DATA PROTECTION NOTICE OF FINNKINO

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.

 

DATA PROCESSING IN A NUTSHELL

  • We may collect your personal data when you transact in one of our service locations or via our online or mobile services. Your personal data is processed when you register in the Finnkino Lab program, buy movie tickets, subscribe to our newsletter, participate in a marketing campaign or questionnaire, provide feedback to us or contact our customer service.
  • The data we collect may be data that you yourself provide when logging in or participating in a campaign, or data that is saved while you use our services (such as cookies, location data and IP addresses).
  • We may process your data for the purpose of implementing our services and designing new experiences. The processing of collected data helps us in analyzing our customers’ preferences and wishes.
  • We may combine the data we have collected and create profiles for personalizing our services and marketing.
  • To the extent permitted by law, on the basis of your consent or customer relationship, we will send you direct-marketing messages in digital format and process your personal data to target marketing according to your areas of interest.
  • We utilize customer segments analyzed and profiled from personal data in order to implement targeted marketing of third parties on our website.
  • We respect your privacy in all the processing of data we perform. Whenever possible, we will process pseudonymized data and segment data. We do not process data which can be directly connected to you, unless it is necessary in order to implement the purposes of the processing.
  • You can also influence the way we process your data. We will explain you here your rights as a data subject and how you can exercise these rights.
  • Finnkino’s products and services are typically intended for all audiences. However, Finnkino does not knowingly collect the personal data of children under the age of 15 without the consent of their parents or guardians.

 

  1. CONTACT INFORMATION
  2. WHAT TYPE OF PERSONAL DATA DO WE PROCESS?
  3. FOR WHAT PURPOSES DO WE PROCESS PERSONAL DATA?
  4. WHAT GIVES US THE RIGHT TO PROCESS YOUR PERSONAL DATA?
  5. DO WE DISCLOSE YOUR PERSONAL DATA?
  6. WILL WE TRANSFER YOUR PERSONAL DATA TO A THIRD COUNTRY?
  7. FOR HOW LONG WILL WE STORE YOUR PERSONAL DATA?
  8. RIGHTS OF THE DATA SUBJECT: HOW CAN YOU INFLUENCE THE WAY WE PROCESS YOUR PERSONAL DATA?
  9. THIS IS HOW YOU CAN EXERCISE YOUR DATA PROTECTION RIGHTS
  10. THE RIGHT TO FILE A COMPLAINT TO THE SUPERVISORY AUTHORITIES
  11. FROM WHERE DO WE COLLECT THE PERSONAL DATA?
  12. SECURITY OF PROCESSING PERSONAL DATA: HOW DO WE PROTECT YOUR PERSONAL DATA?
  13. COOKIES AND USER TRACKING
  14. SOCIAL MEDIA
  15. CHANGES TO FINNKINO’S DATA PROTECTION POLICY

 

1 CONTACT INFORMATION

Finnkino Oy
tietosuoja@finnkino.fi
Mannerheimintie 113, 00280 Helsinki, Finland

2 WHAT TYPE OF PERSONAL DATA DO WE PROCESS?

Web shop

When you buy tickets or other products from our web shop, we may process the following personal data provided by you:

  • User ID and password created during registration
  • Information on your purchase transactions
  • Account information, credit card information and payment data
  • Invoicing and collection information
  • Information on using Finnair Plus points, the S-Etukortti card, Plussa benefits or the Veikkaus card in our web shop
  • Information on utilized discounts and benefits and other possible special cases, such as reserving a wheelchair seat
  • Information on bookings and cancellations and compensation paid on the basis of error situations
  • Information on the customer segment and your profile
  • Information on your language selections and other equivalent choices.

This information is mandatory for making purchases on our web shop.

Finnkino Lab

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:

  • Information on the customer profile you have created (user ID and password and the date when you joined the loyalty program)
  • Information on a marketing permission or prohibition
  • Ordering and purchasing behavior data
  • Information on customer type (e.g. pensioner, conscript or student)
  • Information on benefits and campaigns that you have participated in or that you have utilized via the loyalty program
  • Delivery data for products and services

This information is mandatory, if you wish to join the Finnkino Lab loyalty program.

Subscribers of the Finnkino newsletter

  • Information on your consent, such as the date and method of the consent
  • Contact information
  • Information on whether you have opened newsletters and which links you have clicked

Website

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:

  • IP address
  • Time of browsing
  • The website from where you land on our website and the website you go to next
  • Which links or advertisements you click on and what advertisements or other content you have viewed
  • The duration of your session
  • The type of your browser (such as Firefox or Google Chrome) or application or other equivalent information
  • Data that is profiled or derived through website analytics
  • Location 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.

3 FOR WHAT PURPOSES DO WE PROCESS PERSONAL DATA?

3.1 Developing Finnkino’s services and sales, including profiling

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.

3.2 Implementing web shop purchases

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.

3.3 Promoting the Finnkino Lab loyalty program

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.

3.4 Customer communications and direct marketing

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.

3.5 Targeted marketing

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.

4 WHAT GIVES US THE RIGHT TO PROCESS YOUR PERSONAL DATA?

4.1 Legitimate interest

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.

4.2 Agreement

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.

4.3 Consent

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.

5 DO WE DISCLOSE YOUR PERSONAL DATA?

5.1 Marketing purposes

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.

5.2 Statutory disclosure and executive regulations

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.

5.3. Outsourced processing of personal data

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.

6 WILL WE TRANSFER YOUR PERSONAL DATA TO A THIRD COUNTRY?

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.

7 FOR HOW LONG WILL WE STORE YOUR PERSONAL DATA?

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:

  • If you have not logged in to Finnkino’s web shop or your Finnkino Lab customer account for the past twenty-four (24) months, we will request you to renew your access rights. If you do not respond to our request, we will consider the customer relationship to have expired.
  • If you have made purchases in our web shop without logging in to our service, we will retain your personal data for twelve (12) months, after which the data will be retained for as long as it is necessary in order to fulfil our statutory obligations with regard to consumer protection and accounting.
  • If you have subscribed to our newsletter or otherwise provided your consent to receiving direct-marketing messages, we will store your personal data for as long as the newsletter subscription is valid. If you cancel your newsletter subscription, in other words, withdraw your consent to receive direct marketing, we will without delay cease delivering the newsletter to you, but will retain information on the marketing prohibition after the cancellation for as long as your personal data is processed for other purposes, such as making web shop purchases or on the basis of your Finnkino Lab customer relationship.
  • If you have participated in a draw or campaign organized by Finnkino, but you have no other connection to us, for example, on the basis of a customer relationship or a marketing permission, we will store your personal data for one (1) year after the end of such a campaign, unless our statutory obligations require a longer retaining period.

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.

8 RIGHTS OF THE DATA SUBJECT: HOW CAN YOU INFLUENCE THE WAY WE PROCESS YOUR PERSONAL DATA?

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.

8.1 The right to request access to personal data

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.

8.2 The right to rectify personal data

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.

8.3 The right to request the erasure of personal data

You have the right to make Finnkino delete any personal data regarding you without any undue delay, if:

  • the personal data is no longer needed for the purposes for which it was collected or for the purpose it was otherwise processed (if, for example, you are no longer a customer and the latest ticket purchases or other customer transactions were made several years ago);
  • you object to the processing of your personal data on grounds relating to your personal particular situation and there is no justified reason for the data processing, or you object to the use of your personal data for direct-marketing purposes;
  • Finnkino has processed your personal data unlawfully; or
  • the personal data must be erased in order to observe a statutory obligation applied to Finnkino.

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.

8.4 The right to request the restriction of the processing of personal data

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:

  • you deny the validity of your personal data, in which case we will restrict the processing of the personal data for the duration of the confirmation of validity;
  • we process your data unlawfully, and you object to the erasure of the personal data and, instead, insist on restriction of the processing of the personal data;
  • Finnkino no longer needs the personal data for the purpose of processing the data and we would otherwise erase or anonymize your data, but you need the data in order to establish, exercise or defend a legal claim; or
  • you have objected to the processing of your personal data on grounds relating to your personal particular situation and you are waiting to hear whether the legitimate interest of Finnkino will override the grounds of your objection.

8.5 The right to data portability from one system to another

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:

  • we perform automated processing of personal data; and
  • the processing is based on your consent (such as with a newsletter subscription) or the processing of personal data is required in order to enforce an agreement, for example, the Finnkino Lab loyalty program agreement or a web shop agreement.

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.

8.6 The right to object to the processing of personal data

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.

9 This is how you can exercise your data protection rights

9.1 Changes regarding communications and cancelling a newsletter subscription

You can easily change any settings regarding Finnkino’s communications by using the My Profile menu after you have logged in.

9.2 Exercising the data subject’s data protection rights

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:

  • name
  • e-mail
  • address information
  • date of birth
  • and EITHER

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:

  • Log in to My Profile
  • Select the My Transactions tab where you can view all the purchases you have made
  • Open the purchase using the Open button and the purchase number can be viewed at the top of the purchase data

3. Send your request via e-mail to the address: asiakaspalvelu@finnkino.fi 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.

10 THE RIGHT TO FILE A COMPLAINT TO THE SUPERVISORY AUTHORITIES

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.

11 FROM WHERE DO WE COLLECT THE 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.

12 SECURITY OF PROCESSING PERSONAL DATA: HOW DO WE PROTECT YOUR PERSONAL DATA?

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.

13 COOKIES AND USER TRACKING

13.1 Cookies

We use cookies and other similar technologies on our website to serve our customers to the best of our ability. A cookie is a small text file that can be delivered to the terminal device when you visit our website. We use cookies to enable the functionalities of our web service, such as logging in and implementation of the shopping cart feature.

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.

13.2 How can you prohibit the use of cookies?

You have the option of preventing the use of cookies in whole or in part at any time by changing your browser settings. You can also choose to delete previously stored cookies. However, please note that preventing the use of cookies may affect the use of some parts or functions of our website and services, or even block their use altogether.

13.3 Google AdWords and Google Analytics

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/.

14 SOCIAL MEDIA

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.

For more information on these types of community services, please refer to the terms of use in each service. Information on Facebook’s data protection can be found here, Twitter’s data protection information here, and for Instagram, the data can be found here.

15 CHANGES TO FINNKINO’S DATA PROTECTION POLICY

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.