Consumer Privacy Policy

Effective as of January 1, 2020

Last updated July 1, 2024

Introduction

National CineMedia, LLC (“NCM,” “we,” “our,” or “us”) respects the privacy of your information. This Privacy Policy is designed to assist you in understanding how we collect, record, use, share, and safeguard your information. This Privacy Policy applies to individuals who access our websites, mobile applications, and social media pages(collectively, “Sites”) and any of our online and, where required, offline services (collectively, “Services”).

From time to time, we may change this Privacy Policy. If we do, we will post an amended version on this webpage. Please review this Privacy Policy periodically.

This Privacy Policy covers the following topics:

1. Personal Data We Collect

2. How We Use Your Personal Data

3. How We Share Your Personal Data

4. Cookies and Other Tracking Technologies

5. Universal Opt-Out Mechanisms

6. Security

7. Third Party Links

8. Children’s Privacy

9. Your State Privacy Rights and Additional Disclosures

10. Notice to California Residents

11. Accessibility

12. How to Contact Us

1. Personal Data We Collect

We collect personal data from you through your use of the Sites and Services. Personal data is information that is linked or reasonably linkable to an identified or identifiable individual. We collect the following types of personal data:

Personal Data You Provide

Depending on how you interact with our Sites and Services, we will collect the following personal data that you voluntarily provide to us for the following purposes:

• Sign Up. If you sign up for access to our Noovie ^® app, you will provide us with your social account information or your email address and password for future login purposes.
• Create an Account. If you create an account through our Campaign Manager, you will provide us with your name, email address, phone number, company name, company address, and a password for future login purposes.
• Sign In. When you sign into our app or your account, you will provide us with your login credentials.

Enter a Promotion. If you enter a promotion, you will provide us with information that may include, depending on the nature of the promotion, your name, address, email address, social account information, phone number, company name, title, age/date of birth, and Social Security Number/Tax Identification Number.

• Create Your Campaign.To create your advertising campaign, you will provide us with your name, email address, phone number, company name, company address, and financial information.
• Upload Your Media.
  • Shopify provides the functionality to upload your media through our Campaign Manager site. Please review Shopify’s privacy policy here regarding the information it collects, records and stores.
  • MASV provides the functionality to upload your media through our File Delivery Upload page. Please review MASV’s privacy policy here regarding the information it collects, records and stores.

• Make a Payment.
  • Shopify provides the functionality to make a payment through our Campaign Manager site. Please review Shopify’s privacy policy here regarding the information it collects, records and stores.
  • Hitachi Solutions provides the functionality to make a payment through https://payments.ncm.com. Please review Hitachi Solutions’ privacy policy here regarding the information it collects, records and stores

• Contact Us. If you contact us, you will provide us with your name, email address, company name, and company zip code and have the option to provide us with your city, state and phone number.
• Contact the Audit Committee. If you contact the Audit Committee regarding accounting, internal accounting controls or auditing matters, you have the option to provide us with your name, email address, phone number, company relationship, and any other information you provide in your message.
• Contact the Board. If you contact our board of directors, you have the option to provide us with your name, email address, company relationship, and any other information you provide in your message.
• Sign Up for Email. If you sign up to receive emails from us, you will provide us with your email address.
• Chat. Gorgias provides the functionality for our chat feature. Please review Gorgias’ privacy policy here regarding the information it collects, records and stores.
• Careers. UKG provides the functionality for our application portal. Please review UKG’s privacy policy here regarding the information it collects, records and stores.

Personal Data as You Navigate Our Sites

We automatically collect certain personal data through your use of our Sites and our use of cookies and other tracking technologies, such as the following:

• Usage Information. For example, the pages on the Sites you access, the frequency of access, and what you click on while on the Sites.
• Device/Social Account Information.For example, hardware model, operating system, application version number, IP address, browser, and social account information.
• Mobile Device Information. Mobile advertising ID and aggregated information about whether the Sites are accessed via a mobile device or tablet, the device type, and the carrier.
• Location Information. Location information from visitors to the Sites on a city-regional basis.

For more information on our cookie usage see our “Cookies and Other Tracking Technologies” section below.

Personal Data We Collect About You from Other Sources

In some cases, we may receive personal data about you and your household from other sources (such as movie ticket sellers, movie exhibitors and data brokers). This includes mobile advertising IDs, device and network identifiers and configurations, device attributes, names, email addresses, IP addresses, phone numbers, precise geo-location with date and time stamps, and information about places visited, purchases made, and personal attributes (such as age, gender, interests, and preferences).

2. How We Use Your Personal Data

We use your personal data for the following purposes:

• Your Interactions with Us and the Sites.

We use your personal data to provide a more meaningful experience to you when you use or access the Sites or Services, or you interact with us. For example, we use your personal data when you contact us, use any of our social media platforms, or place orders with us. We also use your personal data to maintain your progress in our games, to display that progress on leaderboards, and to provide You with rewards (e.g., Popcorn) in connection with your gameplay. In addition, we use personal data in our promotions to collect entry information, select winners, award prizes, and comply with applicable laws relating to announcing winners and tax reporting.

• Developing Profiles and Creating Advertising Segments.

We use personal data to create pseudonymized profiles at the personal, device, or household level utilizing characteristics, behaviors, attributes, preferences, and interests that we know or infer. We aggregate profiles having common characteristics into segments that we think may be of interest to advertisers. We make information about these segments available to prospective clients and their agencies through demand side platforms. Clients and their agencies engage demand side platforms to deliver targeted advertising (including ads related to housing, employment, or financial or lending services) to one or more segments, and the demand side platforms facilitate the delivery of targeted advertising on publisher sites (such as websites, mobile applications, and Internet-connected televisions) that make advertising inventory available through supply side platforms.

• Delivering Personalized Advertising to You.

In addition, we use personal data to deliver targeted advertising to you, including on behalf of our clients. Targeted advertising, sometimes referred to as cross-context behavioral advertising, involves the targeting and display of advertising to you where the advertisement is selected based on personal data obtained from your activities over time across businesses, distinctly-branded websites, applications, or services, other than your intentional interaction with us, our distinctly-branded websites, applications, or services (including to predict your preferences or interests). To better target advertising, we use an algorithm to create profiles based on what we know or can infer about you from information that we collect or receive. We maintain profiles in a third-party data management platform that pseudonymizes each profile by rendering the personal data no longer attributable to you without the use of additional information.

• Measuring Success of Advertising Campaigns.

We also use pseudonymized information to measure the success of advertising campaigns. For example, we make pseudonymized information available to attribution and measurement providers to help us understand your interaction with an ad and your purchase behavior after seeing an ad. We then provide metrics about targeted advertising campaign performance to clients and their agencies.

In addition, we may use all the personal data we collect in accordance with applicable law such as to:

• Maintain and improve our Sites and Services;
• Protect the security and integrity of our Sites and Services;
• Investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of our Terms of Use, and to otherwise fulfill our legal obligations;
• Monitor compliance with and enforce this Privacy Policy and any applicable agreements and policies;
• Defend our legal rights and the rights of others;
• Fulfill any other purposes for which you provide it;
• For any purpose that is reasonably necessary to or compatible with the original purpose for which we collected the personal data as disclosed to you; and
• Comply with applicable law.

3. How We Share Your Personal Data

We may share the personal data that we collect about you in the following ways:

• With vendors who perform data or Site-related services on our behalf (e.g., email, hosting, maintenance, backup, analysis, etc.);
• To the extent that we are required to do so by law;
• With vendors to prepare, deploy and analyze advertising content and campaigns;
• In connection with any legal proceedings or prospective legal proceedings;
• With co-sponsors and prize providers in connection with promotions we offer;
• To establish, exercise, or defend our or a third party’s legal rights, including providing information to others for the purposes of fraud prevention;
• With any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal data where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal data;
• With any other person or entity as part of any business or asset sale, equity transaction, merger, acquisition, bankruptcy, liquidation, or similar proceeding, or in preparation for any of these events;
• With any other person or entity where you consent to the disclosure; and
• For any other purpose disclosed by us when you provide the personal data or for any other purpose we deem necessary, including to protect the health or safety of others.

For more information on how we sell or share personal data with third parties, see our “Your State Privacy Rights and Additional Disclosures” section below.

4. Cookies and Other Tracking Technologies

How We Use Cookies

Like many other companies, we use cookies and other tracking technologies (collectively, “Cookies”). Cookies are small files of information that are stored by your web browser software on your computer hard drive, mobile or other devices (e.g., smartphones or tablets).

We use Cookies to:

• Estimate audience size and usage patterns;
• Understand and save your preferences for future visits, allowing us to customize the Sites and Services to your individual needs;
• Advertise new content and services that relate to your interests;
• Keep track of advertisements and search engine results;
• Compile aggregate data about site traffic and site interactions to resolve issues and offer better site experiences and tools in the future; and
• Recognize when you return to the Sites.

We set some Cookies ourselves, while separate entities set other Cookies. We use Cookies that other entities set to provide us with useful information, to help us improve our Sites and Services, to conduct advertising, and to analyze the effectiveness of advertising. For example, we use Cookies from Google and other similar companies.

How You Can Opt Out of Cookies

• Browser Settings

You can block Cookies by changing your Internet browser settings to refuse all or some Cookies. If you choose to block all Cookies (including essential Cookies) you may not be able to access all or parts of the Sites.

You can find out more about Cookies and how to manage them by visiting www.AboutCookies.org or www.allaboutcookies.org.

• Platform Controls

You can opt out of Cookies set by Google by following the instructions found at https://adssettings.google.com .

• Advertising Industry Resources

You can understand which entities have currently enabled Cookies for your browser or mobile device and how to opt out of some of those Cookies by accessing the Network Advertising Initiative’s website or the Digital Advertising Alliance’s website . For more information on mobile specific opt-out choices, visit the Network Advertising Initiative’s Mobile Choices website .

Please note these opt-out mechanisms are specific to the device or browser on which they are exercised. Therefore, you will need to opt out on every browser and device that you use.

Google Analytics

We use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses Cookies to help us analyze how users interact with the Sites and Services, compile reports on their activity, and provide other services related to their activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a returning visitor, and any referring website. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt out of tracking of analytics by Google, click here .

Google reCAPTCHA

We use Google reCAPTCHA, a free service provided by Google, Inc., to protect our Sites from spam and abuse. Google reCAPTCHA uses advanced risk analysis techniques to decipher humans and bots. Google reCAPTCHA works differently depending on what version is deployed. For example, you may be asked to check a box indicating that you are not a robot or Google reCAPTCHA may detect abusive traffic without user interaction. Google reCAPTCHA works by transmitting certain types of information to Google, such as the referrer URL, IP address, visitor behavior, operating system information, browser and length of the visit, cookies, and mouse movements. Your use of Google reCAPTCHA is subject to Google’s Privacy Policy and Terms of Service . More information as to Google reCAPTCHA and how it works is available here .

5. Universal Opt-Out Mechanisms

The Sites recognize the Global Privacy Control (“GPC”) signal. If you are using a browser setting or plug-in that sends a GPC opt-out preference signal to each website you visit, we will treat that as a valid request to opt out. To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs . If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.

Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the Sites do not currently interpret, respond to or alter their practices when they receive “Do Not Track” signals.

6. Security

We maintain commercially reasonable security measures to protect the personal data we collect and store from loss, misuse, destruction, or unauthorized access. However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your personal data, we cannot guarantee absolute security.

7. Third Party Links

The Sites may contain links that will let you leave the Sites and access another website. Linked websites are not under our control. We accept no responsibility or liability for these other websites.

8. Children’s Privacy

The Sites and Services are not intended for children under 13 years of age. We do not knowingly collect, use, or disclose personal data from children under 13.

9. Your State Privacy Rights and Additional Disclosures

Depending on the state in which you reside and the capacity in which you interact with us, you may have certain privacy rights regarding your personal data. If you are a California resident, please see our “Notice to California Residents” section below. For other state residents, your privacy rights may include (if applicable):

• The right to confirm whether or not we are processing your personal data and to access such personal data and the categories of personal data we are processing or have processed;
• The right, at our option, to obtain a list of specific third parties, other than natural persons, to which we have disclosed your personal data or any personal data;
• The right to obtain a copy of your personal data that we collected from and/or about you in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another controller without hindrance, where the processing is carried out by automated means;
• The right to delete personal data that we collected from and/or about you, subject to certain exceptions;
• The right to correct inaccurate personal data that we maintain about you, subject to certain exceptions;
• The right, if applicable, to opt out of the processing of your personal data for purposes of (1) targeted advertising; (2) the “sale” of your personal data (as that term is defined by applicable law); and (3) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
• If we are required by applicable law to obtain your consent to process sensitive personal data, the right to withdraw your consent; and
• The right not to receive discriminatory treatment by us for the exercise of your privacy rights.
• We sell and share online identifiers to third-parties, such as advertising networks and analytics and measurement companies. We do not use personal data for profiling in furtherance of decisions that produce legal or similarly significant effects concerning individuals.

To exercise your rights, please submit a request through our interactive webform available here or by calling us at 833-626-2272. If legally required, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the individual on whose behalf you are making such request. To do so, we may ask you to verify data points based on information we have in our records. If you are submitting a request on behalf of another individual, please use the same contact methods described above. If we refuse to take action regarding your request, you may appeal our decision through our interactive webform available here or by calling us at 833-626-2272.

10. Notice to California Residents

The California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (“CCPA”), requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, sale, sharing, and retention of personal information and of the rights of California residents regarding their personal information. This section of the Privacy Policy is intended solely for, and is applicable only to, California residents. If you are not a California resident, this section does not apply to you and you should not rely on it.

The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified or aggregated informationor lawfully obtained, truthful information that is a matter of public concern. For purposes of this “Notice to California Residents” section we will refer to this information as “Personal Information.”

If you are a California resident and a current or former employee, officer, director, owner, job applicant, or independent contractor of ours, please see our privacy notice available here for more information on our collection and use of your Personal Information in that capacity.

Notice at Collection of Personal Information

Consumers

We currently collect and, in the 12 months prior to the Last Updated Date of this Privacy Policy, have collected the following categories of Personal Information when you interact with us in a consumer capacity:

• Identifiers (name, postal address, online identifier, Internet Protocol address, email address, account name, Social Security number, tax ID number)
• Unique personal identifiers (device identifier; cookies, pixel tags, mobile ad identifiers, or other similar technology; unique pseudonym or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device)
• Personal information described in California’s Customer Records statute (California Civil Code § 1798.80(e)) (signature, telephone number, as well as the categories listed in “Identifiers” category above)
• Commercial information (records of personal property, products or services purchased, obtained or considered; other purchasing or consuming histories or tendencies; or other commercial information)
• Internet or other electronic network activity information (information regarding consumer’s interaction with website, application or advertisement)
• Geolocation data
• Audio, electronic, visual, thermal, olfactory, or similar information
• Professional or employment-related information (including employment history)
• Education information
• Inferences drawn from above information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
• Sensitive Personal Information (Personal Information that reveals a consumer’s Social Security number; account log-in in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation

We collect Personal Information directly from California residents and their devices directly, movie exhibitors, and ticket sellers, advertising networks, internet service providers, data analytics providers, operating systems and platforms, and data brokers. We do not collect all categories of Personal Information from each source.

In addition to the purposes stated above in the section “How We Use Your Personal Data” we currently collect and have collected the above categories of Personal Information for the following business or commercial purposes:

• Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes
• Debugging to identify and repair errors that impair existing intended functionality
• Short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of your current interaction with us
• Performing services, including facilitating game play and disclosing promotion winners, maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, providing analytic services, or providing similar services
• Providing advertising and marketing services, except for cross-context behavioral advertising, to you
• Undertaking internal research for technological development and demonstration
• Undertaking activities to verify or maintain the quality of a service or device that is owned or controlled by us, and to improve, upgrade, or enhance the service or device
• Advancing our commercial or economic interests

Sale, Sharing, and Disclosure of Personal Information

The CCPA defines “sale” as the transfer of Personal Information for monetary or other valuable consideration. Although we do not “sell” Personal Information as that term may be commonly interpreted, we engage in online activities that may constitute a sale or a share of Personal Information under California law. This may include showing you advertisements on other websites or applications.

The following table identifies the categories of Personal Information that we sold or shared to third parties in the 12 months preceding the Last Updated Date of this Privacy Policy and, for each category, the categories of third parties to whom we sold or shared Personal Information:

We sold or shared Personal Information to third parties to advance our commercial and economic interests.

The following table identifies the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding the Last Updated Date of this Privacy Policy and, for each category, the categories of recipients to whom we disclosed Personal Information.

We disclosed Personal Information for the business or commercial purposes described above.

Business-to-Business

We currently collect and, in the 12 months prior to the Last Updated Date of this Privacy Policy, have collected the following categories of Personal Information when you interact with us in a business-to-business capacity:

• Identifiers (name, postal address, online identifier, Internet Protocol address, email address, Social Security number, tax ID number)
• Unique personal identifiers (device identifier; cookies or other similar technology; customer number; telephone numbers, or other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device)
• Personal information described in California’s Customer Records statute (California Civil Code § 1798.80(e)) (signature, telephone number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, as well as the categories listed in “Identifiers” category above)
• Characteristics of protected classifications under California or federal law (race, color, sex/gender, military or veteran status, political affiliations or activities)
• Commercial information (records of personal property, products or services purchased, obtained or considered; other purchasing or consuming histories or tendencies; or other commercial information)
• Internet or other electronic network activity information (information regarding consumer’s interaction with website, application or advertisement)
• Geolocation data
• Professional or employment-related information (including employment history)
• Education information
• Sensitive Personal Information (Personal Information that reveals a consumer’s Social Security; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; racial or ethnic origin, religious or philosophical beliefs

We collect Personal Information directly from California residents (such as email correspondence, client meetings, etc.), third parties (such as your organization and event organizers, Internet service providers, and operating systems and platforms), industry or prospecting reports, and social media platforms (such as LinkedIn). We do not collect all categories of Personal Information from each source.

In addition to the purposes stated above in the section “How We Use Your Personal Data” we currently collect and have collected the above categories of Personal Information for the following business or commercial purposes:

• Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes
• Debugging to identify and repair errors that impair existing intended functionality
• Performing services, vendor selection and setup, credit checks, payment processing and collection, and enabling account access and purchases
• Advancing our commercial or economic interests, including lead generation, sales tracking, marketing, and analytics

We did not sell or share this Personal Information to third parties in the 12 months preceding the Last Updated Date of this Privacy Policy. The following table identifies the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding the Last Updated Date of this Privacy Policy and, for each category, the categories of recipients to whom we disclosed Personal Information.

We disclosed Personal Information for the business or commercial purposes described above.

We do not knowingly sell or share the Personal Information of consumers under 16 years of age.

Retention of Personal Information

We retain your Personal Information for as long as necessary to fulfill the purposes for which we collect it, such as to provide you with the service you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us.

Your Rights

If you are a California resident, you have the following rights with respect to your Personal Information:

1. The right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which we collected Personal Information, the business or commercial purpose for collecting, selling or sharing Personal Information (if applicable), the categories of third parties to whom we disclose Personal Information (if applicable), and the specific pieces of Personal Information we collected about you;
2. The right to delete Personal Information that we collected from you, subject to certain exceptions;
3. The right to correct inaccurate Personal Information that we maintain about you;
4. If we sell or share Personal Information, the right to opt out of the sale or sharing;
5. If we use or disclose sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations, the right to limit our use or disclosure; and
6. The right not to receive discriminatory treatment by us for the exercise of privacy rights the CCPA confers.

How to Submit a Request to Know, Delete, and/or Correct

You may submit a request to know, delete, and/or correct through our interactive webform available here or by calling us toll free at 833-626-2272 . If you have an account with us, you must provide your password when you submit your request to know, delete, and/or correct.

If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, we will require additional information to verify your authority to act on behalf of the California resident.

Our Process for Verifying a Request to Know, Delete, and/or Correct

We will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. Our verification process may differ depending on whether you maintain a password-protected account with us.

If you maintain a password-protected account, we may verify by requiring you to provide your password. Prior to disclosing or deleting the Personal Information, we may ask you to re-authenticate yourself with respect to that account.

If you do not maintain a password-protected account, or if you are an account-holder but we suspect fraudulent or malicious activity with your account, we will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure, deletion, or correction as applicable. To do so, we will ask you to verify data points based on information we have in our records concerning you.

Right to Opt Out of Sale or Sharing of Personal Information

If you are a California resident, you have the right to direct us to stop selling or sharing your Personal Information.

You may submit a request to opt out of sales or sharing through our interactive webform available by clicking here. You also may submit a request by calling us toll free at 833-626-2272. If you have enabled certain privacy controls on your browser (such as a plugin), we will also treat that as a valid request to opt out. Please see the “Universal Opt-Out Mechanisms” section above for more information.

Right to Limit Use and Disclosure of Sensitive Personal Information

California residents have the right to limit our use or disclosure of their sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations. You may submit a request to limit our use or disclosure of your sensitive Personal Information through our interactive webform available by clicking here .

Shine the Light Law

We do not disclose personal information obtained through our Sites or Services to third parties for their direct marketing purposes. Accordingly, we have no obligations under California Civil Code § 1798.83.

11. Accessibility

We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities. If you wish to access this Privacy Policy in an alternative format, please contact us as described below.

12. How to Contact Us

For questions or concerns about our privacy policies or practices, please contact us at:

833-626-2272
6300 S. Syracuse Way, Suite 300
Centennial, CO 80111
privacy@ncm.com