Privacy Policy
Table of Contents
General Provisions
What is Personal Data?
What User Data Does the Administrator Process?
Under What Conditions May the Administrator Process Children's Data?
On What Legal Basis Does the Administrator Process Data? For What Purposes Does the Administrator Process Data?
How Long is the User's Personal Data Stored?
What Rights Does the User Have Regarding Their Personal Data?
What Are Cookies and How Do We Use Them?
To Whom Do We Transfer Your Data?
Other Cases of Data Disclosure
When May the Administrator Change the Terms of This Policy?
How Does the Administrator Protect Personal Data?
Contacting the Administrator or the Data Protection Authority
1. GENERAL PROVISIONS
1.1. This Privacy Policy provides the User with information about the processing of their personal data by the administrator of the website (hereinafter — the "Website") — STARLIGHT PRODUCTION LIMITED LIABILITY COMPANY (hereinafter — the "Administrator"), including information required by Articles 13 and 14 of Regulation 2016/679 ("GDPR") on the protection of natural persons with regard to the processing of personal data (hereinafter — "GDPR"), as well as in accordance with the Law of Ukraine "On Personal Data Protection".
1.2. The Administrator operates in the field of production of films, video films, television programs, series, and also provides related services in the field of media production, distribution, and demonstration of audiovisual content.
1.3. Please read the Privacy Policy carefully before using the Website, as during the use of the Website, personal data is collected, processed, used, and stored, as well as transferred to third parties (including cross-border data transfer).
1.4. The controller of the personal data of Website Users is:
STARLIGHT PRODUCTION LIMITED LIABILITY COMPANY
EDRPOU Code: 33475515
Address: Ukraine, 01033, Kyiv, 11 Pankivska Street
1.5. For all questions regarding the processing (including collection, use, and storage) of personal data, as well as the transfer of personal data, Users may contact: datarequest@slm.ua, dpo@slm.ua.
2. WHAT IS PERSONAL DATA?
2.1. Personal data (hereinafter — "Data") means any information relating to the User that allows the User to be identified directly or indirectly, for example, name, user identifier on the Website (user ID), location information, online identifiers (indicators of User actions on the Website), or other information about the User.
3. WHAT USER DATA DOES THE ADMINISTRATOR PROCESS?
The Administrator may process various categories of User Data, namely:
3.1. Data Provided by the User:
3.1.1. User's first and last name, pseudonym (nickname), email address, phone number, gender, age, photo (avatar), payment data, and payment method information. You provide such data in several ways, for example, during registration and/or use of the Website, interaction with the support service, and/or participation in promotional activities conducted by the Administrator (both independently and with the help of partners).
3.1.2. Information provided when filling out feedback forms, submitting applications for participation in castings, collaboration, or other Administrator projects.
3.1.3. Information provided when posting reviews and/or comments on the Website.
3.2. Data Collected by the Administrator, Including Through Cookies:
3.2.1. Data about User activity on the Website, such as browsing history, search history, and more.
3.2.2. Data about the type of device, model, device ID, and its operating system used to access the Website; the internet browser used to access the Website. Data about the device location (down to the city).
3.2.3. Details of interaction with the support service, such as date, time, and reason for the inquiry, transcript of any conversation with support staff, phone number from which the call to support was made, and recording of such conversation.
3.2.4. Data we receive through cookies, web beacons, and other similar technologies.
3.2.5. Results of advertising activities.
3.3. Data from Other Sources:
3.3.1. When registering on the Website using the User's social network account, the User consents to the transfer of Data necessary for registering an account on the Website (such as first name, last name, email address, photo (avatar), social network user identifier (user ID), date of birth) from the owner of such social network to the Administrator.
4. UNDER WHAT CONDITIONS MAY THE ADMINISTRATOR PROCESS CHILDREN'S DATA?
4.1. Our services may be used by children only under the supervision of parents or another legal guardian. The User must be at least 18 years old to use the Website independently.
4.2. The User must be old enough to make a decision about providing their Data to the Administrator. If the User is under 14 years old, consent to the processing of their data must be given or approved by one of their parents, guardian, or other legal representative.
5. ON WHAT LEGAL BASIS DOES THE ADMINISTRATOR PROCESS DATA? FOR WHAT PURPOSES DOES THE ADMINISTRATOR PROCESS DATA?
5.1. The Legal Bases for Processing Personal Data Are:
5.1.1. Processing for the Purpose of Providing, Analyzing, Administering, Improving, and Personalizing the Website (Art. 6 (1) (b) GDPR).
Here are some examples:
Identification of Users when using the Website.
Processing applications for participation in castings, projects, and other Administrator activities.
Personalization of the User's use of the Website based on behavioral patterns and areas of interest.
Ensuring the sending of important notifications, such as changes to the Privacy Policy.
5.1.2. User's Consent to the Processing of Personal Data (Art. 6 (1) (a) GDPR):
Use of personal data to increase the relevance of advertising materials and more accurate targeting.
Use of cookies and similar technologies to provide content and the best user experience.
5.1.3. Legitimate Interest of the Administrator (Art. 6 (1) (f) GDPR):
Conduct direct marketing, for example, send letters, SMS messages, messages through messengers, push notifications, and other informational and advertising messages.
Counteract fraudulent activities.
Analysis and research of User actions to improve service quality.
Informing Users about new projects, castings, premieres, and other news.
The User has the right to refuse to receive marketing information by independently disabling the subscription function or by sending a letter to the Administrator's email address.
6. HOW LONG IS THE USER'S PERSONAL DATA STORED?
6.1. We store and process your data no longer than necessary to achieve the purposes for which it was collected. Storage periods are determined individually in each specific case and depend on the nature of the data, the reason for its collection and processing, as well as relevant legal or operational storage needs.
6.2. We may also store and use your information if necessary to comply with legal obligations, resolve disputes, and enforce our agreements.
6.3. After the storage period expires, we may aggregate or delete data to a level where the User can no longer be identified and process it exclusively in statistical form.
7. WHAT RIGHTS DOES THE USER HAVE REGARDING THEIR PERSONAL DATA?
7.1. The User has the following rights regarding their personal data:
Right of Access — to request from the controller access to data relating to them, their rectification, erasure, or restriction of processing.
Right to Object — to object to processing if such processing is carried out on the basis of the Administrator's legitimate interest, including objecting to processing for marketing purposes.
Right to Data Portability — to receive data in a structured, commonly used, and machine-readable format, and, where technically feasible, to have it transmitted to another controller without hindrance.
Right to Withdraw Consent — to withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
Right to Complain — to lodge a complaint with the Ukrainian Parliament Commissioner for Human Rights or another competent supervisory authority.
7.2. To exercise their rights, the User may contact the Administrator by email — by writing to datarequest@slm.ua , dpo@slm.ua .
7.3. Upon the User's request for deletion of Personal Data, the Administrator ensures the deletion of the account and personal data associated with such account.
7.4. Deletion of personal data may be limited in accordance with the requirements of applicable law, in particular, such limitations may provide for the Administrator's obligation to retain information for the period established by applicable law.
8. WHAT ARE COOKIES AND HOW DO WE USE THEM?
8.1. The Website may use cookies and other similar technologies. These technologies store identification text files on the User's device that allow storing information about the User and identifying them during subsequent use of the Website.
8.2. Types of Cookies:
Essential Cookies — these cookies are mandatory for the functioning of the Website and cannot be disabled. They are set in response to User actions that constitute a request for services, such as settings, registration, login, or filling out forms.
Analytical Cookies — these cookies collect information about how Users use the Website, for example, which pages Users visit most often. They are used to provide statistical information and improve the Website.
Targeting Cookies — these cookies are used to deliver advertising that is more relevant to the User and their interests, as well as to determine the effectiveness of advertising campaigns.
Third-Party Cookies — these cookies are set by third parties for marketing, analytical, and functional purposes.
8.3. The User can always limit the use of cookies or change cookie settings through their internet browser or mobile device settings.
9. TO WHOM DO WE TRANSFER YOUR DATA?
9.1. For the proper and quality provision of services to the User, support of various Website functions and ensuring its operation, for the provision of marketing and advertising services, or for conducting transactions, we enter into agreements with independent contractors and also cooperate with other service providers. As part of this engagement, User data may be transferred to third parties.
9.2. In cases where data is transferred to a third party located in a country that does not ensure an adequate level of data protection within the meaning of European Union law, the Administrator takes additional measures to protect User data.
9.3. In particular, but not limited to, the Administrator may use:
data center services that process data exclusively in encrypted form;
cloud platform services for SaaS solutions;
services of companies for analysis and statistical research;
services of companies for communication with the User;
payment system services for payment processing.
9.4. The Administrator does not grant third parties the right to further disclose Users' personal data or use data for any purposes other than in connection with the provision of services.
10. OTHER CASES OF DATA DISCLOSURE
10.1. Disclosure of personal data may also occur in the following cases:
Disclosure of information pursuant to an order of a competent court or regulatory authority in cases provided by law.
With the User's consent to such disclosure.
In the case of joint promotional activities with third parties.
In the case of reorganization, restructuring, merger, sale, or other transfer of assets.
10.2. When using the Website, the User may disclose information about themselves by using "share to" plugins for social platforms (the terms of use of such buttons and plugins are subject to the privacy policies of the respective social platforms).
11. WHEN MAY THE ADMINISTRATOR CHANGE THE TERMS OF THIS POLICY?
11.1. The Administrator reserves the right to change this Policy. In the event of changes to the content of the Policy, the Administrator will inform the User of the revised Policy.
11.2. In the event of changes that alter the Administrator's rights to use previously collected information, the Administrator will require the User's consent to such use, unless otherwise provided by applicable law.
11.3. The User may continue to use the Website only after giving proper consent to such changes. If the User does not accept any amendments to the Privacy Policy, the User refuses to use the Website and is obliged to contact the Administrator to delete their account.
12. HOW DOES THE ADMINISTRATOR PROTECT PERSONAL DATA?
12.1. The Administrator implements all necessary security measures to protect the User's personal data:
we provide access to data to a limited number of persons and only when necessary;
we use the secure Hypertext Transfer Protocol Secure (HTTPS);
we train our staff in secure data handling and require the use of strong passwords and multi-factor authentication;
we enter into non-disclosure and data processing agreements with our employees and subcontractors;
to protect against unauthorized access to data, we have implemented a firewall, User password hashing, etc.;
we regularly create data backups.
12.2. However, the Administrator cannot guarantee 100% security of all information that is transmitted and/or collected, as no method of transmission over the Internet is completely secure.
13. CONTACTING THE ADMINISTRATOR OR THE DATA PROTECTION AUTHORITY
13.1. If you have any questions or concerns about our Privacy Policy, you can always contact us:
STARLIGHT PRODUCTION LIMITED LIABILITY COMPANY
Address: Ukraine, 01033, Kyiv, 11 Pankivska Street
Email: datarequest@slm.ua , dpo@slm.ua .
13.2. You may also lodge a complaint with the Ukrainian Parliament Commissioner for Human Rights or another competent data protection authority in accordance with your rights under the GDPR and the Law of Ukraine "On Personal Data Protection".
Effective Date: 04.02.2026