate interest (or those of a third party) 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 to another party.
  • change your data processing preferences at any time. If you have changed your mind you can contact us using the contact details below. In respect of marketing messages, you can also unsubscribe by using the “unsubscribe” link at the bottom of the message.

8.4                    You should be aware that if you ask us to stop processing your personal data in a certain way or erase your personal data, and this type of processing or data is needed to facilitate your use of our website you may not be able to use the website as you did before. This does not include your right to object to direct marketing, which can be exercised at any time without restriction.

8.5                    If you want to exercise any of the above rights, please contact us using the details below.

No fee usually required

8.6                    You will not usually have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

What we may need from you

8.7                    We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data are not disclosed to any person who has no right to receive it.

Right to withdraw consent

8.8                    In the limited circumstances where we are relying on your consent as the legal basis to process your personal data for a particular purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us. Once we know that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

  1. MARKETING

9.1                    We would like to send you information by email about our products and services which may be of interest to you (including, for example promotional materials and newsletters).

9.2                    You have the right at any time to stop us from contacting you for marketing purposes. If you no longer wish to be contacted for marketing purposes, you can unsubscribe by using the “unsubscribe” link at the bottom of our marketing messages or by emailing us.

  1. COOKIES

10.1                 Our site uses cookies (text files placed on your computer) which, if you agree, will collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the site and to compile statistical reports on site activity.

10.2                 By clicking “Ok” on the cookie consent box when you first access our site and by continuing to access and use our site, you accept our use of cookies. For your reference, we set out below the wording we use in our cookie consent box.

“We use cookies to personalise content and ads, to provide social media features and to analyse our traffic. We also share information about your use of our site with our social media, advertising and analytics partners who may combine it with other information that you’ve provided to them or that they’ve collected from your use of their services. You consent to our cookies if you continue to use our website.

ü         Ok

?          Show Details”

10.3                 Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control.

10.4                 You can set your browser not to accept cookies and information on how to remove cookies from your browser can be found here: www.allaboutcookies.org/manage-cookie. In a few cases, however, some of our site features may not work as a result.

10.5                 You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Cookie

Name

Provider Expiry Purpose
catAccCookies c-screens.com 1 month Records user’s acknowledgement of cookies notice.
vuid vimeo.com 2 years Collects data on the user’s visits to the website, such as which pages have been read.
GPS youtube.com Session Registers a unique ID on mobile devices to enable tracking based on geographical GPS location.
IDE doubleclick.net 2 years Used by Google DoubleClick to register and report the website user’s actions after viewing or clicking one of the advertiser’s ads with the purpose of measuring the efficacy of an ad and to present targeted ads to the user.
test_cookie doubleclick.net Session Used to check if the user’s browser supports cookies.
VISITOR_INFO1_LIVE youtube.com 179 days Tries to estimate the users’ band width on pages with integrated YouTube videos.
YSC youtube.com Session Registers a unique ID to keep statistics of what videos from YouTube the user has seen.
yt.innertube::nextId youtube.com Persistent Unclassified
yt.innertube::requests youtube.com Persistent Unclassified
yt-remote-cast-installed youtube.com Session Stores the user’s video player preferences using embedded YouTube video
yt-remote-connected-devices youtube.com Persistent Stores the user’s video player preferences using embedded YouTube video
yt-remote-device-id youtube.com Persistent Stores the user’s video player preferences using embedded YouTube video
yt-remote-fast-check-period youtube.com Session Stores the user’s video player preferences using embedded YouTube video
yt-remote-session-app youtube.com Session Stores the user’s video player preferences using embedded YouTube video
yt-remote-session-name youtube.com Session Stores the user’s video player preferences using embedded YouTube video
  1. OTHER WEBSITES

Our website contains links to other website. This privacy policy only applies to this website so when you link to other websites you should read their own privacy policies.

  1. OUR CAMERA REPORTING

CScreens Ltd work with Espirit Digital Interactive ( EDI ) to provide any camera technology reporting. This data is anonymous and used/output in binary format only. Personal privacy and the protection of personal privacy is a fundamental element in the development of Espirit Digital Interactive ( EDI ) Guest Engagement Platform (GEP) technology. EDI’s software is designed to provide insightful Business Intelligence Data (BID) by using fully anonymous measurements.

EDI’s GEP software employs intelligent facial detection software and not facial recognition technologies. Audience BID is generated from the aggregated measurements of people who engage with and/or are in the range of the detector view.

Information uniquely associated to an individual is not collected by EDI’s GEP software; gender, age and other demographics are analysed to create BID from visual cues. All video processing is performed locally in real time so that no image needs to be recorded or transmitted. We don’t record personal images. For any further questions, please contact info@c-screens.com

The General Data Protection Regulation (GDPR) is a European regulation on data protection which aims to strengthen privacy while providing increased harmonisation across all EU member states. It will be effective as of May 25th, 2018. Under the GDPR framework GEP will continue operate in the same way as it does today because of the approach defined above.

Under the GDPR framework our GEP clients will have to inform the public, via a notice placed on their screens and/or at the entrance of the venue, that a GEP solution is in operation. This notice provides a statement about the collection of anonymous viewer data and how to get further information regarding privacy from the operator

  1. CHANGES TO THIS PRIVACY POLICY

We keep our privacy policy under regular review and will post any updates on this webpage. This privacy policy was last updated in October 2018.

  1. HOW TO CONTACT US AND COMPLAINTS

14.1                 If you have any questions about this privacy policy or how we handle your personal data please contact us at traffic@c-screens.com or by writing to us at C-Screens, 8 Domingo Street, London EC1Y 0TA.

14.2                 If for any reason you are not happy with the way that we have handled your personal data, please contact us at traffic@c-screens.com. If you are still not happy, you have the right to make a make a complaint to the Information Commissioner’s Office see: https://ico.org.uk/global/contact-us/.

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