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PRIVACY POLICY NOTICE

 

1. INTRODUCTION

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We are TIFFANY’S TALENT MGMT Ltd (“we” or “us”), a company registered in England and Wales. Our company registration number is 12071181 and our registered office is at 25A Avenue Gardens, London, W3 8HB. Our registered VAT number is GB332284420.

TIFFANY’S TALENT MGMT Ltd (“we” or “us”) understands that your privacy is important to you and that you care about how your personal data is used. We respect the privacy of everyone who visits this website, www.tiffanystalentmgmt.co.uk (“Our Site”) and we will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

This Privacy Policy describes our policies and procedures on the collection, use and disclosure of your information. Please read this policy alongside any applicable Terms & Conditions to understand our views and practices regarding your personal data and how we will treat it.

By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy. 

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CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES  

This version was last updated on 20/03/23

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.

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2. THE DATA WE COLLECT ABOUT YOU

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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 listed below:

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  • Identity & Contact Data such as your name, address, contact details, education and employment history, identification documentation.
     

  • Checks that include background checks (financial and criminal);
     

  • Personal information relating to next of kin/ dependants;
     

  • Financial data including bank details and identifiers (e.g. National Insurance numbers);
     

  • Images or photographs of you
     

  • Reviews/feedback relating to your ability as/to become a Model.
     

       We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

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IF YOU FAIL TO PROVIDE PERSONAL DATA 

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

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3.  HOW WE USE YOUR PERSONAL DATA  

 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:

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  • Where we need to perform the 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.
     

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4. HOW LONG WILL YOU KEEP MY PERSONAL DATA?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. 

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5. DO YOU SHARE OR TRANSFER MY PERSONAL DATA ABROAD? 

We will not share any of your personal data with any third parties for any purposes, subject to one important exception.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

We will only transfer your personal data to countries that the European Commission has deemed to provide an adequate level of personal data protection. More information is available from the European Commission. Wherever we transfer your personal data outside of the United Kingdom, we will take proper steps to ensure that it is protected in accordance with this Privacy Policy and applicable privacy laws.

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6. HOW CAN I ACCESS MY PERSONAL DATA?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to tiffany@tiffanystalentmgmt.co.uk

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7. YOUR LEGAL RIGHTS

Personal data must be processed in line with an individual’s rights, including the right to:

  • request a copy of their personal data;
     

  • request that their inaccurate personal data is corrected;
     

  • request that their personal data is deleted and destroyed when causing damage or distress; and
     

  • opt-out of receiving electronic communications from us.
     

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Should you wish to make a request in line with your rights as an individual, please email tiffany@tiffanystalen.co.uk

Our People must notify or inform the Data Protection Manager immediately if they receive a request in relation to personal data that the firm processes.

The Data Protection Legislation gives you the right to access information held about you. Your right of access can be exercised in accordance with the Data Protection Legislation (as applicable).

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WHAT WE MAY NEED FROM YOU  

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.

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8. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA  

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

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/Activity

To register you as a new customer  

To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us 

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

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences 

To make suggestions and recommendations to you about goods or services that may be of interest to you

Type of data

(a) Identity (b) Contact

(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications

(a) Identity (b) Contact (c) Profile (d) Marketing and Communications 

(a) Identity (b) Contact (c) Technical  

(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical 

(a) Technical (b) Usage

(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile

Lawful basis for processing including basis of legitimate interest

Performance of a contract with you

(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)

(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) 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

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

Necessary for our legitimate interests (to develop our products/services and grow our business)

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. 

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CHANGE OF PURPOSE  

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. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please email us at tiffany@tiffanystalentmgmt.co.uk

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


  

9.  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. 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.

 

Appendix

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Clients: any person, business or other organisation who engages, or is looking to engage, the services of our Talent.

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Data Protection Manager: an individual who is responsible for ensuring compliance with data protection legislation, including training staff, conducting internal audits, implementing internal policies and being the first point of contact for the Information Commissioner’s Office.

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Data Protection Policy: our internal data protection policy sets out how we keep personal data secure, including technical measures (e.g. encryption of personal data, restricted access to personal data, monitoring and testing systems for unauthorised access, backups of personal data), roles and responsibilities of individuals and the scope of protection.

 

Talent: talent who have engaged, or are looking to engage with our management services, or are considering being represented by us. 

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People: all people providing services to or working for us, including but not limited to our employees, directors, members, and contractors.

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Personal data: information (including opinions) that relates to an individual and from which he or she can be identified either directly or indirectly through other data which we have or are likely to have in our possession. These individuals are sometimes referred to as data subjects.

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Personal Data Breach: a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed by an organisation electronically. A personal data breach may mean someone outside the organisation gets unauthorised access to personal data, but a breach can occur if there is unauthorised access within the organisation or if an employee accidentally alters or deletes personal data.

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Process: the ‘processing’ of personal data captures a wide range of activities, and includes obtaining, recording and holding personal data and performing any operation of the personal data (including erasure/destruction).

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Purpose: the purposes identified in the “Purpose” column of the tables in section 3 of this privacy policy (How we collect, use and disclose your personal data), as applicable.

Terms and Conditions:  the AMA Terms and Conditions for Booking Talent, the Talent Representation Agreement and the Website Terms of Use.  

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Third-party: a person, organisation or other body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.      

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