Introduction

Eljin Productions, Inc. (“Eljin,” “we,” “us,” “our”) takes the security and privacy of your personal information seriously.

This Privacy Policy describes how we collect, use, share, and safeguard information about you when you use our Platform (https://eljininc.com and associated subdomains).

By accessing the Platform, you consent to the practices described below and agree that this Privacy Policy is incorporated into the Terms of Service.

1. Personal Information We Collect

We may collect and process the following types of information:

• Account and Profile Information: name, address, email, phone, tax ID or SSN, bank account details, union affiliation, and talent agency (if applicable).
• Transaction Data: payment instructions, project identifiers, ACH trace numbers, invoice data, and payment confirmations.
• Verification Data: government ID, date of birth, union membership verification, sanctions-screening results, and proof of authorization.
• Technical Data: IP address, browser type, device identifiers, and cookies/usage data.
• Communications Data: records of correspondence with Eljin (support tickets, compliance inquiries, etc.).

We may also collect or receive data from third-party service providers (e.g., ACH processors, KYC/AML verification vendors, or payment partners) to fulfill payment and compliance obligations.

2. How We Use Personal Information

We use your personal information to:

• Process payments, verify identity, and perform compliance checks;
• Communicate with you about transactions and account activity;
• Report and remit payments to unions (e.g., SAG-AFTRA, ACTRA) and applicable authorities;
• Prevent fraud and ensure legal and union compliance;
• Improve and secure our Platform; and
• Fulfill contractual, legal, and audit obligations.

Banking and payment data are processed in accordance with your ACH Registration Agreement.

We do not sell or rent personal information to third parties.

However, we may create, use, and share aggregated, de-identified, or anonymized information that does not identify any individual. Such information may be used for analytics, benchmarking, product development, or commercial purposes, including sale to or licensing by third parties.

Eljin will not attempt to re-identify such anonymized data, and will contractually require third parties to refrain from doing so.

3. How We Share Personal Information

We may disclose personal information:

• To financial institutions, ACH operators, and payment processors for transaction execution;
• To unions and their administrators for compliance reporting and payment remittance;
• To identity verification, KYC/AML, and sanctions screening providers;
• To cloud hosting, data analytics, and security vendors;
• To publishers, rights holders, or authorized signatories who initiated your project;
• To our affiliates or professional advisors in the normal course of business;
• In connection with a reorganization, merger, or sale; or
• As required by law or regulation.

Eljin stores and processes data using secure third-party cloud infrastructure providers (including AWS). These providers do not access your personal information except as required to operate the Platform, and their obligations to Eljin are governed by contract and law.

New: We maintain a current list of sub-processors, available upon request at legalnotices@eljininc.com.

4. Legal Bases for Processing (GDPR/UK Addendum)

If you are located in the European Economic Area or United Kingdom, we process your data under one or more of the following legal bases:

• Performance of a contract;
• Compliance with a legal obligation;
• Legitimate interests in providing and improving our services; or
• Your explicit consent.

For most processing activities, Eljin acts as a data controller; for payments initiated by Clients, Eljin may act as a data processor on their behalf.

5. Data Security

We implement reasonable and appropriate administrative, technical, and physical safeguards to protect your personal information. This includes encryption at rest and in transit, access controls, and periodic security reviews.

If we become aware of a security incident affecting your personal information, we will notify affected users without undue delay and as required by applicable law.

6. Data Retention

We retain personal information for as long as necessary to:

• Process transactions;
• Meet legal, union, and accounting requirements; or
• Resolve disputes or enforce agreements.

We may retain limited metadata and audit records for compliance or fraud prevention purposes.

7. Cookies and Tracking

We use cookies and similar technologies to enable secure login, remember preferences, and analyze Platform usage. You can manage cookies through your browser settings. We do not honor Do-Not-Track (DNT) signals.

8. Your Rights and Choices

You may: 

• Access, correct, or delete your personal information by contacting us at legalnotices@eljininc.com;
• Opt out of promotional emails at any time;
• Request to know, correct, or delete your data (for California or other state residents with such rights).

We will verify requests as required by law and respond within legally mandated timeframes.

9. CPRA (California Privacy Rights Act) Summary

Categories Collected: Identifiers, financial data, union and agency affiliations, commercial and transactional data, internet activity, and professional information.
Business Purposes: Payment processing, compliance, analytics, and fraud prevention.
Categories Disclosed: Unions, financial institutions, verification vendors, cloud providers, and counterparties.
Sales or Sharing: Eljin does not sell or share personal information for cross-context behavioral advertising.
Consumer Rights: California residents may request access, correction, deletion, and restriction of use, or designate an authorized agent to do so.

10. International Transfers

Eljin stores and processes data primarily in the United States. If you are located outside the U.S., you consent to the transfer of your personal information to the U.S.

Where applicable, such transfers rely on Standard Contractual Clauses (SCCs) or other recognized transfer mechanisms.

11. Children’s Privacy

The Platform is not intended for individuals under 18. We do not knowingly collect personal information from minors. If we become aware that such data has been provided, we will delete it promptly.

12. Changes to this Privacy Policy

We may update this Policy from time to time. Changes take effect upon posting to the Platform.
Material changes will be communicated via email or user notice.

13. Contact

Privacy policy inquiries: legalnotices@eljininc.com
Mail: Eljin Productions, Inc., 44 Kane Avenue, Larchmont, NY 10538

Last updated: August 1, 2025.