1. OVERVIEW

Glasgow Film At Home is the on demand platform owned and operated by Glasgow Film.

Glasgow Film (referred to as either “The Company”, “we”, “us” or “our”) is the controller of your personal data (for the purposes of the General Data Protection Regulation).

We are committed to respecting your privacy and protecting your personal data. We respect your privacy.

Your use of the Platform is subject to our Privacy Policy

This policy is subject to General Data Protection Regulation (GDPR.) Government guidance on GDPR can be found here.

Further GDPR guidance from Glasgow Film can be found here.


2. THE INFORMATION WE COLLECT

Personal Data
For the purposes of our uses, Personal Data is information about an individual from which that individual is directly identified or can be identified. It does not include anonymous data (that is, information where the identity of an individual has been permanently removed.) However, it does include indirect identifiers or pseudonymous data (that is, information which alone does not identify and individual but, when combined with certain additional and reasonably accessible information, could be attributed to a particular person.)

All the Personal Data we collect, both from you and from third parties about you, is outlined below:

  1. Identity data: First name, surname, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender.
  2. Contact data: Your home address, work address (for corporate customers, schools and suppliers), billing address, email address, telephone numbers.
  3. Financial data: Your bank account and payment card details.
  4. Transaction data: Any details about payments to and from you and other details of subscriptions and services you have purchased from us. Data in respect of your transactions with third parties (including your credit history).
  5. Marketing data: Your preferences in receiving marketing from us and our third parties and your communication preferences. Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of purchasing products (such as booking confirmation emails).
  6. Behavioural data: Inferred or assumed information relating to your behaviour and interests, based on your online activity. This is most often collated and grouped into “segments” (for example, there may be a segment for women, who like films from a particular country).
  7. Technical data: Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website or use our services.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). We do not collect any information about criminal convictions and offences.

Gender and date of birth do not fall under these Special Categories.


Aggregated Data
We also collect, use and share Aggregated Data such as statistical or demographic. Aggregated Data may be derived from your Personal Data, but once in aggregated form it will not constitute considered Personal Data for the purposes of the GDPR as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.


Personal Data from Third Party Sources
In addition to the Personal Data that we collect directly from you (as described), we also collect certain of your Personal Data from third party sources. Further details of this can be found below in Section 10, Third Party Services .


3. OUR BASIS FOR PROCESSING YOUR PERSONAL DATA

In respect of each of the purposes for which we use your Personal Data as outlined above (identity data, contact data, financial data, transaction data, marketing data, behavioural and technical data) the GDPR requires us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases:

Generally we do not rely on your consent as a legal basis for using your Personal Data other than in the context of direct marketing communications.


4. How You Can Access and Correct Your Information

You can access all your personally identifiable information that we collect online and maintain by visiting your Account Settings page. We use this procedure to better safeguard your information.
You can correct factual errors in your personally identifiable information by sending us a request that credibly shows error.
To protect your privacy and security, we will also take reasonable steps to verify your identity before granting access or making corrections.


5. COOKIES

We use two broad categories of cookies; first party cookies, served directly by us to your computer or mobile device, and third party cookies, which are served by service providers on our Site, e.g. embedded Youtube videos.

Glasgow Film At Home uses the following types of cookies for the purposes set out below:

  1. Essential cookies: These cookies are essential to provide you with services available through our site and to enable you to use some of its features. For example, they allow you to log in to secure areas of our site and help the content of the pages you request to load quickly. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
  2. Functionality Cookies: These cookies allow our site to remember choices you make when you use our site, such as remembering your login details and remembering the changes you make to other parts of our site which you can customise. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our site.
  3. Analytics cookies: These cookies are used to collect information about traffic to our site and how users use our site. The information gathered via these cookies does not directly identify any individual visitor. However, it may render such visitors _indirectly _identifiable. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our site. The information collected is aggregated and anonymous. It includes the number of visitors to our site, the websites that referred them to our site, the pages they visited on our site, what time of day they visited our site, whether they have visited our site before, and other similar information. We use this information to help operate our site more efficiently, to gather broad demographic information and to monitor the level of activity on our site.

If you do not accept our cookies, you may experience some inconvenience in your use of our site. For example, we may not be able to recognise your computer or mobile device and you may need to log in every time you visit our site.


6. WHO WE SHARE YOUR DATA WITH

We may share your Personal Data with the below third parties. Listed is who we may share your personal data with and why we share it:

  1. Service providers: Our service providers maintain and supply our IT and system administration services.
  2. Professional advisors: Our auditors, lawyers, bankers and insurers provide accounting, consultancy, banking, legal and insurance services.
  3. HM Revenue & Customs, regulators and other authorities: Authorities may require reporting of processing activities in certain circumstances


7. OUR COMMITMENT TO DATA SECURITY

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.

We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.

We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (for example, where we are legally required to do so) we may notify you of breaches affecting your Personal Data.

To prevent unauthorised access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online.


8. HOW LONG WE STORE YOUR PERSONAL DATA

We will only retain your Personal Data for so long as we reasonably need to use it for unless a longer retention period is required by (for example for regulatory purposes).


9. OUR POLICY ON CHILDREN

This website is not intended for anyone below the age of 18 and we do not knowingly collect data relating to such people.


10. THIRD PARTY SERVICES

Presently, Glasgow Film at Home works with two third parties which handle Personal Data from outwith the European Economic Area (being the European Union plus Norway, Liechtenstein and Iceland) (“Europe”). These are MailChimp and Mandrill, based in the United States, which are the platforms we use to send welcome emails, receipt of purchase, forgotten password emails, promotional emails and e-newsletters to customers. Our use of their service does mean that email information will at times be sitting on servers outside of the EEA. We have appropriate contracts in place with these organisations to ensure your information is stored securely and used appropriately.

Google Analytics
We use Google Analytics to help us to understand how you use our site and tools, which allows us to know how to improve our products for your benefit. It follows your progress through the website, collecting anonymous data on where you have come from, which pages you visit, and how long you spend on the site. Google then stores this data in order to create reports. But don’t worry; they do not store your personal data. Google will track your IP address, and it may be transmitted to and stored by Google on servers in the United States. Google may use this information for the purpose of evaluating your use of the website, compiling reports on website activity for us, and providing other services relating to website activity and Internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. For more information on Google’s privacy policies, please click here. Google Analytics services are governed by the Google Analytics Terms of Service which can be found here.

Intercom
We use third-party analytics services to help understand your usage of our services. In particular, we provide a limited amount of your information (such as sign-up date and some personal information like your email address) to Intercom, Inc. (“Intercom”) and utilise Intercom to collect data for analytics purposes when you visit our website or use our product. As a data processor acting on our behalf, Intercom analyses your use of our website and/or product and tracks our relationship by way of cookies and similar technologies so that we can improve our service to you. For more information on Intercom’s use of cookies, please click here. We may also use Intercom as a medium for communications, either through email, or through messages within our product(s). For more information on the privacy practices of Intercom, please click here. Intercom’s services are governed by Intercom’s terms of use which can be found here.

Mandrill and Mailchimp
We use Mandrill to send transactional emails, such as a welcome email, purchase receipt, or forgot password email. We provide a limited amount of your information, such as your email address, to The Rocket Science Group LLC, who operate Mailchimp and Mandrill. We utilise Mandrill to collect data for analytics purposes when you view the email. We use Mailchimp to send tailored communications relating to your viewing habits. For more information on the privacy practices of Mandrill, please click here. Mandrill’s services are governed by Mailchimp’s terms of use which can be found here.

Amazon Web Services
We use Amazon Web Services (AWS) who provide us with cloud storage solution. AWS has demonstrated compliance with a range of internationally recognised standards for content, data and infrastructure security, such as information security management system- ISO-27001, System and Organization Controls Report- SOC1/2, and The Payment Card Industry Data Security Standard; in addition, AWS has demonstrated alignment with the MPAA Content Security Best Practices and the AWS infrastructure is compliant with all applicable MPAA controls. For more information on AWS’ privacy policy please click here.

Stripe
We use a third party payment processor, Stripe, to process payments made to us. In connection with the processing of such payments, we do not retain any personally identifiable information or any financial information such as credit card numbers. Rather, all such information is provided directly to our third party processor, Stripe, whose use of your personal information is governed by their privacy policy, which may be viewed here. Stripe is certified to PCI Service Provider Level 1, the most stringent level of certification.


11. THIRD PARTY LINKS

This Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share your Personal Data. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every site you visit.