Privacy Policy

1 Important information and who we are

Privacy policy

This privacy policy gives you information about how Sensible Spark Ltd collects and uses your personal data through your use of this platform, including any data you may provide when you register with us or use our platform.

Our platform is not intended for children and we do not knowingly collect data relating to children.

Controller

In certain circumstances on the platform Sensible Spark Ltd is the controller and responsible for your personal data (collectively referred to as "we", "us" or "our" in this privacy policy). In other cases we act as a processor and process personal data only on behalf of our clients. This privacy policy applies only where we act as the data controller. If you have any questions about this privacy policy, including any requests to exercise your legal rights (see section 10), please contact us using the information set out in the contact details section (11).

2 The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, title, and date of birth.
• Content Data includes job title, role type, IMDb/LinkedIn links, website, needs, goals, genre and format preferences, project stage, project owner(s) and associated roles, funding needs, other needs, and the creative and financial material you upload about a project.
• Contact Data includes billing address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of services you have purchased from us.
• 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, device ID and other technology on the devices you use to access our platform, and diagnostic information about faults, including the technical detail of the fault and the page you were on.
• Profile Data includes your username and password, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you interact with and use our platform and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific platform feature in order to analyse general trends in how users are interacting with our platform to help improve the platform and our service offering.

3 How is your personal data collected?

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

• Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • use the platform;
  • apply for services;
  • create an account on our platform;
  • subscribe to our service or any publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.
• Automated technologies or interactions. As you interact with our platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other platforms employing our cookies.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below: IMDb. Where you are not the project owner then information may be supplied to us by the project owner. In such case we are not acting as a data controller but processing this data on their behalf.
  • Technical Data is collected by the third party tools we use to measure how the Platform is performing and how it is used.
  • Identity and Contact Data is collected from publicly available sources, including public registers.

4 How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

The retention column above is shorthand. The 6 year period runs from the end of your contract with us and exists so that we can meet our legal, tax and accounting obligations. Project materials are the exception and are deleted or anonymised within 6 months of your account closing, because those obligations do not apply to them. Section 9 sets this out in full.

Direct marketing

During the registration process on our platform when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from us via email. You will receive marketing communications from us if you have requested information from us or purchased services via the platform and you have not opted out of receiving the marketing.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view on which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing

You can ask us to stop sending you marketing communications at any time by logging into the platform and checking or unchecking relevant boxes to adjust your marketing preferences.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes, for example communications relating to services and the platform, updates to our Terms and Conditions, and checking that your contact details are correct.

5 Disclosures of your personal data

We may share your personal data where necessary with the parties set out below for the purposes set out in the table "Purposes for which we will use your personal data" above.

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

Service providers who help us run the Platform, including hosting, infrastructure, usage measurement, fault monitoring and communications providers. They act on our instructions and only for the purposes set out in this policy. Other users of the platform, where you choose to share your project or User Content with them, or where you ask us to contact someone to confirm their participation in your project. Providers of the technology we use to analyse project materials, who process that material on our instructions and do not use it for their own purposes.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6 International transfers

Whenever we transfer your personal data out of the UK to countries which have laws that do not provide the same level of data protection as UK law, we always ensure that a similar degree of protection is afforded to it by ensuring that the following safeguards are implemented:

Depending on the country and the provider, we rely on one of the following: UK adequacy regulations, where the Secretary of State has decided that the country provides an adequate level of protection; the International Data Transfer Agreement; or the Addendum issued by the Information Commissioner to the European Commission standard contractual clauses. Where we rely on the Agreement or the Addendum we also assess the law and practice of the destination country and put in place additional measures where they are needed. You can ask us which safeguard applies to a particular transfer by contacting us using the details in section 11.

7 Cookies and similar technologies

We use cookies and similar technologies both on our website at sensiblespark.com and on the platform. They are set up differently in each place, so we describe them separately where that matters.

Strictly necessary. These are needed to run the service, for example to keep you signed in on the platform, to keep your session secure, to remember what you have entered in a form and to detect and fix technical faults. We also store your privacy choice itself in your browser so that we do not have to ask you again on every visit. The service does not work without these, so they are set without asking for your consent.

We use Cloudflare Turnstile to protect account registration from bots and automated abuse. Cloudflare processes limited technical information for this security purpose.

Analytics. These tell us how the website and the platform are used so we can improve them, for example which pages and features are opened and where people run into difficulty. This is handled for us by an analytics provider, which processes the information on our behalf and on our instructions, on servers in the European Union. You can ask us who our current providers are using the details in section 11. We do not use analytics information for advertising, and we do not sell it.

Diagnostics. We look at how sessions unfold on the platform, meaning the pages you move through and the actions you take, so we can find where the product is not working. This shows us the pages as they appeared to you, and we mask anything you type into a form. It runs only where you have consented, and you can turn it off at any time.

Preference. These remember choices you have made so the service behaves the way you left it.

We set analytics, diagnostics and preference technologies only where you have consented, and you can withdraw your consent at any time, without giving a reason and without charge. On our website, use the Cookies link in the footer. On the platform, use your privacy settings. You can also block or delete cookies through your browser settings, though the platform may not work properly if you block the strictly necessary ones. We do not sell the information these technologies collect. If you would like us to delete analytics or diagnostics information we have already collected about you, email compliance@sensiblespark.com.

8 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.

9 Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. Technical and Usage Data, including diagnostics, and Profile Data are not part of those six year records. We keep them only for as long as they are needed for the security, fault-detection and analytics purposes described in this policy and then delete them, and you can ask us to delete them sooner at any time.

Project materials.Your project materials, meaning the creative and financial material you upload about a project, are treated differently from the rest of your data. We delete or anonymise them within 6 months of your account closing. We do not keep them for the 6 year period that applies to identity, contact, financial and transaction records, because the legal, tax and accounting obligations that justify that period do not apply to project materials. The 6 month window exists so that an account closed by mistake can be restored and so that we can deal with any dispute that is already under way. If you want your project materials deleted sooner, ask us and we will do it. By anonymise we mean that nothing in the material can identify you or anyone in it; anything that could still be linked to you or to the people in it is deleted rather than kept. After your account closes we do not analyse your project materials. This 6 month window, and any longer period we keep material for a complaint or legal claim, is the archival period referred to in our terms.

In some circumstances you can ask us to delete your data: see section 10 below for further information.

In some circumstances we will anonymise personal data other than project materials (so that it can no longer be associated with you or anyone else) for statistical purposes, in which case we may use that information indefinitely without further notice to you.

10 Your legal rights

You have a number of rights under data protection laws in relation to your personal data. You have the right to:

• Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object. That does not apply to analysis of your project materials to develop, train or improve our technology: you can object to that at any time by emailing compliance@sensiblespark.com with the word Object in the subject line, we will stop using your materials for that purpose within one month without asking you for a reason, and this does not affect your account or the services. Objecting stops any further use of your materials in training but does not reverse what our technology has already learned from them.
• You also have the absolute right to object at any time to the processing of your personal data for direct marketing purposes (see "Opting out of marketing" in section 4 for details of how to object to receiving direct marketing communications).
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
  • if you want us to establish the data's accuracy;
  • where our use of the data is unlawful but you do not want us to erase it;
  • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Automated decision-making

We use technology to analyse the material you upload as part of providing and improving the Services. Anything it produces is a suggestion. A person at Sensible Spark is involved in any decision that has a legal effect on you or a similarly significant effect on you, so those decisions are not taken by automated means alone. If that ever changes we will tell you first, and you will be able to ask for a person to review the decision, to make representations about it and to contest it.

Withdrawing consent

Where we rely on your consent to process your personal data, you can withdraw it at any time. This will not affect the lawfulness of any processing we carried out before you withdrew it.

If you wish to exercise any of the rights set out above, please contact us at compliance@sensiblespark.com.

No fee usually required

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 could refuse to comply with your request in these circumstances.

What we may need from you

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.

Time limit to respond

We try to respond to all legitimate requests within one month of receipt of documents confirming your identity. Occasionally it could 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.

People we may contact about our work

If you received an introductory message from us about a possible film or television project, see People we may contact about our work for how we identified and contacted you before that message.

11 Contact details

If you have any questions about this privacy policy or about the use of your personal data, or you want to exercise your privacy rights, please contact us in the following ways:

• Email address: compliance@sensiblespark.com
• Postal address: 167-169 Great Portland Street, 5th Floor, London, England, W1W 5PF

12 Complaints

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

You also have the right to make a complaint to us directly under section 164A of the Data Protection Act 2018, and we would ask you to do that first so that we have the chance to put things right.

13 Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated in September 2026. If you already had an account before this version was published, the change to how we analyse project materials takes effect only from the date stated in the notice we send you, and not before. If we change a retention period, or anything else in this policy that affects how long we keep or may use your User Content, we treat that as a change to our terms and give you the notice and the right to leave that the terms provide.

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, for example a new address or email address.

14 Third-party links

This platform may include links to third-party platforms, plug-ins and applications. 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 platforms and are not responsible for their privacy statements. When you leave our platform, we encourage you to read the privacy policy of every platform you visit.