Effective Date: 25 May 2018
We at Magic Memories Group Holdings Limited, along with our subsidiaries and affiliates (collectively, the “Magic Memories Group,” “we,” or “us”) value your privacy rights and are committed to being transparent about our data practices.
This Global Privacy Notice applies whether you visit us in person or interact with us online or via a mobile device and it provides you with information about the following:
- our use of your data;
- our sharing of your data;
- our collection of your data;
- our international transfers of your data;
- our legal basis for processing your data;
- our data retention practices;
- our security measures;
- your rights and choices relating to your data; and
- contacting Magic Memories.
How we use your personal data
We use your personal data to do the following:
- to provide goods and services to you;
- to process and track your orders, process payments, and coordinate delivery of merchandise;
- to verify your identity so that you can access, view, and share photos;
- to manage any registered account that you hold with us;
- to operate, evaluate and improve our business (e.g. developing new products and services; improving our products and services; analyzing our customer base; and performing accounting, auditing, and other internal functions);
- to manage customer service interactions with you;
- to send you promotional materials and other communications,
- to comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations, and our policies; and
- to perform other functions for which we provide specific notice at the time of collection.
In addition, we use data collected through cookies, web beacons, pixels, web server logs and other automated means for purposes such as (i) customizing your visits to our websites and apps, (ii) delivering banner advertisements to you on other websites, (iii) delivering content tailored to your interests and the manner in which you browse our websites and apps, and (iii) managing our websites, apps and other aspects of our business.
What personal data we share
We share your personal data under the circumstances described below.
Third Party Service Providers
We share your personal data with third party service providers we engage to perform services on our behalf, such as processing credit card payments, reducing credit risk, fulfilling orders, data storage, website hosting, performing data analytics, and sending marketing messages.
We do not authorize these service providers to use, disclose, or otherwise process your personal data except as required to perform services on our behalf.
Magic Memories Group
Your personal data may be shared with other Magic Memories companies around the world that make up the Magic Memories Group. These companies process your personal data in accordance with this Global Privacy Notice.
We work closely with the operators of the attractions where we provide photographic services. We may share your data with these operators so that they can evaluate and improve their businesses and also provide you with information about their offers and promotional events.
If you log in to one of our websites through Facebook or other social media platforms the information you share may be shared with those social media platforms.
Your personal data may be disclosed to a third party if we are required to do so because of an applicable law, court order, or governmental regulation or if the disclosure is necessary to support a criminal or other legal investigation or proceeding.
If we are involved in a liquidation, reorganization, merger, acquisition, or sale of our assets then your personal data may be transferred as part of that transaction.
With Your Consent
We may disclose your personal data to others with your consent. For instance, your data will be shared if you send a link or email to allow your friends and family to view your photographs or videos.
What personal data we collect
We may collect the following personal data:
- your name, prefix, age, date of birth, and gender;
- photographs and videos of you;
- your contact details including; postal addresses, telephone numbers, and email addresses;
- your payment card details when you make a purchase or place an order;
- your communications with us;
- the location of the attraction you visited and date of your visit;
- username and password;
- your communication and marketing preferences;
- publicly available personal data, including data you have shared via a public platform such as Twitter or Facebook;
- purchases made by you;
- your online browsing activities; and
- information we obtain from our third party service providers;
In addition, when you visit our websites, open our emails, use our apps or interact with Magic Memories related tools, widgets or plug-ins, we may collect certain information by automated means, such as cookies, web beacons and web server logs. The information we collect in this manner includes IP address, unique device identifier, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on our site, and dates and times of website visits.
For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Notice.
What personal data we transfer internationally
Magic Memories operates a global business. As a result, we may transfer your personal data outside of the country in which it was originally collected, such as the United States, the United Kingdom, Australia, and New Zealand. This will typically occur because a service provider is located outside the country where the personal data was collected.
The United States, European Economic Area (“EEA”) Member States, and other countries have different laws. For example, the circumstances in which law enforcement can access personal information may vary from country to country. Data in the US, in particular, may be accessed by government authorities in accordance with US law.
If your data is collected or otherwise processed in the European Union we will comply with applicable legal requirements providing adequate protection for the transfer of personal information to recipients in countries outside the EU. These include implementing the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies, which require all group companies to protect any personal information they process from the EEA in accordance with European Union data protection law.
Legal basis for processing personal data
Generally, we rely on three separate and overlapping bases to process your personal information lawfully.
First, when you have given us consent to process your data in certain ways, we will rely on your consent. For example, we generally rely on consent as a legal basis for processing in relation to sending direct marketing communications to customers via email or text message. Customers have the right to withdraw consent at any time.
Second, we process personal data when it is necessary to perform a contractual obligation. For example, we provide your shipping address to a third party fulfillment vendor so that merchandise you have ordered can be shipped to you.
Third, we may process your personal data where necessary to fulfill our legitimate interests, where those interests are not overridden by your rights or interests. These legitimate interests include:
- selling and supplying goods and services to our customers;
- protecting customers, employees and other individuals and maintaining their safety, health, and welfare;
- promoting, marketing, and advertising our products and services;
- sending promotional communications which are relevant and tailored to individual customers;
- understanding our customers' behavior, activities, preferences, and needs;
- improving existing products and services and developing new products and services;
- complying with our legal and regulatory obligations;
- preventing, investigating and detecting crime, fraud or anti-social behavior and prosecuting offenders, including working with law enforcement agencies;
- handling customer contacts, queries, complaints or disputes;
- managing insurance claims by customers;
- protecting Magic Memories, its employees, and customers, by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to Magic Memories;
- effectively handling any legal claims or regulatory enforcement actions taken against us; and
- fulfilling our duties to our customers, colleagues, shareholders and other stakeholders.
How long we retain personal data
We keep your personal data in accordance with our own guidelines, procedures, and principles.
Generally, if you register an account with us then we will retain your personal data for as long as your account is active. We will deem your account inactive if you do not upload, download, or sign in to the account for a period of five years, in which case your personal data will be deleted.
For additional information about your rights concerning your data please review the information below under “Your rights and choices.”
How we protect personal data
We maintain administrative, technical, and physical safeguards that are designed to protect your personal data against, accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use.
Your rights and choices
If our processing of your data is subject to EU privacy rules, you have the following rights (some of which are subject to conditions or qualifications):
- to ask what personal data we hold about you and to obtain a copy of your personal information in an easily accessible format and (for some data) also a right of portability;
- to ask us to update or correct the personal data we hold about you;
- to ask us to delete personal data we hold about you;
- to ask us to restrict or limit the ways in which we use your personal data; and
- to opt out of any marketing messages we may send you.
If you would like to exercise any of these rights or would like further information please contact us through one of the channels listed under “Contact Magic Memories.” Our customer service teams are located around the world; we will respond as promptly as possible.
You have the right to lodge a complaint with a data protection authority. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries are available here: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.) The data controller of your personal information is Magic Memories Group (UK) Limited.
Subject to certain limitations under California Civil Code § 1798.83, California residents may ask us to provide them with (i) a list of certain categories of personal information that we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year, and (ii) the identity of those third parties.
If you are under 18 years old, you are allowed by Section 22581 of the California Business and Professions Code to ask us to remove content or information posted publicly by you. In some instances, we may be legally required not to delete this information.
To exercise your rights under this section, California residents may contact us through one of the channels listed under “Contact Magic Memories.”
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Updates to this Privacy Notice
We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make.
You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.
Contact Magic Memories
If you have any questions about your personal data or if you want to exercise your rights regarding your personal data please contact us by any of the following means:
Australia / New Zealand at: +64.3.450.2170 ext. 4
General Counsel’s Office