Privacy Policy

Definitions and Interpretation

1. In this Privacy Policy, the following definitions are used:

   Data

   collectively all information that you submit to Studio Santa via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;

   Cookies

   a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);

   Data Protection Laws

   any applicable law relating to the processing of personal Data, including but not limited to the GDPR, and any national implementing and supplementary laws, regulations and secondary legislation;

   GDPR

   the UK General Data Protection Regulation;

   Studio Santa, we or us

   Studio Santa, a trading name of Cavoria Limited, a company registered in England and Wales under company number 17434586, whose registered office is at 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, contactable at hello@studiosanta.co.uk;

   UK and EU Cookie Law

   the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011 and the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2018;

   User or you

   any third party that accesses the Website and is not either (i) employed by Studio Santa and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Studio Santa and accessing the Website in connection with the provision of such services; and

   Website

   the website that you are currently using, www.studiosanta.co.uk, and any sub-domains of this site, unless expressly excluded by their own terms and conditions.

2. In this Privacy Policy, unless the context requires a different interpretation:
   1. the singular includes the plural and vice versa;
   2. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this Privacy Policy;
   3. a reference to a person includes firms, companies, government entities, trusts and partnerships;
   4. “including” is understood to mean “including without limitation”;
   5. reference to any statutory provision includes any modification or amendment of it;
   6. the headings and sub-headings do not form part of this Privacy Policy.

Scope of this Privacy Policy

3. This Privacy Policy applies only to the actions of Studio Santa and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website, including, but not limited to, any links we may provide to social media websites.
4. For purposes of the applicable Data Protection Laws, Cavoria Limited — trading as Studio Santa — is the “data controller”. This means that Cavoria Limiteddetermines the purposes for which, and the manner in which, your Data is processed. You can write to us at 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, or email hello@studiosanta.co.uk.

Data Collected

5. 1. name;
   2. gender;
   3. contact information such as email addresses and telephone numbers;
   4. IP address (automatically collected);
   5. web browser type and version (automatically collected);
   6. operating system (automatically collected);
   7. your child’s first name, age, the town where they live, their interests, something they have achieved this year and what they would like for Christmas;

   in each case, in accordance with this Privacy Policy.

Information about your child

How We Collect Data

6. 1. data is given to us by you; and
   2. data is collected automatically.

Data That is Given to Us by You

7. 1. when you contact us through the Website, by telephone, post, e-mail or through any other means;
   2. when you register with us and set up an account to receive our products/services;
   3. when you make payments to us, through this Website or otherwise;
   4. when you elect to receive marketing communications from us;
   5. when you use our services;

   in each case, in accordance with this Privacy Policy.

Data That is Collected Automatically

8. 1. our hosting and security providers keep server logs, which record your IP address and the date and time of the requests your browser makes to the Website. These are used to keep the Website running and secure;
   2. we count visits to each page using Vercel Web Analytics, so that we can see which parts of the Website people find useful. It does not use cookies, does not store anything on your device and does not follow you across other websites. It does not build a profile of you, and we cannot use it to identify you;
   3. we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed “Cookies”.

Our Use of Data

9. 1. internal record keeping;
   2. improvement of our products / services;
   3. transmission by email of marketing materials that may be of interest to you;
   4. to write the script and produce the personalised Santa video that has been ordered, to deliver it and let you download it, and to deal with your order enquiries and any refunds;

   in each case, in accordance with this Privacy Policy.

10. We may use your Data for the above purposes if we deem it necessary to do so for our legitimate interests. If you are not satisfied with this, you have the right to object in certain circumstances (see the section headed “Your rights” below).
11. For the delivery of direct marketing to you via e-mail, we’ll need your consent, whether via an opt-in or soft-opt-in:
    1. soft opt-in consent is a specific type of consent that applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under “soft opt-in” consent, we will take your consent as given unless you opt-out.
    2. for other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we’ll provide.
    3. if you are not satisfied with our approach to marketing, you have the right to withdraw consent at any time. To find out how to withdraw your consent, see the section headed “Your rights” below.
12. When you register with us and set up an account to receive our services, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

Who We Share Data With

13. 1. third party service providers who provide services to us which require the processing of personal data — to write the scripts and produce the personalised video that has been ordered, and to host the website, store the finished video and send order emails;
    2. third party payment providers who process payments made over the Website — to take payment for orders and process any refunds;
    3. relevant authorities — to comply with a legal obligation, a court order or a lawful request;
    4. partner businesses using a Studio Santa branded storefront — so the partner business whose storefront was used to place the order can see and manage the order they referred;

    in each case, in accordance with this Privacy Policy.

    The service providers referred to in clause 13(a) and (b) are, at the date of this policy:

    Company	What it receives	Where
    OpenAI	Your child's details, to write the three scripts	United States
    HeyGen	The approved script, to record Santa saying it	United States
    Supabase	Your account, your order and your child's details (our database)	Ireland (EU)
    Cloudflare R2	The finished video file	See clause 23
    Resend	Your email address, and the emails we send you	Ireland (EU)
    Stripe	Your payment. Card details go to Stripe and never reach us	EU / United States
    Vercel	Hosting for the website, and visitor numbers (see clause 8)	See clause 23
    Railway	The service that renders your video	See clause 23

    Santa’s face and voice are created with licensed AI performers. The words, and the child they are for, come from you.

    On whether these companies learn from your information: neither of them does. OpenAI, which writes the scripts, does not use anything sent through its interface to train its models, and deletes it within 30 days. HeyGen, which records the video, confirmed in writing on 31 August 2026 that our account is excluded from data training entirely — in their words, that your data will not be used in any way to train or improve their models. That is a change from their standard terms, which do reserve that right, and we asked for it precisely because these videos are made for children.

    TO SUPPLY: The HeyGen opt-out is held in writing (support email, 31 August 2026) and the stronger wording above now reflects it. Keep re-checking both providers’ terms — this is a promise about children’s data and it has to stay true, not merely have been true. Last checked 2 September 2026.

Keeping Data Secure

14. 1. access to your account is controlled by a password and a user name that is unique to you.
    2. we store your Data on secure servers.
15. Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: hello@studiosanta.co.uk.
16. If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Data Retention

17. Unless a longer retention period is required or permitted by law, we will only hold your Data on our systems for the period necessary to fulfil the purposes outlined in this Privacy Policy or until you request that the Data be deleted.
18. Even if we delete your Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

Your Rights

19. 1. Right to access— the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive”. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.
    2. Right to correct — the right to have your Data rectified if it is inaccurate or incomplete.
    3. Right to erase — the right to request that we delete or remove your Data from our systems.
    4. Right to restrict our use of your Data — the right to “block” us from using your Data or limit the way in which we can use it.
    5. Right to data portability — the right to request that we move, copy or transfer your Data.
    6. Right to object — the right to object to our use of your Data, including where we use it for our legitimate interests.
    7. Right to complain — the right to raise a complaint with us directly about how we handle your Data.
20. To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: hello@studiosanta.co.uk.
21. If you have a complaint about how we handle your Data, please contact us in the first instance via this e-mail address: hello@studiosanta.co.uk. We will acknowledge your complaint within 30 days, investigate and respond without undue delay and inform you of the outcome.
    1. If you are not satisfied with the way your complaint is handled by us, you may refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.
22. It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

Transfers Outside the United Kingdom and European Economic Area

23. Data which we collect from you may be stored and processed in and transferred to countries outside of the UK and European Economic Area (EEA). For example, this could occur if our servers are located in a country outside the UK or EEA or one of our service providers is situated in a country outside the UK or EEA. In particular, the providers named under clause 13 that are located in the United States will receive the Data described in that table, including your child’s details.
24. We will only transfer Data outside the UK or EEA where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example by way of a data transfer agreement incorporating the UK International Data Transfer Agreement, or the UK Addendum to the standard contractual clauses adopted by the European Commission.
25. To ensure that your Data receives an adequate level of protection, we have put in place appropriate safeguards and procedures with the third parties we share your Data with. This ensures your Data is treated by those third parties in a way that is consistent with the Data Protection Laws.

Links to Other Websites

26. This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This Privacy Policy does not extend to your use of such websites. You are advised to read the Privacy Policy or statement of other websites prior to using them.

Changes of Business Ownership and Control

27. Studio Santa may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Studio Santa. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the Data for the purposes for which it was originally supplied to us.
28. We may also disclose Data to a prospective purchaser of our business or any part of it.
29. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

Cookies

30. This Website may place and access certain Cookies on your computer. Studio Santa uses Cookies to operate the Website and to improve your experience of using it. Studio Santa has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.
31. All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.
32. The Website does not set any advertising, analytics or tracking Cookies. Every Cookie it does set is either strictly necessary for the Website to work or is there to provide a feature you have asked for, and Cookie Law does not require us to ask your consent for those. The page-counting described in clause 8 uses no Cookies and stores nothing on your device. Because of all this, the Website does not show a cookie consent banner and there is nothing for you to accept or decline. If we ever introduce Cookies that do require consent, we will ask for it before setting them and update this Privacy Policy.
33. This Website may place the following Cookies:

    Type of Cookie	Purpose
    Strictly necessary cookies	These are cookies that are required for the operation of our website. They include, for example, the cookies that let you log in to your account and stay logged in.
    Functionality cookies	These are used to remember choices you have already made, so that a feature works the way you would expect. On this Website that means remembering what you have typed into the order form so you do not lose it part-way through.

34. You can find a list of Cookies that we use in the Cookies Schedule below.
35. You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies, but this can be changed. For further details, please see the help menu in your internet browser. You can switch off Cookies at any time, however, you may lose any information that enables you to access the Website more quickly and efficiently.
36. You can choose to delete Cookies at any time; however, you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
37. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.
38. For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.

General

39. You may not transfer any of your rights under this Privacy Policy to any other person. We may transfer our rights under this Privacy Policy where we reasonably believe your rights will not be affected.
40. If any court or competent authority finds that any provision of this Privacy Policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Privacy Policy will not be affected.
41. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
42. This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

Changes to This Privacy Policy

43. Studio Santa reserves the right to change this Privacy Policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the Privacy Policy on your first use of the Website following the alterations.

Cookies Schedule