Legal
Privacy policy
Last updated: June 2026
1. Who we are
This Privacy Policy is issued by d2 Benelux BV (trading as d2 / Digital Darwin), a company incorporated under Belgian law with registered office at Schaarbeekstraat 20E bus 11, 9120 Beveren, Belgium, and registered in the Crossroads Bank for Enterprises under number BE 0863.205.869.
d2 Benelux BV is the data controller responsible for the personal data collected through this website (d2cinema.com) and any related digital services. For all privacy-related enquiries, contact us at info@d2.eu.
2. Legal framework
This policy is drafted in accordance with Regulation (EU) 2016/679 (the General Data Protection Regulation, "GDPR") and the Belgian Act of 30 July 2018 on the protection of natural persons with regard to the processing of personal data.
3. What personal data we collect
We collect personal data only to the extent necessary for the purposes described in this policy:
- Contact data: name, company name, email address, telephone number, provided voluntarily when you use our contact form.
- Communication data: the content of messages you send us and our correspondence with you.
- Technical data: IP address, browser type and version, device type, pages visited, time and date of visit, collected automatically when you browse our website.
- Cookie data: see Section 8 below.
We do not collect special categories of personal data, and we do not knowingly collect data from persons under the age of 16.
4. Purposes and legal basis for processing
| Purpose | Legal basis (GDPR Art. 6) |
|---|---|
| Responding to contact form enquiries | Legitimate interest (Art. 6(1)(f)), to respond to business enquiries |
| Providing information about our services | Legitimate interest (Art. 6(1)(f)), pre-contractual communication |
| Improving and securing our website | Legitimate interest (Art. 6(1)(f)), to maintain our digital services |
| Analysing website usage via Google Analytics 4 (anonymised) | Consent (Art. 6(1)(a)), only where given via the cookie banner |
| Showing embedded YouTube trailers | Consent (Art. 6(1)(a)), marketing category, loaded only after consent |
| Complying with legal obligations | Legal obligation (Art. 6(1)(c)) |
5. How long we keep your data
- Contact form data: retained for a maximum of 3 years from the last interaction.
- Technical and log data: retained for a maximum of 12 months.
- Data processed for legal compliance: retained for the period required by law, typically 7 years for accounting records under Belgian law.
6. Who we share your data with
We do not sell, rent or trade your personal data. We may share data with trusted service providers who process it on our behalf and under our instructions, subject to data processing agreements:
- Vercel Inc. (website hosting, USA), transfers governed by Standard Contractual Clauses.
- Sanity Inc. (content management infrastructure, USA), transfers governed by Standard Contractual Clauses.
- Resend Inc. (transactional email delivery, USA), transfers governed by Standard Contractual Clauses.
- Google LLC (Google Analytics 4, and YouTube embedded trailers, USA), only where you have consented to the relevant cookies. Transfers governed by Standard Contractual Clauses. IP anonymisation is enabled for analytics, and trailers load through the privacy-friendly youtube-nocookie domain.
We may also disclose personal data where required by law, court order or a competent regulatory authority.
7. Your rights under the GDPR
- Right of access (Art. 15)
- Right to rectification (Art. 16)
- Right to erasure (Art. 17)
- Right to restriction of processing (Art. 18)
- Right to data portability (Art. 20)
- Right to object (Art. 21)
- Right to withdraw consent at any time, without affecting the lawfulness of prior processing.
To exercise any of these rights, contact us at info@d2.eu. We will respond within one month. You also have the right to lodge a complaint with the Belgian Data Protection Authority (dataprotectionauthority.be).
8. Cookies and tracking technologies
Our website uses three categories of cookies:
- Strictly necessary cookies: required for the site to function and to remember your cookie choice. These cannot be disabled.
- Analytics cookies (optional): anonymised statistics via Google Analytics 4, set only if you accept them.
- Marketing cookies (optional): set only when you choose to play an embedded YouTube trailer. Until then, the page makes no request to YouTube or Google.
Google Analytics 4 uses IP anonymisation, with data transferred under Standard Contractual Clauses. You can change or withdraw your cookie preferences at any time through the cookie settings. We do not use advertising cookies, social media tracking pixels or cross-site tracking technologies.
9. Data security
We implement appropriate technical and organisational measures to protect your personal data, including encrypted transmission (HTTPS/TLS), access controls and regular security assessments. In the event of a data breach likely to result in high risk to your rights and freedoms, we will notify you as required under Art. 34 GDPR.
10. Links to third-party websites
Our website may contain links to external websites. This Privacy Policy does not apply to those websites, and we encourage you to review their own policies.
11. Changes to this policy
We may update this Privacy Policy from time to time. The date of the most recent revision is shown at the top of this page.