Updated on 17 May 2018 (See the changes here)
Finnkino Ltd (hereinafter referred to as “Finnkino” or “we”) collects, stores and processes personal data as a controller in order to provide the Finnkino website, mobile application and associated services (hereinafter also referred to as “services”). We are committed to compliance with applicable legislation in Finnkino’s operations. We collect, store and process your personal data in accordance with the data protection policy described herein.
Mannerheimintie 113, 00280 Helsinki, Finland
When you buy tickets or other products from our web shop, we may process the following personal data provided by you:
This information is mandatory for making purchases on our web shop.
If you join the Finnkino Lab loyalty program, in addition to the personal data processed for web shop customers, we may also process the following data related to the loyalty program:
This information is mandatory, if you wish to join the Finnkino Lab loyalty program.
Subscribers of the Finnkino newsletter
We may process your personal data when you transact on the Finnkino website or in the mobile app, even when you have not logged in to our service. When you go to the Finnkino web site or open the mobile app, we may process the following personal data:
The processing of this data is partly mandatory in order to guarantee the operation of our website and mobile app. You can influence the processing of data collected during browsing by changing your browser settings. For more information on using cookies and other tracking methods, click here.
We may also process information that you provide to the customer service. We may collect and store data related to customer communications and contacts, and information on complaints and customer feedback.
We may process your personal data to develop and manage Finnkino products and services, as well as sales and marketing, and to develop user experiences.
We may combine data collected in connection with different services insofar as the data has been collected for the same purpose, and we may produce statistics to the extent required for the development of products and services. We may use your personal data to create customer profiles for both developing our services and for targeting marketing. We may, for example, combine data collected using cookies with information in your customer account. Your personal data may be profiled in order to personalize our services and to present recommendations and targeted advertising. Our online services may, for example, remember what events you have browsed through so that we can make your next visit even more adapted to your needs by presenting movie showings and other content that are related to your previous visit. We do not perform automated decision-making on the basis of profiling.
We also process your personal data as necessary to prevent and investigate misuse.
We process your personal data to manage your bookings and purchases, to complete payment transactions, and to fulfil other similar obligations. We also process your data in order to offer discounts and benefits, and to investigate complaints, errors and other problems.
We may process the personal data of those who have joined the Finnkino loyalty program to produce services related to the loyalty program, to manage and maintain the customer relationship, for invoicing, remote sales, service usage research and further development of the service, direct marketing, as well as opinion and market research.
We process your personal data to receive and respond to customer feedback. Your personal data is also processed for the purpose of customer communications when we send you notifications on our products and services, and communications which do not contain marketing.
Even if you prohibit direct marketing, we may still send you notifications regarding Finnkino and our services; for example, notify you of fault situations and disruptions in services, as well as contact you for this purpose.
If you have subscribed to our newsletter or provided your consent for receiving direct marketing in electronic format in another connection, or in some cases when you have provided your e-mail address or telephone number to us when purchasing a product or a service and we decide to use the contact information in question for the direct marketing of equivalent products or services, we may process your personal data in the extent permitted by law for the purpose of sending you a newsletter or another direct-marketing message in electronic format.
You have the right to withdraw your consent and prohibit direct marketing at any time. In such cases we will retain information on your direct-marketing prohibition for as long as we process your other personal data.
We process your personal data to make our products and services more personal and more targeted, for example, by making recommendations and showing you targeted content in our services. We may also target marketing efforts according to location data, if you have given your consent for us to process your location data.
Finnkino’s right to process your personal data is partly based on a legitimate interest created by the customer relationship. We will process your data, for example, to sell tickets and to offer Finnkino Lab loyalty program services. Profiling and the targeting of marketing activities also relates to the processing of personal data.
We have weighed up the interests and established that the basic rights and freedoms of data subjects do not override Finnkino’s grounds of legitimate interest to process personal data on the basis of the customer relationship. You have the right to object at any time to the processing of your personal data based on Finnkino’s legitimate interest on grounds relating to your personal particular situation. In such cases, we will assess whether there is a significantly important and justified reason for the processing of your personal data to continue that would override your rights and privileges. You can read more about your rights here.
We will process your personal data in order to enforce an agreement to which you are a party, or in order to implement procedures prior to the agreement, at your request.
We will process the personal data of persons who have joined the Finnkino Lab loyalty program in accordance with the agreement made on the Finnkino Lab membership. Such an agreement is entered into when we provide detailed information to our customers on the binding terms of the Finnkino Lab loyalty program on our website, and the customer registers to be a member of the Finnkino Lab loyalty program.
Also the processing of personal data related to registration to the online service and to purchases made in the web shop will be implemented in accordance with the agreement, insofar as the processing of personal data is necessary in order to implement procedures prior to registration or enforce an agreement regarding the purchasing of tickets or in order to implement procedures prior to the agreement, at your request.
We will process your personal data on the basis of your consent, insofar as you have provided your consent for electronic direct marketing and we will send you the Finnkino newsletter or other electronic direct marketing periodically.
We will also process your personal data collected using cookies in accordance with your consent to store cookies.
When you use our mobile application, we will process your location data, if you have given your consent for us to process your location data.
You have the right to withdraw your consent for the processing of personal data at any time. You can withdraw your consent for electronic direct marketing by notifying our contact person of this or by clicking the cancellation link found at the bottom corner or each direct-marketing message.
We transfer customer segments and profiles combined from personal data in order to implement targeted marketing by third parties on our online service.
We do not disclose your personal data for the direct-marketing purposes of third parties.
In addition, we may also disclose your personal data based on currently applicable law or a mandatory stipulation from the authorities. In the future, we may also disclose your personal data to a prospective buyer or their adviser in connection with mergers and acquisitions.
We will transfer your personal data to selected Finnkino partners in cooperation to whom we have outsourced tasks which involve the processing of personal data. The cooperation partners process your personal data on Finnkino’s behalf on the basis of the cooperation agreement between the parties. In such cases, data processors have no right to process the transferred data on their own behalf or for their own purposes. We transfer your personal data to IT service providers and to financial administration service providers to store and process data in accordance with Finnkino’s instructions for the purposes defined in this description.
We will transfer your personal data outside the EU or EEA where appropriate, when we utilize service providers in third countries. We use agreements to ensure that all our service providers and the subcontractors of our service providers adhere to the requirements set in applicable data protection legislation in connection to the transfer of personal data.
In the transfer of data, we utilize, for example, model contract clauses approved by the European Commission. In addition, some of our service providers located in the United States have committed to the Privacy Shield framework which guarantees a sufficient level of data protection in the relevant enterprises. If you want more information on the Privacy Shield certification, please refer to: https://www.privacyshield.gov/welcome.
We will store your personal data only for as long as it is required with regard to the data processing purposes described under section 3, or in order to fulfil our statutory obligations.
The retaining periods of personal data are determined in accordance with the following grounds:
Instead of erasing your data, we will at times transform it to such a format, that you can no longer be identified on the basis of your data. We will process such anonymized data for the purpose of conducting analyses or research, and in order to develop our business operations, services and products.
You can exercise your rights as a data subject in accordance with the General Data Protection Regulation with the help of these instructions. Additional information and instructions on your rights are available by contacting our contact person.
Without undue delay and at the latest within a month of your contact, we will deliver you the data on the procedures we have undertaken with regard to your requests relating to the implementation of your rights. If you present several requests or if your request is especially complicated, we can continue the prescribed time limit by a maximum of two months, if needed. We will notify you separately of such a delay within a month of your request.
Please note that, where appropriate, we can request that you provide additional information in order to verify your identity.
You have the right to receive verification from Finnkino on whether we process any personal data related to you. You also have the right to access your personal data and to receive information on the processing of personal data in accordance with the General Data Protection Regulation.
We will not provide you access to any data that is confidential or considered Finnkino’s trade secrets, or data that could violate the privacy of another person.
When you exercise your right to access your personal data, we will provide you with a copy of the personal data pertaining to you that we have processed. If you request several copies, we can charge a reasonable fee on the basis of administrative expenses. If you make your request electronically, we will provide you the requested data in a commonly used machine-readable format, unless you request a delivery provided orally or as a hardcopy.
You have the right to request us to rectify or update any inaccurate and incorrect personal data relating to you without any undue delay. We can request that you provide additional clarification, if we need more information, for example, to verify your identity or confirm the validity of any new information you may have provided.
You have the right to make Finnkino delete any personal data regarding you without any undue delay, if:
We will assess your rights and our possibility to erase the data case-specifically. We strive to respect your wishes and your right to have your personal data erased to the extent provided by law.
You have the right to demand that we restrict the processing of your personal data such that in addition to storing the personal data, it can only be processed with your consent or in order to establish, exercise or defend a legal claim or in order to protect another person’s rights, if:
If you have provided your personal data to us yourself, for example, when joining the Finnkino Lab loyalty program, you have the right to obtain the relevant personal data in a structured, commonly used and machine-readable format and the right to transfer the relevant data to another controller, insofar as:
The right to transfer personal data from one system to another is restricted to a method which does not adversely affect the rights or freedoms of others. We do not provide you with or transfer to you or another controller any personal data belonging to other persons or data considered as Finnkino’s trade secrets.
You do not have the right to transfer personal data from one system to another, if the relevant personal data is processed on the basis of Finnkino’s legitimate interest or a statutory obligation.
You have the right to object to the processing of your personal data on grounds relating to your personal particular situation insofar as our processing is based on legitimate interest, if there is no important and justified reason for our processing which would override your rights and freedoms.
In addition, you have the right to object to the processing of your personal data for direct-marketing purposes. You can also object to the profiling we perform for direct-marketing purposes. After you have exercised this right to object, we will no longer send you any direct marketing or process your personal data for such direct-marketing purposes.
You can easily change any settings regarding Finnkino’s communications by using the My Profile menu after you have logged in.
You can send Finnkino a request in order to exercise your data protection rights in accordance with the following instructions:
1. Explain in detail which rights of the data subject regarding personal data you wish to exercise
2. Verify your identity by providing the following information in the message:
a) Indicate the numbers of your last two purchase transactions (refer to instruction below), OR
b) Attach a photograph of both sides of your personal identity card or passport. In addition, attach a photograph of your face next to the photo page of your personal identity card or passport.
The number of the purchase transaction in My Profile:
3. Send your request via e-mail to the address: email@example.com with the heading “Request regarding the processing of personal data”. Send the e-mail message from the same e-mail address that you have used for registering as a customer.
We will respond to customer requests within 30 days of receiving a request compiled in accordance with the instructions above.
You have the right to file a complaint to the Finnish Data Protection Ombudsman or another competent authority, if you consider that your rights on the basis of the General Data Protection Regulation have been violated in the processing of your personal data.
We collect your personal data from you when you complete electronic forms on our website and in our mobile application. We also collect personal data in connection with campaigns and customer service events, and by using social media accounts and cookies.
We also collect and update your personal data and profile with the help of data received from our cooperation partners and from authorities and companies offering services related to personal data, such as the Population register Centre and the credit information register of Suomen Asiakastieto Oy with regard to credit information.
We also collect and update personal data using website cookies and other tracking technology.
We produce and design all our services with privacy and data security in mind. Databases and systems are protected by firewalls, passwords and other technical means against external data breaches. We take proper care of telecommunications security and the risks related to processing personal data, taking into account the likelihood of the risk and the nature of the protected data. We restrict access to personal data strictly to authorized persons with a legitimate need to process the personal data in question.
Our services may include links to third-party websites or services with their own applicable data protection policies. We recommend that you carefully review the privacy policies of such third parties separately. Finnkino is not responsible for the data protection policies or personal data processing of such third parties.
Cookies are used to collect data on, for example, the terminal devices you use and your behavior in our service, including information on the website from which you have landed in our service, the browser you use and when you use it, and what section of the service you have browsed. We use this data, for example, to develop the user comfort of our web service, to analyze user data, to do customer research, to personalize content, as well as for advertising management and targeting communications and marketing.
With our permission, third parties, such as Adform, Frosmo and Hotjar, may place cookies on our website in order to provide us with data or to provide a customized user experience. With our permission, third parties may place cookies on our website in order to target marketing.
We use Google AdWords technology which enables us to perform targeted advertising on the Google Partner network websites for users who have visited our website and shown interest in our offering. When you visit our website, a cookie will be stored on your terminal device so that you can be identified again when you visit an advertising partner’s website.
In addition to this, we will analyze your activities and target advertising accordingly. Data stored in cookies will not be combined with any other personal data included in your user profile. By using this website you give Google your consent to process information collected on you as described above and for the purpose mentioned above.
We use the Google Analytics online analysis software which utilizes so-called cookies, in other words, text files which are stored on your computer, for analyzing how you use the website.
Google uses this information to evaluate your use of a website, to compile reports to the website operator on website traffic, and to offer other service relating to website traffic and use of the Internet.
You can also prevent Google from collecting and processing data (such as your IP address) related to the use of our website collected using cookies by downloading and installing a browser add-on from the following link: http://tools.google.com/dlpage/gaoptout?hl=fi. Please note that this add-on is browser- and computer-specific. More information on Google’s data protection description can be found here: http://www.google.com/intl/fi/policies/privacy/.
We collect personal data via the social media accounts offered by Finnkino’s third parties, when you contact us and transfer from social media services to our website or services.
Our website also includes “community plug-ins” for social media, such as the “Like” and/or “Share” button on Facebook, Twitter or Instagram. Community plug-ins can enable third parties to collect information on the use of our services, if you have logged in to the relevant service. If you are not logged in to our service or if you do not have a user account in the relevant social media service, the relevant third party may only collect limited data on you.
From time to time, we may make some changes to our data protection policy on the basis of, for example, our own methods of operation or in accordance with changes in legislation and practices of interpretation. We recommend that you review our data protection information regularly so that you receive comprehensive information on any changes made.
When we amend our data protection policies, we provide a notification on this on our website.