CREATOR & TALENT PRIVACY POLICY

Introduction

Please read this Creator / Talent privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information when you submit an application to us, to be considered as a creator or as “talent,” to feature in a media, advertising or marketing campaign for any of our clients.

It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal information about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to services we offer to individuals and our wider operations in the European Economic Area (EEA). 

It would be helpful to start by explaining some key terms used in this policy:

We, us, our	Salt and Lime Media Incorporated at 401 Ryland St., STE 200-A, Reno , NV 89502 USA.
Agency Partners	Means our clients, for whom we scout and obtain Content Creators, Talent and prospective real people for media and marketing campaigns
Our data protection officer	Daniel Michell data@saltandlimemedia.com
Personal information	Any information relating to an identified or identifiable individual
Special category personal information	Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic and biometric data (when processed to uniquely identify an individual) Data concerning health, sex life or sexual orientation
Talent	Individuals (like yourself) who submit an application to us,or  attend an interview (if we have approached you) or agree to being pitched, represented or featured in our Agency Partners’ media productions or marketing campaigns
Website	means our website (https://saltandlimemedia.com)
You or Your	an individual end-user of our Website or an individual that otherwise interacts with us

Personal information we collect about you

If you contact us through our Website or via application forms that we link to (such as https://docs.google.com/forms/), via email / social media messages or following a telephone conversation with one of our authorised representatives regarding a Creator or Talent application, we will need to collect certain personal information about you in order to process your application. 

This privacy policy applies to personal information we collect about you when you contact us through our Website or when you otherwise communicate with us about a Talent application (including our google forms at https://docs.google.com/forms/...). In particular, we may collect:

• • Contact data: contact information, including your email address, your hometown (e.g. where you live at the time of your application to us), telephone number, any social media accounts held by you.. In limited circumstances, if you have been booked as Creator/Talent, we may need to collect your residential address (e.g. your registered home address), tax details and payment/bank account details. We will not ask for your residential address, tax or financial details for casting, interviewing or audition purposes.
  • Identity data: your first name, last name, age, social handles, biographical information related to the production, resume / credit list and a photograph for ID purposes  (your face or videos of you);

• Marketing Data: your preferences for receiving marketing communications form us;

• • Sensitive Data: Please see the sensitive data we collect as detailed in the section below, titled “Sensitive Data”; and

• Technical Data: technical and usage information about how you use the Website.

How your personal information is collected

Any of the above information could be collected directly from you supplying it to us, either when you submit an application form via our Website or Application form, or  when we contact you via telephone, video call or email; or when we correspond with each other via direct social media messages. However, we may also collect information for:

• third party vendor production partners
• sanctions screening providers, social and public criminality searches; global sanctions, watchlist searches and Crimcheck searches; (only occasionally applicable and will be approved by you in the form of additional signed agreements) collectively referred to as “Background Checks”; and
• manual social, web and news searches conducted by our staff for the purposes of casting, pitching and storytelling 
• from cookies on our Website—for more information on our use of cookies, please see our cookie policy.

How and why we use your personal information

Under data protection law, we can only use your personal information if we have a proper reason, e.g.:

• where you have given consent;
• to comply with our legal and regulatory obligations;
• for the performance of a contract with you or to take steps at your request before entering into a contract; or
• for our legitimate interests or those of a third party.

A legitimate interest is when we have a business or commercial reason to use your personal information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own.

The table below explains what we use (process) your personal information for doing so. In some cases, we may use more than one legal basis for processing your personal information; this will depend on the specific purpose for which you are using your personal information. 

What we use your personal information for	Type of data	Legal basis for processing
To provide our services to you. For example, to:  consider your application against the brief provided by our clients and Agency or Production Partners’ to be considered as “Talent”; conduct interviews with you for the purpose of your application; notify you as to whether you have been selected; negotiate contracts and secure releases where you are selected for a Media Production or Marketing Campaign by one of our Agency or Production Partners;  complete any required paperwork and to close engagements post production; and  resolve disputes and troubleshoot problems;  inform you of updates to our Website; and to contact you about future campaigns or productions with our Agency or Production Partners which might be of interest to you (via alerts)	Identity data Contact data	For the performance of our contract with you or to take steps at your request before entering into a contract
To verify your identity if your application is selected	Identity Data	For the performance of our contract with you
As above, to conduct Background Checks via third parties	Identity data Contact data
To communicate with our clients who are networks, production companies, creative agencies and brand marketing or media managers to submit and process your application	Identity data Contact data	For the performance of our contract with you or to take steps at your request before entering into a contract
Preventing and detecting fraud, monitor against theft, and protect against criminal activity against you or us	Identity data Contact data Profile data Technical data	For our legitimate interest, i.e. to minimise fraud that could be damaging for you and/or us
To respond to your enquiries or to process your requests in relation to your information	Identity data Contact data	With your consent
Operational reasons, such as improving efficiency, training and quality control	Identity data Contact data Profile data Technical data	For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price
Statistical analysis and research purposes (where the personal information is not anonymised) to: help us manage our business, e.g. to maintain feedback trackers and details of individuals being sourced and contacted by us; and  generate a personal profile about you.	Identity data Contact data Profile data	For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you.
Marketing our services to our existing and former Talent.	Identity data Contact data Profile data Marketing data	For our legitimate interests, i.e. to promote our business to existing and former customers.
To share your personal information with members of our group (e.g. any parent companies or subsidiaries) and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency In such cases information will be anonymised where possible and only shared where necessary	Identity data Contact data Demographic data Profile data Marketing Data	Depending on the circumstances, to comply with our legal and regulatory obligations and in other cases, for our legitimate interests, i.e. to protect, realise or grow the value in our business and assets.
Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, e.g. to record and demonstrate evidence of your consents where relevant	Identity data Contact data Profile data	To comply with our legal and regulatory obligations.

Special category personal information

Certain personal information we collect is treated as a special category to which additional protections apply under data protection law, such as:

• personal information revealing racial or ethnic origin; and 
• personal information concerning health, sex life or sexual orientation.

Where we process special category personal information, we will also ensure we are permitted to do so under data protection laws, e.g.:

• we have your explicit consent;
• the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
• the processing is necessary to establish, exercise or defend legal claims.

Marketing

We may use your personal information to send you updates (by email or text message) about our services, including the launch of new services and promotions related to such services.

We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you marketing communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never share it with other organisations outside the Salt and Lime Media Inc group for marketing purposes.

You have the right to opt out of receiving marketing communications at any time by contacting us using the details below (see the ‘How to contact us’ section).

We may ask you to confirm or update your marketing preferences if you instruct us to provide further  services in the future, or if there are changes in the law, regulation, or the structure of our business.

Who we share your personal information with

We share your personal information with:

Third party service providers: who help us run our business efficiently, such as our Website host, “HostGator”, and our other business service providers such as Dropbox, Docusign, Vimeo and Google when you share your initial application with us; 

We will not share your personal information with any other party, unless it is necessary to book you as a Creator or Talent or your personal information needs to be shared with our Agency, client or production partners for the purpose of the casting pitch or storytelling. Once we pitch you and/or your story you share with us to our Client, Agency or Production partners for consideration or you are booked as Talent, we may share your personal information with our third party background check provider, Crimcheck.net  or Credence Background Screening Limited (with your additional written permission. 

We  could disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations. 

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a restructuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

We will not share your personal information with any other third party.

How long your personal information will be kept

We will not keep your personal information for longer than necessary for the purposes set out in this privacy policy. Thereafter, we will keep your personal information for as long as is necessary:

• to respond to any requests, questions, complaints or claims made by you or on your behalf;
• to show that we treated you fairly; and
• to keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this privacy notice. 

When it is no longer necessary to retain your personal information, we will delete or anonymise it.

Transferring your personal information out of the UK

To deliver services to you, it is sometimes necessary for us to share your personal information outside the UK, for example:

• where your and our service providers whose servers may be located outside the UK (for example, we may use Dropbox (when you first send us your Talent application). Dropbox have servers located across the United States; or
• if you are based outside the UK;

Under data protection law, we can only transfer your personal information to a country or international organisation outside the UK where:

• the UK government has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy decision’); or
• there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects; or
• a specific exception applies under data protection law.

We may transfer your personal data to certain countries, on the basis of an adequacy decision. These include: all European Union countries, plus Iceland, Liechtenstein and Norway (collectively known as the ‘EEA’); Gibraltar; and Andorra, Argentina, Canada, Faroe Islands, Guernsey, Israel, Isle of Man, Japan, Jersey, New Zealand, Switzerland and Uruguay.

The list of countries that benefit from adequacy decisions will change from time to time. We will always seek to rely on an adequacy decision, where one exists.

Other countries or international organisations we are likely to transfer personal data to do not have the benefit of an adequacy decision. This does not necessarily mean they provide poor protection for personal data, but we must look at alternative grounds for transferring the personal data, such as ensuring appropriate safeguards are in place, including using standard contractual clauses.

Where there is no adequacy decision, we may transfer your personal data to another country or international organisation if we are satisfied the transfer complies with data protection law, appropriate safeguards are in place, and enforceable rights and effective legal remedies are available for data subjects. The safeguards will usually include using legally-approved standard data protection contract clauses.

In the absence of an adequacy decision or appropriate safeguards, we may transfer personal data to a third country or international organisation where an exception applies under relevant data protection law, including:

• you have explicitly consented to the proposed transfer after having been informed of the possible risks;
• the transfer is necessary for the performance of a contract between us or to take pre-contract measures at your request;
• the transfer is necessary for a contract in your interests, between us and another person; or
• the transfer is necessary to establish, exercise or defend legal claims.

We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal data on this ground.

Your rights

You have the following rights, which you can exercise free of charge:

Access	The right to be provided with a copy of your personal information (the right of access).
Rectification	The right to require us to correct any mistakes in your personal information.
Erasure (also known as the right to be forgotten)	The right to require us to delete your personal information—in certain situations.
Restriction of processing	The right to require us to restrict processing of your personal information in certain circumstances, e.g. if you contest the accuracy of the data.
Data portability	The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object	The right to object: —at any time to your personal information being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal information, eg processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
The right to withdraw consents	If you have provided us with a consent to use your personal information you have a right to withdraw that consent easily at any time You may withdraw consents by contacting data@saltandlimemedia.com Withdrawing a consent will not affect the lawfulness of our use of your personal information in reliance on that consent before it was withdrawn

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.

If you would like to exercise any of those rights, please:

• contact us using the details below (see the ‘How to contact us’ section); and
• let us have enough information to identify you;
• let us know what right you want to exercise and the information to which your request relates.

Keeping your personal information secure

We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your personal information will do so only in an authorised manner and are subject to a duty of confidentiality. 

We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you want detailed information from Get Safe Online on how to protect your personal information and other 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.

How to complain

We hope that we can resolve any query or concern you may raise about our use of your information. 

The UK General Data Protection Regulation also gives you right to lodge a complaint with the  Information Commissioner (which is the supervisory authority in the UK). The Information Commissioner may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.

Changes to this privacy policy

This privacy notice was published on January 19th 2023 and last updated on January 19th 2023.

We may change this privacy notice from time to time—when we do we will inform you e-mail.

How to contact us - Individuals in the UK and the EEA

We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact.

Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal information). If you want to contact us via our representative Prighter or make use of your data subject rights, please visit the following website. https://prighter.com/q/18905945.