Processing a moviegoer's right to erasure (’right to be forgotten’) with Movio

Data protection laws in certain countries allow individuals (i.e. your moviegoers) the right to request the deletion of their personal data from your and, where you have transferred personal data to a processor (i.e. service provider), your processors’ databases, unless certain exceptions apply. Examples of applicable data protection laws which confer this right include GDPR in the European Union, CCPA in California, and LGPD in Brazil.

The right to data erasure is not the only way in which applicable data protection laws may place an obligation on you to consider whether to delete moviegoer data. As a controller or business collecting personal data, you will need to determine your legal obligations as a matter of applicable data protection law.

Movio, as your processor or service provider, will action your deletion request as set out in this Guide. Please note that any deletion actioned by Movio will relate to personal data held by Movio in Movio’s databases and systems only.

The scope, applicability and exemptions to the right to erasure vary between applicable data protection laws. Data protection laws typically give you a timeframe within which you must respond to a request. For example, under GDPR a controller has one month to respond and under CCPA a business has 45 calendar days to respond. Movio will respond to a request without undue delay and no later than one month from the date Movio receives the request from you.

Where you wish to delete personal data following a moviegoer’s request for their personal data to be deleted, you will need to forward the request to Movio by following these steps:

1. Exhibitor receives the request from the moviegoer
2. Exhibitor considers its obligation to delete data and agrees to the deletion
3. Exhibitor logs a Deletion Request on Movio's support site located at help.vista.co, including the following data points (see attached file):
   • Email address
   • Date the request was made to the Exhibitor
4. Unless your loyalty platform automatically actions moviegoer deletion requests and anonymizes the data, the Exhibitor will mark the moviegoer as deleted in their loyalty platform
5. Following completion of step 4 above, Movio will action the request without undue delay
6. Your Movio Account Manager will send you a confirmation providing details of the information erased and the date of erasure within the timeframe specified above

This article is intended as a general overview of the subject it deals with. It is not intended to be, and should not be used as, a substitute for taking legal advice in any specific situation. Movio will not accept liability for any actions taken or not taken based on this Guide.