1. INTRODUCTION
1.1 Village Roadshow Group of Companies
Village Roadshow Gold Class Cinemas (“Village”) operates luxury Cinemas in the US and through the operation of these cinemas, Village from time to time gathers information from Customers and other parties with whom we deal for a variety of reasons including, in particular, to enable us to improve the nature of the services we provide. Village understands individuals' concerns regarding confidentiality and takes seriously its obligations with respect to all information it gathers. This Privacy Policy outlines how Village deals with Personal Information.
2. WHY VILLAGE COLLECTS PERSONAL INFORMATION
2.1 Nature of Information
The information Village collects in most cases relates to Customers but can relate to suppliers and other parties we deal with (for the purposes of this Privacy Policy all such people are described as “Customers”). Information is gathered for a range of purposes, including the provision of ongoing Customer support and the compiling of Customer databases to enable us to more accurately market our goods and services. The type of information we collect may include such things as contact details (name, physical and e-mail addresses, phone numbers, etc.), demographic information (such as zip code, age or income level), financial information (such as account or credit card numbers), buying habits, opinions, product preferences and transactional details. We may also collect the Internet Protocol address and e-mail address of visitors to our website, the e-mail addresses of those who post messages to a bulletin board (if applicable), and the e-mail addresses of those who communicate with us via e-mail. Village treats all information which is collected and identifiable as relating to an individual as Personal Information. It is this information which is described as “Personal Information” for the purposes of this Privacy Policy. In addition to Personal Information, our web servers automatically collect website usage information from Customers when they visit our website. Website usage information is anonymous information about our visitors that describes how our website is used and navigated, including the number and frequency of visitors and subscribers to each web page, their actions taken during visits to the site, and the length of their stays. Website usage information does not contain personally identifiable information.
2.2 Collection of Information
Where practical, Customers of Village may deal with Village on an anonymous basis. However, as a provider of a wide range of services, Village frequently finds that it is necessary or desirable to collect Personal Information during the course of transactions.
Personal Information may be collected about Customers via the following means:
1. (a) contest entry forms;
2. (b) application forms;
3. (c) email;
4. (d) websites (including in some instances cookies);
5. (e) online transactions;
6. (f) networking functions (e.g.: business cards);
7. (g) over the phone;
8. (h) credit card details via credit card purchases; and
9. (i) Information collected from third parties.
2.3 'Sensitive Information'
Village will not ask a Customer for information revealing racial or ethnic origin, political opinions, religious beliefs, or details of health, disability or sexual orientation, unless:
1. (a) the Customer provides their consent;
2. (b) the collection of that information is specifically authorized by law;
3. (c) the collection is necessary to lessen a serious or imminent threat to the health or safety of a person; or
4. (d) the collection of the information is necessary for the establishment, exercise or defense of a legal claim.
2.4 Customer Consent
Wherever practical, Village will obtain the express consent of Customers to the collection of Personal Information. In some situations, Village will interpret a Customer's actions as indicating that a Customer consents to the collection of Personal Information. This may occur where the Customer has provided Personal Information for a particular purpose and that purpose cannot be achieved without Village making use of the Customer's Personal Information.
2.5 What happens if Personal Information is not provided
Where relevant, Village will endeavor to make Customers aware that Village may not be able to provide a particular service to them if Personal Information is not provided upon request.
3. MAINTENANCE AND MANAGEMENT OF PERSONAL INFORMATION
3.1 Who may view Personal Information
In general, only officers, employees or contractors of Village may view Personal Information.
Village will only grant access to parties other than Village’s officers, employees and contractors to view Personal Information where Village believes that access is necessary to achieve the purpose for which the Personal Information was collected.
Village will only disclose Personal Information to parties other than Village's officers, employees and contractors if:
1. (a) that disclosure is required to give effect to the purposes for which Village collected the Personal Information;
2. (b) the Customer has consented to that disclosure;
3. (c) Village believes that the disclosure may lessen a risk of harm to the health or safety of any person;
4. (d) Village believes an unlawful activity is being undertaken and the Personal Information is disclosed as part of Village's investigation into this activity;
5. (e) Village is required by law to disclose the Personal Information; or
6. (f) the disclosure is required for the enforcement of a criminal law or a law imposing a pecuniary penalty or for the protection of public revenue.
3.2 Storage and Security
Personal Information may be stored in either hard copy form or on computer or both. Hard copy Personal Information is, wherever practical, kept under locked security. Personal Information stored on computer is, wherever practical, password protected. Village will endeavor to comply with recognized U.S. and international standards relating to information security. Village regularly deletes and de-identifies Personal Information if the information is no longer needed by Village.
3.3 Updating Personal Information
Village regularly monitors the quality and accuracy of Personal Information that it maintains and where practical, updates that information on a regular basis. Customers can update their Personal Information at any time by contacting Village's Privacy Officer as described in Paragraph 10 below.
4. CHILDREN
Village does not specifically target its online services to children under 13 years old. If you are under the age of 13 you may use our website only under the supervision and with the consent of a parent or legal guardian. Where Village is aware that it is gathering information from a minor, Village will obtain consent from a parent or legal guardian for the collection of the information. Where this is not possible, Village's staff will not knowingly collect Personal Information from a minor under age 13.
5. CONTESTS
Personal information gathered during contests run by Village will be governed by the principles set out in this Privacy Policy unless an express statement is made in relation to privacy in the conditions of entry for the contest.
6. DIRECT MARKETING
Personal Information collected for direct marketing purposes will only be collected, used or disclosed with the consent of the relevant Customer as provided for in this Privacy Policy. In circumstances where Village cannot practically obtain the consent of a Customer, then Village may still engage in direct marketing to that Customer, but will:
1. (a) advise the Customer that he or she can be taken off the mailing list at any time; and
2. (b) display its contact details clearly in each direct marketing publication.
Customers may be taken off any mailing list or may opt-out of receiving marketing communications from Village by contacting Village's Privacy Officer as described in Paragraph 10, below.
7. ACCESS TO PERSONAL INFORMATION
Customers may access their Personal Information by contacting Village's Privacy Officer as described in Paragraph 10, below. Access is generally granted within 30 days of that request. Village may impose a reasonable charge for access.
8. WHEN VILLAGE MAY WITHHOLD ACCESS TO PERSONAL INFORMATION
8.1 When access can be withheld
Access to Personal Information may be withheld in a number of circumstances. These include where:
1. (a) providing access would pose a serious and imminent threat to the life or health of a person;
2. (b) providing access would have an unreasonable impact on the privacy of others;
3. (c) the information is subject to confidentiality where the person who provided the information to Village did so expressly on the condition that it remains confidential;
4. (d) the request is vexatious or frivolous;
5. (e) the information relates to current or anticipated legal proceedings between Village and the person and the information would not be available pursuant to the applicable rules of discovery;
6. (f) Village is in commercial negotiations with the person and the information would reveal Village's intentions;
7. (g) providing access would be unlawful or Village is required by a law to withhold access; or
8. (h) providing access could prejudice the investigation or detection by Village or by a government body of an unlawful activity or some serious or improper misconduct.
Where Village does withhold Personal Information, Village may instead choose to give the Customer a summary of that information.
8.2 Written reasons
If Village does withhold Personal Information, Village will provide written reasons.
8.3 Third party intermediary
If Village withholds access to Personal Information, Village will consider whether the provision of access to an independent third party will meet Village's and the relevant Customer's needs.
9. CONTRACTORS
Village may from time to time employ subcontractors to provide services to it. In these situations, Personal Information may be collected about those subcontractors. This Privacy Policy applies equally to those subcontractors.
10. WHO TO CONTACT
If you have any questions regarding this Privacy Policy, Village's privacy practices, or your interaction with this website, please contact our Privacy Officer by e-mail at privacyofficer@vrgcc.com or by mail at:
Village Roadshow Gold Coast Cinemas
3400 Riverside Drive, Suite 900
Burbank, CA 91505
Or you can call us at: (818) 260-6000
11. MODIFICATIONS TO THIS DOCUMENT
Village may, from time to time, modify this Privacy Policy and the way it handles Personal Information. We will post any changes on our website, so please check back periodically. Your continued use of our website after any change has been posted constitutes acceptance of the change to this Privacy Policy.
This Privacy Policy was last updated September, 2008.
