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Particle Productions Ltd - Privacy Policy

Who We Are

Particle Productions Ltd ("Particle6," "we," "us," "our") is an AI-driven content production company registered in England and Wales at 20 Vespasian Way, Dorchester, DT1 2RD, company number 07471362. We are registered with the UK Information Commissioner’s Office, registration reference ZB709816. This policy explains how we collect, use, and protect the personal data of our clients, prospective clients, partners, suppliers, website users and anyone else who emails, meets or otherwise interacts with us.

What Data We Collect

We may collect:

  • Contact and business details (name, role, company, email, phone) when you engage with us as a client, partner, supplier or subscriber

  • Invoicing and payment details

  • Communications you send us (emails, form submissions, meeting notes and transcripts)

  • Information you provide in the course of a production or project (briefs, creative assets, feedback)

  • Sign-in details for our client brief tool (see Section 10)

  • Where relevant to a project, biometric identifiers, voice recordings, or likeness data used in AI character or content generation, which may be special category data (see Section 8)

How We Use Your Data and Our Legal Basis
  • Delivering contracted production services — Legal basis: Performance of a contract

  • Invoicing, payments and financial record-keeping — Legal basis: Performance of a contract and legal obligation

  • Responding to enquiries and business development — Legal basis: Legitimate interests

  • Running our business with AI tools for email, meetings and documents (see Section 9) — Legal basis: Legitimate interests

  • Providing our client brief tool to invited users (see Section 10) — Legal basis: Legitimate interests (account data); on behalf of your organisation as controller (brief content)

  • Legal and regulatory compliance — Legal basis: Legal obligation

  • Use of voice, likeness, or biometric data in AI content creation — Legal basis: Explicit consent, obtained in writing

  • Sending newsletters or marketing communications you’ve opted into — Legal basis: Consent

How We Collect Data
  • Directly from you (contracts, briefs, emails, meetings)

  • Directly through online enquiry forms or newsletter subscription

  • From third parties (e.g., your organisation, referral partners) where relevant to delivering a project

  • From publicly available sources, such as company websites and professional networking sites, for business development

Data Retention

We retain personal data only for as long as necessary for the purposes for which it was collected. For client and project data, retention periods may be agreed on a project-by-project basis as part of our contractual terms, in addition to any minimum periods required by law.

Your Rights

Under UK GDPR, you have the right to:

  • Access the personal data we hold about you

  • Rectify inaccurate or incomplete data

  • Erasure (“right to be forgotten”), subject to legal exceptions

  • Restrict processing in certain circumstances

  • Data portability

  • Object to processing, including where we rely on legitimate interests and for direct marketing

  • Withdraw consent at any time where processing is based on consent (e.g., use of your voice or likeness, or email subscription to our newsletter)

To exercise any of these rights, contact us using the details in Section 15. We respond within one month and may need to verify your identity first.

If you have a concern about how we’ve handled your data, please contact us so we can try to resolve it directly. You also have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO) at ico.org.uk at any time.

Data Security

We apply appropriate technical and organisational measures, including encryption, access controls, and regular monitoring, to protect personal data from unauthorised access, loss, or misuse.

AI, Voice, and Likeness Data

Some engagements may involve processing biometric or likeness data, such as voice cloning or AI character generation. Where this applies, it is governed by separate written consent obtained at the point of engagement, and you may withdraw that consent at any time. Withdrawing consent does not affect processing already carried out, and may affect our ability to complete contracted work. To withdraw, contact us using the details in Section 15.

How We Use AI in Our Operations

AI is part of how we operate internally, not only how we make content. As part of your interactions with us, the following may be read or processed by AI:

  • Emails and attachments we send and receive

  • Transcripts and notes of meetings we hold, including video calls

  • Documents, contracts, briefs and messages shared with us or held in our systems

We use these tools to transcribe, summarise, search, draft and organise this material, so personal data of people who email or meet with us, including non-clients, may be processed by AI tools.

We do not use this material to train AI models, and we do not permit our providers to do so. Providers act under written terms limiting their use of data to providing the service, and we switch off training settings where a tool has one. Some providers keep data briefly for security and abuse monitoring before deleting it.

We tell participants at the start of any recorded or transcribed meeting. You can ask us not to record, or to delete a recording or transcript.

You can object under Section 6. AI-generated summaries and transcripts are kept in line with Section 5. A list of the AI tools and providers we use is available on request (see Section 15).

Client Brief Tool

brief.particle6.com is an invite-only AI chat that helps clients put together a video brief. This section applies in addition to the rest of this policy.

Users are invited by their organisation, which provides us with their email address. For email addresses and sign-in records we act as controller. For what users type, the PDFs they attach and the AI’s replies, we act on behalf of the user’s organisation, which decides how that content is used and whose privacy notice covers it. If you make a rights request about the content of a brief, we may pass it to your organisation.

The tool collects the email addresses of invited users, sign-in records, and what users type, including any PDFs they attach.

It stores email addresses and sign-in records, each finished brief (every version, as a PDF), the attached PDFs, the conversation (what users type and the AI’s replies), and who started each brief and when.

The following providers handle this data:

  • Supabase holds accounts, brief records, stored files, and conversations, in the EU (Ireland). Supabase Inc (US) may access them for support.

  • Vercel hosts the app and stores no content. 

  • Anthropic (Claude) reads typed text and PDF text to write the brief. It is not used for training and is kept for up to 30 days. Processing takes place in the US.

  • Resend sends the sign-in and notification emails, using the email address only. It operates in the EU (Ireland).

Transfers to the US are protected by the providers’ UK Addendum to the EU standard contractual clauses or the UK Extension to the EU-US Data Privacy Framework.

Within Particle6, our team can see stored files and each version of a brief. We do not routinely access the conversation.

Each stored file is deleted automatically one year after it was saved. Conversations are deleted one year after the brief was started. A brief record is deleted automatically once it’s a year old and its files and conversation are gone. Files and conversations can be deleted earlier on your organisation’s written request. Accounts are kept until the user is removed.

Users are told they are chatting with an AI and should check facts. The only browser storage used is a sign-in token.

Sharing Your Data

We share personal data only where necessary:

  • With vetted third-party service providers and AI platforms, under contracts requiring appropriate safeguards (full details available on request), including:

    • Audio-visual generative AI platforms

    • Cloud hosting and data storage providers

    • Payment processing providers

    • AI-assisted administrative and operational tools

    • Email and communication providers

  • Where required by law or regulatory authority

  • Where you have given explicit consent, obtained in writing

  • With our professional advisers, such as lawyers, accountants and insurers

International Data Transfers

Where personal data is transferred outside the UK or EEA, we ensure appropriate safeguards are in place. These include UK adequacy regulations (such as the UK Extension to the EU-US Data Privacy Framework), the UK International Data Transfer Agreement, and the UK Addendum to the EU Standard Contractual Clauses. You can request details of these safeguards using the contact details in Section 15.

Automated Decision-Making

We do not use your personal data for any automated decision-making that produces legal or similarly significant effects on you.

Changes to This Policy

We may update this policy from time to time. Material changes will be notified via our website or direct communication where appropriate.

Contact Us

For any questions about this policy or to exercise your rights, contact:

Email: privacy@particle6.com

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