Definitions
In this Privacy Policy, the following terms shall have the meanings set out below, unless the context otherwise requires:
| Term | Meaning |
|---|---|
| “Personal Data” | Any information relating to an identified or identifiable natural person (“Data Principal” under Indian law; “Data Subject” under GDPR). This includes, without limitation, name, email address, IP address, device identifiers, photographs, voice recordings, and video footage. |
| “Processing” | Any operation performed on Personal Data, whether by automated or manual means, including collection, recording, organisation, structuring, storage, adaptation, retrieval, consultation, use, disclosure, dissemination, alignment, restriction, erasure, or destruction. |
| “Services” | All professional services offered by the Company, including but not limited to: Video Production, Audio Production, Graphic Designing, Branding & Identity, Film / Web Series Production, 360° IMC Campaigns, AI Automations, Digital Marketing, and Campaign Execution & Promotion. |
| “Website” | The website located at www.abodhitreemedia.com and all its sub-pages, including the contact form, portfolio section, and any landing pages operated by the Company. |
| “Talent” | Any individual who appears in, performs in, or contributes creatively to a production, including actors, voiceover artists, presenters, musicians, models, and other performers. |
| “Service Agreement” | Any separate written agreement between the Company and a Client governing a specific service engagement, including proposals, statements of work, and production agreements. |
Data Controller & Contact Information
A Bodhi Tree Media is the data controller (referred to as “Data Fiduciary” under the Digital Personal Data Protection Act, 2023 of India) responsible for the Personal Data processed through this Website and in connection with our Services.
| Detail | Information |
|---|---|
| Entity Name | A Bodhi Tree Media |
| Registered Office (India) | 71, Jal Enclave, Silver Spring Phase 1, Indore, Madhya Pradesh, India — 452020 |
| UK Office | 116 Little Nights, Leys Court, Pegrum Drive, Napsbury Park, St Albans — AL2 1FB, United Kingdom |
| Additional Offices | Delhi, India · Pune, India (operational offices; no public postal address) |
| info@abodhitreemedia.com | |
| Telephone (India) | +91 96047 55555 |
| CEO & Founder | Dr Shahaji Shovakar |
| Grievance Officer / DPO | Reachable at info@abodhitreemedia.com |
We shall acknowledge and respond to any privacy-related enquiry or data subject request within thirty (30) calendar days of receipt, or within such shorter period as may be mandated under applicable law (e.g., one calendar month under UK GDPR / EU GDPR).
Information We Collect
3.1 Information You Provide Directly via the Website
When you submit our “Send us a message” contact form, the Website collects the following fields:
- Full Name
- Email Address
- Service Needed (selected from: Video Production, Audio Production, Graphic Designing, Branding & Identity, Film / Web Series, 360° IMC Campaign, AI Automations, or Digital Marketing)
- Message (free-text field containing your project details, enquiry, or any other information you choose to provide)
We do not collect your telephone number, postal address, or payment information through the Website contact form. If you contact us directly by email or telephone, we will collect whatever information you provide during that communication.
3.2 Information Collected Automatically
When you access our Website, the following data may be collected automatically through cookies, server logs, and similar technologies:
- Device Data: IP address, browser type and version, operating system, device type, screen resolution, language preference.
- Usage Data: Pages viewed, time spent on pages, click paths, referring URL, exit pages, scroll depth, interaction with portfolio video thumbnails.
- Location Data: Approximate geographic location inferred from your IP address (city/region level only).
- Cookie Data: Data collected via cookies and similar tracking technologies as detailed in Section 6 and our Cookie Policy.
3.3 Information Arising from Service Engagements
When you engage us for Services under a Service Agreement, we may additionally collect:
- Contractual Data: Company name, job title, billing address, GST/VAT numbers, bank details for invoice processing, and correspondence exchanged during the engagement.
- Production Data: Scripts, storyboards, brand guidelines, creative assets, location details, and other materials you provide for the performance of Services.
- Talent / Performer Data: Names, photographs, voice recordings, video footage, biographical information, and professional credentials of Talent involved in productions.
- Release & Consent Records: Signed talent release forms, model releases, location releases, and records of consent for use of image, likeness, and voice.
3.4 Information from Third-Party Sources
We may receive information about you from social media platforms (Instagram, LinkedIn, YouTube) where you engage with our content, from analytics providers (such as Google Analytics), from advertising networks, from casting or talent agencies, or from our Client organisations — only to the extent permitted under applicable law.
Sensitive Personal Data: We do not intentionally collect special category or sensitive Personal Data (such as racial or ethnic origin, political opinions, religious beliefs, biometric data, health information, or sexual orientation) through our Website. In the context of productions, where health and safety information is necessary (e.g., medical conditions relevant to on-set safety), we collect such data only with explicit consent and process it solely for that specified purpose.
Purposes & Use of Your Information
| Purpose | Categories of Data Used |
|---|---|
| Responding to your enquiries submitted via the Website contact form | Full Name, Email, Service Needed, Message |
| Providing, managing, and delivering our Services under a Service Agreement | Contractual Data, Production Data, Talent Data |
| Managing productions (casting, scheduling, crew coordination, post-production) | Talent Data, Production Data, Contact details |
| Exercising and licensing intellectual property rights in production outputs as authorised by applicable agreements and talent releases | Talent Data, Release & Consent Records |
| Displaying our portfolio, showreels, case studies, and celebrity collaboration references on the Website and marketing channels | Talent Data, Production Data |
| Sending service-related administrative communications (project updates, invoices, delivery confirmations) | Full Name, Email, Contractual Data |
| Sending marketing communications, newsletters, or promotional materials (only with your prior explicit consent where required by law) | Full Name, Email |
| Operating, maintaining, and improving the Website (analytics, performance monitoring, troubleshooting) | Device Data, Usage Data, Cookie Data |
| Ensuring Website security, preventing fraud, and detecting abuse | Device Data, Usage Data, Location Data |
| Complying with applicable legal and regulatory obligations, and responding to lawful requests from authorities | All categories as necessary |
We shall not use your Personal Data for any purpose materially different from those listed above without providing you with prior notice and, where required by law, obtaining your consent.
Legal Basis for Processing
5.1 Indian Law (DPDP Act, 2023 & IT Act, 2000)
- Consent: Where you have given clear, informed, and affirmative consent for a specified purpose.
- Certain Legitimate Uses: As permitted under the DPDP Act, 2023, including performance of contractual obligations, compliance with Indian law, and the protection of vital interests.
5.2 UK GDPR (UK General Data Protection Regulation, as retained under the European Union (Withdrawal) Act 2018, supplemented by the Data Protection Act 2018)
For individuals located in the United Kingdom:
- Consent (Article 6(1)(a)): Marketing communications, non-essential cookies, and use of image/likeness beyond contractual necessity.
- Contract (Article 6(1)(b)): Where processing is necessary to perform a contract with you or take pre-contractual steps at your request.
- Legitimate Interests (Article 6(1)(f)): Website analytics, security, portfolio display, service improvement — where not overridden by your rights.
- Legal Obligation (Article 6(1)(c)): Where required under UK law, including tax, employment, health & safety, and intellectual property legislation.
5.3 EU GDPR
For individuals in the European Economic Area or Switzerland, the same lawful bases as Section 5.2 apply, under the EU General Data Protection Regulation (Regulation (EU) 2016/679).
5.4 CCPA / CPRA (California, USA)
If you are a California resident, we process your personal information in accordance with the California Consumer Privacy Act (as amended by CPRA). We do not “sell” or “share” your personal information as those terms are defined under the CCPA/CPRA. For your California-specific rights, see Section 10.3.
Cookies & Tracking Technologies
Our Website uses cookies and similar tracking technologies. For full details — including the specific cookies in use, their categories, purposes, durations, and your choices — please refer to our dedicated Cookie Policy.
Where required by applicable law (including the UK Privacy and Electronic Communications Regulations 2003 (PECR), the EU ePrivacy Directive (Directive 2002/58/EC as amended), and the DPDP Act, 2023), we obtain your prior opt-in consent before placing non-essential cookies on your device.
Data Sharing & Disclosure
We do not sell, rent, lease, or trade your Personal Data. We disclose it only in the following limited circumstances:
7.1 Service Providers & Data Processors
We engage third-party service providers who process Personal Data on our behalf and under our documented instructions, including:
- Cloud hosting and infrastructure providers
- Email delivery services
- Analytics platforms (e.g., Google Analytics)
- Website development and maintenance provider (Clepto.io, which built and maintains this Website)
- Payment processors and accounting software providers
- Video hosting platforms (e.g., YouTube, Vimeo)
- Project management and collaboration tools
All processors are contractually bound to process data only on our instructions, maintain appropriate security measures, and comply with applicable data protection law. Where required, we have executed data processing agreements (DPAs) or equivalent contractual provisions.
7.2 Production Partners, Co-Producers & Clients
Where a production is commissioned by or co-produced with a Client, broadcaster, OTT platform, or advertising agency, we may share production-related Personal Data (including Talent data) with such parties to the extent necessary for the production and as authorised under the applicable Service Agreement or production agreement. Clients’ own privacy practices govern their subsequent use of such data.
7.3 Professional Advisors
Legal counsel, auditors, accountants, tax advisors, and insurers — where necessary for managing risks, obtaining professional advice, or establishing, exercising, or defending legal claims.
7.4 Legal & Regulatory Compliance
We may disclose Personal Data where required by law, regulation, court order, or governmental request — including under the Information Technology Act, 2000, the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, the UK Data Protection Act 2018, or by competent law enforcement or regulatory authorities in any applicable jurisdiction.
7.5 Business Transfers
In the event of a merger, acquisition, reorganisation, insolvency, or asset sale, your Personal Data may be transferred as part of that transaction. We will provide prior notice where practicable and ensure the receiving entity is bound by obligations at least as protective as this Policy.
7.6 With Your Consent
In any other circumstance, we will share your data only with your specific, informed consent.
No Sale of Personal Data: A Bodhi Tree Media does not sell your Personal Data to any third party for monetary or other valuable consideration. This commitment applies globally, including under the CCPA/CPRA definitions of “sale” and “sharing.”
International Data Transfers
A Bodhi Tree Media operates from India (Indore, Delhi, Pune) and the United Kingdom (St Albans) and serves clients globally. Your Personal Data may be transferred to, stored in, and processed in countries outside your country of residence.
8.1 Transfers from the UK / EEA
Where Personal Data originating in the UK or EEA is transferred to India or other countries not subject to an adequacy decision, we implement appropriate safeguards, including:
- UK International Data Transfer Agreement (IDTA) or the UK Addendum to EU Standard Contractual Clauses, as required under the UK GDPR.
- EU Standard Contractual Clauses (SCCs) as adopted by the European Commission (Commission Implementing Decision (EU) 2021/914).
- Adequacy decisions, where available.
8.2 Transfers from India
We comply with the Digital Personal Data Protection Act, 2023, including any restrictions the Central Government may notify regarding transfers to specified jurisdictions.
You may request a copy of the relevant transfer safeguards by contacting us.
Data Retention
We retain Personal Data only for as long as reasonably necessary to fulfil the purposes described in this Policy. Specific retention periods:
| Data Category | Retention Period |
|---|---|
| Website contact form submissions | Up to 24 months from submission, or longer if the enquiry leads to a Service engagement |
| Client engagement / contractual records | Duration of the engagement + 6 years (to cover limitation periods under Indian and UK law) |
| Production deliverables (final films, videos, audio, designs) | In perpetuity, or for the licence period stipulated in the applicable Service Agreement / talent release — whichever is longer |
| Raw footage, outtakes, and production working files | Up to 7 years from delivery of the final deliverable, unless a longer period is agreed or required |
| Talent release forms and consent records | Duration of the licence granted + 7 years, or as required to evidence lawful use |
| Financial and tax records (India) | 8 years (as required under the Income Tax Act, 1961, and GST legislation) |
| Financial and tax records (UK) | 6 years (as required by HMRC and the Companies Act 2006) |
| Analytics and cookie data | As specified in our Cookie Policy (typically 14–26 months for Google Analytics) |
Upon expiry, we securely delete or irreversibly anonymise your data. Anonymised data (from which you cannot be identified) is no longer Personal Data and may be retained indefinitely for statistical or analytical purposes.
Your Rights
10.1 Rights Available to All Individuals
- Access: Request confirmation of whether we process your data and obtain a copy.
- Correction / Rectification: Request correction of inaccurate or incomplete data.
- Deletion / Erasure: Request deletion of your data, subject to legal exceptions (ongoing contracts, statutory retention, rights under talent releases).
- Withdraw Consent: Where processing is based on consent, withdraw at any time — without affecting the lawfulness of processing prior to withdrawal.
10.2 Additional Rights — UK GDPR / EU GDPR
- Restriction of Processing: In certain circumstances.
- Data Portability: Receive your data in a structured, commonly used, machine-readable format.
- Object to Processing: Based on legitimate interests, or for direct marketing.
- Automated Decision-Making: Right not to be subject to decisions based solely on automated processing producing legal or similarly significant effects.
- Lodge a Complaint: With the Information Commissioner’s Office (ICO) in the UK (ico.org.uk) or the relevant DPA in your EU Member State.
10.3 Additional Rights — CCPA / CPRA (California Residents)
- Right to Know: Categories and specific pieces of personal information collected.
- Right to Delete.
- Right to Opt-Out of Sale/Sharing: We do not sell or share. You may submit a request for confirmation.
- Right to Non-Discrimination for exercising your rights.
- Right to Correct inaccurate personal information.
- Right to Limit Use of Sensitive Personal Information (if applicable).
10.4 Rights under DPDP Act, 2023 (India)
- Right to information about processing.
- Right to correction and erasure.
- Right of grievance redressal.
- Right to nominate another individual to exercise rights in case of death or incapacity.
How to Exercise Your Rights: Email info@abodhitreemedia.com with the subject line “Data Subject Request — [Your Right].” We may verify your identity before processing. Response within 30 days or the shorter statutory period. Manifestly unfounded, excessive, or repetitive requests may be subject to a reasonable fee or refusal, as permitted by law.
Data Security
We implement appropriate technical and organisational measures proportionate to the sensitivity of the data and the risks of Processing, including:
- SSL/TLS encryption for all data transmitted between your browser and our Website.
- Role-based access controls and multi-factor authentication for internal systems and production storage.
- Encrypted storage for production assets, client deliverables, and contractual records.
- Regular security assessments and vulnerability scanning.
- Confidentiality obligations binding all employees, contractors, freelancers, and Talent with access to Personal Data.
- Secure physical storage of production equipment and physical media.
- Documented incident response and breach notification procedures.
No transmission method or storage system is 100% secure. In the event of a Personal Data breach, we will notify the affected individuals and the relevant supervisory authorities within the timeframes prescribed by applicable law (72 hours under UK GDPR; as prescribed under the DPDP Act, 2023 upon rules being notified).
Children’s Privacy
Our Website is not directed at individuals under the age of eighteen (18). We do not knowingly collect Personal Data from children through the Website.
In production contexts, where a minor (under 18) participates as Talent, we collect and process their data only with verifiable consent from a parent or legal guardian, in compliance with applicable child protection legislation including the Child and Adolescent Labour (Prohibition and Regulation) Act, 1986 (India), the Children and Young Persons Act 1933 (UK), and any applicable state-level regulations. On-set safeguards, including licensed chaperones, are maintained as required.
If you believe a child’s data has been collected without proper consent, please contact us immediately at info@abodhitreemedia.com.
Production, Talent & Celebrity Data — Special Provisions
13.1 Celebrity & Talent Images on the Website
Our Website displays photographs, names, video thumbnails (sourced from YouTube), and descriptions of celebrities, public figures, athletes, politicians, musicians, and other personalities with whom A Bodhi Tree Media has collaborated over its history since 2010. This content is displayed:
- Pursuant to production agreements, talent releases, or contractual arrangements authorising such use; and/or
- For the legitimate purpose of showcasing our professional portfolio and credentials; and/or
- Under applicable fair dealing provisions (Section 52 of the Indian Copyright Act, 1957) and fair use principles.
The appearance of any celebrity, public figure, or individual on this Website does not constitute or imply their personal endorsement of A Bodhi Tree Media or any of its Services, unless a formal endorsement agreement exists and is expressly stated.
13.2 YouTube Video Thumbnails
Our portfolio section displays video thumbnails sourced from YouTube (img.youtube.com). These are static images and do not constitute YouTube iframe embeds that auto-load YouTube cookies. However, if you click on a portfolio item and are redirected to YouTube, Google/YouTube will collect data in accordance with Google’s Privacy Policy.
13.3 Self-Hosted Video Content
Certain sections of our Website feature self-hosted video files (e.g., background hero video and about-us video). These videos are served directly from our servers and do not involve third-party tracking or cookies. Standard server logs (IP address, request timestamp) may be generated when these videos are loaded.
13.4 Requests from Individuals Featured on the Website
If you are a person (or the authorised representative of a person) whose image, likeness, name, or voice appears on our Website and you wish to exercise any right under data protection law, personality rights, or publicity rights, please contact us at info@abodhitreemedia.com. We will address your request promptly and in good faith.
Third-Party Links & Embedded Content
Our Website contains hyperlinks to third-party websites and social media profiles (including Instagram, LinkedIn, and YouTube) for our team members and collaborators. This Privacy Policy applies solely to Personal Data collected by A Bodhi Tree Media through our Website. We have no control over, and assume no responsibility for, the privacy practices of third-party sites or platforms.
The inclusion of a link does not imply endorsement or affiliation with the linked site or its operators. We recommend reviewing the privacy policy of every external website you visit.
Changes to This Privacy Policy
We may update this Policy to reflect changes in our practices, legal requirements, or operational needs. When we make material changes:
- We will update the “Last Updated” date above.
- Where practicable, we will post a prominent notice on our Website.
- Where required by law, we will obtain your renewed consent.
Continued use of the Website after changes are posted constitutes acknowledgement. Where continued use does not constitute valid consent under applicable law, we will seek consent through appropriate means.
Grievance Redressal & Supervisory Authorities
In accordance with the Information Technology Act, 2000, the IT (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, and the DPDP Act, 2023:
| Detail | Information |
|---|---|
| Designation | Grievance Officer / Data Protection Officer |
| info@abodhitreemedia.com | |
| Telephone | +91 96047 55555 |
| Response Time | Within 30 days of receipt of complaint |
If you are not satisfied with our response, you may escalate to:
- India: The Data Protection Board of India (once constituted under the DPDP Act, 2023).
- United Kingdom: The Information Commissioner’s Office (ICO) — ico.org.uk · Tel: 0303 123 1113.
- EU Member States: The relevant national Data Protection Authority.
- California: The California Attorney General — oag.ca.gov/privacy.
Governing Law & Dispute Resolution
This Privacy Policy shall be governed by and construed in accordance with the laws of India. Any dispute arising out of or in connection with this Policy shall be subject to the exclusive jurisdiction of the courts at Indore, Madhya Pradesh, India, subject to the following:
- For individuals in the United Kingdom, nothing herein limits your right to bring proceedings before the courts of England and Wales (or Scotland or Northern Ireland, as applicable to your domicile), or to lodge a complaint with the ICO.
- For individuals in the EU or any jurisdiction with mandatory consumer protection or data protection law, nothing herein restricts your right to bring proceedings in the courts of your habitual residence or to lodge a complaint with your local supervisory authority.