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Cinereach Privacy Policy
Adopted on July 09, 2018.

SCOPE
Cinereach Ltd. (“Cinereach”) is an independent film company and private foundation dedicated to vital, artful filmmaking.

This privacy policy (the “Policy”) describes the information Cinereach collects from users of its website, cinereach.org (“Website” or “Site”) and how that information is used. Your privacy is important to us and we are committed to protecting your information, and this Policy is designed to help you understand Cinereach’s approach to the collection and use of Personal Information (as defined below) and General Information (as defined below) received from users of the Site. This Policy also applies to all information received, both online and offline, via the Cinereach submission portal (the “Cinereach Portal”) when active or film-specific websites owned or operated by Cinereach linking to this Policy (“Film Sites”, together with the Site and the Cinereach Portal, the “Cinereach Platforms”), as well as through any electronic, written or oral communications with Cinereach.

“Personal Information” means any type of information that could be used to identify you and includes your name, mailing address, telephone number, and e-mail address. Such voluntarily disclosed information enables Cinereach to process applications for support or fulfill requests for information. Your Personal Information will not be publicly available to other users through the Cinereach Platforms.

When you visit, access and/or use the Cinereach Platforms, we may also collect additional information either directly or through Third-Party Service Providers that do not personally identify you (“General Information”). General Information may include your internet protocol address, internet service provider, user’s browser type, the website that referred you to the Cinereach Platforms, as well as other information automatically collected using technical methods, including but not limited to cookies and pixel tags.

ACCEPTANCE OF TERMS
By visiting the Cinereach Platforms, you consent to the terms of this Policy and to Cinereach’s collection and use of information in accordance with this Policy. If you do not agree with the terms of this Policy, please refrain from using the Cinereach Platforms, or limit your use of the Cinereach Platforms to those elements that do not require transmitting Personal Information. You can access content on our Cinereach Platforms and use many of the features without revealing any Personal Information.

WHAT INFORMATION DO WE COLLECT AND HOW DO WE USE IT?
Cinereach collects information for purposes of (i) enhancing user experience and usefulness of the Site; (ii) processing applications for potential support; and (iii) providing subscribers to our email list with information on Cinereach activities.

Cinereach collects Personal Information and General Information both directly and indirectly through outside companies or individuals (“Third Party Service Providers”).

Cinereach will not sell, rent, share, exchange, or otherwise disclose your Personal Information with anyone else, except as necessary to serve the purposes noted above. In an effort to better understand visitors to our Site and other Cinereach Platforms, we may analyze General Information in aggregate form. In addition Third Party Service Providers may perform some functions on Cinereach’s behalf, including conducting traffic analytics, maintaining contact databases or distributing electronic communications. These Third-Party Service Providers will have access to Personal Information only as necessary to perform their functions and to the extent permitted by law. Other than Third-Party Service Providers, Cinereach will keep all of your Personal Information private and will not share it with any third party unless you have authorized us to or we are legally compelled to do so by court order or other government or law enforcement authority or regulatory agency.

We hold information about you that is collected through the Cinereach Platforms until the later of (x) when it is no longer necessary for the purposes for which it is being processed or (y) when no longer needed for archival / research purposes, unless the user contacts us to request earlier deletion as permitted under the terms herein. Such time limits shall be subject to periodic review and revision by us.

OPTING OUT OR UNSUBSCRIBING
Cinereach utilizes Google Analytics to collect demographics and interests statistics to help us improve user experience on the Cinereach Platforms. These statistics come from third-party cookies. A “cookie” is a small data file that certain websites write to a computer’s hard drive when a website is accessed. When a cookie is present, Google collects any demographic and interest statistics available in the cookie. These statistics are also shared with Google for benchmarking purposes. All users may opt-out of Google Analytics here.

Cinereach also ensures that users who have previously opted in to email communications have the opportunity to opt out of receiving future automated communications. If you wish to unsubscribe from a Cinereach-related newsletter received from a Third Party Service Provider, please follow the Third Party Service Provider’s instructions located in the publication to unsubscribe.

NOTICE TO INTERNATIONAL USERS
The Cinereach Platforms and servers are operated in the United States. If you are located outside of the United States, please be aware that data protection laws of New York and/or the United States may not be as comprehensive or the same as those in the country where you are located. By using the Cinereach Platforms, you agree and consent that your Personal Information, General Information or other data you provide us may be transferred to facilities in the United States or elsewhere, and used or shared with Third-Party Service Providers.

PROTECTING CHILDREN’S PRIVACY
We do not knowingly collect Personal Information from children under the age of 13 through the Cinereach Platforms. If you are under 13, please do not give us any Personal Information. If you have reason to believe that a child under the age of 13 has provided Personal Information to us, please contact us and we will endeavor to delete that information from our databases.

CONTACT US
By visiting the Cinereach Platforms, you consent to the terms of this Policy and to the collection and use of information by Cinereach. This Policy was last updated on July 09, 2018 and Cinereach reserves the right to modify this Policy without prior notification to users.

You may also contact us at [email protected] or by postal mail at 126 Fifth Avenue, Fifth Floor, New York, NY 10011. We hope that we can address any concerns or complaints but if you are a resident of a country in the European Economic Area, you may also lodge complaints with a supervisory authority, particularly the supervisory authority in your place of residence, place of work or in the place where any alleged improper acts occurred.

FOR RESIDENTS OF THE EUROPEAN ECONOMIC AREA

Why We Are Able to Collect and Use Your Personal Information
We rely on our legitimate interests and the legitimate interests of our users as the legal basis for processing data concerning users of the Site who are residents of the European Economic Area (or “EEA”). Specifically, it is necessary for us to process personal data in order to pursue our legitimate interests in ensuring the proper operation and furthering our understanding of the Site and services accessed through the Site. Also, for people who use the Site or access services on behalf of one of our users, we collect and process information as a necessary part of the services that we provide to our users.

In some cases, where we ask for your consent to use information about you, your consent acts as the legal basis for our use of that data. In those cases, you have the right to withdraw your consent at any time. If you would like to withdraw your consent, please contact us as provided in this Policy under “Contact Us.”

Transfer of Your Personal Information Outside of the European Economic Area
For the purposes described in this Policy, we may transfer personal information out of the EEA to the United States or other non-EEA countries. These countries may not have enacted laws that provide the same level of protection of personal information as the laws of the EEA, and the European Commission has not issued any formal decision that these countries provide an adequate level of protection of personal information.

In order to ensure that adequate protections are provided for personal information concerning you, we will perform these transfers of personal information outside of the EEA under standard contractual clauses approved by the European Commission, as permitted pursuant to Article 46(2)(d) and (5) of the General Data Protection Regulation (Regulation 2016/679). If you would like more information about our transfer of data outside of the EEA or copies of relevant documents, please contact us as provided in this Policy under “Contact Us.”

Rights of Residents of the European Economic Area
If you are a resident of a country within the EEA, you have certain individual rights under the General Data Protection Regulation (Regulation 2016/679) or related local legislation. You have the right to obtain confirmation from us as to whether or not we process personal information about you. And if we do process your personal information, your other rights include the right to: (a) access your personal information and receive certain information about our privacy practices; (b) have us correct incorrect information that we hold concerning you, or to complete incomplete information; (c) request that we erase information concerning you and to have that information erased under certain conditions; (d) restrict our processing of information concerning you under certain conditions; (e) object to our processing of information concerning you under certain conditions; (f) object to our use of information concerning you for direct marketing, or for profiling relating to direct marketing; (g) receive personal information that you provided to us in a structured and commonly used, electronic format and (h) transmit that information to another entity, in certain situations.

If you would like to exercise any of these rights, please contact us as provided in this Policy under “Contact Us.” Please understand that, before responding to your request, we may ask you for additional information in order to verify your identity.

We may not be obligated to fulfill your request to exercise your rights if applicable local laws restrict us, or if fulfilling your request would negatively impact the rights and freedoms of other individuals. We may decline to fulfill requests or charge a reasonable fee based on our administrative costs if requests are clearly excessive or unfounded, and particularly in cases where requests are repetitive.