PRIVACY POLICY/ DATA PROTECTION
INTRODUCTION
We respect the privacy of every person who visits our website, uses our mobile applications for iPhone and Android (the “Sites”) or uses the services that we make available from the Sites, on our telephone booking line, in our cinemas or through our customer services facilities (our “Services”) and we are committed to ensuring a safe and protected online experience.
Purpose of This Policy
This privacy policy/Data protection policy (“Privacy Policy”) explains our approach to any personal information that Silverbird Cinemas Limited (“Silverbird”, “we” or “us”) might collect from you or which we have obtained about you from a third party, including someone who has purchased a gift for you, and the purposes for and the basis on which we process your personal information. This Privacy Policy also sets out your rights in respect of our processing of your personal information. This Privacy Policy will inform you of the nature of the personal information about you that is processed by us and how you can request that we delete, update, transfer it and/or provide you with access to it. This Privacy Policy is intended to assist you in making informed decisions when using the Sites and our Services. Please take a moment to read and understand it. Please note that it should be read in conjunction with our Online, Phone and Terms of Use (which includes our Website Terms of Use).
Please also note that this Privacy Policy only applies to the use of your personal information obtained by us, it does not apply to your personal information collected during your communications with third parties.
This Privacy Policy may vary from time to time so please check it regularly. If you have any comments on this Policy, please email them to support.onlineticketing@Silverbirdgroup.com
Consent for Data Protection/Retention
You accept this Policy and hereby give us consent to save, process and use your Personal Data to the extent as allowed by law when you provide us with details of your Personal Data or by clicking on the “accept” button. We may request for further consent in the event that your Personal Data is required to be transferred to a third party for marketing purposes or when it is to be further processed in a manner which would require your further consent.
You may withdraw your consent at any time before, during and after we process your Personal Data. Personal Data is information that can be directly used to identify you, including but not limited to your name, address, telephone number, email address and any other information of like nature.
We may use and transfer your Personal Data either with your consent, for compliance with a legal obligation to which we are subject or when we have assessed that it is necessary for the purposes of the legitimate interests pursued by us or by a third party to whom it may be necessary to disclose information. We may also use your Personal Data to further develop the quality of our services.
The Personal Information We May Collect
We will collect and process the following data about you:
- Information you provide directly to us
We collect the content, communication and other information you provide to us when you use any of our services. These include when you:
fill forms, questionnaires or surveys;
contact us on our social media pages;
take part in a competition or take advantage of a promotion;
provide debit card details (such as when purchasing products from us);
contact us with an enquiry or ask us to provide you with information;
register on our website or app or leave any comments or reviews;
attend any of our promotional events;
inform us of your marketing preferences; and/or communicate with us via social media websites, third party apps or similar technologies.
- Information we collect about you
With regard to each of your visits to our website, office or the use of our products, we may collect the following information:
technical information, including the Internet Protocol (IP) address used to connect your computer to the internet, your login information, browser type, time zone setting, browser plug-in types and versions, operating system and platform;
information about your use of our website and mobile application (including date and time), details of transactions you carry out, interaction information, record of any correspondence between us and any phone number used to call our customer service number;
information about your visit(s) from your IP address, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time); products or services you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), and methods used to browse away from the page.
- Information we receive from other sources
This is information we receive about you if you use any of the other websites we operate or the other services we provide. In this case we will inform you at the point of data collection, if we intend to share your data internally and combine it with data collected on our website. We will also tell you for what purpose we will share and combine your data. We may work with third parties from time to time and shall notify when we receive information about you from them and the purposes for which we intend to use that information.
How We Use Your Personal Data
We use information held about you in the following ways, that is to:
provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
notify you about changes in our service;
tailor the content we display to you;
ensure your health and safety while you visit our cinema;
carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
aid our marketing and communication strategies;
ensure that content from our product is presented in the most effective manner for you and for your computer;
administer our product and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
get feedback about our product and use it to improve it;
ensure that content is presented in the most effective manner for you and for your device;
help you to participate in interactive features of our service, when you choose to do so;
make suggestions and recommendations to you and other users of our product about goods or services that may interest you or them.
We will use information provided by you to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those, which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, you may unsubscribe from promotional emails via a link provided in each email.
Legal Basis for Processing Your Personal Data
We will only process your Personal Data where we have a legal basis to do so. The legal basis will depend on the purpose for which we have collected and use your Personal Data.
The legal basis for processing your data may be any of the following:
Consent: This will apply where you have provided your consent to the processing of your Personal Data for one or more specific purposes;
Performance of Contract: This will apply where processing is necessary for the performance of a contract to which you are a party or in order to take steps prior to entering into a contract with you;
Vital interests: This is where processing is required for the protection of your vital interests.
Compliance with legal obligation: Where we are subject to a legal obligation and need to use your Personal Data in order to comply with that obligation.
Public interest: Where processing is necessary for the performance of a task or function carried out in the interest of the public.
Legitimate Interest – means the interest of our business in conducting and managing our business to enable us give you the best services and most secure experience.
Privacy by Design
When designing and implementing a new business or technological process involving the collection or use of Personal Data, we will take into consideration, among other consideration, the need for structured privacy planning for this process. For example, the company will consider collecting only the types of information required for the business process in the first place.
Confidentiality and Security of Your Personal Information
We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration.
We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:
unauthorized access;
improper use or disclosure;
unauthorized modification; and
unlawful destruction or accidental loss.
All of our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of our Services. We have also taken measures to comply with global Information Security Management Systems (ISMS). We therefore have put in place digital and physical security measures to limit or eliminate possibilities of data privacy breach incidents.
Where you have chosen a password that allows you to access certain parts of the website and mobile application, you are responsible for keeping this password confidential. We advise you not to share your password with anyone.
Who Do We Share Your Personal Information With?
We will usually not share your Personal Data with other third parties without your consent. Where we need to transfer your data to another country, such country must have an adequate data protection law. Where we need to send your data to a country without an adequate data protection law, we shall ensure that such transfer is subject only to the exceptions contained in Article 2.12 of the Nigeria Data Protection Regulation 2019.
You agree that we have the right to share your Personal Data as follows:
internally with our employees and affiliated companies as defined under the Nigerian Companies and Allied Matters Act, Cap. C20, Laws of the Federation of Nigeria, 2004.
and
externally with third party service providers.
The categories of third party service providers that we share your personal information with are:
providers of ticketing systems;
suppliers of systems and services that help us provide and administer our gift products;
suppliers who host, provide, manage, support or administer certain aspects of our websites, phone booking service, IT systems and data centers;
providers of customer surveys and customer insight analytics;
suppliers of email, online and social media advertising and other marketing systems and services such as Salesforce;
third parties who help us to run or administer competitions or deliver prizes;
third parties who host our events;
with our professional advisers such as our lawyers, accountants, health and safety consultants and insurance brokers for our business administration and legal purposes;
Social media sites and platforms such as Facebook for marketing purposes
third party advertising partners for targeted advertising purposes
any other third party where we are obliged to, or permitted to do so, by law, court order or to comply with any search warrant or similar instrument presented to us by any law enforcement, government officer or regulatory authority;
in the event that our business is sold or integrated with another business, our lawyers, and other professional advisers, any prospective purchasers’ lawyers and professional advisers, and any prospective purchaser (subject to duties of confidentiality).
Where We Store Your Personal Data
The Personal Data that we collect from you will be transferred to and stored at destinations within Nigeria. By submitting your Personal Data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Policy.
How Long We Retain Your Personal Data
Your Personal Data will not be retained for longer than is necessary for the purposes for which it was processed unless a longer retention period is required or permitted by law. At the end of that retention period, your data will either be deleted or anonymized, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning. We keep the length of time that we hold your personal data for under review.
Your Rights In Relation to Data Processing And Retention
The law gives you certain rights in respect of the information we hold about you. Below is a highlight of some of those rights, which do not however constitute a complete, exhaustive statement of your rights in respect of your Personal Data:
You have a right to consent to this Policy and to withdraw your consent at any time.
You have a right to a copy of the Personal Data we hold about you, as well as the information about what we do with it, who we share it with and how long we hold it for. We may make a reasonable charge for additional copies of that Personal Data in the case of unfounded and excessive requests.
You have a right to freely transfer your Personal Data received from us to any other person.
You have the right to have the information we hold about you corrected, if it is factually inaccurate. You may contact us for this purpose by sending a mail to support.onlineticketing@Silverbirdgroup.com
In some circumstances, you have the right to the deletion of the information that we hold about you.
You have a right to lodge a complaint about the handling of your Personal Data with the National Information Technology Development Agency (“NITDA”).
You have the right to ask us not to process your Personal Data for marketing purposes. We will usually inform you (before collecting your Personal Data) if we intend to use your Personal Data for such purposes or if we intend to disclose your information to any third party for such purposes.
You have the right to be informed about the existence of automated decision-making processes, including profiling as well as meaningful information about the logic involved, the significance and the envisaged consequences of such processing.
NITDA’s website (https://nitda.gov.ng/nit/) has a wealth of useful information in respect of your rights over your Personal Data.
If you wish to exercise your rights, you may contact the office of our Data Protection Officer at support.onlineticketing@Silverbirdgroup.com
Where we do not act on your request to exercise any of your rights, we shall inform you within one month of the receipt of your request, of the reasons for not taking action and on the possibility of lodging a complaint with NITDA.
Breach/ Privacy Violation
In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to your Personal Data, Silverbird Cinemas LImited shall within 72 (seventy-two) hours of having knowledge of such breach report the details of the breach to NITDA. Furthermore, Silverbird Cinemas Limited shall within 7 (seven) days of having knowledge of the occurrence of such breach take steps to inform the Data Subject of the breach incident, the risk to the rights and freedoms of the Data Subject resulting from such breach and any course of action to remedy the said breach.
If you feel that your Personal Data has not been handled correctly or you are unhappy with our response to any requests you have made to us regarding the use of your Personal Data, you have a right to lodge a complaint with the NITDA. The contact details are:
National Information Technology Development Agency
Tel: +234929220263, +2348168401851, +2347052420189
Email: info@nitda.gov.ng
Website: www.nitda.gov.ng
Changes to Our Privacy Policy
Any changes we 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 Privacy Policy are welcomed and should be addressed to support.onlineticketing@Silverbirdgroup.com or our offices at: 133, Ahmadu Bello Way, Victoria Island, Lagos.