Privacy and Cookie Policy
This privacy and cookie policy (“Policy”) describes how Ithi Private Limited (“Company”, “we”, “us”, or “our”), collects, uses, stores, shares, transfers, and protects personal data in connection with the access to and use of its digital platform and related services designed for the film and creative production ecosystem. The Platform is intended to enable networking, coordination, opportunity discovery, project creation, professional engagement, and related interactions among producers, directors, actors, technical crew, support staff, businesses, agents, managers, event partners and other creative professionals.
We are committed to upholding the privacy and security of information supplied by Users accessing the Platform. Please take a moment to familiarize yourself with our privacy practices and learn about our information-gathering practices. By accessing the Platform, the User acknowledges the acceptance of and agrees to be bound by the terms of this Policy. You signify that you have read and understood this Policy.
If you do not agree with this Policy, please do not use the Platform or provide us with any Information.
This Policy applies to all Users, visitors, registrants, businesses, event organizers, service providers and other individuals whose personal data is processed through the Platform. For the avoidance of doubt, this Policy applies only to the collection, use, disclosure and processing of personal data through the Platform and does not apply to third-party websites, applications, or services that do not link to or are not controlled by the Company, even if accessible through the Platform.
Definitions
“Applicable Law” means all privacy and data protection laws applicable to the Company and the Platform in India, as amended from time to time, including but not limited to the Digital Personal Data Protection Act, 2023 and the rules made thereunder, Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, as applicable from time to time;
“Company” means Ithi Private Limited, and includes its successors, permitted assigns, affiliates, and authorised representatives, as the context may require;
“Personal Data” means any data about an individual who is identifiable by or in relation to such data, directly or indirectly, and includes any equivalent concept recognised under Applicable Law;
“Platform” means the digital platform, website, application, interface, tools, functionalities, databases, and related services operated, owned, or made available by the Company for networking, coordination, opportunity discovery, project creation, professional engagement, event discovery, listing, communication, content hosting, and related interactions in the media and production ecosystem;
“Sensitive Personal Data” or any similar category shall be interpreted in accordance with Applicable Law, if and to the extent recognized thereunder;
“User” means any person or entity who accesses, browses, registers on, uses, interacts with, lists on, uploads content to, purchases services through, or otherwise uses the Platform in any capacity, including visitors, registrants, businesses, event organiser, service providers, talent resources, technical crew, support staff, agents, managers, and other creative professionals or entities, and for the purposes of this Policy, may also include any visitors of the Platform.
General Consent
By using the Platform or submitting Personal Data through it, the User consents to the collection, use, storage, disclosure, and other processing of Personal Data in accordance with this Policy, to the extent such consent is required under Applicable Law.
The User represents that any Personal Data and other information submitted to the Company is, to the best of the User’s knowledge, true, accurate, complete, and up to date, and undertakes to update such information where necessary through the Platform or by contacting the Company.
Categories and Collection of Data
In order to better provide you with the services offered on the Platform, the Company will collect Information that may be personally identifiable to you as defined under this Policy. You acknowledge that any Information provided by you shall be true, correct, accurate and up-to-date.
The Company may collect the following Personal Data, in the following manner:
data collected directly from Users when they create an account, subscribe to services, upload Portfolio Materials (see user generated content policy), react to opportunities and listings, interact with other Users, or contact the Company. This may include, inter alia, information that Users share through device settings, such as camera access, photos, and any other allied device information and IP addresses;
device and technical information, including device type, operating system, browser type, internet protocol (IP) address, approximate geolocation, language preferences, timestamps, log file information, usage patterns, and unique device or application identifiers, where collected lawfully and as necessary for Platform functionality, analytics, diagnostics, fraud prevention, or security
data from authorized representatives, employers, business accounts, event organizers, or talent agents where they lawfully provide such information;
data from third-party vendors such as payment gateways, identity verification service providers, analytics providers, and telecommunication or infrastructure providers; and/or
data from cookies and similar tracking technologies used on the Platform.
If the User enables permissions on a mobile device or other device, the Company may access data such as camera, photo library, microphone, location, notifications, or other device features solely to the extent necessary to provide the relevant functionality requested by the User, subject to Applicable Law and device-level permissions. Users may manage such permissions through their device settings, though disabling certain permissions may limit Platform functionality.
Cookie Policy
The Platform uses cookies and similar tracking technologies, including pixels, tags, scripts, and local storage tools, to enhance functionality and user experience. Cookies are small data files stored on a User’s device that enable core features such as secure login, session continuity, and service delivery. The Platform uses different categories of cookies, such as and including:
Strictly necessary cookies: These cookies are essential for our services to function correctly. They enable core features like user login, security, network management, and accessibility. Without these cookies, certain services or functionalities may be unavailable;
Performance cookies: These cookies collect aggregated, anonymous data on how users interact with our services. They help us understand and improve performance, such as which pages or screens are most visited and if any errors occur.
Functional cookies: These cookies help personalize your experience by remembering your preferences (e.g., language or region). They enhance usability but are not strictly necessary for the services to function;
Analytics and performance cookies: These cookies track user activity across pages or screens. We use the data to analyze trends, understand user behavior, and tailor content or ads based on interests.
These technologies are used to recognize Users, maintain security, analyse platform usage, support diagnostics, and enable lawful analytics and service-related functions.
Some cookies may be placed by third-party service providers, such as analytics or payment processors, who process data under their own privacy policies. Users can manage or disable cookies through the Platform’s consent tools, browser settings, or device controls. However, restricting certain cookies may impact functionality or limit access to parts of the Platform.
Where the Company uses third-party analytics tools, such third-party service providers may collect information in accordance with their own privacy policies. The Company may provide appropriate controls or opt-out mechanisms where feasible and legally required.
Processing of Personal Data
The Company may process Personal Data for the following purposes:
to register, administer, and maintain the User accounts and subscriptions;
to enable professional networking, project creation, talent discovery, recruitment, shortlisting, and opportunity display among Users;
to host, store, display, watermark, and safeguard User Portfolio Materials and digital repository functions;
to manage event and workshop discovery, listings, redirections, and related interactions;
to send such information that may be of interest to Users;
conducting research and perform analysis in order to measure, maintain, protect, develop and improve our services;
to send service-related communications, account alerts, authentication codes, transactional messages, updates relating to opportunities, project participation, events, changes to services, and, where permitted by law, promotional or engagement communications. Users may be able to opt out of non-essential promotional communications through the unsubscribe mechanism provided by the Company, though they may still receive essential service communications;
to verify identity, eligibility, age/majority, parental authority, business authorisation, and credentials where required or permitted;
to process payments, invoices, refunds, and related financial transactions;
to provide customer support, grievance handling, internal complaint or escalation procedures, and dispute-related administration;
to enforce contractual terms, community standards, moderation rules, intellectual property protections, and platform safety measures;
to detect, investigate, prevent, and respond to fraud, abuse, unlawful conduct, security incidents, and policy violations; and/or
to comply with legal, regulatory, tax, accounting, audit, and law-enforcement obligations.
The Company also aims to improve its service by applying information about the usage of such services, from the Users. We may also process any data to personalize and improve a Users’ experience with the Company’s platform.
Subject to Applicable Law, the Company may keep track of the websites and pages our users visit within the Platform to determine what services are the most popular. This data is used to deliver customized content and advertising within the Platform to customers whose behavior indicates that they are interested in a particular subject area.
Legal Basis for Processing
To the extent required under Applicable Law, the Company shall process Personal Data only on a valid legal basis, including:
the User’s consent;
performance of a contract or taking steps at the request of the User before entering into a contract;
compliance with legal obligations; and
legitimate uses or legitimate interests recognised under Applicable Law and enforcement of Platform rules, subject to applicable safeguards.
Where consent is relied upon, Users may withdraw consent in accordance with Applicable Law, subject to the consequences of such withdrawal on service availability, usage of the Company’s Platform, and lawful prior processing.
Sharing and Disclosure of Personal Data
The Company may share Personal Data with the following categories of recipients, only to the extent necessary:
other Users, where such disclosure is inherent in profile visibility, networking, shortlisting, project collaboration, or communication features of the Platform;
Business Users, production houses, event organiser, business partners, and commercial users, where the User chooses to engage with opportunities, listings, collaborations, or events;
third-party service providers, including payment gateways, identity verification providers, hosting providers, telecommunication providers, analytics vendors, customer support tools, and security service providers;
legal, regulatory, judicial, or governmental authorities where required by law or for the protection of rights and safety;
professional advisers, auditors, and consultants, subject to confidentiality obligations;
prospective investors, acquirers, or successors in the event of a restructuring, merger, acquisition, sale of assets, or similar transaction, subject to appropriate confidentiality and lawful processing requirements.
The Platform integrates various third-party services and links, and use of such services is subject to their respective terms and privacy policies. The Company disclaims liability for the acts, omissions, breaches, or service failures of third-party vendors to the extent set out in the governing contract and Applicable Law.
The Company may also process aggregated, anonymized, or de-identified data for analytics, product improvement, security, research, business intelligence, and service development purposes, provided such data does not identify an individual or is used in accordance with Applicable Law.
We may anonymize and/or de-identify information collected from, including via the use of third-party web analytic tools as described below. As a result, our use and disclosure of aggregated and/or de-identified information is not restricted by this Policy, and it may be used and disclosed to others without limitation.
Data Retention
The Company shall retain Personal Data only for as long as necessary for the purposes described in this Policy, including:
while the User account remains active;
for such period as required to provide Platform services, maintain records, resolve disputes, enforce agreements, and comply with legal or regulatory obligations;
for backup, fraud prevention, security, and audit purposes, subject to lawful retention limits;
until valid deletion requests are processed, subject to exceptions under Applicable Data Protection Law and the Company’s legitimate record-retention needs.
User Portfolio Materials (see User Generated Content Policy) may remain stored for a limited period after account closure where necessary for legal compliance, dispute resolution, backup cycles, or enforcement-related review.
Where Personal Data is no longer required for the purpose for which it was collected, the Company shall delete, erase, anonymize, or otherwise dispose of such data in accordance with Applicable Law and its internal retention or disposal practices, unless retention is required by law or reasonably necessary for legitimate business purposes.
Cross-Border Transfers
The Company intends to process Personal Data primarily within India. If, in limited circumstances, Personal Data is accessed from or transferred outside India, the Company shall implement such contractual, technical, or organizational safeguards as may be required under Applicable Law.
Users acknowledge that certain third-party vendors or infrastructure providers engaged by the Company may process data from multiple jurisdictions, subject to lawful safeguards and contractual controls.
User Rights
Subject to, and in accordance with Applicable Law, Users may have the right to:
access their Personal Data and information about processing;
request correction, completion, or updating of inaccurate or incomplete data;
request deletion or erasure of Personal Data, subject to legal exceptions;
withdraw consent where processing is based on consent;
object to or restrict certain kinds of processing, where recognized by law;
request grievance redressal;
nominate another person to exercise rights in accordance with applicable law, where such right is recognized.
Users may exercise such rights by using the mechanisms made available on the Platform or by contacting the Company through the grievance/contact details set out below. The Company may request reasonable information to verify the identity or authority of the requesting person before acting on a request.
Minor Users
We do not knowingly collect or solicit personally identifiable information from minors. If you are under the age of 18 (eighteen) or below the age permitted under applicable local laws, you must seek permission from a parent or guardian to use this website.
Where the Platform permits registration of children, being Users under the age of 18 years, such accounts must be created, managed, and operated exclusively by a parent or legal guardian. Verifiable parental consent must be obtained before collection of any personal data relating to a minor, in strict compliance with Applicable Law.
The Company reserves the right to suspend or delete accounts where age, consent, or guardian authority cannot be adequately verified.
Security Measures
The Company shall implement reasonable technical and organizational security measures appropriate to the nature of the Personal Data and the risk involved and to safeguard the Personal Data of Users.
If a password is used to help protect User accounts and account information, it is the responsibility of the User to keep the password confidential. We will use generally accepted industry standards to protect the User information.
Users acknowledge and agree that no method of transmission or storage is completely secure, and the Company does not warrant or represent that unauthorized access, hacking, data loss, or misuse can be prevented in all cases.
Breach Reporting
In the event of an actual or suspected personal data breach, the Company may investigate, contain, assess, document, and respond to the incident and make such disclosures or notifications as are required under Applicable Law.
Publicly Available Information and Liability
Information that is lawfully available in the public domain, furnished under applicable law, or otherwise excluded from protection under Applicable Law shall be treated in accordance with such law and may not be regarded as protected Personal Data for certain purposes to the extent permitted by law.
The Company shall in no manner be liable for any violation under this Policy, if the Information,
is already available in public domain; or
is collected by way of any illegal and unlawful means; or
is provided by any person who is incompetent under Section 11 of Indian Contract Act, 1872.
External Sources
Where the Platform permits sign-in or integration through third-party services or social media accounts, the Company may collect such information as is made available to it through those third-party interfaces in accordance with the User’s settings and the relevant third party’s policies. The Company may also receive information from partners, service providers, business accounts, recruiters, agents, event organizers, or other lawful sources and combine such information with data collected directly through the Platform, in each case in accordance with Applicable Law.
Data Protection Officer
The Company shall designate a Data Protection Officer, as required under Applicable Law, to oversee compliance with this Policy, coordinate privacy governance measures, receive and address complaints or grievances relating to the processing of Personal Data, and facilitate the exercise of User rights available under Applicable Law.
The Company’s Data Protection Officer is responsible for monitoring compliance with relevant legislation in relation to the protection of personal data.
The contact details of the officer are:
Name: [●]
Phone: [●]
Address: [●]
Email ID: [●]
Amendments
The Company may amend this Policy from time to time to reflect changes in law, business operations, services, or processing practices. Updated versions shall be published on the Platform.
Where required or appropriate, the Company may also notify Users of material changes through the Platform, by email, or through other service-related communications. Continued use of the Platform after such updates shall be subject to the revised policy, to the extent permitted under Applicable Law.
