Privacy and Cookies Notice

Introduction and scope

Prime Focus is committed to protecting the privacy and security of your personal data.

This Privacy and Cookies Notice (herein referred to as “Notice”) is applicable to the websites it is present and applies to the processing of personal data, including information we collect and store via cookies, by Prime Focus Limited. References in this notice to “Prime Focus”, “PFL”, “we”, “us” and “our” should be interpreted accordingly.

Prime Focus Limited is the Data Fiduciary (referred to as Data Controller) responsible for determining the purposes and means of the processing of your personal data described in this Notice.

Prime Focus Limited Group referred to in this Notice constitutes of Prime Focus Limited, Prime Focus Studios, Prime Focus Technologies, DNEG, Redefine and Stereo. If you access the products and services of other companies of Prime Focus Group and businesses, you should refer to their privacy notices.

Types of information we process and where it comes from

We collect information about you when you interact with us, whether through our website, applications, at events, or through other channels. This section details the kinds of information we gather and its sources:

Information you've provided to us, including through our websites or applications, or when you attend one of our events.
Contact details, including your name, and contact information (such as phone numbers, email addresses and), employer, and marketing preferences.
Information relating to your interactions with us (e.g., website visits, feature usage, communication history).
Information about our content, products and services that you have enquired about.
IP addresses, MAC addresses, online identifiers (including device IDs and advertising IDs), browser information, location data port information, logical network address, and other similar identifying information required for your devices to communicate with websites and applications on the internet.
Technical information from the devices you use to access PFL content, products and services, for example, the collection of diagnostics (e.g. errors and system statuses) and traffic or location information. Note that devices and applications have their own privacy settings and notices under which they collect your information, so please check and manage your device and application settings.

How we use your information and the legal bases

Your personal data is used by PFL for the following purposes and rely on the following legal bases for processing.

In reliance on PFL’s legitimate interests, including:

To respond to general enquiries, queries and complaints from members of the public, the media and investors and to communicate with business contacts.
To gather expressions of interest in, and to help coordinate, plan and administer events with our legitimate interests in organizing and running successful events, managing attendance, and promoting our activities.
For advertising, marketing, business development and public relations purposes, where consent is not required and our legitimate interest is in promotion of our business and services. Our interests do not override your fundamental rights and you may opt-out of receiving these communications. This may include communications by post, telephone, SMS, email or other electronic means, using contact details you or your representatives have provided to us.
For research and development purposes related to our industry and services, where this involves anonymised or aggregated data as far as possible, but may occasionally involve personal data.
To capture photographs and videos taken at our events, and to use and communicate the images for marketing and promotional purposes. with an aim to promote our events and activities.
To monitor, record, store and use service communications we have with you. This helps us to improve the quality of our customer service, to confirm any instructions you give us, and/or for training and development. Our interest lies in monitoring and improving the quality of our services, ensuring accuracy of instructions, and staff training. In some cases, this may also be necessary for the performance of a contract with you or to comply with a legal obligation.
To promote our people, services and the content on which we have been engaged. For example, by listing the Credits (the names and job titles) of the cast and crew of content on which PFL, by nominating PFL people for awards consideration and by creating news and press releases.
To protect or enforce our rights or the rights of any third party and prevent and detect fraud, including by analysing activity on our network to help block unauthorised or illegitimate content, publication of or access to it. The processing helps us in protecting our business, assets, and legal rights, and preventing illegal activities. This may also be necessary for compliance with a legal obligation or for the establishment, exercise, or defence of legal claims.
For the protection of the legitimate rights and interests of PFL and/or third parties, including to support legal and compliance activity including the defence of litigation claims. This is also necessary for compliance with a legal obligation or for the establishment, exercise, or defence of legal claims.
With our legitimate interest in running our business efficiently and securely, we may process your personal data for our internal business administration and operations, including managing our IT systems, network security, and business continuity.

Where PFL has a legal or regulatory obligation, including:

Responding to legitimate, lawful requests for information from law enforcement and other government agencies and as part of court orders where PFL is legally required to provide the information.
Processing data to conduct internal investigations as part of responding to requests for information and complaints from regulators, and to comply with requirements from regulators.
Monitoring PFL’s compliance with Data Protection obligations and principles and maintaining records to demonstrate such compliance, including managing and responding to requests received from individuals exercising their rights under Data Protection legislation.

Where you have provided your consent, including:

For advertising, marketing, business development and public relations purposes.

Where Vital interest is the legal basis

We will also process your data where we need to in order to safeguard your vital interests or those of another person, for example, to support crime prevention and protect the safety of members of the public and PFL employees

How we share your information

We work with a number of trusted suppliers and partners who process your personal data on our behalf for the purposes described in this Notice. Where these suppliers and partners act on our behalf (i.e. data processors), they are required to process your personal data in accordance with our documented instructions and applicable data protection laws. The categories of suppliers and partners that we use include:

IT and information technology and services companies (to provide and maintain our systems and website)
Other companies within the Prime Focus Limited Group (for internal administration and shared services)
Marketing and PR companies that deliver our communications and promotional activities
Companies that manage and maintain website content and functionality
Freelancers and other service providers who assist us in delivering our services

We may also share personal data with the courts, enforcement agencies (e.g. the police) and with regulatory authorities where this is required, in order for us to comply with our legal and regulatory obligations or in connection with legal proceedings.

In the event the structure of our business changes so that another Prime Focus Limited Group company provides our services, we will pass your personal data to that company. This includes, for example, a merger between us and another company, where another company acquires us or some or all of our assets, where we acquire another company or where our holding company restructures our corporate group.

International Data Transfers

As a global company supporting clients worldwide and working with vendors across the globe, your personal data may be transferred to, and stored at, destinations outside of the United Kingdom or the European Economic Area (EEA) or India. This includes transfers to countries that may not have the same level of data protection laws as that of the EEA, UK or India.

When we transfer your personal data to such countries, we ensure that appropriate safeguards are in place to protect your data in accordance with applicable data protection laws, including the UK GDPR, EU GDPR and the Digital Personal Data Protection Act 2023 of India. These safeguards are designed to ensure that your personal data receives a level of protection equivalent to that afforded within the UK and EEA. The safeguards we may rely on include:

Transferring data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or the UK government (Adequacy Decisions).
Implementing Standard Contractual Clauses (SCCs) approved by the European Commission or the UK Information Commissioner's Office (ICO), which contractually oblige the recipient to protect the personal data.
For transfers within the Prime Focus Group, relying on Binding Corporate Rules (BCRs) if they are in place, or Standard Contractual Clauses.
In limited and specific circumstances, relying on derogations under data protection law, such as your explicit consent or the necessity of the transfer for the performance of a contract with you.

Artistic purposes

As a company involved in visual effects and production, there may be circumstances where our processing of personal data is necessary for artistic purposes in the public interest but that such processing is incompatible with data protection laws (for instance, as part of the exploitation of a production and in publishing lists of cast and crew on our website).

We recognise that in certain specific circumstances, data protection laws such as GDPR may allow for exemptions or derogations from certain requirements where personal data is processed solely for artistic purposes and making certain data protection provisions applicable would be incompatible with such purposes. However, we are committed to upholding data protection principles. We will always use our best efforts to comply with data protection laws and this Notice where possible, balancing the needs of artistic expression in the public interest with your fundamental rights and freedoms.

Your data subject rights

As an individual whose personal data we process (referred to as a "Data Subject" or "Data Principal" depending on your location), you have various rights concerning your data. The specific rights available to you depend on your geographic location and the applicable data protection laws. You have the following rights in relation to your personal data:

To request access to, erasure of, and/or correction of the personal data we hold about you.
To request us to restrict the processing of the personal data we hold about you.
To object to us processing personal data relating to you.
Where you have given us consent to process your personal data, to withdraw that consent at any time.
To obtain certain personal data from us in a format that can be transferred electronically to a third party (also called “data portability”).
To object to decisions based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, where applicable.

For Data Principals in India (under the Digital Personal Data Protection Act, 2023):

In addition to the rights above, if you are a Data Principal resident in India, you also have the following specific rights:

A summary of the personal data being processed and the processing activities undertaken by us.
The identities of all other Data Fiduciaries and Data Processors with whom your personal data has been shared, along with a description of such sharing.
Lodge a complaint, please refer section “How to raise a complaint”.
To nominate another individual to exercise your rights under the DPDP Act on your behalf in the event of your death or incapacity.

For California Residents (under the California Consumer Privacy Act/California Privacy Rights Act - CCPA/CPRA):

If you are a California resident, you may have the right to:

Request to know what personal information we collect, use, disclose, and sell.
Request deletion of your personal information.
Limit the use and disclosure of sensitive personal information.
Please note that PFL does not sell or share your personal information as defined under (CCPA/CPRA).

Please note that some of these rights are not absolute, and whether you can exercise your right depends on the circumstances. We will keep you informed throughout the process.

You may update, correct or modify any information held by PFL, or withdraw your consent where your data is processed on the basis of consent, at any time by contacting us using the details below. All data held by PFL is processed in accordance with all applicable data protection laws, meaning that the data will only be processed and retained for the purposes for which it was originally collected. You can contact us using the details below if you wish to find out more about how to exercise your subject rights.

How long we may keep your information

We will usually only keep your information for as long as we need it for the purposes it was collected, and we apply the following retention periods to your information:

General enquiries and correspondence are retained for 2 years.
Contact details for advertising, marketing, business development and public relations purposes will be retained for a maximum of 3 years after we last contact you.

We keep the data for this length of time for business reasons because the information is helpful if we receive any enquiries or complaints, and so that we are able to verify your identity when you contact PFL.

In some cases, information such as contact information and correspondence with notes and complaints will need to be retained for longer periods for regulatory purposes so that PFL can demonstrate compliance with Data Protection legislation, for example, where we need to evidence that we have responded to and dealt with subject rights requests made by individuals; or to enable us to defend potential legal claims under the statutory periods set out in applicable legislation.

How to contact Prime Focus

If you have any queries or comments about this Privacy and Cookies Notice, please contact us at info@primefocus.com or the Data Protection Officer by email on dataprivacy@dneg.com.

In addition, you can contact the Data Protection Officer by mail at Prime Focus Limited, Prime Focus House, Linking Road, Khar West, Mumbai, 400052, India

How to raise a complaint

If you wish to make a complaint about how PFL uses your information, please contact the Data Protection Officer via email and we will do our best to help. If you are based in the UK and are still unhappy, you can contact the Information Commissioner’s Office via their website.

Cookies Notice

Cookies are created when you visit a website.They are small files that are stored on your device and used to customise your experience.

When you access primefocus.com for the first time, you will be asked to set your cookie preferences for the site.

To help you make your choices this notice explains how we use cookies and similar technologies to collect information when you access our services and how we use that information. We also explain when and how you can manage your cookie preferences.

We use cookies to make your use of our sites and apps quicker, easier and more relevant to you. If you don’t turn these cookies on it may affect your browsing experience. To avoid impacting your browsing experience cookies need to be enabled in your browser settings.

What do we use cookies for?

Required Cookies:

These cookies are necessary to enable the basic features of this site to function, such as providing secure log-in or remembering how far you are through an order. We use essential cookies for the following purposes:

Enabling you to stream content properly
Making sure our website is working properly and displayed correctly
Remembering if you've been to the site before
Enabling features of our service.

Functional cookies:

We use cookies to help improve our website. For example:

To keep track of what pages, content and links are popular and which ones don't get used.
To see how users navigate through our sites, when error messages appear and what caused them.
The information collected using these cookies is grouped with the information from everyone else so we can see overall patterns rather than individual activity. When given the option, we recommend you turn on cookies used for these purposes.

Advertising Cookies

These cookies are used to show you ads that are more relevant to you. We may share this information with advertisers or use it to better understand your interests. For example, Advertising Cookies may be used to share data with advertisers so that the ads you see are more relevant to you, allow you to share certain pages with social networks, or allow you to post comments on our site.

How long do cookies stay on your device?

We do not use session cookies. Persistent cookies, which remain on your device for a set period, are used for non-essential purposes such as tracking analytics, advertising, and remembering your user preferences across visits.

When you set your cookie preferences on one of our sites, we will remember those preferences. We will ask you again to confirm your preferences after 180 days, unless we add new cookies or use non-essential cookies for different purposes in the meantime, in which case we will ask you to confirm your preferences again when we make those changes. Please note that if you change your preferences to reject cookies which you had previously accepted, PFL will stop collecting data from these cookies but some of them may remain on your device until you clear them. To find out how to do this, please see “Other ways to manage your cookie preferences” below.

Managing your cookie preferences

We don’t give you the option to turn off required cookies when you manage your cookie preferences because these cookies are required and necessary to make our sites function properly. For the other categories of cookies referred to above, you can control how they are used on that Prime Focus site. After you have made your initial choice, you can change your preferences via the ‘Cookie Preferences’ link in the footer of the site.

Other ways to manage your cookie preferences

Most modern browsers allow you to see what cookies you have on your device and to clear them all or individually. To find out how to do this, go to aboutcookies.org, which contains comprehensive information on how to do this on a variety of browsers.

Please remember that any settings you change will not just affect the cookies we use. The changes will apply to all websites you visit unless you choose to block cookies only from specific sites.

Deleting cookies means that settings you have made on a site or app will be lost. If you’ve set your preferences to opt out of cookies, this setting will be lost too if that information is stored in a cookie. Blocking all cookies means functionality on our sites and apps may be lost. Therefore, we don’t recommend turning all cookies off when using our sites and apps.

Changes to this notice

We will occasionally update our Privacy and Cookies Notice. We will post a notice of any material changes on our website prior to implementing the changes, and, where appropriate, notify you using any of the contact details we hold for you for this purpose. We encourage you to periodically review this Notice to be informed of how we use your information.