Privacy Policy

Effective date: [23 February 2023]
Last updated: 1 February 2026
Contact (Privacy & Legal): [email protected]

This Privacy Policy explains how LowLightKing Productions (“LowLightKing”, “we”, “us”) collects, uses, discloses, stores, transfers, and protects Personal Data when you interact with our websites, client services, productions, studios/locations, communications, and related platforms (collectively, the “Services”).

This Policy is designed to comply with major global privacy frameworks, including (where applicable) the Digital Personal Data Protection Act, 2023 and Digital Personal Data Protection Rules, 2025 in India.


1) Who we are

LowLightKing is a film and video production company that provides creative development, pre-production, production, post-production, distribution support, and related operational services.

Depending on the engagement:

  • We act as a Data Fiduciary / Controller (we decide why/how data is processed), or
  • We act as a Data Processor / Service Provider (we process data on behalf of clients under contract).

If we are processing data as a Processor, the client’s privacy terms and our production agreement/data processing terms may govern and override parts of this Policy.


2) Scope

This Policy applies to Personal Data collected from:

  • Website visitors, leads, prospects, and social media visitors
  • Clients, client representatives, and brand partners
  • Talent (actors, models, VO artists), crew, contractors, vendors
  • Location owners/representatives and on-site visitors
  • Job applicants and interns
  • Anyone appearing in production footage where applicable (see Section 9)

Not covered: purely personal/household use by you, or third-party sites/platforms you use independently.


3) Definitions

  • “Personal Data” means information that identifies or can reasonably identify an individual (directly or indirectly).
  • “Sensitive Personal Data” (or “special category” data) includes data like government IDs, biometrics, health info, precise location, etc., when regulated as such.
  • “Processing” includes collection, recording, storage, use, disclosure, transfer, deletion, etc.

4) What we collect

A) Data you provide

  • Identity & contact: name, email, phone, company, role, addresses
  • Commercial & project: briefs, scripts, decks, references, budgets, invoices, purchase orders
  • Talent & crew administration: CVs, portfolios, headshots, measurements, scheduling availability
  • Compliance/KYC (when required): passport/visa, national ID, tax details, bank details, invoicing details
  • On-set safety & logistics: emergency contact, dietary needs, medical considerations relevant to safety (only when necessary and proportionate)
  • Communications: messages, recordings of calls/meetings (where lawful and with notice)

B) Data we collect automatically

  • Device & usage: IP address, device type, browser, pages viewed, referrals, timestamps, approximate location
  • Cookies & similar: analytics, performance, security, session management (see Section 11)

C) Data collected during productions

  • Footage & audio: raw and edited recordings (which may include faces/voices)
  • Still images / BTS: production stills, behind-the-scenes captures
  • Location & access logs: studio access logs, visitor registers, call sheets, equipment checkout logs
  • Security: CCTV in studios/controlled premises where posted/notice is provided (where legally permitted)

D) Data from third parties

Platforms used for production collaboration, file transfer, review/approval, casting tools, payroll/contracting tools, payment gateways, couriers, and marketing platforms—only as needed to deliver Services.


5) Why we process Personal Data (purposes)

We process data to:

  1. Deliver Services (plan, shoot, edit, grade, deliver assets, manage projects)
  2. Client management (quotations, proposals, invoicing, payments, account administration)
  3. Production operations (casting, crew hiring, schedules, permits, logistics, safety)
  4. Quality, security, and fraud prevention (access control, incident detection, abuse prevention)
  5. Legal and compliance (tax, accounting, audits, lawful requests, dispute handling)
  6. Marketing and growth (portfolio, case studies, announcements, lead generation—see Section 10)
  7. Improve and maintain our website and workflows (analytics, performance monitoring)

6) Lawful bases for processing

Where required by applicable law, we rely on one or more of the following:

  • Consent (e.g., marketing preferences, certain recordings, certain talent usage)
  • Contract necessity (to perform a production agreement or take pre-contract steps)
  • Legal obligations (tax, labor, accounting, lawful government requests)
  • Legitimate interests (security, preventing misuse, service improvement, business operations)—balanced against your rights
  • Vital interests (rare—e.g., safety emergencies on set)

7) How we disclose Personal Data

We may share data with:

  • Clients (as required to deliver the project)
  • Vendors/Processors (cloud storage, editing platforms, review/approval tools, payroll/contracting, accounting, analytics, email/SMS, hosting)
  • Production partners (studios, equipment rental houses, casting agencies, location managers, couriers)
  • Professional advisers (lawyers, accountants, auditors, insurers)
  • Authorities if required by law, court order, or to protect rights/safety

No resale of your Personal Data: we do not sell personal data as a business model.


8) Cross-border transfers

Your data may be processed in countries other than where you live, depending on production needs and service providers.

We use contractual and technical safeguards for cross-border transfers where required, including recognized transfer mechanisms (e.g., SCC-style clauses where applicable).


9) Film/video-specific privacy rules (critical)

A) Releases and approvals

Where legally required or contractually agreed, we use talent releaseslocation releases, and client approvals to govern how footage/images/audio may be used.

B) Public filming and incidental capture

You acknowledge that filming in public/semi-public environments can incidentally capture individuals. Where required and feasible, we may implement:

  • Notice/signage, controlled sets, consent workflows
  • Blurring/redaction or audio masking (when agreed, legally required, or necessary)

C) Minors

If minors are involved:

  • We require parent/guardian consent and may require additional safeguards
  • We may refuse to proceed if compliance risk is unacceptable

D) Faces/voices and biometric-like elements

Footage can inherently include facial images and voice. We treat production media as sensitive operational content and protect it with access controls and contractual limits.


10) Marketing, portfolio, and case studies

We may showcase work (reels, stills, BTS, case studies) only when:

  • permitted under the client contract, or
  • consent has been obtained, or
  • the content is already publicly released by the client and use is consistent with agreed terms.

If you require no-publicity, it must be agreed in writing in advance.


11) Cookies and tracking

We may use cookies and similar technologies for:

  • Essential: security, session management
  • Analytics: traffic and performance measurement
  • Preference: remembering settings

You can control cookies through browser settings and (where implemented) our cookie banner/preferences.


12) Your rights and choices

Subject to applicable law, you may request:

  • Access, correction, deletion
  • Withdrawal of consent (where applicable)
  • Objection/restriction in certain cases

To exercise rights: email [email protected] with “Privacy Request” and enough details to verify identity. We may reject or limit requests where allowed by law (e.g., legal privilege, security, fraud prevention, contractual restrictions).


13) Data retention

We retain Personal Data only as long as necessary for:

  • production delivery, revisions, archiving (as contracted)
  • legal/tax/accounting and audit requirements
  • dispute prevention/resolution, rights enforcement
  • security and fraud prevention

Production media (raw footage, project files, exports) may be retained longer than standard website data due to operational needs and contractual deliverables—unless the contract specifies deletion or return.


14) Security controls

We use safeguards proportionate to risk, which may include:

  • Role-based access control (least privilege)
  • MFA where available, strong credential policies
  • Encryption in transit and at rest where supported
  • Segmented storage for client projects
  • Audit logs for access and transfers
  • Vendor due diligence and contractual security commitments
  • Incident response and breach assessment procedures

No security program guarantees zero risk.


15) Breach and incident notifications

Where required by law and/or contract, we will notify relevant parties and/or regulators consistent with applicable legal requirements.


16) Audits, compliance, and documentation

We maintain internal records and logs as needed for governance, security, legal defense, and operational continuity. Any client audit rights (if any) are governed by contract and may be refused where confidentiality or risk makes disclosure inappropriate.


17) Third-party links and platforms

Our Services may reference or integrate third-party services (review tools, file delivery platforms, payment gateways). Their privacy practices are not controlled by us. You must review their policies separately.


18) Disputes and priority of documents

If a conflict exists between this Policy and a signed production agreement, the signed agreement controls. Unless overridden by mandatory local law:

  • Governing law: [State], India
  • Jurisdiction: Courts at [City], [State]

19) Updates to this Policy

We may update this Policy from time to time. The “Last updated” date will change. Continued use of Services means you accept the updated Policy to the extent permitted by law.


20) Contact

All privacy, legal, and production data requests: [email protected]


Production Privacy Notice (On-Set / Location Notice)

LOWLIGHTKING PRODUCTIONS — PRODUCTION PRIVACY NOTICE
Contact: [email protected]
Production: [Project Name] | Date(s): [Shoot Date(s)] | Location: [Location]

1) Filming in progress

This area is an active film/video production location. By entering, you acknowledge that video, photographs, and audiomay be recorded and that you may be captured incidentally or intentionally.

2) What we may collect on set

  • Your image/likenessvoice, and actions (via cameras/microphones)
  • Behind-the-scenes recordings and stills
  • Access/visitor records (sign-in logs, badges)
  • Security footage (CCTV) where posted/required for safety and security
  • Limited contact details if required for scheduling, safety, or access control

3) Why we record

Recordings are used for:

  • Producing, editing, and delivering the project
  • Quality control, continuity, and operational documentation
  • Security, incident prevention, and investigation where applicable
  • Client approvals, compliance, and legal defense where necessary

4) Consent and releases

Where legally required or contractually required, we may ask you to sign a release form. If you do not wish to be recorded, you must:

  • Inform the production manager immediately, and
  • Avoid marked filming zones and camera paths as directed
    We may not be able to accommodate non-recording requests in all circumstances (especially in active set areas).

5) Minors

Minors must be accompanied by a parent/guardian. Where minors are filmed, a parent/guardian release is required. Unauthorized presence of minors may be denied access.

6) Confidentiality and IP

All scripts, sets, props, call sheets, shot lists, and captured media are confidential unless expressly authorized. Unauthorized recording (including phone video) may be prohibited and may lead to removal from the set.

7) Safety and compliance

You must follow on-set safety rules, signage, and staff instructions. Entry may be refused or revoked for safety, confidentiality, or operational reasons.

8) Retention and sharing

Captured media and logs may be retained for production, legal, audit, and archival purposes, and may be shared with clients, post-production vendors, insurers, advisers, and authorities when required by law or contract.

9) Questions / requests

For privacy questions or requests relating to on-set data, contact: [email protected]

By entering this area, you acknowledge this Production Privacy Notice.