PRIVACY POLICY

Effective Date: May 7, 2025

1. Introduction

This Privacy Policy applies to 2ND.STUDIO, operating under the registered legal entity Clumster B.V., incorporated under the laws of the Netherlands (KVK registration number: 91961076).

2ND.STUDIO (“we”, “our”, or “the Company”) is a creative video production studio specializing in commercial and educational content (music videos, documentaries, event filming, visual design, etc.). We value your privacy and are committed to protecting the personal data we handle. This Privacy Policy explains what information we collect, how we use and share it, and your rights under applicable data protection laws (including the EU General Data Protection Regulation, GDPR). 

We adhere to the following core data protection principles:

• Lawfulness, fairness, and transparency: We process personal data in a lawful and transparent way.

• Purpose limitation: Data is collected only for specified and legitimate purposes.

• Data minimisation: We collect only what is necessary for those purposes.

• Accuracy: We keep data up to date and correct it when needed.

• Storage limitation: We retain data only as long as necessary.

• Integrity and confidentiality: We use appropriate security to protect data.

• Accountability: We take responsibility for how we handle personal data and document our practices.

2. Data Controller

2ND.STUDIO is the data controller responsible for the processing of personal information under this policy. If you have questions about this policy or our data practices, you may contact us using the information provided in the Contact Us section below.

3. Acceptance of This Privacy Policy

By accessing or using our website, submitting a request through our Google contact form (available on the “Contact Us” page), or otherwise interacting with our services or content, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of it, we respectfully ask you not to use our website or services, and not to submit any personal data through our forms.

When you complete our Google contact form (available on the “Contact Us” page), you explicitly consent to the collection and processing of the personal information you provide, in accordance with this Privacy Policy.

4. Information We Collect

We collect different categories of personal data depending on how you interact with us. The table below summarizes the main types of data we gather, examples of each, the purposes for processing them, and the legal basis for processing:

1/ Category of Data

2/ Examples of Personal Data

3/ Purpose of Processing

4/ Legal Basis

• 1/ Contact and Inquiry Information

2/ Name, email address, phone number, and any message or query you submit through our contact form.

3/ To respond to your inquiries, provide information about our services, manage communications, and facilitate the services or quotes you request.

4/ Performance of a contract (providing requested services) and legitimate interest (communicating with you)

• 1/ Account, Order, and Transaction Data

2/ Name, billing or shipping address, payment details, and order history (if you engage our services or make a purchase).

3/ To create and manage your account (if any), process orders and payments, fulfill service agreements, and maintain financial and tax records.

4/ Performance of a contract (providing and billing for services) and compliance with legal obligations (financial and tax accounting)

• 1/ Technical and Usage Data

2/ IP address, device and browser information, operating system, pages viewed, time stamps, and other analytics or log data from your use of our site.

3/ To analyze how visitors use the website, improve our site and services, customize content, and protect against abuse or security threats.

4/ Legitimate interests (improving website performance, analytics, and security)

We do not collect sensitive personal data (such as health, religious, or biometric information). If you provide content that includes other individuals, you should ensure you have their permission to share it with us.

5. How We Collect Your Data

• Directly from You: When you fill out our Contact Us form, subscribe to our newsletter, request a quote, place an order, or communicate with us by email or phone, we collect the information you provide (for example, your name, email address, phone number, company name, address, and details of your request).

• Automatically through the Website: Our website is hosted on Google Sites, which may automatically collect certain technical and usage data during your visit (such as IP address, browser type, operating system, device information, and usage metrics). This data is collected and processed by Google, not by us. We do not access, control, or use this information. For more information, please refer to Google’s Cookie Policy.

• 
  

• From Third Parties: We may receive personal data from third-party sources. For example, if you engage us via a partner platform or social media, we might collect information provided through those channels. We may also use publicly available information (such as LinkedIn profiles) for outreach to potential clients.

6. Purposes of Processing

We use the personal data we collect for the following purposes:

• Providing and Managing Services: We use your data to respond to inquiries, deliver the video production or educational services you request, manage ongoing projects, and provide customer support. This includes scheduling, performing editing/post-production, and delivering final video content. (Legal basis: performance of a contract and legitimate interest.)

• Communication: We use your contact information to correspond with you—such as replying to emails or phone calls—and to send important information related to our services. (Legal basis: legitimate interest in maintaining communication about your request or project.)

• Marketing and Promotions: With your explicit consent, we may use your email address or phone number to send newsletters, updates, or promotional offers about our services. You can opt in or opt out of marketing communications at any time. (Legal basis: consent.)

• Website Analytics and Improvement: Our website is hosted on Google Sites, which may collect technical and usage data (such as IP address, device and browser type, time spent on pages, etc.) during your visit. This data is collected and processed by Google in accordance with their own privacy and cookie policies. We do not access, store, or analyze this information ourselves. (Legal basis: legitimate interest of the platform provider.)

• Legal and Regulatory Compliance: We may use and retain personal data as necessary to comply with legal obligations (for example, keeping transaction records for tax purposes, or responding to lawful requests from authorities). (Legal basis: compliance with a legal obligation.)

You provide personal data to us voluntarily when requesting services or communicating. If you do not provide certain information (like contact details), we may be unable to respond to your inquiry or fulfill your request.

7. Cookies and Similar Technologies

We do not use cookies or similar tracking technologies ourselves on this website, nor do we have the ability to control or configure them. Our website is built using Google Sites, a platform provided by Google LLC.

Any cookies that may be stored during your visit are placed and managed by Google, and may include cookies related to security, preferences, performance, or analytics. These cookies operate under Google’s own technologies and policies.

We encourage you to review Google’s Cookie Policy for more information on how these cookies are used and how you can manage them: https://policies.google.com/technologies/cookies

Please note: we do not collect, access, or process any cookie data ourselves, and we do not use this data for our own analytics or marketing purposes.

8. Data Sharing and International Transfers

We may share your personal data with the following recipients:

• Service Providers: We engage third-party companies to perform services on our behalf (for example, hosting providers, email delivery services, payment processors, analytics services, and marketing platforms). These vendors process data only on our instruction and are contractually obliged to maintain its confidentiality and security. For instance, we use Google Forms and Google Sites (Google LLC) to host our website and contact form, and Google Analytics for web analytics.

• Business Partners: With your consent, we may share data with trusted business partners for joint marketing activities or combined service offerings. We will only do this if you have agreed.

• Legal and Regulatory Authorities: We may disclose personal data to government or legal authorities if required by law or to protect our legal rights (for example, in response to a subpoena or court order).

No Sale of Personal Data: We do not sell or rent your personal data to third parties.

9. International Data Transfers

Your personal data may be transferred to or processed in countries outside the European Economic Area (EEA), including the United States. For example, our website infrastructure (Google Sites and Google Forms) and analytics (Google Analytics) involve data processing by Google in various countries. When we transfer data internationally, we implement appropriate safeguards to protect your information, such as:

• Transferring data only to countries for which the European Commission has issued an adequacy decision.

• Using Standard Contractual Clauses (SCCs) approved by the EU to legally transfer data to recipients outside the EEA.

• Relying on other approved mechanisms (such as the EU-US Data Privacy Framework for transfers to the United States, where applicable) to ensure an adequate level of protection.

We require all our partners and service providers to apply at least the same level of protection to your data as we do under this policy and applicable law.

10. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes described above and to comply with our legal obligations. Our retention periods depend on the type of data and its use. Examples include:

• Contact and Inquiry Data: We keep information you submit (via contact form or email) for as long as needed to respond to your request and for a reasonable period afterward (typically up to 2 years, unless we have a continuing relationship with you).
  
  

• Orders and Transactions: If you enter into a service agreement with us, we retain necessary personal and billing information for the duration of the contract and thereafter for as long as required by financial, tax, or statutory obligations (for example, up to 7–10 years for accounting records).

• Project Media Content: We keep media (video, audio, images) and related materials for the duration of the project and as needed to provide our services. After project completion, we may archive or delete these materials in accordance with our contracts and industry practices (typically within 3–5 years), unless you request their earlier deletion and no legal requirement prevents it.

• Analytics Data: Data collected via web analytics is retained according to the default retention settings of the service (e.g. Google Analytics retains data for up to 26 months). We regularly purge or anonymize old analytics data.

• Marketing and Communication Records: Records of your consent or opt-out for marketing purposes are kept until revoked or no longer needed for legal compliance.

When personal data is no longer needed, we will securely delete it or anonymize it so that it cannot be linked back to you.

11. Security of Your Data

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. For example:

• We use encryption (HTTPS) for data transmitted between you and our website.

• We store data on secure servers with access controls and firewalls.

• Access to personal data is restricted to authorized staff and service providers who need it to perform their duties.

• Our employees and contractors receive training on data protection and are bound by confidentiality obligations.

Although we strive to protect your data, please note that no method of transmission or storage is 100% secure. We cannot guarantee absolute security, but we regularly review our security measures and follow industry best practices to safeguard your information.

12. Your Rights

Under the GDPR and other applicable data protection laws, you have the following rights concerning your personal data:

• Right of Access: You can ask us to confirm whether we are processing your personal data and request a copy of your data.

• Right to Rectification: If your personal data is inaccurate or incomplete, you can request that we correct or complete it.

• Right to Erasure (“Right to be Forgotten”): You can ask us to delete your personal data in certain circumstances (for example, if it is no longer needed for its original purpose and we have no overriding legal obligations to retain it).

• Right to Restrict Processing: You can ask us to restrict our processing of your data in specific situations (for example, if you contest the accuracy of the data or object to processing).

• Right to Object: You can object to our processing of your data when it is based on legitimate interests (for example, you can opt out of direct marketing or analytics tracking).

• Right to Data Portability: You can request a copy of your personal data in a structured, commonly used format (if processing is based on your consent or a contract and done by automated means) and transfer it to another controller.

• Right to Withdraw Consent: When processing is based on your consent (such as for marketing communications), you can withdraw your consent at any time by contacting us or using the opt-out options provided in our messages. For cookies that may be set via our website (hosted on Google Sites), we do not control their placement or processing. However, you can manage or withdraw your cookie consent through your browser settings or by following the instructions in Google’s Cookie Policy.

• Right to Lodge a Complaint: If you believe that we have processed your data unlawfully, you have the right to file a complaint with your local data protection supervisory authority (for example, in the EU country where you reside).

To exercise any of these rights, please contact us using the details in the Contact Us section below. We will respond to your request as required by law, typically within one month of receipt.

13. Children’s Privacy

We do not knowingly collect personal data from children. If we become aware that a child has provided us with personal data, we will delete it as soon as possible. If you are a parent or guardian and believe your child has given us personal data, please contact us to request deletion.

14. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our data practices or applicable laws. When we do, we will revise the Effective Date at the top of this policy. If we make significant changes, we will provide a prominent notice (for example, via our website or email). We encourage you to review this policy periodically to stay informed about how we protect your information.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

• Email: info@2nd.studio

• Contact Form: Use the “Contact Us” form on our website to send us a message.

We strive to respond to all inquiries regarding privacy within a reasonable timeframe. Thank you for trusting 2ND.STUDIO with your personal information.

If you are not satisfied with how we have handled your personal data or privacy concerns, you have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens):

Autoriteit Persoonsgegevens
Postbus 93374
2509 AJ DEN HAAG
Telephone: (+31) (0)70 888 85 00
Website: https://autoriteitpersoonsgegevens.nl/en