Privacy Policy (GDPR)

1. Who is responsible for your data?

Data Controllers: N.V. Sony Pictures Releasing S.A. (Hooikaai 55, 1000 Brussels, VAT BE 0402.201.194) and Columbia Pictures Corporation, Ltd. (together "Sony Pictures"). They determine the purpose and legal framework of the data processing.

Data Processor: Production Pirates BV (Dikberd 34/3c, 2200 Herentals, VAT BE 0845.588.986). Production Pirates acts as processor, technically hosting the online platform and collecting the data under the secure instruction of Sony Pictures.

2. What data is collected?

Only the following personal data is processed via the online platform:

• Contact details: First name, last name and email address.
• Game and score data: Points scored in the Time Challenge (max. 100), points scored in the Scent Challenge (max. 100), Photobooth participation status (for awarding the 50 bonus points), and the total final score (max. 250).
• Technical logs: Registration timestamp (also used for the tie-break rule) and stored opt-in choices.

Photobooth clarification: The online contest platform does not process, store or synchronise any photo files. The interaction is limited purely to awarding the numeric bonus score to the user profile.

3. Purposes and Legal Bases for the Processing

Organising the contest (Art. 6(1)(b) GDPR - Contractual necessity): Correctly processing the registration, determining the leaderboard via scores (with registration time as the tie-break rule), selecting the 10 winners, and delivering the duo tickets for Heart of the Beast.

Direct Marketing & Newsletters (Art. 6(1)(a) GDPR - Consent): Only if you explicitly checked the optional marketing checkbox(es), your data is used by Sony Pictures to send you film news, releases and promotional updates.

4. International Transfer

If you consent to marketing communications, data may be transferred to and stored centrally by Sony Pictures Entertainment Inc. in the United States in accordance with the provisions of Chapter V of the GDPR (including the EU-US Data Privacy Framework and/or Standard Contractual Clauses).

5. Retention Periods

Production Pirates BV: Stores participant data only for as long as necessary for the contest and the winners' response period. Within 30 calendar days after final transfer to Sony Pictures and completion of the promotion, all local files are deleted.

Sony Pictures: Keeps contest administration records for the statutory limitation periods. Marketing data is kept until you withdraw your consent or unsubscribe.

6. Your Rights and Contact

Under the GDPR you have the right to access, correct, erase, restrict processing of, object to, and port your data. Consent for newsletters can be withdrawn at any time via the unsubscribe link at the bottom of every email.