The 48 Hour Film Project

Welcome to the 48 Hour Film Project's privacy policy. The 48 Hour Film Project (48HFP) respects your privacy and is committed to protecting your personal data.

1. Introduction

This privacy policy tells you how the 48HFP uses your personal data when you visit our website, interact with us, and buy our goods and services.

It also tells you about your privacy rights and how the law protects you.

It is important that you read this privacy policy, together with any other privacy policies we may provide, so that you are fully aware of how and why we are using your data.

This privacy policy was last updated on 24th of May 2018.

If you have any questions, or would like to exercise your privacy rights, please follow the instructions in this privacy policy. See How to contact 48HFP about privacy below.

2. Our website and the 48HFP

Our website at 48hourfilm.com organizes a number of filmmaking competitions that take place in cities around the world and sells registrations and provides information related to these competitions.  The content of the website is aimed at filmmakers, film-lovers, and creative-types in general.

The 48HFP is a US-based corporation that works with a network of local producers around the world.  In most cases; the 48HFP is responsible for this website and any handling of personal data related to competition registration and/or the global newsletter list.  The local producer is responsible for the local email list.

3. Personal data which we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We collect a variety of information about our customers (you!) and visitors to the 48HFP website. This personal data falls into these categories:

• Identity Data includes title, first name, last name, username or similar identifier and an encrypted version of your login/password. If you interact with us through social media, this may include your social media user name.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
  Financial Data includes payment card details.  NOTE: The 48HFP does not retain payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Profile Data includes your username and password, purchases or orders made by you, preferences, feedback and survey responses, as well as any profile data which we have added (for example, using analytics and profiling).
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Usage Data includes information about how you use our website, products and services.
• Tracking Data includes information we or others collect about you from cookies and similar tracking technologies, such as web beacons, pixels, and mobile identifiers.
• Marketing and Communications Data includes your preferences in receiving direct marketing from us and your communication preferences.  The 48HFP never sells its list to third parties.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

4. How is your personal data collected?

We use different methods to collect data from and about you, including through:

Direct interactions

You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by email or social media.

This includes personal data you provide when you:

• sign up to receive the 48HFP newsletter;
• make enquiries or request information be sent to you;
• create an account on our website;
• order our products or services;
• ask for marketing to be sent to you;
• engage with us on social media;
• enter a competition, promotion or survey; or
• contact customer services;

Automated technologies or interactions

As you interact with us, including via the 48hourfilm.com website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may also collect Tracking Data when you use our website.

5. How we use your personal data

• Where we need to perform the contract we are about to enter into or have entered into with you. For example, when you purchase our products, that’s a contract.
• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests. For example, when we carry out fraud screening as part of the check-out process.

Generally, we do not rely on consent as a legal basis for processing your personal data other than where the law requires it, for example in relation to sending certain direct marketing communications. Where our legal basis is consent, you have the right to withdraw consent any time.

6. Advertising, marketing and your communications preferences

We may use your Identity, Contact, Technical, Tracking, Usage and Profile Data to form a picture of what we think may be of interest to you. This is how we decide which products, services and offers may be relevant for you and tell you about them. This is what we call direct marketing.

We may carry out direct marketing by email or social media. For example, you might have the 48HFP newsletter hit your inbox or a promotion through social media.

On our website, we always try hard to make it really clear what we are doing and what communications you will be sent, whether it’s you deciding to sign up to the 48HFP newsletter or as part of creating an account or the purchase journey – and you have a right at any time to change your mind and say no thank you and opt out. The easiest way to opt out is to use the unsubscribe link at the bottom of the communication.

Manage My Subscription

Here are some things we may do that may be specifically directed at you:

• emails, for example the 48HFP newsletter;
• social media posts

We also work with partners to try and promote the reach of our social media and use analytics and retargeting for this reason. We use Tracking Data to deliver relevant online advertising, including via websites and social media.

Tracking Data, and in particular cookies, help us to deliver website and social advertising that we believe is most relevant to you and to potential new customers of 48HFP. The cookies used for this purpose are often placed on our website by specialist organizations.

Cookies can also tell us if you have seen a specific ad, and how long it has been since you have seen it. This is helpful, because it means we can control the effectiveness of our ads and control the number of times people might be shown our ads (you know, before we risk become annoying). Cookies also help us understand if you’ve opened a marketing email because we don’t want to send you things you don’t read.

If you want more information about Tracking Data, in particular cookies, see Cookies below.

7. Cookies

You can see from Advertising, marketing and your communications preferences above, that cookies are a tool which we (and everyone one else who operates online) uses for advertising. That is just part of why cookies are used. Generally, they are pretty clever.

Cookies help 48hourfilm.com work better and provide lots of help in the background to make the process of being a 48hourfilm.com  customer a lot easier. You’d miss a lot of these things if they were gone – like it being easy to log in and move from page to page, and things staying in your cart while you go off and look at other pages.

Other cookies collect information about how visitors use 48hourfilm.com , for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don't collect information that identifies a visitor. All information these cookies collect is aggregated and used to improve how 48hourfilm.com  works.

There are also cookies that allow 48hourfilm.com  to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog.

There are cookies that collect information about your browsing habits in order to make advertising delivered to you more relevant to you and your interests (see Advertising, marketing and your communications preferences above). They are usually placed by advertising networks with our permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organization.

When you use 48hourfilm.com , your device or browser may be sent cookies from third parties, for example when using embedded content and social network links. It's important for you to know that we have no access to or control over cookies used by these companies or third-party websites. We suggest you check the third-party websites for more information about their cookies and how to manage them.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

8. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in this privacy policy. We may also share your personal data if the law otherwise allows it.

We may share personal data with the following categories third parties:

• Suppliers and service providers (such as technology service providers, payment processing and fraud prevention providers, manufacturers and post and courier services);

We share personal data with the following specific third parties:

• iContact: we share your data with iContact to send our newsletter and direct marketing campaigns to prospective and current customers.

We also share data with third parties connected to advertising, retargeting and analytics. Please see Cookies above, including the cookie list, for more information about who those third parties are.

9. Payment information

48HFP uses third party payment processors Braintree and PayPal to process payments made for products and services via the Website. All online payments will be conducted in accordance with Payment Card Industry (PCI) data security standards (which are high!) and your billing information (which is only used by these payment processors for the purpose of performing fraud protection) is encrypted before being communicated to them. Subject to the below exceptions, your credit card details are communicated directly from your browser to these payment processors - 48HFP never (ever!) sees your full Permanent Account Number (PAN). This means that the payment form is either off-site or displayed in a frame on the payment page.

10. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

11. Third-party links

This website may include links to third-party websites, plug-ins and applications (for example, the ability to sign in with Facebook). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

12. Data retention

We will only keep your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data; see Your legal rights below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

13. Your legal rights

If the General Data Protection Regulation applies to you because you are in the European Union, you have rights under data protection laws in relation to your personal data:

• The right to be informed – that’s an obligation on us to inform you how we use your personal data (and that’s what we’re doing that in this privacy policy);
• The right of access – that’s a right to make what’s known as a ‘data subject access request’ for copy of the personal data we hold about you;
• The right to rectification – that’s a right to make us correct personal data about you that may be incomplete or inaccurate;
• The right to erasure – that’s also known as the ‘right to be forgotten’ where in certain circumstances you can ask us to delete the personal data we have about you (unless there’s an overriding legal reason we need to keep it);
• The right to restrict processing – that’s a right for you in certain circumstances to ask us to suspend processing personal data;
• The right to data portability – that’s a right for you to ask us for a copy of your personal data in a common format (for example, a .csv file);
• The right to object – that’s a right for you to object to us processing your personal data (for example, if you object to us processing your data for direct marketing); and
• Rights in relation to automated decision making and profiling – that’s a right you have for us to be transparent about any profiling we do, or any automated decision making.

These rights are subject to certain rules around when you can exercise them.

If you wish to exercise any of the rights set out above, please contact us (see How to contact 48HFP about privacy).

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

14. How to contact 48HFP about privacy

If you have any questions about this privacy policy, or would like to exercise any of your rights, please email us at: privacy@48hourfilm.com or write to us with your letter addressed to: Data Privacy, PO Box 40008, Washington, DC 20016, USA.

15. Keep your personal data up-to-date

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. You can do this by updating your account. Thank you.

16. Changes to this privacy policy

The General Data Protection Regulation is new and we are receiving new advice regularly about how businesses should follow it. So, you may see little updates to our privacy policy over the coming months. Be sure to check in and have a read every now and then. Thank you.