Privacy policy

If you only read one section, read this one. The rest of the document expands on what's here.

The shorter the list, the better. We've worked hard to keep it short.

We collect data to do six things — nothing more.

• Run the cinema — stream films, store your watchlist, render your portfolio.
• Pay people — distribute investor returns, pay creator royalties, file taxes.
• Comply with law — Reg CF investor caps, AML/KYC, DMCA, tax reporting.
• Make recommendations — suggest films you might like, based on what you've watched. Off by default for unauthenticated viewing.
• Improve the product — aggregate analytics on what features get used, what films get watched. Always pseudonymized.
• Email you — receipts, distribution statements, security alerts (always); product news (only if you opt in).

What we use AI for

We use machine learning for film recommendations, search ranking, automated content classification (NSFW detection, copyright matching), and abuse moderation. We don't train third-party AI models on your private data, and we don't use the contents of your private messages to train anything.

Cinema is run by a small team and a short list of vendors who help us operate. We share data with them only when necessary, only the minimum, and only under contract.

Stripe

Card and ACH processing for investor purchases and creator payouts. Receives payment details. Subject to PCI-DSS.

Plaid

Bank account verification for investors. Receives account credentials transiently; we never see them.

Persona

Identity verification (KYC) for investors. Receives ID documents and selfie. Cinema receives a pass/fail and a hash.

AWS / Cloudflare

Hosting, video delivery, DDoS protection. Sees encrypted payloads in transit, encrypted-at-rest in storage.

Postmark

Transactional email delivery. Receives email addresses and message bodies for the emails we send you.

Funding portal

Our SEC-registered Reg CF partner. Receives investor identity and order details to operate the offering.

Tax authorities

The IRS and applicable state agencies, as required by law. 1099-DIV, 1099-NEC.

Law enforcement

When compelled by valid legal process. We push back where we can; we publish a transparency report annually.

We do not share data with advertisers, data brokers, or AI training data resellers.

A short list of things you might worry about, and our standing position on each.

• We will not sell your personal data, watch history, or contact information.
• We will not let advertisers track you across the web. There is no Cinema pixel on third-party sites.
• We will not train AI on your private messages, your support tickets, or content marked private.
• We will not require account creation to watch films.
• We will not build a shadow profile of you if you choose not to log in.
• We will not retain investor KYC documents longer than the law requires (5 years post-relationship).
• We will not read your DMs, except where required to investigate a specific abuse report.

Different data ages out at different rates. Here's how each category behaves.

Wherever you are, these are available. If you live in California, the EU, the UK, Brazil, or any jurisdiction with a data-rights regime, the same controls apply — we don't run a separate menu by region.

We use the smallest set of cookies the law allows. None are advertising cookies.

Strictly necessary

Session cookies for keeping you signed in. CSRF tokens. These can't be disabled without breaking the site.

Functional

Player quality preference, last position, theme preference. Stored device-local. You can clear at will.

Analytics

First-party, self-hosted, IP-anonymized. Off by default for visitors who send a Global Privacy Control signal. We do not use Google Analytics.

Advertising

None. We don't run ad-tracking cookies.

Cinema is not directed to children under 13. We don't knowingly collect data from anyone under 13. If you're a parent and believe we have your child's data, write to us at privacy@cinema.example and we'll delete it.

Account creation requires age 16+. Investing requires age 18+. Creator uploads require age 18+ and tax-form completion.

Cinema is operated from the U.S. If you are outside the U.S., your data is processed in the U.S. We rely on Standard Contractual Clauses for transfers from the EEA, UK, and Switzerland, and on equivalent mechanisms for other jurisdictions.

Investing is currently U.S.-only. Watching is global.

We encrypt data in transit (TLS 1.3) and at rest (AES-256). Passwords are stored as Argon2id hashes. We run continuous vulnerability scanning and an external security audit annually. Two-factor authentication is available; we encourage you to enable it.

If we ever experience a breach affecting you, we will notify you within 72 hours of confirming impact, in plain language, with what was exposed and what we're doing about it.

Report vulnerabilities to security@cinema.example. We pay bounties for responsible disclosure.

Material changes to this policy will be announced by email and a banner in the Service at least 14 days before they take effect. Minor edits (typos, clarifications) are made in place. The full version history is published at the bottom of this page on request.

Privacy questions go to a human, not a bot.

Privacy team

privacy@cinema.example · Replies within 5 business days.

Data Protection Officer

R. Alvarado · dpo@cinema.example

EU representative

Schenkenberg & Sahla, Berlin · cinema-eu@s-s-law.example

Mailing

Cinema Cooperative, Inc.
Privacy Office
2100 Mission Street, Suite 4
San Francisco, CA 94110