PRIVACY POLICY

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Last updated: December 15, 2025

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1. Controller

Unforgotten Films UG (haftungsbeschränkt) c/o Bon Capital GmbH Mönckebergstraße 19 20095 Hamburg Germany

Email: info@unforgotten-films.com

Managing Directors: Neil Steinberg, Conrad Bon (Managing Directors also serve as Data Protection Officers)

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2. Data We Collect

We collect the following personal data:

• Name

• Email address

• Mailing address

• IP address

• Payment information

• Age confirmation (18+)

• Newsletter subscription preferences

• Inquiry content and correspondence
   

3. How We Collect Data

We collect data when you:

• Purchase streaming access to documentaries

• Subscribe to our newsletter

• Submit contact forms or inquiries

• Visit our website (automatic collection via cookies and server logs)
   

4. Legal Basis for Processing

We process your data under:

• Contract performance (Article 6(1)(b) GDPR): Processing purchase orders and providing streaming access

• Legal obligation (Article 6(1)(c) GDPR): Tax and accounting record retention

• Consent (Article 6(1)(a) GDPR): Newsletter subscriptions, optional marketing communications

• Legitimate interest (Article 6(1)(f) GDPR): Website security, fraud prevention, technical operations
   

5. How We Use Your Data

• Process documentary purchases and grant streaming access

• Send transactional emails (order confirmations, access credentials)

• Send newsletters (with your consent)

• Respond to inquiries

• Analyze website traffic and improve user experience

• Comply with tax and accounting obligations

• Prevent fraud and maintain website security
   

6. Data Storage and Location

Our website is hosted by Wix.com Ltd. Data is stored on Amazon Web Services servers located in:

• Ireland (EU)

• United States

Data transferred to the United States is protected by:

• EU Standard Contractual Clauses

• Wix's GDPR compliance measures

• AWS's data processing agreements
   

7. Third-Party Services

Wix Platform Services:

• Wix Analytics (website usage analysis)

• Wix Contact Forms

• Wix Newsletter/Email Marketing

• Wix Payments (payment processing)

• Wix Video Player (streaming delivery)

Wix processes data as our processor under a data processing agreement. Wix's privacy policy: https://www.wix.com/about/privacy

Payment Processing:

Payment card data is processed directly by Wix Payments and payment service providers. We do not store complete credit card numbers on our servers.
 

8. Cookies

We use cookies for:

• Essential website functionality (session management, security)

• Analytics (visitor statistics, page views)

• Remembering your preferences

You can control cookies through your browser settings. Disabling certain cookies may limit website functionality.
 

9. Data Retention

We retain your data for the following periods:

• Purchase records and invoices: 10 years (German tax law requirement under §147 AO)

• Payment transaction records: 10 years (German commercial code requirement under §257 HGB)

• Newsletter subscribers: Until you unsubscribe, then deleted within 30 days

• Contact form inquiries: 3 years from last contact, then deleted

• Website logs and analytics: 26 months maximum

• Account data (if registered): Until account deletion requested, then deleted within 30 days (except records retained for legal obligations)

After these periods, we securely delete or anonymize your data unless longer retention is required by law.
 

10. Age Restriction

Our services require users to be 18 years or older. We ask for age confirmation during purchase. We do not knowingly collect data from persons under 18. If we learn we have collected data from someone under 18, we will delete it promptly.
 

11. Your Rights Under GDPR

You have the right to:

• Access: Request copies of your personal data (Article 15 GDPR)

• Rectification: Correct inaccurate data (Article 16 GDPR)

• Erasure: Request deletion of your data ("right to be forgotten") where no legal retention obligation exists (Article 17 GDPR)

• Restriction: Limit how we process your data (Article 18 GDPR)

• Data portability: Receive your data in machine-readable format (Article 20 GDPR)

• Object: Object to processing based on legitimate interests (Article 21 GDPR)

• Withdraw consent: Withdraw consent for newsletter or marketing at any time (does not affect prior lawful processing)

To exercise these rights, contact: info@unforgotten-films.com

We will respond within one month.
 

12. Newsletter

With your consent, we send newsletters about new documentaries and company updates. You can unsubscribe at any time using the link in each email or by contacting us. Unsubscribing does not affect transactional emails related to purchases.
 

13. Data Security

We implement technical and organizational measures to protect your data:

• Encrypted data transmission (SSL/TLS)

• Secure server infrastructure

• Access controls and authentication

• Regular security updates

No internet transmission is completely secure. We cannot guarantee absolute security but take reasonable precautions.
 

14. Data Sharing

We do not sell your data. We share data only with:

• Service providers processing data on our behalf (Wix, payment processors)

• Legal authorities when required by law

• Professional advisors under confidentiality obligations
   

15. Automated Decision-Making

We do not use automated decision-making or profiling that produces legal effects.
 

16. Right to Lodge Complaint

You have the right to lodge a complaint with a supervisory authority:

Hamburg Commissioner for Data Protection and Freedom of Information Ludwig-Erhard-Straße 22 20459 Hamburg Germany Phone: +49 40 42854-4040 Email: mailbox@datenschutz.hamburg.de
 

17. Changes to This Policy

We may update this privacy policy. We will post changes on this page with a new "Last updated" date. Continued use of our website after changes constitutes acceptance.
 

18. Contact

For questions about this privacy policy or data protection:

Email: info@unforgotten-films.com Address: Unforgotten Films UG, c/o Bon Capital GmbH, Mönckebergstraße 19, 20095 Hamburg