Contents
- Summary
- About Us And This Policy
- Definitions
- What Information We Collect
- Why Do We Process Your Personal Data
- How Is Processing Your Data Lawful
- When Will We Delete Your Data
- Who Will Have Access To Your Personal Data
- Your Rights
Summary
We process your personal information during the course of your direct interaction with us, for example: by visiting TwoVHill.com, interacting with our content such as a film, sizzle reel, trailer or gallery, news post, filling out a contact form, during a promotional call, when signing up to a newsletter or mailing list or by making a donation to one of our projects.
You should not provide us with your data if you are under sixteen years of age. Please contact us using the details provided below if you think we may be processing the data of persons under the age of sixteen.
Our site includes links to third-party websites and applications. If you visit a third-party website via a link from TwoVHill.com, please be aware that we cannot control what data those third parties collect or share about you.
As you interact with TwoVHill.com, we collect personal data using cookies. Please review our Cookie Policy here.
If we decide to change our Privacy Policy, we will post those changes on this page, and update the modification date below. We will also provide a notice on the site.
About Us and This Policy
This Privacy Policy is provided by TwoVHill.com, of Harshaw Ave., Toronto, ON who is a ‘controller’ for the purposes of the General Data Protection Regulation (EU) 2016/679. This Privacy Notice applies to all visitors to TwoVHill.com (the “Website”).
Before you interact with our site, you should review our Terms of Service, which can be found here.
TwoVHill.com respects your privacy and takes your personal data seriously.
This Privacy Policy contains important information about how we collect, process and look after your personal data when you interact with us, whether by visiting the website, streaming our content, buying a product or service from us, making a donation, signing up to our newsletter, filling out a contact form, engaging in a promotional call or otherwise, as well as your privacy rights as they pertain to your data and how the law protects you. Please read it carefully to understand how and why your data is being processed and what your rights are in relation to the processing of your data.
How to contact us
To contact us about this Privacy Policy:
- Privacy Manager: Email Us
This Privacy Policy is provided in a layered format for ease of use. Use the links at the top to click through to the specific areas you would like to review.
If you would like this Privacy Policy in another format (for example: pdf large print or audio), just: Email Us
*If you experience issues reaching us using Chrome or any other browser, check your privacy handlers, pop up blockers or alternatively email us directly at admin[at symbol]twovhill.com.
Important Notice
We limit the collection of personal data to that which is reasonably necessary to promote our film, our services as filmmakers or provide a product or service in relation to our film or accept financial donations for one of our projects.
In keeping with COPPA (Children’s Online Privacy Protection Act), PIPEDA (Personal Information Protection and Electronic Documents Act) and the GDPR (General Data Protection Regulation (EU) 2016/679), we do not collect any information from anyone under sixteen years of age (other than information provided by a parent or guardian that allows us to reasonably carry out our contract with them). Though our content is suitable for all ages, our website, products and services are all directed to people who are at least sixteen years old or older.
If we learn that we have unknowingly or unreasonably collected personal information from a child under the age of sixteen, we will delete that information as quickly as possible. If you believe that we might have any information from a child under the age of sixteen, not required to carry out our contract with you, please: Email Us.
Third-Party Links
This Website may include links to third party websites, plug-ins and applications. Visiting those links may allow third parties to collect or share data about you. We do not control these websites and are not responsible for their privacy policies. We encourage you to read the privacy policy of every website you visit.
Changes to this Privacy Policy
This version was last updated on 7.14.2020 and the latest version can always be found here.
Definitions
Please familiarize yourself with the following words and phrases as they are specifically defined in Data Protection Laws and are used throughout this Privacy Policy:
| Term | Definition |
| Controller | This means any person who determines the purposes for which, and the manner in which, any personal data is processed. |
| Data Protection Laws | This means the laws which govern the handling of personal data. This includes the General Data Protection Regulation (EU) 2016/679 and any other national laws implementing that Regulation or related to data protection. |
| Data Subject | The person to whom the personal data relates. |
| ICO (UK) | This means the UK Information Commissioner’s Office which is responsible for implementing, overseeing and enforcing the Data Protection Laws in the UK. |
| OPCC | This means the Office of the Privacy Commissioner of Canada, the Canadian supervisory authority for data protection issues, who is responsible for implementing, overseeing and enforcing the Data Protection Laws in Canada. |
| Personal Data | This means any information from which a living individual can be identified. This will include information such as telephone numbers, names, addresses, e-mail addresses, photographs and voice recordings. It will also include expressions of opinion and indications of intentions about data subjects (and their own expressions of opinion/intentions).It will also cover information which on its own does not identify someone but which would identify them if put together with other information which we have or are likely to have in the future. |
| Processing | This covers virtually anything anyone can do with personal data, including: obtaining, recording, retrieving, consulting or holding it; organizing, adapting or altering it; disclosing, disseminating or otherwise making it available; and aligning, blocking, erasing or destroying it. |
| Processor | This means any person who processes the personal data on behalf of the controller. |
| Special Categories of Data | This means any information relating to:racial or ethnic origin; political opinions; religious beliefs or beliefs of a similar nature; trade union membership; physical or mental health or condition; sexual life; orgenetic data or biometric data for the purpose of uniquely identifying you. |
| COPPA | Children’s Online Privacy Protection Act |
| PIPEDA | Personal Information Protection and Electronic Documents Act |
| GDPR | General Data Protection Regulation (EU) 2016/679 |
| CCPA | California Consumer Protection Act |
What Personal Data Do We Collect?
Information provided by you:
We collect the following information from you when you interact with us, whether by interacting with the Website, submitting information through the Website or by corresponding with us by mail, phone or email.
Contact Data: includes first name, last name, email address, telephone number, billing address, and delivery address.
Order Processing Data: includes first name, last name and email address, telephone number, delivery address for any person for whom you wish to purchase a product, service or make a donation on their behalf to our project (which we have only if you choose to provide to us).
Profile Data: includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Financial Data: includes payment card details, and billing address.
Transaction Data: includes details about payments to and from you and other details of products or services you have purchased from us or donations you have made to us.
Technical Data: includes your 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 your use of our Website, products including the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time), elements you viewed or words you searched for, page response times, download errors, length of visits and interaction information such as scrolling, clicks, and mouse-overs.
Marketing Data: includes your preferences in receiving marketing material from us.
Communications Data: includes comments, emails, information entered via contact forms and notes of conversations.
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. However, if we 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.
Cookies
This Website uses cookies to collect Technical Data about your equipment and browsing actions. We collect this personal data using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. You can set your browser to refuse all or some of the browser cookies, or to let you know when websites set or access cookies. If you disable or refuse cookies, some parts of this Website may not function. For more information about the cookies we use, please see our cookie policy here.
Personal information provided by third parties
We may receive personal data about you from various third parties as set out below:
- Analytics providers such as Google (Technical Data);
- Advertising networks such as Google AdSense and the Facebook pixel (Technical Data);
- Providers of technical, payment and delivery services such as Paypal, Visa, Mastercard, AmEx, Discover, email money transfers and debit cards.
- Film Festival and film and television conference websites.
- Promotional services and website for the purposes of promoting or film property or service.
- Content streaming applications such as YouTube and Vimeo.
Personal information about other individuals
If you provide us with information about other individuals (e.g. your next of kin or children), you confirm that you have informed the relevant individuals accordingly or have the legal right (e.g. parent or guardian) to do so.
Why Do We Process Your Personal Data?
Here is a description of all the ways we plan to use your personal data, and which of the legal bases allows us to do so. We have also identified what our legitimate interests are where appropriate. We may process your personal data based on one or more lawful ground depending on the reason we are using your data. Please contact us if you need clarification or more information about legal grounds for processing your data.
The table below describes all of the ways we plan to use 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. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose / Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To register you as a new follower, customer or consumer | Contact | Performance of a contract with you |
| Profile | Necessary for our legitimate interests (to record your personalised account) | |
| To send you our newsletter or other marketing materials. To make suggestions and recommendations to you about projects, goods or services that may be of interest to you | Contact | Consent where you have specifically opted in |
| Marketing | Necessary for our legitimate interests (to market our film(s) grow our business and send you offers about our latest products, services and projects (where you have chosen not to opt out of receiving these) | |
| Technical | ||
| Usage | ||
| Profile | ||
| To process and arrange for delivery of your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us (c) provide you with customer support services (d) accept a donation | Contact | Performance of a contract with you |
| Order Recipient | Necessary for our legitimate interests (to receive payment) | |
| Financial | Necessary for our legitimate interests (to deliver orders to recipients at your request) | |
| Transaction | ||
| Communications | ||
| To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey | Contact | Performance of a contract with you |
| Profile | Necessary to comply with a legal obligation | |
| Usage | Necessary for our legitimate interests (to keep our records updated and to study how customers use our products) | |
| Marketing | ||
| Communications | ||
| To enable you to partake in a prize draw, competition or complete a survey | Contact | Performance of a contract with you |
| Profile | Necessary for our legitimate interests (to study how customers use our products, to develop them and grow our business) | |
| Usage | ||
| Marketing | ||
| Communications | ||
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | Contact | Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) |
| Technical | Necessary to comply with a legal obligation | |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | Contact | Necessary for our legitimate interests (to study how customers use our products, to develop them, to grow our business and to inform our marketing strategy) |
| Profile | ||
| Usage | ||
| Marketing | ||
| Communications | ||
| Technical | ||
| To use data analytics to improve our website, products, marketing, customer relationships and experiences | Technical | Necessary for our legitimate interests (to define types of customers for our products, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| Usage |
Promotional offers from us
We may use your Personal Data to determine what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant to you for marketing purposes.
You will receive marketing communications from us if you have requested information from us or purchased products from us and, in each case, you have not opted out of receiving that marketing.
Opting out
You can ask us to stop sending you marketing messages or our newsletter at any time by using the unsubscribe link at the bottom of every mailing or by contacting us at any time.
Where you opt out of receiving these marketing messages or newsletters, this will not apply to personal data provided to us as a result of a product purchase, product experience or other transactions.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third-party company for marketing purposes.
How Is Processing Your Personal Data Lawful?
Consent
This includes the processing of your data in a way that is optional to you, and for which you have provided consent, (like sending a Newsletter or other digital marketing communication, letting you know about a new product or service and so forth). You can withdraw this consent at any time using the “Unsubscribe” link in the footer of every communication we send.
Contractual
It is sometimes necessary for us to process your personal data to allow us to perform the contract you have entered into with us. If you do not provide your personal data to us, we will not be able to carry out our obligations under the terms of the contract
Legal obligations
We may be required to process your personal data for the purpose of complying with regulatory, accounting, financial or health and safety rules or to make mandatory disclosures to government bodies and/or law enforcement agencies or to defend or establish a legal claim.
Vital interests
We may process your personal data in an emergency for life-saving or similar reasons.
Public interest
Processing your data may be necessary for the performance of a task carried out in the public interest.
Legitimate interests
We are permitted to process your personal data based on our “legitimate interest” i.e. we have a good, logical reason to process it in the interest of twovhill.com. In these cases, your interests and rights have been carefully considered and appropriate safeguards to your privacy have been put into place.
You can object to processing that we carry out on the grounds of legitimate interests. See the section headed “Your Rights” to find out how.
When Will We Delete Your Data
In most cases, we will not keep your data for longer than we need to in order to meet all the purposes we included in the section “Why do we process your personal data?”
We will keep your data as long as you are a member, user of our services and then, as as long as we need it to comply with a legal obligation or for research or statistical purposes, but if we do not need all the data you provided at first instance, we will delete the remaining data.
In general, we have 7 years as the retention period for your Technical Data, Contact, Identity, Financial, Transactional, Usage, Profile, Marketing, Communications and Oder Recipient data.
In some circumstances, we may anonymize 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.
Who Will Have Access To Your Personal Data
Below is listed some of our key service providers that act as our processors who will have access to your personal data. If you would like to know the names of our other service providers please contact us using the details at the start of this Privacy Policy.
- Hosting service providers such as Endurance International Group/Hosgator with website privacy policy here
- Payment processing service providers such as Paypal, Visa, Mastercard, AmEx, Discover and email money transfers and debit (via Paypal).
- Project Management service providers such as Google Suite, Trello and CRM Services such as Insightly based in the USA.
- Email management service providers such as MailChimp based in the USA.
- Video conferencing apps such as Zoom which records consultations and Q&A calls and is based in the USA.
- Third party social media plugins such as Facebook, Twitter, Instagram and Snapchat to connect you with your social network and which can be disabled by adjusting your privacy settings on the relevant social media site.
- Third parties with whom we partner such as film festivals and film and television industry conferences.
- 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.
*We do not allow our third-party processors 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.
In addition, we share your personal data with the following entities who act as separate controllers of your personal data. We provide them with your name and contact details so that they can contact you separately in order to arrange services/benefits directly with you, or to note you on our company group policies. You should review their privacy policies to find out how they process your personal data. If you have any queries or complaints about how they process your personal data by them, please contact them separately using the contact information provided on their website.
- Third party social media plugins such as Facebook, Twitter, Instagram and Snapchat to connect you with your social network and which can be disabled by adjusting your privacy settings on the relevant social media site.
We will also share your personal data with the police, other law enforcements or regulators where we are required by law to do so. We may also transfer your personal data on the sale, transfer or reorganization of our business. 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.
Transfers of your personal data outside the EEA
We may need to transfer your personal data collected within the European Economic Area (the “EEA”) to the United States of America and Canada, both of which are located outside the EEA, for the purpose of:
Where our service providers are based in Canada and the United States of America and provide their services to us from those countries.
Any transfer of your data will be carried out in accordance with the law to safeguard your privacy rights and give you remedies in the unlikely event of a security breach or to any other similar approved mechanisms. If you want to know more about how data is transferred, please contact us using the details in the section above.
How your personal data is kept safe
- We will take reasonable technical and organizational precautions to prevent the loss, misuse, or alteration of your personal information.
- We limit access to your personal data to third parties who have a business need to know.
- You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
- We will notify you and any applicable controllers with any suspected data breach.
- You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website).
Your Rights
As a data subject, in certain circumstances, you have the following rights under the Data Protection Laws:
- the right to object to processing of your personal data
- the right of access to personal data relating to you (known as data subject access request)
- the right to correct any mistakes in your information
- the right to restrict processing
- the right to ask us to stop contacting you with direct marketing
- the right to prevent your personal data being processed
- the right to have your personal data ported to another controller
- the right to withdraw your consent
- the right to erasure
- rights in relation to automated decision making
If you want to exercise any of these rights, please contact us (please see “How to contact us”).
We will respond to any rights that you exercise within two weeks of receiving your request, unless the request is particularly complex, in which case we will respond within a month.
Please be aware that there are exceptions and exemptions that apply to some of the rights which we will apply in accordance with the Data Protection Laws.
Right to object to processing of your personal data
You may object to us processing your personal data where we rely on a legitimate interest as our legal grounds for processing.
If you object to us processing your personal data we must demonstrate compelling grounds for continuing to do so. We believe we have demonstrated compelling grounds in the section headed “How is processing your personal data lawful”.
Right to access personal data relating to you
You may ask to see what personal data we hold about you and be provided with:
- a copy of the personal data
- details of the purpose for which the personal data is being or is to be processed
- details of the recipients or classes of recipients to whom the personal data is or may be disclosed, including if they are overseas and what protections are used for those overseas transfers
- the period for which the personal data is held (or the criteria we use to determine how long it is held)
- any information available about the source of that data
- whether we carry out an automated decision-making, or profiling, and where we do information about the logic involved and the envisaged outcome or consequences of that decision or profiling.
To help us find the information easily, please provide us as much information as possible about the type of information you would like to see.
Right to correct any mistakes in your information
You can require us to correct any mistakes in your information which we hold. If you would like to do this, please let us know what information is incorrect and what it should be replaced with.
Right to restrict the processing of personal data
You may request that we stop processing your personal data temporarily if:
- you don’t believe your data is accurate. (We will start processing again once we have confirmed its accuracy)
- the processing is unlawful but you don’t want your data erased
- we no longer need to process your personal data, but you need the data to establish, exercise or defend legal claims
- you have objected to processing because you believe that your interests should override our legitimate interests.
Right to ask us to stop contacting you with direct marketing
As a data subject you have the right to object at any time to processing of personal data for the purposes of direct marketing, which includes profiling to the extent that it is related to such direct marketing. In such cases we are required to immediately comply and stop processing your data.
Right to data portability
You may request an electronic copy of your personal data which we hold electronically and which we process when we have entered into a contract with you. You can also ask us to provide this directly to another party.
Right to withdraw consent
You may withdraw any consent that you have given us to process your personal data at any time. This means that we will not be able to carry out any processing which required use of that personal data.
Right to erasure
You can ask us to erase your personal data where:
- you do not believe that we need your data in order to process it for the purposes set out in this Privacy Policy
- if you had given us consent to process your data, you withdraw that consent and we cannot otherwise legally process your data
- you object to our processing and we do not have any legitimate interests that mean we can continue to process your data
- your data has been processed unlawfully or has not been erased when it should have been.
Rights in relation to automated decision making
You have the right to have any decision that has been made by automated means and which has a significant effect on you reviewed by the Controller and we will consider any objections you have to the decision that was reached.
No fees usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights)
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.
Response Time
We try to respond to your concerns within two weeks. If your request is particularly complex or will take longer to respond to for any reason, we will notify you and keep you updated.
What will happen if your rights are breached?
You may be entitled to compensation for damage caused by contravention of the Data Protection Laws.
Complaints to the regulator
Please read this Privacy Policy – and if you do not think that we have processed your data in accordance with this policy – you should let us know as soon as possible.
You have the right to make a complaint at any time to the OPCC in Canada (information about how to do this is available on its website www.priv.gc.ca/en/) or the ICO in the UK (information about how to do this is available on its website at www.ico.org.uk.)
We would, however, appreciate the chance to deal with your concerns about data protection before you approach the Privacy Commissioner so please: Email Us