REALD INC. 

PRIVACY POLICY

Effective: March 1, 2024

Introduction

This privacy policy sets out how RealD Inc., and our related companies (collectively referred to herein as “RealD”) uses and protects your personal data.

California residents should review the Section entitled “Important Information for California Residents” below.

1.     IMPORTANT INFORMATION AND WHO WE ARE

Privacy policy

This privacy policy gives you information about how the Company collects and uses your personal data through your use of this website ( the “Site”).

This Site is not intended for children and we do not knowingly collect data relating to children.

Controller

The RealD group is made up of different legal entities, including RealD Inc., RealD Europe Limited, RealD Hong Kong Limited, LLC RealD Russia, RealD Brasil Ltda, RealD (Shanghai) 3D Equipment Leasing Co. Ltd., RealD Cinema (Shanghai) Company Limited, Colorlink Inc.

This privacy policy is issued on behalf of RealD so when we mention RealD, "we", "us" or "our" in this privacy policy, we are referring to the relevant company in the Group responsible for processing your data. RealD Inc. is the controller and responsible for this website.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights (paragraph 8), please contact the DPO using the information set out in the contact details section (paragraph 9).

1.              The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

·       Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender.

·       Contact Data includes billing address, delivery address, email address and telephone numbers.

·       Financial Data includes bank account and payment card details.

·       Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

·       Technical Data includes 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, device ID and other technology on the devices you use to access this website.

·       Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. 

·       Usage Data includes information about how you interact with and use our website, products and services.

·       Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

2.              How is your personal data collected?

We use different methods to collect data from and about you including through:

·       Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

·       apply for our products or services;

·       create an account on our website;

·       subscribe to our service or publications;

·       request marketing to be sent to you;

·       enter a competition, promotion or survey; or

·       give us feedback or contact us.

·       Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

·       Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

·       Technical Data is collected from the following parties:

·       analytics providers such as Google;

·       advertising networks; and

·       search information providers.

·       Contact, Financial and Transaction Data is collected from providers of technical, payment and delivery services.

·       Identity and Contact Data is collected from data brokers or aggregators.

·       Identity and Contact Data is collected from publicly available sources.

3.              How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

·       Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.

·       Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

·       Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.

·       Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Direct marketing

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving the marketing.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing

You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

4.              Disclosures of your personal data

We may share your personal data where necessary with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

·       Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. 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 and in accordance with our instructions.

5.              International transfers

We share your personal data within the RealD Group. This will involve transferring your data outside the UK to our overseas offices in the United States of America, China, Hong Kong and Taiwan.

Whenever we transfer your personal data out of the UK to countries which have laws that do not provide the same level of data protection as the UK law, we always ensure that a similar degree of protection is afforded to it by ensuring that the following safeguards are implemented:

We use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement. To obtain a copy of these contractual safeguards, please contact us at website@reald.com .

We may transfer your personal data to service providers that carry out certain functions on our behalf. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.

Whenever we transfer your personal data out of the UK to service providers, we ensure a similar degree of protection is afforded to it by ensuring that the following safeguards are in place:

·       We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data.

6.              Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

7.              Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see paragraph 8 below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

8.              Your legal rights

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

·       Request access to your personal data (commonly known as a "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.

·       Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

·       Request erasure of your personal data in certain circumstances. 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 successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

·       Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.

·       You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see OPTING OUT OF MARKETING in paragraph 3 for details of how to object to receiving direct marketing communications).

·       Request the transfer of your personal data to you or to a third party. 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.

·       3[Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 3 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

·       Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:

·       If you want us to establish the data's accuracy;

·       Where our use of the data is unlawful but you do not want us to erase it;

·       Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

·       You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us: see Contact details (paragraph 9).

No fee usually required

You will not 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 is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could 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.

9.              Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact our DPO in the following ways:

·       Email address: nororke@reald.com  

·       Postal address: The Space, The Maylands Building, Maylands Avenue, Hemel Hempstead HP2 7TG

10.           Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

11.           Changes to the privacy policy and your duty to inform us of changes 

We keep our privacy policy under regular review. This version was last updated on 1 March 2024. Historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

12.           Third-party links 

This website 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 data about you. 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 website you visit.

13.           IMPORTANT INFORMATION FOR CALIFORNIA RESIDENTS

This section applies only to California residents.  It describes how we may collect, use and share Personal Information of California residents in operating our business, and their rights with respect to that Personal Information.  For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018, as amended from time to time (“CCPA”), but does not include information exempted from the scope of the CCPA. 

Your California privacy rights. As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

  • Information.  You can request the following information about how we have collected and used your Personal Information during the past 12 months:

    • The categories of Personal Information that we have collected.

    • The categories of sources from which we collected Personal Information.

    • The business or commercial purpose for collecting and/or selling Personal Information.

    • The categories of third parties with whom we share Personal Information.

    • Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient.

    • Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.  

  • Access.  You can request a copy of the Personal Information that we have collected about you during the past 12 months. 

  • Deletion.  You can ask us to delete the Personal Information that we have collected from you.

  • Opt-in. If we know that you are younger than 16 years old, we will ask for your permission (or if you are younger than 13 years old, your parent’s or guardian’s permission) to sell your Personal Information before we do so.

  • Nondiscrimination.  You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as denying you services; increasing the price/rate of services; decreasing service quality; or suggesting that we may penalize you as described above for exercising your rights.  

How to exercise your rights

You may exercise your California privacy rights described above as follows:

  • Right to information, access and deletion. You can request to exercise your information, access and deletion rights by:

    • calling us toll free at 1-833-661-0117

    • emailing consumerdatainquiries@reald.com

    • sending correspondence to RealD Inc., 9777 Wilshire Blvd. Suite 400, Beverly Hills, California 90212, Attention: Legal Department.  

We will need to confirm your identity and California residency to process your requests to exercise your information, access or deletion rights.  We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

California residents can empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming that authority.

Personal information that we collect, use and share

The below summarizes how we may collect, use and share Personal Information by reference to the statutory categories specified in the CCPA, and describes our practices during the 12 months preceding the effective date of this Privacy Policy. 

We may collect the following personal information (PI) from the statutory categories listed below:

  • Commercial Information(records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)

    • We may collect “Commercial Information” from our exhibitor customers who purchase RealD products or services.

  • Financial Information(bank account number, debit or credit card numbers, insurance policy number, and other financial information.

    • We may collect “Financial Information” from our exhibitor customers who purchase RealD products or services.

  • Identifiers(real name, alias, postal address, unique personal identifier, customer number, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers)

    • We may collect “Identifiers” from our exhibitor customers who purchase RealD products or services and from individuals who elect to participate in our marketing promotions, engage with our social media content and/or attend our live events.

  • Inferences(the derivation of information, data, assumptions, or conclusions from any other category of Personal Information to create a profile about a person reflecting the person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes)

    • We may collect “Inferences” from individuals who visit our Site, elect to participate in our marketing promotions, engage with our social media content and/or attend our live events.

  • Internet or Network Information(browsing history, search history, and information regarding a person’s interaction with an Internet website, application, or advertisement)

    • We may collect “Internet or Network Information” from individuals who visit our Site, elect to participate in our marketing promotions and/or engage with our social media content.

  • Online Identifiers(an online identifier or other persistent identifier that can be used to recognize a person, family or device, over time and across different services, including but not limited to, a device identifier; an Internet Protocol address; cookies, beacons, pixel tags, mobile ad identifiers, or similar technology; customer number, unique pseudonym, or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers (i.e., the identification of a person or a device to a degree of certainty of more probable than not) that can be used to identify a particular person or device)

    • We may collect “Online Identifiers” from individuals who visit our Site, elect to participate in our marketing promotions and/or engage with our social media content.

  • Protected Classification Characteristics(age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information))

    • We do not intentionally collect “Protected Classification Characteristics” but it may be revealed in the other data or information we collect.

The sources from which we may collect PI are: 

  • Information you give us,

  • Information we get from our business partners, and

  • Information automatically collected (such as cookies).

The purpose for this collection of PI is for the following purposes:

  • We may use your personal information to operate, maintain, and improve our sites, products, and services.

  • We may use your personal information to process and deliver contest entries and rewards.

  • We may use your personal information to respond to comments and questions and provide customer service.

  • We may use your personal information to send information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.

  • We may use your personal information to communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners.

  • We may use your personal information to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.

  • We may use your personal information to provide and deliver products and services customers request and in doing so we may transmit financial information to banks, credit card companies or payment clearance services and we may transmit personal identifiers to permit shipping services to deliver products to you.

The following are the categories of third parties to whom we may “disclose” the PI for a business purpose:

  • We may share personal information within the RealD group of companies and to our affiliates.

  • We may share personal information with your consent.

  • We may share personal information for legal, protection, and safety purposes.

    • We may share information to comply with laws.

    • We may share information to respond to lawful requests and legal processes.

    • We may share information to protect the rights and property of RealD Inc., RealD Spark, LLC, our affiliates, agents, customers, and others. This includes enforcing our agreements, policies, and terms of use.

    • We may share information in an emergency. This includes protecting the safety of our employees and agents, our customers, or any person.

  • We may share information with those who need it to do work for us, including our service providers and professional advisors.

  • We may also share aggregated and/or anonymized data with our studio and exhibitor partners. Those uses will be subject to their privacy policies.

 We have not sold your personal information in the preceding 12 months.

 

CONTACT US

If you have any questions about this Privacy Policy you can contact us by email at website@reald.com