Privacy Policy

1. Introduction and Overview.

This Privacy Policy describes SHVKTI FILMS LLC (“SHVKTI” “we,” “our,” or “us”) collects, uses, and shares information about you, and applies to your use of any website, mobile application, or online service location that posts a link to this Privacy Policy, including but not limited to our websites at,,,, and,,,, (each, a “Site”), and all applications, features, content, and other services that we own, control and make available to you (collectively, with the Sites, the “Services”). If you are an employee or contractor, your personal information collected in those contexts will be subject to a separate privacy notice that we provide to you where and when appropriate.
For purposes of applicable data protection laws, SHVKTI FILMS LLC is the data controller with regard to the data processing described below. You can contact our data protection officer

2. What Information We Collect.
We and our agents, vendors, consultants, and other service providers (collectively, “Service Providers”) collect the following categories of personal information, depending on your interactions with us:
* Identifiers and contact information, such as your name, address, phone number, IP address, email address, and SHVKTI account username and password;
* Payment information, such as your credit card number, expiration date, card verification number, and billing address, if you make a purchase on the Sites; This is considered sensitive personal information and may be subject to additional privacy rights, as described more fully below;
* Demographics and characteristics of protected classifications, such as zip code, age, and gender;
* Purchase, viewership, and preference information, such as the films, shows, podcasts, articles, and content that you search for or view and the details thereof, and the products and items that you browse, bid on, add to your cart, buy, or return;
* Internet or other electronic network activity information when you visit the Sites or interact with our emails or online ads and content. For example, we use tracking tools like cookies and pixels to automatically collect information like device identifiers, the type of browser and operating system you are using, your browsing and search history on the Sites, what areas of the Sites you visit and for how long, what products or content you view and click on, what website you came from to get to us and what website you go to when you leave us, and your interactions with our digital ads and content on other websites. We also embed web beacons (also known as pixels) in the emails we send to you to help us understand how you interact with those messages, such as whether and when you opened an email or clicked on any content within the email;
* Location: We collect your general location via pixels when you interact with our Site.
* Professional or employment-related information if you apply for a job, such as your resume/CV, work history, social/professional networking pages, and any other info you choose to submit with your job application. And if you engage with us in a business-to-business capacity on behalf of your employer, we will collect professional information about you, such as your employer name, job title, your business contact information, and records of our business correspondence and transactions with you;
* Sensitive personal information: If you create an account with us, we will collect and store your SHVKTI login credentials. If you make a purchase on the Sites, we will collect your payment card number and billing information.
* Social media information: If you use your login credentials from a social media service in connection with our Sites, we may receive information from or send information to that service in accordance with its terms and privacy policy and your preferences and settings. We also use social widgets (which are buttons or icons provided by third-party social media providers) that allow you to interact with social media services when you view a webpage or mobile app screen. These social widgets collect browsing data.
* Inferences drawn from any of the above information to create a profile about you; and
* Other information that you consent to us collecting from time to time.
3. How We Use Your Information.
We may use personal information (including sensitive personal information) about you for any purposes consistent with this Privacy Policy or as permitted by applicable law, including to:
* Manage our Sites and Services, including your registration and account;
* Process and facilitate your transactions, including purchases made through our online stores and auctions;
* Provide access to free and/or purchased downloads and other similar content;
* Customize your browsing and shopping experience on the Sites;
* Respond to your comments, questions, and requests, and to provide customer service;
* Send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages;
* Prevent and address fraud, breach of policies or terms, and threats or harm;
* Monitor and analyze trends, usage, and activities;
* Conduct research, including focus groups and surveys;
* Improve the Sites, Services, or other SHVKTI applications, marketing efforts, products and services;
* Tailor and serve advertisements to you, and to send you marketing communications regarding our products, services, offers, promotions, rewards and events we think you may be interested in (for information about how to manage these communications and marketing efforts, please see “Your Choices” below);
* Evaluate applications for employment and other employment-related purposes;
* Verify or authenticate your identity in relation to requests you make or communications you send;
* Comply with legal obligations;
* If you engage with us in a business-to-business capacity on behalf of your employer, in addition to the above, we also use your personal information to administer and manage our relationship with you and your employer (such as record keeping, payments, communicating with you, tracking outcomes, and verifying your eligibility and suitability); and
* Fulfill any other purpose disclosed at the time you provide personal information.
We will not use information we’ve collected from you for purposes that are materially different, unrelated, or incompatible with this Privacy Policy without providing you with prior notice. Information that has been deidentified or aggregated is not subject to this Privacy Policy, and we and our Service Providers may use it without obligation to you except as prohibited by applicable law.
4. We Collect Information About You From Various Sources.
We collect and receive information about you from various sources, both indirectly and directly:
* Information you provide directly to us. For example, we collect information when you register an account, make a purchase, sign up for our newsletter, access our content, or otherwise communicate or transact with us through the Sites and Services, or engage with us on behalf of your employer.
* Information collected automatically from your devices. We and our Service Providers use tracking tools like browser cookies, beacons, and pixels to automatically collect information about you when you interact with our Sites and Services, including when you view or click on our digital ads and emails that we send to you.
* Information collected on our behalf by Service Providers. We hire Service Providers to help us operate our business. Service Providers may host or maintain our Sites, provide cloud services, send emails, assist with customer support

, provide market research or analytics, assist in order fulfillment, collect or publish customer reviews, or process payments. In performing such activities on our behalf, those Service Providers collect information about you.
* Information provided by other users. We may receive information about you from other users and individuals, for instance if someone gifts you a SHVKTI membership or if someone gifts you a pass to our Screening Room service.
* Information provided by other parties. We work with other business partners, marketing partners, foundations, data brokers, social media platforms, exhibitors (such as movie theaters and streaming platforms), and other Third Party Services (as defined below) that may give us information about you. If you are a job applicant, we may get information about you from background check providers and job references (such as past employers). When we get information from other sources, we may combine that in a database with information we already have.
5. We Share and Disclose Your Information.
We share your personal information, including in some cases your sensitive personal information. Depending on the circumstances, we can share your personal information with the following parties:
* With our Service Providers who host or maintain our Sites, provide cloud services, send emails, assist with customer support, provide market research or analytics, assist in order fulfillment, collect or publish customer reviews, or process payments. We share information with those Service Providers in order for them to perform the activities listed above in Section 3 at our instruction or on our behalf (in which case they will handle personal information in the capacity of data processors or service providers under applicable data protection law); Please note that these Service Providers will directly collect, or receive from SHVKTI, sensitive personal information as necessary for them to process payments, verify your username and password when logging into a SHVKTI account, or conduct background checks on job applicants;
* With our affiliates. We may share information with other brands within the SHVKTI ownership structure, and future ownership, To be determined. 
* With our business partners. For instance, we may share information with organizations with whom we jointly sell or co-brand merchandise, with whom we run a joint promotion, with whom we collaborate on ticketed events (such as virtual screening rooms or in-person screenings), distributors of our content (such as movie theaters and streaming platforms), or organizations who are the beneficiary of auction proceeds.
* With marketing companies and social media platforms. We share information with companies that help us in our marketing efforts, including social media platforms, ad servers, advertising networks, and adtech platforms. This includes allowing select marketing companies to place their own cookies or other tracking tools on our Sites to track your activities across time and services, so that they may tailor and serve ads to you based on your activities (“Interest-based Advertising”). The information collected and stored by these marketing companies remains subject to their own policies and practices. For further information on tracking technologies and your choices regarding them, please see “Your Choices” below;
* With third parties in relation to the sweepstakes, contests, surveys, and other promotions that we run from time to time, either by ourselves or jointly with another organization. If you voluntarily choose to enter such a promotion, we will disclose your personal information to third parties for administrative purposes and as required by law (e.g., by publishing your information as part of a legally required winners list, if you win), and we may share your information with a co-sponsor;
* With law enforcement, government bodies, and other officials as required to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements;
* With other parties as reasonably necessary to protect the rights, property, life, health, security and safety of us, the Sites, the Services or any third party, including to enforce our policies;
* With other companies (including their and our advisors) in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another company;
* With other third parties we describe to you at the time you provide your personal information, for the limited purposes we disclose at such time; and
* With other third parties at your express consent or at your direction.
Without limiting the foregoing, in our sole discretion, we may share aggregated information which does not identify you, or deidentified information about you, with third parties for any purpose.
Additionally, certain areas of the Sites and Services are designed to help you share information with the public and other users, such as public comment sections or other interactive features. If you choose to make information public through the Sites or Services, other users will have access to it. We cannot guarantee that the information you make public through the Sites or Services will remain protected in accordance with this Privacy Policy. Please think carefully before making information public. You are solely responsible for information you make public.

6. Third Party Services, Features, and Devices.

Our Sites and Services contain content from and hyperlinks to websites, locations, platforms, and services operated and owned by third parties (“Third Party Services”), such as social network sites. In addition, the Sites and Services contain features that allow you to interact with, connect to, or access the Sites and Services through Third Party Services and third party devices (“Third Party Features”). For example, you interact with a Third Party Service when you “like” or “share” content over social media through our Services, or when you purchase merchandise from our Site. Remember that third parties may use their own tracking tools to independently collect information about you, and may solicit personal information from you. Also, if you use a Third Party Feature, both we and the applicable third party may have access to and use information associated with your use of the Third Party Feature.

  1. Your Choices.

A. Marketing Communications.

You can opt out of receiving promotional e-mails from us at any time by following the instructions in the e-mails to click on the unsubscribe link, or by sending an e-mail to us at, with the word UNSUBSCRIBE in the subject field of the e-mail. Please note that your opt out is limited to the e-mail address used and will not affect subsequent subscriptions or non-promotional communications, such as those about your account, transactions, servicing, or SHVKTI’s ongoing business relations. You can opt out of receiving text messages from us at any time by responding STOP to any text message we send you.

B. Our "Do Not Track" Policy.

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is currently no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms. For more information on “Do Not Track,” visit

C. Cookies, Analytics, and Advertising Tracking Tools.

As disclosed in Section 2 and Section 4 above, we and our partners automatically collect information about your devices and online interactions using tracking technologies like cookies, pixels, and web beacons, across time and across different platforms.

We use Google Analytics to provide us with information about how you interact with the Sites and Services, so that we may customize and improve them for you. You may exercise choices regarding the use of cookies from Google Analytics by going to or downloading the Google Analytics Opt-out Browser Add-on.

We and our partners engage in interest-based advertising by using tracking tools to understand your online interactions over time and across different platforms in order to serve advertisements that are more tailored to your interests. To opt-out of tracking for interest-based advertising purposes from participating companies, visit both the Digital Advertising Alliance WebChoices tool at and the Network Advertising Initiative opt-out at Please be aware that even if you opt out of interest-based advertising, you will continue to receive online ads.

Options you select and choices you make are browser-, website-, and device-specific. If you clear your cookies, you will need to set your preferences again.

  1. Your Privacy Rights.

8.1 United States Privacy Rights.

California’s “Shine the Light” law permits consumers in California to request certain details about how their personal information is shared with third parties for those third parties’ own direct marketing purposes, one time per year. SHVKTI may share your personal information with third parties for their own direct marketing purposes. If you are a California resident and wish to obtain information about our compliance with this law, please e-mail us at, or send us a letter to SHVKTI (Attn: Legal), 1245 Broadway, 10th Floor, New York, New York, 10001. Requests should include “Shine the Light Request” in the email subject line or the first line of the letter, and should include your name, street address, city, state, and ZIP code. Also, any California residents under the age of eighteen (18) who have registered to use the Services and who have posted content or information on the Sites or Services can request that such information be removed by sending an e-mail to Requests must state that the user personally posted such content or information, and detail where the content or information is posted. We will make reasonable good faith efforts to remove the post from prospective public view.

In addition, where provided for by applicable United States federal or state privacy laws, you may be entitled to exercise some or all of the rights described below with respect to your personal information:

  • Access / Right to Know: You have the right to confirm whether we process personal information about you and to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. You have the right to know: (i) the categories of personal information we collected about you (including sensitive personal information); (ii) the categories of sources for the personal information we collected about you; (iii) the categories of personal information we sold or disclosed, (iv) our business or commercial purpose for collecting and selling that personal information; (v) the categories of third parties with whom we shared your personal information; (v) a portable copy of the specific pieces of personal information we have collected about you; and (vi) information about the logic involved in any automated decision-making processes used by SHVKTI (if any), as well as a description of the likely outcome of the process with respect to you (if applicable).

  • Right to Correct or Update: You have the right to request that we correct, update, or modify the personal information we maintain about you.

  • Right to Delete: You have the right to request that we delete any of your personal information that we maintain about you, subject to certain exceptions permitted by US privacy laws (such as if the information is necessary to complete a transaction or to retain pursuant to legal obligations).

  • Right to Opt-Out of Automated Decision-Making: You have the right to request to opt-out of any profiling or automated decision-making (however, only to the extent we engage in such automated processing activities).

  • Do Not Sell My Personal Information or Share My Personal Information for Behavioral Advertising: You can opt-out of the “sale” and “sharing” of your personal information by clicking this Do Not Sell or Share My Personal Information link, or by using an opt-out preference signal or universal opt-out mechanism on a supported browser. Your selections are specific to the device, website, and browser you are using, so you should make your selections on every device and browser you use to access this website. Your selections are also deleted whenever you clear your browser’s cache.

  • Limit the Use of my Sensitive Personal Information: In relation to any sensitive personal information identified in Section 2 above, you can request that we limit our use and sharing of such information only to those uses which are necessary to carry out our relationship with you (such as providing our goods and services that you’ve requested, maintaining the quality of our services, or protecting our services against illegal activity), or as otherwise described in relevant privacy laws.

We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. If you are not satisfied with the outcome of your request and would like to request further review, you may send an email to with "Personal Information Requests Appeal" in the subject line.

As noted earlier, if you are an employee or contractor, your rights with respect to your personal information collected in the employment context will be described in a separate privacy notice that we provide to you where and when appropriate. We will not discriminate against you for exercising any of your U.S. privacy rights, such as by denying you goods or services, charging you a different price or rates for goods or services, or providing you a different level of quality of goods or service.

How to Exercise Your United States Privacy Rights

Eligible individuals may request to exercise their privacy rights by submitting a request to us by either emailing us at or sending a letter to SHVKTI (Attn: Privacy), 1245 Broadway, 10th Floor, New York, New York, 10001, or clicking the “Do Not Sell or Share My Personal Information” link at the bottom of this webpage.

We will take reasonable steps to verify your identity prior to responding to your requests. The verification steps may vary depending on the sensitivity of the personal information and whether you have an account with us.

You can designate an authorized agent to make a request on your behalf by following the same steps described above. But when submitting the request, please ensure the authorized agent identifies himself / herself / itself as an authorized agent.

8.2. European Privacy Rights.

This Section of our Privacy Policy applies solely to visitors and users who are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”). For the purpose of EEA and UK data protection laws, SHVKTI FILMS LLC acts as controller in connection with the personal information described in this Privacy Policy.

Legal Basis for Processing

We process personal information on the following bases:

  • Consent – when you opt-in to receive cookies or otherwise provide consent for marketing and other data processing. You have the right to withdraw your consent, or to refrain from granting your consent. You are under no statutory or contractual requirement or obligation to provide personal information to us via our Sites.

  • Contract – when you make a purchase or participate in our events or programming, we need to process your personal information in order to perform that contract.

  • Legitimate interests – when processing your personal information is necessary in furtherance of our legitimate interests and isn’t outweighed by your data protection rights.

  • Compliance with a legal obligation – when we are subject to a legal obligation and need to process your personal information to comply with that obligation.

Your Privacy Rights under European Law

If you are located in the EEA or the UK, you have the following rights in relation to your personal information:

  • Right of access – you have the right to obtain confirmation as to whether or not we are processing personal information about you, and, if so, to request access to the personal information, including the categories of personal information, the sources of personal information, the purposes of processing, and the recipients or categories of recipients.

  • Right to rectification – you have the right to request the correction of inaccurate or incomplete personal information about you.

  • Right to erasure – you have the right to request that we delete personal information about you, subject to certain exceptions under applicable law.

  • Right to restrict processing – you have the right to request that we restrict our processing of personal information about you, subject to certain exceptions under applicable law.

  • Right to data portability – you have the right to receive the personal information you have provided to us, in a structured, commonly used and machine-readable format, and to transmit that information to another data controller, subject to certain exceptions under applicable law.

  • Right to object to processing – you have the right to object to our processing of personal information about you, including for direct marketing purposes, and to object to automated decision-making (including profiling), and where we have justified our processing of your personal information on the basis of a legitimate interest, you have the right to object to our processing on that basis.

  • Right to withdraw consent – where our processing of personal information about you is based solely on your consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of our processing based on consent before its withdrawal.

To exercise any of your rights under European law, please send an email to with “GDPR Request” in the subject line.

We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. If you are not satisfied with the outcome of your request and would like to request further review, you may send an email to with “GDPR Request Appeal” in the subject line.

  1. Data Security.

We implement and maintain reasonable security procedures and practices to protect against the unauthorized access, use, modification, destruction or disclosure of your personal information. However, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us at

  1. Data Retention.

We retain personal information for as long as we reasonably require it for legal or business purposes. For example, we may retain personal information for longer periods of time if doing so is required by law or necessary to assist with a legal proceeding or process, to enforce our agreements, policies, or terms, to resolve disputes, to protect our assets, users, or individuals, or for tax, accounting, and financial reporting purposes. Otherwise, we will delete or de-identify personal information once we no longer need it for the purposes for which it was collected, unless we are required to retain it in order to comply with applicable legal, regulatory, tax, accounting or other reporting requirements.

  1. International Data Transfers.

SHVKTI is based in the United States and personal information we collect from you will be processed in the United States. The United States has not sought, nor received, a finding of “adequacy” from the European Union under Article 45 of the GDPR. SHVKTI relies on derogations for specific situations as set forth in Article 49 of the GDPR, including, where applicable, your consent to the transfer of personal information to the United States.

  1. Changes to Our Privacy Policy.

We may change this Privacy Policy from time to time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on our Sites. We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you. Your continued use of our Sites and Services following the posting of changes to this Privacy Policy constitutes your acceptance of such changes.

  1. Contact Us.

If you have questions or concerns regarding this Privacy Policy, our privacy practices, or would like to exercise your privacy rights, please contact us at or by mail at SHVKTI (Attn: Privacy), 548 MARKET ST #566229 SAN FRANCISCO, CA 94104