Privacy Policy




This is the data protection policy of Windmill Lane Pictures Ltd (company number 324306) (“Windmill Lane”, “we”, “our” and “us”), of 29 Herbert Street, Dublin 2, Ireland.  This policy covers any personal data which Windmill Lane processes, as a data controller.  This may include: individuals that visit our website, (the “Site”); from and/or about contractors; people who apply to work with us, or submit a CV and/or covering letter to us; and current and former customers (“you” and “your”).  This policy explains: who we are; how and why we collect or receive your personal data; how and why we process your personal data and your data protection rights.

If you wish to contact us about the information in this policy, about how we collect, receive and use your personal data or to exercise your data protection rights please use the contact details provided in the Contact Us section below.


Our commitment

Windmill Lane is a controller of the personal data we collect, receive and hold about you which means we are responsible for deciding how we hold and why we use your personal data.  Processing of personal data includes collecting; recording; storing; altering; disclosing; destroying; and blocking.  Our role as controller under applicable data protection legislation requires us to provide you with certain information about what we do with your personal data and your data protection rights.  We are committed to complying with our legal obligations in this regard and are dedicated to protecting all personal data we hold ensuring such personal data is only used for the purpose(s) for which we collect or receive them.  Windmill Lane collects and receives personal data in a variety of circumstances which are set out in Section 6 – Why we process your data.


Whose personal data do we collect or receive?

The type of personal data received and used by us depends upon whether you are:

  • A Visitor to the Site.
  • A Customer: any person that is our prospective, current and/or former customer and any person working with or representing  prospective, current and former customers on behalf of or through a legal entity.
  • A Contractor: any person that we have, are or may engage with, to carry out services on our behalf and any person working on behalf of or through a legal entity that provides their services to us.
  • Job Applicants: any person who applies to work with us, or submits a CV and/or covering letter to us.


What personal data do we collect or receive?

We process the following categories of personal data:

  • Identity Data: such as first name, surname, job title; personal data contained in social media profiles; and personal data contained in job applications, CVs and/or covering letters you provide to us which may include your employment history, your salary, your education and other qualifications and details about your eligibility to work.
  • Contact Data: such as postal and email addresses, telephone and mobile phone numbers.
  • Financial Data: where you are a Customer or Contractor we may process financial information such as bank account details, financial transaction details; PPS number; VAT number (for sole traders); information about payments to and from you; and details of services you purchase from us.    
  • Technical Data: such as internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system.  
  • Usage Data: such as information about how you use the Site.
  • Marketing Communications Data: such as your preferences in relation to receiving marketing materials from us and your communication preferences.


How we collect or receive your personal data

We normally obtain personal data directly from you.  In certain circumstances, it will, however, be necessary to obtain data from third parties such as credit reference agencies, previous employers or social media platforms.  We may collect personal data from public sources such as press or websites.

As you interact with the Site, we collect Technical Data and Usage Data.  We collect this data by using cookies and other similar technologies.  Please see our website cookie policy at for information about how we use cookies on the Site.

You are responsible for ensuring that you inform us of any changes to your personal data, e.g. change of address, contact or banking details where we have obtained the personal data from you.  We endeavour to ensure personal data held by us is up to date and accurate. 


Why we process your personal data

Windmill Lane processes your personal data for the following reasons:

  1. Identity, Contact and Financial Data for our legitimate business activities including production, creative and business purposes. 
  2. Identity, Contact and Financial Data to provide services in accordance with agreements made with you or Customers.
  3. Identity and Contact Data of Job Applicants for our legitimate interests (for running our business, to assess suitability of candidates, and hiring qualified and appropriate persons).
  4. Technical and Usage Data to improve and develop the quality, functionality and user experience of our services and the Site.
  5. Identity, Contact and Financial Data to comply with our legal obligations including performing our obligations in any contract we have agreed with you.
  6. Identity, Contact and Marketing Communications Data to provide you with marketing communications about us and our services if you have opted in to such communications, or where you are an existing Customer of Windmill Lane, have provided us with your personal data or received a marketing communication from us in the past 12 months, and have not opted out of receiving such communications, for our legitimate interests in promoting our business.
  7. Where there is a need to collect personal data for another purpose, we will inform you of this at the time of or prior to the processing. 


Sharing your personal data

During the course of its business, Windmill Lane may be required to share personal data with third parties for the purposes described in Section 6 above.  These third parties may include suppliers, agents, financial institutions and sub-contractors.  

In order to comply with legal obligations Windmill Lane may share personal data with regulating authorities such as Revenue Commissioners or the Department of Employment Affairs and Social Protection.  

Windmill Lane may also share your personal data with the following third party service providers:

  1. financial service providers such as lending institutions; 
  2. storage and back-up providers such as Google, or offsite storage facilities; and 
  3. email subscription service providers such as Google.


Sharing your personal data in other countries

Your personal data may be transferred, stored and accessed within the European Economic Area (“EEA”) or transferred to, stored in, and accessed from countries outside the EEA in order to fulfil the purposes described in this policy.  For transfers to countries outside the EEA, the data protection regime may be different than in the country in which you are located and will therefore be based on a legally adequate transfer method.  Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is given to it by ensuring at least one of the following safeguards is implemented: 

  • Where the country has been deemed to provide an adequate level of protection for personal data by the European Commission.  
  • We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.  
  • Where service providers are based in the US, we may transfer data to them if they are part of the EU-U.S. Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.  

We will provide you on request a list of the countries located outside the EEA to which personal data may be transferred, and an indication of whether they have been determined by the European Commission to grant adequate protection to personal data.  Where applicable, you are entitled, upon request to receive a copy of the relevant safeguard (for example, EC model contractual clauses) that have been taken to protect personal data during such transfer.


Retention of personal data

Windmill Lane is under a legal obligation to keep certain personal data for a specified period of time.  In addition, Windmill Lane may need to keep personal data for a period of time in order to protect its legitimate interests.  We are committed to retaining personal data only for the period of time necessary for which it was originally required.  In particular, we keep the following personal data for the following periods:

  • CVs received from unsuccessful job applicants, or unsolicited CVs: no longer than 12 months after we receive them unless you have requested that we retain for a longer specified period.


Security and disclosure of personal data 

Windmill Lane will take all reasonable steps to ensure that appropriate security measures are in place to protect the confidentiality of both electronic and physically stored personal data.  Security measures that are in place will be reviewed from time to time.  All of our third party processors have obligations to be responsible and implement all organisational security policies and procedures to ensure the security of personal data that they process on our behalf.  However, no entity can keep personal data 100% secure.  If you have reason to believe that any of your personal data is no longer secure, please notify us immediately using the Contact Us information below.

This policy does not address, and we are not responsible for, the privacy, information or other practices of any third-party website, including any third party operating any website to which the Site contains a link.  The inclusion of a link on the Site does not imply endorsement of the linked website by us.  When you leave the Site, we encourage you to read the privacy notice of every website you visit.


Your Data Protection Rights

You have the right, subject to some conditions and limited exceptions under data protection legislation to: 

  1. Request access to your personal data.  This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  2. Request correction of the personal data that we hold about you.  This enables you to have any incomplete or inaccurate personal data we hold about you corrected.
  3. Request erasure of your personal data.  This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.  You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.  Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 
  4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.  You also have the right to object where we are processing your personal data for direct marketing purposes.  In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  5. Request restriction of processing of your personal data.  This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the personal data’s accuracy; (b) where our use of the personal data is unlawful but you do not want us to erase it; (c) where you need us to hold the personal data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your personal data but we need to verify whether we have overriding legitimate grounds to use it. 
  6. Request the transfer of your personal data to you or to a third party.  We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format.  This right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Changes to this Policy

This policy will be reviewed and reissued on the Site from time to time to take into account changes in the law and the experience of the policy in practice.


Contact Us

If you have any queries regarding this policy or if you wish to exercise your data protection rights please contact  

You also have the right to make a complaint at any time to the Data Protection Commission and its contact details are available at  

This policy was last modified on 7th June 2019