New Frames 2026 — Competition Privacy Notice
Last updated: 30 September 2026
1. Who is responsible for your data?
European Generative Film Association MTÜ (EuGFA) organises New Frames and is responsible for the personal data described in this notice.
- Registered address: Käspre tee 7, Tabasalu alevik, Harku vald, Harju maakond 76901, Estonia
- Email for privacy requests: info@eugfa.org
This notice covers competition entries, judging, shortlisted films, public voting, prize payments and related communications.
For team entries, the lead entrant is asked to share this notice with every other team member before submitting their public name and role.
2. What information do we collect?
Depending on your involvement in New Frames, we collect:
| People | Information |
|---|---|
| Lead entrant | Legal name, chosen public name (which may differ), email address, confirmation that they and every team member are at least 18, educational institution, team role or credit, country of study if they choose to provide it, and confirmation that each team member agreed to enter, to have their public name and credit shown, and to grant EuGFA the screening and promotion licence in the competition rules. |
| Other credited team members | Chosen public names and team roles. EuGFA does not collect their email addresses or separate age confirmations. |
| Entrants | The uploaded film, film title, category, credits, short synopsis, uploaded film still or poster image, English subtitles embedded in the video where required, confirmation that the entrant has the rights and permissions needed to submit and publicly screen the film, and communications about the entry. Release forms are not collected with the entry. |
| Entrants | Production & Technology Form answers about AI tools and models, software, hardware, production methods and technical difficulties. Jurors use the form to understand how the film was made, and EuGFA may also use the answers for research as described below. |
| Prize winners | The lead entrant's school-issued email address and a record that they completed an email verification link or code, the account holder name and IBAN needed to pay a prize by SEPA bank transfer, and their country of tax residence. The account holder name must match the lead entrant's legal name. EuGFA does not ask winners for a foreign tax identification number. EuGFA may need an Estonian personal identification code or non-resident code, or evidence of tax residence, if required for tax reporting. It will request any additional document only from an affected winner. |
| Public voters | Their vote, IP address and a voting cookie, used to enforce the one-vote limit and check for fraud. The voting cookie expires when public voting closes on 14 November 2026. Voters do not provide an email address, and the voting application does not intentionally store browser or device details. Website and security providers may process connection information separately to operate and protect the site. |
| People who contact us | Their message and contact details, together with information needed to respond. |
Films may contain the image, voice or other personal information of performers and other identifiable people. Entrants must have the rights and permissions required by the competition rules. People appearing in a submitted film may contact us using the address above about EuGFA's use of that film.
3. Why do we use this information?
| Purpose | Legal basis |
|---|---|
| Receive entries, communicate with lead entrants, check eligibility, organise judging and administer awards | Performance of the competition agreement with the lead entrant, GDPR Article 6(1)(b). |
| Process other team members' public names and roles and information about identifiable people appearing in submitted films | EuGFA's legitimate interest in running, judging, screening and promoting the competition, GDPR Article 6(1)(f). Entrants are responsible for obtaining the permissions required by the competition rules. |
| Detect duplicate entries, inaccurate eligibility claims and voting manipulation | EuGFA's legitimate interest in running a fair competition, GDPR Article 6(1)(f). |
| Screen and publish shortlisted films, stills, excerpts, titles and the lead entrant's chosen public name as described in the competition rules | Performance of the competition agreement with the lead entrant, GDPR Article 6(1)(b). |
| Record and check public votes for the Viewers' Favourite award | EuGFA's legitimate interest in running a fair public vote and preventing duplicate or fraudulent votes, GDPR Article 6(1)(f). |
| Pay prizes | Performance of the competition agreement with the winning lead entrant, GDPR Article 6(1)(b). |
| Keep records required by accounting or tax law | Compliance with legal obligations, GDPR Article 6(1)(c). |
| Analyse Production & Technology Form answers across the 2026 and later New Frames editions and publish combined findings about filmmaking workflows and technical challenges | EuGFA's legitimate interest in understanding student filmmaking methods and improving the competition, GDPR Article 6(1)(f). EuGFA checks published findings so they do not identify individual entrants. |
| Contact lead entrants about marketing | Consent, GDPR Article 6(1)(a), collected through a separate optional choice in the entry form. Refusing or withdrawing consent does not affect eligibility or judging. |
We will not use the Production & Technology Form to give higher scores to entrants who use particular tools or expensive equipment. The competition rules describe how films are judged.
4. What will be public?
EuGFA will publish every shortlisted film for viewing and voting at eugfa.org/newframes. It may also publish full shortlisted films on its social media accounts. Film titles, short synopses, submitted stills or posters, excerpts and filmmakers' chosen public names or credits may appear on its website, social media accounts and at competition events, as allowed by the competition rules. If the lead entrant provides their country of study, it will be shown only if they choose that option in the entry form. No other personal profile details will be published as part of the competition.
The lead entrant's legal name and educational institution, their country of study unless they choose to display it, entry contact details, student evidence, payment information, private communications and individual Production & Technology Form answers will not be published as part of the competition.
5. Who can access the information?
EuGFA staff and authorised organisers access information needed for their roles. Jurors receive a separate export containing the entry materials, the lead entrant's educational institution and Production & Technology Form answers needed to assess films; EuGFA does not give them entrants' legal names, email addresses or country of study. Jurors do not receive access to the master spreadsheet. Credits within a submitted film may still identify its makers. Outside researchers do not receive individual Production & Technology Form answers. Service providers may process information for submission, storage, email, voting, website hosting or payment on EuGFA's behalf.
Uploaded films, stills and posters are stored in Amazon S3 in the Frankfurt AWS region (eu-central-1). Google Sheets stores entry form details and Production & Technology Form answers, and Google Workspace/Gmail handles competition email. The website is hosted on Cloudflare Workers. EuGFA's bank processes SEPA prize payments. No partner or co-organiser receives entrant or voter data for its own purposes. EuGFA will identify the service used to store voting records before public voting opens.
EuGFA may disclose information when required by law or when necessary to establish, exercise or defend a legal claim.
6. Is information transferred outside the European Economic Area?
EuGFA staff and organisers who handle entries work from within the EEA, and uploaded media is stored in AWS's Frankfurt region. The other named providers may process or allow access to personal data outside the EEA through their international operations and support services. Where such access is an international transfer under data protection law, EuGFA uses the transfer safeguards in the relevant provider agreement, including European Commission standard contractual clauses where applicable. Contact info@eugfa.org for information about the safeguards relevant to your data and how to obtain a copy.
The jury has not yet been appointed. If a juror outside the EEA is selected, EuGFA will establish an appropriate transfer basis before sharing entry information with that juror and update this notice.
7. How long do we keep information?
| Information | Retention period or deletion rule |
|---|---|
| Entries that are not shortlisted | The films, uploaded images and entry administration details are deleted on 15 December 2026, unless specific records must be kept longer to meet a legal obligation or resolve an open claim. The minimum identifiers needed to keep Production & Technology Form answers linked for ongoing research, and optional marketing contacts, follow the separate rules below. |
| Shortlisted films | These may remain publicly available after 2026 while EuGFA uses them to document and promote New Frames. EuGFA decides whether to keep publishing a film under the competition licence and reviews removal requests in line with applicable law. EuGFA removes its public copies when it no longer uses the film for these purposes. |
| Public competition pages | Pages with titles, credits, synopses and results may remain online while EuGFA publishes the related film. If EuGFA removes a film from its public channels, it also removes that film's public entry and result details. |
| Winner eligibility check | The lead entrant's school email address and verification record are deleted on 15 November 2029, unless needed for an open claim; records needed for that claim are deleted after it is resolved. |
| Voting records and fraud-prevention data | The voting cookie expires when public voting closes on 14 November 2026. Stored votes and IP addresses are deleted on 15 December 2026, unless a voting dispute is still open; records needed for that dispute are deleted after it is resolved. |
| Prize-payment and tax records | Accounting source documents and records needed to reconstruct a prize payment are kept for seven years from the end of the financial year in which the payment was recorded, as required by Estonian accounting law. Any other winner details are kept only while needed to pay the prize, complete applicable reporting or resolve an open claim. |
| Production & Technology Form answers | EuGFA keeps answers linked to entrants while it needs that link for research on student filmmaking methods and technology use across New Frames editions. When the link is no longer needed for that research, EuGFA anonymises the answers or deletes them. Anonymous research findings may be retained. |
| Optional marketing contact choice | The email address and marketing consent record stay on the mailing list until the person unsubscribes. EuGFA then removes them from the mailing list and does not keep a separate suppression record. |
EuGFA may keep specific records longer if needed to meet a legal obligation or resolve an open claim. It will limit that extended retention to the records needed for that purpose and remove them when the obligation or claim ends, unless another legal retention period applies.
8. What must you provide?
The entry form will identify the information required to enter. Without required entry details, a film and the Production & Technology Form, EuGFA cannot accept the entry. The lead entrant of a winning entry must verify a school-issued email address using a link or code and provide the information needed to pay the prize. The lead entrant's marketing contact choice is optional and separate from entry.
9. Your rights
Depending on the circumstances, you may ask EuGFA to give you access to your personal data, correct it, erase it, restrict its use, provide a portable copy or stop processing based on legitimate interests. If EuGFA relies on your consent, you may withdraw it at any time without affecting processing that took place before withdrawal. Some rights have legal limits; EuGFA will explain any refusal.
Send requests to info@eugfa.org. You may also complain to the Estonian Data Protection Inspectorate or another competent data protection authority.
10. Automated decisions
Humans make the final decisions about eligibility, the shortlist and prize winners. EuGFA does not make those decisions solely by automated processing. The voting system automatically rejects votes it identifies as duplicates or fraudulent, without review by a person before rejection.
11. Changes to this notice
EuGFA will update this notice when competition processes or service providers change. The date at the top shows when it was last updated. If a change materially affects information already submitted, EuGFA will inform affected people where required.