Privacy & Cookies Policy
Last updated 24th May 2018
Real London Casting Ltd. (“we” or “us”) place great importance on your privacy and security using reallondoncasting.co.uk (the “Website”). We take the responsibility of our website visitors, clients and models personal data very seriously and have notified the Information Commissioner’s Office of our role as a Data Processor under the Data Protection Act 1998 (Registration No: A8327749).
DATA COLLECTION POLICY STATEMENT
We collect data in order to provide quotes to prospective clients and to fulfil contractual requirements. This information may be retained for up to 10 years for financial recording reasons as required by regulators. Further, data may be retained for the purposes of client communication, the marketing of similar services, for exercising our rights with regards to Intellectual Property (IP) and for regulatory or legal defence reasons until such time as these details would no longer be relevant or required. If this contractually necessary information is not provided we will be unable to satisfactorily communicate with clients and so be unable to act effectively on any requests from such clients.
This data will be in the form of names, email addresses, telephone numbers and other contact details such as Instant Messaging account names, IP addresses and possibly other online identifiers.
We do not sell data onwards to other recipients, nor do we transfer data to third countries or international organisations that do not have an adequacy agreement.
What is our lawful basis for using your data?
To the extent that the legal basis for our processing of your personal data is:
- consent; or
- that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
What information do we collect about you?
We collect information about you when you make an online application with us via our website; when you make a booking with us and when you attend for a photographic shoot. The personal information we collect includes your:
- Email address
- Phone number
- Parent or Guardian’s name and contact information (for children)
How will we use the information about you?
The information which we hold about you will be used in order to review your application. If we believe you have potential to be a Real London Casting model, we will use the information you provided us with to contact you and arrange an appointment.
If we have tried to arrange an appointment with you and have not received a response from you, we may from time to time contact you in order to try and arrange an appointment. If you no longer wish for us to contact you, please let us know by email: firstname.lastname@example.org
- We work with CDS Online to securely store our models details and send packages to clients, their systems are hosted by GDPR-compliant vendors Amazon AWS and Oxalide (ISO certified business ISO27001) for their Information Systems Management and Security;
- We use GoogleDocs https://cloud.google.com/security/gdpr/ to share joint project documents;
- We use Dropbox https://www.dropbox.com/en_GB/security/GDPR to back up some project related information and files;
- We use WeTransfer https://wetransfer.com/legal/privacy to transfer large project related files over the internet;
- We use MailChimp to send news and announcements to our models and clients and on behalf of clients (for their business); and
- We use Phone or SMS instant messages to notify you of bookings, casting calls and any other news that is specific to facilitating business contracts.
From time to time, we may use images of you on our social media platforms. However, we will only do so if you tell us you consent to us using your images when you attend for a photographic shoot and agree to an order. If you have previously given consent and no longer want us to use your images, you can withdraw your consent any time, tell us by by email: email@example.com
Where you have provided us with your consent in the past, but no longer want us to use your data as we have described above, you have the right to withdraw your consent at any time. To withdraw your consent, contact us: firstname.lastname@example.org
If you book an appointment with us and attend a photographic shoot, we will ask you to sign a copy of our client order form, this is a contract and we will process your data as necessary in order to carry out the terms of the contract.
Sharing your information
We sometimes share your personal data with trusted third parties. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
We may disclose "usage data", "account data", "profile data", "publication data", "enquiry data", "customer relationship data", "notification data" and/or "correspondence data" to our suppliers or subcontractors insofar as reasonably necessary for processing our legitimate interests, namely the proper administration of our website and business and communications with users.
Examples of the kind of third parties we work with are:
- Photographers and post-production suppliers – if you attend an appointment and purchase printed images or a canvas from us, your images and contact information will be shared with our photographer or portfolio provider. This is in order to allow them to produce the images and deliver these to your address. The contact address will be shared with their nominated courier, as they will carry out the delivery service. We may also share your images post-production photographic service agencies to have them retouched and edited before these are put online;
Digital brand marketing and development company, Atelier of Alchemy;
- IT companies who support our website and other business systems;
- Operational companies such as delivery couriers or suppliers; and
- Data insight companies to ensure your details are up to date and accurate.
We may disclose your enquiry data to one or more of those selected third party suppliers of goods and services for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services.
In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
Other than as set out above, we do not share your information with any other companies or organisations, unless required to do so by law.
International transfers of your personal data
In this Section, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
The hosting facilities for our website are situated in United States. The European Commission has made an "adequacy decision" with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which you can obtain from https://www.squarespace.com/dpa/.
From time to time, we needs to transfer large project related files over the internet. In such instances, we use WeTransfer https://wetransfer.com/legal/privacy in the United States. News and announcements to our models and clients and on behalf of clients (for their business) are sent via US based, MailChimp who house our mailing lists securely online.
You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
Retaining your information
We will need to keep a record of the information you have given us in order to complete your booking and carry out the service. This will not be retained for any longer than is necessary and if we do not hear from you within 36 months, this will be deleted automatically.
All accounts information is stored for 6 years, as we are required to store this information by law.
We will keep a copy of your images in a secure environment for 6 years in order to ensure that we can share these with you if you require them in the future. If you do not want us to store your images, they can be deleted upon request at email@example.com
Privacy of Children
Should parents wish to access their children’s personal information held by us, they should contact Data Protection Officer at firstname.lastname@example.org
Internal security measures
Organisational: We are a small team. Access to the administrative portions of the business infrastructure are restricted solely to those within it requiring access.
Technical: Whilst digital content is held in different secure online locations (see Sub-processors), physical copies of client/model details are stored in a single physical location, with physical and logical security in place. The location is secured with multiple layers of key-based access with one key holder. The building is secured and populated almost 24/7, 365 days a year.
Access to data on our internal systems is restricted according to business need and each user has a unique password and username and all systems are logged and monitored for unusual behaviour 24×7. Furthermore, we employ a full suite of anti-malware systems and all updates are applied and checked regularly by our internal team. Our network is protected by a controlled and monitored hardware firewall. Each computer has software firewalling enabled and controlled. Most of the data is kept in secure servers maintained by hosting companies. We have strict password and other access policy.
Under data protection law, you have the following rights in respect of the information we hold about you.
- the right to access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to object to processing;
- the right to data portability;
- the right to complain to a supervisory authority; and
- the right to withdraw consent.
You have the right to access the information which we hold about you and you can contact us to request a copy of this. You can make this request by email at: email@example.com; write to us at: Real London Casting, Flat 4, 34 Elm Park Gardens, London, SW10 9NZ; or call us on: +44(0)207 565 049.
If you do not think that the information we hold about you is correct, or you think that we do not have all the information which we should have about you, you can request that we rectify the information so that it is correct and complete.
You can request that we erase the data which we hold about you, or that we restrict the way that the data is used. This means that we will store your data securely, but it will not be processed in any way. You can also request that we send a copy of the data which we hold about you to another third party.
If you object to the way we have processed your data, please contact us to tell us why.
Once we have received your request for us to do any of the above, we will contact you within 30 days either to confirm that we have carried out your request or why we have not. In some cases we will not have to process your request, or will not be able to. We will still contact you within 30 days to explain to you why we believe this is the case.
If you feel that your data has been used inappropriately, you should contact us. You also have the right to complain to the Information Commissioners Officer (ICO) at www.ico.org.uk
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. We do not engage in profiling or automated decision making. Withdrawal will not affect the lawfulness of processing before the withdrawal.
You may exercise any of your rights in relation to your personal data by written notice to us.
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
Cookies that we and our service providers use and their purpose are detailed below. Your consent applies to the following domains: reallondoncasting.co.uk
login credentials, and to protect our website and services generally;
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
- (a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
- (b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
- (c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
- (d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
- (e) https://support.apple.com/kb/PH21411 (Safari); and
- (f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.
We will occasionally update this Privacy Notice. We will tell you about these changes by posting a notification at the top of our website. This policy was last updated on 24th May 2018
- By email at: firstname.lastname@example.org
- Write to us at: Real London Casting, Flat 4, 34 Elm Park Gardens, London, SW10 9NZ
- Call us on: +44(0)207 565 0493