DWM | DARK WINDOW MEDIA

Your Privacy Matters

Privacy Policy

Dark Window Media respects your privacy and is committed to protecting personal data in accordance with the General Data Protection Regulation (GDPR) and the Data Protection Act 2018 in Ireland.

Last updated: 9 November 2026

This Privacy Policy explains how Dark Window Media collects, uses, stores and protects personal information in connection with its website and film and television production activities.

1. Who We Are

Dark Window Media is an Irish film production company founded in 2008. The company works across independent films, feature films, short films, television and documentary projects in Ireland and internationally. It also provides line production services for international feature films.

For the purposes of this Privacy Policy, references to "Dark Window Media", "we", "us" and "our" mean Dark Window Media.

For general privacy enquiries, you can contact us at:

Email: contact@darkwindowmedia.com

2. The Data Protection Laws That Apply

We process personal data in accordance with applicable data protection legislation, including:

3. What Personal Data We May Collect

The personal information we collect depends on how you interact with Dark Window Media and the nature of the production or service involved.

Website visitors and general enquiries

When you contact us or use our website, we may collect:

Film and production activities

Depending on the project and our role, we may process personal information relating to:

The information may include names, contact details, professional experience, role or contribution to a production, availability, contracts, payment-related information and production correspondence.

Where necessary for a particular production, additional information may be processed, such as identification or eligibility documentation, travel information, emergency contact details or information relating to health, safety and accessibility requirements.

We will seek to limit personal information to what is necessary for the relevant purpose.

4. Special Category and Sensitive Personal Data

In certain production circumstances, we may need to process special category personal data, as defined under Article 9 GDPR. This may include health information or other sensitive information where relevant to a production, contribution, safety arrangement or legal obligation.

Where special category data is required, we will only process it where an appropriate condition under Article 9 GDPR applies, together with a lawful basis under Article 6 GDPR where required.

We do not seek sensitive personal information unless it is necessary for a specified and legitimate purpose.

5. How We Obtain Personal Data

We may obtain personal data:

Where personal data is obtained from another source, we will provide privacy information as required by Articles 13 and 14 GDPR, subject to any applicable legal exceptions.

6. Why We Use Personal Data

We may use personal data for the following purposes:

7. Our Lawful Bases for Processing

Under Article 6 GDPR, we must have a lawful basis for processing personal data. Depending on the circumstances, we may rely on:

Consent – Article 6(1)(a)

Where we ask for consent for a specific purpose, such as certain optional communications or uses of personal information, we will explain what you are agreeing to. You can withdraw consent at any time.

Contract – Article 6(1)(b)

Where processing is necessary to enter into or perform a contract with you, including relevant production, freelance or supplier arrangements.

Legal obligation – Article 6(1)(c)

Where we need to process information to comply with a legal obligation, including applicable tax, accounting and employment-related requirements.

Legitimate interests – Article 6(1)(f)

Where processing is necessary for our legitimate business interests, such as responding to professional enquiries, managing production activities, maintaining business relationships and protecting our operations, provided those interests are not overridden by your rights and freedoms.

Where we rely on legitimate interests, we consider the impact on individuals and their rights.

The appropriate lawful basis will depend on the specific processing activity. We do not assume that one lawful basis applies to every production or individual.

8. Filming, Photography and Production Content

As a film production company, we may record images, video, audio and interviews as part of our production activities.

Where individuals are filmed, photographed or recorded, the relevant privacy information, permissions and arrangements will depend on the nature of the production, the individual's involvement and the circumstances in which recording takes place.

Where appropriate, we may provide production notices, contributor agreements, releases or other relevant information explaining how recordings will be used.

The use of an individual's image, voice or contribution may involve production, editing, distribution, exhibition, promotion or other uses associated with the relevant project, subject to applicable law and the arrangements governing that production.

The publication of footage or other production material does not automatically mean that all personal data protection rights cease to apply.

9. When We Act for Another Production Company or Client

Our data protection responsibilities may vary depending on the production and the services we provide.

In some circumstances, Dark Window Media will act as an independent data controller, deciding how and why personal data is processed.

In other circumstances, where we process personal data on behalf of a production company, client or other organisation and under its documented instructions, we may act as a data processor.

Where we act as a processor, the relevant client or production company will generally be responsible for determining the purposes and means of processing and providing the required privacy information to individuals. We will process the information in accordance with the applicable contractual arrangements and data protection requirements.

The specific responsibilities will be determined by the nature of the production and the arrangements in place.

10. Who We Share Personal Data With

We may share personal information where necessary for the purposes explained in this policy, including with:

We only share personal data where there is an appropriate purpose and lawful basis, and we take reasonable steps to ensure that appropriate confidentiality and data protection arrangements are in place.

11. International Transfers

Film production activities may involve working with individuals, organisations and production partners located outside Ireland and the European Economic Area (EEA).

Where personal data is transferred outside the EEA, we will ensure that an appropriate transfer mechanism is in place in accordance with Chapter V GDPR, where required.

This may include:

Further information about relevant international transfers and safeguards can be requested using the contact details in this policy.

12. How Long We Keep Personal Data

We retain personal information only for as long as necessary for the purposes for which it was collected, taking account of legal, contractual, accounting, production and business requirements.

Retention periods may differ depending on the type of information and the nature of the project.

For example:

When information is no longer required, we will take appropriate steps to delete it, anonymise it or securely dispose of it, subject to any legal or legitimate archival requirements.

13. How We Protect Personal Data

We take appropriate technical and organisational measures designed to protect personal information against unauthorised access, accidental loss, alteration, disclosure or destruction.

Measures may include access controls, password protection, confidentiality arrangements, secure storage and appropriate management of information shared with production partners and service providers.

Access to personal information is limited to those who need it for legitimate business or production purposes.

14. Your Data Protection Rights

Under GDPR, you may have the following rights, subject to the conditions and limitations set out in data protection law:

These rights are not absolute and may be subject to legal conditions, exemptions and limitations.

To exercise a right or make a privacy enquiry, contact us at:

contact@darkwindowmedia.com

We may need to verify your identity before responding to a request. We will respond within the time limits required by applicable data protection law.

15. Children and Young People

Some productions may involve children or young people. Where personal data relating to children is processed, we will take account of their age, circumstances and applicable legal requirements.

Where required, appropriate information, permissions and safeguards will be put in place, including arrangements involving parents, guardians or other responsible persons.

16. Website Cookies

Our website uses cookies and similar technologies. Some cookies are necessary for the operation of the website, while optional cookies may be used for other purposes where permitted.

You can manage your cookie preferences through the cookie consent options available on our website.

For more information about the cookies used on our website and how to manage your choices, please read our Cookie Policy.

17. Third-Party Websites

Our website may contain links to external websites, including social media platforms. Those websites operate independently and have their own privacy policies and practices.

We are not responsible for the privacy practices or content of third-party websites. We recommend reviewing their privacy information before providing personal data.

18. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our business, production activities, website, legal requirements or data protection practices.

The latest version will be published on this page, together with the date on which it was last updated.

19. Complaints and the Data Protection Commission

If you have concerns about how we handle your personal data, we encourage you to contact us first so that we can try to address your concerns.

You also have the right to lodge a complaint with the Irish Data Protection Commission (DPC):

Data Protection Commission
21 Fitzwilliam Square South
Dublin 2
D02 RD28
Ireland

Website: www.dataprotection.ie

20. Contact Us

If you have any questions about this Privacy Policy, our data protection practices or the exercise of your rights, please contact:

Dark Window Media
Email: contact@darkwindowmedia.com
Website: darkwindowmedia.com