Fitting Models UK Ltd Holten Ltd
Effective Date: 25 May 2018
WHO WE ARE
12 Barley Mews
WHAT DATA ABOUT ME IS COLLECTED AND HOW IS IT USED?
How we Collect and Use Your Personal Data
- If You Use Our Internet Products
We automatically collect information including Personal Data when you browse our Website or use our Internet Products, such as your IP address, browser type, operating system, error logs, and other similar information. Such aggregated in-formation does not allow us to identify you and is used by us to analyse trends, to administer the Website, to monitor our Website’s use, and to gather general information about the use of our Website. The legal basis for such processing of your Personal Data are our legitimate interests (Art. 6(1)(f) GDPR) in customizing the content of our services in line with user preferences and in further improving our Internet Products. Our Website offers a free facility for models to advertise their portfolio and measurements to potential clients/hirers. We will only upload or have uploaded such data with your prior consent according to Art. 9(2)(a) GDPR, except where permitted or required by applicable law. Please note that you are not legally required to provide us with your Personal Data. However, without your Personal Data we will not be able to assist in sourcing Models/Talent for Customers or to find Hirers for the models/Talent Such processing of your Personal Data is necessary for the performance of our services. The legal basis for such processing of your Personal Data is therefore Art. 6(1)(b) GDPR. As regards health-related information, we will only process such da-ta with your prior consent according to Art. 9(2)(a) GDPR, except where permitted or required by applicable law. You are contractually required to provide us with such in-formation and without such information we are not able perform the services as de-scribed above.
- If we Send you Candidate/Job Assignment Updates
We use your Personal Data to send you important service announcements and up-dates regarding potential bookings, availability checks, Website or Internet Products or, if you are a subscriber, about your billing account status. When you become a community user or when you subscribe to our Internet Products, we will send you a welcome email to provide transactional information about your subscription or to verify your username and password. Such service announcements and updates contain important information relevant to your use of our Website and/or our Internet Products. The processing of your Personal Data for such purposes is necessary for the performance of our services. The legal basis for such processing of your Personal Data is therefore Art. 6(1)(b) GDPR. Please note that you are contractually required to provide us with such Personal Data and that without such Personal Data we will not be able to send you service-related communication.
- If you Contact us by Telephone or email.
If you contact us, we will communicate with you in response to your inquiries, to provide the services you request. We will communicate with you by email or telephone, in accordance with your preferences. Such processing of your Personal Data is necessary for the performance of our services; the legal basis for such processing of your Personal Data is therefore Art. 6(1)(b) GDPR. Please note that you are contractually required to provide us with such Personal Data and that without such Personal Data we will not be able to send you customer service related communications.
- If you Subscribe to Newsletters and other Marketing Communications
When subscribing to our Internet Products or elsewhere on our Website you have the option to consent to receiving newsletters and other information on our products and services. If you “opt-in” we will send you promotional newsletters and inform you about offers, events and surveys via e-mail and through social media platforms. The legal basis for such processing of your data is your consent (Art. 6(1)(a) GDPR) or – if you are an existing customer or subscriber – our legitimate interest (Art. 6(1)(f) GDPR) in providing you with relevant marketing information. Please note that you are not legally required to provide us with your Personal Data. However, without your Personal Data we will not be able to send you our newsletters and other information as described above. You have the option to opt-out of these types of communication at any time by following the respective instructions in such communication.
- If you Use our Social Features
Our Website features public forums such as message boards, bulletin boards, links to our social media apps where you can swap or similar activities where you and other users of our Website can communicate with one another. In addition, we offer the “Model Profile” feature of our Website to permit you to share information about yourself (including, if you select, Personal Data) with others (together “Social Features”). If you use these Social Features, please be aware that we cannot control how other users of our Website might use your data. We also cannot prevent you receiving un-wanted messages from other users. If you wish that a specific content generated by you shall be removed from the Social Features on our Website, please contact us at the contact details as mentioned below. Any Personal Data posted via the Social Features are processed in order to provide you with the respective service and the legal basis is therefore Art. 6(1)(b) GDPR. Please note that you are not legally required to provide us with your Personal Data, but that you will not be able to use our Social Features without providing your data.
- Strictly necessary cookies: These cookies are essential for you to use our Website and our Internet Products.
- Performance cookies: These cookies collect information about how you use our Website. We use such data to help optimise our Website and make it easier for you to navigate and use our Internet Products.
- Functional cookies: These cookies allow our Website and Internet Products to remember the choices you make using our Website and personalise your experience.
- Third Party cookies: Third party cookies are those placed by websites and/or parties other than us. These cookies are used on our Website to improve our Internet Products or to help us provide more relevant advertising. These cookies are subject to the respective privacy policies of the external service providers placing the cookies on your browser. Visit youronlinechoices.euto learn more about your options and how to opt-out of such third-party cookies
- Analytics cookies: We use analytics cookies to help us understand how users browse our Website and how they arrived at our Website. We use a variety of website analytics providers such as Google Analytics, Hot Jar, Optimizely and Exact Target. These cookies are subject to the respective privacy policies of the external service providers and to learn more about your options and how to opt-out of such analytics cookies visit the respective providers web site for details.
SOCIAL PLUG-INS AND OTHER THIRD-PARTY FEATURES
To the extent certain third-party website features are available on our Website, the following terms apply:
We use plug-ins of the social networks Facebook, Pinterest, Twitter, Instagram and YouTube to enable our Website users to easily share content found on our Website and connect with their friends via such social networks. Whenever you view a page of our Website containing such plug-in, your browser establishes a direct connection to the servers operated by provider of the social network. As a result, the content of the social plug-in is transferred by the network provider directly to your browser and embedded in our Website being shown. If you visit our Website whilst signed into your social network user account, information concerning your visit will be transferred to the network provider and the provider of the social network can assign your visit to our Website to your account with the social network. Please note that a data transfer is triggered already when you visit our Website, irrespective whether you interact with the plug-in. To prevent this, you must log out of your social network account before visiting our Website. Please refer to the privacy policies of Facebook, Pinterest, Twitter, Instagram and YouTube for more information on the purpose and scope of data collection and data analysis undertaken by the social network as well as your options to modify settings and how to protect your privacy.
HOW WE SHARE AND DISCLOSE PERSONAL DATA
We will not share, sell, transfer or otherwise disseminate your Personal Data to third parties, unless required by law according to Art. 6(1)(c) GDPR, unless required for the purpose of your contract according to Art. 6(1)(b) GDPR, unless the third-party acts as a data processor on our behalf according to Art. 28 GDPR or you have given us express consent to do so according to Art. 6(1)(a) GDPR.
Your Personal Data as described above if you have opted in will be shared on our website and mailshots to potential clients/Hirers. The data is securely stored and staff having access to any of the data are fully trained of the safe processing. Data will be used by Fitting Models UK Ltd, Sister Company Holten Ltd.
We also use third-party service providers to offer or facilitate services on our behalf and share your Personal Data with such providers to the extent necessary for such providers to perform their services on our behalf. In particular, we use a mailing company to dispatch email marketing messages, payment service providers to bill you for goods and services and for credit card processing, specialist providers for payment collection and fraud screening, a shipping company to fulfil orders, , social media and other agencies to manage our social media and other advertising campaigns, a cloud provider for our CRM Accounting system and an external provider for the hosting of our web shop.
Some of the companies we share your Personal Data with as described above are located outside of the European Economic Area.
In order to grant sufficient protection of your Personal Data in this context, we use standard data protection clauses adopted by the European Commission according to Art. 46(2)(c) GDPR with such companies or certifications of such companies under the EU-U.S. Privacy Shield according to Art. 45(1) GDPR. You can request further details by contacting us at the contact details as mentioned below.
We may also be required to disclose your Personal Data to government or law enforcement officials in response to a lawful request by a public authority or if we have to do so to comply with a legal obligation, including to meet national security or law enforcement requirements according to Art. 6(1)(c) GDPR. We can also disclose your information in order to pursue our legitimate interest in applying or enforcing our terms and conditions or in responding to any claims, in protecting our rights or the rights of a third party, in protecting the safety of any person or in preventing any illegal activity (including for the purposes of fraud protection and credit risk reduction) according to Art. 6(1)(f) GDPR. I
If required under applicable data protection laws, we will collect your prior consent before sharing your Personal Data with other companies. In such cases, the legal basis is Art. 6(1)(a) GDPR.
IS MY PERSONAL DATA USED FOR ANY OTHER PURPOSES?
WHAT RIGHTS DO I HAVE?
You have the following rights:
- Right of access (Art. 15 GDPR):
You have the right to request confirmation as to whether we process your Personal Data and where that is the case, to request access to the Personal Data we hold about you.
- Right to rectification (Art. 16 GDPR):
You have the right to request the correction of inaccurate Personal Data.
- Right to erasure (Art. 17 GDPR):
You have the right to request erasure of Personal Data without undue delay under certain circumstances, e.g. if your Personal Data is no longer necessary for the purposes for which it was collected or if you withdraw consent on which our processing is based according to Art. 6(1)(a) GDPR and where there is no other legal ground for processing.
- Right to restriction of processing (Art. 18 GDPR):
You have the right to request us to restrict the processing of your Personal Data under certain circumstances, e.g. if you think that the Personal Data we process about you is incorrect or unlawful.
- Right to data portability (Art. 20 GDPR):
Under certain circumstances, you have the right to receive your Personal Data you have provided us with, in a structured, commonly used and machine-readable format and you have the right to transmit that information to another controller without hindrance or ask us to do so.
- Right to object (Art. 21 GDPR):
You have the right to object to the processing of your Personal Data under certain circum-stances, in particular if we process your Personal Data on the legal basis of legitimate interests (Art. 6(1)(f) GDPR) or if we use your Personal Data for marketing purposes. You can assert your abovementioned rights by contacting us at the contact details mentioned below.
RIGHT TO LODGE A COMPLAINT BEFORE THE DATA PROTECTION AUTHORITY
You have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work or place of the alleged infringement if you consider that our processing of your Personal Data infringes the applicable data protection laws. Please contact us at the contact details mentioned below and we will assist you to identify the respective competent supervisory authority.
We store your Personal Data and other information for as long as necessary to enable you to use our Website and our Internet Products, to provide our services to you, to comply with applicable laws (including those regarding document retention), to resolve disputes with any parties and otherwise as necessary to allow us to conduct our business. If you have a question about a specific retention period for certain types of Personal Data we process about you, please contact us at the contact details mentioned below.
AUTOMATED INDIVIDUAL DECISION-MAKING
We do not use your Personal Data to make decisions with legal or similar effects for you based on the automated processing of your Personal Data only.
WHO DO I CONTACT IF I HAVE ANY PRIVACY QUESTIONS?