Statutory Irish & EU Data Protection
DPC Ireland Regulated
EU Data Residency · Germany
Children First Act 2015

Privacy Policy & Data Protection Framework

This document outlines how LocalFilm Ireland protects your personal data, production logistics, and creative work. Built specifically for the film and television community, our architecture enforces strict script confidentiality, zero-AI model training, full European data residency, and statutory safeguarding for young performers under Irish and European law.

Zero AI Ingestion
User scripts, treatments, lookbooks, and auditions are never used to train artificial intelligence or language models.
Production Confidentiality
Call sheets, shoot locations, and crew contact lists remain strictly private to your verified production team.
Child Safeguarding
Minors (<18) are rostered exclusively through verified adult guardians with zero direct contact disclosure.
100% EU Sovereignty
Primary databases, authentication, and media storage are hosted in Germany under direct Irish DPC regulation.
LAST REVISED
13 September 2026
SUPERVISORY AUTHORITY
DPC Ireland (Lead Authority)
HOSTING & STORAGE
Germany (Hetzner ISO 27001)
SECURITY STANDARD
AES-256 · TLS 1.3 · SOC 2 Aligned

1. Overview & Scope

Welcome to LocalFilm Ireland (localfilm.online and localfilm.ie), the dedicated digital infrastructure and professional ecosystem connecting filmmakers, crew, heads of department (HODs), line producers, and studios across all 32 Irish County Hubs and partner international production nodes.

We are deeply committed to safeguarding the personal data, intellectual property, and logistical confidentiality of our community. This Privacy Policy sets out how LocalFilm processes, secures, and respects personal data in full compliance with the General Data Protection Regulation (EU) 2016/679 (GDPR), the Irish Data Protection Act 2018, the Children First Act 2015, and the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011 (S.I. No. 336/2011).

Core Privacy Principle: LocalFilm operates on a strict Privacy-by-Design architecture. We never sell your personal information, never train artificial intelligence or large language models on your private scripts or call sheets, and strictly prohibit automated data scraping across all hubs.

2. Data Controller & Supervisory Authority

For the purposes of the General Data Protection Regulation and Irish Data Protection legislation, the Data Controller responsible for your personal data is:

3. Categories of Data We Collect

We process the following categories of data strictly necessary for our filmmaking directory, digital call sheet, and production logistics services:

  • Account & Professional Identity Data: Full name, verified email address, encrypted password hash (via bcrypt), selected County Hub (e.g., Wicklow, Galway, Cork, Belfast), professional bio, department specialities (e.g., Camera, Grip, Art Dept, Post-Production, Sound), IMDb Pro link, and profile headshots.
  • Federated Single Sign-On (SSO): When authenticating via Google OAuth or Apple Sign-In, we receive your verified email and unique subject identifier (sub) to provision your account without storing your external passwords.
  • Production & Call Sheet Data: Information entered by Line Producers and HODs into the Call Sheet Builder, including shoot dates, daily call times, set basecamps, Google Maps directions, nearest A&E hospital medical safety briefings, walkie-talkie channels, and cast/crew roster lists.
  • Communication & Interaction Data: Real-time WebSocket messages, noticeboard postings, survey pulse responses, peer endorsements (Vouching), and WebRTC video room signaling metadata.
  • Technical & Telemetry Data: IP address (utilized strictly for security, rate limiting, and fraud prevention), browser user-agent, session cookies, and client-side offline storage keys (localfilm_active_callsheet_cache).

5. Protection of Minors & Child Performers

LocalFilm Ireland enforces strict, zero-tolerance child safeguarding policies in full alignment with GDPR Article 8, the Irish Data Protection Act 2018 (Section 31 - Age of Digital Consent), the Children First Act 2015, and the Protection of Young Persons (Employment) Act 1996:

Strict 18+ Account Registration
Direct registration of accounts, directory profiles, and messaging access on LocalFilm is strictly limited to individuals aged 18 years or older. We do not knowingly collect personal registration data from children.
Standard: Mandatory 18+ Verification
Guardian & Chaperone Roster Gate
Where child actors or minor performers participate in productions, their scheduling on digital call sheets must be managed exclusively through their registered parent, legal guardian, or licensed chaperone.
Irish Standard: Children First Act 2015
Zero Direct Child Contact Exposure
Direct personal mobile numbers or personal email addresses of minor performers are strictly forbidden from public directories, radar searches, and unencrypted transmission. All call time dispatches route to verified guardians.
GDPR Art. 8 & DPC Minor Guidance
Child Performance Licensing Alignment
Producers utilizing LocalFilm are obligated to comply with statutory Child Performance Licences issued by the Department of Enterprise, Trade and Employment before adding minors to production schedules.
Dept. of Enterprise Licensing

Minor Data Removal Hotline: If a parent or guardian becomes aware that personal data relating to a minor has been uploaded without proper authorization, please email [email protected]. We will immediately purge the record within 24 hours.

6. Intellectual Property, Script NDA & Zero-AI Training Guarantee

LocalFilm Ireland was founded by and for filmmakers. We recognize that scripts, treatments, concept lookbooks, pitch decks, and call sheets represent highly valuable intellectual property and confidential trade secrets:

Zero-AI Model Training Guarantee
We provide an ironclad, legally binding guarantee: LocalFilm NEVER uses your scripts, treatments, call sheets, dialogue, or video recordings to train artificial intelligence, large language models (LLMs), or generative media systems.
Standard: 100% Zero-AI Training
100% Creator IP Ownership
You retain 100% exclusive copyright, trademark, and moral rights over all screenplays, casting submissions, lookbooks, and production collateral uploaded to LocalFilm. LocalFilm claims zero ownership or licensing rights over your creative assets.
Irish Copyright & Related Rights Act 2000
Production NDA Confidentiality
All script attachments, scene breakdowns, and casting notices shared inside private project workspaces are strictly segregated behind role-based access control (RBAC) and encrypted storage tokens.
Industry Standard Production NDA

7. Digital Call Sheets & Production Confidentiality

Film and television production involves highly confidential logistical and personal information (including actors' personal mobile numbers, unreleased script details, confidential shoot locations, and emergency medical contacts). LocalFilm enforces strict industry confidentiality standards:

  • Production Data Isolation: Call sheets and rosters generated inside LocalFilm belong exclusively to the creating production team. They are never published to public search engines or indexed by external web crawlers.
  • Tokenized Direct Links: 1-Click WhatsApp and SMS call time links utilize private cryptographic tokens, ensuring that only the intended crew member receives their specific call times and directions.
  • Offline Resilience & Local Encryption: On-set caching for remote shoot locations (e.g. Kerry, Connemara, Wicklow) stores draft data locally on your device in localStorage, minimizing unnecessary cloud transmission until reconnection occurs.

8. SOC 2 Type II Alignment & Enterprise Security

While LocalFilm is actively preparing for formal third-party SOC 2 Type II attestation, our core platform architecture has been engineered from the ground up to align directly with the American Institute of Certified Public Accountants (AICPA) SOC 2 Trust Services Criteria and ISO/IEC 27001 standards:

Encryption At Rest & Transit
All persistent database backups are encrypted using authenticated AES-256-GCM streams with unique 12-byte IVs. In-transit traffic is enforced over mandatory TLS 1.3 / HTTPS.
SOC 2 Criteria: CC6.1, CC6.7
Application-Level Authorization
Strict ownership validation verifies req.user.id against database record owners before any edit or delete mutation, eliminating Insecure Direct Object References (IDOR).
SOC 2 Criteria: CC6.2, CC6.3
Automated Maintenance & Purging
Nightly cron workers automatically purge unverified registrations older than 7 days and unlink unreferenced temporary uploads older than 48 hours to prevent data sprawl.
SOC 2 Criteria: CC6.5, CC7.2
Multi-Tenant Hub Isolation
County and regional hub data is logically isolated via Postgres row-level scoping, preventing unauthorized cross-hub access across administrative boundaries.
SOC 2 Criteria: CC6.6

SOC 2 Audit Readiness Roadmap: Formal third-party SOC 2 Type II examination and annual penetration testing are currently tracked under our enterprise compliance milestones.

9. Your Data Subject Rights (Chapter III GDPR)

Under EU and Irish data protection law, you hold statutory rights over your personal data. LocalFilm provides self-service in-app tools to exercise these rights immediately:

Right to Access & Portability
Export your entire profile, post history, and messages as a portable JSON archive with 1 click in your Dashboard.
Dashboard > Download My Data
Right to Restrict & Go Off-Grid
Instantly toggle your profile off the grid to vanish from global directories, radar searches, and public member lists.
Dashboard > Digital Visibility Toggle
Right to Rectification
Update or modify your biographical details, department credits, County Hub location, and headshots anytime in "My Profile".
Dashboard > My Profile
Right to Erasure ("To Be Forgotten")
Initiates our 2-Step Verified Erasure protocol. A cryptographic confirmation link is sent to your email to verify your intent before permanent purging.
Dashboard > Request Deletion (2-Step Email Gate)

🛡️ Mandatory 2-Step Verification & Multiple Warning Gates for Data Erasure

To prevent accidental deletion or unauthorized account sabotage, LocalFilm enforces a strict 2-Step Cryptographic Email Verification Protocol whenever an account deletion request is triggered from the Personal Dashboard:

  1. In-App Multi-Warning Modal: When you click "Request Deletion", the dashboard alerts you that the action is permanent, irreversible, and cannot be undone, and prompts for your explicit confirmation.
  2. Cryptographic Email Verification Link: An automated confirmation email is immediately dispatched to your verified registered email address with a single-use, 24-hour cryptographic token.
  3. Irreversible Execution Gate: The email clearly reiterates multiple warnings that confirming will permanently wipe all your profile credits, headshots, messages, and call sheet connections. Data erasure executes only when you click the confirmation button in your email. If the link is ignored, it expires automatically after 24 hours and your account remains active and secure.

To exercise any rights via formal inquiry, contact our Data Protection Officer at [email protected]. We will respond within 30 days in accordance with GDPR Article 12(3).

10. German Cloud Infrastructure & Third-Party Sub-Processors

To deliver frictionless authentication, geolocation mapping, and critical on-set communication, LocalFilm partners with vetted enterprise infrastructure providers under Article 28 (Data Processing Agreements) and Chapter V (Articles 44–49) of the GDPR.

Where personal data is transferred outside the European Economic Area (EEA), such transfers are strictly executed under European Commission Adequacy Decisions (such as the EU-U.S. Data Privacy Framework) or Standard Contractual Clauses (SCCs):

Primary European Cloud Infrastructure (Germany Datacenter Node)
Hetzner Cloud GmbH · Industriestr. 25, 91710 Gunzenhausen, Germany (Falkenstein & Nuremberg Nodes)
100% EU Data Residency: Germany German BDSG & EU GDPR Art. 28 DPA · ISO 27001

Core Database & Media Sovereignty: LocalFilm's entire production platform, PostgreSQL databases, Redis real-time caches, media uploads, and secure authentication gateways are hosted on enterprise dedicated cloud nodes physically situated in Germany (Falkenstein / Nuremberg).

Zero Third-Country Storage Transfers: Because our primary infrastructure is 100% EU-hosted in Germany, all member accounts, film credits, call sheet rosters, and chat logs are governed strictly by the German Federal Data Protection Act (BDSG) and European GDPR, with zero mandatory data export to non-EU jurisdictions.

Infrastructure Scope: PostgreSQL Database, Node.js API, Real-Time WebSockets, Media Storage
Data Protection Standards: ISO/IEC 27001 Certified Datacenters, AES-256-GCM Volume Encryption
Google Identity Services (OAuth 2.0)
Google Ireland Limited · Gordon House, Barrow St, Dublin 4, Ireland
EEA Primary: Dublin, Ireland EU-U.S. Data Privacy Framework (DPF) & SCCs

Purpose & Privacy Protections: When you choose to sign in with Google, authentication is handled directly on Google's encrypted servers. LocalFilm receives only your verified email address, display name, and a cryptographic subject ID token (sub) to safely create or link your account.

Zero Password Access: LocalFilm never sees, processes, or stores your Google password. We do not request access to your Google Drive, Gmail, contacts, or calendar. For European users, the contracting controller is Google Ireland Ltd, with global backup transfers safeguarded by the official EU-U.S. Data Privacy Framework.

Data Exchanged: Verified Email, Display Name, Google Subject ID Token
GDPR Lawful Basis: Contractual Performance (Art. 6(1)(b)) / User Request
Sign in with Apple (Apple ID & Private Relay)
Apple Distribution International Ltd. · Hollyhill Industrial Estate, Cork, Ireland
EEA Primary: Cork, Ireland Irish / EU Data Protection Law & SCCs

Purpose & Privacy Protections: Apple Sign-In enables seamless Face ID / Touch ID biometric authentication. Apple gives you the option to use Hide My Email, generating a random, privacy-preserving relay address (e.g. [email protected]) so your real personal email is never shared.

Zero Password Access: LocalFilm never receives your Apple ID password or biometric credentials. Apple Distribution International Ltd in Cork, Ireland acts as the EEA entity, and all operations adhere strictly to Irish Data Protection Law and European Commission Standard Contractual Clauses.

Data Exchanged: Verified Apple Email or Private Relay Address, Apple User ID
GDPR Lawful Basis: Contractual Performance (Art. 6(1)(b)) / User Request
Dynamic 3D Orbit Globe, Production Radar & Geocoding
LocalFilm Dynamic Visualization Engine · Mapbox GL JS Integration
EU-U.S. Data Privacy Framework (DPF) & SCCs

Dynamic Hub & Network Scalability: The 3D Orbit Globe and 2D Production Radar dynamically scale to render new Irish County Hubs and verified international production nodes as new filmmakers and studios join the network across Ireland, the UK, Europe, and global co-production territories.

Privacy Guardrails & Off-Grid Control: Talent and studio pins are mapped to regional County Hub centroids to safeguard private residential addresses. Furthermore, members who toggle Digital Visibility off in their dashboard vanish immediately from all 3D Orbit and 2D Radar visualizations in real time. Map tile queries contain zero personal identity data.

11. Beta Telemetry, UX Diagnostics & Privacy Masking

Active Beta Development & Community Feedback Loop

Building the Future of Irish Film Production — Fast, Safe & Intuitive

LocalFilm is currently operating in active Beta. Because our mission is to build the definitive digital infrastructure for Ireland's film and television industry, we must ensure our platform is lighting-fast, easy to navigate, and free from frustrating obstacles for filmmakers, Line Producers, and Heads of Department working on set.

We use Microsoft Clarity as a behavioral diagnostic tool to identify where users encounter friction, confusing layouts, or dead clicks. This telemetry allows our team to iterate rapidly and pivot features directly around how our members actually want to use the platform.

Microsoft Clarity (Beta UX Diagnostics & Telemetry)
Microsoft Ireland Operations Limited · One Microsoft Place, Leopardstown, Dublin 18, Ireland
EEA Entity: Dublin 18, Ireland EU-U.S. Data Privacy Framework (DPF) & ISO 27001 / 27018

Privacy-by-Design Sensitive Data Masking: Microsoft Clarity operates with strict, automated client-side data masking enabled. Before any diagnostic data leaves your browser, sensitive inputs (including form fields, names, email addresses, phone numbers, passwords, call sheet cast lists, and confidential script notes) are masked locally with asterisks (***).

Zero Keystroke / Password Logging: Keystrokes inside sensitive text fields and passwords are never captured or stored. Clarity does not record video of your physical screen; it only reproduces an abstracted, masked visual layout of user interface interactions (such as scroll depth and navigation clicks).

No Cross-Site Profiling & No Data Brokering: Microsoft Clarity does not track you across third-party websites and does not sell telemetry data to behavioral advertisers. Microsoft Ireland Operations Ltd is certified under the EU-U.S. Data Privacy Framework and adheres to strict ISO/IEC 27001 and ISO/IEC 27018 cloud privacy standards.

Strict Prior Consent Gating (ePrivacy S.I. No. 336/2011): In compliance with Irish and EU ePrivacy rules, Microsoft Clarity is completely disabled and blocked from loading until you explicitly grant consent via our Cookie Preferences or floating shield. You can revoke consent at any time in 1 click.

Diagnostic Scope: Aggregated Heatmaps, Scroll Depth, UI Friction & Dead-Click Diagnostics
Privacy Safeguards: Default Client-Side Masking, Zero Keystroke Capture, Consent-Gated Execution

12. WebRTC Video Rooms & Ephemeral Media Privacy

LocalFilm features integrated real-time video conferencing for auditions, table reads, production meetings, and remote casting calls powered by a dedicated LiveKit Selective Forwarding Unit (SFU):

  • Ephemeral Media Routing: Video and audio streams are forwarded ephemerally through our dedicated server memory. LocalFilm does not record, analyze, or archive any live video or audio streams by default.
  • Zero Covert Recording: Background recording is strictly disabled. If a production team enables an explicit on-screen audition recording feature in the future, all participants will receive mandatory on-screen visual banners and audio prompts before any recording begins.
  • Encrypted In-Transit Streaming: All WebRTC media packets are secured via DTLS-SRTP end-to-middle encryption, preventing eavesdropping on public networks and mobile cellular connections.

13. 72-Hour Incident Response & Data Breach Notification

In strict compliance with Articles 33 and 34 of the GDPR, LocalFilm maintains a formal Security Incident Response Protocol to detect, contain, and remediate any potential data security incidents:

72-Hour Supervisory Authority Notification: In the event of a personal data breach posing a risk to the rights and freedoms of individuals, LocalFilm will notify the Data Protection Commission (DPC) of Ireland without undue delay and, where feasible, not later than 72 hours after becoming aware of it.

Where a breach is likely to result in a high risk to your rights (e.g. unreleased production scripts, sensitive payment information, or identification credentials), LocalFilm will directly communicate the nature of the breach, the affected categories of data, and recommended mitigation steps to affected data subjects without undue delay.

14. Prohibition of Automated Decision-Making & Profiling

In accordance with GDPR Article 22:

  • No Algorithmic Blacklisting or Automated Rejection: LocalFilm does not employ automated algorithms, predictive profiling, or artificial intelligence to make hiring decisions, evaluate actor auditions, or disqualify crew members from call sheets.
  • Human-Led Curation: All talent discovery, casting selections, and vouching reviews remain 100% human-directed by verified directors, Line Producers, and Heads of Department.

15. Data Retention & Storage Maintenance

We retain your data only for as long as necessary to provide our services or comply with legal requirements:

  • Active Profiles: Retained while your account remains active or until you complete the 2-step verified erasure process.
  • User-Initiated 2-Step Erasure: Upon clicking the 24-hour verification link sent to your registered email, your profile, contact numbers, headshots, bio, and credentials are permanently purged and unlinked from the database. A one-way cryptographic SHA-256 hash of your email is placed into deleted_users_log strictly to honor communication suppression and prevent subsequent unsolicited emails.
  • Automated 24h Nightly Storage Cleaner: Unverified registration attempts are permanently deleted from the database after 7 days. Unattached temporary media uploads in /uploads/ are unlinked after 48 hours.
  • Security Audit Logs & IP Bans: Banned IP records in ip_bans are retained to preserve platform safety and prevent repeat spam attacks.

16. Cookies, DPO Inquiries & Complaints

LocalFilm enforces strict prior consent gating under ePrivacy Regulations (S.I. No. 336/2011). You can customize your cookie preferences anytime via the Floating Shield on the bottom right of the website:

  • Strictly Necessary Cookies: Essential session cookies (e.g. token, authentication JWT) enabling account login and CSRF protection. Cannot be disabled.
  • Analytics & Performance Cookies: Anonymous, masked telemetry (Microsoft Clarity & Google Tag Manager) used strictly to diagnose user interface friction and optimize loading speed. Blocked until explicit affirmative consent is granted.
  • Marketing Cookies: We do NOT host third-party behavioral advertising networks or retargeting pixels.

Data Protection Desk & DPO Inquiries: [email protected] / [email protected]
General Support: [email protected]
Security Inquiries: [email protected]

If you are not satisfied with our response, you have the statutory right under GDPR Article 77 to lodge a formal complaint with the Data Protection Commission (DPC) of Ireland at dataprotection.ie.