General Data Protection Regulation

1. INTRODUCTION

4Wall Entertainment UK Ltd (collectively referred to as “4Wall”, “Us”, “We”, “Our” in this privacy notice) registered in England and Wales under company number 5595504 is the data controller of your personal data for the purposes of the EU General Data Protection Regulation (the “Regulation”). We respect your privacy and we are committed to protecting your personal information as that term is defined in the Regulation (“Personal Data”). We comply with the principles of the Regulation and aim to maintain consistently high levels of best practice in our processing of your Personal Data.

This Privacy Policy (“Policy”) is intended to inform you how we collect, use and disclose your Personal Data. This Policy is intended to assist you in making informed decisions about your Personal Data when using our website or the services provided by us. Please take a minute to read and understand the Policy.

By using our website and services you consent to our collection and use of your Personal Data as described in this Policy. If we change our Policy and/or procedures, we will post those changes on our website to keep you aware of what Personal Data we collect, how we use it and under what circumstances we may disclose it. Your continued use of the website or services after this Policy has been amended shall be deemed to be your continued acceptance of this Policy, as amended. We encourage you to bookmark this Web page and review this Policy regularly.

In addition to this Policy, each service offered by us may have additional privacy provisions that are specific to the particular service. These supplemental disclosures are made adjacent to the particular service at the time your Personal Data is collected.

We have appointed a data privacy manager 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 your legal rights, please contact the data privacy manager using the details set out below.

Contact details
Our full contact details are as follows:
Address: 4Wall Entertainment UK Limited, 5 Central Road, Harlow. Essex, CM20 2ST
Telephone Number: 01279 824 877
Data Privacy Manager: Matthew Oliver
Email address: moliver@4wall.com

2. THE PERSONAL DATA WE COLLECT & HOW WE COLLECT IT

All your Personal Data will be held and used in accordance with the Regulation where applicable. If you want to know what Personal Data we collect and hold about you, please write to us at: moliver@4wall.com. When you visit and use our website or request our services you may provide us with or we may collect your Personal Data, such as your postal address, email address and other personal information.

You may provide or we may collect this Personal Data in a number of ways:

2.1 Personal Data you voluntarily provide to us

We collect and maintain Personal Data that you voluntarily submit to us during your use of our website or services. For example:

when you register on our website or for a service, you may provide us with certain identity and contact data including your name, email address, screen name, password and demographic information; where our website contains a social networking function, you may create and add to your profile by providing information about your interests;
if you sign up to our services or contact us via our website using your personal email address and tick the “opt-in” checkbox on our contact form, download form or email campaign, you are agreeing to sign up to receive the latest tech trends, our services, news & company updates and events from 4Wall by email, post and phone. We will always treat your personal details with the utmost care, and we never sell our data to third parties.
if you sign up to receive a newsletter, a magazine, enter a contest or participate in social networking activities, you may provide us with identity and contact data (e.g., email, telephone and/or or physical address); and you may provide us with Personal Data in the course of email, customer support interactions and surveys.

Any corporate email address (a PLC or LTD email address) submitted to us via a contact form or download form on our website or via our corporate email addresses or phone, will be collected and used in accordance with GDPR policy.

2.2 Personal Data we collect through your use of our Website

As you use our website, Personal Data may also be passively collected by us through our use of cookies, pixels, beacons, log files and other technologies. This Technical Data allows us to deliver more helpful information, services, tools and advertisements.

2.3 Personal Data we receive from third parties

We may also combine online and/or offline information received from third parties with your Personal Data. The third party information is used for a variety of purposes including to verify other Personal Data about you (e.g. verify your mailing address to send you requested products or services) and to enhance the content and advertising we provide to you.

3. HOW WE USE YOUR PERSONAL DATA

We will use your Personal Data in the ways described below and as described at the time that the Personal Data is collected.

3.1 To Provide the Services

In general, we use your Personal Data as necessary or appropriate for our legitimate interests and/or in order to fulfil the performance of a contract with you, including to:

administer your account where you have opened an account with us;
register you and provide you access to the website or services requested by you;
respond to enquiries or requests that you direct to us;
fulfil your requests for products or services;
send communications and administrative emails about the website or our services;
personalise and better tailor the features, performance and support of the website and our services for your use; analyse, benchmark and conduct research on user data and user interactions with the website and our services; and
run competitions.

3.2 Marketing

Where you have provided us with the appropriate consents, or where the Regulation entitles us to do so, we may send you marketing materials about other products or services offered by 4Wall, and/or products or services offered by our company. In addition, where you have provided us with the appropriate consents, we may also pass your Personal Data to selected third parties for marketing purposes. However, be assured that we understand the irritations of unsolicited communications and we are fully committed to ensuring the rights and obligations set out in the Regulation and the Privacy and Electronic Communications Regulations 2003, updated 2004, 2011, 2015, 2016 are respected, as follows:

if you provide us with a personal email address and do not agree to receive our updates by checking the “opt in” checkbox at the time of contacting us or after, we will not contact you with updates and will remove your email address from our system after 6 months of obtaining your contact information.
all data is used in accordance with GDPR regulation

3.3 Behavioural Advertising

We believe that advertising is more interesting to you when it is relevant. Accordingly, where you have consented for us to do so we may customise the advertisements that you see based upon:

the Personal Data you voluntarily provide to us;
geographic location information, which we may determine through your IP address, from your mobile device, or other ways;
data we receive from third parties; or
your visits to our website or your use of our services (commonly referred to as “Behavioural Advertising”).
Advertising and use cookies and web beacons in the manner described above. We do not control these advertisers or other parties’ use of cookies or web beacons or what they do with the information they collect.
You can limit the way that we tailor advertising based on your Personal Data by objecting to the cookies that we or third parties wish to place on your browser or deleting the cookies that we or third parties have placed on your browser.

After you have exercised your right to object or reject the use of cookies, you may still see advertisements, but the advertising may not be as relevant to your interests. If you change your computer, change your browser or delete certain cookies, you will need to renew your preferences.

4. DISCLOSURE FOR LEGAL REASONS

We may disclose your Personal Data if we are under a duty to disclose or share your Personal Data to comply with any legal obligation or in order to enforce or apply or fulfil our terms and conditions and other agreements or protect the rights, property, or safety of our customers or others. This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction.

We use a number of third party organisations to help provide a professional service to our customers (i.e. website designers). These organisations act as data controllers and are strictly controlled. They may not use your Personal Data and we remain responsible for the protection of your Personal Data.

When you participate in a Promotion, you are subject to any official rules for that Promotion, which may contain additional information about the specific privacy practices associated with the Promotion

4.1 Promotions and Sponsors

Some or all of the Personal Data collected during a promotion, contest or poll (“Promotions”) may be disclosed publicly. It may also be shared with other third parties as disclosed and consented to by you at the time of collection or in the Promotion rules. These third parties may include providers of prizes in order to update you of your status of your prize or other fulfilment needs or a co-sponsor who may use your Personal Data to administer the Promotion or for their marketing purposes, but only in conformance with your consent. We are not responsible for their privacy policy or practices.

4.2 Changes to our Company

In the event we go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Data may be among the assets transferred. You acknowledge that such transfers may occur and are permitted by this Policy.

4.3 Message Boards and Chats

We may make message boards, chat rooms, and other interactive forums available as part of our services. You should be aware that any Personal Data which you post to these interactive forums or otherwise choose to make publicly available, may be disclosed and available to all users who have access to that portion of our website or services. By using these interactive forums, you agree that we are not responsible for any Personal Data that you disclose or communicate in such forums, and any disclosures you make are at your own risk.

5. INTERNATIONAL TRANSFERS

We may transfer your Personal Data to third parties providing services to us who are based outside of the European Economic Area (EEA). This includes parties providing IT administration services and hosting services, and parties providing assistance with managing our marketing databases.

Whenever we transfer your Personal Data outside of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Transferring data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
using specific contracts approved by the European Commission which give personal data the same protection it has in Europe; or
for providers based in the US, we may transfer data to them if they are part of the Privacy Shield.

6. 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.

For more details of our specific retention periods, please contact our Data Privacy Manager.

7. THIRD PARTY LINKS AND SERVICES

Please remember that when you use a link to go from our website to another website or you request a service from a third party, our Policy no longer applies. Your browsing and interaction on any other website or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies. We do not monitor, control, or endorse the information collection or privacy practices of any third parties. We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices. This Policy applies solely to information collected by us through our website or services and does not apply to these third party websites and third party service providers.

8. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are set out below. If you wish to exercise any of the rights set out above, please contact our Data Privacy Manager.

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.

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 legal rights are as follows:

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.
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.
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.

Updated January 2021