Privacy Policy
This Privacy Policy explains how XIGAMO LTD a company operating from 3 Venics Way, High Wycombe, HP11 1LN, United Kingdom processes personal data in connection with the website https://xigamo.codes, commercial enquiries, video production, visual effects, specialised design services, computer systems design and custom computer programming services. The controller is XIGAMO LTD. The contact address for privacy correspondence is commercial@xigamo.codes as plain text, together with telephone +44 7937 654321. This Policy is governed by the law of England and Wales and is intended to meet the United Kingdom General Data Protection Regulation and the Data Protection Act 2018.
Effective date: 3 September 2026. This Policy applies to visitors, prospective clients, suppliers, talent, freelance crew, software users of commissioned tools, and any person who submits a passage request through the website form. It does not apply to third-party platforms that we do not control. If you follow an external map or font service, that provider’s terms apply to their processing.
Identity of the controller
XIGAMO LTD is the data controller for personal data collected through https://xigamo.codes and through production or software engagements contracted from 3 Venics Way, High Wycombe, HP11 1LN, United Kingdom. Correspondence marked for the lock keeper directory may be sent to commercial@xigamo.codes. Telephone contact is +44 7937 654321. We do not appoint a statutory Data Protection Officer because our core activities do not consist of regular and systematic monitoring of data subjects on a large scale, nor of large-scale processing of special category data as a primary business. We nevertheless apply accountability measures proportionate to a High Wycombe media and software studio.
If we jointly determine purposes with a production company, agency or software licensee, we will identify the respective roles in the relevant contract. Where we act as processor, the processing agreement will prevail for that processing, and this Policy describes only controller processing.
Categories of personal data
Identity and contact data include name, business role, organisation, email address, telephone number, postal address and the content of messages submitted through the passage request form. We collect these because a lock chamber cannot be filled honestly without knowing who is requesting passage.
Professional data include project titles, production schedules, technical specifications, software environment details, review notes and contractual references. Such data may identify individuals where a credit, call sheet or repository username is included. We treat credits and usernames as personal data when they relate to an identifiable living individual.
Technical data include internet protocol address, browser type, device class, approximate location derived from IP at city or region level, referral URL, pages viewed and timestamps. We do not use this technical layer as a maritime tracking product. It is used to keep the website stable, to diagnose faults and, where cookies are agreed, to remember preferences.
Financial and billing data for contracted clients may include purchase-order numbers, invoice addresses and payment references processed through our accountants and payment providers. We do not store full payment card numbers on the website.
Special category data are not sought through the website. If a production brief incidentally includes health, union, or diversity information, we process it only where a lawful basis and condition exist, typically with explicit consent or for employment-style obligations where we engage individuals as workers.
Sources of data
Data are obtained directly from you when you complete the form, write to commercial@xigamo.codes, telephone +44 7937 654321, attend a meeting at 3 Venics Way, High Wycombe, HP11 1LN, United Kingdom, or send files for a level reading. Data may also arrive from a commissioning producer, agency, or legal representative authorised to instruct us.
Limited technical data are generated by your device when you load pages on https://xigamo.codes. Map previews load from Google Maps based on the exact address 3 Venics Way, High Wycombe, HP11 1LN, United Kingdom. Font files may be requested from Google Fonts. Those requests can transfer technical identifiers to those providers.
Purposes and lawful bases
Responding to passage requests and pre-contract enquiries is processed on the basis of steps at the request of the data subject prior to entering a contract, and on legitimate interests in operating a High Wycombe studio that must read a waterline before opening a gate. You may object to legitimate interests where they apply.
Performing video production, VFX, colour, interactive media, virtual production and custom software contracts is processed as necessary for the performance of a contract. Without identity, delivery and approval data the chamber cannot pass work to the next level.
Compliance with accounting, tax, company and health-and-safety duties is processed as a legal obligation under the law of England and Wales, including Companies Act record keeping and HM Revenue and Customs requirements.
Website security, fraud prevention and the integrity of commissioned software environments are processed on legitimate interests. We consider that visitors and clients expect a controlled chamber rather than an open sluice.
Marketing to existing clients about similar services may occur under the Privacy and Electronic Communications Regulations where the soft opt-in conditions are met. Other electronic marketing requires consent. You may withdraw consent without affecting prior lawful processing.
Recruitment, crew and freelancer onboarding, where applicable, is processed on contract, legal obligation and legitimate interests in assessing skill for motion picture and software work.
Legitimate interests assessment
Our legitimate interests include operating https://xigamo.codes, protecting the studio at 3 Venics Way, High Wycombe, HP11 1LN, United Kingdom, keeping production files secure, improving equalisation methods, and communicating about services that match a previous engagement. We balance these against your rights, especially where you are an individual rather than a corporate contact.
We do not use legitimate interests for intrusive profiling, automated decisions producing legal effects, or the sale of personal data. We do not treat the canal-lock visual language of the website as a basis to collect extra identifiers.
Cookies and similar technologies
The website may set strictly necessary cookies to keep a session stable and to remember a cookie banner choice. Analytics or preference cookies, if introduced, will be described in the Cookie Policy and will not run until required consent is recorded, except where an exemption applies.
You can control cookies through your browser. Blocking some cookies may prevent the passage request form from remembering a draft on your device. See the Cookie Policy on this website for fuller detail.
Disclosure of personal data
We disclose data to employees and contractors of XIGAMO LTD who need it to read levels, equalise pressure or open gates in sequence. Access is limited by role.
We disclose data to professional advisers, insurers, accountants, banks, cloud infrastructure and rendering providers, colour-managed review platforms, and production vendors strictly as needed to perform a contract or legal duty. Each recipient is expected to provide appropriate security.
We may disclose data to a purchaser or successor in a corporate transaction involving XIGAMO LTD, subject to confidentiality and, where required, notice.
We disclose data to competent authorities in the United Kingdom when required by law, court order, or to protect vital interests or the rights of XIGAMO LTD and others.
We do not sell personal data. We do not permit advertising networks to harvest passage-request messages for unrelated marketing.
International transfers
Some subprocessors, including font, map or cloud providers, may process data outside the United Kingdom. Where a transfer occurs, we rely on the UK International Data Transfer Agreement, addendum to the EU Standard Contractual Clauses, adequacy regulations, or another lawful transfer tool.
If a production requires transfer of rushes or software repositories outside the UK, the contract will identify the destination and the safeguard. You should not assume that a High Wycombe chamber keeps every render node physically in Buckinghamshire.
Retention
Enquiry data that do not become a contract are typically retained for up to twenty-four months so that a later waterline can be compared, unless you request earlier erasure and no exemption applies.
Contract, invoice and tax records are retained for at least six years from the end of the relevant accounting period, and longer if a dispute or legal hold requires it.
Production media and software repositories are retained as set in the statement of work. If no period is stated, we retain working files for a commercially reasonable period not less than twelve months after delivery, then review for deletion or archive under the client’s instructions.
Server logs used for security are typically rotated within ninety days unless an incident requires longer retention.
Security
XIGAMO LTD applies organisational and technical measures including access control, least privilege, encrypted transit where the website is served over HTTPS, password hygiene for internal systems, and contractual duties on processors. No chamber is perfectly dry. You must not send passwords or unencrypted special category data through the public form.
If a personal data breach is likely to result in a high risk to your rights, we will notify you and the Information Commissioner’s Office as required by UK law.
Your rights
You have the right to access, rectification, erasure, restriction, objection to processing based on legitimate interests, and data portability where processing is automated and based on consent or contract. You may withdraw consent where consent is the basis.
To exercise rights, write to commercial@xigamo.codes from an address we can reasonably associate with the request, or post to 3 Venics Way, High Wycombe, HP11 1LN, United Kingdom. We may need to verify identity. We will respond within one month, extendable by two months for complex requests as permitted by law.
You have the right to complain to the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom. We would prefer to equalise pressure first by discussing the issue with the lock keeper directory.
Children
The website and commercial services are directed at organisations and adults. We do not knowingly collect data from children through the passage form. If you believe a child has submitted data, contact commercial@xigamo.codes and we will delete the record unless a legal duty requires retention.
Automated decision-making
We do not make solely automated decisions, including profiling, that produce legal or similarly significant effects concerning website visitors. Human lock keepers read passage requests.
Third-party sites
Links to about, services, portfolio, contact and legal pages on this domain are first-party. Google Maps is a third-party frame showing 3 Venics Way, High Wycombe, HP11 1LN, United Kingdom. Your interaction with that frame is subject to Google’s terms and privacy notice.
Changes
We may revise this Policy when our chambers, subprocessors or the law change. The date at the head will be updated. Material changes affecting existing clients will be notified using the contact we hold, where practicable.
Contact for privacy
Privacy correspondence: XIGAMO LTD, 3 Venics Way, High Wycombe, HP11 1LN, United Kingdom. Email as plain text: commercial@xigamo.codes. Telephone: +44 7937 654321. Website: https://xigamo.codes.
Production files and identifiable people
Where a production file includes call sheets, XIGAMO LTD treats any identifiable individual as a data subject. Such material is stored only for the purpose stated in the statement of work. The High Wycombe studio records the chamber reference so that erasure or access requests can be located without searching an entire farm.
Where a production file includes editorial notes, XIGAMO LTD treats any identifiable individual as a data subject. Such material is accessible to the smallest set of lock keepers who must equalise that chamber. The High Wycombe studio records the chamber reference so that erasure or access requests can be located without searching an entire farm.
Where a production file includes VFX vendor lists, XIGAMO LTD treats any identifiable individual as a data subject. Such material is deleted or returned when the retention period ends unless a legal hold applies. The High Wycombe studio records the chamber reference so that erasure or access requests can be located without searching an entire farm.
Where a production file includes colour decision lists, XIGAMO LTD treats any identifiable individual as a data subject. Such material is not used to train a public generative model unless a contract expressly allows it. The High Wycombe studio records the chamber reference so that erasure or access requests can be located without searching an entire farm.
Where a production file includes render logs, XIGAMO LTD treats any identifiable individual as a data subject. Such material is not published as a tourism canal story or marina directory listing. The High Wycombe studio records the chamber reference so that erasure or access requests can be located without searching an entire farm.
Where a production file includes repository usernames, XIGAMO LTD treats any identifiable individual as a data subject. Such material is stored only for the purpose stated in the statement of work. The High Wycombe studio records the chamber reference so that erasure or access requests can be located without searching an entire farm.
Where a production file includes stage access lists, XIGAMO LTD treats any identifiable individual as a data subject. Such material is accessible to the smallest set of lock keepers who must equalise that chamber. The High Wycombe studio records the chamber reference so that erasure or access requests can be located without searching an entire farm.
Where a production file includes invoice contacts, XIGAMO LTD treats any identifiable individual as a data subject. Such material is deleted or returned when the retention period ends unless a legal hold applies. The High Wycombe studio records the chamber reference so that erasure or access requests can be located without searching an entire farm.
Where a production file includes insurance certificates, XIGAMO LTD treats any identifiable individual as a data subject. Such material is not used to train a public generative model unless a contract expressly allows it. The High Wycombe studio records the chamber reference so that erasure or access requests can be located without searching an entire farm.
Where a production file includes union paperwork, XIGAMO LTD treats any identifiable individual as a data subject. Such material is not published as a tourism canal story or marina directory listing. The High Wycombe studio records the chamber reference so that erasure or access requests can be located without searching an entire farm.
Where a production file includes location agreements, XIGAMO LTD treats any identifiable individual as a data subject. Such material is stored only for the purpose stated in the statement of work. The High Wycombe studio records the chamber reference so that erasure or access requests can be located without searching an entire farm.
Where a production file includes software licence keys held on behalf of a client, XIGAMO LTD treats any identifiable individual as a data subject. Such material is accessible to the smallest set of lock keepers who must equalise that chamber. The High Wycombe studio records the chamber reference so that erasure or access requests can be located without searching an entire farm.
Where a production file includes review-platform accounts, XIGAMO LTD treats any identifiable individual as a data subject. Such material is deleted or returned when the retention period ends unless a legal hold applies. The High Wycombe studio records the chamber reference so that erasure or access requests can be located without searching an entire farm.
Where a production file includes courier names, XIGAMO LTD treats any identifiable individual as a data subject. Such material is not used to train a public generative model unless a contract expressly allows it. The High Wycombe studio records the chamber reference so that erasure or access requests can be located without searching an entire farm.
Where a production file includes emergency contacts on a risk assessment, XIGAMO LTD treats any identifiable individual as a data subject. Such material is not published as a tourism canal story or marina directory listing. The High Wycombe studio records the chamber reference so that erasure or access requests can be located without searching an entire farm.
Worked illustrations of rights handling
In illustration 1, if a data subject asks XIGAMO LTD to correct a misspelt credit, invoice name or repository identifier, we will amend systems we control within the statutory period, and we will instruct processors who hold a copy for the same engagement. If a broadcast master has already passed to a third-party distributor under the client’s authority, we will explain the limit of our chamber and the client’s role as a separate controller or joint controller as the case may be.
In illustration 2, if a data subject asks XIGAMO LTD to correct a misspelt credit, invoice name or repository identifier, we will amend systems we control within the statutory period, and we will instruct processors who hold a copy for the same engagement. If a broadcast master has already passed to a third-party distributor under the client’s authority, we will explain the limit of our chamber and the client’s role as a separate controller or joint controller as the case may be.
In illustration 3, if a data subject asks XIGAMO LTD to correct a misspelt credit, invoice name or repository identifier, we will amend systems we control within the statutory period, and we will instruct processors who hold a copy for the same engagement. If a broadcast master has already passed to a third-party distributor under the client’s authority, we will explain the limit of our chamber and the client’s role as a separate controller or joint controller as the case may be.
In illustration 4, if a data subject asks XIGAMO LTD to correct a misspelt credit, invoice name or repository identifier, we will amend systems we control within the statutory period, and we will instruct processors who hold a copy for the same engagement. If a broadcast master has already passed to a third-party distributor under the client’s authority, we will explain the limit of our chamber and the client’s role as a separate controller or joint controller as the case may be.
In illustration 5, if a data subject asks XIGAMO LTD to correct a misspelt credit, invoice name or repository identifier, we will amend systems we control within the statutory period, and we will instruct processors who hold a copy for the same engagement. If a broadcast master has already passed to a third-party distributor under the client’s authority, we will explain the limit of our chamber and the client’s role as a separate controller or joint controller as the case may be.
In illustration 6, if a data subject asks XIGAMO LTD to correct a misspelt credit, invoice name or repository identifier, we will amend systems we control within the statutory period, and we will instruct processors who hold a copy for the same engagement. If a broadcast master has already passed to a third-party distributor under the client’s authority, we will explain the limit of our chamber and the client’s role as a separate controller or joint controller as the case may be.
In illustration 7, if a data subject asks XIGAMO LTD to correct a misspelt credit, invoice name or repository identifier, we will amend systems we control within the statutory period, and we will instruct processors who hold a copy for the same engagement. If a broadcast master has already passed to a third-party distributor under the client’s authority, we will explain the limit of our chamber and the client’s role as a separate controller or joint controller as the case may be.
Processor categories
Category 1: secure email and office software. XIGAMO LTD selects providers capable of supporting UK GDPR. Processing is limited to instructions. International transfers, if any, use a lawful tool. A current list of named providers can be requested from commercial@xigamo.codes where disclosure would not create a security risk to the chamber.
Category 2: accountancy platforms. XIGAMO LTD selects providers capable of supporting UK GDPR. Processing is limited to instructions. International transfers, if any, use a lawful tool. A current list of named providers can be requested from commercial@xigamo.codes where disclosure would not create a security risk to the chamber.
Category 3: cloud object storage. XIGAMO LTD selects providers capable of supporting UK GDPR. Processing is limited to instructions. International transfers, if any, use a lawful tool. A current list of named providers can be requested from commercial@xigamo.codes where disclosure would not create a security risk to the chamber.
Category 4: managed render or GPU instances. XIGAMO LTD selects providers capable of supporting UK GDPR. Processing is limited to instructions. International transfers, if any, use a lawful tool. A current list of named providers can be requested from commercial@xigamo.codes where disclosure would not create a security risk to the chamber.
Category 5: code hosting. XIGAMO LTD selects providers capable of supporting UK GDPR. Processing is limited to instructions. International transfers, if any, use a lawful tool. A current list of named providers can be requested from commercial@xigamo.codes where disclosure would not create a security risk to the chamber.
Category 6: colour-managed review. XIGAMO LTD selects providers capable of supporting UK GDPR. Processing is limited to instructions. International transfers, if any, use a lawful tool. A current list of named providers can be requested from commercial@xigamo.codes where disclosure would not create a security risk to the chamber.
Category 7: payroll or contractor payment tools. XIGAMO LTD selects providers capable of supporting UK GDPR. Processing is limited to instructions. International transfers, if any, use a lawful tool. A current list of named providers can be requested from commercial@xigamo.codes where disclosure would not create a security risk to the chamber.
Category 8: insurers. XIGAMO LTD selects providers capable of supporting UK GDPR. Processing is limited to instructions. International transfers, if any, use a lawful tool. A current list of named providers can be requested from commercial@xigamo.codes where disclosure would not create a security risk to the chamber.
Category 9: solicitors. XIGAMO LTD selects providers capable of supporting UK GDPR. Processing is limited to instructions. International transfers, if any, use a lawful tool. A current list of named providers can be requested from commercial@xigamo.codes where disclosure would not create a security risk to the chamber.
Category 10: website hosting. XIGAMO LTD selects providers capable of supporting UK GDPR. Processing is limited to instructions. International transfers, if any, use a lawful tool. A current list of named providers can be requested from commercial@xigamo.codes where disclosure would not create a security risk to the chamber.
Accountability records
XIGAMO LTD maintains records of processing activities proportionate to a studio of this scale, including purposes, categories, recipients, retention and security measures. The record can be summarised to the Information Commissioner if required.
Training and awareness
Personnel who handle personal data receive induction on UK GDPR principles, the meaning of a passage request, and the prohibition on using client materials for unrelated demonstration without authority.
Physical premises
Premises at 3 Venics Way, High Wycombe, HP11 1LN, United Kingdom are used for meetings and lock-keeper work. Visitors should not photograph other clients’ walls. Access is by arrangement.
Bring-your-own-device
If a contractor uses a personal device, XIGAMO LTD requires encryption at rest where feasible, no forwarding of rushes to private social accounts, and remote wipe cooperation on loss.
Retention schedule method
Retention is reviewed at least annually. The lock keeper directory checks whether a chamber can be lowered and files deleted or returned.
Data minimisation in briefs
Briefs should omit unnecessary home addresses, dates of birth and special category data. If a call sheet requires them, the producer remains responsible for the source collection.
Credits and publicity
Publicity stills and credits are issued only under the production contract. Website portfolio descriptions on https://xigamo.codes use chamber codes rather than private contact details.
CCTV if installed
If CCTV is operated at 3 Venics Way, High Wycombe, HP11 1LN, United Kingdom, signage will be displayed and footage retained only for security, typically for a short rotation unless an incident is recorded.
Telephone recordings
XIGAMO LTD does not routinely record telephone calls on +44 7937 654321. If a recording is introduced, a notice will be given at the start of the call.
Equality monitoring
Equality data, if collected for a lawful reporting duty, are separated from hiring decisions except where the law requires otherwise.
Archival film scans
Scans of archive picture may include deceased persons, who are outside UK GDPR, and living extras, who remain protected. We follow the commissioning client’s chain of title and privacy warranties.
Open source contributions
Open source patches authored by XIGAMO LTD staff in the course of employment are company copyright as a default. Personal data should not be committed to public repositories.
Student attachments
Work experience attendees are not used as unpaid data processors. Any access is supervised and logged.
Press enquiries
Press questions about a living individual are not answered with private data. Direct journalists to the client’s publicist unless we are authorised.
Shareholders and Companies House
Companies House filings contain directors’ required particulars. That processing is a legal obligation and is published by the registrar, not by this Policy.
Relationship with production contracts
Where a statement of work appoints XIGAMO LTD as a processor, the processing terms in that contract control the relevant personal data. This Policy continues to describe controller processing for the website, accounts, and our own staff. If a joint-controller arrangement is needed for a co-production, the parties will set out the essence of the arrangement as required by UK GDPR Article 26, including a contact point at commercial@xigamo.codes.
Direct marketing to a named individual at a company uses a lawful basis as set out above and can be stopped by writing to commercial@xigamo.codes. We keep a suppression list so that a stopped contact is not accidentally re-filled into a later marketing sluice. The suppression list itself is personal data retained only for that purpose.
Supervisory authority and complaints handling
Internal complaints about privacy are logged by the lock keeper directory at 3 Venics Way, High Wycombe, HP11 1LN, United Kingdom. We aim to equalise the issue before a formal ICO complaint is necessary, without limiting your right to go to the Commissioner. We do not charge a fee for a rights request unless it is manifestly unfounded or excessive, in which case we may charge a reasonable fee or refuse, as UK GDPR allows. Copies of this Policy are available from https://xigamo.codes and from 3 Venics Way, High Wycombe, HP11 1LN, United Kingdom on request. Version control is by effective date at the head of the page.
Version and language
This Policy is issued in English, which is the controlling language. It applies to processing connected with https://xigamo.codes and with services supplied from High Wycombe. If a translation is later provided, the English text prevails in the event of conflict. Questions about the meaning of a waterline, chamber or gate metaphor in this Policy should be read as references to production and software process, not as a separate legal code. Write to commercial@xigamo.codes or telephone +44 7937 654321.