Privacy Policy

Last updated: 29th July 2026

Introduction
 

This document explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe. 

There’s a lot of information here and it’s possible (if you’ve started reading) that you might not make it all the way to the end, but we want to make it as easy as we can for you to understand your rights and how we use your data. 

Hopefully the rest of this document will make things clear for you, but if not, feel free to contact us via the website and we’ll do what we can to help you. 

  

What is The Cinema Society?
 

The Cinema Society (we’ll call it TCS from now on) is a “closed user group” club that offers its members the opportunity to buy vouchers that may be exchanged for cinema tickets with partner cinema companies.  The price of the vouchers normally (unless the cinemas themselves are running a special offer) represent a discount against the face value of a cinema ticket. 

The Cinema Society is a trading name of SPARK Marketing Services Limited, a company trading in England and Wales, from now on when we refer to “we” or “us” take it to mean both SPARK and TCS. 

To take advantage of the discounted prices of vouchers you will need to become a member of TCS.  Only those people who are part of a closed user group with whom we are working (we’ll refer to them as “clients”) are allowed to become members.  Those people who are entitled to join will typically either be employees of our clients or customers (for example gym members or members of a charity). 

There are two ways to become a member of TCS: you can register your own details with us directly, using a secure link provided by your client’s own website; or, where we have a secure single sign-on (“SSO”) relationship with your client, you may become a member automatically when you access TCS via a secure link from our client’s website, without needing to separately register your details with us. 

Where you become a member via a secure single sign-on (SSO) link from our client’s website, we receive certain information about you from our client (such as your name and email address) in order to create and maintain your TCS membership account. We use industry-standard secure digital techniques to manage this connection with our clients’ businesses, and we’d be very happy to talk you through them if you wish – just get in touch through the website. 

Why do we collect your data?
 

In accordance with the law there are a few reasons why we collect your data: 

In specific situations, we can collect and process your data with your consent.  For example, when you tick a box to allow us to let you know about forthcoming movies. Under the Privacy and Electronic Communications Regulations 2003 (PECR), marketing emails and texts to individuals require your consent, or must fall within the limited "soft opt-in" exception for existing customers; legitimate interest alone is not a sufficient basis for this specific channel, even though it may support other uses of your data described elsewhere in this policy. 

 

Contractual obligations
 

In certain circumstances, we need your personal data to support our clients in understanding how many of their members are taking up the offer of discounted cinema tickets and so we need to identify you as a member of a particular client and we may tell that client about your cinemagoing habits in order to help them (and us) to tailor the information we send to you (for example making sure that if you like sci-fi movies then we may tell you when the next one is released) (We rely on our legitimate interests, rather than contractual necessity, as the legal basis for this particular use, since sharing this information is not required in order to perform our contract with you personally). This also includes creating and maintaining your TCS membership account where you access TCS via a secure single sign-on (SSO) link from our client's website. 

 

Legal compliance
 

If the law requires us to, we may need to collect and process your data.  For example, we can pass on details of people involved in fraud or other criminal activity affecting us to law enforcement. 

 

Legitimate interest
 

In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected to help us build and operate a successful business and which does not materially impact your rights, freedom or interests. 

  For example, we may, over time build a picture of the types of films you like to watch so that we can let you know when something is coming up that we think you may enjoy 

 

When do we collect your data?
 

·           When you register for TCS, or become a member automatically via a secure single sign-on (SSO) link from your client’s website 

·           When you make a purchase from TCS 

·           When you engage with us on social media (please do, we’re on Facebook, LinkedIn, Twitter and Instagram) 

·           When you contact us with queries, complaints etc 

·           When you enter prize draws or competitions. 

·           When you choose to complete any surveys we send you. 

·           When you comment on or review our products and services. 

·           When you’ve given a third-party permission to share with us the information they hold about you.

What data do we collect?
 

·           Your name, address, telephone number and email address.

·           Some information about your cinemagoing habits such as favourite types of films and how often you go.

·           Purchase patterns – when do you buy cinema vouchers, how often, what type of vouchers do you buy?

·           How you arrived at TCS

·           Where you become a member via a secure single sign-on (SSO) link, certain identifying information (such as your name and work email address) that your client provides to us in order to set up and maintain your membership. 

·           Information about how you use our website, collected through tools such as Google Analytics and Microsoft Clarity. This includes information such as your device type, pages visited, time spent on pages, clicks and scrolling activity, which helps us improve our website and service.
  

We expressly do not collect or store any financial information from you such as credit or debit card details.
  

How do we use that data?
 

We only use your data in order to try and give you the best experience of using TCS that we possibly can, that might include: 

·           To allow you to purchase our products quickly and easily, for example by “guessing” what vouchers you might want to buy. 

·           Predicting the types of movies that you want to see and telling you about what movies are out now or soon and what products are available through us via email, social media and post. 

·           Using the data regarding your cinemagoing habits to try and ensure that we negotiate the best prices that we possibly can with the participating cinemas. 

·           Creating effective promotions that reward your buying behaviour or encouraging you to use our service more often. 

·           To tell you about offers we have sourced that we think you might be interested in. 

·           To share limited information about your TCS activity with the client through whom you joined – helping them to understand how their members are using the offer and improve the benefits they provide. 

·           To assist your order process and make sure you can purchase vouchers as easily as possible. 

·           To answer any queries or complaints that you may have as quickly and effectively as possible. 

·           To ask you to help us improve our service by asking you some questions about it. 

·           To analyse how users interact with our website to improve usability and our service. 

·           To, as far as possible, protect you from fraud or crime we may use your data or share it with law enforcement. 

·           To respond to any queries that you may have submitted to us. 

 

We know how much data security matters to you. With this in mind we treat your data with the utmost care and take all appropriate steps to protect it. 

We secure access to all transactional areas of our websites and apps using ‘https’ technology. 

Access to your personal data is password-protected, and sensitive data (such as payment card information) is not stored or collected by our platforms. 

We maintain our systems using the latest software updates. 

 

How long do we keep your personal data?
 

Typically we will only retain your data for as long as you are a member of TCS though we will retain access to your transactional information for 5 years. 

If you are a member via a secure single sign-on (SSO) link, your membership will typically end when your client’s business relationship with SPARK ends, or when your client removes your access to their site (for example, when you are no longer an employee or customer of that client). We may continue to retain your account information until we are notified by the client that it should be removed, or for as long as necessary to comply with our legal obligations and retention policies. In any event, we will not retain your account information for longer than 5 years after your last activity on TCS, save where a longer period is required by law. 

 

Who will we share your personal information with?
 

We sometimes share your personal data with trusted third parties.  For example, our transactional partner, delivery couriers, for fraud prevention, to handle complaints, to help us personalise our offers to you and so on.  

We may also share information about your activity within The Cinema Society with the client through whom you joined. Depending on the client’s chosen integration, the information we share may include: 

·       confirmation that you have registered as a member of The Cinema Society 

·       an email address or external user ID used to link your TCS account to the client’s internal system 

·       details of your voucher purchases through TCS, including: 

o   date of purchase 

o   frequency and value of purchase 

o   chains and voucher types purchased 

o   approximate savings compared with cinema box office RRPs 

o   information about order history within date ranges (for example daily or periodic activity reports) 

This information may be shared where necessary to help the client administer the benefit they provide, understand member engagement, measure the value of the service, and improve awareness and uptake of the service. Please note this may include information identifiable to you individually (rather than only aggregated or anonymised statistics); we only share what is proportionate for these purposes and clients may only access data relating to their own eligible members. 

All access shared via the API is authenticated using encrypted API keys, and clients can only retrieve data relating to their own eligible members. 

 

Where might your personal data be processed?
 

Any personal data is managed within the United Kingdom and may also be processed within the European Economic Area (EEA).  Some of the third-party tools we use for website analytics (such as Google Analytics and Microsoft Clarity) may transfer data to servers located outside the UK and EEA, including the United States. Where this happens, we ensure appropriate safeguards are in place (for example the UK International Data Transfer Agreement, or the UK extension to the EU-US Data Privacy Framework, as applicable to that provider). 

 If you are based outside the UK and place an order with us, we will transfer the personal data that we collect from you to our business in the UK. 

 

What are your rights with regards to the data we hold?
 

You can at any time: 

·           Access the data we hold about you (this is normally free of charge and we’ll let you know if not). 

·           Correct whatever we hold which is incorrect, out of date or incomplete. 

·           Request that we stop using your personal data for direct marketing. 

·           Ask us to erase your personal data in certain circumstances (the "right to be forgotten"). 

·           Ask us to restrict how we use your personal data while a query or objection is resolved. 

·           Receive a copy of the personal data you have provided to us in a portable, machine-readable format. 

·           Object to our processing of your personal data where we rely on legitimate interests, including profiling used to personalise offers and recommendations. 

·           Not be subject to a decision based solely on automated processing (including profiling) that produces legal or similarly significant effects concerning you. 

 

Your right to withdraw consent
 

Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent – you just need to contact us to let us know or change the settings in your user area. 

All email communications issued by us give you the opportunity to unsubscribe to such communications in future.  Just click the link at the bottom of the page. 

We will always need to confirm your identity should you wish to make any changes to the data we hold.  In most cases you can do this by logging into TCS though on occasion we may need to take further steps to confirm who you are. 

 

Further action
 

We’ll always do our best to ensure that you are satisfied with the way your data has been handled, however if you are not satisfied then we hope you will contact us in the first instance. 

If however, you want to take things further then you have the right to make a complain to the Information Commissioner’s Office (ICO). 

You can contact them by calling 0303 123 1113.
Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can't be responsible for the content of external websites) 

If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence. 

 

Questions
 

If you have any questions about this policy, please contact us at hello@wearespark.com or contact us via the TCS web platform.