Alessi Hartigan Casting Privacy Policy
Alessi Hartigan Casting (“AHC”, “we”, “our” or “us”) has created its unique website https://alessihartigancasting.uk and mobile application which we offer our agency services through (hereby collectively referred to as the “Software”).
This Privacy Policy governs those that will access and use our Software as an authorised user (“Authorised User”) which means you will have a registered account with us enabling you to use the Software, those that we provide our Services to generally, those that we work with in the provision of our services (“Services”), or those that are general visitors to the website or mobile application (“you” or “your”) for the purpose of this Privacy Policy
Overview
At Alessi Hartigan Casting, we take privacy very seriously. We have prepared this Privacy Policy (“Privacy Policy”) to ensure that we communicate to you, in the clearest way possible, how we treat your personal information.
We are committed to ensuring that your personal information remains confidential and secure in accordance with applicable Data Protection Legislation.
This policy sets out how we look after your personal data if you are a:
• Visitor to our Alessi Hartigan Casting website;
• An Authorised User with a registered account;
• Supplier or business contact of AHC Digital;
• An Extra generally through us;
• A potential end client of AHC Digital;
• Any third-party organisation that uses AHC Digital;
This Privacy Policy (together with any applicable terms and conditions of service, website terms of use, and any other documents or terms incorporated by reference) describe the types of information that we collect from you through the use of the Software, or through our business generally, and how that information may be used or disclosed by us and the safeguards we use to protect it. The personal information that we collect is used for providing and improving our Services. We will not use or share your information with anyone except as described in this Privacy Policy.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
We may update this notice from time to time, and you can find our latest version on our website or by asking us for a copy.
Due to the nature of our Services we provide, and the requirements of our clients, the decision to invite you to appear as an Extra in certain productions may be automated based on the information you provide on your profile; for example, your gender, ethnicity, measurements and location. When registering with us as an Extra, you acknowledge that the decision to invite you to appear as an Extra in certain productions may be automated and if you proceed you are doing so on the strict understanding that you have given us explicit consent for this.
Who is Alessi Hartigan Casting?
Alessi Hartigan Casting is a company incorporated in Saint Giles, London, England with its company number 15977964 and its registered office being 10 John Street, Saint Giles WC1N 2EB.
This Privacy Policy applies to any personal data we collect through our business and within the Software to enable us to deliver our Services. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us at info@alessihartigancasting.uk
We will only process personal information about you in accordance with the UK Data Protection Legislation which for the purposes of this Privacy Policy shall mean: all applicable data protection and privacy legislation in force from time to time in the UK including without limitation the UK GDPR; the Data Protection Act 2018 (and regulations made thereunder) and the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426) as amended; and all other legislation and regulatory requirements in force from time to time which apply to a party relating to the use of personal data (including, without limitation, the privacy of electronic communications); and the guidance and codes of practice issued by the Commissioner or other relevant regulatory authority and which are applicable to a party (“Data Protection Legislation”).
1. Collection of Information and how we use it
1.1 We will collect any information that you provide to us when you:
• Input forms in the Software, including any application forms;
• place a booking in person, over the phone or by email;
• register to use our Services;
• make an enquiry, provide feedback or make a complaint to us over the phone, by
email or via the Software;
• submit correspondence to us by post, email or via the Software;
• submit a CV;
• ‘follow’, ‘like’, post to or interact with any of our social media accounts including but
not limited to Instagram, Facebook, Twitter, Snapchat, LinkedIn;
• Interact with us as to express an interest for work;
• Interact with us as a client or potential client.
1.2 Personal data, or personal information, means any information about an individual from
which that person can be identified. It does not include data where the identity has been
removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which
we have grouped together depending on your relationship with us (for instance,
whether you are an Authorised User benefitting from our Services, visitors, or client of
ours, or a supplier) as follows:
• Identity Data: includes first name, maiden name, last name, username or similar
identifier, marital status, title, date of birth and gender.
• Application Data: any data you may supply in your application with us on the
Software, which may include specific profile data.
• Financial Information: details of bank account details for billing services and
payment services.
• Contact Data: your email address, telephone number and postal address.
• Technical Log Data includes internet protocol (IP) address, device ID’s, your login
data, browser type and version, time zone setting and location, browser plug-in
types and versions, geolocation data, social media preferences, operating system
and platform and other technology on the devices you use to access the Software.
• Profile Data includes your authorised username and password, complaints,
preferences, profile information relating to your image, such as hair and eye colour,
height, measurements, photographs.
• Usage Data includes information about how you use the Software, and our
services.
• Cookies Data like many websites, we may use some “cookies” to enhance your
experience and gather information about the visitors and number of visits to the
Software. Please refer to our Cookie Policy on our website about cookies, how we
use them and what kind.
• Analytics includes third-party analytics services (such as Google Analytics) to
evaluate your use of the Software, compile reports on activity, collect demographic
data, analyse performance metrics, and collect and evaluate other information
relating to our website and internet usage. These third parties use cookies and
other technologies to help analyse and provide us the data. By accessing and
using the Software, you consent to the processing of data about you by these
analytics providers in the manner and for the purposes set out in this Privacy Policy.
• Sensitive personal information due to the nature of the Services we provide, we
also may collect sensitive personal information from you which includes specific
measurements, race, health, ethnicity, religious or philosophical beliefs. Please
refer to our section 7 on sensitive personal data in this Privacy Policy, which covers how we deal with it.
You can withhold your personal data from us, but we may not be able to provide our Services to you if you do so.
We may collect your personal data from different sources:
• We collect all the types of data listed above directly from you when you interact
with us. This includes when you register or use the Software.
• We collect Technical Data automatically when you interact with the Software, by
using cookies and other similar technologies.
1.3 We have no automatic deletion period for personal information. The nature of our
business is such that our production clients have no limits or restrictions to their
requirements so personal information which is infrequently or never used may still be
required. See below our section on data retention.
2. Information we collect about you
2.1 Non-Personal information is used to help us monitor and improve our service, for
example by showing how many people are visiting our website and which pages are
most or least popular. Individual user patterns are not monitored.
2.2 We (or third-party data processors, agents and sub-contractors acting on our behalf) may collect, store and use your personal information by way of different methods to collect data from and about you including through:
Direct interactions. This is information (including Identity, Contact and Financial Data) you consent to giving us about you when you fill in forms and sections through the Software or send to us directly, or by corresponding with us (for example, by email or chat). It includes information you provide when you register for any of our Services, visit or use the Software, or when you create an account with us and finally when you report a problem with our Services, or with Alessi Hartigan Casting. If you contact us, we will keep a record of that correspondence.
Information we collect about you and your device either automated or otherwise.
Each time you visit or use the Software, we will automatically collect personal data including Technical Log Data. We collect this data using cookies and other similar technologies including server logs. We may also receive technical data about you if you visit other websites employing our cookies. We may also collect Technical Log Data if you contact us and use our services generally through Alessi Hartigan Casting.
Financial information. We will collect information related to bookings and time worksheets. We will also collect information relating to payments to you such as bank details or other related transaction information. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions, which include strict confidentiality and contractual terms. We will only use your personal data when the law allows us to. Most commonly we will use your personal data in the following circumstances:
• Where you have consented before the processing.
• Where we need to perform a contract, we are about to enter into, or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
2.3 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. When we are acting as a data controller, we will use your personal data for the purposes set out in the table below. The law sets out several different reasons for which we can collect and use your data. The legal grounds on which we collect and use your data are also set out in the table below. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose for using your data
To allow you to access your account through the Software and to register an account with us.
To enable access to and to enable you to benefit from our Services. This may include sharing your information with our website hosts and developers.
To publish your portfolio and information in the Software when you agree to be represented by us if you are an Extra.
To manage any account with us and to enable us to deliver our Services, including making bookings, managing and making payments.
To provide support to you when you contact us.
To manage our relationship with you, which will include notifying you about changes to our Privacy Policy, revised Terms of Service and any key
correspondence with you.
To administer and protect our business and the Software (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
To deliver relevant system, software and website content and advertisement and promotional activity to measure or understand the effectiveness of the business.
To use data analytics to improve our website, products/services, marketing,
customer relationships and experiences.
Marketing our Services to existing and former customers.
To enable us to keep you informed of news, events and services that may be of interest.
To create anonymous aggregated data, as
set out below.
To comply with policies, applicable laws and regulatory obligations.
Social media interactions. To enable us to interact with users on social media.
Legal ground for using your data for this purpose
Necessary for our legitimate interests (to allow those with an account in the Software to use it) / Performance of a contract with us. To comply with a legal obligation.
Necessary on the basis of us performing our contract with you and for our legitimate interests in promoting our website and mobile application and Services as an extra’s agency.
Necessary for our legitimate interests (to recover debts due to us and to make payments) / Performance of a contract with us.
Necessary for our legitimate interests (to respond to support calls as our users would expect) / Performance of a contract.
Necessary for our legitimate interests (to provide important updates to our users)/ Performance of a contract.
Necessary for our legitimate interests (to protect our business, software and website; to keep our services updated).
Necessary for our legitimate interests (to study how Authorised Users use our products/services, to develop them, to grow our business and to inform our marketing strategy).
Necessary for our legitimate interests (to continuously improve our services for our customers and users).
For our legitimate interests, i.e. to promote our business to existing and former customers, or on the basis of consent where we have requested it. See “Marketing” below for further information.
Necessary for our legitimate interests (to provide additional benefits and functionality to our customers and users without disclosing personal data).
To comply with a legal obligation and on the basis of our legitimate interests to operate a safe and lawful business.
On the basis of our legitimate interests in promoting our brand.
2.4 As outlined above, from time to time we may use your personal data to pursue legitimate interests of our own or those of third parties.
3. Who do we share your information with?
3.1 We may need to share your personal data when using your personal data as set out in the table above. We may share your personal data with the following third parties:
• Our professional advisers, including lawyers, auditors and insurers and any other
third parties that may be necessary such as authorities, regulatory or other
government agencies which may be required.
• Clients (for actual and potential assignments). There may be occasions where
these clients are based outside of the United Kingdom and the EEA.
• Service providers who we work with to deliver our Services, who may act as
processors and provide the following services (including, but not limited to)
web development, hosting services, IT and system administration, marketing services,
social media plug in services, payment services.
• Regulators and Government bodies.
• Third parties to whom we may choose to sell, transfer, or merge parts of our
business or our assets. Alternatively, we may seek to acquire other businesses or
merge with them. If a change happens to our business, then the new owners may
use your personal data in the same way as set out in this Privacy Policy.
Where any of your personal data is required for such a purpose, we will take all reasonable steps to ensure that your personal data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the Data Protection Legislation. This type of external data processing is always subject to contractual assurances that personal data will be kept securely and used only in accordance with our specific directions.
We will not misuse your personal data for any other purpose other than as set out in this Privacy Policy.
4. International Transfers
4.1 Subject to us complying with Data Protection Legislation and ensuring appropriate
safeguards are in place, we may transfer your personal data to third parties providing
services to us who are based outside of the UK and EEA without obtaining your specific
written consent. This may include parties providing IT administration services and
hosting services and other organisations which have products or services that are
essential in the delivery of our Services; and finally, organisations providing assistance
with managing our marketing databases.
4.2 Whenever we transfer your personal data outside of the UK, we ensure a similar degree
of protection is afforded to it by ensuring at least one of the following safeguards is
implemented:
4.2.1 the personal data is transferred to or processed in a territory which is subject to
adequacy regulations under the Data Protection Legislation that the territory
provides adequate protection for the privacy rights of individuals such as the
EEA; or
4.2.2 we participate in a valid cross-border transfer mechanism under Data Protection
Legislation, so that we can ensure that appropriate safeguards are in place to
ensure an adequate level of protection with respect to the privacy rights of
individuals as required under the Data Protection Legislation; or
4.2.3 the transfer otherwise complies with Data Protection Legislation.
5. Retention Periods
5.1 We will only retain your personal data for as long as necessary to fulfil the purposes we
collected it for, including for the purposes of satisfying any legal, accounting, or
reporting requirements.
5.2 To determine the appropriate retention period for personal data, we consider the
amount, nature, and sensitivity of the personal data, the potential risk of harm from
unauthorised use or disclosure of your personal data, the purposes for which we
process your personal data and whether we can achieve those purposes through other
means, and the applicable legal requirements.
5.3 For more details of our specific retention periods, please contact us.
6. Data Security
6.1 Data security is of great importance to us, and to protect your data we have put in place
suitable physical, electronic and managerial procedures to safeguard and secure data
collected through the Software and through our business.
6.2 We have implemented significant security measures to maintain a high level of security.
6.3 We have put in place procedures to deal with any suspected personal data breach and
will notify you and any applicable regulator of a breach where we are legally required
to do so.
6.4 Notwithstanding the security measures that we take, it is important to remember that
the transmission of data via the internet may not be completely secure and that you are
advised to take suitable precautions when transmitting to us data via the internet and
you take the risk that any sending of that data turns out to be not secure despite our
efforts.
6.5 If we give you a password upon registration and use of the Software, you must keep it
confidential. Please don’t share it.
7. Sensitive Personal Information
7.1 “Special Categories” of particularly sensitive personal information require us to have
higher levels of security in place. Sensitive personal information includes any details
about your race or ethnicity, specific body measurements, hair colour, health data,
genetic data, sexual orientation, religious or philosophical beliefs. As such, higher levels
of protection are required in order for us to process these types of data. We may also
require information from you about any criminal convictions.
7.2 We need further justification for collecting, storing and using these types of data and to
do so, we implement safeguards and policies to ensure we can meet the requirements
of the Data Protection Legislation. We therefore may process sensitive personal
information in the following circumstances:
7.2.1 Where you might provide explicit consent;
7.2.2 Where processing is necessary for the purposes of carrying out our obligations
and exercising your specific rights as either the data controller or the data
subject; and
7.2.3 where we need to carry out our legal obligations.
8. Your rights to the information we hold about you
8.1 Under certain circumstances, you have rights under the Data Protection Legislation in
relation to your personal data. These rights are set out below. If you wish to exercise
any of the rights set out below, please contact us.
8.2 You will not have to pay a fee to access your personal data (or to exercise any of the
other rights). However, we may charge a reasonable fee if your request is clearly
unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your
request in these circumstances.
8.3 Your rights are as follows:
• Right of access – you have the right to request a copy of the personal data that we
hold about you and to check that we are lawfully processing it.
• Right of rectification – you have a right to request that we correct personal data
that we hold about you that is inaccurate or incomplete.
• Right to be forgotten / erasure – in certain circumstances you can ask for the data
we hold about you to be erased from our records i.e., when there is no good reason
for us continuing to process it.
• Right to restriction of processing – where certain conditions apply, you have a right
to restrict or suspend the processing, for example if you want us to establish its
accuracy or the reason for processing it.
• Right of portability – you have the right to have the data we hold about you
transferred to another organisation.
• Right to object – you have the right to object to processing of your personal data
where we are relying on a legitimate interest (or those of a third party) and there is
something about your situation which makes you want to object to processing on
this ground as you feel it impacts on your fundamental rights and freedoms.
There are some exceptions to the above rights.
• Right to withdraw consent. In the limited circumstances where you have provided
your consent to the collection, processing and transfer of the personal data referred
to above, you may withdraw that consent at any time. However, this will not affect
the lawfulness of any processing carried out before you withdraw your consent, or
to processing carried out on other legal grounds. If you withdraw your consent, we
may not be able to provide certain products or services to you. We will advise you
if this is the case at the time you withdraw your consent.
8.4 All the above requests will be forwarded to the relevant party should there be a third
party involved in the processing of your personal data.
9. Privacy of Children
9.1 We do not knowingly collect personal information from children below the age of 16.
9.2 By sending us any information to us, registering to use our Services, or asking us to
email you, you are confirming that your parent or guardian has consented to you doing
so. We may be required to confirm this with your parent or guardian accordingly.
10. Marketing
10.1 We will use your personal data to send you updates (by email, text message, telephone
or post) about our products, including exclusive offers, promotions or new products.
10.2 We have a legitimate interest in using your personal data for marketing purposes (see
above ‘How and why we use your personal data’). This means we do not need your
consent to send you marketing information. If we change our marketing approach in
the future so that consent is needed, we will ask for this separately and clearly.
10.3 You have the right to opt out of receiving marketing communications at any time by
contacting us at info@alessihartigancasting.uk
11. Complaints to the Information Commissioner’s Office
11.1 You have the right to make a complaint at any time to the Information Commissioner’s
Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
We would, however, appreciate the chance to deal with your concerns before you
approach the ICO so please contact us in the first instance by emailing us at info@alessihartigancasting.uk
12. Changes to this Privacy Policy
12.1 We may from time to time make changes to this Privacy Policy. We will post changes
to our website or notify you of any material changes by email.
13. Contact
13.1 If you have any queries or concerns, then please in the first instance contact
info@alessihartigancasting.uk
13.2 You have the right to access or exercise any other statutory right by contacting us at
info@alessihartigancasting.uk
13.3 At any time you have the right to bring a complaint to the Information Commissioner’s
Office (https://ico.org.uk)