Privacy Policy

1. Introduction & Data Controller

Welcome to 2rahen Media & Entertainment Inc. ("2rahen Media", "Company", "we", "us", or "our"). We are committed to safeguarding the privacy and fundamental data rights of visitors, users, content partners, and creators who interact with our websites, mini-programs, mobile applications, and digital media distributions (collectively, the "Services").

For the purposes of the EU General Data Protection Regulation (Regulation (EU) 2016/679 - "GDPR"), the UK Data Protection Act 2018 ("UK GDPR"), and the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA/CPRA"), the Data Controller responsible for your personal information is:

2rahen Media & Entertainment Inc.
Attn: Data Protection Officer (DPO)
10250 Constellation Blvd, Suite 1400, Los Angeles, CA 90067, United States
Email: privacy@2rahen.com / legal@2rahen.com

2. Categories of Information We Collect

We collect personal information in several ways depending on how you engage with our Services:

2.1 Information You Voluntarily Provide

• Contact & Identity Data: Your first and last name, business email address, company name, phone number, and physical mailing address when submitting inquiries or entering creator representation agreements.
• Partnership & Casting Data: Casting portfolios, audition clips, headshots, SAG-AFTRA membership status, and professional resumes submitted for production considerations.
• Commercial & Transaction Data: Banking coordinates, tax identification (e.g., US W-8BEN/W-9 or EU VAT IDs) for creator royalty disbursements and license settlement.

2.2 Information Automatically Collected

• Device & Technical Telemetry: IP address, browser type and version, time zone setting, operating system, platform, device identifiers, and network connection parameters.
• Usage & Interaction Analytics: Pages viewed, video watch durations, completion rates, click-through paths, referring URLs, and timestamps.

2.3 Information from Third Parties & Platforms

When you engage with our media content via third-party digital platforms (such as TikTok, YouTube, Meta, Snapchat, or external streaming stores), we receive aggregated audience telemetry, referral attribution parameters, and anonymized engagement insights compliant with respective platform APIs.

3. Legal Bases for Processing (GDPR & UK GDPR)

We process your personal information only when lawful justifications exist under Article 6 of the GDPR:

• Consent (Art. 6(1)(a)): Where you have granted explicit consent for specific processing, such as non-essential marketing cookies or promotional communications.
• Performance of a Contract (Art. 6(1)(b)): To execute licensing contracts, talent agreements, and fulfill distribution obligations.
• Legitimate Interests (Art. 6(1)(f)): To enhance service stability, prevent fraud, measure content performance, and defend our legal claims, provided such interests do not override your privacy rights.
• Legal Obligations (Art. 6(1)(c)): To comply with statutory tax reporting, intellectual property licensing audits, and law enforcement requests.

4. Tracking Technologies & Cookies

We utilize essential session cookies, performance cookies, and analytical pixels. You can control your preferences at any time through our interactive Cookie Consent Center. We do not engage in unauthorized cross-context behavioral tracking without consent.

5. How We Share & Disclose Information

We do not sell, rent, or trade your personal data to third-party data brokers. Disclosures are limited to:

• Authorized Service Providers: Cloud infrastructure (Cloudflare, AWS), audience analytics, legal counsel, and secure enterprise communications.
• Distribution Partners: Aggregated, non-identifiable demographic and performance metrics shared with streaming platforms.
• Corporate Restructuring: In the event of a merger, acquisition, or asset divestiture, subject to strict non-disclosure obligations.
• Regulatory & Legal Compulsion: When required by court order, subpoena, or to uphold our Terms of Service.

6. International Data Transfers

As a global media enterprise operating across the United States, Europe, and Asia, information we collect may be transferred to and processed outside of your country of residence.

For transfers from the European Economic Area (EEA) and the UK to countries not deemed to offer an adequate level of data protection by the European Commission, we rely on standard contractual clauses (SCCs) approved by the European Commission or equivalent UK safeguards, coupled with technical encryption safeguards.

7. Your Privacy Rights

7.1 Rights for European (EEA / UK) Individuals

Under Chapter III of the GDPR, you are entitled to:

• Right of Access: Request a copy of the personal data we maintain about you.
• Right to Rectification: Request correction of inaccurate or incomplete records.
• Right to Erasure ("Right to be Forgotten"): Request deletion of your personal information where no overriding legal basis persists.
• Right to Restriction & Objection: Object to processing grounded in legitimate interests or direct marketing.
• Right to Data Portability: Receive your data in a structured, commonly used, machine-readable format.
• Right to Lodge a Complaint: File a grievance with your local supervisory authority (e.g., the UK ICO or EU Data Protection Authorities).

7.2 California Privacy Rights (CCPA / CPRA Notice)

California residents hold specific statutory rights under California Civil Code §§ 1798.100 et seq.:

• Notice at Collection: The categories of personal information collected in the preceding 12 months.
• Right to Know & Delete: Request specific pieces of personal information collected and prompt deletion thereof.
• No "Sale" of Personal Information: We do not sell your personal information or share personal data for cross-context behavioral advertising for monetary consideration.
• Non-Discrimination: We will not discriminate against you in pricing, service quality, or access for exercising any California privacy right.

8. Protection of Children (COPPA & GDPR-K)

Our Services are strictly directed toward individuals aged 16 and older (or 13 where applicable under local regulations). We do not knowingly collect or solicit personal data from children under these age thresholds. If we discover inadvertent receipt of such data, it will be deleted immediately.

9. Data Retention & Security Architecture

We retain personal records only for the duration necessary to satisfy the purposes outlined in this Policy, or as mandated by legal, tax, and regulatory compliance periods. We maintain enterprise-grade physical, technical, and administrative protections, including TLS 1.3 cryptographic transit protocols and least-privilege role-based access control.

10. Revisions to this Privacy Policy

We may modify this Privacy Policy periodically to reflect technological advancements, legal evolutions, or shifts in our business operations. Material revisions will be accompanied by prominent notifications on our homepage and updated Effective Date timestamps.