Privacy Policy

Acamar Films Limited (“We“ or “Us”) are committed to protecting and respecting your privacy and the
security of your personal data. This policy (together with our terms of use) sets out the basis on which
any personal data we collect from you, or that you provide to us, will be used by us. 
This policy applies to: (i) use of the websites owned and operated by Us (at
or or and their subdomains) (“the Site”) and use of Our Bing
mobile application (“the Bing App”); (ii) our marketing activities, including newsletters, emails,
competitions, and any other product or activity that links to, or otherwise references, this policy
(collectively, with the Site and the Bing App, the “Bing Products“). Please read the following carefully
to understand our views and practices regarding your personal data and how we will treat it. By
visiting or using the Bing Products you are accepting and consenting to the practices described in this

1.1 For the purpose of the General Data Protection Regulation, the data controller is Acamar Films
Limited, a company registered in England and Wales under company number 04399568, registered
address is at 7 Savoy Court, London, United Kingdom, WC2R 0EX).
1.2 If you have any questions or concerns about this policy, the information we collect about you or
our personal data processing activities in connection with your dealings with the Bing Products, please
contact our Data Protection Officer: General Counsel at Acamar Films Limited, at
1.3. You can also contact us through physical mail to Acamar Films Limited, The Rotunda (Ground Floor),
42-23 Gloucester Crescent, London NW1 7DL, United Kingdom, to the attention of our General
Information on data protection generally is also on the Information Commissioner’s website at or at the official website of the European Union:

We will collect and process the following data about you:
2.1 Information you give us. This is information about you (or your child) that you voluntarily give
and share with us by filling in the form or field on the Site or Bing App, by any other communication
(e.g. email, phone, mail etc.) or when you request to receive certain content that we may make available
through the Bing Products. It includes information you provide when you register to sign up to our
email newsletter and when you report a problem with our Site or Bing App or download content from
the Site or the Bing App. The information you give us may include your name and email address, your
children’s date(s) of birth as well as any other content that you provide through the above
communication channels, such as any information you submit as part of a competition.
2.2 Information we collect about you. With regard to your use of the Bing Products we will
automatically collect the following information:
2.2.1. Technical information, for example: IP address, browser type, operating system version,
device type, device model, orientation of device, app version, disk space left on device and
other similar technical information typically received from a browser or device automatically
when visiting or interacting with Internet and mobile products.
2.2.2. Usage information, for example: the pages you visited on the Bing Products, where you
clicked, searches performed on the Bing Products, time and date of incidents, error report of
incidents, which subscription has been purchased, success / failure of payment and other
similar information related to how you have used the Bing Products. It may also include
information related to whether you received, opened or clicked on any links in an email sent to
2.3 Certain technical information or usage information may, either alone or when combined with other
data, be deemed personal data under data protection laws and we are committed to treating such data
in compliance with them.
2.4 The technical and usage information is collected by Us through use of cookies and other similar
technologies (e.g. pixels, web beacons, JavaScript, etc.). These technologies help us to analyse how the
Bing Products are used and to tailor content of the Bing Products that is relevant to you. However, we
are not tracking any payment details through this technology. For more information on such
technologies, including how to manage your cookie preferences please see our Cookie Policy below.
2.5 Sometimes we can also obtain the above information from third party sources, such as the various
business support tools and services offered by third party providers that We use (e.g. Crashlytics and
Firebase analytics services offered by Google companies).

3.1 It is important that you understand how and why we use the personal data that we collect about
you. This section sets out the different purposes for which we process personal data and which types
of personal data we need for each purpose.
3.2 We will only use your personal data when the law allows us to. Most commonly, we will use your
personal data in the following circumstances:
3.2.1. to perform our contract with you if you subscribe to the Bing App;
3.2.2. to process your inquiries and to respond to your requests;
3.2.3. in order to manage your subscription to the Bing newsletter;
3.2.4. to provide you with offers relating to Bing Products and additional marketing materials
where you have provided your consent to receive marketing from Us. You can withdraw your
consent at any time, including by clicking on the “unsubscribe” link at the bottom of any
marketing email we send you;
3.2.5. where we need to comply with a legal obligation;
3.2.6. where it is necessary for our legitimate interests (or those of a third party) and your
interests and fundamental rights do not override those interests.
We may also use your personal information in the following situations, which are likely to be rare:

3.2.7. where we need to protect your interests (or someone else’s interests).
3.2.8. where it is needed in the public interest or for official purposes.
3.3 In some cases, we may use your personal information to pursue legitimate interests of Our own or
those of third parties, provided your interests and fundamental rights do not override those interests.
The situations in which we will process your personal information based on legitimate interests are
listed below:
3.3.1. to optimise and improve the performance and content on the Bing Products;
3.3.2. to provide you with information about the Bing Products that might include marketing
and promotional activities in relation to the Bing Products;
3.3.3. to provide you, or permit selected third parties to provide you, with information about
goods or services we feel may interest you;
3.3.4. to notify you about changes to the Bing Products;
3.3.5. to ensure that content from the Bing Products is presented in the most effective
manner for you and for your computer;
3.3.6. to prevent fraud or harm to Us or to any third party, and ensure the security of the Bing
Products and Our network;
3.3.7. where it is necessary to enforce Our rights, for example enforce the claims We may
have against you in connection with your use of the Bing Products.
Change of purpose
3.4 We will only use your personal data for the purposes for which we collected it, unless we
reasonably consider that we need to use it for another reason and that reason is compatible with the
original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and
we will explain the legal basis which allows us to do so.
3.5 Please note that we may process your personal data without your knowledge or consent, in
compliance with the above rules, where this is required or permitted by law.
4.1 We may have to share your data with third parties, including third-party service providers. We
require third parties to respect the security of your data and to treat it in accordance with the law. 
4.2 Selected third parties include:
4.2.1. business partners and service providers who help manage our IT and communications in
order to tailor marketing and advertising and host the Bing App and Site; and
4.2.2. analytics and search engine providers that assist us in the improvement and optimisation
of the Bing Products.
4.3 We will also disclose your personal data to third parties:

4.3.1. In the event that we sell or buy any business or assets, in which case we will disclose your
personal data to the prospective seller or buyer of such business or assets.
4.3.2. If Acamar Films Limited or substantially all of its assets are acquired by a third party, in
which case personal data held by it about its customers will be one of the transferred assets.
4.3.3. If we are under a duty to disclose or share your personal data in order to comply with
any legal obligation, or in order to enforce or apply terms and conditions of sale and other
agreements; or to protect the rights, property, or safety of Acamar Films Limited, our
customers, or others. This includes exchanging information with other companies and
organisations for the purposes of fraud protection and credit risk reduction.
We may store your personal data on our own servers as well as those operated by third party data
hosting providers. All information you provide to Us is currently processed and stored by Our data
processor: Mail Chimp, a Georgia limited liability company whose legal name is The Rocket Science
Group LLC d/b/a Mailchimp, based in the US, who manage our subscriber database and process the
newsletter mailouts on behalf of Acamar Films Limited. Mail Chimp’s privacy policy can be found

6.1 Information we maintain may be stored both within and outside of the European Economic Area
(EEA). Where possible, we try to keep the information you supply to us locally. However, as part of our
services offered through the Bing Products, the information you provide to us may be transferred to
countries outside the EEA or the UK. This site is subject to U.K. laws, which may not afford the same
level of protection or data protection laws to those in your country.
Transfers outside of the EEA
6.2 If we transfer your information outside of the EEA or UK as described in the above paragraph, we
will take appropriate steps to ensure that any personal data relating to you will be transferred in
accordance with this policy and as permitted by the applicable laws on data protection. We rely on
European adequacy decisions or use contracts with standard safeguards published by the European
Commission and similar measures under UK laws for such transfers.
6.3 By way of example, when we transfer data to Mail Chimp, a company based in the US, we rely on
approved data transfer mechanisms such as the EU “Standard Contractual Clauses” to ensure your
information is subject to adequate safeguards in the recipient country.
7.1 We have put in place appropriate security measures to prevent your personal information from
being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.  This includes
secure socket layer (SSL) technology to ensure your details are safe and information you provide is
fully encrypted so that it cannot be read by third parties.

7.2 In addition, we limit access to your personal information to those employees, agents, contractors
and other third parties who have a business need to know. They will only process your personal
information on our instructions and they are subject to a duty of confidentiality.
7.3 We have put in place procedures to deal with any suspected data security breach and will notify
you and any applicable regulator of a suspected breach where we are legally required to do so.

8.1 We will only retain your personal information for as long as necessary to fulfil the purposes we
collected it for and specified in section 3 of this policy.
8.2 When We use your personal data for direct marketing purposes, We will retain your data until you
opt-out from receiving the marketing materials in accordance with data protection laws, provided that
we will need to retain certain information to maintain a record of your request. We may also retain
your personal data for such time that is required to pursue Our legal claims and compliance with our
legal obligations (such as tax and accounting obligations).
8.3 In some circumstances we may anonymise your personal information so that it can no longer be
associated with you, in which case we may use such information without further notice to you.

Your duty to inform us of changes
9.1 It is important that the personal data we hold about you is accurate and current. Please keep us
informed if your personal data that you voluntarily share with us changes at any point in the future.
Notice to EU residents
Your rights in connection with personal information
9.2 Under certain circumstances, by law you have the right to:
9.2.1. Request access to your personal information (commonly known as a “data subject access
request“). This enables you to receive a copy of the personal information We hold about you
and to check that We are lawfully processing it.
9.2.2. Request correction of the personal information that we hold about you. This enables you
to have any incomplete or inaccurate information We hold about you corrected.
9.2.3. Request erasure of your personal information. This enables you to ask us to delete or
remove personal information where there is no good reason for Us continuing to process it. You
also have the right to ask Us to delete or remove your personal information where you have
exercised your right to object to processing (see below).
9.2.4. Object to processing of your personal information where We are relying on a legitimate
interest (or those of a third party) and there is something about your particular situation
which makes you want to object to processing on this ground. You also have the right to object
where We are processing your personal information for direct marketing purposes.

9.2.5. Request the restriction of processing of your personal information. This enables you to
ask Us to suspend the processing of personal information about you, for example if you want
Us to establish its accuracy or the reason for processing it.
9.2.6. Request the transfer of your personal information to another party.
9.2.7. File a complaint with a data protection authority that supervises our personal data
processing activities (such as the UK Information Commissioner’s Office) if you think we gave
processed your information in a manner which is unlawful or breaches your rights. If you have
such concerns we request that you initially contact us (using the contact details below) so that
we can investigate, and hopefully resolve your concerns. Since We are a company with a
registered office in the United Kingdom, our processing activities are supervised by the
Information Commissioner’s Office (“the ICO”). More information on the ICO’s, including
instructions on making a complaint, is available at:
9.3 If you want to review, verify, correct or request erasure of your personal information, object to
the processing of your personal data, or request that we transfer a copy of your personal information
to another party, please contact Our Data Protection Officer via email to:
No fee usually required
9.4 You will not have to pay a fee to access your personal information (or to exercise any of the other
rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or
excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
9.5 We may need to request specific information from you to help us confirm your identity and ensure
your right to access the information (or to exercise any of your other rights). This is another
appropriate security measure to ensure that personal information is not disclosed to any person who
has no right to receive it.
Right to withdraw consent
9.6 In the limited circumstances where you may have provided your consent to the collection,
processing and transfer of your personal information for a specific purpose, you have the right to
withdraw your consent for that specific processing at any time. To withdraw your consent, please
contact Once we have received notification that you have withdrawn your
consent, we will no longer process your information for the purpose or purposes you originally agreed
to, unless we have another legitimate basis for doing so in law.

Our Site and the Bing App may, from time to time, contain links to and from the websites of our
partner networks, advertisers and affiliates.  If you follow a link to any of these websites, please note
that these websites have their own privacy policies and that we do not accept any responsibility or
liability for these policies.  Please check these policies before you submit any personal data to these

11.1 Automated decision-making or profiling takes place when an electronic system uses personal
information to make a decision without human intervention. We are allowed to use automated decision-
making in the following circumstances:
11.1.1. Where it is necessary to perform the contract with you and appropriate measures are in
place to safeguard your rights.
11.1.2. In limited circumstances, with your explicit written consent and where appropriate
measures are in place to safeguard your rights.
11.2 We use information we have about you to tailor the content of communications that are sent to
you to try to ensure that the offers are as relevant to you as possible and so you have exclusive access
to the best deals.
11.3 You will not be subject to decisions that will have a significant impact on you based solely on
automated decision-making, unless we have a lawful basis for doing so and we have notified you.

12.1 We are concerned to protect the privacy of children aged 16 or under. We do not knowingly
collect or process personal data from or with respect to children aged 16 or under without your
permission. You must be 16 years of age or older in order to use the Bing Products and make purchase
through the Bing App. The Bing App has parent gating to get to an adult section and/or to link out of
the Bing App.
12.2 If you are aged 16 or under‚ please get your parent/guardian’s permission beforehand whenever
you provide us with personal information.
12.3 If you are a parent or legal guardian and believe that your child aged 16 or under has submitted
his or her personal data or other data without your consent, permission, or authorization – please let
Us know immediately, and We will promptly act to remove your child’s data from our database.

Any changes we make to our privacy policy in the future will be posted on this page and, where
appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to
our privacy policy.


1.1 A cookie is a text-only string of information that a website transfers to the cookie file of the
browser on your computer’s hard disk so that the website can remember who you are. A cookie will
typically contain the name of the domain from which the cookie has come, the “lifetime” of the cookie,
and a value, usually a randomly generated unique number.
1.2 Two types of cookies are used on the Site depending on the cookie owner:

1.2.1 First-party cookies – these are cookies that contain the same domain on which the cookie is
placed, i.e. We place an cookie on website;
1.2.2 Third-party cookies – there are cookies that contain a domain that is different to the domain on
which it is placed, i.e. these are cookies used by Our providers or other parties (such as ad providers)
on our domain (e.g. cookies places on website).
These cookies can also be categorised from their purpose of use perspective:
1.2.3 Strictly necessary cookies: these are cookies that enable core functionality of the Site, such as:
security, network management, and accessibility. You may disable these cookies by changing your
browser settings, but this may affect how the Site functions.
1.2.4. Optional cookies:
a). performance and analytical cookies that help us:
(i) to measure and improve the performance of the Site;
(ii) to improve the Site by collecting and reporting information on how you use it;
(iii) to provide enhanced functionality and personalization of the Site by helping a website to
arrange content to match your preferred interests more quickly;
(iv) to help us recognise you as a unique visitor (just a number) when you return to the Site and
to allow us to tailor content or advertisements to match your preferred interests or to avoid
showing you the same adverts repeatedly;
(v) to compile anonymous, aggregated statistics that allow us to understand how users use the
Site and to help us improve the structure of our website. We cannot identify you personally in
this way;
(vi) within research surveys to ensure you are not invited to complete a questionnaire too
often or after you have already done so.
b). Targeting/advertisement cookies that are dropped on the Site when you use it by third
party marketing and advertising networks to build a profile of your interests and show you
relevant advertisements on other websites.
Taking into account the lifetime of the cookie, these can be divided into two categories:
1.2.5. Session Cookies: which are temporary cookies that remain in the cookie file of your browser
until you leave the Site to allow you to carry information across pages of our Site and avoid having to
re-enter information. Session cookies retain data for approximately 1 hour.
1.2.6. Persistent cookies: which remain in the cookie file of your browser for much longer (though how
long will depend on the lifetime of the specific cookie).
1.5 Most major websites use cookies. Cookies cannot be used by themselves to identify you.

2.1 WordPress (__cfduid) – Strictly necessary
2.2 Google Analytics (_ga) – Performance measurement
2.3 Facebook Pixel (_fbp) – Targeting/Advertising
2.4 Google Doubleclick (DSIS) – Targeting/Advertising

3.1 You have the ability to accept or decline cookies by modifying the settings in your browser.
3.2 We also attach below a list of help links for major Web browsers where you can change your
cookie settings:

3.2.1 Internet Explorer:
3.2.2. Google Chrome:
3.2.3. Safari:
3.2.4. Firefox:
3.3 You may also refuse the use of optional cookies by using the tool that we provide via cookie banner
on the Site by leaving the small checkbox next to Optional cookies empty.
3.4 You can change your cookie setting anytime. However, you may not be able to use all the
interactive features of the Site if cookies are disabled.

For more information about how cookies are used on our Website and about your rights, please contact
Us at


You can contact Acamar Films by email or by post:

Acamar Films Limited
Ground Floor
The Rotunda
42-43 Gloucester Crescent
London NW1 7DL

Tel: 020 3675 7450