Kino-mo Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
This privacy notice aims to give you information on how Kino-mo Limited collects and processes your personal data, including any data you may provide through this website when you sign up to our newsletter, request for commercial proposal or purchase a product or service.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing 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. This privacy notice supplements the other notices and is not intended to override them.
Controller
Kino-mo is made up of different legal entities. This privacy notice is issued on behalf of the Kino-mo Limited Group so when we mention “Kino-mo Limited”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Kino-mo Limited Group responsible for processing your data. Kino-mo Limited is the controller and responsible for this website.
We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise, please contact the DPO using the details set out below.
Address: Office A, The Makers Building, Nile Street, London, United Kingdom, N1 7RD.
Attn: Data Protection Officer
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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
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 changes during your relationship with us.
Third-party links
This 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. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The data we 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:
•Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
•Contact Data includes billing address, delivery address, email address and telephone numbers.
•Financial Data includes bank account.
•Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
•Technical Data includes 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.
•Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
•Usage Data includes information about how you use our website, products and services.
•Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.
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, any information about criminal convictions and offences) with the exclusions specified below and only with regards to the services ordered by You and subject to your consent.
Interactive Experience Video Data
In limited circumstances, and only with your consent, we collect biometric data associated with our interactive services. This consists solely of a video recording of your interactive experience. No other biometric identifiers are collected.
Dialog Data (Avatar Interactions)
With your consent, we collect recordings of dialogs you initiate with our holographic avatar product. These recordings are used to generate a dialog report for you. We do not use or share your dialog recordings without your consent for any other purpose, unless they are anonymised to remove personal data.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
•Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• apply for our products or services;
• create an account on our website;
• create an account on our website;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us some feedback.
•Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our information about how we use cookies for further details.
•Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
• Technical Data from the following parties:
◦ analytics providers such as Google based inside or outside the UK and EU;
◦ advertising networks based inside or outside the UK and EU; and
◦ search information providers based inside or outside the UK and EU.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside or outside the UK and EU.
• Identity and Contact Data from data brokers or aggregators based inside or outside the UK and EU.
• Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the UK and EU.
4. How we use your personal data
We will only use your personal data when the law allows us to.
Purposes for which we will use your personal data
Purpose/Activity
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer
(a) Identity (b) Contact
Performance of a contract with you
To process and deliver your order including:(a) Manage payments, fees and charges(b) Collect and recover money owed to us
(a) Performance of a contract with you(b) Necessary for our legitimate interests (to recover debts due to us)
To provide our interactive experience, including recording your participation for your own download and copy, followed by automatic deletion from our systems
(a) Interactive Experience Video Data (video recording only)
To provide holographic Avatar dialog experiences, record dialogs to generate a personal dialog report, and anonymise dialogs for other analytical purposes
(a) Dialog Data
Consent (withdraw at [email protected] ); Legitimate interest (in anonymised analytics)
To manage our relationship with you which will include:(a) Notifying you about changes to our terms or privacy policy(b) Asking you to leave a review or take a survey
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications
(a) Performance of a contract with you(b) Necessary to comply with a legal obligation(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey
(a) Performance of a contract with you(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity (b) Contact (c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
(a) Technical (b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
Necessary for our legitimate interests (to develop our products/services and grow our business)
Marketing
We strive to provide you with clear choices regarding how your personal data is used for marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data (for example, your name, email address, IP address, and how you use our website) to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if:
• you have given us your consent to do so, or
• you are an existing customer and we are marketing similar products or services to those you purchased from us, and you have not opted out of receiving such communications (this is known as the “soft opt-in”).
Third-party marketing
We will only share your personal data with any company outside Kino-mo group of companies for marketing purposes if you have given us your express opt-in consent.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by:
• clicking the “unsubscribe” link in any email we send you, or
•contacting us directly using the details in the “Contact Us” section of this Privacy Notice.
Where you opt out of receiving marketing messages, this will not affect personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience, or other transactions.
Cookies
Our website uses cookies and similar technologies. Some cookies are essential for the operation of the website. For all non-essential cookies (such as analytics and advertising cookies), we will ask for your consent via our cookie banner when you first visit our site.
You can also set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see the Cookies section below.
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 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.
Use of Event Analytics Technologies
We may use technologies such as (i) occupancy sensors and (ii) Wi-Fi presence analytics at some of our events to understand how spaces are used. These systems help us measure visitor numbers, manage capacity, and improve event layout and safety.
Types of Data Processed
•Occupancy sensors: These count the number of people passing through an area or present in a space. They do not capture images or information that can identify you as an individual.
•Wi-Fi analytics (if enabled): Our systems may detect anonymized signals from mobile devices that are searching for or connected to Wi-Fi networks. These signals may include device identifiers (such as MAC addresses) which are immediately pseudonymized or aggregated so that we cannot identify you directly.
Purpose and Legal Basis
We process this information to manage event operations, ensure health and safety, and improve visitor experience. Where Wi-Fi analytics are used, our legal basis is our legitimate interest in analyzing aggregated visitor flows.
Transparency and Choice
Clear signage will be provided at event venues when these systems are in use. If Wi-Fi analytics are active, you may opt out at any time by disabling Wi-Fi or Bluetooth scanning on your device.
You have the right to object to this processing and to exercise your GDPR rights as stated further in this policy and at law (access, erasure, restriction, portability) by contacting us at [email protected].
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below.
Additional disclosures:
• Cloud hosting and content delivery providers (such as Amazon Web Services) engaged to securely process and temporarily store livestreaming data and dialog data.
• Gesture recognition technology providers (such as Google) who process visual data either locally on device or via their cloud infrastructure.
6. International transfers
Whenever we transfer your personal data outside the United Kingdom (UK) and/or the European Economic Area (EEA), we ensure a similar degree of protection is afforded to it by implementing one of the following safeguards:
• We will only transfer your personal data to countries that have been deemed by the UK Government and/or the European Commission (as applicable) to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may implement specific contracts approved by the UK Information Commissioner’s Office (ICO), such as the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the European Commission’s Standard Contractual Clauses (SCCs). These require recipients of personal data to protect it to standards essentially equivalent to those under UK data protection law.
• Where we work with providers based in the United States or other third countries, we may transfer data to them if they have entered into approved contractual safeguards (such as the SCCs with the UK Addendum or the IDTA), or if another recognised safeguard applies.
Please contact us if you would like further information on the specific safeguards we rely upon when transferring your personal data outside the UK and/or EEA.
7. 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 business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
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.
8. Data retention
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.
We will keep your contact details for as long as they are necessary for our legitimate business purposes (typically 24 months), unless you opt out earlier.
By law we have to keep basic information about our existing customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Product-specific provisions:
Interactive experience video recordings: retained for a maximum of seven (7) days solely to facilitate download and access by you. Recordings are automatically deleted after this period, unless you request earlier deletion by contacting us at [email protected].
Dialog recordings (Avatar interactions): retained for up to three (3) months to allow you to access dialog reports. We anonymise dialogs for any analytical use beyond this period. You may request earlier deletion by contacting us at [email protected].
Event Analytics:
• Occupancy data is only stored in aggregated form.
• Any pseudonymized device data is deleted or further anonymized after thirty (30) days and is not used to track individuals across events.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
If you wish to exercise any of the rights set out above, please contact us.
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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. Information about our use of cookies
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies:
Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
11. Glossary
LAWFUL BASIS
Consent means your explicit agreement to the processing of your personal data for a specific purpose, such as recording livestreaming experiences or dialog interactions.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us [[email protected]]
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
THIRD PARTIES
Internal Third Parties
Other companies in Kino-mo Group acting as joint controllers or processors and provide IT and system administration services and undertake leadership reporting.
External Third Parties
• Service providers who provide IT and system administration and analytical services.
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
• Payment processors who provide services on processing payments.
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
