Prime Focus Privacy and Cookies Notice

Introduction and scope
Prime Focus is committed to protecting the privacy and security of your personal information.
This Privacy and Cookies Notice 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.
If you access the products and services of other Prime Focus or DNEG companies and businesses, you should refer to their privacy notices.

Types of information we process and where it comes from

• 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), employer and marketing preferences.
• Information relating to your interactions with us.
• Information about our content, products and services that you have enquired about.
• IP addresses, MAC addresses, unique identification numbers, 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
Your personal data is used by PFL for the following purposes and legal bases:

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.
• For advertising, marketing, business development and public relations purposes. This may include communications by post, telephone, SMS, email or other electronic means, using contact details you or your representatives have provided to us.
• 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.
• 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 and DNEG worked, 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.
• 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.

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.

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 suppliers and partners to process your personal data for the purposes described above. Where these suppliers and partners act on our behalf they must only process your personal data in accordance with our instructions. The categories of suppliers and partners that we use include:

• IT and information technology and services companies
• Other companies within the Prime Focus Limited Group
• Marketing and PR companies that deliver our communications
• Companies that manage and maintain website content
• Freelancers

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.

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 information 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.

Your data subject rights
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”).

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.
For individuals who are resident in California, please be aware that PFL does not sell your personal information.

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 or use an app. 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?

Essential Cookies:
These cookies are needed to provide the content, product or service you have asked for. We use essential cookies for the following purposes:

• Enabling you to stream content properly
• Make sure our website is working properly
• Remembering if you've been to the site or app before
• Enabling features of our service.

Performance 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.

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.

This Privacy and Cookies Notice was last updated on 07 November 2022.