Privacy Policy

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Welcome to Cinobo 👋

1. Who we are

At Cinobo, we respect your privacy and are committed to protecting your personal data. We understand that when you use the Cinobo Service, you trust us with information about you, and we take that responsibility seriously. Cinobo is made up of different companies. The Cinobo company that provides you with our services is responsible for processing your personal data in connection with those services.

In this Privacy Notice (‘Notice’), the Cinobo companies are referred to as ‘Cinobo’, ‘we’, ‘us’ or ‘our’. You can find their full details in Schedule 1.

This Notice explains how we collect, use, share, store and otherwise process your personal data when you visit our website, create an account, subscribe to the Cinobo Service, watch content on our platform, contact us, or otherwise interact with Cinobo.

We aim to provide clear information about:

• what personal data we collect;
• how and why we use it;
• the legal grounds on which we process it;
• who we may share it with;
• how long we retain it;
• the safeguards we apply to protect it; and
• the rights available to you under applicable data protection laws.

We process personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (‘GDPR’), applicable national data protection laws, and other relevant requirements.

2. Getting in touch

Please read this Privacy Notice. If you have any questions about how we process your personal data or wish to exercise your privacy rights, you can contact us:

• by post using the relevant company address provided in Schedule 1; or
• by email at gdpr@cinobo.com.

For information about what cookies are and how we use them, please read our Cookie Notice.

3. What personal data we collect and how we use It

To provide the Cinobo Service, we collect and process different categories of personal data depending on how you interact with Cinobo. This may include information you provide directly to us, information generated through your use of the Cinobo Service, and certain technical information collected when you access our website or applications.

We may also receive personal data from third parties involved in providing or promoting the Cinobo Service, such as payment providers, social-media and advertising platforms, business partners and other service providers. The information received depends on the relevant service or interaction and may include account, transaction, subscription, engagement or technical information.

In a nutshell, the categories of personal data we process generally include account and registration information, subscription and billing information, viewing activity and user preferences, technical and device information, customer support communications and marketing preferences.

We process this information for a number of purposes, including providing and managing your Cinobo account, delivering the Cinobo Service, processing subscriptions and payments, personalising your experience, ensuring the security and proper functioning of our platform, responding to your enquiries, complying with legal obligations, and, where permitted, communicating with you about Cinobo's services and updates.

The table below provides an overview of the main categories of personal data we process, the purposes for which we use them, and the legal basis on which we rely.

Table - Overview of Personal Data Processing

Certain personal data is required in order to create and maintain a Cinobo account and to provide the Cinobo Service. If you choose not to provide such information, we may be unable to provide some or all of the Cinobo Service.

Information that you choose to include in your public profile, reviews, lists and other Community Features may be displayed publicly on the Cinobo website and platform. Please do not include information that you do not want to make public.

We do not ask you to provide special categories of personal data, such as information concerning your health, racial or ethnic origin, political opinions, religious or philosophical beliefs or sexual orientation. You may nevertheless choose to disclose such information through communications or content you submit to Cinobo. Where this occurs, we process it only where permitted by applicable law.

A Cinobo subscription and account may only be created by an adult. Children may use the Cinobo Service under the supervision of the account holder and subject to the controls and conditions described in our Terms and Conditions. We process children’s personal data only where permitted by applicable law and, where required, with appropriate parental or guardian involvement.

4. How long we keep your personal data

We retain your personal data for as long as your Cinobo account remains active and for as long as necessary to provide the Cinobo Service to you. In certain circumstances, we may retain personal data for a longer period where this is necessary to comply with applicable legal, regulatory, tax, accounting or reporting obligations, resolve disputes, enforce our agreements, or protect our legal rights. When personal data is no longer required for these purposes, we will securely delete or anonymise it in accordance with our retention practices.

5. Who we share your personal data with

We may share your personal data with the following categories of recipients where necessary to provide the Cinobo Service, operate our business, comply with legal obligations, or protect our rights and interests.

Service providers

We work with trusted third-party service providers who support the operation of the Cinobo Service. Some of these providers process personal data on our behalf and in accordance with our instructions. Others may process personal data for purposes determined by them, as described in their own privacy notices.

Categories of providers include:

• cloud hosting and infrastructure services;
• payment processing services;
• customer support tools and services;
• analytics and performance monitoring services;
• email and communication services;
• security and fraud prevention services.

Cinobo companies

Other Cinobo companies listed in Schedule 1, where necessary to provide the Cinobo Service, including platform operation, billing and customer support.

Business and corporate transactions

We may disclose or transfer personal data in connection with a merger, acquisition, restructuring or sale of all or part of our business, subject to appropriate confidentiality and security measures.

Social media and advertising providers

We may work with social media platforms and advertising providers to promote the Cinobo Service, measure the effectiveness of our marketing activities, and communicate with existing and prospective users.

For these purposes, we may share limited personal data with such providers, including your name, email address, subscriber status (where relevant) and information about your interactions with our communications and the Cinobo Service.

We may use these providers to measure the effectiveness of our marketing activities, avoid displaying advertisements for services you already use, and help us reach audiences that may be interested in the Cinobo Service.

Where permitted by applicable law, this processing is based on our legitimate interests (Article 6(1)(f) GDPR) in promoting and improving the Cinobo Service and ensuring that our marketing activities are effective and relevant.

You may object to this processing at any time by contacting us at gdpr@cinobo.com.

Legal and regulatory disclosures

We may disclose personal data where required to do so by applicable law, regulation, court order, legal process or governmental request.

We may also disclose personal data where necessary to establish, exercise or defend legal claims, protect the security and integrity of the Cinobo Service, investigate unlawful activity, or protect the rights, property or safety of Cinobo, our users or others.

We do not sell your personal data to third parties.

6. International transfers of personal data

Some of the service providers we use may be located outside the European Economic Area ('EEA'), or may process personal data from locations outside the EEA.

Whenever personal data is transferred outside the EEA, we ensure that appropriate safeguards are in place in accordance with applicable data protection laws. Depending on the circumstances, these safeguards may include:

• transfers to countries that have been recognised by the European Commission as providing an adequate level of data protection;
• the use of Standard Contractual Clauses (‘SCCs’) approved by the European Commission; or
• other lawful transfer mechanisms recognised under applicable data protection laws.

We take appropriate contractual, technical and organisational measures to protect personal data when it is transferred internationally.

7. Your rights

Under applicable data protection laws, including the GDPR, you have the following rights in relation to your personal data:

• Right of Access – You can request confirmation of whether we process your personal data and obtain a copy of the personal data we hold about you.
• Right to Rectification – You can request that we correct inaccurate or incomplete personal data.
• Right to Erasure – You can request that we delete your personal data in certain circumstances.
• Right to Restriction of Processing – You can request that we temporarily restrict the processing of your personal data in certain circumstances.
• Right to Data Portability – You can request a copy of certain personal data in a structured, commonly used and machine-readable format and, where technically feasible, have it transferred to another service provider.
• Right to Object – You can object to certain types of processing, including processing based on our legitimate interests and processing carried out for direct marketing purposes.
• Right to Lodge a Complaint – If you believe that we have processed your personal data in violation of applicable law, you have the right to lodge a complaint with the competent data protection authority.

To exercise any of your rights, please contact us at gdpr@cinobo.com. Where necessary we may request additional information to verify your identity before responding to your request.

8. Changes

We may update this Privacy Notice from time to time to reflect changes to our processing activities or applicable law. Where required, we will notify you of material changes. The latest version will always be available on the Cinobo Service.

Schedule 1 - Cinobo Companies