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Contact Creatives Limited Privacy Policy
GENERAL
We are Contact Creatives Limited,  27 Old Gloucester Street, London, United Kingdom, WC1N 3AX, VAT Reg. No. 339316101 (referred to herein as “we”, “us” or “our”, as the context requires). 
This policy (together with our terms and any other documents referred to on them) set out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. It applies to our models, our customers, and to other individuals whose data we may process.
We are the controller of the data pertaining to our models and other creatives (such as photographers, videographers, hair and makeup artists, influencers, stylists and artists), together referred to as talent, and the data pertaining to our clients and prospects to the extent it pertains to natural persons, and of their personal contacts’ data, plus of all of our website visitors’ data.
We may change this policy from time to time so please, check our website from time to time for any updates. If we make material changes in the way we use your personal information, we may notify you by posting a notice on our website or sending you an email at the email address that you provided.
THE BASIS FOR THE PROCESSING OF YOUR DATA
We process our talent data and our clients’ data for the performance of the contract that they have entered into for the provision of our services, and/or in order to take steps, at their request, to enter into the contract. This includes the publication and sharing of our talent data on our websites, apps, social media, and by other means, for the purposes of making it available to our clients and potential clients.
We may process your data based on our legitimate interests where these are not overridden by your interests or fundamental rights. Such legitimate interests include talent representation and promotion, marketing, analytics, fraud- and identity theft prevention, the making of- and defence against claims, online- and physical security, enhancing website / app performance. 
We may ask for your consent to process your data, for example to keep in touch via email or if we wish to process special categories of your data, unless we process the data that has been manifestly made public by you, based on your contract with us or otherwise. Such consent can be withdrawn at any time by contacting us at info@contact.xyz, but such withdrawal will not apply to any processing before this withdrawal. 
DATA WE COLLECT ABOUT YOU
The information we gather about you may be collected directly from you or from third-party online sources.
Information we gather about our talent comprise but may not be limited to: name, email, phone number, address, country, postcode, password, push notification device tokens, talent area, introduction, biography, quotes, social account names, date of birth, height, waist size, leg length, shoe size, chest size, suit size, bust size, hip size, gender, complexion, eye colour, hair colour, hair style, location, hobbies, social follower count, photos, including photos of their work, jobs information, correspondence.
Information we gather about our clients, including prospects, and their contacts comprises name, email, slug, phone number, address, country, postcode, password, access token fingerprint, company, website, job requested details, correspondence. similar data may be gathered about our external contractors.
Information we gather about our website visitors: we will automatically collect the following information when you visit our website: your computer’s IP address, browser type and version, source of traffic and/or previous webpage before visiting our website, the pages visited and actions taken within our website, the time spent within our website, access times and dates, page response times, errors and other statistics and technology on the devices you use to access our websites, your location as part of website analytics.
COOKIES
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your device if you agree. Cookies contain information that is transferred to your device hard drive.
We use the following cookies on our website: 
Strictly necessary cookies. These are cookies that are required for the operation of our website. 
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Remarketing / social cookies. These cookies are used to select ads for you in relation to other websites and platforms you may be using.
• Google Analytics • Facebook Pixel • Google Optimize • Delighted • Cookiehub • ZenDesk • CustomerIO • Hotjar • Amplitude
MARKETING
You may receive marketing communications from us if you have requested information from us or requested our services if, in each case, you have not opted out of receiving that marketing.  
We may send marketing emails to your corporate email address, subject to your right to opt-out of such communications by objecting to it at any time.
Where you opt out of receiving these marketing communications, we may still process your personal data for other required purposes.
We do not sell, rent, or lease or provide in any other way our customer lists to third parties.
You may always object / opt-out by following the link in our email message or by sending us an email to info@contact.xyz
RECIPIENTS OF YOUR INFORMATION
We do not rent or sell your personal information to anyone without your explicit consent, but, subject to the need to enter into- or perform the contract with you or our legitimate interests, we may share your personal information with the recipients identified below:
  • Our clients, their representatives and contractors, our talent, plus other persons who may require the data in order to fulfil our bookings
  • Our IT providers, cloud service providers, storage providers, system administrators who host and manage our data
  • Our database management, communications, and analytics providers
  • Providers of online and offline marketing and promotion services
  • Other parties if we are required to do so by law, or if we believe that such action is necessary to: (a) fulfil a government, or regulatory authority request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our websites or customers.
INTERNATIONAL DATA TRANSFERS
The data that we collect from you may be transferred to, and stored at, a destination outside the UK and the European Economic Area ("EEA"), where the laws on processing personal data may be less stringent than in your country. 
We will ensure that, upon any such transfers, at least one of the following safeguards is implemented:
  • transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
  • entering into specific contractual terms which have been approved by the ICO or the European Commission.
DATA RETENTION
We retain personal information for as long as we require for the purposes for which it is processed or as is otherwise required by applicable law. Our retention periods will vary depending on the type of data involved, but, generally, we will refer to these criteria in order to determine retention period:
  • Whether we have a statutory or contractual need to retain the data;
  • Whether the data is necessary to provide our services;
  • Whether data may be required to make-/defend against claims, subject to the limitation period.
YOUR RIGHTS
Under the UK General Data Protection Regulation (GDPR), you are entitled to certain rights in relation to our handling of your personal data, as described below:
  • Request access to your personal data that we hold about you (commonly known as a “data subject access request” or DSAR). This enables you to receive a copy of the personal data we hold about you or are otherwise processing;
  • The right to obtain without undue delay the rectification of inaccurate personal data concerning you, including the right to have incomplete personal data completed e.g. by means of providing a supplementary statement. This enables you to have any incomplete or inaccurate data we hold about you corrected. We may need to verify the accuracy of the new data you provide to us;
  • Restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data where the data is wrongfully processed but should not be erased for a reason listed in Article 18 (1) GDPR;
  • Right to erasure ('right to be forgotten'). This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it, except for information where a contract or legitimate interest continues to exist (e.g. to pursue claims);
  • 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 particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
  • You may exercise your right of data portability in a common, machine- readable form by obtaining your data.
Where another mechanism is not provided, you can exercise the rights at any time by contacting us at info@contact.xyz
CONTACT AND COMPLAINTS
Questions, comments and requests regarding this privacy notice are welcomed and should be addressed to:
Contact Creatives Limited, 27 Old Gloucester Street, London, United Kingdom, WC1N 3AX
Contact email:  info@contact.xyz
You may always launch a complaint regarding our processing of your data by contacting the UK Information Commissioner’s Office with ico.org.uk.