Security and Privacy Policy

Part 1 – Privacy Policy

Acamar Films Limited (“We“) are committed to protecting and respecting your privacy and the security of your personal data. This policy (together with our terms of use) sets out the basis on which any personal data we collect from you, or that you provide to us, will be used by us.

This policy applies to: (i) use of the websites owned and operated by Us (at https://uk.bingbunny.com/ or www.bingbunny.co.uk or www.bingbunny.com and their subdomains) (“the Site”) and use of Our Bing mobile application (“the Bing App”); (ii) our marketing activities, including newsletters, emails, competitions, and any other product or activity that links to, or otherwise references, this policy (collectively, with the Site and the Bing App, the “Bing Products“). Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting or using the Bing Products you are accepting and consenting to the practices described in this policy.

  1. DATA CONTROLLER

For the purpose of the General Data Protection Regulation, the data controller is Acamar Films Limited, a company registered in England and Wales under company number 04399568, registered address is at 7 Savoy Court, London, United Kingdom, WC2R 0EX).

If you have any questions or concerns about this policy, the information we collect about you or our personal data processing activities in connection with your dealings with the Bing Products, please contact our Data Protection Officer: General Counsel at Acamar Films Limited, at webmaster@acamarfilms.com.

You can also contact us through physical mail to Acamar Films Limited, The Rotunda (Ground Floor), 42-23 Gloucester Crescent, London NW1 7DL, United Kingdom, to the attention of our General Counsel.

Information on data protection generally is also on the Information Commissioner’s website at www.ico.gov.uk or at the official website of the European Union: https://ec.europa.eu/info/law/law-topic/data-protection_en.

  1. INFORMATION WE COLLECT ABOUT YOU

We will collect and process the following data about you:

Information you give us. This is information about you that you voluntarily give and share with us by filling in the form or field on the Site or Bing App, by any other communication (e.g. email, phone, mail etc.) or when you request to receive certain content that we may make available through the Bing Products. It includes information you provide when you register to sign up to our email newsletter and when you report a problem with our Site or Bing App or download content from the Site or the Bing App. The information you give us may include your name and email address as well as any other content that you provide through the above communication channels.

Information we collect about you. With regard to your use of the Bing Products we will automatically collect the following information:

  • Technical information, for example: IP address, browser type, operating system version, device type, device model, orientation of device, app version, disk space left on device and other similar technical information typically received from a browser or device automatically when visiting or interacting with Internet and mobile products.
  • Usage information, for example: the pages you visited on the Bing Products, where you clicked, searches performed on the Bing Products, time and date of incidents, error report of incidents, which subscription has been purchased, success / failure of payment and other similar information related to how you have used the Bing Products. It may also include information related to whether you received, opened or clicked on any links in an email sent to you.

Certain technical information or usage information may, either alone or when combined with other data, be deemed personal data under data protection laws and we are committed to treating such data in compliance with them.

The technical and usage information is collected by Us through use of cookies and other similar technologies (e.g. pixels, web beacons, JavaScript, etc.). These technologies help us to analyse how the Bing Products are used and to tailor content of the Bing Products that is relevant to you. However, we are not tracking any payment details through this technology. For more information on such technologies, including how to manage your cookie preferences please see our Cookie Policy below.

Sometimes we can also obtain the above information from third party sources, such as the various business support tools and services offered by third party providers that We use (e.g. Crashlytics and Firebase analytics services offered by Google companies).

  1. HOW WE MAKE USE OF THE INFORMATION

It is important that you understand how and why we use the personal data that we collect about you. This section sets out the different purposes for which we process personal data and which types of personal data we need for each purpose.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • to perform our contract with you if you subscribe to the Bing App;
  • to process your inquiries and to respond to your requests;
  • in order to manage your subscription to the Bing newsletter;
  • to provide you with offers relating to Bing Products and additional marketing materials;
  • where we need to comply with a legal obligation;
  • where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

We may also use your personal information in the following situations, which are likely to be rare:

  • where we need to protect your interests (or someone else’s interests).
  • where it is needed in the public interest or for official purposes.

In some cases we may use your personal information to pursue legitimate interests of Our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information based on legitimate interests are listed below:

  • to optimise and improve the performance and content on the Bing Products;
  • to provide you with information about the Bing Products that might include marketing and promotional activities in relation to the Bing Products;
  • to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you;
  • to notify you about changes to the Bing Products;
  • to ensure that content from the Bing Products is presented in the most effective manner for you and for your computer;
  • to prevent fraud or harm to Us or to any third party, and ensure the security of the Bing Products and Our network;
  • where it is necessary to enforce Our rights, for example enforce the claims We may have against you in connection with your use of the Bing Products.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  1. SHARING YOUR INFORMATION WITH THIRD PARTIES

We may have to share your data with third parties, including third-party service providers. We require third parties to respect the security of your data and to treat it in accordance with the law.

  • Selected third parties including:
    • business partners and service providers who help manage our IT and communications in order to tailor marketing and advertising and host the Bing App and Site; and
    • analytics and search engine providers that assist us in the improvement and optimisation of the Bing Products.

We will also disclose your personal data to third parties:

  • In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
  • If Acamar Films Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply terms and conditions of sale and other agreements; or to protect the rights, property, or safety of Acamar Films Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
  1. WHERE WE STORE YOUR PERSONAL DATA

We may store your personal data on our own servers as well as those operated by third party data hosting providers. All information you provide to Us is currently processed and stored by Our data processor: Mail Chimp, a Georgia limited liability company whose legal name is The Rocket Science Group LLC d/b/a Mailchimp, based in the US, who manage our subscriber database and process the newsletter mailouts on behalf of Acamar Films Limited. Mail Chimp’s privacy policy can be found here: https://mailchimp.com/legal/privacy/.

  1. TRANSFERRING INFORMATION OUTSIDE THE EEA

We may transfer your personal information to Our services providers outside the EU. If we do, you can expect a similar degree of protection in respect of your personal data as is required in the territory of the European Union.

Mail Chimp are based in the US, however we transfer data to them as they are signatories to the EU Privacy Shield framework which requires them to provide similar protection to personal data shared between Europe and the US.

You can find more information about the EU Privacy Shield framework at https://www.privacyshield.gov/welcome, at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/eu-us-data-transfers_en and https://ico.org.uk/make-a-complaint/eu-us-privacy-shield/.

  1. SECURITY

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.  This includes secure socket layer (SSL) technology to ensure your details are safe and information you provide is fully encrypted so that it cannot be read by third parties.

In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

  1. HOW LONG WE RETAIN YOUR PERSONAL DATA

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for and specified in section 3 of this policy.

When We use your personal data for direct marketing purposes, We will retain your data until you opt-out from receiving the marketing materials in accordance with data protection laws, provided that we will need to retain certain information to maintain a record of your request. We may also retain your personal data for such time that is required to pursue Our legal claims and compliance with our legal obligations (such as tax and accounting obligations).

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

  1. YOUR RIGHTS OF ACCESS, CORRECTION, ERASURE AND RESTRICTION
  • Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data that you voluntarily share with us changes at any point in the future.

  • Your rights in connection with personal information

Under certain circumstances, by law you have the right to:

  • Request access to your personal information(commonly known as a “data subject access request“). This enables you to receive a copy of the personal information We hold about you and to check that We are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information We hold about you corrected.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for Us continuing to process it. You also have the right to ask Us to delete or remove your personal information where you have exercised your right to object to processing (see below).
  • Object to processing of your personal information where We are relying on a legitimate interest(or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where We are processing your personal information for direct marketing purposes.
  • Request the restriction of processing of your personal information. This enables you to ask Us to suspend the processing of personal information about you, for example if you want Us to establish its accuracy or the reason for processing it.
  • Request the transfer of your personal information to another party.
  • File a complaint with the data protection authority that supervises our personal data processing activities. Since We are a company with a registered office in the United Kingdom, our processing activities are supervised by the Information Commissioner’s Office (“the ICO”). More information on the ICO’s, including instructions on making a complaint, is available at: https://ico.org.uk/.

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact Our Data Protection Officer via email to: webmaster@bingbunny.com.

  • No fee usually required

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

  • What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

  • Right to withdraw consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact webmaster@bingbunny.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

  1. THIRD PARTY WEBSITES

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

  1. AUTOMATED DECISION-MAKING/ PROFILING

Automated decision-making or profiling takes place when an electronic system uses personal information to make a decision without human intervention. We are allowed to use automated decision-making in the following circumstances:

  • Where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights.
  • In limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights.

We use information we have about you to tailor the content of communications that are sent to you to try to ensure that the offers are as relevant to you as possible and so you have exclusive access to the best deals.

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.

  1. CHILDREN UNDER 16

We are concerned to protect the privacy of children aged 16 or under. We do not knowingly collect or process personal data from or with respect to children aged 16 or under, and you must be 16 years of age or older in order to use the Bing Products and make purchase through the Bing App. The Bing App has parent gating to get to an adult section and/or to link out of the Bing App.

If you are aged 16 or under‚ please get your parent/guardian’s permission beforehand whenever you provide us with personal information.

If you are a parent or legal guardian and believe that your child aged 16 or under has submitted his or her personal data or other data without your consent, permission, or authorization – please let Us know immediately, and We will promptly act to remove your child’s data from our database.

  1. CHANGES TO OUR POLICY

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

Part 2 – Cookie Policy

  1. OUR USE OF COOKIES

A cookie is a text-only string of information that a website transfers to the cookie file of the browser on your computer’s hard disk so that the website can remember who you are. A cookie will typically contain the name of the domain from which the cookie has come, the “lifetime” of the cookie, and a value, usually a randomly generated unique number.

Two types of cookies are used on the Site depending on the cookie owner:

  1. First-party cookies – these are cookies that contain the same domain on which the cookie is placed, i.e. We place an bingbunny.co.uk cookie on bingbunny.co.uk website;
  2. Third-party cookies – there are cookies that contain a domain that is different to the domain on which it is placed, i.e. these are cookies used by Our providers or other parties (such as ad providers) on our domain (e.g. google.com cookies places on bingbunny.co.uk website).

 

These cookies can also be categorised from their purpose of use perspective:

  1. Strictly necessary cookies: these are cookies that enable core functionality of the Site, such as: security, network management, and accessibility. You may disable these cookies by changing your browser settings, but this may affect how the Site functions.
  2. Optional cookies:
    • Performance and analytical cookies that help us:
      1. to measure and improve the performance of the Site;
      2. to improve the Site by collecting and reporting information on how you use it;
      3. to provide enhanced functionality and personalization of the Site by helping a website to arrange content to match your preferred interests more quickly;
      4. to help us recognise you as a unique visitor (just a number) when you return to the Site and to allow us to tailor content or advertisements to match your preferred interests or to avoid showing you the same adverts repeatedly;
      5. to compile anonymous, aggregated statistics that allow us to understand how users use the Site and to help us improve the structure of our website. We cannot identify you personally in this way;
      6. within research surveys to ensure you are not invited to complete a questionnaire too often or after you have already done so.
    • Targeting/advertisement cookies that are dropped on the Site when you use it by third party marketing and advertising networks to build a profile of your interests and show you relevant advertisements on other websites.

 

Taking into account the lifetime of the cookie, these can be divided into two categories:

    • Session Cookies: which are temporary cookies that remain in the cookie file of your browser until you leave the Site to allow you to carry information across pages of our Site and avoid having to re-enter information. Session cookies retain data for approximately 1 hour.
    • Persistent cookies: which remain in the cookie file of your browser for much longer (though how long will depend on the lifetime of the specific cookie).

Most major websites use cookies. Cookies cannot be used by themselves to identify you.

  1. WHAT COOKIES EXACTLY DO WE USE AND WHY?

  1. DISABLING/ENABLING COOKIES

You have the ability to accept or decline cookies by modifying the settings in your browser.

We also attach below a list of help links for major Web browsers where you can change your cookie settings:

You may also refuse the use of optional cookies by using the tool that we provide via cookie banner on the Site by leaving the small checkbox next to Optional cookies empty.

You can change your cookie setting anytime. However, you may not be able to use all the interactive features of the Site if cookies are disabled.

  1. FURTHER INFORMATION

For more information about how cookies are used on our Website and about your rights, please contact us at webmaster@acamarfilms.com.

Acamar 02/09/2020

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