Privacy Policy - Flagship Cinemas

CINEMAPLUS PRIVACY POLICY

Effective Date: December 3, 2025

This Privacy Policy describes the privacy practices of CinemaPlus, LLC ("CinemaPlus," "we," "our," or "us") with respect to how we collect, use, disclose and share the information you provide when you complete a transaction through our services, including the CinemaPlus.com website and the CinemaPlus hosted service and applications used by exhibitors and website operators ("Services"), or interact with our Services, email us or use any other communication that links to or references this Privacy Policy. If a specific Service has an applicable privacy policy for such Service, then such privacy policy shall govern for that specific Service.

In addition, (a) to the extent a theater owner, operator of theater chains, cinema exhibitor, ticket syndicator, ticket aggregator, website publisher, or other third party with whom we have a contractual relationship (each, an "Operator") validly adopts this Privacy Policy, then such Operator's collection, use, and processing of Personal Data shall be governed by this Privacy Policy; provided, however, that where such Operator maintains its own privacy policy that conflicts with this Privacy Policy, this Privacy Policy shall control with respect to the Services provided by CinemaPlus; and (b) to the extent an Operator maintains its own privacy policy ("Operator Privacy Policy"), such Operator Privacy Policy will govern such Operator's collection, use, and processing of Personal Data.

This Privacy Policy does not apply to Personal Data that an Operator may collect from you outside of our Services. Each Operator is solely responsible for its own data collection and processing activities conducted outside of our Services. To understand how an Operator manages your Personal Data in those instances, please refer to the relevant Operator's privacy policy or contact the Operator directly. We are not responsible for the privacy practices of any Operator.

This Privacy Policy also does not apply when we process Personal Data in the role of a processor or service provider on behalf of an Operator, such as when we create or manage websites or newsletters on behalf of an Operator, unless the Operator validly adopts and hyperlinks to this Privacy Policy to describe their collection, use, and process of Personal Data. When an Operator validly adopts and hyperlinks to this Privacy Policy, we process Personal Data in the role of a processor or service provider on their behalf.

A reference to CinemaPlus is a reference to CinemaPlus, LLC, and its relevant affiliates involved in the collection, use, sharing, or other processing of Personal Data.

Before using or submitting information to the Services please review this Privacy Policy carefully, as well as the terms of service (the "Ticket Buyer Terms of Service"), available through our application and at CinemaPlus Terms of Service, which governs your use of the Services.

1. Personal Data We Collect

Personal Data You Give Us. You may give us Personal Data by buying movie tickets via the Services, signing up for an online account, entering information through our online forms or surveys, inputting information while using the Services, or contacting us for information or customer service.

The categories of information include:

Identifiers, such as real name, alias, postal address, online identifier, device identifier, Internet Protocol address, email address, account name, or other similar identifiers.
Categories of personal information described in Section 1798.80(e) of the California Civil Code, such as name, address, telephone number, bank account number, credit card number, debit card number, or any other financial information.
Characteristics of protected classifications under federal or California law, such as age.
Commercial information, such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or other electronic network activity information.
Geolocation data.
Inferences drawn from the above categories of information.

The categories of sensitive information include:

Account log-in, in combination with any required security or access code, password, or credentials allowing access to the account.

Information We Automatically Collect. Like many website operators, we collect information that your browser sends whenever you visit our Services. This includes log data, such as your computer’s IP address, browser type, browser version, the webpages that you visit, the time and date of your visit, the time spent on those pages and other statistics, and whether you reached our page via a social media or email campaign. This information may be collected via several technologies, including cookies, web beacons, clear GIFs, canvas fingerprinting and other means, such as Google Remarketing and Facebook Pixel. You can control cookies in your browser to enable or disable them.

Location Information. You may opt-in when prompted to allow us to collect real-time location information for use of our Services with your mobile device. CinemaPlus may then use that location information to provide real-time information about theaters near you and their show times. If you wish to opt-out of sharing your location data, you can manage your preferences or disable the GPS on your mobile device.

Information We Collect From Third Parties. If you access our Services through third parties (e.g., Facebook or Google), or if you share content from our Services to a third-party social media service, the third-party service will send us certain information about you if the third-party service and your account settings allow such sharing. The information we receive will depend on the policies and your account settings with the third-party service.

Third Party Links and Websites. Our Services may contain links to and from the websites of third parties. If you follow a link to any of these websites, please note that these websites may 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 data to these websites.

2. How We Use Your Data

We use your Personal Data for the following purposes:

Providing Services to you, which includes:
- Maintaining and servicing accounts,
- Providing customer service,
- Processing and fulfilling orders and transactions,
- Verifying customer information,
- Processing payments, and,
- Providing advertising and marketing services.
Providing analytic services, such as analyzing customer usage and improving the Services.
Detecting security incidents, protecting against fraudulent or other criminal activity, debugging and repairing errors, and maintaining the overall quality and safety of our Services.
Conducting market research and project planning.
Administering subscription and loyalty programs.
Fulfilling our legal and financial obligations.
Sharing your website visitor activity, through website cookies, with third-party marketing partners to market our Services on websites that you may visit.

Marketing. We may use your Personal Data to contact you with newsletters, marketing or promotional materials, and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe instructions provided in any email we send, or you can contact us using the contact details provided in the “Contact Us” section below. You will still continue to receive service-related messages concerning products and services you have purchased (unless we have indicated otherwise).

3. How We Share Your Data

Affiliates and Service Providers. We share your information with our third-party service providers, affiliates, and any subcontractors as required to offer you our products and services. These entities help us to:

Run, operate, and maintain our Services through third-party platforms and software tools;
Perform content moderation and crash analytics;
Run email and mobile messaging campaigns;
Perform marketing analytics;
Provide measurement services and targeted ads (you can opt out of these services at websites such as http://www.aboutads.info/choices and http://www.youronlinechoices.eu/);
Administer sweepstakes and promotions, including registering attendees, managing check-in and attendance, verifying eligibility and prize fulfilment;
Provide payment attribution; and,
Provide technical and customer support.

Some external service providers may also collect information directly from you (for example, a payment processor may request your billing and financial information) in accordance with their own privacy policy. These external service providers do not share your financial information, like full credit card numbers, with us, but may share limited information with us related to your purchase, like your IP address, the last 4 digits of your credit card, your zip code, and the credit card brand.

Operators. The Personal Data collected under this Privacy Policy may be provided to Operators so that they can authorize admission to specific movie theater locations for movie show times, handle attendance related issues and administer exhibitor loyalty programs. The categories of Personal Data that may be shared with Operators under this Privacy Policy include:

Identifiers, such as real name, email address, or other similar identifiers.
Categories of personal information described in Section 1798.80(e) of the California Civil Code, such as name and telephone number.
Characteristics of protected classifications under federal or California law, such as age.
Commercial information, such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or other electronic network activity information.

Social Media. From your interaction with our Services, you may allow us to have access to information on one or more of your social media profiles or social media networks. When you supply information from one or more of your social media accounts, we may use the information to deliver you specific content, customize your online experience, and send you news, special offerings and rewards. When you provide us information through social media, it may be available for the public to view including other members of these social media networks which may result in your Personal Data being accessed and used by other third parties.

Aggregated or Deidentified Data. We may aggregate, deidentify, or otherwise strip information of all personally identifying characteristics and may share that aggregated, deidentified, or anonymized data with third parties or publish it. We reserve the right to make use of any such data as we see fit.

Change of Control. Personal Data may be transferred to a third party because of a sale, acquisition, merger, reorganization, or other change in control. If we sell, merge, or transfer any part of the business, part of the sale may include your Personal Data.

Legal Process. We may be required to disclose your Personal Data in response to lawful requests by public authorities, including to meet law enforcement requirements. We may be under a duty to disclose or share your Personal Data to comply with any legal obligation, to enforce or apply our terms and conditions and other agreements, to protect our rights, property, or safety, or to protect the rights, property, or safety of others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.

Third Party Marketing and Advertising Organizations. With respect to website cookies, we may share your Personal Data with third-party marketing and advertising partners to market our Services on websites that you may visit.

4. Children’s Privacy

The Services are not intended for or directed at individuals under the age of 13. We do not knowingly collect Personal Data from individuals under the age of 13. We ask that individuals under the age of 13 do not attempt to use the Services or provide CinemaPlus with information. Should information be collected inadvertently from an individual under the age of 13, reasonable efforts will be implemented to delete this information. If you become aware that a child has provided us with Personal Data, please contact us using the contact details provided at the end of this Privacy Policy.

5. Data Security and Retention

CinemaPlus implements a variety of security measures to maintain the safety of Personal Data you have provided when using the Services. However, no website, application, or transmission can guarantee security. Thus, while we have established and maintain what we believe to be appropriate technical and organizational measures to protect the confidentiality, security, and integrity of Personal Data obtained through the Services, we cannot ensure or warrant the security of any information you transmit to us.

We retain information from or about you for so long as necessary to fulfill the purposes outlined in this Privacy Policy. When the information is no longer necessary for these purposes, we delete it or keep it in a form that does not identify you, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrollment with our products or services, the impact on the Services if we delete some information from or about you, mandatory retention periods provided by law, and the statute of limitations.

6. Cookies and Other Third-Party Integrations

CinemaPlus may use cookies and other third-party integrations (e.g., APIs, SDKs, etc.) in connection with our Services. We reserve the right to change our use of cookies and third-party integrations from time to time.

Cookies are small text files that are stored on your computer or mobile device. They are widely used to make websites and applications work, or work in a better, more efficient way. They can do this because websites can read and write these files, enabling them to recognize you and remember important information that will make your use of a website or application more convenient by remembering preference settings.

Google Analytics. We may use Google Analytics. We use the information we get from Google Analytics only to improve the website. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Please refer to Google’s Privacy Policy for more information. You may also choose to download the Google Analytics opt-out browser add-on.

You may wish to restrict the use of cookies. Please be aware that some of the features of our website may not function correctly if you disable cookies. Most modern browsers allow you to change your cookie settings. You can usually find these settings in the options or preferences menu of your browser. To understand these settings, the following links for commonly used browsers may be helpful:

Personalized Advertising. We may also use targeted advertising cookies, such as Google Ads, to deliver tailored advertising on our website and other websites that you may visit. You can learn more about how to control advertising cookies by visiting the Network Advertising Initiative’s Consumer Opt-Out link, the DAA’s Consumer Opt-Out link for browsers, or the DAA’s opt-out link for mobile devices. Please note that electing to opt-out will not stop advertising from appearing in your browser or applications and may make the ads you see less relevant to your interests.

7. International Transfers of Data

Any data that you provide to us may be accessed, shared, or processed by our offices, located in the United States, and service providers located in the United States, if such data transfer is necessary for the specific purpose for which you submitted your data (such as the provision of goods or services under a written contract). This may entail the transfer of your Personal Data across international borders. The data protection standards may differ and be lower than the standards enforced in your jurisdiction.

8. Privacy Rights and Additional Disclosures for Certain U.S. Residents

Several jurisdictions grant state residents certain rights and disclosures. We provide the following information to further help you understand your potential privacy rights. If you would like to exercise any rights or inquire as to whether such rights are available to you, please email us at legal@cinemaplus.com

Request for Information or Deletion. Residents of certain U.S. states have the right to know whether we are processing your Personal Data, and in some instances, you have the right to request that we disclose to you the categories listed below for the preceding 12 months. We have the right to request verification of your identity for all requests for information. In responding to this right, we shall provide to you:

The categories of Personal Data we collect about you.
The categories of sources from which your Personal Data is collected.
The business or commercial purpose(s) for collecting, selling, sharing, or disclosing your Personal Data, and the categories of Personal Data disclosed for such purpose(s).
The categories of third parties with whom we share your Personal Data.
The categories of Personal Data we have sold, if any, about you and the categories of third parties to whom your Personal Data was sold, by category or categories of Personal Data for each third party to whom the Personal Data was sold.
The specific pieces of Personal Data we have collected about you.

In addition, you may have the right to request we delete your Personal Data.

Request for Correction. Residents of certain U.S. states have the right to request the correction or rectification of inaccurate information in the resident’s Personal Data.

Request for Portable Data. Residents of certain U.S. states have the right to receive, in certain circumstances, a portable format of their Personal Data that allows the data to be transmitted to another entity.

Do Not Sell or Share My Personal Information. Residents of certain U.S. states have the right to opt out of the sale or sharing of the consumer’s Personal Data. However, we do not sell your Personal Data, nor do we share your Personal Data to provide personalized or targeted advertising.

Limiting the Use of Sensitive Personal Information. Residents of California have the right to direct us to use or disclose sensitive Personal Data only for providing goods or services, or as otherwise minimally permitted under applicable law. However, we do not use or disclose sensitive Personal Data for any purpose other than providing our goods and services to you, or as otherwise minimally permitted under applicable law.

Third Party Marketing. If you are one of our California customers, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your Personal Data to third parties for the third parties’ direct marketing purposes.

Automated Processing & Profiling. Residents of certain U.S. states have the right to opt out of the processing of Personal Data for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects concerning a consumer.

Right to Equal Service & Price. You have the right to receive equal service and price, even if you exercise a privacy right.

Appeal Process. In certain cases, we may decline to take action on your request as permitted by law. Should we decline your request, we may provide you with a written explanation of the reasons for our decision and, where required by applicable law, an opportunity to appeal these decisions.

If we deny your appeal, we may provide a written explanation of our decision and, where required by applicable law, instructions on how to contact your local Attorney General or Department of Justice for further review.

9. How We Respond to ‘Do Not Track’ Signals

Some browsers provide you with a way to signal that you do not want your browsing activity to be tracked. The Services may not currently respond to all Do Not Track (“DNT”) or similar signals, as we are awaiting consensus from the Internet policy and legal community on the meaning of DNT and the best way to respond to these signals.

10. Changes to this Privacy Policy

This Privacy Policy may be periodically updated. We encourage you to periodically review this Privacy Policy to ensure you are familiar with the most current version. Please review carefully before submitting Personal Data.

11. Contact Us

If you have any questions regarding this Privacy Policy, please contact us at: legal@cinemaplus.com.

12. Notice of Financial Incentive

Please read this Notice of Financial Incentive (the “Notice”) carefully to learn about the financial incentives that may be offered relating to the collection, use, retention, sale, or disclosure of your Personal Data, and to learn about your rights regarding our financial incentives for your Personal Data.

To the extent an Operator validly adopts this Privacy Policy and provides a Rewards Program, then the Operator’s collection, use, and processing of Personal Data under the Rewards Program shall be governed by this Privacy Policy and this Section 12 shall apply to the Rewards Program. However, to the extent the Operator adopts this Privacy Policy and provides a separate notice of financial incentive for the Rewards Program, then this Section 12 shall not apply.

Incentives Offered. We offer programs, benefits, free products, discounts, and other incentives to you relating to the collection, use, retention, sale, or disclosure of your Personal Data (our “Rewards Program(s)”). Examples of our Rewards Programs include surveys, limited-time promotions, sweepstakes, free tickets, discounts on products or services, and more.

Categories of Personal Data Involved. Our Rewards Programs may involve the following categories of Personal Data from customers who participate:

Identifiers, such as real name, alias, postal address, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
Categories of personal information described in Section 1798.80(e) of the California Civil Code, such as name, address, telephone number, bank account number, credit card number, debit card number, or any other financial information.
Characteristics of protected classifications under federal or California law, such as age.
Commercial information, such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or other electronic network activity information.
Geolocation data.
Inferences drawn from the above categories of information.

The following categories of Personal Data may be sold or used for targeting advertising:

Identifiers, such as real name, alias, postal address, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
Categories of personal information described in Section 1798.80(e) of the California Civil Code, such as name, address, telephone number, bank account number, credit card number, debit card number, or any other financial information.
Characteristics of protected classifications under federal or California law, such as age.
Commercial information, such as products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Internet or other electronic network activity information.
Geolocation data.
Inferences drawn from the above categories of information.

We are providing you with this information so that you may make an informed decision on whether to participate in our Rewards Programs.

Who Receives Your Personal Data. Personal Data provided under the Rewards Program may be shared with the following third parties:

Analytics companies;
Third-party advertisers;
Lenders;
Other merchants; and,
Government agencies.

For the avoidance of doubt, Personal Data provided under the Rewards Program will not be provided to data brokers.

To provide you with the Rewards Programs, we may use the certain partners, other than the Operator(s) to provide you with the benefits listed. If such partners, other than the Operator(s), provide benefits, we will update this Privacy Policy to list them here.

How to Get These Incentives. You can access our Rewards Programs within the Services. You can also contact us to learn more about our Rewards Programs and how to sign up.

How to Opt Out of Incentives. Participation in our Rewards Programs is always optional, and you can terminate program participation at any time by contacting us at legal@cinemaplus.com.

Additional Disclosures. We respect your decision to opt in to our Rewards Program, and we strive to provide financial benefits worth your time and attention. While it is extremely difficult to assign a monetary value to the Personal Data we collect under the Rewards Program, we believe that, based on our reasonable estimates, the value of your Personal Data is reasonably equal to or greater than the value we provide with our financial benefits program.

We arrived at this conclusion by analyzing market trends and similar Rewards Programs and comparing these factors against our good-faith estimate of what we receive from your Personal Data.