Last Updated: September 28, 2023
Filmio International Limited (“Filmio”, “Company”, “we” or “us”) recognizes that your privacy is important, and we take it seriously. This Privacy Policy (the “Privacy Policy”) describes the collection, use, and disclosure of your information when you visit, access, use, or engage in exchanges or transactions on websites, including https://film.io/,(the “Sites”), mobile applications and other mediums operated by us, (collectively the “Services”). Capitalized terms that are not defined in this Privacy Policy have the meaning given to them in the Terms of Use.
By accessing and using the Services and/or Site through which you may provide information to us, you agree to the terms and conditions of this Privacy Policy and the Terms of Use (the “Terms”). If you do not agree to this Privacy Policy and the Agreement, please do not access or use the Sites or Services, nor provide any information to us. We reserve the right to update or make changes to this Privacy Policy from time to time at our sole discretion, and we may notify you of changes by any reasonable means, including without limitation, by notifying you at the email address you provide us in your User Profile or by posting the revised version of this Privacy Policy on the Site, which changes will become effective immediately upon the transmission of such email or posting on the Site, whichever occurs first. Please return to this page periodically to ensure familiarity with the most current version of this Privacy Policy. Your continued access or use of the Services and/or Site after any changes to this Privacy Policy have been made shall constitute your agreement and consent to such changes.
As a condition precedent to your use of this website and participation in the activities and opportunities contemplated hereby, by accepting the Terms and Conditions of Use, and/or using the Sites, Services, and Offerings we provide, you expressly agree as follows:
To request account deletion please click this link and fill out and submit the form at Request Account Deletion.
We collect two categories of data and information: (1) Anonymous Data, and (2) Personal Information, as each is described below.
(a) Anonymous Information
When you visit the Sites, we automatically collect certain information about your device (e.g., computer, tablet, mobile phone), including information about your MAC address, web browser, IP address, time zone, screen resolution, OS type and version, non-personal demographic information, including the approximate geographic location, your activity on the Sites and Services including the date and time of your visit, the pages you visit and the length of time you spend on those pages, referring/exit pages, pages of our Site that you visit, the time spent on those pages, the information you browse and search for on our Sites. We may also use clear GIFs or web beacons to track usage patterns of users on the Site or Services. Additionally, we may use clear GIFs in HTML-based emails sent to our users to track which emails are opened by recipients. and some of the cookies that are installed on your device, as well as other information that does not reveal your specific identity. Additionally, as you browse our Sites and use our Services, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Sites, and information about how you interact with the Sites and Services . We refer to this automatically collected information as “Anonymous Information”. We collect Anonymous Information using the following technologies:
We keep track of certain information about you when you visit our Sites and interact with our Services. This information includes the features you use; the links you click on; frequently used search terms; and how you interact with others on the Services. We also collect information about the people you interact with and how you interact with them, like who you communicate with most frequently.
In addition to the tracking technologies including those described above, other companies may set their own cookies or similar tools when you visit our Sites and use our Services. This includes third-party analytics services, credit bureaus, public databases, blockchain data, advertising networks, marketing partners and resellers that we engage to help analyze how users use our Sites and Services and to provide us information that we may utilize in connection with your Information (collectively, the “Analytics Services”). The information generated by the Cookies or other technologies about your use of our Service (the “Analytics Information”) is transmitted to the Analytics Services. The Analytics Services use Analytics Information to compile reports on user activity, which we may receive on an individual or aggregate basis. We use the information we get from Analytics Services to improve our Service. The Analytics Services may also transfer information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Services’ ability to use and share Analytics Information is restricted by such Analytics Services’ terms of use and privacy policy. By using our Services, you consent to the processing of data about you by Analytics Services in the manner and for the purposes set out above.
(b) Personal Information
We collect information about you when you register for an account, create, or modify your profile, set preferences, sign-up for, interact with, or make purchases through the Services, as well as when you engage in chat or forums, post or share photographs, NFTs, videos, audio, text, links, and other content in all mediums (collectively, the “Content”). For example, you provide your contact information and, in some cases, billing information, when you register for the Services. You also have the option of adding a display name, profile photo, and other details to your profile information to be displayed in our Services. We keep track of your preferences when you select settings within the Services. Personal Information we collect, includes certain information you provide, which may include:
Your Personal Information is required for you to access and use our Sites and Services and do such things as (i) post content and join community forums, (ii) purchase and receive products, goods and Services using our Sites and Services, (iii) mint NFTs and other digital assets, (iv) receive payments and engage in exchange transactions; and/or (v) enter into drops, contests, sweepstakes or other activities that provide you with an opportunity to win prizes, receive discounts, recognition and/or value. Your Personal Information will be accessible and viewable by us and whenever such Personal Information is shared publicly or to non-confidential third parties by you. Through, and as allowed on, our Sites and Services, and pursuant to our Terms, you may enter, transmit, upload, publish and communicate Personal Information. You can delete or terminate your account at any time pursuant to our Terms of Use. Once your account is deleted, you will not be able to recover your Personal Information.
(c) Legal Basis for collecting your Personal Information
We collect, process, and use your information for the purposes described in this Privacy Policy, based at least on one of the following legal grounds:
We use both Personal Information and Anonymous Information (collectively, your “Information”) to provide you access to, and use of, our Sites and Services, and to authenticate you when you log in to our Sites and Services, to monitor and facilitate transactions for you, and operate, maintain, and improve the Services. We are consistently seeking ways to make our Services smarter, faster, more secure, more integrated, and more useful. We use information and collective learnings (including feedback) about how people use our Services to troubleshoot our Services, to identify trends, usage, activity patterns, and areas for integration to improve our Services and to develop new products, features and technologies that benefit our users and the public.
a) Sending Communications. We use your Information to send you communications via email, text, pop-ups, or other mediums, including notices of new updates, drops, features and other promotional communications that may be of interest to you. We also provide tailored communications based on your activity and interactions with our Services and other users. We use your Information to verify your accounts and activity, to detect, prevent, and respond to potential or actual security incidents and to monitor and protect against other malicious, deceptive, fraudulent, or illegal activity, including violations of the Terms and this Privacy Policy.
(b) To Improve our Services. We also use your Information to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Services, including generating analytics about how our customers browse and interact with our Services, and to assess the success of our Services and the way we market, advertise, and promote our Services. Additionally, we may create Anonymous Information records from Personal Information. We use this Anonymous Information to analyze request and usage patterns so that we may improve our Services and enhance navigation and dynamic delivery of content. We reserve the right to use Anonymous Information for any purpose and to disclose Anonymous Information to third parties without restriction. Because Anonymous Information does not identify you, we may use and share with third parties any non-personal information for any purpose, including our own internal business purposes. If non-personal information is combined with any of your personal information, then such combined information will be treated by us as personal information for so long as such information is combined. We may use certain third-party services such as Google Analytics to help understand the use of the Services. Google Analytics collects the information sent by your browser as part of a web page request, including cookies and the approximate geographic location of your IP address. Google Analytics receives this information and their use of it is governed by their Privacy Policy. If you wish to opt-out of Google Analytics and other similar services that we use, you can find instructions in our Cookie Policy. Specifically, we use your Information to do the following:
(c) To comply with applicable law and protect our rights. As we believe to be necessary or appropriate: (i) in any manner permitted under applicable law, including laws outside your country of residence; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (iv) to enforce our terms and conditions; (v) to protect our operations, business and systems; (vi) to protect our rights, privacy, safety or property, and/or that of other Users, including you; (vii) to allow us to pursue available remedies or limit the damages that we may sustain; and (viii) to send you important information regarding the Services or Site, changes to our terms, conditions, and policies, and/or other administrative information. Because this information may be important, you may not opt-out of receiving such communications and continue to use the Site and/or Services.
(d) For our internal scoring system. Filmio uses a proprietary scoring system to calculate a score for each registered user based on film credit and awards history using machine-aided statistical analysis that considers the user’s role, financial performances, associated projects, awards quality, and numerous other factors. Filmio uses the calculated score (as well as other attributes) to automatically surface individual users and projects to other users for communication, attachment, and investment opportunities based on matched attributes and score levels. This part of the Filmio platform also uses a sophisticated machine-learning algorithm to present opportunities to users based on various factors. The automated surfacing of or inclusion in opportunities based on credit score and other factors applies only to registered Users who have agreed to the Filmio Terms of Use.
We share and disclose your Information for the purposes described above and as follows:
(a) Third Party Service Providers. We may share your Information with third party service providers, such as website hosting, data analysis, payment and credit card processing, infrastructure provision, IT services, customer service, e-mail delivery services, and other similar services to enable them to provide services to us, including, but not limited to: providing technical infrastructure services; conducting quality assurance testing; analyzing how our Service are used; prevent, detect, and respond to unauthorized activities; provide technical and customer support; and/or to provide other support to us and to the Services we provide. For example, we use Google Analytics to help us understand how our customers use the Sites and Services.
You can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/ You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
(b) Affiliates. We may share some or all of your Information with any subsidiaries, joint ventures, or other companies under our common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy.
(c) Corporate Restructuring. We may share some or all of your Information in connection with or during negotiation of any merger, financing, acquisition, or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Information may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Information collected by us and will assume the rights and obligations regarding your Personal Information as described in this Privacy Policy.
(d) Legal Rights. Regardless of any choices you make regarding your Personal Information and Anonymous Information we may disclose such information if we believe in good faith that such disclosure is necessary: (i) in connection with any legal investigation; (ii) to comply with relevant laws or to respond to subpoenas, warrants, or other legal process served on the Company; (iii) to protect or defend the rights or property of the Company or the users of our Sites and Services; (iv) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Use Agreement; (v) to protect our operations, business and systems; (vi) to protect our rights, privacy, safety or property, and/or that of other Users, including you; and (vii) to allow us to pursue available remedies or limit the damages that we may sustain.
We represent and warrant that we will comply with all applicable laws, rules, regulations, directives and guidelines regarding the collection, use and disclosure of data collected from or about Users or specific devices which apply to the services utilized hereunder. The term “Rules” shall include, without limitation, (i) United States Federal Trade Commission Laws regarding the collection, use and disclosure of data from or about users and/or specific devices; (ii) the Children’s Privacy Protection Act of 1998 (“COPPA”); (iii) the privacy laws applicable to residents of certain states in United States, and (iv) if applicable, the Rules of any other jurisdiction, including and European Union General Data Protection Regulation), rules, regulations and/or directives promulgated by a pertinent Data Protection Act, and all amendments and updates to them or regulations as replaced or superseded from time to time.
(a) General Data Protection Regulations (“GDPR”). If you are a user in the European Economic Area or United Kingdom, you have certain rights under the respective European and UK General Data Protection Regulations (collectively, “GDPR”). These include the right to (i) request access and obtain a copy of your Personal Information; (ii) request rectification or erasure; (iii) object to or restrict the processing of your Personal Information; and (iv) request portability of your Personal Information. Additionally, if we have collected and processed your Personal Information with your consent, you have the right to withdraw your consent at any time by contacting us at: https://filmio.atlassian.net/servicedesk/customer/portal/4. Additionally, if you are an individual in the European Economic Area (EEA), we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Sites), or otherwise to pursue our legitimate business interests listed above under applicable EU laws. Additionally, please note that your information will be transferred internationally outside of Europe and across national borders, including but not limited to the British Virgin Islands, Canada, and the United States.
(b) California Privacy Rights. If you are a California resident, there are some additional rights that may be available to you under the California Consumer Protection Act (“CCPA”). Pursuant to the CCPA, you may ask businesses to disclose what personal information they have about you and what they do with that information, to delete your personal information and not to sell your personal information. You also have the right to be notified, before or at the point businesses collect your personal information, of the types of personal information they are collecting and what they may do with that information. This Privacy Policy provides you with the information required by the CCPA. Generally, businesses cannot discriminate against you for exercising your rights under the CCPA. Businesses cannot make you waive these rights, and any contract provision that says you waive these rights is unenforceable. While in no manner will we discriminate against you as a California resident seeking to enforce your rights under CCPA, certain Information is required to access and use our Services, without which you will not be allowed to, or unable to, use our Services. We encourage you to manage your Information, and to make use of the privacy controls we have included in our Services. To protect your Information from unauthorized access or deletion, we may require you to provide additional information for verification. If we cannot verify your identity, we will not provide or delete your Information.
(c) Colorado Privacy Rights. As a Colorado resident you have the following rights regarding your personal data under the Colorado Privacy Act (the “CPA”) effective as of July 1, 2023. The CPA grants consumers, or the parents or guardians of children under 13, the right to:
The CPA defines personal data as any “information that is linked or reasonably linkable to an identified or identifiable individual.” Based on this definition, personal data may include information such as individual’s name, email address, phone number, credit card details, IP address, identification number. Additionally, “sensitive data”, refers to a distinct category of personal data that is considered confidential. We would need your explicit consent to collect any of the following:
Colorado residents may exercise any of their rights under this section by contacting us at: https://filmio.atlassian.net/servicedesk/customer/portal/4 or email: [email protected].
(d) Connecticut Privacy Rights. As a Connecticut resident you have the following rights regarding your personal data under the Connecticut Data Privacy Act (“CTDPA”) effective as of July 1, 2023. The CTDPA provides Connecticut residents with the following rights regarding the personal data:
Connecticut residents may exercise any of their rights under this section by sending an email to [email protected]. We will promptly respond to a consumer’s request within 45 days after receiving the request. If reasonably necessary to comply with your request, we may extend this deadline by an additional 45 days upon notice to you stating the reason we need such extension. Note that we may charge a reasonable fee if you make more than one request within a 12-month period or if the request is “manifestly unfounded, excessive, or repetitive.
(e) Nevada Privacy Notice. This section outlines certain rights for Nevada residents. We comply with the requirements as defined under Nevada’s Privacy Law, which provides Nevada residents with choices regarding how we share and collect personal information from you in the course of providing requested services. If you are a Nevada resident, you have the right to submit a verified request to us, directing us not to make any sale of certain Personal Information that we have or will collect about you. The Services does not currently engage in the “sale” (as defined by Nevada law) of personal information. “Nevada Personal Information” includes personally identifiable information about a Nevada consumer collected online, such as an identifier that allows the specific individual to be contacted. Nevada Personal Information also includes any other information about a Nevada consumer collected online that can be combined with an identifier to identify the specific individual. Unless otherwise stated, the Services does not sell any “Covered Information”, as defined under Chapter 603A of the Nevada Revised Statutes. For Nevada residents who wish to exercise their rights under this section and/or for information regarding the categories of Nevada Personal Information that we collect, please contact [email protected]. Please indicate that you are a Nevada resident making a “Nevada Opt-Out” request, and include your name, telephone number and the email address used to access our site. We will respond to requests within 60 days and no more than 90 days after a request is submitted.
(f) Virginia Privacy Notice. As a Virginia resident you have the following rights regarding your personal data under the Virginia Consumer Data Protection Act (the “VCDPA”) effective as of January 1, 2023:
We may collect, use, and disclose your personal data for business purposes. A summary of the categories of personal data collected and the purposes for which it is used can be found below. The VCDPA applies to individuals who are Virginia residents, acting in an “individual or household” context, but does not apply to individuals acting in a commercial context (i.e., as a representative of a business) or employment context. Depending on the specific service or product you use, the categories of Personal Data collected may include:
Additionally, “sensitive data”, a category of personal data, would include the following:
Depending on the specific service or product you use, we may use your personal data for various business purposes, including (a) to provide, manage, support and improve our products and services, (b) to maintain and service your account, (c) to verify you, your account activity and your information, (d) to detect, investigate and report fraud, abuse or illegal use of our products and services or customer accounts, (e) to provide customer service, (f) to provide advertising and marketing to our customers, and (g) to measure our marketing campaigns and to audit consumer interactions. To exercise any of your rights under VCDPA, please submit an email to [email protected].
If you no longer wish to use our Sites and Services, please click this link and fill out and submit the form at support.film.io with your request to deactivate your account. Please be aware that deactivating your account does not delete your Information. Your Information remains visible to other Service users and Third-Party Sites based on your past participation within the Sites and Services. Also, Anonymous Information will not be deleted. We have the ability to delete some Personal Information on the Services we control and allow you the ability to stop public dissemination on the Sites and Services we control, however, it is your responsibility to delete your Information or request that your Information be hidden on the Sites and Services we control, to the extent allowable, by following the instructions on our FAQs. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.
If you choose to use the Sites and Services, your access and use, and any dispute over privacy, is subject to this Privacy Policy, our Cookie Policy and our Terms and Conditions of Use including, but not limited to, limitations on damages, resolution of disputes, and applicable law.
The Services are not directed to or intended for use by children under 13 years of age. If you are a child under the age of 13, please do not attempt to register for or otherwise use the Services or send us any Personal Information. By accessing, using and/or submitting information to or through the Services, you represent that you are not under the age of 13. As noted in the Terms and Conditions, we do not knowingly collect or solicit Personal Information from children under the age of 13. If we learn that we have received any Personal Information directly from a child under age 13 without first receiving his or her parent’s verified consent, we will use that Personal Information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Services. We will then subsequently delete that child’s Personal Information.
The Company may change this Privacy Policy from time to time in its sole discretion with or without notice. We will post any privacy policy changes on this page. We encourage you to review our Privacy Policy whenever you use the Services to stay informed about our information practices and the ways you can help protect your privacy. If you disagree with any changes to this Privacy Policy, you will need to stop using the Services and deactivate your account(s), as outlined above.
If you have any questions about our practices or this Privacy Policy or would like to request assistance from us, you may contact us by clicking this link and filling out and submitting the form at https://filmio.atlassian.net/servicedesk/customer/portal/4 or by mail at Filmio International Limited, Filmio International Limited, Jaylar Place, P.O. Box 216, Road Town, British Virgin Islands.
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