Effective date: 04 August 2026. Modem Studios is a trading name of Pence Talent Ltd. We are committed to protecting and respecting your privacy.
This Privacy Policy explains how Pence Talent Ltd, trading as Modem Studios ("we", "us", or "our"), collects, uses, and protects personal data in connection with our website(s), our production and digital content activity, our creator-venture business, and our wider business activities. Modem Studios is not a separately incorporated company. It is a trading name and brand of Pence Talent Ltd. Any reference to "Modem Studios" in this policy, on our website, or in our communications refers to Pence Talent Ltd operating under that trading name.
Pence Talent Ltd, trading as Modem Studios, is the data controller responsible for your personal data across both brands. Contact details: Email: contact@modem-studios.com Address: Perk Accounting, 31 Cattle Market St, Norwich NR1 3DY, United Kingdom
This policy applies to personal data relating to: – Visitors to our website(s) – Individuals who contact us – Talent we represent or engage with (under the Pence Talent brand) – Creators and talent partners we build ventures with (under the Modem Studios brand) – Shareholders, co-founders, and individuals named in subsidiary venture arrangements – Clients, prospective clients, and industry partners – Brands, agencies, broadcasters, retailers, manufacturers, and collaborators – Investors and prospective investors in Modem Studios ventures
We may collect and process the following categories of personal data: 4.1 Information provided directly – Name and contact details (such as email address and telephone number) – Information submitted via our website contact form(s) – Correspondence and communications 4.2 Professional and business information – CVs, social media profiles, and media kits – Employment or business details – Audience, follower, and engagement data relating to creators and talent partners – Project, production, and collaboration information – Venture, shareholder, and equity partnership information (including details relevant to subsidiary company formation) 4.3 Operational and transactional data – Communication history – Pitch materials, proposals, and investor documents – Campaign and production information – Contracts and agreements, including shareholder agreements and heads of terms – Talent and creator analytics and performance data – Creative content (including video and still imagery) – Feedback, concepts, and intellectual property – Financial information, including invoices, payment records, and equity/investment records 4.4 Website and technical data Basic usage data relating to how visitors interact with our website(s). Information collected through cookies and similar technologies. We do not intentionally collect special category (sensitive) personal data unless required and agreed as part of a specific engagement.
We collect personal data through: – Website contact forms – Direct communications (including email and messaging platforms) – Professional onboarding and business relationships – Contracts and agreements, including venture and shareholder agreements – Ongoing project, production, and collaboration activity – Cookies and analytics technologies – Third-party platforms used to support our operations, including cloud storage, communication, workflow, and e-commerce tools – Publicly available audience and social media data used for product and audience research
We process personal data for the following purposes: – To respond to enquiries and communications – To represent talent and manage professional relationships (Pence Talent) – To identify, develop, and secure commercial opportunities – To pitch talent, services, and venture opportunities to brands, agencies, partners, retailers, and investors – To identify and assess creator audiences for potential product and venture opportunities – To manage collaborations, campaigns, and productions – To develop, launch, and operate subsidiary brand ventures, including AI-enabled marketing, email, and e-commerce operations run on behalf of those ventures – To negotiate and administer shareholder agreements and equity arrangements – To deliver creative and strategic services – To administer contracts, invoicing, and payments – To maintain records of business activities – To operate, maintain, and improve our website(s) and services
We rely on the following legal bases under UK GDPR: 7.1 Legitimate interests Processing is necessary for the purposes of our legitimate interests, including: – Operating and developing our business, including venture and production activity – Communicating with relevant individuals and organisations – Promoting and representing talent and creator partners – Identifying and validating product and venture opportunities using audience data – Improving our services and website(s) 7.2 Contract Processing is necessary for the performance of a contract or to take steps prior to entering into a contract, including: – Talent representation agreements – Creator venture and shareholder agreements – Client and partnership arrangements 7.3 Legal obligation Processing is necessary to comply with legal obligations, including: – Financial record keeping – Tax and regulatory compliance – Company and shareholder record keeping We do not generally rely on consent as a primary legal basis, except where specifically required.
Our website(s) use cookies and similar technologies to ensure functionality and to understand how visitors interact with the site. We may implement analytics and behavioural tools, including services such as Hotjar, to analyse user engagement (for example navigation patterns, clicks, and scrolling behaviour). Our website(s) may be hosted on platforms such as Squarespace, which may use essential cookies necessary for the operation of the site. Users can control or disable cookies through their browser settings.
We do not sell personal data. We may share personal data where necessary with: – Brands, agencies, broadcasters, and commercial partners – Clients and collaborators – Retail and manufacturing partners involved in subsidiary venture products – Investors and prospective investors, where relevant to a specific venture – Service providers supporting our operations (including hosting, storage, communication, e-commerce, and marketing automation platforms) – Professional advisers, including legal and accounting providers Such disclosures may include: – Talent and creator profiles and supporting materials – Contact details – Pitch documents and proposals – Campaign and venture deliverables and related communications – Shareholder and venture-related documentation, where necessary for a specific transaction All third parties are expected to process personal data securely and in accordance with applicable laws.
Personal data may be transferred to, and processed in, countries outside the United Kingdom where our service providers operate. Where such transfers occur, we ensure appropriate safeguards are in place, including the use of standard contractual clauses or equivalent protections.
We retain personal data only for as long as necessary for the purposes for which it was collected, including: – Website enquiries: typically up to 12 months – Talent, creator, client, and partner data: for the duration of the relationship and for a reasonable period thereafter – Shareholder and venture-related records: for the duration of the relevant venture and for as long as required by law thereafter – Financial and contractual records: in accordance with legal requirements Retention periods may vary depending on the nature of the data and legal obligations.
We implement appropriate technical and organisational measures to protect personal data, including: – Use of secure, cloud-based systems – Multi-factor authentication – Access controls and restricted permissions – Secure handling and storage of business data
Under UK GDPR, individuals have the right to: – Access their personal data – Request correction of inaccurate or incomplete data – Request erasure of personal data – Restrict or object to processing – Request data portability – Withdraw consent where applicable Requests can be made by contacting us at contact@modem-studios.com
If you have concerns about how your personal data is handled, please contact us in the first instance. You also have the right to lodge a complaint with the Information Commissioner's Office.
We may update this Privacy Policy from time to time to reflect changes in our practices, our corporate structure, or our legal obligations. The most current version will be available on our website(s).
For any questions regarding this Privacy Policy or our data practices, please contact: Email: contact@modem-studios.com