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47 Ronin

<h1 class="h2">Privacy policy</h1>

<h2 class="h3">Introduction </h2>

We are StarzPlay Direct UK Limited ("Starz", "us", "our" or "we"). We provide the Lionsgate+ subscription service (the "Service"). 

This policy explains how and why we use personal data (also known as personal information, personally identifiable information or PII) for the purposes of providing, promoting and developing the Service. This policy also provides contact details and important information about privacy rights. 

We explain the Service in more detail in the Terms of Use. Please read this policy together with our Terms of Use <a class="text-lowercase hyperlink" href="https://www.lionsgateplus.com/ie/en/termsofuse">https://www.lionsgateplus.com/ie/en/termsofuse</a>. 

This policy was last updated September 28, 2022. We will periodically update this policy so please check back for updates. 
<h2 class="h3">Our contact details</h2>

StarzPlay Direct UK Limited, 
45 Mortimer Street, 
London, W1W 8HJ, 
United Kingdom 
<a class="text-lowercase hyperlink" href="mailto:privacy@lionsgateplus.com">privacy@lionsgateplus.com</a> 

GDPR Article 27 Representative:
Dr. Stefan Krempl
Katharinenheimstrasse 3
D-83093 Bad Endorf
stefan@krempl.net
Tel: +49 175 221 4287

If you would like to contact our Data Protection Office, please email privacy@lionsgateplus.com.
<h2 class="h3">What personal data do we collect?</h2>

We collect personal data relating to subscribers of the Service and other users authorised by such subscribers to access their subscription ("Subscribers") when they interact with the website associated with the Service, any mobile or TV app associated with the Service and/or any of the features or downloads that we make available through the Service. We also collect personal data relating to other individuals, who are not Subscribers, that interact with the Service, such may be website visitors or individuals who view our Service via their device or profile. 

Specifically, we collect the following types of personal data relating to Subscribers and other individuals – 

<ol>
 <li>Name and address.</li>
 <li>Date of birth.</li>
 <li>Contact details (including email address and phone number).</li>
 <li>Registration, username, password, password reminder and other information relating to “User Accounts” (as defined in the Terms of Use <a class="text-lowercase hyperlink" href="https://www.lionsgateplus.com/ie/en/termsofuse">https://www.lionsgateplus.com/ie/en/termsofuse</a>.</li>
 <li>Payment details (in limited circumstances).</li>
 <li>Registration for any contests, features and other promotions offered as part of, or in relation to, the Service.</li>
 <li>Participation in online research.</li>
 <li>Reports of issues with the Service.</li>
 <li>Correspondence (including email and chat).</li>
 <li>Screen names. </li>
 <li>Submissions, voting and polling activities.</li>
 <li>Service usage and activity.</li>
 <li>Search queries.</li>
 <li>Information about interests. </li>
 <li>Social media accounts and use.</li>
 <li>Third party access to the Service (for example, access via Facebook login).</li>
 <li>Technology used to access the Service, including –</li>
</ol>
<ul>
 <li>Device information.</li>
 <li>Browser information. </li>
 <li>Internet service provider or mobile carrier.</li>
 <li>Referring and exit pages.</li>
 <li>Date and time stamps.</li>
 <li>Clickstream data (including page clicks and scrolls).</li>
 <li>Location.</li>
 <li>Bandwidth speed.</li>
 <li>Software and registry keys.</li>
 <li>IP address and device ID.</li>
 <li>Information from cookies and similar technologies.</li>
</ul>
 
In addition to collecting personal data directly from Subscribers and other individuals, we collect information from social media companies as well as other companies with whom Subscribers and other individuals have a relationship (“Partners”). Whilst this information is generally aggregated/anonymous, we accept it may on occasion include personal data. Partners include Internet Service Providers, third parties that distribute the Service, online and offline data providers and voice assistant platform providers. We recommend that Subscribers and other individuals read the privacy policies of all organisations that process personal data relating to them. 

<h2 class="h3">How we use personal data</h2>

We use personal data of the categories under lit. a-q above to provide, promote and develop the Service. More specifically we use personal data to –

<ul>
 <li>Improve the Service by providing personalized content, language, help and instructions </li>
 <li>Customize the Service by location.</li>
 <li>Provide customer service assistance.</li>
 <li>Ask Subscribers to participate in surveys, products, services, news and events.</li>
 <li>Provide Subscribers with news, newsletters, updates, targeted advertising, promotions, sweepstakes and special offers. </li>
 <li>Better understand how Subscribers use the Service (including checking traffic patterns and what types of content are most popular).</li>
 <li>Receive and respond to submissions or correspondence. </li>
 <li>Use Subscriber submissions in accordance with the Terms of Use <a class="text-lowercase hyperlink" href="https://www.lionsgateplus.com/ie/en/termsofuse">https://www.lionsgateplus.com/ie/en/termsofuse</a> for the Service. </li>
 <li>Administer community postings (for example, chat and bulletin boards), including publishing screen names and other information provided by Subscribers (on the Internet or elsewhere). </li>
 <li>Repost comments about the Service, programmes and/or content on various online platforms and social media (for example, Twitter). </li>
 <li>Check email *opens*.</li>
 <li>Exercise and comply with legal rights.</li>
</ul>

<h2 class="h3">Our legal grounds to use personal data</h2>

	Necessary for the performance of a contract 
Where we use personal data to provide the Service to Subscribers or to otherwise perform our obligations and exercise our rights under the Terms of Use <a class="text-lowercase hyperlink" href="https://www.lionsgateplus.com/ie/en/termsofuse">https://www.lionsgateplus.com/ie/en/termsofuse</a> our legal ground is primarily that doing so is necessary for the performance of a contract with the Subscriber. 

 Legitimate interests 
Where we use personal data relating to individuals with whom we do not have a contract for the purposes of the Service, our legal ground is that doing so is necessary for the legitimate interest of operating and progressing our business. 

Similarly, where we use personal data relating to Subscribers outside the Terms of Use <a class="text-lowercase hyperlink" href="https://www.lionsgateplus.com/ie/en/termsofuse">https://www.lionsgateplus.com/ie/en/termsofuse</a> for the purposes of the Service (for example, the development and promotion of the service), our legal ground is that doing so is necessary for the legitimate interest of providing, developing and promoting our business. 

Where we send Subscribers emails (or other electronic messages) containing promotional material about the Service, our legal ground is that doing so is for necessary for the purposes of the legitimate interest of promoting our business.

Sometimes, we may use personal data if necessary for a third party's legitimate interest. Where required and appropriate, we or the third party will provide you with more information about any such legitimate interest.

We will also use personal data where we have a legitimate interest in establishing, exercising or defending our legal rights. 

Importantly, we will not use personal data on the grounds of a legitimate interest where the relevant individual or Subscriber's rights and freedoms override the legitimate interest. In addition, where we rely on a legitimate interest to use personal data, the individual or Subscriber to whom the personal data relates may object. To object please contact us at <a class="text-lowercase hyperlink" href="mailto:privacy@lionsgateplus.com">privacy@lionsgateplus.com</a>. 

 Consent 
If we need consent to use personal data (for example, for advertising cookies), we will request consent in a clear manner and explain for what purpose the personal data will be used. 
 
 Legal obligations 
Separately from providing, developing and promoting the Service, we will also use personal data when we are required to do so by law. Where that is the case, our legal ground is that the use of personal data is necessary to comply with a legal obligation.

<h2 class="h3">Consequences of not providing personal data</h2>

Subscribers are required to provide registration, contact and payment details in order to access the Service. We will not be able to provide the Service to Subscribers that do not provide this information.

<h2 class="h3">Automated decision-making</h2>

We use automated decision-making to provide Subscribers with the most relevant content and develop the Service. However, we do not use automated decision-making to make any legally significant decisions about individuals.

<h2 class="h3">Sharing personal data</h2>
Social media 
Subscribers and other individuals may engage with the Service through third-party social networks (for example, Facebook, Twitter and Pinterest). We may also allow Subscribers to access their accounts or specific content through social networks. Where Subscribers or other individuals engage or login through social media, we will share personal data with and receive personal data from the relevant social network. Where Subscribers or individuals engage or login through a social network, we recommend they read the relevant social network's privacy policy. 

 Partners
We share aggregated information with Partners. This information may include personal data.

 Service providers 
To help provide, develop and promote the Service, we share personal data with and receive personal data from the following types of service provider – 

<ul>
 <li>Distributors.</li>
 <li>Payment processors.</li>
 <li>Fraud and credit risk service screening providers.</li>
 <li>Advertising partners.</li>
 <li>Analytics service providers. </li>
 <li>IT providers. </li>
 <li>Professional services (for example, accountants and lawyers). </li>
</ul>

We have contracts in place with these service providers that strictly govern how they may use the personal data (listed above lit-a-q) we share with them.

Group companies and business reorganizations 
We will share personal data (listed above lit. a-q) with our group companies where necessary to provide, develop or promote the Service. 

We will share personal data with potential buyers, group companies and/or business partners where necessary for a reorganization, restructuring, merger, sale or transfer of assets involving Starz and/or the Service. 

 Legal rights and obligations 
We will share personal data where necessary to establish, exercise or defend our legal rights. 

We will also share personal data where required by the courts, regulators or law. 

<h2 class="h3">Cookies and similar technologies</h2>
 
Cookies 
Cookies are small information files that we place on the devices used to access the Service. The types of Cookies we use are described below:

 Essential Cookies. Our sites and services wont work properly without essential cookies. For example, We and our Service Providers may use essential cookies to identify and authenticate Subscribers. We also use essential cookies to enforce our Terms of Use, maintain the security of our sites and services.
 Performance Cookies. Performance cookies collect information about how visitors use our sites and services, for example, which pages users visit most often and error messages received by users from web pages. Performance cookies don’t collect information that identify a visitor and the information these cookies collect is aggregated and anonymized.
 Advertising Cookies. Advertising cookies are used to deliver advertisements relevant to visitors based on the visitor’s interests and to measure the effectiveness of advertising campaigns. Theses cookies are usually placed by advertising networks with our permission. They remember that you have visited the website and this information is shared with other organizations such as advertisers.

 Embedded scripts 
An embedded script is a programming code used to collect information about how Subscribers use the Service. The embedded script is temporarily downloaded onto devices used to access the Service. The embedded script is only active whilst the device is used to access the Service.

 Web beacons 
A web beacon is a small graphic image or programming code that is included in some parts of the Service. 

 Advertising 
We, and selected third-party advertising partners, use cookies, embedded scripts and web beacons to present adverts through the Service. Our advertising partners may also employ other similar types of technologies.

We have not implemented a response to browser-based Do Not Track signals. 

For more information about advertising and your ability to opt-out of targeted advertising from such third parties, please visit the Network Advertising Initiative (www.networkadvertising.org) and/or the Self-Regulatory Program for Online Behavioral Advertising (www.aboutads.info/choices).

Analytics 
We, and selected analytics service providers, use cookies, embedded scripts and web beacons to provide analytical information about the Service. Our analytics service providers may also employ other similar types of technologies.

 Consent 
Where we need to seek consent for analytics and advertising cookies, embedded scripts, web beacons and other similar technologies, we will let you know. 

<h2 class="h3">Children </h2>

We do not knowingly collect or use any personal data relating to individuals under the age of 13 – except if necessary on a one-time basis in response to a specific issue. If you are a parent or guardian that has discovered that your child under 13 has submitted personal data without your permission, please contact us immediately at privacy@lionsgateplus.com. 

If we require consent from a child under the age of 16, we will ask the child's parent or guardian. 

<h2 class="h3">International transfers </h2>

We routinely transfer personal data from the European Economic Area ("EEA") to the United States. Where we transfer personal data to the United States we normally use the Privacy Shield or approved standard contractual clauses safeguards. Similarly, if we transfer personal data to any other country outside the EEA, we will use standard contractual clauses where necessary.
If you would like more information about how we transfer personal data outside the EEA and the safeguards we use, please contact us at privacy@lionsgateplus.com.

<h2 class="h3">Data retention </h2>

We keep personal data relating to a Subscriber up until the end of their subscription. We will only keep personal data relating to a Subscriber after their subscription where necessary to exercise our legal rights and fulfil our legal obligations. 

We only keep information relating to any other individuals whilst it is need for our business purposes and/or to comply with our legal obligations or exercise our legal rights.

<h2 class="h3">Rights</h2>

Subscribers and other individuals have the rights to – 

<ul>
 <li>Information about how we use personal data (which is what this policy is for).</li>
 <li>Access to personal data.</li>
 <li>Object to direct marketing and the use of personal data based on the grounds of legitimate interest.</li>
 <li>Erasure of personal data.</li>
 <li>Portability of personal data.</li>
 <li>Withdraw consent where our use of personal data is based on consent.</li>
 <li>Rectification of personal data.</li>
 <li>Restriction of personal data. </li>
 <li>Complain to your supervisory authority. </li>
</ul>

Please note that the Account Management section of the Service provides access to a broad range of payment, contact and account information (including the content you have viewed and rated). You may access further information or exercise the other rights listed above using the contact details below. 

Please be aware that these rights are not absolute and there may be some situations in which they cannot be exercised or they are not relevant. The Information Commissioner's Office has more information about each of these rights at <a class="text-lowercase hyperlink" href="http://www.ico.org.uk">www.ico.org.uk</a>. 

<h2 class="h3">Exercising Your Rights </h2>

Exercising Your Rights. To submit a request to know, delete, or opt-out, please visit <a class="text-lowercase hyperlink" href="https://submit-irm.trustarc.com/services/validation/7c11ddc5-703e-4661-ba8c-85ef940aa717" target="_blank">Lionsgate+ Privacy Rights Manager</a>.
<h2 class="h3">Contact and Data Protection Office</h2>

If you need assistance with any of the issues covered in this policy and are unable to resolve your question via the "Help" feature of the Service, please contact us at StarzPlay Direct UK Limited, 45 Mortimer Street, London, W1W 8HJ, United Kingdom <a class="text-lowercase hyperlink" href="mailto:privacy@lionsgateplus.com">privacy@lionsgateplus.com</a>. 

If you would like to contact our Data Protection Office, please email privacy@lionsgateplus.com.

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