ŌMA CINEMA PRIVACY POLICY

This Privacy Policy was last updated on March 23, 2021.

Your privacy is important to Ōma Cinema (“ŌMA”). We created this Privacy Policy to document our firm commitment to privacy and to handling your information in accordance with applicable data protection laws. This Privacy Policy covers how we collect your Personal Information and how that information, together with any other Personal Information that you provide to us, may be used, disclosed, transferred and stored by us. This includes information collected online through our websites, mobile applications, social media pages, and through our direct marketing campaigns or other online communications (collectively the “Services”). This Privacy Policy should also be read in conjunction with our Cookies Policy and the Terms of Use.

If you are located in the European Economic Area, for the purposes of applicable data protection legislation, ŌMA is the data controller of Personal Information collected from you. Please see the Privacy Questions section below for further details.

1. What Personal Information we collect

Personal Information is information that identifies or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household. We collect the following categories of Personal Information:
· Identifiers/Contact Information: Your name, age, postal and email address, phone number, username, password, and unique identifiers that may identify your device or browser but not you by name.
· Geolocation Data: Data about the location of the device you use to access the Services.
· Commercial Information: Your purchase history and payment information.
· Internet/Electronic Activity: Your IP address, web/app browsing and search history related to our Services, and information regarding your interaction(s) with the Services.
· Visual/Audio Information: Your activity in our theaters.
· Inferences: The inferences that we draw from the above categories of Personal Information and web activity to create a personalized profile so we can better identify goods and services that may be of interest.
We collect the above types of Personal Information from a variety of sources, including from:
· Internet service providers
· Security/fraud prevention service providers
· Data analytics providers
· Social media networks
· Operating systems and platforms (including video cameras in our theatres)
· From you directly or groups you participate in that organize events at our theatres.

2. How we collect your Personal Information

Personal Information You Provide

You may be asked to provide your Personal Information anytime you are in contact with ŌMA or any member of our group, which means ŌMA and its subsidiaries. ŌMA and any member of our group may share this information with each other and use it consistent with this Privacy Policy. They may also combine it with other information to provide and improve our products, services, content, and advertising. You are not required to provide the Personal Information that we request, but if you choose not to do so, in many cases we will not be able to provide you with our products or services or respond to any queries you may have.

Here are some examples of how we collect Personal Information from you:
· When you register with us through the Services and provide us your contact information;
· When you subscribe to the ŌMA email newsletter and provide your email address and postal code;
· If you enter an ŌMA contest, competition or similar promotion and provide your contact information;
· When you post on an ŌMA social media channel (including on Facebook, Reddit, Instagram and Twitter). If you use these social media channels, please remember that any information you post is available for others to see and in each case, is subject to the privacy terms of the applicable social media providers;

· When you make a purchase from us;
· When you report a problem with our website or services;
· When you participate in a customer research, satisfaction or other survey that we use for research purposes;
· If you participate in a customer video or other testimonial used for research and advertising purposes;
· If you download and create a personal account through an ŌMA mobile application.
Note that when you use an ŌMA website or app, we or our providers receive and may store information automatically, including IP addresses, browser types, Internet Service Provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. Furthermore, if you contact us for any other reason, we may keep a record of that correspondence.

Personal Information Collected Automatically

Whenever you visit or interact with the Services, we, as well as any third-party advertisers and/or service providers, may use a variety of technologies that automatically or passively collect information about your online activity. This Personal Information may be collected in the following ways: Internet Activity: We may use cookies, web beacons, pixel tags, mobile analytics software, log files, or other technologies to collect certain information about your online activity, and interactions with us, and to allow us to keep track of analytics and certain statistical information which enables us to improve the Services and provide you with more relevant content. We may use third party service providers to support the Services. Some of these service providers may use technology such as cookies, web beacons, pixel tags, log files, or other technologies to receive, collect, and store Personal Information on our behalf.

Electronic Activity: We may automatically collect your IP address or other unique identifier for the computer, mobile device, tablet or other device you use to access the Services, including the hardware model and mobile network information. We may use this information to provide the Services, help diagnose problems, analyze trends, track your interactions with the Services, and retarget online and mobile advertisements to you across computers or devices you may use.
Geolocation Information: We may collect information about the location of your device when you access or use the Services. In addition, if you choose to turn on your Bluetooth, Wi-Fi or other geolocation functionality when you use our mobile applications, we may collect and use your geolocation information.

We may use third parties’ analytics and tracking tools, such as Google Analytics, to help us track, segment and analyze usage of the Services, and to help us or those third parties serve more targeted advertising to you. These tools may use technology such as cookies, web beacons, pixel tags, log files, Flash cookies, or other technologies to track online activity. They may also combine information they collect from your interaction with the Services with information they collect from other sources. We do not have access to, or control over, these third parties’ use of cookies or other tracking technologies.

Combination of Personal Information

We may combine the Personal Information we receive from you and about you, including Personal Information you provide to us and Personal Information we automatically collect through the Services, as well as Personal Information collected across other computers or devices that you may use, from other online or offline sources, and from third party sources. This combined Personal Information may be used in any manner detailed in this Privacy Policy.

3. How we use Personal Information we collect

We will hold, process and disclose your Personal Information for the following purposes and in accordance with the bases set out below: Purpose(s) for processing Basis for Processing - To communicate with you, to send you information about our services, contests, and promotions - To administer contests and other promotions - To provide you with information about ŌMA and its products and services and provide newsletters or email updates to you Your consent, which you can withdraw at any time - To create, develop, produce, operate, deliver and improve our products, services, content and advertising - To communicate with you and provide information in relation to our business relationship The processing is necessary for the performance of a contract or to take steps at your request prior to entering into a contract to which you are a party Where you work for, or otherwise provide services to, a party that has entered into a contract with ŌMA (or where such party has taken steps to enter into a contract with ŌMA): - To create, develop, produce, operate, deliver and improve our products, services, content and advertising - To communicate with you and provide you with information in relation to that business relationship The processing is necessary to support our legitimate business interests in meeting our obligations and enforcing our rights related to a contract to which your employer (or party you provide services to) is or may become a party, provided such interests are not overridden by your interests and rights Where you are a potential business partner of ŌMA, or have expressed interest in ŌMA’s business, including analysts, investors and job applicants: - To provide you with information about ŌMA and its products and services and provide newsletters or email updates to you - To respond to your requests and to contact you if necessary The processing is necessary to support our legitimate business interests in managing our resources, managing, organising and protecting our business and improving our services, provided such interests are not overridden by your interests and rights In relation to the company’s legal and tax obligations: - For the purpose of fraud protection and credit risk reduction - To protect ŌMA in the event of litigation, or to protect the company’s legal rights - To meet the company’s tax obligations The processing is necessary to comply with a legal obligation to which ŌMA is subject

When you access our Services: - To help us address problems with and improve our Services design, products and services - To correct our records and make it easier to deliver your next communication - To respond to your requests and to contact you if necessary - To protect the security and integrity of the Services and our business The processing is necessary to support our legitimate business interests in managing our resources, managing, organising and protecting our business and improving our services, provided such interests are not overridden by your interests and rights In connection with our Cookies Policy, when you access our websites: - To analyse trends and statistics in terms of how our website is used and to understand the flow of traffic on our website and to provide a better and more personalized website experience and to understand the needs of our customers Where required by applicable law, your consent, which you can withdraw at any time, and to support our legitimate business interests to manage and improve our services, provided such interests are not overridden by your interests and rights When you access, download, create an account for, log in to or use an ŌMA app: - To provide the benefits, services and convenience of the offerings of an ŌMA app - To troubleshoot any glitches or malfunctions with an ŌMA app - To track the functionality and usage of an ŌMA app by consumers For our legitimate business interest, to provide you the app functions you request and to manage and troubleshoot any issues with the ŌMA app, provided such interests are not overridden by your interests and rights

Additional information regarding individuals in the European Economic Area: For purposes of applicable data protection laws, the bases for processing outlined above comprise, in each case, the “legal basis” for processing Personal Information for each listed purpose. We will only use your Personal Information for the purposes for which we collect it, and subject to the legal basis for each purpose as outlined above, in compliance with applicable data protection laws.

4. How we share your Personal Information

We may transfer and/or disclose Personal Information in connection with the services being provided to you by ŌMA, including to: · ŌMA subsidiaries, for the purposes set out above. · Service providers that carry out certain services for a permitted business purpose on our behalf. For example, if you make a purchase on our mobile application, our payment processor vendor will process your payment information, or if you win a competition, we will pass your information onto a third party who will arrange delivery of your prize. · Legal disclosures, where we are under a duty to disclose or share your Personal Information to comply with any legal obligation, to enforce or apply our Terms of Use, or to protect our rights. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. · Business Partners, on an aggregated level, to give them a better understanding of our business. Such information will not identify you personally.

5. Links to other websites

Our Services may, from time to time, contain links to and from the websites of our partner theatres, distributors, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Personal Information to these websites.

6. International transfers of your Personal Information

Personal Information may be stored and processed in any country where we have operations or in which we engage service providers, including Canada and the United States. Further information about our policies regarding international transfers of your Personal Information can be obtained by contacting us using the contact information set out below.

If you are located in the European Economic Area (EEA) or Canada: Please note that the recipients may be located in countries which do not provide a similar or adequate level of protection to that provided by the country in which you reside. To the limited extent that it is necessary to transfer Personal Information outside of your country of residence, we will take measures to ensure appropriate safeguards are in place, such as standard contractual clauses under GDPR Article 46.2 or an adequacy decision concerning the country at issue under GDPR Article 45. If you would like further information regarding safeguards, please contact us.

7. Marketing Communications

Information that we collect about you may be used to send you information about our business, our films or other useful information (for example, newsletters, details of competitions, special offers and promotions and information about latest releases) in accordance with applicable laws. When you access certain functions of our website or download and create an account for an ŌMA app we will also ask you if you would like to receive information about the products or services of our third party business partners that we think may be of interest to you. We will not send you this information without your consent.

If you do not want to receive marketing communications from us please contact us or follow the unsubscribe instructions in any communication received from us.

8. How does ŌMA keep your information secure?

We have taken reasonable steps to secure the Personal Information in our control, but no set of security measures is guaranteed to be effective against all threats of unauthorized Personal Information access or use. The steps we have taken include physical, contractual, technical, and managerial safeguards to protect your Personal Information. However, security lies in your hands as well. It is important for you to protect against unauthorized access to your passwords and to your computers and other connected devices. Be sure to sign off when finished using a shared device and log out of our websites or any ŌMA app if you have been using them.

9. Minors

Neither this website nor any ŌMA app is intended for children and we do not knowingly collect data relating to children. If you are under the age of 16, or equivalent minimum age in the relevant jurisdiction, please do not attempt to provide any Personal Information about yourself to us. If we learn that we have collected Personal Information from a child under the age of 16, or equivalent minimum age in the relevant jurisdiction, we will promptly delete that information. If you believe we have collected Personal Information from a child under the age of 16, or equivalent minimum age in the relevant jurisdiction, please contact us.

10. Data retention

We will retain your Personal Information for the period necessary to reasonably fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. Under some circumstances we may anonymize or aggregate your Personal Information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent. If you have questions in relation to our data retention practices please contact us.

11. Your rights in respect of Personal Information

We respect your right to request access to, correction of, erasure of, or restriction of processing of your Personal Information, or to object to processing of your Personal Information, as well as the right to portability in accordance with applicable law. In each case, these rights are subject to restrictions contained in applicable laws. If you would like to exercise your rights in respect of your Personal Information please contact us. We will respond to your request in accordance with applicable law.

If you request access to a copy of your Personal Information which is held by ŌMA, your request will be dealt with as quickly as reasonably possible and in any event in accordance with applicable law.

EEA and Canada Residents

Under the European Union General Data Protection Regulation and applicable Canadian privacy laws, you may have certain rights regarding your Personal Information, including: · Right to access your information: You have the right to confirm whether and how we use your Personal Information, why we use it, how long we keep it, and who we share it with. You also have the right to request a free copy of the information we hold about you. · Right to rectify your information: If you believe that we hold Personal Information about you that is inaccurate, misleading, or incomplete, you have the right to request that we correct that information in our records. · Right to request that we remove your information: You have the right to request that we remove your Personal Information from our records. · Right to withdraw consent: Where you provide consent to our use of your Personal Information, you can withdraw your consent at any time by contacting us. · Right to complain to a supervisory authority: Where you are unhappy with how we treat or handle your Personal Information, you have the right to make a complaint to the data protection supervisory authority or privacy commissioner in your home country or jurisdiction. EEA residents specifically have the following additional rights: · Right to portability: You have the right to request a copy of your Personal Information for your personal use, including sharing with other entities. · Right to request that we limit use of your information: You also have the right to request that our use of your Personal Information be restricted.

To take advantage of these rights, please contact us at by email at nchican@omacinema.com. We will need to verify your identity before we can process either of these requests but will honor such requests where technically feasible based on the information provided. We value your privacy and will not discriminate in response to your exercise of your privacy rights. We will confirm receipt of your request within 10 business days and will respond to your request within 45 calendar days, after proper verification, unless we need additional time, in which case we will let you know. Opt-Out: You also may request to opt out of the “sale” of your Personal Information to third parties for their commercial use. This means that, if you opt out, going forward, we will not share your Personal Information with such third parties to use for their purposes unless you later direct us to do so. To effect the opt out, please click on the Do Not Sell My Information link, which also is on our website footer. Agent Requests: You may authorize someone to make a privacy rights request on your behalf (an authorized agent). Authorized agents will need to demonstrate that you’ve authorized them to act on your behalf, and that they are registered with the California Secretary of State to conduct business in California, or must demonstrate they have power of attorney pursuant to applicable probate law. We retain the right to request confirmation directly from you confirming that the agent is authorized to make such a request, or to request additional information to confirm the agent’s status as an authorized agent. An authorized agent is prohibited from using a consumer’s Personal Information, or any information collected from or about the consumer, for any purpose other than to fulfill the consumer’s requests, for verification, or for fraud prevention.

12. Consequences of failure to provide information

If ŌMA asks for information and you do not wish to give it to us, or if you wish to withdraw consent to the use of your information, ŌMA will explain the consequences based on the specific information concerned, including whether it is a legal or contractual requirement that we use such data. However, if ŌMA cannot collect necessary information from you, it may make it difficult or impossible for us to provide our services to you through our website, through an ŌMA app or otherwise. If you have any queries in respect of the consequences of not providing information or withdrawing your consent, please contact us.

13. Our companywide commitment to your privacy

To help make sure your Personal Information is secure, we communicate our privacy and security guidelines to all ŌMAL employees and strictly enforce these safeguards within the company.

14. Privacy questions

If you wish to contact us or have any questions about or complaints in relation to our Privacy Policy or the way ŌMA handles your Personal Information, please contact us at nchican@omacinema.com and we will try to address your concerns swiftly and resolve any issues you might have. For general inquiries about ŌMA, please email nchican@omacinema.com.

If you are unsatisfied with the reply received, you may refer your complaint to the relevant regulator in your jurisdiction. ŌMA may update its Privacy Policy from time to time. When we change the policy in a material way, we will update the Privacy Policy on our Services.

Ōma Cinéma, 38, rue de Trévise, 75009 Paris France