Privacy policy

Privacy Policy - Modem Studios
Effective Date: 01.05.2026

1. Introduction
This Privacy Policy explains how Modem Studios (“we”, “us”, or “our”) collects, uses, and protects personal data in connection with our website and our creative, strategic, and technology-driven activities.

Modem Studios operates as a creative and venture studio, working with creators and brands to develop digital communities, applications, products, and campaigns.

Modem Studios is a trading name of Pence Talent Ltd., which acts as the data controller for the purposes of applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR).

2. Data Controller

The data controller responsible for your personal data is:

Pence Talent Ltd.
Email: talent@pencetalent.com
Address: Perk Accounting, 31 Cattle Market St, Norwich NR1 3DY, United Kingdom

3. Scope of This Policy

This policy applies to personal data relating to:
● Visitors to the Modem Studios website
● Clients and prospective clients
● Creators, collaborators, and partners
● Individuals featured in, or contributing to, content and productions
● Individuals submitting information for casting, collaboration, or opportunities
● Users or contributors involved in digital communities, platforms, or products we help develop
● Individuals who contact us


4. Categories of Personal Data

We may collect and process the following categories of personal data:

4.1 Contact and communication data
● Name, email address, and other contact details
● Information submitted via contact forms
● Correspondence and communications

4.2 Professional and creator data
● CVs, portfolios, social media profiles, and creative work
● Creator performance data and audience insights
● Information submitted for collaborations, partnerships, or opportunities

4.3 Project, product, and platform data
● Client briefs and strategic information
● Campaign and marketing data
● Product and app development information
● Community and audience engagement data (where applicable)
● Contributor and partner details
● Contracts and agreements
● Project timelines, deliverables, and feedback

4.4 Creative content and media
● Video, photography, and audio recordings
● Content created for digital platforms, campaigns, or products
● Visual and editorial content featuring identifiable individuals

4.5 Business and financial data
● Invoices and payment records
● Freelancer, creator, and supplier information

4.6 Website and technical data
● Information submitted via our website contact form
● Limited usage data (such as pages visited and interaction patterns)
● Data collected through cookies and similar technologies

We do not intentionally collect sensitive personal data unless required and agreed in the context of a specific project or product.

5. How We Collect Data

We collect personal data through:
● Website contact forms
● Direct communication (including email and messaging platforms)
● Creator and partner onboarding processes
● Casting, submissions, and collaboration outreach
● Client engagements and project work
● Development and operation of digital communities, platforms, and products
● Production activities, including filming and content creation
● Contracts and agreements
● Third party tools used for communication, storage, analytics, and workflow management
● Cookies and analytics technologies on our website

6. Purposes of Processing

We process personal data for the following purposes:

● Responding to enquiries and business opportunities
● Developing creative strategy and cross platform marketing campaigns
● Building and launching digital communities, applications, and products
● Collaborating with creators and brands on ventures and shared initiatives
● Supporting audience growth, retention, and engagement strategies
● Delivering user acquisition and sales optimisation activities
● Producing, managing, and distributing content across platforms
● Managing partnerships, contributors, and collaborators
● Reviewing and assessing submissions and opportunities
● Managing client relationships and communications
● Delivering project outputs and reporting
● Managing contracts, invoicing, and payments
● Showcasing work for portfolio, marketing, and promotional purposes
● Operating, maintaining, and improving our website, services, and products

7. Legal Basis for Processing

We rely on the following legal bases under UK GDPR:

7.1 Legitimate interests
● Operating and developing our studio, products, and ventures
● Collaborating with creators, clients, and partners
● Managing campaigns, communities, and digital platforms
● Promoting our services and showcasing work
● Improving performance, engagement, and user experience

7.2 Contract
● Performing obligations under agreements with creators, clients, and partners
● Developing and delivering products, campaigns, and services
● Managing commercial and venture relationships

7.3 Legal obligation
● Financial record keeping
● Compliance with tax and regulatory requirements

Where content features identifiable individuals, rights of use are typically governed by contracts, releases, or agreed permissions.

8. Cookies and Website Technologies

Our website uses cookies and similar technologies to:
● Ensure the proper functioning of the site
● Understand how visitors interact with the website
● Improve user experience

We may use analytics and behavioural tools such as Hotjar to analyse engagement patterns, including navigation behaviour, clicks, and scrolling. Users can manage or disable cookies through their browser settings.

9. Sharing of Personal Data
We do not sell personal data. We may share personal data where necessary with:
● Creators, brands, and commercial partners
● Clients and collaborators
● Contributors involved in campaigns, products, or productions
● Technology, analytics, and platform providers
● Service providers supporting operations (including storage, communication, and workflow tools)
● Professional advisers, including legal and accounting providers

This may include:
● Contact and coordination details
● Creator and audience insights (where relevant)
● Project materials, content, and deliverables
● Submissions, portfolios, and strategic materials

10. International Transfers
Personal data may be processed outside the United Kingdom where our service providers or platforms operate. Where this occurs, appropriate safeguards are implemented, including standard contractual clauses or equivalent protections.

11. Data Retention
We retain personal data only as long as necessary:
General enquiries: typically up to 12 months
Submissions and creator data: retained for a reasonable period for opportunity assessment and collaboration
Project, platform, and client data: for the duration of the relationship and a reasonable period thereafter
Financial and contractual records: as required by law

Content and materials may be retained for portfolio, product, or ongoing venture purposes where appropriate.

12. Data Security

We implement appropriate technical and organisational measures, including:
● Secure cloud-based storage systems
● Access controls and restricted permissions
● Multi factor authentication
● Secure handling of creative, product, and user-related data

13. Your Rights
Under UK data protection law, you have the right to:
● Access your personal data
● Request correction of inaccurate data
● Request deletion of your data
● Object to or restrict processing
● Request data portability
● Withdraw consent where applicable

To exercise your rights, contact: contact@modem-studios.com

14. Complaints
If you have concerns about how your personal data is handled, please contact us in the first instance. You also have the right to lodge a complaint with the Information Commissioner's Office.

15. Changes to This Policy
We may update this Privacy Policy from time to time. The latest version will always be available on our website.

16. Contact
For any privacy-related queries:
Email: contact@modem-studios.com