# Privacy Policy

**Last Updated:** January 12, 2026

## 1. Introduction
Welcome to the privacy policy of **Commotion Agency Ltd** ("we", "us", or "our").

We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or engage our services, and tell you about your privacy rights and how the law protects you.

## 2. Important Information and Who We Are

### Controller
**Commotion Agency Ltd** is the controller and responsible for your personal data.

### Contact Details
If you have any questions about this privacy policy, please contact us using the details below:

* **Full name of legal entity:** Commotion Agency Ltd
* **Email address:** hello@commotion.agency
* **Postal address:** Old Stock Exchange, St. Nicholas Street, Bristol, BS1 1TG, United Kingdom.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

## 3. The Data We Collect About You
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

* **Identity Data:** Includes first name, last name, username or similar identifier, and title.
* **Contact Data:** Includes billing address, delivery address, email address and telephone numbers.
* **Financial Data:** Includes bank account and payment card details (processed securely via third-party providers).
* **Transaction Data:** Includes details about payments to and from you and other details of services you have purchased from us.
* **Technical Data:** Includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform on the devices you use to access this website.
* **Usage Data:** Includes information about how you use our website and services (e.g., viewing our showreel, submitting forms).

## 4. How Is Your Personal Data Collected?
We use different methods to collect data from and about you including through:

* **Direct interactions:** You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
   * Enquire about our services;
   * Subscribe to our publications;
   * Request marketing to be sent to you.
* **Automated technologies or interactions:** As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies (including Google Analytics).

## 5. How We Use Your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

* **Performance of Contract:** Where we need to perform the contract we are about to enter into or have entered into with you (e.g., producing a video project).
* **Legitimate Interest:** Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (e.g., keeping our records updated, studying how customers use our services to develop them).
* **Legal Obligation:** Where we need to comply with a legal or regulatory obligation.

## 6. Cookies and Third-Party Links
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and allows us to improve our site.

**Third-Party Analytics:**
We use **Google Analytics (GA4)** and other tracking technologies to measure traffic and usage trends. These tools collect information sent by your device or our Service, including the web pages you visit, add-ons, and other information that assists us in improving the Service.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

## 7. Disclosures of Your Personal Data
We may have to share your personal data with the parties set out below for the purposes set out in paragraph 5 above.

* **Service Providers:** Acting as processors who provide IT and system administration services (e.g., Google Workspace, Bunny.net for video hosting, Cloud storage).
* **Professional Advisers:** Acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
* **HM Revenue & Customs:** Regulators and other authorities based in the UK who require reporting of processing activities in certain circumstances.

## 8. International Transfers
We share your personal data within the Commotion Agency Ltd group. Whenever we transfer your personal data out of the UK or the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

* We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
* Where we use certain service providers, we may use specific contracts approved for use in the UK/EEA which give personal data the same protection it has in the UK/EEA.

## 9. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.

## 10. Data Retention
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

## 11. Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the right to:

* Request access to your personal data.
* Request correction of your personal data.
* Request erasure of your personal data.
* Object to processing of your personal data.
* Request restriction of processing your personal data.
* Request transfer of your personal data.
* Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us at **hello@commotion.agency**.

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