October 2, 2017

Privacy Policy

Privacy Policy

Spotlight is committed to protecting the privacy of ProFile’s users. This Privacy Policy sets out the type of personal information that we collect, what it is used for and the rights you have in relation to this information. By using the ProFile Site you accept the terms of this Privacy Policy.

If you are a Parent or Guardian of a young performer/child you are a third party acting on behalf of your child and it is your responsibility to inform the child of their rights and to act solely in your child’s best interests. This Privacy Policy has been written in a way to be accessible to children, but if there is anything you or your child does not understand, please contact the Data Protection Officer. Changes to this Privacy policy

We keep this Privacy policy under regular review and may change this policy occasionally by updating this page. Where practical we will notify you of changes to this Policy and prompt you to review these. However, you should, therefore, check this page from time to time to ensure that you are happy with any changes. Your continued access and use of this site will mean that you agree to our current Privacy Policy. Please note that Privacy Policies contain specific information regarding how companies process your sensitive personal information, and also information to set out the circumstances under which they may transfer data outside the European Economic Area. By using our site and our services you consent to us processing your personal information as set out in our Privacy Policy and within your related Terms.

This Privacy policy was last updated on 11th May 2018.

Definitions

In this Privacy Policy:

“you” means the user of our website or the Spotlight Services,

“we/us/Spotlight” means [Spotlight], whose trading address and registered office is 7 Leicester Place, London WC2H 7RJ. VAT Number 239068741. Registered in England and Wales, Company Number 07172054,

“Services” means any of the services available from Spotlight, and

“Site” means the site located at profileperformers.com.

Spotlight as your Data Controller

Spotlight is your Data Controller. Spotlight has a Data Protection Officer who can be contacted via data.protection@spotlight.com or by writing to Data Protection Officer, 7 Leicester Place, London WC2H 7RJ.

We regard the lawful and correct treatment of your personal information by us as very important to our business. To this end we fully endorse and adhere to data protection law across Europe in the form of the General Data Protection Regulation (GDPR) and the equivalent data protection law in the UK. As your Data Controller, Spotlight has notified its activities to the Office of the Information Commissioner as required under the Data Protection Act 1998 and can be found in the Data Protection Public Register.

Relationships when Spotlight is not your Data Controller

If you are a Spotlight Member please note that your agent (if you are represented) or training establishment may also act as your Data Controller both for the supply of your information to Spotlight and its use in submissions made by your Agent on your behalf via The Spotlight Link, and additionally for any third party tools your Agent or training establishment may employ to administer your data. It is your responsibility to ensure that your Agent or training establishment only processes your personal data in accordance with your wishes.

How we make sure your data is used lawfully?

We will only collect, use, store, share (and any other of the defined uses of processing data) where there is a lawful basis as defined by data protection legislation, and do not collect more information than we need to fulfil the purpose. We document what lawful bases are relied upon for our processing activities. Lawful bases include where you have given consent, where processing is necessary for the performance of a contract with you, when complying with the law and where there are legitimate interests. More information on how we use these lawful bases is provided below:

  • Consent – In certain situations, we can process your data with your consent. Where we process data based on consent, we will ask you for your explicit consent (you have to take an action) which you can withdraw at any time, but it will not affect the lawfulness of processing before then.
    • For example, you ticking a box to receive marketing communication from us.
  • Contract – In certain situations, we need your personal information to comply with our contractual obligations. Where we rely on contract, we will ask you to agree to the use of your personal data necessary for entering into or the performance of your contract with us.
    • For example, by becoming a ProFile member we will collect information about you so we can deliver the service to you.
  • Complying with the law – we may need to process your personal information if the law requires us to.
    • For example, we may have to pass on information of people in fraud or other criminal activity to law enforcement,
  • Legitimate interest – We will only rely on legitimate interests where the processing of your data is not overridden by your interests or rights and freedoms. This means that we may need your information and use in a way that can reasonably be expected as part of us running Spotlight and does not materially impact your rights, freedoms or interests.
    • For example, we may use your information to build a more accurate picture of you to better inform our business decisions.

When do we collect your personal information?

We will collect personal information from you when you complete an application or contact form or use our Site.

What personal information do we collect?

We will only ever ask you for the necessary information needed to process your data. We may process data including the following personal information about you, where supplied: Name, gender, date of birth, address(es), email, telephone number(s), information pertaining to disability and ethnicity, IP address, photographs, video and audio clips and career history.

How will we use your personal information?

We (or third party data processors acting on our behalf) may collect, store, use and share your personal information for the following purposes:

  • to keep your details and records up-to-date and accurate;
  • to answer your enquiries or otherwise communicate with you,
  • to provide you with important service communications
  • internal record keeping,
  • to notify you of other products and/or services that we think will be of interest to you (you can unsubscribe from these communications at any time), and
  • to develop, test and improve our sites, services and products that we provide to you;
  • to comply with any legal obligation such as to share data with law enforcement.

What personal information do we share?

We sometimes share personal information with carefully selected and trusted third parties. Wherever possible only information contained within your public profile would be released to such third parties. To keep your data safe and maintain your privacy we have the following approach:

  • We implement appropriate legal, procedural and technical controls;
  • We only provide the information they need to undertake that service;
  • They can only use the information for that specific purpose;
  • We maintain a close relationship to make sure that your data is protected and your privacy maintained;
  • We mandate that if or when the service stops, they must return or delete any information held.

Here are the examples of the types of trusted third parties we work with:

  • IT companies who help us deliver our sites and services;
  • third parties who provide service enhancements or additional functionality to our users related to how they use our services.
    • More information: In order to facilitate certain users of Spotlight with their workflow management processes or other functionality, Spotlight may from time to time provide or authorise the use of certain third party software or applications to facilitate additional off-site access to the professional materials and content otherwise available via the Services. An example of this would be third-party tools used by Agents to administer their client submissions to casting services alongside diary management etc. Such third-party packages or systems should only be used subject to the written approval of Spotlight. You acknowledge that your personal information may be used in this way. Please note however that Spotlight does not endorse and is therefore not responsible for any such third-party packages or systems, and Spotlight will not be liable for any loss of information, materials, data or otherwise that may occur due to the use of your information within them.
  • third parties who are involved in furthering research and technology in areas connected with our service.
    • More information: We are constantly looking for new ways to change and upgrade our Services and functionality. This may involve partnering with selected and trusted research organisations and technology providers to contribute to their research and innovation projects. Often the most innovative developments come from other industries or fields of research outside of our own, and the outputs of the research may have a broader application beyond the improvements from which we directly benefit. As part of this research, our trusted partners may be given access to our systems and data and/or be provided with copies of our data, including member photos, video and audio clips, and other professional information from their public profile. In all such circumstances, our partners’ access to and use of this information will be comprehensively documented and strictly limited to specific research projects that may include benefits for Spotlight and our Services to you, and will be under secure, confidential, temporary conditions, and closed testing environments. Under no circumstances will this information be used for any commercial or live operational activity, other than to develop and test the specific technology and functionality, without your prior consent.
  • law enforcement in complying with the law, or to enforce our Terms and Conditions or to protect the rights, property, or safety of ourselves, our customers or other third parties, and
  • if we acquire any new business, and/or sell all or part of our business.

 

How long do we keep your information?

We will not keep personal information for longer than it is necessary, and will only retain information for as long as needed to carry out our functions and that purpose. Personal information is retained in line with our retention schedule.

Where your information may be processed?

The information that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA) in certain circumstances. For example, if we contract with service providers based outside the EEA, or if any of our servers are at any time based outside the EEA (including ‘cloud’ service provision). If it is, then we put in place controls to make sure that your information has the same level of protection as if it was inside the EEA. Where we would have to disclose your personal information to third parties, in any circumstances, we will always take all appropriate steps to ensure that such third parties are responsible and trusted and that your personal information will be treated in accordance with this Privacy Policy, and to European and UK Data Protection standards or equivalent.

Links to other websites

Our site may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Privacy Policy. You should exercise caution and look at the privacy policy applicable to the website in question.

Keeping your personal information up-to-date If you have provided us with personal information, it is your responsibility to ensure that it is correct and up to date. This will enable us to provide you with the best service possible.

Please contact us as soon as possible if you believe that any information we are holding on you is incorrect or incomplete. Our contact details are set out below.

Your rights

You have a number of rights to your information that can be accessed by contacting the Data Protection Officer at data.protection@spotlight.com or by writing to Spotlight, 7 Leicester Place, London WC2H 7RJ.

To make sure we protect you and your information, we will need to verify your identity for any requests we receive from you before we begin to process your request.

Children

As a Parent or Guardian representing a child, you are a third party acting on behalf of your child and it is your responsibility to inform the child of their rights and to act solely in your child’s best interests. Parents or guardians have the right to exercise the below rights on behalf of the child that they represent.

Third party

If this is a third party acting on your behalf, we will request that they provide proof that they have your consent to represent you.

If we decide not to action your request we will explain our justification for refusal.

  • Access your information – you can request access to or a copy of your personal information and check what information we hold about you.
  • Change or correct your information – if you wish to have any errors corrected, you can request this – although this is not an absolute right and we may request for further information.
  • Take your information – you can ask for a copy of your personal information to be provided in a reusable and machine-readable form.
  • Object to, limit or restrict the use of your information – you can ask that we stop using parts or all of your personal information or limit its use if you believe that this personal information is unlawfully held.
  • Direct marketing – you can ask that we stop using your personal information for direct marketing. This can be by clicking on an ‘unsubscribe’ link in an email or writing to the Data Protection Officer.
  • Delete your information – you can ask that your personal information is deleted if you believe it is no longer necessary for the purposes it was collected.
  • Legitimate interest – if we are processing your information on the grounds of legitimate interest, you can ask us to stop this if there are reasons related to your individual circumstances. We have to do this unless we believe we still have an overriding legitimate reason.

If you are unhappy

The theme throughout this Policy is that Spotlight treats your privacy with the utmost importance and we strive to meet the highest standards when collecting and using personal information. If for whatever reason you believe that our collection or use of your information is unfair or inappropriate, we encourage you to report this to our Data Protection Officer. We will take any complaints we receive about your privacy very seriously.

You also have the right to complain to your supervisory authority if you are unhappy with how your personal information has been collected, used or managed which within the UK is the Information Commissioner’s Office (ICO) who can be contacted by calling 0303 123 1113 or by visiting www.ico.org.uk.

Cookies, IP Addresses and Analytics

A cookie is a piece of information that is stored on your computer’s hard drive by your web browser. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Most web browsers allow control over these cookies through the browser settings. Spotlight uses cookies to track and analyse visits to our site and the use of video and audio material, with the aim of constantly improving our site services and ensuring that we are adequately supporting the growing number of visitors to our site. These may include third party cookies set by Google Analytics, Twitter, and Eventbrite (our event booking service).

Cookies from third parties may also be used by Spotlight to help us understand how our visitors engage with the website and to determine the number of people who click on an advertisement and subsequently buy our services. To gather this information, Spotlight uses Google Analytics and Google AdWords. For more information on how Google uses cookies for analytics and conversion tracking visit Google’s Advertising and Privacy information pages. Spotlight also uses Google Analytics Measurement Protocol to track and analyse usage of the Spotlight Casting Mac application. More information is available here.

You can also see a full list of all third party cookies on your web browser by visiting this website:http://www.youronlinechoices.com/uk/.

For more information about cookies, including how to remove and disable them, visit the following website: http://ico.org.uk/for_the_public/topic_specific_guides/online/cookies.

An IP address is a number which is automatically assigned to your computer whenever you access the internet. When you access the ProFile site we will log your IP address. We generally only use IP addresses to analyse trends, administer our website, track general user movements and gather broad demographic information for aggregate use, or where investigating possible criminal activity

More information and information in an accessible format

This Privacy Policy has been carefully written to try to provide clarity and understanding and to make sure the information contained within it to be accessible for you. If there is information you do not understand, or if you require additional explanation, please contact the Data Protection Officer using the contact details within this Policy and we will be happy to assist you.

Queries and Requests

If you have any queries about the way your data is used by Spotlight, please contact:

Data Protection Officer
Spotlight
7 Leicester Place
London WC2H 7RJ
data.protection@spotlight.com

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