Overall Privacy

Commitment

Toluna UK Ltd of Ealing Cross, 85 Uxbridge Road, London W5 5TH ("Toluna") is an online data collection company focused on providing high quality data to the full-service marketing research industry, advertising agencies and consultancies.

For the purposes of this privacy policy (Privacy Policy) Toluna builds and maintains large online consumer panels and operates The Screening Room on behalf of Columbia Pictures Corporation Limited, Sony Pictures Europe House, 25 Golden Square, London W1F 9LU ("CPC Limited") who is the "data controller" in respect of all personal data collected and used via this site and "The Screening Room" with the exception of any personal data processed in the course of the "Digital Finger Printing" fraud detection procedure described in the "Digital Finger Printing" section below, where such data is processed by Toluna as the data controller. For the purposes of this Privacy Policy when we refer to "we", "us", or "our" we mean CPC Limited, the data controller of your personal data.

The Screening Room is an online market research tool operated by Toluna which enables us to better understand our consumers ("you" or "your") by running qualitative research, studies and panels with you. Your participation with The Screening Room is entirely voluntary. We take your privacy seriously and have developed this Privacy Policy to explain what personal data we collect from you when you engage with us via The Screening Room and how we use and share this information.

The information we gather

  • We gather personal information that you provide to us when you register to become a member of The Screening Room. After registration we will ask you to provide us with more personal information so that we may invite you to participate in appropriate surveys. To become a member of The Screening Room, we ask that you fill out a registration survey that gathers some personal and general consumer information. We ask for your email address so that we can send you email invitations to participate in our upcoming surveys and, subject to the preferences you expressed when registering, to send you newsletters to make you aware of new features or contests running on the site or The Screening Room.
  • The other information we ask you to provide to us, such as your name, address, gender, and birthday is for matching you with the appropriate marketing research projects and panels. Your birthday is used to automatically update your age for us to target age-related marketing groups. We ask you for this information as a means to see if you might qualify for particular projects. All email contact from The Screening Room will be sent to your primary email address that you gave to us upon registration. If you become a member of The Screening Room, your information (name, address, city, state, and zip or postcode) is also used for the purposes of incentive fulfilment.
  • Please be aware that any personal information you choose to make public on the publicly accessible parts of our site or in the Community area (as an opinion or topic in a message board or live chat or any other public area or forum within The Screening Room) can be read by other members. To request removal of your personal information from such parts, please refer to the "Your Rights" section below.

Use of this information

We use your personal information:

  • to enable Toluna to provide you with access to the site and The Screening Room;
  • for the purposes of our market research endeavours and to contact you in connection with market research questions, panels and activities carried out via The Screening Room;
  • to display your anonymous testimonials on the site or with your name if you have given your consent;
  • to provide you with support in relation to The Screening Room, deal with enquiries or notify you of changes to our services and/or terms; and
  • to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees.

We do not sell your personal information and will only share your information with third parties in accordance with the terms of this Privacy Policy or otherwise subject to your consent. Note that this is not intended to preclude our right to sell or share aggregated and anonymised results of any market research, panels or activities that you may have participated in.

If you are a member of The Screening Room panel, your information is stored in our proprietary database so we may call upon it to determine which people match up with specific research studies. If we think your profile makes you a potential candidate for a study, we will email you an invitation to make you aware of this opportunity. From time to time we may use third-party software to manage our emails to you.

Sharing

We may share your information with the following parties:

  • Third party service providers

    Your information is processed by Toluna UK Ltd acting as a "data processor" on our behalf (CPC Limited) and on our instructions only. By joining The Screening Room panel, you acknowledge and agree that you provide personal information to Toluna's USA affiliated company; Toluna USA Inc., (" Toluna USA") and that such information will be stored on servers owned by Toluna and located in the USA. For these purposes we have implemented the Standard Contractual Clauses of the European Commission with Toluna USA in order to secure such transfer but we reserve the right to implement alternative means of ensuring adequate protections of data transferred out of the European Economic Area in compliance with data protection laws.

    We may also need to share your information with other third party service providers where necessary to help us operate The Screening Room or deliver other services to you. For example we may engage third parties to deliver prizes you may have won for your participation in our panels, to perform functions on our behalf, such as hosting or operating The Screening Room and associated website, sending e-mail communications, and data analysis. We may share your information with third parties in order for them to provide content or otherwise perform services for us, and we will require such parties to maintain appropriate security to protect such data from unauthorized access or processing.

  • Enforcing our rights

    Though we make every effort to preserve your privacy, we may need to disclose your personal information to third parties when we have a good-faith belief that such action is necessary to comply with judicial proceedings or a court order or if we believe it is necessary in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Toluna site terms, or as otherwise required by law.

  • When You Agree To Have Your Information Shared

    While using The Screening Room and site, you may have the opportunity to opt-in to receive information and/or marketing offers from someone else or to otherwise consent to the sharing of your information with a third party. If you agree to have your information shared, your information will be disclosed to the third party and will be subject to the privacy policy and business practices of that third party. You may also specifically request, sometimes through your use of an interactive feature, a widget or an application, that we share your information with a third party and we will typically do so under those circumstances. In addition, if you choose to register for a promotion, such as a competition, prize draw or contest, your information may be disclosed to third parties for purposes of the administration of such promotion.

  • Affiliate Sharing and Business Transfers

    We may share your information with other entities affiliated with us for internal business and operational purposes but only to enable us to use and process such information in accordance with the terms of this Privacy Policy.

    We may also share your information with the buyers of all or part of our business or with any business we merge with or acquire.

The Use of Digital Finger Printing on Our Site

In general, Digital Fingerprinting technologies ("the technology") assign a unique identifier or "Machine-ID" to a user's computer to identify and track the computer. Toluna will not disrupt or interfere with the use or control of a computer or alter, modify or change the settings or functionality of a computer. Toluna uses the technology to assist Toluna's clients (including us) in ensuring the integrity of survey results. To the extent that the use of this technology involves the processing of your personal data, Toluna will be the data controller. From now on in this Digital Finger Printing section, all the activities in respect of such data and the restrictions on Toluna's use of those data that are described below shall also apply to our use of such data.

The technology will analyse publicly available information and data obtained from the computer's web browser and from other publicly available data points, including without limitation the technical settings of the computer, the characteristics of the computer, and the computer's IP Address, to create a unique identifier assigned to the computer. The unique identifier will be an alpha-numeric ID. After creating the unique identifier, Toluna does not retain the information ID used by the Technology to create the unique identifier.

Toluna may (a) link or associate your unique identifier to you and any of your Personal Information, (b) share your unique identifier with Toluna's clients and with other sample or panel providers; and (c) receive or obtain a unique identifier linked to you from a third party, including without limitation a sample or panel provider or a client of Toluna. Any unique identifier(s) received or obtained by Toluna and linked to a specific individual will be protected in accordance with this privacy policy. These steps are taken in furtherance of Toluna's efforts to assist its clients in protecting and ensuring the integrity of survey results, as they allow the identification of fraudulent and duplicate respondents.

Toluna shall use commercially reasonable efforts to ensure that the technology is safe, secure and does not cause undue privacy or data security risks.

Toluna shall use and distribute the technology in a professional and ethical manner and in accordance with (a) Toluna's privacy policy, (b) any statements and/or disclosures made by Toluna to respondents, and (c) applicable laws and codes.

In the event that Toluna discovers or learns of any unethical conduct in connection with the use of the technology, or that the technology is being used in a manner that is inconsistent with the statements and/or disclosures made by Toluna to respondents or in violation of applicable laws and codes, Toluna will take immediate action to prohibit such unethical conduct and to ensure the proper administration of the technology.

Your rights to the information we hold about you

You have certain rights in respect of the information that we hold about you, including the rights to:

  • · gain access to your information;
  • · ask us to correct information that we hold about you to ensure that it is accurate and kept up to date; and
  • · in certain circumstances, require that we delete information that we hold about you.

In order to exercise any of the rights set out above, you may update or review your information in your account profile, by writing to us at the address below or Contact Us at support@screeningroomcommunity.com.

We provide you with a Members Area on our site; here you may correct or update your membership information or delete your membership. If you are a panel member and delete your membership, your profile information will be permanently removed, but may be stored (but put beyond use) in our disaster recovery databases, and in such circumstances will not be used for commercial purposes. Please note that in most cases, it will take two or three business days for your information to be completely removed from our records; but please allow up to fifteen days.

Your preferences

In order to become a panel member of The Screening Room, you agree to receive emails from us (CPC Limited) via The Screening Room inviting you to participate in surveys that we feel may match your experiences and background and any gathering and processing personal information in accordance with this policy.

From time to time, subject to any preferences you express at or after signing up to be a panel member we may also email newsletters to you to make you aware of new features or contests we are running within The Screening Room. Subject to your preferences, we may also share your information with third parties for these purposes if you have consented to hear from them, provided that such communications shall be for market research purposes only.

Correct/Update policy

You agree to keep your profile information up to date. If you need to correct any of your profile information or if you would like to update any of your information, you may do so by clicking on Your Profile after logging in. By following the appropriate directions, your information should be automatically updated on our database.

Delete/Deactivate policy

If you wish to end your membership with The Screening Room or to require us to cease processing your personal data, you may automatically discontinue your membership by clicking Unsubscribe in the footer of our Homepage or by contacting us at support@screeningroomcommunity.com. By following the appropriate directions, your record will be marked as "unsubscribed", and you will no longer receive communications from The Screening Room. In addition, you will forfeit any incentive balance that has not been requested as of the time you opt out. We will process your unsubscribe request as soon as we can but please note that you may still receive emails from us whilst are processing your request. Email links are provided on the site so that you may contact us directly with any questions or concerns you may have. Each email we receive is read and responded to individually; please allow two to three business days for us to get back to you.

Questions about this policy

Email links are provided on the site so that you may contact Toluna directly with any questions or concerns you may have. Each email Toluna receive is read and responded to individually; please allow two to three business days for Toluna to get back to you.

Data retention

We will retain your account information for as long as necessary to provide you with access to your account or as needed to provide you services or otherwise for as long as the law permits. Note that this does not preclude us from retaining anonymised and aggregated results of market research studies that you may have been involved with before ending your account with us. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements

Winners policy and privacy guarantee

The Screening Room panel members are randomly selected to win prizes for participation in surveys, polls, and other promotions. All winners are notified by email of their winnings. For more information, please visit our Terms and Conditions page. Toluna shall post the usernames or partial name and county of winners on the Reward Page or communicate them via newsletter to all panellists.

Notification of changes

If we decide to change our privacy policy, we will post those changes to this privacy statement, the home page, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by Email, or by means of a notice on our home page prior to the change becoming effective.

Security of your information and where we may store it

We take appropriate technological and operational security measures to ensure that your information is kept secure. Access to all personal information is restricted and limited to few key personnel. Our website security is reviewed periodically and can only be accessed via a strict password policy. We will never ask you for private information such as your credit card or social security numbers as a part of our research. We use SSL encryption when collecting or transmitting sensitive information. Your profile information is highly confidential and will be used only by us to email you concerning our studies, newsletters, winner notifications, and incentive redemptions, or as otherwise provided for in this privacy policy.

Without intending to limit our commitments to the security of your information, you acknowledge that data transmission over the internet is inherently insecure and that whilst we will implement security measures to protect your data from unauthorised access, we cannot guarantee the security of data shared over the internet. Therefore please take special care in deciding what information to share with us over the internet.

In addition to our hosting your information in the US in accordance with the Sharing section above, we may store or transfer your information to other countries within and outside the European Economic Area ( EEA). In certain circumstances your information may be processed outside of the European Economic Area (EEA) such as when we engage third parties based outside of the EEA to assist us with in operating The Screening Room as outlined above. In such circumstances, we will take all steps necessary to ensure that any of your information is adequately protected and processed in accordance with this Privacy Policy and applicable data protection laws. You consent to this transfer and processing of your information.

Social Media Widgets

The Screening Room site may include Social Media Features, such as the Facebook Like button (and Widgets, such as the Share this button or interactive mini-programs that run on our site). These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our site. Your interactions with these Features are governed by the privacy policy of the company providing them (such as Facebook).

Single Sign-On

You may be able to log in to our site using sign-in services such as Facebook Connect or an Open ID provider. These services will authenticate your identity and provide you the option to share certain personally identifiable information with us such as your name and email address to pre-populate our sign up form. Services like Facebook Connect give you the option to post information about your activities on this Website to your profile page to share with others within your network.

Legal disclaimer

The site may contain links that will direct you to other websites or services that are operated and controlled by third parties. This includes links from advertisers, sponsors and partners that may use our logo(s) as part of a co-branding agreement. We have no control over these third parties, and your use of their websites and features are subject to their privacy policies. We are not responsible for the privacy practices or business practices of any third party website. In addition, we may place our widgets or other features on certain third party websites. When we do so, any personal data that we obtain about you will be subject to this Privacy Policy.

Children's privacy

We do not intend to and will not knowingly collect any information from any child without permission from his/her parents or legal guardian.

Privacy contact:

Privacy Officer acting on behalf of Columbia Pictures Corporation Limited
Toluna UK Ltd. Ealing Cross, 85 Uxbridge Road, W5 5TH
E-Mail: support@screeningroomcommunity.com

Copy always to: SonyPrivacy@spe.sony.com