WEBSITE PRIVACY NOTICE
Introduction
Please read this Privacy Notice 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 visit our website (defined below) or otherwise communicate with us.
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:
Daniel Michell
data@saltandlimemedia.com
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
means individuals who engage with us to apply to feature or are successful and feature in our Agency Partners’ marketing campaigns
Website
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 submit information to us during a telephone conversation with one of our authorised representatives, we will need to collect certain personal information about You in order to respond to You.
This Privacy Notice applies to personal information we collect about You when You contact us through our Website or when You otherwise communicate with us. e.g. to make a general enquiry or if You are one of our service providers. In particular, we collect:
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- Contact data: contact information, including Your email address, Your hometown (e.g. where you live at the time of Your application to us) and Your telephone number and any other personal information that You provide to us via online chat and message boards;
- Identity data: Your first name, last name and age;
- Marketing Data: Your preferences for receiving marketing communications from us;
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- 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 such as Your IP address, Your browser type, Your operating system, Your access times, and the pages You have viewed directly before and after accessing the Website.
How Your personal information is collected
Most of the above personal information is collected directly from You, either when You contact us via our Website, (or when You otherwise communicate with us,) when we contact You via telephone , email and when we correspond with each other to exchange our casting campaign application forms shared via direct messenger and social media.
However, in addition to collecting personal information from you directly, we also collect information from cookies on our Website—for more information on our use of cookies, please see our cookie policy [insert link].
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.
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What we use Your personal information for |
Type of data |
Legal basis for processing |
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To provide our services to You. For example, to:
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For the performance of our contract with You or to take steps at Your request before entering into a contract |
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If You are communicating with us for the above reason - regarding a Talent Application, we have a separate “Talent Privacy Policy” which can be found here [link]. |
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To communicate with You e.g. to email You |
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For the performance of our contract with you |
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To prevent and detect fraud, monitor against theft, and protect against criminal activity against You or us |
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For our legitimate interest, i.e. to minimise fraud that could be damaging for You and/or us |
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To respond to Your enquiries or to process Your requests in relation to Your personal information |
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With Your consent |
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Operational reasons, such as improving efficiency, training and quality control of our Website |
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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 |
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To notify You of updates to our Websites |
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For our legitimate interests, i.e. to be as efficient as we can so we can deliver improved services to you via the Website |
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To request feedback and to contact You about Your use of our Websites |
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For our legitimate interests, i.e. to be as efficient as we can so we can deliver improved services to you via the Website |
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To resolve disputes and troubleshoot problems |
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For the performance of our contract with you |
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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 |
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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 |
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To share with third parties that perform services for us or on our behalf e.g. data analysis, email delivery, hosting services, customer service, and marketing assistance (as set out below under “who we share Your personal information with”) |
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With your consent |
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To share with our affiliates which include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us |
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For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you via the Website |
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Statistical analysis and research purposes (where the personal information is not anonymised) to:
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For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to You |
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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 |
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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.
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); or
- using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts;
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 [https://www.hostgator.com/];
- third party background check providers which we won’t use unless you are notified first and sign permission to do so separately. We use Crimcheck.net and Credence Background Screening Limited;
- software providers e.g. Google Business Suite, Dropbox, Docusign, Mail Chimp to store our work and documents and Vimeo for storing and/or sharing our content
- we 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.
When it is no longer necessary to retain Your personal information, we will delete or anonymise it.
Individuals in the UK and the EEA - 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 Dropbox whose data centres are 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 information (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 information 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 information to do not have the benefit of an adequacy decision. This does not necessarily mean they provide poor protection for personal information, but we must look at alternative grounds for transferring the personal information, such as ensuring appropriate safeguards are in place, including using standard contractual clauses.
Where there is no adequacy decision, we may transfer Your personal information 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 information 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 information on this ground.
Your rights
You have the following rights, which You can exercise free of charge:
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Access |
The right to be provided with a copy of Your personal information (the right of access) |
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Rectification |
The right to require us to correct any mistakes in Your personal information |
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Erasure (also known as the right to be forgotten) |
The right to require us to delete Your personal information—in certain situations. |
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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 |
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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 |
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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 |
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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 |
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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 - Individuals in the UK and the EEA
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 Notice
This privacy notice was published and last updated on 20th January, 2023.
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.
Global Contact
info@saltandlimemedia.com
