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Business-to-Business Privacy Policy For California Residents
Consumer Privacy Policy
Last Updated: December 8, 2023
National CineMedia, LLC and its affiliates (“NCM,” “We,” or “Us”) have published this Privacy Policy to provide consumers (“You” or “Consumer”) with a description of our practices regarding the collection, recording, use, disclosure, sale, and sharing of Personal Information and of the rights You have regarding your Personal Information. We discuss below the Personal Information We collect, record, and store; provide information about how We use Personal Information and the Personal Information that We disclose, sell, and share; and describe your rights regarding your Personal Information. For details about what constitutes Personal Information and details about the categories of Personal Information We collect; the categories of sources from which We collect that Personal Information; our business or commercial purposes for collecting, using, selling, and sharing Personal Information; an indication of whether We have sold, shared, or disclosed Personal Information, the categories of third-parties to which We disclose Personal Information; and our intended length of retention for each category of Personal Information, please refer to the definitions, discussion, and chart in Appendix A.
Personal Information We Collect, Record, and/or Store
Information from You:
We collect, record, and/or store Personal Information from You. For example, We receive Personal Information from and about You when You visit, use, or register with our NCM Properties, which include the Sites defined in the Terms of Use available at https://www.noovie.com/terms; visit or follow our social media pages or like our posts; or request information or materials from Us, including:
· your name and contact information, such as mobile number, email address, or postal address
· any username and password You create with Us
· information on areas or components of the NCM Properties You access
· bank account or credit or debit card numbers You use to purchase goods or services from Us
· information required to enter a promotion or win a prize, such as your age, date of birth, and Social Security Number or Tax ID Number
· any social account credentials that You provide to Us
· other Personal Information that You provide to Us
Information from Your Devices and Other Sites and Apps:
When You visit one of our websites or download or use one of our applications, We collect information about You and your device using cookies (which are small text files that websites save to your browser) pixels, web beacons, software, and/or other technology. Some cookies are necessary for our websites to function properly (for example, to facilitate and enhance interaction with the NCM Properties by saving your user preferences, customizing content for You, recording session information (such as items that You add to your shopping cart), alerting You to new areas that might be of interest upon return to the NCM Properties, and saving certain information about You). Other cookies are used for analytics, performance, or advertising purposes (for example, ensuring that You are not repeatedly sent the same banner ads, delivering targeted ads across websites and applications, and measuring ad delivery, interaction, performance). Similarly, We also collect, record, and store information provided by third-party sites and apps (which is affected by the privacy settings You establish with those sites and apps).
Information We receive about your device and from other sites and apps includes:
· hardware and software information and settings
· Internet Protocol addresses
· device attributes, such as make and model
· mobile advertising ID
· mobile carrier’s name
· precise geo-location with date and time stamps
· email open rate
· your visits to and interaction with NCM Properties
Information from Others:
We also receive Personal Information from other parties (such as movie ticket sellers, movie exhibitors, and data brokers), including:
· mobile advertising IDs
· device and network identifiers and configurations
· device attributes
· names
· email addresses
· Internet Protocol addresses
· phone numbers
· precise geo-location with date and time stamps
· information about places visited, purchases made, and personal attributes (such as age, gender, interests, and preferences)
In many instances, the Personal Information that We receive from other parties is pseudonymized. Pseudonymized information includes mobile advertising IDs, device and network identifiers, cookie identifiers, and other persistent alpha-numeric identifiers that are created by replacing Personal Information, such as name or email address, with a unique numeric or alpha-numeric string. For example, the email address “anyperson@ncm.com” would be represented as “B1FD4D6E3F8CFDC3207BE6E75DED349D6B629EC963F568847A5FFCCB134E6F73” after applying the SHA256 hash function. Pseudonymized information is not "anonymous" or "de-identified" because it can be used to identify You personally when paired with additional information.
At times, third-parties collect, record, or store Personal Information for Us on servers that may be inside or outside of the United States. We may link the information We have collected or received with other Personal Information to give Us a better understanding of your interests and preferences.
How We Use Personal Information
Your Interactions with Us and the NCM Properties:
We use your Personal Information to provide a more meaningful experience to You when You use or access the NCM Properties or interact with Us. For example, We use your Personal Information when You contact Us, use any of our social media platforms, or place orders with Us. We also use your Personal Information to maintain your progress in our games, to display that progress on leaderboards, and to provide You with rewards (e.g., Popcorn) in connection with your gameplay. In addition, We use Personal Information in our promotions to collect entry information, select winners, award prizes, and comply with applicable laws relating to announcing winners and tax reporting.
Developing Profiles and Creating Advertising Segments:
We use Personal Information to create pseudonymized profiles at the personal, device, or household level utilizing characteristics, behaviors, preferences, and interests that we know or infer. We aggregate profiles having common characteristics into segments that We think may be of interest to advertisers. We make information about these segments available to prospective clients and their agencies through demand side platforms. Clients and their agencies engage demand side platforms to deliver targeted advertising (including ads related to housing, employment, or financial or lending services) to one or more segments, and the demand side platforms facilitate the delivery of targeted advertising on publisher sites (such as websites, mobile applications, and Internet-connected televisions) that make advertising inventory available through supply side platforms.
Delivering Personalized Advertising to You:
In addition, We use Personal Information to deliver targeted advertising to You, including on behalf of our clients. Targeted advertising, sometimes referred to as cross-context behavioral advertising, involves the targeting and display of advertising to You where the advertisement is selected based on Personal Information obtained from your activities over time across businesses, distinctly-branded websites, applications, or services, other than your intentional interaction with Us, our distinctly-branded website, applications, or services (including to predict your preferences or interests). To better target advertising, We use an algorithm to create profiles based on what We know or can infer about You from information that We collect or receive. We maintain profiles in a third-party data management platform that pseudonymizes each profile by rendering the Personal Information no longer attributable to You without the use of additional information.
Measuring Success of Advertising Campaigns:
We also use pseudonymized information to measure the success of advertising campaigns. For example, We make pseudonymized information available to attribution and measurement providers to help Us understand your interaction with an ad and your purchase behavior after seeing an ad. We then provide aggregate metrics about targeted advertising campaign performance to clients and their agencies.
Personal Information We Disclose
We primarily disclose pseudonymized Personal Information and associated inferences with advertising technology companies that help us to enhance your Personal Information, to deliver targeted advertising to You, to attribute behaviors following your exposure to advertising, and to measure the success of advertising campaigns. We also disclose Personal Information (such as your username) when You interact with others on the NCM Properties. In addition, some sites and apps have features that allow You to send information about your activity on the NCM Properties back to the sites or apps (for example, to be published in your profile). If You choose to use these features, then your activity on the NCM Properties will be shared with the sites and apps. Further, We disclose Personal Information in connection with promotions that We run. For example, We disclose the names of winners in accordance with applicable law, We disclose names and contact information to co-sponsors and prize providers, and We report winner information (such as name, address, and Social Security Number) to relevant government agencies.
We may also disclose your Personal Information to third parties, such as service providers, in connection with a product or service You purchase from Us (e.g., for transaction processing and fraud prevention purposes), and those third may be located in other countries.
Sale of Personal Information
We do not currently sell Personal Information for monetary consideration, but We may receive other consideration that could result in the transfer of your Personal Information being considered a sale under certain state laws. In addition, We may sell Personal Information in the future. For example, We may sell Personal Information for monetary consideration to one or more clients, agencies, advertising technology providers, data aggregators, or other third-parties. In addition, We may sell Personal Information in connection with a merger or an acquisition of all or a portion of our business.
We do not have actual knowledge that We sell or share Personal Information of consumers under 16 years of age.
Sharing of Personal Information
We share, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate (“share”) pseudonymized Personal Information to third-parties for targeted advertising purposes. For example, We share segments containing pseudonymized Personal Information from our data management platform with demand side platforms and other advertising technology companies, which in turn share that information with supply side platforms for displaying targeted advertising through publisher properties, such as websites, mobile applications, and Internet-connected televisions. We also share that information with attribution and measurement companies that provide Us with insights on your characteristics, behaviors, preferences, and interests and to help determine for our clients their increase in sales attributable to exposure to targeted advertising.
We also use third-party services to facilitate and personalize online and offline communication about products and services that may be of interest to You based on your activities on the NCM Properties and other interactions You have with Us and other sites and apps. For example, We may use one or more outside ad serving companies to display advertisements on the NCM Properties. These companies may use Personal Information or other information (e.g., click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to or use of the NCM Properties and other web sites or applications to provide advertisements about goods and services that may be of interest to You. Similarly, We may use third-party providers for other purposes (e.g., to analyze data and patterns regarding use of the NCM Properties). These third-parties may collect Personal Information on the NCM Properties using cookies, pixels, web beacons, tracking agents, and/or other technology for advertising purposes. The Personal Information the third-parties may collect includes Internet Protocol addresses (or series of numbers that identify devices on networks), advertising IDs (or unique user IDs assigned to mobile devices, such as Apple’s "Identifier for Advertisers" or "Google Advertising ID," or operating environments to help personalizing offers) and other unique identifiers that are linked or reasonably linkable to a particular computer or device; date and time stamps; header and referrer Uniform Resource Locator (or domain name) data; and information about your activities on the NCM Properties and other sites and apps. For information about how You can manage your privacy preferences with third-parties, please see the “Your Rights Regarding Personal Information” section.
Your Rights Regarding Personal Information
In accordance with applicable law (and subject to applicable restrictions, limitations, and exceptions), You have the right to:
Know What Personal Information is Being Collected, Access Your Personal Information, and Obtain a Copy of Your Personal Information
You have the right to request that We disclose to You the categories of Personal Information We have collected about You; the categories of sources from which the Personal Information is collected; our business or commercial purpose for collecting, selling, or sharing your Personal Information; the categories of third-parties to whom We disclose Personal Information; and the specific pieces of Personal Information We have collected about You.
Correct Inaccurate Personal Information
You have the right to request that We correct your inaccurate Personal Information, taking into account the nature of the Personal Information and the purposes of processing the Personal Information.
Know What Personal Information is Sold, Shared, or Disclosed for a Business Purpose and to Whom
You have the right to request that We disclose to You the categories of Personal Information about You that We sold, shared, or disclosed for a business purpose and the categories of third-parties to whom the Personal Information was sold, shared, or disclosed.
Opt-Out of the Sale of Your Personal Information, Sharing of Your Personal Information, and Profiling in Furtherance of Decisions that Produce Legal or Similarly Significant Effects
You have the right, at any time, to direct Us not to sell your Personal Information, share your Personal Information for targeted advertising, or use your Personal Information for profiling (automated processing of your Personal Information to evaluate, analyze, or predict personal aspects related to your economic situation, health, personal preferences, interests, reliability, behavior, location, or movements).
Limit Use and Disclosure of Your Sensitive Personal Information
You have the right, at any time, to direct Us to limit our use of your Sensitive Personal Information, but your direction to do so will not affect any use: necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services; helping to ensure security and integrity; that is short-term and transient (including non-personalized advertising shown as part of your current interaction with Us); involving performing services on our behalf (including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on our behalf); to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by Us, or to improve, upgrade, or enhance that service or device; or as authorized by law, rule, or regulation.
Delete Your Personal Information
You have the right to request that We delete your Personal Information that We have collected from or about You unless it is reasonably necessary for Us to maintain your Personal Information (e.g., to complete a transaction, provide a good or service You requested or reasonably anticipate within our ongoing business relationship with You, or otherwise perform under a contract with You, help to ensure security and integrity, debug to identify and repair errors that impair existing intended functionality, in connection with the exercise of free speech or another right provided for by law, enable internal uses, or comply with a legal obligation or law (including electronic communications laws)). We may in some cases treat a request to delete as a request to opt-out.
Not be Discriminated Against following Your Opt-Out or Exercise of Other Privacy Rights
We will not discriminate against You because You exercise any of the rights listed above, but We may charge You a different price or rate or provide a different level or quality of goods or services to You when that difference is reasonably related to the value of your data to Us.
Exercising Your Rights
You (or an authorized agent that has signed permission from You) can submit requests relating to these rights by filling out the form available at https://www.ncm.com/privacy-choices; emailing Us at unsubscribe@ncm.com; writing Us at National CineMedia, Attn: Customer Service, 6300 South Syracuse Way, Suite 300, Centennial, CO 80111; or calling Us at 1-833-NCM-2272. You may also opt-out of the sale of your Personal Information by enabling the Global Privacy Control available at https://globalprivacycontrol.org/, which We will treat as a valid request for your browser or device.
For requests that are manifestly unfounded, excessive, or repetitive, We may either charge You a reasonable fee or refuse to act on your request. Further, We are not obligated to act on requests in connection with your rights to know what Personal Information is being collected, access Personal Information, or obtain a copy of Personal Information; correct inaccurate Personal Information; know what Personal Information is sold, shared, or disclosed and to whom; or delete Personal Information if We cannot verify that You are the Consumer about whom We have collected the Personal Information or are an agent authorized to act on the Consumer’s behalf. Certain requests (e.g., confirmation of processing of, access to, correcting inaccuracies in, deletion of, and obtaining a copy of Personal Information) do not apply to pseudonymized data. In addition, We do not have to honor your request if doing so would violate an evidentiary privilege or adversely affect or infringe on the rights, freedoms, or activities of others.
We will honor your request to opt-out no later than 15 business days after We receive your request. We will generally respond to verified requests for information, correction, or deletion within 45 days after We receive a verifiable consumer request, but We may extend our response period by an additional 45 days by notifying You within the initial 45-day period that We are extending it. If We decline your request, You may submit an appeal to Us by emailing Us at unsubscribe@ncm.com or writing Us at National CineMedia, Attn: Customer Service, 6300 South Syracuse Way, Suite 300, Centennial, CO 80111. In your appeal, You must provide Us with an explanation of why You think We should not have declined your request. Within 45 days after We receive your appeal, We will notify You of any action taken or not taken in response to your appeal. If We deny your appeal, You may contact your state Attorney General’s office.
What Exercising Your Rights Does Not Affect
Even after You submit a request, We can use or disclose your information in certain ways that are allowed by law, rule, or regulation. For example, We can collect, record, use, disclose, sell, or share your information:
To comply with federal, state, or local laws or comply with a court order or subpoena;
To comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;
To cooperate with law enforcement agencies concerning conduct or activity that We reasonably and in good faith believe may violate federal, state, or local law;
To cooperate with a government agency request for emergency access to your Personal Information if any natural person is at risk or danger of death or serious physical injury;
To a service provider, contractor, or other third-party bound to comply with specified privacy obligations;
As a furnisher of information for use in a credit report or as a user of a credit report;
To exercise or defend legal claims;
With a person covered by an evidentiary privilege;
In deidentified or aggregate form;
In connection with a merger or the sale of an ownership interest in Us or all or a portion of our assets; or
As otherwise permitted by law, rule, or regulation.
Other Steps You Can Take
Most browsers will allow You to erase cookies from your computer hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. Please refer to your browser instructions or help screen to learn more about these functions. Some browsers have a “do not track” feature that lets You tell websites that You do not want your online activities tracked. At this time, the NCM Properties do not respond to web browser “do not track” requests or similar signals because a uniform technological standard has not yet been developed.
If You access any of the NCM Properties through a mobile device, You may adjust the settings on your mobile device to allow or prevent the sharing of location information. For example, You can disable “Location” (or “Location Services” on iOS-based devices) on your mobile device to prevent sharing your location information with Us. Please note that if You disable the sharing of location information, You may be unable to access some features of the NCM Properties that are designed for mobile devices.
We do not control third-parties’ collection or use of your information to serve interest-based advertising. To learn more about this this advertising practice or to opt-out of the use of cookies for interest-based advertising, You can visit the Network Advertising Initiative, a coalition of online advertising networks that provides an opportunity for consumers to opt-out of targeted advertising by member companies. Please visit https://optout.aboutads.info/ for more information and https://optout.networkadvertising.org/ to exercise these choices. You may download the AppChoices app at https://youradchoices.com/appchoices to opt-out in mobile apps.
Appendix A
As defined by state privacy laws, “Personal Information” includes information that identifies, relates to, describes, is linked to, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular identified or identifiable natural person or household. “Sensitive Personal Information” includes Personal Information that reveals your social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, citizenship or immigration status, religious or philosophical beliefs, or union membership; the contents of your mail, email, and text messages unless We are the intended recipient; genetic or biometric information for the purpose of uniquely identifying You; Personal Information collected and analyzed concerning your health (including mental or physical health diagnosis), sex life, or sexual orientation; and Personal Information collected from a known child.
We do not collect, record, use, disclose, sell, or share all the information listed in the terms defined above. Instead, in the following chart, We provide more detail about the categories of Personal Information we collect; the categories of sources from which We collect that Personal Information; our business or commercial purposes for collecting, using, selling, and sharing Personal Information; an indication of whether We have sold, shared, or disclosed Personal Information, the categories of third-parties to which We disclose Personal Information; and our intended length of retention for each category of Personal Information:
|
Categories of Personal Information Collected (including in the preceding 12 months) |
Categories of Sources from which Information Collected |
Business or Commercial Purposes for Collecting, Using, Disclosing, Selling, or Sharing |
Whether Information Sold or Shared (including within the preceding 12 months) |
Whether Information Disclosed (including within the preceding 12 months) |
Categories of Third-Parties to which Information Disclosed, Sold, or Shared |
Intended Length of Retention |
|
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers |
Consumers and their devices directly, movie exhibitors and ticket sellers, advertising networks, internet service providers, data analytics providers, operating systems and platforms, and data brokers |
Facilitate game play, disclose promotion winners, develop profiles, deliver targeted ads, and measure effectiveness |
Information is not sold for monetary consideration, but in some states, may be considered as sold for non-monetary consideration; information is shared for targeted advertising |
Information is disclosed |
Advertising networks, service providers, internet service providers, data analytics providers, operating systems and platforms, other users, social networks, promotion co-sponsors and prize providers, and government entities |
For registered users: termination of registration + 3 years; For others: 10 years after collection |
|
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information |
Consumers and their devices directly, movie exhibitors and ticket sellers, advertising networks, internet service providers, data analytics providers, operating systems and platforms, and data brokers |
Facilitate game play, disclose promotion winners, develop profiles, deliver targeted ads, and measure effectiveness |
Information is not sold for monetary consideration, but in some states, may be considered as sold for non-monetary consideration; information is shared for targeted advertising |
Information is disclosed |
Advertising networks, service providers, internet service providers, data analytics providers, operating systems and platforms, other users, social networks, and government entities |
For registered users: termination of registration + 3 years; For others: 10 years after collection |
|
Characteristics of protected classifications under California or federal law |
Consumers and their devices directly, advertising networks, data analytics providers, operating systems and platforms, and data brokers |
Develop profiles, deliver targeted ads, and measure effectiveness |
Information is not sold for monetary consideration, but in some states, may be considered as sold for non-monetary consideration; information is shared for targeted advertising |
Information is disclosed |
Advertising networks, service providers, data analytics providers, operating systems and platforms, and social networks |
For registered users: termination of registration + 3 years; For others: 10 years after collection |
|
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies |
Consumers and their devices directly, movie exhibitors and ticket sellers, advertising networks, internet service providers, data analytics providers, operating systems and platforms, and data brokers |
Develop profiles, deliver targeted ads, and measure effectiveness |
Information is not sold for monetary consideration, but in some states, may be considered as sold for non-monetary consideration; information is shared for targeted advertising |
Information is disclosed |
Advertising networks, service providers, data analytics providers, operating systems and platforms, and social networks |
For registered users: termination of registration + 3 years; For others: 10 years after collection |
|
Biometric information |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement |
Consumers and their devices directly, advertising networks, internet service providers, data analytics providers, operating systems and platforms, and data brokers |
Develop profiles, deliver targeted ads, and measure effectiveness |
Information is not sold for monetary consideration, but in some states, may be considered as sold for non-monetary consideration; information is shared for targeted advertising |
Information is disclosed |
Advertising networks, service providers, internet service providers, data analytics providers, operating systems and platforms, and social networks |
For registered users: termination of registration + 3 years; For others: 10 years after collection |
|
Geolocation data |
Consumers and their devices directly, movie exhibitors and ticket sellers, advertising networks, internet service providers, data analytics providers, operating systems and platforms, and data brokers |
Develop profiles, deliver targeted ads, and measure effectiveness |
Information is not sold for monetary consideration, but in some states, may be considered as sold for non-monetary consideration; information is shared for targeted advertising |
Information is disclosed |
Advertising networks, service providers, internet service providers, data analytics providers, operating systems and platforms, and social networks |
For registered users: termination of registration + 3 years; For others: 10 years after collection |
|
Audio, electronic, visual, thermal, olfactory, or similar information |
Consumers and their devices directly, movie exhibitors and ticket sellers, advertising networks, internet service providers, data analytics providers, operating systems and platforms, and data brokers |
Develop profiles, deliver targeted ads, and measure effectiveness |
Information is not sold for monetary consideration, but in some states, may be considered as sold for non-monetary consideration; information is shared for targeted advertising |
Information is disclosed |
Advertising networks, service providers, internet service providers, data analytics providers, operating systems and platforms, and social networks |
For registered users: termination of registration + 3 years; For others: 10 years after collection |
|
Professional or employment-related information |
Advertising networks, data analytics providers, operating systems and platforms, and data brokers |
Develop profiles, deliver targeted ads, and measure effectiveness |
Information is not sold; information is shared for targeted advertising |
Information is disclosed |
Advertising networks, service providers, data analytics providers, operating systems and platforms, and social networks |
For registered users: termination of registration + 3 years; For others: 10 years after collection |
|
Education information |
Advertising networks, data analytics providers, operating systems and platforms, and data brokers |
Develop profiles, deliver targeted ads, and measure effectiveness |
Information is not sold; information is shared for targeted advertising |
Information is disclosed |
Advertising networks, service providers, data analytics providers, operating systems and platforms, and social networks |
For registered users: termination of registration + 3 years; For others: 10 years after collection |
|
Inferences drawn from any of the above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, affiliations, beliefs, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes |
Advertising networks, data analytics providers, operating systems and platforms, and data brokers |
Develop profiles, deliver targeted ads, and measure effectiveness |
Information is not sold for monetary consideration, but in some states, may be considered as sold for non-monetary consideration; information is shared for targeted advertising |
Information is disclosed |
Advertising networks, service providers, data analytics providers, operating systems and platforms, and social networks |
For registered users: termination of registration + 3 years; For others: 10 years after collection |
|
Categories of Sensitive Personal Information Collected (including in the preceding 12 months). Sensitive Personal Information is Personal information that reveals: |
Categories of Sources from which Information Collected |
Business or Commercial Purposes for Collecting, Using, Disclosing, Selling, or Sharing |
Whether Information Sold or Shared (including within the preceding 12 months) |
Whether Information Disclosed (including within the preceding 12 months) |
Categories of Third-Parties to which Information Disclosed, Sold, or Shared |
Intended Length of Retention |
|
A consumer’s social security, driver’s license, state identification card, or passport number |
Consumers directly |
Administer promotions |
Information is not sold or shared |
Information is disclosed |
Government agencies and service providers |
7 years after last use (e.g., tax reporting) |
|
A consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account |
Consumers directly |
Enable account access |
Information is not sold or shared |
Information is disclosed |
Service providers |
Termination of registration + 3 years |
|
A consumer’s precise geolocation (within 1,850 feet of a specific location) |
Consumers and their devices directly, movie exhibitors and ticket sellers, advertising networks, internet service providers, data analytics providers, operating systems and platforms, and data brokers |
Develop profiles, deliver targeted ads, and measure effectiveness |
Information is not sold for monetary consideration, but in some states, may be considered as sold for non-monetary consideration; information is shared for targeted advertising |
Information is disclosed |
Advertising networks, service providers, internet service providers, data analytics providers, operating systems and platforms, and social networks |
For registered users: termination of registration + 3 years; For others: 10 years after collection |
|
A consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
A consumer’s citizenship or immigration status |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
A consumer’s genetic data |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
The processing of biometric information for the purpose of uniquely identifying a consumer |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
Personal Information collected and analyzed concerning a consumer’s health (including a mental or physical health diagnosis) |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
Personal Information collected and analyzed concerning a consumer’s sex life or sexual orientation |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
Business-to-Business Privacy Policy
For California Residents
Last Updated: December 8, 2023
National CineMedia, LLC and its affiliates (“NCM,” “We,” or “Us”) have published this Privacy Policy to provide California residents who have acted or are acting as an employee, owner, director, officer, or independent contractor of another organization (“You” or “Consumer”) with a description of our practices regarding the collection, recording, use, and disclosure of Personal Information within the context of Us and your organization conducting due diligence or providing or receiving a product or service and of the rights You have regarding your Personal Information. We discuss below the Personal Information We collect, record, and store; provide information about how We use Personal Information and the Personal Information that We disclose; and describe your rights regarding your Personal Information. For details about what constitutes Personal Information and details about the categories of Personal Information We collect; the categories of sources from which We collect that Personal Information; our business or commercial purposes for collecting and using Personal Information; an indication of whether We have disclosed Personal Information, the categories of third-parties to which We disclose Personal Information; and our intended length of retention for each category of Personal Information, please refer to the definitions, discussion, and chart in Appendix A.
Personal Information We Collect, Record, and/or Store
Information from You:
We collect, record, and/or store Personal Information from You. For example, We receive Personal Information from and about You in connection with written or verbal communications or transactions between Us and You, where You have acted or are acting as an employee, owner, director, officer, or independent contractor of your organization (which may be a company, partnership, sole proprietorship, non-profit, or government agency) and in connection with your or your organization’s communications or transactions with Us that occur within the context of our conducting due diligence regarding, or Us providing or receiving a product or service to or from, your organization. That Personal Information may include:
· your name, title, and contact information, such as mobile or office number, email address, postal address, and social media handle
· employment-related information
· any username and password You create with Us
· information on areas or components of the NCM websites You access
· bank account or credit or debit card numbers You use to purchase goods or services from Us
· additional information required for a credit check, such as your age, date of birth, and Social Security Number or Tax ID Number
· your image or likeness (for example, as used in creative assets)
· other Personal Information that You provide to Us
Information from Your Devices and Other Sites and Apps:
We receive information from your device and from other sites and apps, including:
· Internet Protocol addresses
· device identifiers
· email open rate
· your visits to and interaction with NCM Properties
Information from Others:
We may also receive Personal Information from other parties (such as your organization, event organizers, industry or prospecting reports, social media platforms such as LinkedIn, and credit bureaus), including:
· name, title, and contact information (such as email address, postal address, and phone number), and social media handle
· employment-related information
· credit history and creditworthiness
How We Use Personal Information
Interactions between Us, You, and/or your organization
We use your Personal Information in connection with interactions between Us, You, and/or your organization. Those interactions may include conducting due diligence regarding, or Us providing or receiving a product or service. In connection with selling products or services, We may use Personal Information when We are prospecting, monitoring our sales efforts (such as email open rates), assessing creditworthiness, contracting, delivering our products and services, providing post-campaign reporting, receiving feedback, and collecting payments. In connection with buying products or services, We may use Personal Information when We are evaluating potential vendors, contracting, obtaining and using products or services, providing feedback, paying, and reporting payments made (such as to relevant government entities).
Personal Information We Disclose
We may disclose your Personal Information to third parties, such as service providers, in connection with a product or service You or your organization purchases from Us (e.g., for transaction processing and fraud prevention purposes), and those third may be located in other countries. We disclose Personal Information (such as names, addresses, Social Security Numbers or Tax Identification Numbers, and payment amounts) to credit bureaus so We can receive information to assess creditworthiness, to government entities (such as in connection with required tax reporting), and to collection agencies in connection with past-due receivables. We may also disclose Personal Information (such as names or images) when that information is included in creative assets that we distribute or display.
Sale of Personal Information
We do not currently sell your Personal Information, however, We may sell Personal Information in the future, including in connection with a merger or an acquisition of all or a portion of our business.
Sharing of Personal Information
We do not share, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate (“share”) your Personal Information to third-parties for targeted advertising purposes.
Your Rights Regarding Personal Information
In accordance with applicable law (and subject to applicable restrictions, limitations, and exceptions), You have the right to:
Know What Personal Information is Being Collected, Access Your Personal Information, and Obtain a Copy of Your Personal Information
You have the right to request that We disclose to You the categories of Personal Information We have collected about You; the categories of sources from which the Personal Information is collected; our business or commercial purpose for collecting, selling, or sharing your Personal Information; the categories of third-parties to whom We disclose Personal Information; and the specific pieces of Personal Information We have collected about You.
Correct Inaccurate Personal Information
You have the right to request that We correct your inaccurate Personal Information, taking into account the nature of the Personal Information and the purposes of processing the Personal Information.
Know What Personal Information is Sold, Shared, or Disclosed for a Business Purpose and to Whom
You have the right to request that We disclose to You the categories of Personal Information about You that We disclosed for a business purpose and the categories of third-parties to whom the Personal Information was disclosed. We do not currently sell or share your Personal Information.
Limit Use and Disclosure of Your Sensitive Personal Information
You have the right, at any time, to direct Us to limit our use of your Sensitive Personal Information, but your direction will not affect any use: necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services; helping to ensure security and integrity; that is short-term and transient (including non-personalized advertising shown as part of your current interaction with Us); involving performing services on our behalf (including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on our behalf); to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by Us, or to improve, upgrade, or enhance that service or device; or as authorized by law, rule, or regulation.
Delete Your Personal Information
You have the right to request that We delete your Personal Information that We have collected from or about You unless it is reasonably necessary for Us to maintain your Personal Information (e.g., to complete a transaction, provide a good or service You requested or reasonably anticipate within our ongoing business relationship with You, or otherwise perform under a contract with You, help to ensure security and integrity, debug to identify and repair errors that impair existing intended functionality, in connection with the exercise of free speech or another right provided for by law, enable internal uses, or comply with a legal obligation or law (including electronic communications laws)).
Not be Discriminated Against following Your Opt-Out or Exercise of Other Privacy Rights
We will not discriminate against You because You exercise any of the rights listed above, but We may charge You a different price or rate or provide a different level or quality of goods or services to You when that difference is reasonably related to the value of your data to Us.
Exercising Your Rights
You (or an authorized agent that has signed permission from You) can submit requests relating to these rights by filling out the form available at https://www.ncm.com/privacy-choices; emailing Us at unsubscribe@ncm.com; writing Us at National CineMedia, Attn: Customer Service, 6300 South Syracuse Way, Suite 300, Centennial, CO 80111; or calling Us at 1-833-NCM-2272.
For requests that are manifestly unfounded, excessive, or repetitive, We may either charge You a reasonable fee or refuse to act on your request. Further, We are not obligated to provide information in connection with your rights to know what Personal Information is being collected, access Personal Information, or obtain a copy of Personal Information; correct inaccurate Personal Information; know what Personal Information is disclosed and to whom; or delete Personal Information if We cannot verify that You are the Consumer about whom We have collected the Personal Information or are an agent authorized to act on the Consumer’s behalf. In addition, We do not have to honor your request if doing so would violate an evidentiary privilege or adversely affect or infringe on the rights, freedoms, or activities of others.
We will generally respond to verified requests for information, correction, or deletion within 45 days after We receive a verifiable consumer request, but We may extend our response period by an additional 45 days by notifying You within the initial 45-day period that We are extending it. If We decline your request, You may submit an appeal to Us by emailing Us at unsubscribe@ncm.com or writing Us at National CineMedia, Attn: Customer Service, 6300 South Syracuse Way, Suite 300, Centennial, CO 80111. In your appeal, You must provide Us with an explanation of why You think We should not have declined your request. Within 45 days after We receive your appeal, We will notify You of any action taken or not taken in response to your appeal. If We deny your appeal, You may contact your state Attorney General’s office.
What Exercising Your Rights Does Not Affect
Even after You submit a request, We can use or disclose your information in certain ways that are allowed by law, rule, or regulation. For example, We can collect, record, use, or disclose your information:
To comply with federal, state, or local laws or comply with a court order or subpoena;
To comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;
To cooperate with law enforcement agencies concerning conduct or activity that We reasonably and in good faith believe may violate federal, state, or local law;
To cooperate with a government agency request for emergency access to your Personal Information if any natural person is at risk or danger of death or serious physical injury;
To a service provider, contractor, or other third-party bound to comply with specified privacy obligations;
As a furnisher of information for use in a credit report or as a user of a credit report;
To exercise or defend legal claims;
With a person covered by an evidentiary privilege;
In deidentified or aggregate form;
In connection with a merger or the sale of an ownership interest in Us or all or a portion of our assets; or
As otherwise permitted by law, rule, or regulation.
Some browsers have a “do not track” feature that lets You tell websites that You do not want your online activities tracked. At this time, the NCM Properties do not respond to web browser “do not track” requests or similar signals because a uniform technological standard has not yet been developed.
Appendix A
As defined by state privacy laws, “Personal Information” includes information that identifies, relates to, describes, is linked to, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular identified or identifiable natural person or household. “Sensitive Personal Information” includes Personal Information that reveals your social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, citizenship or immigration status, religious or philosophical beliefs, or union membership; the contents of your mail, email, and text messages unless We are the intended recipient; genetic or biometric information for the purpose of uniquely identifying You; Personal Information collected and analyzed concerning your health (including mental or physical health diagnosis), sex life, or sexual orientation; and Personal Information collected from a known child.
We do not collect, record, use, or disclose all the information listed in the terms defined above. Instead, in the following chart, We provide more detail about the categories of Personal Information we collect; the categories of sources from which We collect that Personal Information; our business or commercial purposes for collecting and using Personal Information; an indication of whether We have disclosed Personal Information, the categories of third-parties to which We disclose Personal Information; and our intended length of retention for each category of Personal Information:
|
Categories of Personal Information Collected (including in the preceding 12 months) |
Categories of Sources from which Information Collected |
Business or Commercial Purposes for Collecting, Using, or Disclosing |
Whether Information Sold or Shared (including within the preceding 12 months) |
Whether Information Disclosed (including within the preceding 12 months) |
Categories of Third-Parties to which Information Disclosed |
Intended Length of Retention |
|
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers |
Consumers directly (such as email correspondence, client meetings, etc.), third parties (such as your organization), industry or prospecting reports, and social media platforms (such as LinkedIn) |
Lead generation, sales tracking, marketing, vendor setup, credit checks, and payment processing and collection |
Information is not sold or shared |
Information is disclosed |
Service providers, collection agencies, and government entities |
Length of relationship + 5 years of inactivity |
|
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information |
Consumers directly (such as email correspondence, client meetings, etc.), third parties (such as your organization), industry or prospecting reports, and social media platforms (such as LinkedIn) |
Lead generation, sales tracking, marketing, vendor setup, credit checks, and payment processing and collection |
Information is not sold or shared |
Information is disclosed |
Service providers and collection agencies |
Length of relationship + 5 years of inactivity |
|
Characteristics of protected classifications under California or federal law |
Consumers directly, third parties (such as your organization), industry or prospecting reports, and social media platforms (such as LinkedIn) |
Lead generation, sales tracking, marketing, and vendor setup |
Information is not sold or shared |
Information is disclosed |
Service providers, prospective clients, public audiences, and government entities |
Length of relationship + 5 years of inactivity |
|
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies |
Consumers directly, and third parties (such as your organization) |
Lead generation, sales tracking, marketing, vendor setup, credit checks, and payment processing and collection |
Information is not sold or shared |
Information is disclosed |
Service providers and collection agencies |
Length of relationship + 5 years of inactivity |
|
Biometric information |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement |
Consumers’ devices, Internet service providers, and operating systems and platforms |
Lead generation, marketing, and analytics |
Information is not sold or shared |
Information is disclosed |
Service providers and internet service providers |
Length of relationship + 5 years of inactivity |
|
Geolocation data |
Consumers directly, and third parties (such as your organization and event organizers) |
Lead generation, sales tracking, marketing, vendor setup, credit checks, and payment processing, reporting, and collection |
Information is not sold or shared |
Information is disclosed |
Service providers, collection agencies, and government entities |
Length of relationship + 5 years of inactivity |
|
Audio, electronic, visual, thermal, olfactory, or similar information |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
Professional or employment-related information |
Consumers directly, and third parties (such as your organization and event organizers) |
Lead generation, sales tracking, marketing, vendor setup, credit checks, and payment processing and collection |
Information is not sold or shared |
Information is not disclosed |
N/A |
Length of relationship + 5 years of inactivity |
|
Education information |
Consumers directly |
Marketing |
Information is not sold or shared |
Information is not disclosed |
N/A |
Length of relationship + 5 years of inactivity |
|
Inferences drawn from any of the above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, affiliations, beliefs, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
Categories of Sensitive Personal Information Collected (including in the preceding 12 months). Sensitive Personal Information is Personal information that reveals: |
Categories of Sources from which Information Collected |
Business or Commercial Purposes for Collecting, Using, or Disclosing |
Whether Information Sold or Shared (including within the preceding 12 months) |
Whether Information Disclosed (including within the preceding 12 months) |
Categories of Third-Parties to which Information Disclosed |
Intended Length of Retention |
|
A consumer’s social security, driver’s license, state identification card, or passport number |
Consumers directly |
Vendor setup, credit checks, and payment processing and collection |
Information is not sold or shared |
Information is disclosed |
Service providers, collection agencies, and government entities |
Length of relationship + 5 years of inactivity |
|
A consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account |
Consumers directly |
Enable account access and purchases |
Information is not sold or shared |
Information is disclosed |
Service providers |
Length of relationship + 5 years of inactivity |
|
A consumer’s precise geolocation (within 1,850 feet of a specific location) |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
A consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership |
Consumers directly, third parties (such as your organization), industry or prospecting reports, and social media platforms (such as LinkedIn) |
Lead generation, sales tracking, marketing, and vendor setup |
Information is not sold or shared |
Information is disclosed |
Service providers, prospective clients, public audiences, and government entities |
Length of relationship + 5 years of inactivity |
|
A consumer’s citizenship or immigration status |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
A consumer’s genetic data |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
The processing of biometric information for the purpose of uniquely identifying a consumer |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
Personal Information collected and analyzed concerning a consumer’s health (including a mental or physical health diagnosis) |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
Personal Information collected and analyzed concerning a consumer’s sex life or sexual orientation |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
Employee /Officer/ Director/ Owner/ Applicant/ Independent Contractor Privacy Policy
For California Residents
Last Updated: December 8, 2023
National CineMedia, LLC and its affiliates (“NCM,” “We,” or “Us”) have published this Privacy Policy to provide California residents who are employees, officers, directors, owners, applicants, or independent contractors of NCM (“You” or “Consumer”) with a description of our practices regarding the collection, recording, use, selling, and disclosure of Personal Information and of the rights You have regarding your Personal Information. We discuss below the Personal Information We collect, record, and store; provide information about how We use Personal Information and the Personal Information that We disclose; and describe your rights regarding your Personal Information. For details about what constitutes Personal Information and details about the categories of Personal Information We collect; the categories of sources from which We collect that Personal Information; our business or commercial purposes for collecting and using Personal Information; an indication of whether We have disclosed Personal Information, the categories of third-parties to which We disclose Personal Information; and our intended length of retention for each category of Personal Information, please refer to the definitions, discussion, and chart in Appendix A.
Personal Information We Collect, Record, and/or Store
Information from You:
We collect, record, and/or store Personal Information from You. For example, We receive Personal Information from and about You when You apply for a job with Us; work for Us as an employee, officer, or director; or provide products or services to Us as an independent contractor. That Personal Information may include:
· your name, title, and contact information, such as mobile or office number, email address, postal address(es), and social media handle
· documents establishing identity and/or employment authorization as shown on Form I-9 (such as passport, state driver’s license or other ID card, Social Security Account Number or Tax Identification Number card or other document establishing employment authorization)
· work history
· education
· date of birth
· gender
· ethnicity
· nationality
· marital status
· disability status
· veteran status
· medical information
· vehicle insurance information
· sponsorship and work visa information
· any username and password You create with Us or use through our network
· bank account information (such as account number and routing number)
· life event records (e.g., birth or marriage certificates and divorce documentation)
· information about your dependents and beneficiaries (such as name, address, phone number, relationship, gender, Social Security Number or Tax Identification Number, medical information, and date of birth)
· photos of You and your dependents
· other Personal Information that You provide to Us
Information from Your and Our Devices and Other Sites and Apps:
We receive information from your and our devices and from other sites and apps, including:
· hardware and software information and settings
· Internet Protocol addresses
· device attributes, such as make and model
· precise geo-location with date and time stamps
· your visits to and interaction with NCM systems, including information on areas or components of the NCM systems and websites You access
Information from Others:
We may also receive Personal Information from other parties (such as former employers, health care providers, background check providers, and government entities), including:
· name and aliases
· employment-related information (such as titles and dates employed)
· background check information (such as criminal history, motor vehicle history, and education information)
· medical information about you and your dependents
· alimony and child support obligations
Personal Information Other Organizations May Collect, Record, Store, and/or Use
Similarly, when You have acted or are acting as an employee, owner, director, officer, or independent contractor for Us, other organizations may collect, record, use, and disclose your Personal Information that they receive within the context of Us and those organizations conducting due diligence or providing or receiving products or services to or from each other. You should refer to each organization’s privacy policy for a description about its privacy practices and your privacy rights.
How We Use Personal Information
Furthering the Relationship between Us and You, as an Applicant, Employee, Officer, Director, Owner, or Independent Contractor
We use your Personal Information in connection with the relationship You have with Us. For example, depending on the nature of your relationship with Us, We may use your Personal Information to:
· evaluate your capabilities (such as performing skills assessments, comparing skills to job postings, performing background checks, conducting performance reviews, or managing performance)
· fulfill our obligations to You (such as paying fees You have earned, paying wages and bonuses, granting equity awards, or providing employee benefits to You and your beneficiaries)
· fulfill our legal and reporting obligations (such as tax reporting, reporting employment metrics, complying with alimony or child support requirements, or securities filings)
· enhancing our workforce (such as through our Diversity, Equity, and Inclusion initiatives and affirmative action plans)
· confirming your employment and income history with NCM
Personal Information We Disclose
We disclose Personal Information in connection with our current or past relationship with You. For example, We disclose your name, bank account number, and routing number to make payments to You. We may also disclose to government entities your name, address, Social Security Number or Tax ID Number, and amounts We have paid to You or included in your income (such as wages, bonuses, or equity awards). We may provide your name, address, email address, equity awards, and dividends to brokerages. We may also disclose your and your beneficiaries’ Personal Information to provide You and them with benefits. We may disclose your employment and income history in connection with a loan You are seeking or to confirm your employment history with Us to your future prospective employers. We report Personal Information (such as gender, veteran status, disability, ethnicity, age, date of birth, workers compensation classification, or unemployment information) to government entities. We may make such disclosures directly to others or through our service providers or other third parties.
Sale of Personal Information
We do not currently sell your Personal Information, however, We may sell Personal Information in the future, including in connection with a merger or an acquisition of all or a portion of our business.
Sharing of Personal Information
We do not share, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate (“share”) your Personal Information to third-parties for targeted advertising purposes.
Your Rights Regarding Personal Information
In accordance with applicable law (and subject to applicable restrictions, limitations, and exceptions), You have the right to:
Know What Personal Information is Being Collected, Access Your Personal Information, and Obtain a Copy of Your Personal Information
You have the right to request that We disclose to You the categories of Personal Information We have collected about You; the categories of sources from which the Personal Information is collected; our business or commercial purpose for collecting, selling, or sharing your Personal Information; the categories of third-parties to whom We disclose Personal Information; and the specific pieces of Personal Information We have collected about You.
Correct Inaccurate Personal Information
You have the right to request that We correct your inaccurate Personal Information, taking into account the nature of the Personal Information and the purposes of processing the Personal Information.
Know What Personal Information is Sold, Shared, or Disclosed for a Business Purpose and to Whom
You have the right to request that We disclose to You the categories of Personal Information about You that We disclosed for a business purpose and the categories of third-parties to whom the Personal Information was disclosed. We do not currently sell or share your Personal Information.
Limit Use and Disclosure of Your Sensitive Personal Information
You have the right, at any time, to direct Us to limit our use of your Sensitive Personal Information, but your direction will not affect any use: necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services; helping to ensure security and integrity; that is short-term and transient (including non-personalized advertising shown as part of your current interaction with Us); involving performing services on our behalf (including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on our behalf); to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by Us, or to improve, upgrade, or enhance that service or device; or as authorized by law, rule, or regulation.
Delete Your Personal Information
You have the right to request that We delete your Personal Information that We have collected from or about You unless it is reasonably necessary for Us to maintain your Personal Information (e.g., to complete a transaction, provide a good or service You requested or reasonably anticipate within our ongoing business relationship with You, or otherwise perform under a contract with You, help to ensure security and integrity, debug to identify and repair errors that impair existing intended functionality, in connection with the exercise of free speech or another right provided for by law, enable internal uses, or comply with a legal obligation or law (including electronic communications laws)).
Not be Discriminated Against following Your Opt-Out or Exercise of Other Privacy Rights
We will not discriminate against You because You exercise any of the rights listed above, but We may charge You a different price or rate or provide a different level or quality of goods or services to You when that difference is reasonably related to the value of your data to Us.
Exercising Your Rights
You (or an authorized agent that has signed permission from You) can submit requests relating to these rights by filling out the form available at https://www.ncm.com/privacy-choices; emailing Us at unsubscribe@ncm.com; writing Us at National CineMedia, Attn: Customer Service, 6300 South Syracuse Way, Suite 300, Centennial, CO 80111; or calling Us at 1-833-NCM-2272.
For requests that are manifestly unfounded, excessive, or repetitive, We may either charge You a reasonable fee or refuse to act on your request. Further, We are not obligated to provide information in connection with your rights to know what Personal Information is being collected, access Personal Information, or obtain a copy of Personal Information; correct inaccurate Personal Information; know what Personal Information is disclosed and to whom; or delete Personal Information if We cannot verify that You are the Consumer about whom We have collected the Personal Information or are an agent authorized to act on the Consumer’s behalf. In addition, We do not have to honor your request if doing so would violate an evidentiary privilege or adversely affect or infringe on the rights, freedoms, or activities of others.
We will generally respond to verified requests for information, correction, or deletion within 45 days after We receive a verifiable consumer request, but We may extend our response period by an additional 45 days by notifying You within the initial 45-day period that We are extending it. If We decline your request, You may submit an appeal to Us by emailing Us at unsubscribe@ncm.com or writing Us at National CineMedia, Attn: Customer Service, 6300 South Syracuse Way, Suite 300, Centennial, CO 80111. In your appeal, You must provide Us with an explanation of why You think We should not have declined your request. Within 45 days after We receive your appeal, We will notify You of any action taken or not taken in response to your appeal. If We deny your appeal, You may contact your state Attorney General’s office.
What Exercising Your Rights Does Not Affect
Even after You submit a request, We can use or disclose your information in certain ways that are allowed by law, rule, or regulation. For example, We can collect, record, use, disclose, sell, or share your information:
To comply with federal, state, or local laws or comply with a court order or subpoena;
To comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;
To cooperate with law enforcement agencies concerning conduct or activity that We reasonably and in good faith believe may violate federal, state, or local law;
To cooperate with a government agency request for emergency access to your Personal Information if any natural person is at risk or danger of death or serious physical injury;
To a service provider, contractor, or other third-party bound to comply with specified privacy obligations;
As a furnisher of information for use in a credit report or as a user of a credit report;
To exercise or defend legal claims;
With a person covered by an evidentiary privilege;
In deidentified or aggregate form;
In connection with a merger or sale of an ownership interest or all or a portion of our assets; or
As otherwise permitted by law, rule, or regulation.
Some browsers have a “do not track” feature that lets You tell websites that You do not want your online activities tracked. At this time, the NCM Properties do not respond to web browser “do not track” requests or similar signals because a uniform technological standard has not yet been developed.
Appendix A
As defined by state privacy laws, “Personal Information” includes information that identifies, relates to, describes, is linked to, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular identified or identifiable natural person or household. “Sensitive Personal Information” includes Personal Information that reveals your social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, citizenship or immigration status, religious or philosophical beliefs, or union membership; the contents of your mail, email, and text messages unless We are the intended recipient; genetic or biometric information for the purpose of uniquely identifying You; Personal Information collected and analyzed concerning your health (including mental or physical health diagnosis), sex life, or sexual orientation; and Personal Information collected from a known child.
We do not collect, record, use, or disclose all the information listed in the terms defined above. Instead, in the following chart, We provide more detail about the categories of Personal Information we collect; the categories of sources from which We collect that Personal Information; our business or commercial purposes for collecting and using Personal Information; an indication of whether We have disclosed Personal Information, the categories of third-parties to which We disclose Personal Information; and our intended length of retention for each category of Personal Information:
|
Categories of Personal Information Collected (including in the preceding 12 months) |
Categories of Sources from which Information Collected |
Business or Commercial Purposes for Collecting, Using, or Disclosing |
Whether Information Sold or Shared (including within the preceding 12 months) |
Whether Information Disclosed (including within the preceding 12 months) |
Categories of Third-Parties to which Information Disclosed |
Intended Length of Retention |
|
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers |
Consumers and their devices directly, operating systems and platforms, background check providers, recruiting services and platforms, employees, healthcare providers, and government entities |
Work-related activities and communications, such as evaluating candidates, assessing performance, making payments, providing compensation, granting stock rights, providing benefits, filing government reports, and auditing |
Information is not sold or shared |
Information is disclosed |
Financial institutions, benefits brokers and providers, insurance brokers and carriers, employment verification services, operating systems and platforms, accounting firms, law firms, service providers, healthcare providers, and government entities |
Up to 25 years |
|
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information |
Consumers and their devices directly, operating systems and platforms, background check providers, recruiting services and platforms, employees, healthcare providers, and government entities |
Work-related activities and communications, such as evaluating candidates, assessing performance, making payments, providing compensation, granting stock rights, providing benefits, filing government reports, and auditing |
Information is not sold or shared |
Information is disclosed |
Financial institutions, benefits brokers and providers, insurance brokers and carriers, employment verification services, operating systems and platforms, accounting firms, law firms, service providers, healthcare providers, and government entities |
Up to 25 years |
|
Characteristics of protected classifications under California or federal law |
Consumers directly, operating systems and platforms, background check providers, recruiting services and platforms, employees, healthcare providers, and government entities |
Work-related activities and communications, such as facilitating Diversity, Equity, and Inclusion initiates, filing government reports, and auditing |
Information is not sold or shared |
Information is disclosed |
Law firms, service providers, and government entities |
Up to 25 years |
|
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
Biometric information |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement |
Consumers and their devices directly, operating systems and platforms, and background check providers, recruiting services and platforms, employees, healthcare providers, and government entities |
Work-related activities, such as monitoring network access, use, and security |
Information is not sold or shared |
Information is disclosed |
Service providers |
Up to 25 years |
|
Geolocation data |
Consumers and their devices directly, operating systems and platforms, background check providers, recruiting services and platforms, employees, healthcare providers, and government entities |
Work-related activities, such as monitoring network access, use, and security |
Information is not sold or shared |
Information is disclosed |
Service providers |
Up to 25 years |
|
Audio, electronic, visual, thermal, olfactory, or similar information |
Consumers and their devices directly, operating systems and platforms, background check providers, recruiting services and platforms, employees, healthcare providers, and government entities |
Work-related activities and communications, such as evaluating candidates, assessing performance, making payments, providing compensation, granting stock rights, providing benefits, filing government reports, and auditing |
Information is not sold or shared |
Information is disclosed |
Financial institutions, benefits brokers and providers, insurance brokers and carriers, employment verification services, operating systems and platforms, accounting firms, law firms, service providers, healthcare providers, and government entities |
Up to 25 years |
|
Professional or employment-related information |
Consumers directly, background check providers, and former employers |
Work-related activities and communications, such as evaluating candidates, filing government reports, and auditing |
Information is not sold or shared |
Information is disclosed |
Financial institutions, benefits brokers and providers, insurance brokers and carriers, employment verification services, operating systems and platforms, accounting firms, law firms, service providers, healthcare providers, and government entities |
Up to 25 years |
|
Education information |
Consumers directly, background check providers, and educational institutions |
Work-related activities and communications, such as evaluating candidates, filing government reports, and auditing |
Information is not sold or shared |
Information is disclosed |
Employment verification services, operating systems and platforms, and government entities |
Up to 25 years |
|
Inferences drawn from any of the above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, affiliations, beliefs, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
Categories of Sensitive Personal Information Collected (including in the preceding 12 months). Sensitive Personal Information is Personal information that reveals: |
Categories of Sources from which Information Collected |
Business or Commercial Purposes for Collecting, Using, or Disclosing |
Whether Information Sold or Shared (including within the preceding 12 months) |
Whether Information Disclosed (including within the preceding 12 months) |
Categories of Third-Parties to which Information Disclosed |
Intended Length of Retention |
|
A consumer’s social security, driver’s license, state identification card, or passport number |
Consumers directly |
Work-related activities and communications, such as confirming work eligibility, filing government reports, and auditing |
Information is not sold or shared |
Information is disclosed |
Government agencies and service providers |
Up to 25 years |
|
A consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account |
Consumers directly |
Work-related activities and communications, such as identity management, and monitoring network access, use, and security |
Information is not sold or shared |
Information is disclosed |
Service providers |
Up to 25 years |
|
A consumer’s precise geolocation (within 1,850 feet of a specific location) |
Consumers and their devices directly, operating systems and platforms, background check providers, recruiting services and platforms, employees, healthcare providers, and government entities |
Work-related activities, such as monitoring worksite presence (e.g., field technicians at exhibitor locations) |
Information is not sold or shared |
Information is disclosed |
Service providers |
Up to 25 years |
|
A consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership |
Consumers directly |
Work-related activities and communications, such as facilitating Diversity, Equity, and Inclusion initiates, filing government reports, and auditing |
Information is not sold or shared |
Information is disclosed |
Law firms, service providers, healthcare providers, and government entities |
Up to 25 years |
|
A consumer’s citizenship or immigration status |
Consumers directly |
Work-related activities and communications, such as establishing work authorization, facilitating Diversity, Equity, and Inclusion initiates, filing government reports, and auditing |
Information is not sold or shared |
Information is disclosed |
Law firms, service providers, and government entities |
Up to 25 years |
|
The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
A consumer’s genetic data |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
The processing of biometric information for the purpose of uniquely identifying a consumer |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |
|
Personal Information collected and analyzed concerning a consumer’s health (including a mental or physical health diagnosis) |
Consumers directly, healthcare providers, and insurance companies |
Work-related activities, such as providing health benefits and granting family and medical leave |
N/A |
N/A |
Law firms, service providers, healthcare providers, and government entities |
Up to 25 years |
|
Personal Information collected and analyzed concerning a consumer’s sex life or sexual orientation |
N/A |
N/A |
N/A |
N/A |
N/A |
N/A |