Privacy Policy
Last updated: [BLANK: publication date]
This Privacy Policy explains how [BLANK: legal entity name] ("Dolfinn", "we", "us"), operator of the film-production planning tool available at dolfinn.be, collects and uses personal data. It applies to visitors of our website and users of our application.
We are committed to processing personal data in accordance with the EU General Data Protection Regulation (GDPR) and Belgian data protection law.
1. Who is responsible (controller)
[BLANK: legal entity name] [BLANK: registered address] Company number (BCE/KBO): [BLANK] Contact for privacy matters: [BLANK: privacy@dolfinn.be]
We have [BLANK: appointed / not appointed] a Data Protection Officer. [If appointed: DPO contact: [BLANK].]
2. Two roles: controller and processor
Dolfinn acts in two capacities, and this determines your rights and our duties:
- As a controller, for the account and billing data of the people who sign up and use Dolfinn (our users). We decide why and how that data is processed. This policy covers that data.
- As a processor, for the production content our customers create inside the tool — breakdowns, schedules, cast and crew details, scripts, etc. Here, our customer (the production or company that holds the account) is the controller, and we process that data on their behalf and on their instructions. Processing of that content is governed by our Data Processing Agreement (DPA) with the customer, not by this policy. If you are a cast or crew member whose data appears in a production, please contact the production company that entered your data; we will assist them in responding to your request.
3. What personal data we collect
3.1 Account data (we are controller)
- Identity & contact: name, email address.
- Authentication: hashed password and/or third-party login (OAuth) tokens, email verification status, profile image (if you set one).
- Session & security data: session tokens, IP address, and browser user-agent, which we store to keep you logged in and to protect the account against unauthorised access.
- Invitations: email addresses of people you invite to an organisation or production.
- Feedback you submit: your message, and — to help us reproduce issues — your email, name, the page path and your viewport size.
3.2 Billing data (we are controller; only if billing is enabled for you)
- Subscription status and plan, and identifiers linking your account to our payment processor (Stripe customer and subscription IDs). Card details are handled directly by Stripe and are never stored on our systems.
3.3 Production content (we are processor)
Content our customers enter may include personal data of third parties, for example: cast/actor names, crew members' email addresses, production-member roles, and shooting location addresses and coordinates. Uploaded scripts may also contain personal data. See section 5 on our use of AI for script processing.
4. Why we process it, and our legal basis
| Purpose | Data | Legal basis (GDPR Art. 6) |
|---|---|---|
| Provide the service, your account and organisations | Account data | Performance of a contract (Art. 6(1)(b)) |
| Keep you logged in; protect against unauthorised access and abuse | Session, IP, user-agent | Legitimate interest — security (Art. 6(1)(f)) |
| Send transactional email (password reset, invitations) | Name, email | Performance of a contract (Art. 6(1)(b)) |
| Handle billing and subscriptions | Billing data | Contract (Art. 6(1)(b)); legal obligation for accounting records (Art. 6(1)(c)) |
| Understand and improve product performance | Aggregate, cookieless analytics (no personal data) | Legitimate interest (Art. 6(1)(f)) |
| Respond to feedback and support | Feedback data | Legitimate interest (Art. 6(1)(f)) |
| Process production content on the customer's behalf | Production content | The customer's basis as controller (governed by the DPA) |
Where we rely on legitimate interest, we have balanced that interest against your rights; you may object at any time (see section 9).
5. AI-assisted script processing
To speed up breakdown creation, uploaded scripts are sent to Mistral AI (a processor established in France, EU) for automated extraction of scenes, characters and other production elements. Script content may contain personal data (for example, character or cast names). Mistral processes this data on our instructions under a data processing agreement and does not use it to train its models on our behalf. No script content is sent to any AI provider outside the EU.
6. Cookies
We use only two cookies, and no advertising or tracking cookies:
- an essential session cookie (set by our authentication system) to keep you logged in; and
- a functional preference cookie that remembers whether you collapsed the sidebar.
Our website analytics (Vercel Analytics and Speed Insights) are cookieless and collect no personal data. Because we set no non-essential tracking cookies, no cookie consent banner is required. Full details are in our Cookie Notice.
7. Who we share data with (subprocessors)
We do not sell your data. We share it only with the service providers needed to run Dolfinn, each bound by a data processing agreement. Our current subprocessors:
| Provider | Purpose | Location |
|---|---|---|
| Neon | Database hosting | Frankfurt, EU |
| Vercel | Application hosting & delivery | Compute in Frankfurt (fra1); Vercel Inc. is US-based |
| Resend | Transactional email | United States |
| Stripe | Payments & subscriptions | United States |
| Mistral AI | AI script extraction | France, EU |
The current list, kept up to date, is at Subprocessors.
8. International transfers
Your data is primarily stored and processed in the EU (database in Frankfurt, application compute in Frankfurt). However, some of our subprocessors are established in, or parented in, the United States — Vercel (US company; control-plane, logging and support access may occur in the US even though compute runs in Frankfurt), Resend, and Stripe. Where personal data is transferred to the US, the transfer is protected by appropriate safeguards under GDPR Chapter V — the EU Standard Contractual Clauses and/or certification under the EU-U.S. Data Privacy Framework. A copy of the relevant safeguards is available on request.
9. Your rights
Under the GDPR you have the right to: access your data; rectify inaccurate data; erase your data ("right to be forgotten"); restrict or object to processing; and data portability. Where processing is based on consent, you may withdraw it at any time.
To exercise any right, email [BLANK: privacy@dolfinn.be]. We will respond within one month. (Interim note while self-serve deletion is being built: account deletion is currently handled on request via this address; on deletion, your account data is removed and associated records are deleted or anonymised.)
You also have the right to lodge a complaint with the Belgian supervisory authority: Gegevensbeschermingsautoriteit / Autorité de protection des données (APD/GBA), Rue de la Presse 35 / Drukpersstraat 35, 1000 Brussels — www.dataprotectionauthority.be.
10. How long we keep data
- Account data: for as long as your account is active. When you delete your account it is scheduled for deletion and permanently erased after a 30-day grace period (during which you can cancel); your personal identifiers are then removed from any shared production records you created.
- Sessions, IP and user-agent: kept until the session expires; expired sessions are deleted automatically every day.
- Billing records: retained for 7 years to meet Belgian accounting-law obligations.
- Activity log: entries are deleted automatically after 12 months.
- Notifications: read notifications are deleted after 6 months; unread notifications are kept until you have read them.
- Feedback and support: deleted after 12 months.
- Production content: for as long as the customer keeps it; deleted on the customer's instruction or when the production/account is deleted (cascade deletion).
11. Security
We use encryption in transit, hashed passwords, HTTP-only session cookies, tenant isolation at the database level, and access controls. No system is perfectly secure, but we take appropriate technical and organisational measures to protect your data.
12. Changes
We may update this policy. Material changes will be notified [BLANK: by email / in-app], and the "last updated" date above will change.
13. Contact
Questions about this policy: [BLANK: privacy@dolfinn.be].