A few words about your

Privacy notice

Head Holiday and Live Cinema Ltd takes your privacy seriously and is committed to protecting your Personal Data.

This privacy notice tells you how we deal with your Personal Data, your privacy, and other various rights you have when you supply information to us either through our website or otherwise.

Important information and who we are

Purpose of this privacy notice

This privacy notice gives you information on how Head Holiday and Live Cinema Ltd collects and processes your Personal Data, including any data you may provide through our website or otherwise. Head Holiday is owned and operated by Live Cinema Ltd, and this privacy notice applies to how Live Cinema Ltd uses data provided by your for use of Head Holiday.

It is important that you read this privacy notice together with any amended notice we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your data. Please note that we may amend this notice at any time.

Data Controller

Head Holiday and Live Cinema Ltd (referred to in this policy as either “Head Holiday”, "LCUK", "we", "us" or "our") is the data controller. That means that we determine the purposes for which, and the way in which, your Personal Data is processed. We are also responsible for looking after your Personal Data in accordance with all relevant legislation and you should contact us if you have any questions or concerns about your Personal Data. Lisa Brook, our Director, is our lead contact for data processing questions.

Changes to this notice and your obligation to inform us of changes

The data protection law in the UK changed on 25 May 2018. Although this privacy notice sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your Personal Data) straight away as we are still working towards getting our systems ready for some of these changes.

It is important that the Personal Data we hold about you is accurate and current. Please do let us know if your Personal Data changes.

Third-party links

Our website 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 data about you. We do not control these third-party websites and are not responsible for their privacy statements. Please do ensure you are familiar with any privacy notice or policy of any website you visit.

Data usage

The data we may collect about you

Personal Data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:

On occasions, we may receive Special Categories of Personal Data which relate to you such as:

How is your Personal Data collected?

We use different methods to collect data from and about you including through:

Why we will process your Personal Data

We have set out below, in a table format, a description of all the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where we consider that we have such an interest.

Note that we may process your Personal Data on more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table below:

Purpose/activity Type of data Lawful basis for processing including basis of legitimate interest

Initiating contact in relation to any service or update which is reasonably likely to be of interest to Head Holiday users. This includes, but is not limited to, app updates and new content added to the platform. (a) Identity Data

(b) Contact Data Necessary for our Legitimate Interests (to keep our records updated and to maintain and manage our relationship with Head Holiday users).

To register you to receive our latest news via Mailchimp (a) Identity Data

(b) Contact Data (c) Your consent Consent Registering to use the website or app (a) Identity Data (b) Contact Data Necessary for the Performance of a Contract To manage our relationship with you which will include: (a) Notifying you about changes to our terms and conditions or privacy policy (b) Asking you to leave a review or take a survey (c) Asking for feedback (d) Recording your communications preferences (a) Identity Data (b) Contact Data (c) Profile Data (d) Communications Data Necessary for our Legitimate Interests (to keep our records updated and to manage our relationship with our users). To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity Data (b) Contact Data (c) Technical Data Necessary for our Legitimate Interests (for running our operations, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity Data (b) Contact Data (c) Technical Data (d) Usage Data (e) Profile Data Necessary for our Legitimate Interests (to develop our products/services and to grow our user network). Legitimate Interests assessment Because we think that we have a legitimate interest in processing your Personal Data, we have undertaken a Legitimate Interest Assessment which sets out why we think such processing is justified. We have a specific purpose with a defined benefit: Given your previous engagement with Head Holiday, we consider that you may have an ongoing interest in our services. The processing is necessary to achieve the defined benefit: We cannot fulfil the purpose without processing your Personal Data. The purpose is balanced against, and does not override, the interests, rights and freedoms of data subjects: Yes. There is no material risk to your rights or freedoms. We consider that our legitimate interest in keeping you up to date with our activities is balanced against, and does not override, your interests, rights and freedoms. How we use your personal data 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: • Where you consent to us using your Personal Data, for example when you correspond with us or request updates relating to Head Holiday (your consent can be withdrawn by you at any time as set out in this policy). • In the absence of consent, where it is necessary for our Legitimate Interests (or those of a third party), for the purposes set out above, and your interests and fundamental rights do not override those interests. • Where we need to comply with a legal or regulatory obligation. Third parties We do not share your Personal Data with any third parties other than the third parties which are identified below. We may obtain or share your Personal Data with the parties set out below for the purposes set out in the table above. • Third parties who have funded Head Holiday including Innovate UK. • Third parties with whom we contract to provide services including our developers Marmelo Digital. • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. We require all third parties and sub-contractors to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions. Where we need to share your Personal Data with a third party other than one of those named below we will obtain your express opt-in consent before we share it. Opting out You can ask us or third parties to stop sending you messages at any time by contacting us at the email address set out above, or by following the opt-out links on any communication or marketing message sent to you via email or Mailchimp. Where you opt out of receiving these messages, this will not apply to Personal Data provided to us as a result of litigation or complaints and only as long as the information is required. 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 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. International transfers We do not intend to transfer your Personal Data outside the European Economic Area (EEA) but if we do we will only transfer it to country which the European Commission has assessed to have an adequate data protection regime. We may occasionally use certain third party communications and marketing platforms such as MailChimp. Where these providers operate servers based in the USA, we have confirmed they are certified under the EU-US Privacy Shield program and we will ensure that any other transfers meet all legal requirements. Data security We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality. Your personal data held in our website database will be stored on the servers of our hosting services providers Amazon Web Services. We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. Data retention How long will you use my personal data for? We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements. Your legal rights You have the following rights regarding your personal data: • The right to be informed about any data we hold about you; • The right to request a copy of your Personal Data which we hold about you; • The right to request that we correct any Personal Data if it is found to be inaccurate or out of date; • The right to request that your Personal Data is erased where it is no longer necessary for us to retain such data; • The right, where there is a dispute in relation to the accuracy or processing of your Personal Data, to request that a restriction is placed on further processing; • The right to object to the processing of your Personal Data. If you wish to exercise any of the rights set out above, please contact us at hello@headholiday.com. No fee usually required You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these 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 your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. Complaints If you have any complaints or queries about matters affecting your privacy, or any other general data protection matters, then please do let us know by contacting us as set out above and we will endeavour to resolve the problem. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues. The ICO can be contacted as follows: The ICO's address: Information Commissioner's Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Helpline number: 0303 123 1113 Please go to their website for more information.