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1. Introduction
 

Sky Bar Pictures Ltd ("we", "our", "us") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, store, and protect your information when you visit our website, engage with our services, or participate in our film projects and investment opportunities.

Company Details:

• Company Name: Sky Bar Pictures Ltd

• Registered in: England and Wales

• Company Registration Number: 16647649

• Registered Office: 167-169 Great Portland Street, London, England, W1W 5PF

• Contact Email: info@skybarpictures.com

• Data Protection Officer: Ben Hardyment
   

2. Legal Basis
 

We process personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Our lawful bases for processing include:

• Consent: You have given clear consent for us to process your personal data

• Contract: Processing is necessary for a contract we have with you

• Legal Obligation: Processing is necessary to comply with the law

• Legitimate Interests: Processing is necessary for our legitimate interests
   

3. Information We Collect
 

3.1 Information You Provide Directly

• Contact Information: Name, email address, phone number, postal address

• Professional Information: Job title, company, industry experience, portfolio details

• Investment Inquiries: Financial capacity, investment interests, accreditation status

• Film Project Participation: Casting applications, crew applications, location details

• Communications: Messages, feedback, and correspondence with us

• Event Participation: Information for screenings, premieres, and industry events
   

3.2 Information Collected Automatically

• Website Analytics: IP address, browser type, device information, pages visited

• Cookies and Tracking: Session data, preferences, website usage patterns

• Technical Data: Operating system, screen resolution, referring websites
   

3.3 Information from Third Parties

• Industry Contacts: Referrals from agents, distributors, and industry partners

• Public Sources: Publicly available professional information and credits

• Social Media: Information from linked social media profiles (with consent)
   

4. How We Use Your Information
 

4.1 Film Production Activities

• Managing casting processes and crew recruitment

• Coordinating production schedules and logistics

• Location scouting and management

• Post-production and distribution planning

• Industry networking and partnership development
   

4.2 Investment and Business Development

• Processing investment inquiries and due diligence

• Providing project updates to investors and stakeholders

• Preparing pitch materials and business presentations

• Maintaining investor relations and communications

• Compliance with financial regulations and reporting requirements
   

4.3 Marketing and Communications

• Sending project updates and company newsletters

• Promoting film releases and screenings

• Industry event invitations and networking

• Website personalization and user experience improvement

• Social media engagement and content sharing
   

4.4 Legal and Administrative

• Fulfilling contractual obligations

• Complying with legal and regulatory requirements

• Protecting intellectual property rights

• Maintaining business records and archives

• Dispute resolution and legal proceedings
   

5. Information Sharing and Disclosure
 

5.1 Industry Partners

We may share information with:

• Distributors and Sales Agents: For film distribution and marketing

• Production Partners: Co-producers, financiers, and creative collaborators

• Industry Professionals: Agents, managers, and casting directors

• Festival Programmers: For film submissions and screenings

• Press and Media: For promotional activities (with consent)
   

5.2 Service Providers

We work with trusted third parties including:

• Technology Providers: Website hosting, email services, cloud storage

• Professional Services: Legal, accounting, and business advisory services

• Marketing Agencies: Digital marketing and public relations support

• Event Management: Screening venues and event coordination services
   

5.3 Legal Requirements

We may disclose information when required by:

• Legal Process: Court orders, subpoenas, or legal investigations

• Regulatory Compliance: Film industry regulations and tax authorities

• Intellectual Property Protection: Copyright and trademark enforcement

• Emergency Situations: Protecting safety and preventing harm
   

6. Data Retention

We retain personal data for as long as necessary to fulfill the purposes outlined in this policy:

• Active Projects: Duration of production plus 7 years for business records

• Investment Records: 7 years from completion of investment relationship

• Marketing Contacts: Until consent is withdrawn or contact becomes inactive

• Legal Documents: As required by law, typically 6-7 years

• Website Analytics: 26 months maximum
   

7. Your Rights

Under UK GDPR, you have the following rights:
 

7.1 Access Rights

• Right to Access: Request copies of your personal data

• Data Portability: Receive your data in a structured, machine-readable format
   

7.2 Correction and Deletion

• Right to Rectification: Correct inaccurate or incomplete data

• Right to Erasure: Request deletion of your personal data ("right to be forgotten")
   

7.3 Processing Controls

• Right to Restrict Processing: Limit how we use your data

• Right to Object: Object to processing based on legitimate interests

• Right to Withdraw Consent: Withdraw consent for consent-based processing
   

7.4 Automated Decision Making

• Right to Human Review: Challenge automated decisions affecting you

• Right to Explanation: Understand the logic behind automated processing
   

8. International Transfers

We may transfer personal data outside the UK for:

• International Co-productions: Film projects with overseas partners

• Global Distribution: Worldwide film sales and marketing

• Cloud Services: Data storage and processing services

• Industry Events: International festivals and markets
   

All international transfers are protected by:

• Adequacy Decisions: Transfers to countries with adequate protection

• Standard Contractual Clauses: EU-approved transfer mechanisms

• Binding Corporate Rules: For transfers within corporate groups

• Explicit Consent: Where other safeguards are not available
   

9. Security Measures

We implement robust security measures including:
 

9.1 Technical Safeguards

• Encryption: Data encrypted in transit and at rest

• Access Controls: Multi-factor authentication and role-based permissions

• Regular Backups: Secure data backup and recovery procedures

• System Monitoring: Continuous monitoring for security threats
   

9.2 Organizational Measures

• Staff Training: Regular data protection and security training

• Privacy by Design: Privacy considerations built into all processes

• Incident Response: Procedures for handling data breaches

• Regular Audits: Internal and external security assessments
   

10. Cookies and Tracking

Our website uses cookies and similar technologies:
 

10.1 Essential Cookies

• Functionality: Enable basic website features and navigation

• Security: Protect against fraud and maintain session security

• Performance: Monitor website performance and identify issues
   

10.2 Analytics Cookies

• Usage Analytics: Understand how visitors use our website

• Performance Metrics: Measure website speed and effectiveness

• User Experience: Improve website design and functionality
   

10.3 Marketing Cookies

• Targeted Advertising: Display relevant ads on other websites

• Social Media Integration: Enable social sharing and engagement

• Campaign Tracking: Measure effectiveness of marketing campaigns
   

You can control cookies through your browser settings or our cookie preference centre.
 

11. Children's Privacy

Our services are not directed at children under 16. We do not knowingly collect personal data from children. If you are a parent or guardian and believe we have collected information about a child, please contact us immediately.
 

Exception: For film projects involving child actors, we collect information only with proper parental consent and additional safeguards in compliance with industry standards and child protection laws.
 

12. Changes to This Policy

We may update this Privacy Policy to reflect:

• Legal Requirements: Changes in data protection laws

• Business Changes: New services or business activities

• Technology Updates: New website features or data processing methods

• Industry Standards: Evolving film industry practices
   

We will notify you of significant changes through:

• Website Notice: Prominent notice on our homepage

• Email Notification: Direct communication to registered users

• Version History: Clear indication of changes made
   

13. Contact Information

For privacy-related questions or to exercise your rights:
 

Data Protection Officer:
Ben Hardyment
Sky Bar Pictures Ltd
167-169 Great Portland Street, London, England, W1W 5PF
Email: info@skybarpictures.com
 

General Inquiries:
Email: info@skybarpictures.com
 

Regulatory Authority:

If you're not satisfied with our response, you can contact the Information Commissioner's Office (ICO):

• Website: ico.org.uk

• Phone: 0303 123 1113

• Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
   

14. Definitions

• Personal Data: Any information relating to an identified or identifiable individual

• Processing: Any operation performed on personal data (collection, storage, use, etc.)

• Data Controller: The entity that determines the purposes and means of processing

• Data Processor: The entity that processes personal data on behalf of the controller

• Consent: Freely given, specific, informed agreement to processing
   

Document Control:

• Version: 1.0

• Approved by: Ben Hardyment

• Next Review Date: 12/9/2026
   

This Privacy Policy is governed by English law and the jurisdiction of English courts.

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