Privacy Policy

1.1 The controller for the processing of your data when you use this Portal is its operator (the “Operator”), for example your library, school or university, or a cinema, festival or association:

The name and contact details of the operator are given in the legal notice (imprint) of this portal.

1.2 filmwerte GmbH, Dianastraße 44, 14482 Potsdam, Germany (“filmwerte”), operates the Portal technically on behalf of the Operator. filmwerte processes your data as a processor only on the Operator’s instructions (Art. 28 GDPR), not for its own purposes and not for advertising. filmwerte does not sell any data and does not pass them on to advertising partners.

1.3 filmwerte provides this notice on behalf of the Operator. It describes which data are processed when you use the Portal. The Operator’s privacy policy also applies. The Operator decides which of the following functions a Portal uses.

1.4 filmwerte itself is the controller for newsletters, prize draws and the filmwerte websites on which you do not sign in. This is explained in the privacy policy of filmwerte GmbH at www.filmwerte.de. Data from the use of the Portal are not combined with these data.

Applies to: Portals with sign-in through the institution’s system

2.1 You sign in with the credentials that the Operator has issued to you, for example with your library card number and password, or through a single sign-on procedure of your institution (such as SAML or OpenID Connect).

2.2 Your library card number and password are forwarded to the Operator’s system, which checks your eligibility. The password is not stored. filmwerte stores the library card number or user name only as a hash value. With single sign-on, the pseudonymous identifier transmitted by your institution’s system is stored. The Portal uses this value to recognize your user account the next time you sign in.

2.3 In addition, your eligibility status and, where your institution’s system transmits them, your age or date of birth are stored. They are used for the protection of minors.

Applies to: Portals with eligibility check against a user list of the Operator (divibib offline)

2.4 In this Portal, filmwerte checks your eligibility against a list of user data that the Operator regularly transmits to filmwerte. filmwerte stores the library card number and password from this list only as a hash value.

2.5 The legal basis is your user relationship with the Operator (Art. 6(1)(b) GDPR) or, for public institutions, Art. 6(1)(e) GDPR in conjunction with the provisions applicable to the Operator.

Applies to: Portals with their own user accounts

3.1 In some Portals, you create your own user account or receive one from the Operator. Depending on the Portal, your name, email address or user name, password, date of birth, country and language are processed for this purpose. Required fields are marked in the form.

3.2 Your password is stored only as a salted hash value. You receive emails with a link to confirm your email address and to reset your password.

3.3 You can delete your account in the Portal. What is deleted in that case is explained in the section “Retention Period”.

3.4 The legal basis is your user agreement with the Operator (Art. 6(1)(b) GDPR).

4.1 The content is labeled with age ratings or age recommendations. If your age is known, the Portal blocks content that is not approved for that age. You can also set a parental-control PIN with an age threshold. The PIN is stored only as a salted hash value.

4.2 The legal basis is your user relationship with the Operator (Art. 6(1)(b) GDPR) and, where age limits are required by law, Art. 6(1)(c) GDPR in conjunction with the provisions on the protection of minors in the media.

5.1 The following are stored with your user account:

• a profile name; it is “filmfriend” or “myfilmfriend” unless you have changed it. You can change it if you have your own user account;
• country and language for correspondence;
• your acceptance of the Terms of Use, with timestamp;
• your watchlist;
• the playback position for each title, with timestamp, so that you can later continue watching from the same point.

5.2 If you change the profile name, you do not have to use your name.

5.3 You can share your watchlist with others via a link. Anyone who knows the link can see the titles on the list, but no information about you. You can stop sharing at any time.

5.4 The legal basis is your user relationship with the Operator (Art. 6(1)(b) GDPR).

6.1 The films are delivered through the content delivery network bunny.net of BunnyWay d.o.o., Ljubljana (Slovenia). In the process, your IP address is processed in order to send the stream to your device. filmwerte stores it only in the application logs, which are deleted after 60 days.

6.2 The rights holders require copy protection (DRM). When playback starts, your device obtains a license from the ExpressPlay service of Intertrust Technologies Corporation, Sunnyvale (USA). In the process, your IP address and technical information about the device and player are processed. The transfer to the United States is based on Standard Contractual Clauses of the European Commission.

6.3 The player loads fonts from the Portal’s servers. So that you can cast films to a Chromecast device, the player loads the necessary software library from Google servers when it starts. In the process, Google receives your IP address and technical information about your browser. The legal basis is Art. 6(1)(f) GDPR; the legitimate interest lies in being able to offer casting to TVs. Google may transfer data to the United States; Google LLC is certified under the EU-US Data Privacy Framework.

6.4 In the apps for smartphones and tablets, you can download content temporarily where the license permits. The content and the associated license are stored in encrypted form on your device and can only be played in the app.

6.5 The legal basis is your user relationship with the Operator (Art. 6(1)(b) GDPR).

7.1 While you are signed in, the Portal sends usage events to the platform: that you are active (no more than once every 5 minutes), which titles are displayed and played, and how far playback has progressed. From these, the playback position and the minutes played per title are determined. The usage events do not contain an IP address.

7.2 From these data, filmwerte creates anonymous statistics for the Operator, such as the number of active and new users, the number of views, minutes streamed and the most-watched titles. On the Operator’s instructions, the usage data are also anonymized and used for accounting to rights holders and collecting societies and to improve the Portal. The statistics do not allow any conclusions to be drawn about individual persons; in the administration area, the Operator cannot see who watched which title.

7.3 The legal basis is your user relationship with the Operator (Art. 6(1)(b) GDPR) and, for the statistics, the Operator’s legitimate interest in accounting for and planning its service (Art. 6(1)(f) GDPR) or its public task (Art. 6(1)(e) GDPR).

7.4 The Portal does not use any analytics or advertising services and does not create profiles for advertising purposes.

8.1 You download the apps from the app stores of Apple, Google or Amazon. When you download them, the respective store processes data under its own responsibility, for example your store account. The apps contain no advertising or analytics services and no error reporting that relates to you personally.

8.2 On TVs, you can sign in by confirming a code shown on the TV on another device on which you are signed in.

8.3 When you cast a film to a TV via Chromecast or AirPlay, the receiving device receives the address of the stream. With Chromecast, the receiver software is loaded from Google; in the process, Google receives your IP address and technical information about the device and processes them under its own responsibility. AirPlay is a feature of your Apple device. Casting itself only takes place when you start it (Section 25(2) no. 2 TDDDG, Art. 6(1)(b) GDPR).

9.1 After you sign in, the Portal stores the following cookies on your device. They are strictly necessary for the functions you have requested (Section 25(2) no. 2 TDDDG):

• “access_token”, “token_type”, “access_token_expiration”, “refresh_token” and “refresh_token_expiration”: you stay signed in, up to 15 days;
• “external_sign_in_state” and “external_sign_in_redirect_uri”: security and redirect back during single sign-on, deleted after sign-in;
• cookies beginning with “preferred-”: your player settings, such as language and subtitles, 1 year;
• cookies for sorting lists, such as “watchlist-sort-order”, 1 year;
• “android-smart-banner-closed”: notice about the Android app hidden, 90 days.

9.2 In the apps, your sign-in data are stored on your device; you stay signed in there for up to 365 days.

9.3 The Portal does not set any cookies for analytics or advertising purposes.

10.1 If you have questions about using the Portal, please contact the Operator first. The Operator forwards questions that it cannot answer itself to filmwerte. You can also contact filmwerte support directly, for example through the contact form in the Portal or by email. In the contact form, you choose whether your request goes to the Operator or to filmwerte.

10.2 Your name, email address and the content of your request are processed. filmwerte handles requests in Microsoft 365 and in the Azure DevOps ticket system. To answer more quickly, filmwerte has draft answers prepared by an AI service of Microsoft (Azure AI Foundry), which runs in the European Union data zone. A member of filmwerte’s staff reviews every draft before the answer is sent. No other AI services are used for your requests.

10.3 The legal basis is your user relationship with the Operator (Art. 6(1)(b) GDPR).

11.1 With the Operator’s approval, filmwerte uses the following subprocessors:

• Microsoft Ireland Operations Ltd., Dublin (Ireland): hosting of the platform (Microsoft Azure, West Europe region, Netherlands), email mailboxes and ticket system (Microsoft 365, Azure DevOps), and AI-assisted drafting of answers to support requests (Azure AI Foundry, European Union data zone);
• BunnyWay d.o.o. (bunny.net), Ljubljana (Slovenia): content delivery network and storage; for some Portals through an account of the Operator;
• Intertrust Technologies Corporation, Sunnyvale (USA): copy protection (ExpressPlay);
• STRATO GmbH, Berlin (Germany): forwarding of emails to the Portal’s addresses (such as support) and sending of system notifications.

11.2 The payment service providers, the app stores and Google, when the Chromecast receiver software is loaded, are controllers in their own right. Authorities receive data only where there is a legal obligation to provide them.

12.1 The platform and all data of your user account are located in the European Union. filmwerte transfers data to the United States only when the copy protection license is obtained (IP address and technical information), on the basis of the Standard Contractual Clauses of the European Commission. Access by Microsoft from the United States in individual cases is safeguarded by the EU-US Data Privacy Framework, under which Microsoft is certified. You can obtain a copy of the Standard Contractual Clauses through the Operator.

13.1 The data are stored for as long as necessary for the respective purpose:

• account data, watchlist, profile and parental-control PIN: as long as your user account exists and the Operator uses the Portal; if you delete your account, they are deleted immediately;
• playback position and minutes played: as long as your user account exists. If you delete your account, they are retained without reference to your account and can no longer be attributed to you;
• usage events: same as playback position and minutes played;
• application logs: 60 days; metrics: 30 days;
• support requests: until fully handled;
• order and invoice data: until the Operator’s statutory retention periods expire, in Germany 8 years for invoices and 6 years for business letters;
• anonymous statistics: without time limit, as they do not contain any personal data.

13.2 If the contract between the Operator and filmwerte ends, filmwerte returns the Portal’s data at the Operator’s request and deletes them within 60 days after the end of the contract, unless there is a statutory retention obligation. Copies in backups are overwritten in the regular cycle, after 52 weeks at the latest; until then, they remain encrypted and are no longer used.

14.1 You have the right of access (Art. 15 GDPR), rectification (Art. 16 GDPR), erasure (Art. 17 GDPR), restriction of processing (Art. 18 GDPR) and data portability (Art. 20 GDPR). You can withdraw your consent at any time with effect for the future (Art. 7(3) GDPR).

14.2 Right to object (Art. 21 GDPR): If your data are processed on the basis of Art. 6(1)(e) or (f) GDPR, you can object to the processing at any time on grounds relating to your particular situation. The data will then no longer be processed, unless the Operator demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defense of legal claims.

14.3 You exercise your rights with the Operator (contact details above). If your request reaches filmwerte, filmwerte forwards it to the Operator without undue delay and supports the Operator in responding.

14.4 You can lodge a complaint with a data protection supervisory authority (Art. 77 GDPR), in particular in the Member State of your habitual residence or place of work. For persons and Operators in Switzerland, the Federal Act on Data Protection (FADP) also applies.

15.1 No decisions are made that are based solely on automated processing and that produce legal effects concerning you or similarly significantly affect you (Art. 22 GDPR).

15.2 You cannot use the Portal without the data required for sign-in and eligibility check. Other information, such as a profile name, a parental-control PIN or answers to questionnaires, is voluntary.

15.3 filmwerte protects the data through technical and organizational measures under Art. 32 GDPR, in particular encrypted transmission and storage, storage of library card numbers, passwords and PINs only as hash values, a role and permission model, and the separation of the data of the individual Operators.

Effective date: November 2026, Version 1.0