Effective date: 23 February 2023
Last updated: 29 May 2026
Contact (Privacy & Legal): [email protected]
DPDPA Section 9 — Verifiable Parental Consent: In accordance with Section 9 of the Digital Personal Data Protection Act, 2023, LowLightKing will not process personal data of individuals below the age of 18 without obtaining verifiable consent from a parent or lawful guardian as required by applicable Rules. On-set involvement of minors in productions requires a signed parental/guardian release form as a pre-condition to filming. Where processing of children’s personal data is involved in our services, we implement age-appropriate safeguards as required under the DPDPA and Rules notified thereunder.
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:
- Deliver Services (plan, shoot, edit, grade, deliver assets, manage projects)
- Client management (quotations, proposals, invoicing, payments, account administration)
- Production operations (casting, crew hiring, schedules, permits, logistics, safety)
- Quality, security, and fraud prevention (access control, incident detection, abuse prevention)
- Legal and compliance (tax, accounting, audits, lawful requests, dispute handling)
- Marketing and growth (portfolio, case studies, announcements, lead generation—see Section 10)
- 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. Cross-border transfers of personal data occur only to countries or entities permitted under Section 16 of the Digital Personal Data Protection Act, 2023 and as may be notified by the Government of India from time to time. We apply appropriate technical and organisational measures consistent with applicable Indian data protection law.
9) Film/video-specific privacy rules (critical)
A) Releases and approvals
Where legally required or contractually agreed, we use talent releases, location 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).
Data Protection Board of India: The Data Protection Board of India (once operationalised under the Digital Personal Data Protection Act, 2023) is the designated adjudicatory authority for complaints and appeals under the DPDPA. You may approach the Board for matters that cannot be resolved through our Grievance Officer mechanism (Section 21 of this Policy).
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: Kerala, India
- Jurisdiction: Courts at Kochi, Kerala
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]
21) Grievance Officer
In accordance with the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, LowLightKing Productions Pvt. Ltd. has appointed a Grievance Officer to address concerns, complaints, and data-related requests from users, clients, and data principals.
Grievance Officer: Paul Joseph, Founder & Director
Company: LowLightKing Productions Pvt. Ltd.
Address: 43/2153 E1, Jewel Homes, Whitefield SRM Road, Lissie Junction, Ernakulam, Kerala – 682018
Email: [email protected]
Phone: +91 99953 70707
Complaints and grievances will be acknowledged within 24 hours and resolved within 30 days of receipt. To raise a grievance, email us at [email protected] with the subject line “Grievance – [Your Name]” and a brief description of your concern.
This mechanism covers complaints relating to privacy, data processing, content, and any other matter arising from your interaction with LowLightKing Productions or this website.
Production Privacy Notice (On-Set / Location Notice)
Our full On-Set Production Privacy Notice — which applies to all active filming locations and production sets — is available as a separate document: View On-Set Production Privacy Notice →
This notice covers what data is collected on set, consent and release requirements, minor (under 18) protections in accordance with DPDPA Section 9, confidentiality obligations, and safety compliance. Print and post at all entry points to active filming areas.