Legal
Privacy Policy
Last updated: May 2026
At a glance
FilmConnector helps filmmakers, festival strategists, and sales agents move films through the world. To do that, we hold a small, deliberate amount of information about you and the films you work on. This policy explains what we hold, why, who we share it with, how long we keep it, and what you can ask us to do with it. We are based in Belgium and operate under the EU General Data Protection Regulation (GDPR).
If you only read one section, read Section 11 — Your rights. It is the part that gives you control.
For any privacy question, write to integrations@filmconnector.app.
Contents
- 1. Who we are
- 2. Scope of this policy
- 3. The data we collect
- 4. How we collect your data
- 5. Why we use your data and our lawful bases
- 6. Sharing your data — our subprocessors
- 7. When you invite collaborators on a project
- 8. International data transfers
- 9. How long we keep your data
- 10. Security
- 11. Your rights
- 12. Children
- 13. Cookies and similar technologies
- 14. AI processing and automated decision-making
- 15. Changes to this policy
- 16. How to contact us
- Appendix — Definitions
1.Who we are
FilmConnector is operated by [LEGAL ENTITY NAME] (referred to as "FilmConnector", "we", "us", "our").
Registered office: [REGISTERED ADDRESS, BELGIUM]
BCE / KBO (Belgian company register): [BCE NUMBER]
VAT identification: [BE VAT NUMBER]
Contact for privacy matters: integrations@filmconnector.app
Data Protection point of contact: same address.
We act as the data controller for the personal data we process about our subscribers, the people they invite as collaborators, our website visitors, and the people who contact us. In some cases (described in Section 7), we act as a data processor on behalf of our subscribers.
2.Scope of this policy
This policy applies to:
- The FilmConnector website (filmconnector.app and any subdomains).
- The FilmConnector web and mobile applications (subscriber accounts, the strategy creator, submission tracker, project workspaces, and related features).
- Communications between you and us (email, customer support, calendar bookings).
It does not cover third-party services we link to but do not operate (for example, the websites of the festivals you submit your film to). Those services have their own privacy policies — please consult them directly.
3.The data we collect
We collect the data described below. For each category we explain the kind of information involved and where it comes from.
3.1 Account and identity data
- Your email address.
- Your name.
- Your password (stored only in hashed form; we never see your plaintext password).
- The role you describe yourself as (filmmaker, sales agent, producer, festival programmer, etc.).
- The country and language you operate in.
3.2 Subscription and billing data
Most billing data is processed by Stripe on our behalf — we do not store full card numbers. We retain:
- Subscription tier and start/end dates.
- Billing cycle (monthly or annual).
- Add-ons purchased (extra projects, extra collaborator seats).
- Founding-member status and price-lock metadata where applicable.
- Invoice records, including the billing name, address, and (for businesses) VAT identification number.
- A reference token (stripe_customer_id) linking you to your billing record at Stripe.
For B2B subscribers, we validate VAT identification numbers against the European Commission's VIES service. VIES returns a yes/no validity result; we store the answer and the timestamp.
3.3 Profile and company data
If you operate as a company or sales agency, we collect your company name, logo (optional), country of operation, and (for invoicing) registered address and VAT number.
3.4 Project content and creative data
When you create a project (a film) on FilmConnector, you can add:
- The film's title, languages, year, runtime, format, genres, and other catalogue metadata.
- Synopsis and logline text.
- Press kit materials (text, images, posters).
- Screener links and password-protected viewing assets.
- Trailers, stills, and other promotional assets you choose to upload.
- Notes and strategy documents you write inside the platform.
The film itself (the moving image file) is not stored on our infrastructure — large media files live on the user's own archive or specialist platforms. We may store screener links that point to such platforms, but we do not host the underlying video.
3.5 Festival strategy and submission data
- The list of festivals you have added to a project's strategy radar (drawn from our database of approximately 2,200 festivals).
- Submission status (planned, submitted, accepted, declined, awarded).
- Notes and timestamps you record about each submission.
- Festival fees paid through external systems (we record the fact of payment and amount, not the card data).
3.6 Collaborator data
When you invite a collaborator to a project — a producer, director, the director's assistant, a national promotion agency, a funder, or any other stakeholder — we hold the collaborator's email address, name (if provided), declared role, and the projects they have access to. See Section 7 for the special privacy considerations that apply.
3.7 Communications data
- The content of emails you send to us and we send to you (support enquiries, transactional emails, replies).
- Calendar bookings you make with us (for example, a Portal Eclipse onboarding call).
- Optional WhatsApp or chat messages where applicable.
3.8 Technical data
- IP address (truncated where possible for analytics).
- Device, browser, and operating system identifiers.
- Pages visited, features used, and timing data, captured via our analytics tooling.
- Cookies and similar technologies (see Section 13).
3.9 AI processing inputs and outputs (Phase 2 onward)
When AI features ship in Phase 2 (target 2027), our AI systems will process certain content you provide — synopses, project descriptions, festival history — to generate suggestions, drafts, or analyses. We will:
- Process this content only when you choose to use an AI feature.
- Not use your content to train third-party foundation models without explicit, separate consent.
- Make AI-generated content visible and editable by you before any external action.
Phase 2 carries no automated decision-making with legal or similarly significant effects. You can read Section 14 for more.
3.10 Customer support data
Support tickets, the email thread that produced them, and any internal notes we add while resolving them.
4.How we collect your data
We collect data through three routes:
- Directly from you — when you sign up, complete your profile, create projects, invite collaborators, build a strategy, contact support, or book a call.
- Automatically through your use of the service — analytics, cookies, technical logs, AI feature inputs.
- From third parties — Stripe for billing confirmations; VIES for VAT validation; festival platforms for submission decision data when our integrations support it; and, where you grant explicit permission, public film databases (TMDB, Letterboxd) for catalogue enrichment.
5.Why we use your data and our lawful bases (GDPR Art. 6)
We process personal data only when we have a clear lawful basis under GDPR. The summary below maps each purpose to its basis.
| Purpose | Lawful basis (GDPR Art. 6) |
|---|---|
| Provide the service you subscribed to (account, projects, strategy, submissions, collaboration) | Contract (Art. 6(1)(b)) |
| Process payments and manage your subscription | Contract + Legal obligation (Art. 6(1)(b) and (c)) |
| Comply with Belgian and EU tax, accounting, and corporate law (invoice retention, VAT records) | Legal obligation (Art. 6(1)(c)) |
| Provide customer support | Contract (Art. 6(1)(b)) |
| Maintain security, prevent fraud, investigate misuse | Legitimate interests (Art. 6(1)(f)) |
| Improve the product and platform reliability via aggregated analytics | Legitimate interests (Art. 6(1)(f)), with opt-out for non-essential analytics |
| Send transactional emails (e.g. trial-ending notice, renewal reminder) | Contract (Art. 6(1)(b)) |
| Send optional marketing communications and product newsletters | Consent (Art. 6(1)(a)) |
| Process content with AI features when you choose to use them (Phase 2) | Contract (Art. 6(1)(b)) |
| Produce anonymised, aggregated industry insights about festival programming patterns | Legitimate interests (Art. 6(1)(f)); no re-identifiable data is shared |
| Respond to lawful requests from public authorities | Legal obligation (Art. 6(1)(c)) |
Where we rely on legitimate interests, we have balanced our interest against your rights and concluded that the processing does not override them. You can ask us about that balancing test at any time — write to integrations@filmconnector.app.
Where we rely on consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
We do not process special category data (health, racial or ethnic origin, religious beliefs, biometric data) in the ordinary course of providing FilmConnector. Please do not include such data in project notes, synopses, or submission records unless it is essential to the film and you have a clear lawful basis to share it.
6.Sharing your data — our subprocessors
To run FilmConnector we rely on a small number of carefully chosen subprocessors. Each is contractually bound by GDPR-compliant data processing terms.
| Subprocessor | Purpose | Region | Notes |
|---|---|---|---|
| Stripe Payments Europe Ltd | Payment processing, subscription management, invoicing | Ireland (with US group company) | Uses Standard Contractual Clauses for any non-EEA transfer |
| Supabase Inc. | Application database | EU region (Frankfurt) | Underlying infrastructure: AWS |
| Amazon Web Services (AWS) | Cloud hosting underlying Supabase and other infrastructure | EEA (Frankfurt / Dublin) | Standard Contractual Clauses for any required transfer |
| [Email Provider] | Transactional and notification emails | EU + US | SCCs in place |
| PostHog Inc. | Product analytics, optional and opt-out-able | EU region selected | SCCs in place |
| [Calendar Provider] | Onboarding call bookings (Eclipse and Constellation tiers) | EU / US | SCCs in place |
| European Commission VIES | Validate VAT numbers for B2B subscribers | EU | Public service operated by the European Commission |
| Belgian and EU tax authorities | Required tax and accounting reporting | Belgium / EU | Sharing is limited to what the law requires |
We may share data with festival platforms when you instruct us to forward a submission. The data shared is the data the festival requires (typically: film title, runtime, synopsis, contact email, screener link). Each festival's privacy policy then governs what they do with it.
We may also share data with our professional advisors (lawyers, accountants, auditors) under confidentiality, and with public authorities when required by law (court order, regulatory request, fraud or security investigation).
We do not sell your personal data. We do not allow our subprocessors to use your data for their own marketing.
A current, full list of subprocessors is maintained at [/legal/subprocessors] and updated when changes occur. Material changes are announced in advance by email to active subscribers.
7.When you invite collaborators on a project
This section is important. FilmConnector projects support up to 5 collaborators per project (more available as paid add-ons). Collaborators are typically the producer, director, director's assistant, a national promotion agency, a funder, a co-producer, or a publicist.
When you invite a collaborator, you make a decision about another person's personal data. In legal terms:
- You are the data controller for the relationship with that collaborator.
- FilmConnector is your data processor for that collaborator's personal data, acting on your instructions.
This means a few practical things:
- You should only invite collaborators who have a legitimate reason to see the project's information and who have a reasonable expectation that they would be invited.
- You should inform the collaborator that the project is hosted on FilmConnector and how their data will be used.
- If a collaborator asks us to delete their data, we will route the request to you (the controlling subscriber) and act on your instruction. We will only act unilaterally if the collaborator has a clear right that supersedes your instruction (for example, GDPR-grounded erasure that you fail to act on).
- When your subscription ends or you remove a collaborator, the collaborator loses access to the project. We retain the audit trail (who was invited, when, by whom) for the period set out in Section 9.
The Subscription Terms include a Data Processing Addendum that formalises this controller/processor relationship.
8.International data transfers
Most of our processing happens within the European Economic Area. Some of our subprocessors (notably Stripe's group entities, the email provider, and AWS for redundancy) may process data outside the EEA, primarily in the United States.
For any transfer outside the EEA we rely on one or more of the following safeguards:
- Standard Contractual Clauses approved by the European Commission.
- Adequacy decisions where they apply (for example, the EU-US Data Privacy Framework where our subprocessor is certified).
- Supplementary technical measures such as encryption in transit and at rest.
If you'd like a copy of the safeguards that apply to a specific transfer, write to integrations@filmconnector.app and we will provide it.
9.How long we keep your data
We keep your data only as long as we need it. Broadly:
| Data category | Retention |
|---|---|
| Active account and profile data | While your subscription is active, plus 12 months after termination so you can return without losing your work |
| Billing records, invoices, VAT documentation | 7 years from the end of the accounting period (Belgian commercial code requirement) |
| Submission history (festivals, decisions, dates) | 10 years after submission, for industry continuity and statistical purposes |
| Project content (synopses, press kits, screener links) | While your subscription is active; on termination, 90 days for recovery before deletion |
| Collaborator records | While the parent project is active; 12 months after project archival; 7 years for the audit trail of who-invited-whom (compliance) |
| Communications (support tickets, email threads) | 3 years from last contact |
| Technical logs (IP, browser, server logs) | 90 days |
| Analytics data (PostHog) | 26 months |
| Backups | 90 days, then permanently deleted |
| AI processing inputs and outputs (Phase 2) | 12 months unless you delete them sooner |
| Marketing consent records | While the consent is active, plus 3 years after withdrawal as proof of compliance |
Where data must be kept for legal reasons beyond the period you would prefer, we restrict access and stop using it actively as soon as we can.
10.Security
We take security seriously without making promises we cannot keep. The measures we have in place include:
- Encryption in transit for all communication with the FilmConnector application (TLS).
- Encryption at rest for the application database (Supabase / AWS-managed encryption).
- Hashed and salted passwords — we never store, log, or transmit your plaintext password.
- Access controls — only authorised members of the FilmConnector team have administrative access, and access is logged.
- Subprocessor selection — we only work with vendors that meet our security and GDPR-compliance criteria.
- Data minimisation — we collect only what we need.
- Incident response procedure — we have a written process for detecting, containing, and notifying data breaches in line with GDPR Art. 33-34 (notification to the Belgian DPA within 72 hours of becoming aware of a personal data breach where required, and notification to affected users where the breach is likely to result in a high risk to their rights).
No security system is perfect. If a breach affects your data and is likely to create a high risk to your rights, we will tell you what happened, what we are doing about it, and what you can do.
11.Your rights
Under GDPR you have the following rights, exercisable at any time and free of charge in most cases.
| Right | What it means |
|---|---|
| Access | You can ask us for a copy of the personal data we hold about you. |
| Rectification | You can ask us to correct data that is wrong or incomplete. |
| Erasure ("right to be forgotten") | You can ask us to delete your data, subject to legal exceptions (for example, we cannot delete invoices we are required to keep for tax purposes). |
| Restriction of processing | You can ask us to limit how we use your data while a question (e.g. accuracy) is being resolved. |
| Data portability | You can ask us to provide your data in a structured, machine-readable format so you can take it to another service. |
| Object | You can object to processing we carry out under our legitimate interests, including for direct marketing. |
| Withdraw consent | Where we rely on your consent (for example, marketing emails), you can withdraw it at any time. |
| Avoid solely automated decisions with legal or similarly significant effects | We do not make such decisions about you. See Section 14. |
How to exercise your rights: write to integrations@filmconnector.app with a clear description of your request. We will respond within one month (extendable by two months if the request is complex, with notice to you within the first month).
Right to complain to the Belgian Data Protection Authority:
Autorité de protection des données / Gegevensbeschermingsautoriteit
Rue de la Presse 35, 1000 Bruxelles
You can also complain to the data protection authority of your country of residence within the EU.
12.Children
FilmConnector is a professional tool for filmmakers, sales agents, and festival strategists. It is not directed at people under 18 and we do not knowingly create accounts for them.
Belgian law sets the digital age of consent at 13. We choose 18 as our threshold because the platform involves contractual relationships, payments, and rights management that are most appropriately handled by adults.
If we learn that we have inadvertently collected personal data from a person under 18, we will delete it as soon as practicable. If you believe a person under 18 has registered, please write to integrations@filmconnector.app.
13.Cookies and similar technologies
We use cookies and similar technologies to make the service work, to remember your preferences, and (with your consent) to understand how the platform is used. Cookies fall into three categories:
- Strictly necessary cookies — required for the site to work (authentication, security, session management). These do not require your consent.
- Preference cookies — remember your billing toggle (monthly/annual), language, theme. Set with consent.
- Analytics cookies — help us understand which features are used and where users hit friction. Set only with consent and easy to opt out of.
We do not use advertising cookies. We do not run third-party advertising on the platform.
A separate Cookie Policy documents the specific cookies we set, their purpose, and their expiry. The cookie consent banner you see on your first visit is the legal point of consent — you can revisit your choices any time via the "Cookie preferences" link in the footer.
14.AI processing and automated decision-making
In Phase 1 of FilmConnector (the period this policy is published in), we do not process your data with AI for decision-making purposes.
When AI features ship in Phase 2 (target 2027), the following commitments apply:
- AI features process only the data you choose to submit to them (a synopsis, a project description, a list of festivals you are considering).
- We do not use your project content to train third-party foundation models without explicit, separate consent.
- We do not make solely automated decisions about you that produce legal effects or similarly significantly affect you. Suggestions and rankings the AI produces are recommendations — you remain the decision-maker on every submission.
- You can opt out of AI features at any time in your account settings, and your project will continue to function with the manual workflow.
- AI inputs and outputs follow the retention schedule in Section 9.
This section will be updated when Phase 2 ships, and the change will be communicated in advance.
15.Changes to this policy
We may update this policy as our service evolves, as the law changes, or as we add new subprocessors or features. When we do:
- The new version will be published on this page with a revised "Last updated" date.
- Material changes (new categories of data, new lawful bases, new countries of processing, substantive changes to retention) will be announced by email to active subscribers at least 30 days before they take effect.
- Continued use of FilmConnector after a material change indicates acceptance, but you can always cancel and exercise your erasure rights if you disagree.
A history of versions is kept internally for compliance purposes. Older versions are available on request.
16.How to contact us
For any privacy question, request, or concern:
Email: integrations@filmconnector.app
Postal: [LEGAL ENTITY NAME], [REGISTERED ADDRESS], Belgium
We aim to reply within five working days for general questions and within one month (extendable by two months for complex cases, with prior notice) for formal Data Subject Requests.
Appendix — Definitions used in this policy
- Personal data
- Any information that identifies you or could be used to identify you, directly or indirectly.
- Processing
- Any operation performed on personal data: collecting, storing, using, sharing, deleting, etc.
- Data controller
- The party that decides why and how personal data is processed.
- Data processor
- The party that processes personal data on behalf of a controller.
- Subprocessor
- A third party engaged by a processor to help with the processing.
- GDPR
- The EU General Data Protection Regulation (Regulation (EU) 2016/679).
- Belgian DPA
- The Belgian Data Protection Authority (Autorité de protection des données / Gegevensbeschermingsautoriteit).
- VIES
- VAT Information Exchange System operated by the European Commission for cross-border VAT validation.
- EEA
- European Economic Area: the EU member states plus Norway, Iceland, and Liechtenstein.
- SCCs
- Standard Contractual Clauses approved by the European Commission for international data transfers.