Jujamcyn Theaters LLC Privacy Policy

Effective Date of this Privacy Policy: February 15, 2023

This Privacy Policy describes the policies of Jujamcyn Theaters LLC and its majority-owned subsidiaries (collectively, “Jujamcyn“, “we”, “our” or “us”) regarding the collection, use and disclosure of your information received directly by us from you or indirectly by us through various third party sources or through your use of various services that we may offer (“Services”). This Privacy Policy does not apply to our subsidiary, Lucky Seat, LLC. For Lucky Seat’s privacy policy, please go to www.luckyseat.com.

Contents

What Does This Privacy Policy Cover?

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This Privacy Policy covers our processing of Personal Data. As used in this Privacy Policy, “Personal Data” means any information that can be used to individually identify a person, such as your name, residential address, city, state, and zip code, date of birth, and e-mail address, as well as information that is reasonably capable of being associated with, or could reasonably be linked to you or your device. “Processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure, whether or not by automated means.

This Privacy Policy also covers our treatment of any Personal Data that our service providers, contractors, and other third parties share with us.

This Privacy Policy does not apply to the practices of entities that we do not control (including, without limitation, our Official Ticketing Platform and Third Party Platforms), and their sites, services or applications, or to individuals who we do not employ or manage (all of the foregoing, “Third Parties”). While we attempt to provide access only to those Third Parties that share our respect for your privacy, we cannot take responsibility for the content, actions or privacy policies of those Third Parties. We encourage you to carefully review the privacy policies of any Third Parties you access. Our Site (as defined below) may contain links to third-party internet sites (such as a link to our Official Ticketing Platform), which are not owned or operated by us. We provide such links only as a convenience. If you provide any Personal Data through any such third-party site, your transaction will occur on such third party’s site (not the Site) and the Personal Data you provide will be collected by, and controlled by the privacy policy of, that third party. We are not responsible for the privacy practices or the content of such third-party sites, including such sites’ use of any Personal Data that you provide to them. We strongly encourage you to become familiar with the privacy practices of those sites.

Our Services are provided in the United States. By using our Services, you consent to the transmission of your Personal Data to and in the United States.

If you are a resident of the European Union, United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under European Union Regulation (EU) No. 2016/679 of 27 April 2016, also known as the General Data Protection Regulation or GDPR (the “GDPR”) with respect to your Personal Data, as outlined below. Jujamcyn Theaters LLC is the controller of your Personal Data processed in connection with any website or service that we directly control, manage or operate for purposes of the GDPR.

If you are a resident of the State of California, you may have additional rights under the California Consumer Privacy Act of 2018, as amended (the “CCPA”), as outlined below.

If you have any questions about this Privacy Policy or whether any of the following applies to you, please contact us at [email protected].

Summary of Categories of Personal Data Collected, Disclosed and Sold/Shared Within Last 12 Months

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A. Identifiers

Types of Personal Data Collected

Collected from customers, ticketing platforms, service providers, and business partners

  • real name
  • postal address
  • e-mail address
  • unique personal identifier
  • telephone number
  • IP address

Disclosed: YES

Disclosed to service providers, advertising partners, analytics partners, and business partners

  • real name
  • postal address
  • e-mail address

Disclosed to business partners in connection with administration of loyalty rewards program

  • unique personal identifier

Shared for Cross-Context Behavioral Advertising or Sold: YES

Sold to advertising partners

  • real name
  • postal address

Shared with service providers and advertising partners

  • real name
  • postal address
  • e-mail address

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code §1798.80(e))

Types of Personal Data Collected

Collected from customers, ticketing platforms, service providers

  • name
  • postal address
  • telephone number 

Collected from Customer Analytics Information and service providers

  • education data
  • employment information
  • financial information 

Disclosed: YES

Disclosed to service providers, advertising partners, analytics partners, and business partners

  • name
  • postal address

Shared for Cross-Context Behavioral Advertising or Sold: YES

Sold to advertising partners

  • name
  • postal address

Shared with service providers and advertising partners

  • name
  • postal address

C. Protected classification characteristics under California or federal law

Types of Personal Data Collected

Collected from Customer Analytics Information and service providers

  • age
  • gender/gender identity
  • race
  • ethnicity
  • ancestry
  • national origin
  • religion
  • marital status
  • veteran/military status

Disclosed: NO

Shared for Cross-Context Behavioral Advertising or Sold: YES

Sold/shared to/with service providers and advertising partners

  • age
  • gender/gender identity
  • race
  • ethnicity
  • national origin

D. Commercial information

Types of Personal Data Collected

Collected from ticketing platforms and Customer Analytics Information

  • records of prior ticket purchases 

Collected from Customer Analytics Information and service providers

  • data on purchasing or consuming histories/ tendencies of our consumers 

Disclosed: YES

Disclosed to service providers and business partners

  • records of prior ticket purchases

Shared for Cross-Context Behavioral Advertising or Sold: YES

Sold/shared to/with service providers and advertising partners

  • records of prior ticket purchases

E. Internet or other similar network activity

Types of Personal Data Collected

Collected from service providers

  • browsing history and interaction history with respect to our Site or an e-mail we have sent to you

Collected from Official Ticketing Platform

  • data regarding search history and customers’ interaction with respect to our Official Ticketing Platform’s website

Disclosed: NO

Shared for Cross-Context Behavioral Advertising or Sold: NO

F. Inferences drawn from other personal information

Types of Personal Data Collected

Collected from Customer Analytics Information and service providers

  • information regarding preferences, characteristics, predispositions, behavior

Disclosed: NO

Shared for Cross-Context Behavioral Advertising or Sold: NO

G. Sensitive Personal Information

Types of Personal Data Collected

Collected from service providers

  • racial or ethnic origin
  • religious beliefs

Disclosed: NO

Shared for Cross-Context Behavioral Advertising or Sold: YES

Shared with service providers and advertising partners

  • racial or ethnic origin
  • religious beliefs

What Personal Data and Information Does Jujamcyn Collect From You?

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We collect Personal Data about you from the following categories of sources:

You:

  • When you purchase tickets or conduct any other transaction at one of our venue box offices
  • When you voluntarily provide information through use of our Services or participation in a promotional activity sponsored by us
  • When you respond to surveys, questionnaires or other communications sent by us
  • When you contact us, including by email

Third Parties:

Online/Mobile Ticketing Platforms:

When you purchase tickets to a performance of any attraction playing in one of our venues, or conduct any other transaction such as a ticket transfer, refund or exchange, purchase a product or service (such as concessions, merchandise, or access to a VIP room) or otherwise provide information or complete a questionnaire or survey, through any platform operated by our official ticket sales services provider (our “Official Ticketing Platform”), or any other entity that operates a ticket sales platform or e-commerce platform with which we have a business relationship (such other platforms, “Third Party Platforms”), we may receive Personal Data about you from that entity to the extent it has been provided by you to that entity. If you have purchased tickets or conducted any other transactions through any of our previous official ticket sales services providers or through any third party ticketing platforms with which we have previously worked, we also may hold your Personal Data.

Together with your Personal Data, we will receive and/or continue to maintain information relating to your ticket purchase or other transaction (the foregoing information, including information obtained with respect to transactions conducted on ticketing platforms with which we have worked prior to the date hereof, referred to in this policy as, “Ticket Transaction Data”). “Ticket Transaction Data” may include the number of tickets you purchased, the performance for which you purchased, the price you paid for your tickets, your seat locations, and your method of payment, including the type of credit card you used. It may also include partial and limited credit card information (e.g., last 4 numbers only and expiration date) (the “Partial and Limited CC Information”), which we use and disclose only under the limited circumstances described in this policy.

When conducting transactions on the Official Ticketing Platform, information related to your use of that platform may be collected, including through the use of pixels or other unique technology or tracking codes placed on websites operated by the Official Ticketing Platform, and then shared with us (all such data, “Pixel Data”). If you are logged on to an account you have created with our Official Ticketing Platform when using any website or application of such Official Ticketing Platform, Pixel Data will include Personal Data.

Vendors and Service Providers:

Our Official Ticketing Company and other third party service providers may utilize customer analytics software services to collect demographic and behavioral attributes of our ticket-buying customers (“Customer Analytics Information”) and share such information with us.

When you use Services provided through our vendors or service providers, such as wifi in our venues or electronic purchases of products sold in our venues, we will receive Personal Data from such vendors or service providers.

We also receive information collected by third parties about your use of our website, www.jujamcyn.com (the “Site”). For example, we use analytics service providers such as Google Analytics to analyze how you interact and engage with the Site and any advertisements on the Site, so we can learn and make enhancements to offer you a better experience.

We receive information from our service providers that collect information relating to your interaction with an e-mail message sent by us, including IP address, page view statistics, usage information, and information collected by cookies and similar technologies such as pixel tags, web beacons, clear GIFs, JavaScript and other tracking technologies. See Exhibit A to this Privacy Policy for more information.

Advertising and Show Partners:

We receive information about you from some of our vendors and advertising partners who use information to create user profiles in order to assist us with marketing or promotional services. We may receive personal information about you from some of the producers of attractions in our venues (or their marketing or advertising partners) for which we provide Customer Analytics Services (such information, “Show Partner Data”).

How Does Jujamcyn Use Your Personal Data and Other Data Collected?

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We will process your Personal Data only if we have a lawful basis for doing so. Lawful bases for processing include contractual necessity, our legitimate interests or the legitimate interest of others, and consent, as further described below.

  • Contractual Necessity: We process certain categories of Personal Data as a matter of contractual necessity, meaning that we need to process the data to the extent necessary to perform under any terms and conditions related to or governing the Services provided to you. When we process Personal Data due to contractual necessity, failure to provide such Personal Data will result in your inability to use all or part of the Services that require such data.
  • Legitimate Interest: We process Personal Data when we believe it furthers a legitimate interest of ours or a legitimate interest of a third party. For example, we may process Personal Data to:
    • Operate, improve, understand and personalize our Services, business operations, and communications
    • Communicate with you about Services, surveys, updates or offers
    • Provide customer support and verify customer information
    • Enforce any terms and conditions of a Service
    • Detect, protect against or deter fraudulent, illegal or harmful actions
    • Diagnose problems with our servers and administer our Site
    • Protect the vital interests of you or other data subjects, or carry out a task in the public interest
    • Conduct data analysis, audits, research and product development
    • Analyze and track data and deliver advertising and content targeted to your interests, including through the use of Cookies as further described in Exhibit A 
    • Send you communications (“Marketing Related Communications”) regarding products or services offered by us or any of our affiliates, as well as by our Official Ticketing Platform, any of the attractions in our venues, or other third parties
    • Comply with legal and contractual obligations
    • Complete corporate or financing transactions
  • Consent: In some cases, we process Personal Data based on the consent you expressly grant to us. When we process Personal Data based on your consent, we will expressly indicate such basis to you at the point and time of collection.

We use Ticket Transaction Data in the same manner in which we use Personal Data as described above as well as to optimize future ticket sales to attractions in our venues and improve marketing strategies related to our Services and the attractions in our venues provided that we use any Partial and Limited CC Information only to verify the rightful owner/holder of a ticket, in connection with customer service to the cardholder, in connection with any fraud investigation, or to comply with any legal obligations.

We use Pixel Data only to analyze ways in which to optimize future ticket sales to attractions in our venues and to improve or tailor the marketing strategies of our business and the attractions in our venues. 

We use Customer Analytics Information only to improve the products and services we offer to our customers and to improve or tailor the marketing strategies of our business and the attractions in our venues. 

We use sensitive personal information (as defined in the California Consumer Privacy Act) related only to a customer’s racial or ethnic origin or religious beliefs and, then, solely for internal analytics and to generate targeted marketing on behalf of third parties, including attractions in our venues. If you do not wish us to use or disclose your sensitive personal information, please e-mail us at [email protected] or go to our website and click the link on the homepage that says “Your Privacy Choices”, or access the link directly here: jujamcyn.com/your-privacy-choices/. We will use Personal Data provided in an opt-out request only to review and comply with the request.

If at any time you do not wish to receive any Marketing Related Communications, please send an e-mail to [email protected] or, if such communication is by e-mail, unsubscribe by selecting the unsubscribe link in the e-mail. We will use Personal Data provided in an opt-out request to review and comply with the request. Even if you are unsubscribed from receiving Marketing Related Communications from us, we may continue to send you other types of e-mail communications without offering you the opportunity to opt out of receiving them, where permitted by law. These may include customer service announcements, information about a performance for which you have purchased tickets and the relevant venue, and surveys. 

We will not use Personal Data to send Marketing Related Communications to any individual who we know or who we believe, resides outside of the United States or who we know is 16 years or younger. 

How and With Whom Does Jujamcyn Share Your Data?

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We share Personal Data with vendors, third party service providers and agents who work on our behalf and provide us with services related to our business operations. These parties include:

  • Analytics service providers
  • Email service providers
  • Payment processors
  • Marketing service providers
  • Data warehousing providers
  • Fraud prevention service providers
  • Hosting service providers
  • Staff augmentation and contract personnel

We also share Personal Data with third parties when necessary to complete an action initiated or authorized by you or if you participate in a loyalty awards program or similar program that requires that your Personal Data in our possession be shared with a third party for administration of the program. In addition to those set forth above, these parties include:

  • Social media services (if you interact with them through your use of the Services)
  • Third parties who you access through the Services, including vendors

We also share Personal Data when we believe it is necessary to:

  • Comply with applicable law or respond to valid legal process
  • Protect us, our business, our employees or our customers
  • Investigate, prevent or take other action regarding illegal activity, suspected fraud, or other wrongdoing
  • Establish or exercise our legal rights or defend against legal claims.

If we receive Personal Data or Ticket Transaction Data from a Third Party Platform that is a ticket sales platform, we will share such Personal Data and Ticket Transaction Data with our Official Ticketing Platform, which may use such data for any purpose not otherwise prohibited by law and in accordance with its privacy policy. 

Notwithstanding anything to the contrary in this policy, we will disclose Partial and Limited CC Information to third parties only in connection with any fraud investigation or to comply with any legal obligations and we will never sell Partial and Limited CC Information.

We will share Pixel Data only with the producers of the attraction to which such Pixel Data relates or to those producers’ marketing consultants.

We may elect to disclose some or all of the Personal Data that we collect to the producers of the attraction to which such Personal Data relates, or to those producers’ marketing consultants, in order for those entities to send marketing or advertising materials to individuals about products and services but will not share Personal Data in these instances of individuals who we know are 16 years old or younger or who we know or who we believe, reside outside of the United States.

We may elect to sell some or all of the Personal Data that we collect to entities that may wish to send marketing or advertising materials to individuals about their products and services. In the event we sell any Personal Data to third parties, we do so only in compliance with applicable laws and regulations and will ensure that such Personal Data remains under Jujamcyn’s custody and control or under the custody and control of a service provider retained by Jujamcyn that (a) is not affiliated with the entity purchasing use of such Personal Data, (b) is contractually required to handle the Personal Data for the limited purpose of distributing the marketing materials, (c) is contractually required to destroy such Purchaser Data upon completion of such service provider’s services, and (d) is contractually required, at a minimum, to adhere to best practices and guidelines implemented by the Data and Marketing Association or any similar or successor entity. 

We will not sell any Personal Data of, share any Personal Data for marketing purposes of, or process Personal Data in connection with marketing and customer analytics services related to, any individual who we know is 16 years old or younger. We will not sell Personal Data of, share any Personal Data for marketing purposes of, or process Personal Data in connection with marketing and customer analytics services related to, any individual who we know or who we believe, resides outside of the United States.

We may share Customer Analytics Information with producers of attractions in our venues and their respective marketing consultants but only on an anonymized basis.

We will never sell, share or disclose sensitive personal information (as defined in the California Consumer Privacy Act) except that related to a consumer’s racial or ethnic origin or religious beliefs solely in connection with our provision of Customer Analytics Services. If you do not wish us to use or disclose your sensitive personal information, please e-mail us at [email protected] or go to our website and click the link on the homepage that says “Your Privacy Choices”, or access the link directly here: jujamcyn.com/your-privacy-choices/. We will use Personal Data provided in an opt-out request only to review and comply with the request. 

We may use some or all of the Personal Data, Ticket Transaction Data (excluding Partial and Limited CC Information) and Customer Analytics Information that we collect to provide marketing and customer analytics services (the “Customer Analytics Services”) to a third party, such as an attraction playing in one of our venues, for which we may receive compensation. In the event we provide such services, we will ensure that all such Personal Data, Ticket Transaction Data and Customer Analytics Information remain under Jujamcyn’s custody and control and be presented only in an anonymized manner unless the customer name to which the Customer Analytics Services relate is known to us to already be in the records of such third party provided that, as part of our performance of Customer Analytics Services, some Personal Data, Ticket Transaction Data, and Customer Analytics Information may be shared with one or more service providers performing functions related to the Customer Analytics Services. We do not share Show Partner Data with any entity other than the entity from which we received such data unless we have collected such data separately ourselves pursuant to this policy.

We also share information with third parties when you give us consent to do so.

We may share Personal Data and Ticket Transaction Data and other information with our affiliated companies (e.g., parent companies and subsidiaries), who will process such information in accordance with this policy.

Furthermore, if we choose to buy or sell assets, customer information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, are acquired; we enter into a merger or similar transaction; or if, in the unlikely event we go out of business or enter bankruptcy, customer information would be one of the assets that is transferred to or acquired by a third party, and we would share Personal Data and the other data described in this policy with such third party. You acknowledge that all such transfers, sales, mergers and other transactions may occur, and that any acquirer of us or our assets or any successor or assignee of ours may continue to use your Personal Data and the other data described in this policy as set forth herein. If you do not want your Personal Data shared for targeted advertising purposes or sold, please e-mail us at [email protected] or go to jujamcyn.com/your-privacy-choices/ to submit your request. We will use Personal Data provided in an opt-out request only to review and comply with the request.

How Long Do We Retain Your Personal Data?

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We retain Personal Data about you for as long as necessary to provide you Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally. 

We will delete your Personal Data when we receive a verifiable consumer request for deletion subject to the need to retain Personal Data for security purposes or prevention of fraud or illegal activities; the exercise or defense of legal claims; compliance with laws, regulations or legal obligations; or the fulfillment of any service or transaction requested by you or reasonably anticipated by you within the context of our ongoing business relationship with you. When we delete Personal Data, it will be removed from our active database but may remain in archived or back-up systems where it is not practical or possible to delete it. 

If we are informed by a third party that originally collected the Personal Data of a consumer that is in our possession, that such consumer has requested that their Personal Data be deleted or that it not be shared for marketing purposes or sold, we will take such actions to honor those requests in accordance with this Privacy Policy. Similarly, if a consumer reaches out to us with any such requests, we will inform the third party that originally collected such consumer’s Personal Data and any other party with whom we have disclosed or shared such consumer’s Personal Data, of such consumer’s requests. 

What Security Measures Do We Use?

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We seek to protect Personal Data and the other data described in this policy using technical and organizational measures based on the type of data and applicable processing activity.

We seek to ensure that your information is kept private. However, we cannot guarantee the security of any Personal Data or other data described in this policy. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of Personal Data or other data described in this policy at any time.

Do We Store the Personal Data of Children? Are Our Online Services or Site for Children?

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Our Site and any of our services offered online are not developed with the intention that they will be used by minors and specifically, they are not directed to children age thirteen (13) or younger. 

We do not knowingly collect or solicit Personal Data or other data from anyone 16 years of age or younger, except if we are legally required to collect such information, and except in the case of some promotional activities that we sponsor (such as a sweepstakes or giveaway) that may be open to individuals who are 14 and over, in which case, we require that individuals who are at least 14 years old but less than 18 years old obtain parental or legal guardian consent before participating in any such promotional activity and require such parent or legal guardian to consent to the acceptance of any prize by such individual in connection with such promotional activity should such individual be selected a winner. Additionally, we use Personal Data and other data collected from an individual who we know is 16 years of age or younger only in connection with the administration of a particular promotional activity open to such individual (in which event such information is deleted upon the completion of such promotional activity), or in connection with customer service, fraud prevention, security purposes or compliance with laws or regulations. Any Personal Data or other data that we may receive from or in respect of an individual who we know is 16 years of age or younger, other than in connection with certain promotional activities as described above, in connection with any Ticket Transaction Data, or in connection with any legally required collection, will be deleted as promptly as possible from our system.

If you are 16 years of age or younger, please do not attempt to use any of our Services or the Site, or send any Personal Data or other data about yourself to us unless you are participating in a promotional activity for which you meet eligibility requirements. If you believe that a child 16 years of age or younger may have provided us Personal Data or other data, please contact us at [email protected].

What Do Customers in the European Union Need to Know?

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Rights Regarding Your Personal Data:

By law, users in the European Union, United Kingdom, Lichtenstein, Norway, or Iceland have certain rights with respect to their Personal Data, including the right of access, rectification, erasure, withdrawal of consent, portability, objection to processing, and restriction of processing. For more information about these rights, please email us at [email protected]. You also have the right to lodge a complaint about our practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.

  • Right of Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data, and also access certain of your Personal Data by emailing [email protected].
  • Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data by emailing [email protected].
  • Erasure: You can request that we erase some or all of your Personal Data from our systems by emailing [email protected]. 
  • Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time by emailing [email protected].
  • Portability: You can ask for a copy of your Personal Data in a machine-readable format by emailing [email protected]. You can also request that we transmit the data to another controller where technically feasible.
  • Objection to Processing: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes, by emailing [email protected]. You can unsubscribe from any direct marketing emails by clicking the unsubscribe link in any direct marketing email you have received.
  • Restriction of Processing: You can ask us to restrict further processing of your Personal Data by emailing [email protected].

Transfers of Personal Data:

If you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using any of our Services or any services offered by our affiliates or service providers or the Official Ticketing Platform or any Third Party Platform, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to us in the U.S. and will be hosted on U.S. servers or in other geographical territories, and you authorize us to transfer, store and process your information to and in the U.S., and possibly other countries. If you live in the European Union, United Kingdom, Iceland, Liechtenstein, or Norway, you hereby consent to the transfer of your data. Please contact us at [email protected] with any questions or concerns.

What Do Customers in the State of California Need to Know?

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If you are a resident of California, under the CCPA, you have the right to request that we disclose certain information to you about our collection and use of your Personal Data. You also have the right to request that we delete or correct your Personal Data, subject to certain exceptions. You have the right to request that we disclose certain information to you about the sale or disclosure of your Personal Data by us and also the right to direct us not to sell or share your Personal Data or use or disclose sensitive personal information. For more information regarding your rights under the CCPA with respect to our collection, use, sale and disclosure of your Personal Data, please see Exhibit B to this Privacy Policy.

California’s “Shine the Light” law (Civil Code Section §1798.83) permits customers who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected] or write us at: 246 West 44th Street, New York, NY 10036.

What If You Have Questions Regarding Your Personal Data?

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If you have any questions about this Privacy Policy or our data practices generally, please contact us using the following information:

Jujamcyn Theaters LLC

246 West 44th Street, New York, New York 10036

e-mail: [email protected]

Do not send any credit card information or other sensitive information to us in any e-mail correspondence.

Changes/Updates to this Privacy Policy

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We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make changes in the way we use Personal Data or other data described herein, we will notify you by posting an announcement on the Site or by an e-mail communication to you. You are bound by any changes to the Privacy Policy when you use any of our Services, use the Site, participate in any promotional activity sponsored by us, or use any third party site or service described in this policy after such changes have been first posted. You can determine whether this policy has been revised since your last visit to the Site by referring to the “Effective Date of this Privacy Policy” legend at the top of the first page of this policy.

Exhibit A: Information about Cookies and Similar Technologies

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The Site uses cookies and similar technologies such as pixel tags, web beacons, clear GIFs, and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser and tell us how and when you visit and use our Site, to analyze trends, learn about our user base and operate and improve our Services. We may also embed Cookies in e-mails that we send to you or that are sent to you on our behalf, in order to obtain information on whether you have opened an e-mail, clicked on a link within an e-mail or taken any action in response to an e-mail.

Cookies are small files–usually consisting of letters and numbers–placed on your computer, tablet, phone, or similar device when you use that device to visit our Site or to open, respond to or take action with respect to an e-mail we have sent to you.

We sometimes combine information collected through Cookies that is not Personal Data with Personal Data that we have about you, for example, to tell us who you are. We may also supplement the information we collect from you with information received from third parties.

Cookies can either be “session Cookies” or “persistent Cookies”. Session Cookies are temporary Cookies that are stored on your device while you are visiting our Site or using Services on our Site, whereas “persistent Cookies” are stored on your device for a period of time after you leave our Site or stop using Services on our Site. The length of time a persistent Cookie stays on your device varies from Cookie to Cookie. We use persistent Cookies to store your preferences so that they are available for the next visit, and to keep a more accurate account of how often you visit our Site, how often you return, and how your use of Services may vary over time. We also use persistent Cookies to measure the effectiveness of advertising efforts. Through these Cookies, we may collect information about your online activity after you leave our Site. Your browser may offer you a “Do Not Track” or “DNT” option, which allows you to signal to operators of websites, and web applications, and services that you do not wish such operators to track certain of your online activities over time and across different websites. Because we collect browsing and persistent identifier data, our Site and related Services do not support Do Not Track requests at this time, which means that we may collect information about your online activity both while you are using the Site and related Services and after you leave our properties. 

Some Cookies are placed by a third party on your device and may provide information to us and third parties about your browsing habits (such as your visits to our Site, the pages you have visited and the links and advertisements you have clicked). These Cookies can be used to determine whether certain third party services are being used, to identify your interests, to retarget advertisements to you and to serve advertisements to you that we or others believe are relevant to you. We do not control third party Cookies. 

We use the following types of Cookies on the Site:

  • Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies may enable you to log into secure areas of our Site or Services. Disabling these Cookies may make certain features and services unavailable.
  • Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Site and related Services such as by collecting information about the number of visitors to the Site, what pages visitors view on our Site and how long visitors are viewing pages on the Site. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Site’s content for those who engage with our advertising. For example, Google, Inc. (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Site is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt out of Google’s use of cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.

You can decide whether or not to accept Cookies. One way you can do this is through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your computer. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some Services and functionalities may not work.

To explore what Cookie settings are available to you, look in the “preferences”, “options” or “settings” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit https://ico.org.uk/for-the-public/online/cookies/ or http://www.allaboutcookies.org/.

  • We may serve advertisements on our Site, and also allow third party ad networks, including third party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Site. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Site and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Site and related Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.
  • Through the Digital Advertising Alliance (“DAA”) and Network Advertising Initiative (“NAI”), several media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of and greater control over ads that are customized based on their online behavior across different websites. To make choices about Interest-Based Ads from participating third parties, including to opt out of receiving behaviorally targeted advertisements from participating organizations, please visit the DAA’s or NAI’s consumer opt out pages, which are located at http://www.thenai.org or www.aboutads.info/choices. Users in the European Union should visit the European Interactive Digital Advertising Alliance’s user information website http://www.youronlinechoices.eu/.

We do not share your Personal Data with advertisers on our Site without your consent. However, if you click on or otherwise interact with an advertisement on our Site, there is a possibility that the advertiser may place a Cookie in your browser and note that it meets the criteria they selected.

Exhibit B: Information on Certain Rights of Residents of California Under the CCPA

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If you are a resident of California, you have certain rights under the CCPA, some of which are highlighted in this Exhibit B.

Right to Receive Certain Disclosure Regarding Your Personal Information

You have the right to request that we disclose to you the following information:

  1. The categories of personal information we have collected about you.
  2. The categories of sources from which the personal information is collected.
  3. The business or commercial purpose for collecting, selling or sharing the personal information.
  4. The categories of third parties to whom the business discloses personal information.
  5. The specific pieces of personal information we have collected about you.

“Share”, as used in this Exhibit B, means sharing or disclosing your personal information by us to a third party for cross-context behavioral advertising.

You have the right to request that we disclose to you the following information if we sell or share your personal information or disclose your personal information for a business purpose:

  1. The categories of personal information that we have collected about you.
  2. The categories of personal information that we have sold or shared about you and for each category identified, the categories of third parties to whom we sold or shared that particular category of personal information.
  3. The categories of personal information that we disclosed about you for a business purpose, and for each category identified, the categories of third parties to whom we disclosed that particular category of personal information.

Please note that the “categories of personal information” referred to in this Exhibit B follow the definition of “personal information” in Section 1798.140 of the CCPA.

You may exercise the rights to disclosure above no more than twice in a 12-month period. To exercise any of the rights to disclosure described above, please submit a verifiable consumer request to us by sending an e-mail to [email protected]; by calling us, toll-free, at (866) 386-3121; or submitting your request at: jujamcyn.com/your-privacy-choices/. The disclosure will be made in writing and delivered to you by mail or electronically, at your option, in a readily useable format that will allow you to transmit the information to another entity without hindrance. We may limit the period of time reviewed with respect to a request for disclosure to the 12-month period preceding our receipt of your request if providing personal information beyond the 12-month period would be impossible or would involve disproportionate effort. 

Right to Have Your Personal Information Corrected

You have a right to request that we correct any inaccurate personal information that we maintain about you. We may deny a request to correct if we determine that the contested personal information is more likely than not accurate based on the totality of the circumstances. You may be required to provide supporting documentation in connection with your request to correct. To exercise the right to correct any such information, please submit a verifiable consumer request to us by sending an e-mail to [email protected]; by calling us, toll-free, at (866) 386-3121; or submitting your request at: jujamcyn.com/your-privacy-choices/.

Right to Have Your Personal Information Deleted

You have a right to request that we delete any of your personal information that we have collected from you, subject to certain exceptions set forth in the CCPA. To exercise the right to delete described above, please submit a verifiable consumer request to us by sending an e-mail to [email protected]; by calling us, toll-free, at (866) 386-3121; or submitting your request at: jujamcyn.com/your-privacy-choices/.

Information Regarding Requests for Disclosure, Correction, or Deletion

We cannot respond to a request for disclosure, correction, or deletion or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. The process for determining the verification of the identity of a person making a request will be conducted in accordance with the CCPA and accompanying regulations. You do not have to create an account with us in order to make a verifiable request. Your request must contain sufficient detail that allows us to properly understand, evaluate and respond to it. In certain cases, we may need at least two to three pieces of personal information from you in order to properly verify your identity by matching those pieces or information with data points maintained by us. We will use any personal information collected from you in connection with our verification of your request solely for the purposes of verification. In the case of a request to delete, we may retain a record of the request for the purpose of ensuring that your personal information remains deleted from our records.

We will endeavor to respond to a verifiable consumer request within 45 days of its receipt. When reasonably necessary, we may need additional time but will extend the time period only once by up to no more than an additional 45 days. If we require more than 45 days to respond, we will inform you of the reason and extension period in writing within the first 45 days. If we cannot comply with a request, we will explain our reasons in writing. 

We do not charge a fee to process or respond to a verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before fulfilling your request. 

Please note that if we can comply with your request to delete personal information, it may still exist on archived or back-up systems but not on an active system. 

You may use an authorized agent to submit a request for disclosure, correction or deletion on your behalf. An authorized agent must have your signed permission to submit a request on your behalf or provide proof that they have power of attorney in accordance with California probate law. Authorized agents that are business entities must be registered with the California Secretary of State to conduct business in California. Before completing requests from authorized agents, we may contact you directly to confirm you have given your permission and/or to verify your identity.

Right To Direct Us Not To Sell or Share Your Personal Information

You have the right, at any time, to direct us not to sell or share your personal information to or with third parties (this right is referred to as the “right to opt out of sale/sharing”). To opt out, you can e-mail us at [email protected] or go to our website and click the link on the homepage that says “Your Privacy Choices” or access the link directly here: jujamcyn.com/your-privacy-choices/. We will use any personal information collected from you in connection with your submission of your opt-out request solely for the purposes of complying with the opt-out request. You may use an authorized agent to submit a request to opt out on your behalf if you provide the authorized agent signed written permission to do so. Authorized agents may submit requests to opt out by sending an email to [email protected]. To the extent we receive any opt-out preference signal (as defined in the California Consumer Privacy Act Regulations), we will honor it. However, we do not sell or share any information that may be obtained by us through your interaction with us online or through your use of our Site. We also do not link any browser or device you may use when you interact with us online or when you use our Site, to any consumer profile we may maintain about you. 

Right To Limit Use and Disclosure of Sensitive Personal Information

We collect and use certain “sensitive personal information” (defined under Section 1798.140 of the California Civil Code), as described in our Privacy Policy. You have the right, at any time, to direct us not to use or disclose your sensitive personal information. To opt out, you can e-mail us at [email protected] or go to our website and click the link on the homepage that says “Your Privacy Choices” or access the link directly here: jujamcyn.com/your-privacy-choices/. We will use any personal information collected from you in connection with your submission of your opt-out request solely for the purposes of complying with the opt-out request. You may use an authorized agent to submit a request to opt out on your behalf if you provide the authorized agent signed written permission to do so. Authorized agents may submit requests to opt out by sending an email to [email protected]. 

Non-Discrimination

We will not discriminate against California residents for exercising any of their rights under the CCPA. Unless permitted by the CCPA, we will not:

  1. Deny you goods or services.
  2. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  3. Provide you a different level or quality of goods or services.
  4. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

We may, however, offer you certain financial incentives permitted by the CCPA that can result in different prices, rates or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to the value of your personal information and contain written terms that describe the program’s material aspects. Participation in a financial incentive program, if any, requires your prior opt-in consent, which you may revoke at any time. 

Certain Required Disclosures / Categories of Personal Information of Consumers Collected, Sold/Shared or Disclosed by Us Within the Last Twelve (12) Months

The information provided at the beginning of this Privacy Policy (the “Twelve-Month Information”) lists the categories and sources of personal information that we have collected in connection with our business, our Services and the Site within the last twelve (12) months. The business or commercial purposes of collecting such personal information are as described in the section “How Does Jujamcyn Use Your Personal Data and Other Data Collected?”. The Twelve-Month Information also lists the categories of personal information that we have sold or shared within the last twelve (12) months and the third parties to whom we sold or shared each category of personal information. The business or commercial purposes of selling or sharing personal information was to receive consideration from such entities seeking to encourage individuals to buy certain products or services or to provide targeted cross-contextual advertising to consumers on behalf of third party attractions. Finally, the Twelve-Month Information lists the categories of personal information that we have disclosed for a business purpose and the types of entities to which we disclosed such information within the last twelve (12) months. We disclosed each category of personal information to third parties for auditing related to current interactions with consumers and concurrent transactions, the performance of services on behalf of our business, and the undertaking of internal research.