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AP Talent Management
BESPOKE INTERNATIONAL REPRESENTATION
PRIVACY POLICY - COOKIE POLICY - PRIVACY NOTICE
Website Privacy Notice
1. INTRODUCTION
This privacy notice provides you with details of how we collect and process your personal data through your use of our site http://www.aptalentmanagement.co.uk
By providing us with your data, you warrant to us that you are over 13 years of age.
APTM is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
[We have appointed a Data Protection Officer who oversees privacy related matters for us. If you have any questions about this privacy notice, please contact the Data Protection Officer using the details
set out below.
Contact Details
Our full details are:
APTM
Email address: Info@aptalentmanagement.co.uk
Suite G04,
1 Quality Court,
Chancery Lane
London
WC2A 1HR
Telephone number: 07961018463
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at info@aptalentmanagement.co.uk
2. WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE
PROCESS IT
Personal data means any information capable of identifying an individual. It does not include anonymised data.
We may process the following categories of personal data about you:
Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social
media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which
in this case are to reply to communications sent to us, to keep records and to establish, pursue
or defend legal claims.
Customer Data that includes data relating to any purchases of goods and/or services such as your
name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services
you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your
request to enter into such a contract.
User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to
ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to
properly administer our website and our business.
Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website,
page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our
advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to
partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to
grow our business and to decide our marketing strategy.
We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display
advertisements) and to measure or understand the effectiveness of the advertising we serve you.
Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).
Sensitive Data
We need to collect the following sensitive data about you in order to deliver our services safely:
Information about your health and any disability
Your identified gender
Your sexual orientation
Your ethnicity
We require your explicit consent for processing sensitive data, so when you submit your details, we will send you a further communication asking for you to confirm your consent to this processing.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at INFO@ APTALENTMANAGEMENT.CO.UK . In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
We do not carry out automated decision making or any type of automated profiling.
3. MARKETING COMMUNICATIONS
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.
Before we share your personal data with any third party for their own marketing purposes, we will get your express consent.
You can ask us or third parties to stop sending you marketing messages at any time by emailing us at info@aptalentmanagement.co.uk at any time.
If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.
4. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below:
• Service providers who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers
• Government bodies that require us to report processing activities.
• Third Party organisers of event, exams and competitions.
• Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
5. INTERNATIONAL TRANSFERS
Some of our third party providers are businesses outside of the EEA in countries which do not always offer the same levels of protection for your personal data. We do our best to ensure a similar degree of security by ensuring that contracts, code of conduct or certification are in place which give your personal data the same protection it has within Europe. If we are not able to do so, we will request your explicit consent to the transfer and you can withdraw this consent at any time.
6. DATA SECURITY
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions, and they must keep it confidential.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
7. DATA RETENTION
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.
When deciding what the correct time is to keep the data for, we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.
In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
8. YOUR LEGAL RIGHTS
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-dataprotection-regulation-gdpr/individual-rights/
If you wish to exercise any of the rights set out above, please email us at info@aptalentmanagement.co.uk
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 or refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
9. THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
10. COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use please email us info@aptalentmanagement.co.uk
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What's a cookie?
• A "cookie" is a piece of information that is stored on your computer's
hard drive and which records how you move your way around a website so
that, when you revisit that website, it can present tailored options based
on the information stored about your last visit. Cookies can also be used
to analyse traffic and for advertising and marketing purposes.
• Cookies are used by nearly all websites and do not harm your system.
If you want to check or change what types of cookies you accept, this can
usually be altered within your browser settings. You can block cookies at
any time by activating the setting on your browser that allows you to
refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
How do we use cookies?
• We use cookies to track your use of our website. This enables us to
understand how you use the site and track any patterns with regards how
you are using our website. This helps us to develop and improve our
website as well as products and / or services in response to what you
might need or want.
• Cookies are either:
- Session cookies: these are only stored on your computer during your
web session and are automatically deleted when you close your browser –
they usually store an anonymous session ID allowing you to browse a
website without having to log in to each page but they do not collect any
personal data from your computer;
or
- Persistent cookies: a persistent cookie is stored as a file on your
computer and it remains there when you close your web browser. The
cookie can be read by the website that created it when you visit that
website again.
• Cookies can also be categorised as follows:
- Strictly necessary cookies: These cookies are essential to enable you to
use the website effectively, such as when buying a product and / or
service, and therefore cannot be turned off. Without these cookies, the
services available to you on our website cannot be provided. These
cookies do not gather information about you that could be used for
marketing or remembering where you have been on the internet.
- Performance cookies: These cookies enable us to monitor and improve
the performance of our website. For example, they allow us to count visits,
identify traffic sources and see which parts of the site are most popular.
- Functionality cookies: These cookies allow our website to remember
choices you make and provide enhanced features. For instance, we may be able to provide you with news or updates relevant to the services you
use. They may also be used to provide services you have requested such
as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised.
Please note that third parties who advertise on our website and or social
media pages (including, for example, advertising networks and providers
of external services like web traffic analysis services) may also use
cookies, over which we have no control.
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Privacy Notice
1. INTRODUCTION
This privacy notice provides you with details of how we collect and process your personal data.
AP Talent Management are the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
Our email address is: info@aptalentmanagement.co.uk
If you are not happy with any aspect of how we collect and use your data, you
have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
We should be grateful if you would contact us first if you do have a complaint so that we can try
to resolve it for you.
It is very important that the information we hold about you is accurate and up to date.
Please let us know if at any time your personal information changes by
emailing us at info@aptalentmanagement.co.uk
Sensitive Data
We need to collect the following sensitive data about you in order to deliver our services to and keep you safe. The sensitive data we process is only used where
appropriate.
Information about your health and any disability
You identified gender
Your sexual orientation
Your ethnicity
We require your explicit consent for processing sensitive data, and we will request your signature for this consent.
2. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when legally permitted. The most common uses of your personal data are:
• Where we need to perform the contract between us.
• 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.
Generally, we rely on consent as a legal ground for processing your personal data.
Purposes for processing your personal data Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.
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 email us at info@aptalentmanagement.co.uk if you need details about any specific legal grounds, we are relying on to process your personal data where more than one ground has been set out below.
Purpose/Activity:
To register you as a new customer or talent:
To administer and protect
our business and our site
(including troubleshooting,
data analysis, testing,
system maintenance,
support, reporting and
hosting of data):
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey. (c) Renew or make amendments to the contract
Type of data
Lawful basis for processing.
To register you as a new customer or talent
(a) Identity
(b) Contact
Performance of a contract with you
To process and deliver
your payments including:
(a)Manage payments, fees
and charges
(b) Collect and recover
money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and
Communications
Performance of a contract with you.
Identity
Financial
Contact
Transaction
Marketing and communications.
(a) Performance of a contract
with you
(b) Necessary to comply with a
legal obligation
(c) Necessary for our legitimate
interests to keep our records
updated and to study how
customers use our
products/services
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate
interests for running our
business, provision of
administration and IT services,
network security, to prevent
fraud and in the context of a
business reorganisation or group
restructuring exercise
(b) Necessary to comply with a
legal obligation
To use data analytics to
improve our website,
products/services,
marketing, customer
relationships and
experiences
(a) Technical
(b) Usage
Necessary for our legitimate
interests to define types of
customers for our products and
services, to keep our site
updated and relevant, to develop
our business and to inform our
marketing strategy.
3. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the
purposes set out in the table above:
• Service providers who provide IT and system administration services.
• Professional advisers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
•1 Clients, Casting Directors and licensing agencies who require data upon pursuance of Assignments
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
4. INTERNATIONAL TRANSFERS
Some of our third-party providers are businesses outside of the EEA in countries which do not always offer the same levels of protection for your personal data. We do our best to ensure a similar degree of security by ensuring that contracts, code of conduct or certification are in place which give your personal data the same protection it has within Europe. If we are not able to do so, we will request your explicit consent to the transfer and you can withdraw this consent at any time.
5. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered or
disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
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. DATA RETENTION
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.
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.
By law we must keep basic information about our customers and talent
(including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. There are by law certain extensions to this on behalf of talent under the age of 18 and extends to the parent or guardian with whom the contract is agreed on behalf of a minor.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
7. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
• Request access to your personal data.
•Request correction of your personal data.
•Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.
You can see more about these rights at:
https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulationgdpr/individual-rights/
If you wish to exercise any of the rights set out above, please email us at
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.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
APTM