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2. How we use this information
3. How this information is shared
5. Other useful privacy & data security related matters
Who is the Data Controller?
Ponder have appointed a Data Protection Officer ('DPO'). Our DPO can be reached at firstname.lastname@example.org
1. Information we collect
We collect information during research and castings. This information may include, but is not limited to your name, age, postal address, e-mail address, phone number, bank details, photos and video of you and any other details as might be requested from you for the purpose of our work. Not all the personal information we hold about you will always come directly from you. We may also collect information from third parties such as publicly available websites (i.e. social media platforms).
We hold personal data under the following permitted reasons provided by the GDPR- so one of these reasons will apply to your data:
(a) Consent: the individual has given clear consent for you to process their personal data for a specific purpose.
(b) Contract: the processing is necessary for a contract you have with the individual, or because they have asked you to take specific steps before entering into a contract.
(c) Legal obligation: the processing is necessary for you to comply with the law (not including contractual obligations).
(d) Vital interests: the processing is necessary to protect someone’s life.
(e) Public task: the processing is necessary for you to perform a task in the public interest or for your official functions, and the task or function has a clear basis in law.
(f) Legitimate interests:the processing is necessary for your legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.
2. How do we use this information
We process and share with our clients where required, personal information such as your name, age, postal address, e-mail address, phone number, bank details, photos and video of you and any other details as might be requested from you for the purpose of our work in the casting, planning, research and production and post production of films.
Subject to any preferences you have expressed (where applicable), we use personal information to deliver marketing communications to you across various platforms, such as email, telephone, text messaging, direct mail, online, push notification or otherwise.
Except where we use your personal data for marketing purposes on the basis of your prior written consent and subject to any opt out preferences you notify to us in respect of electronic direct marketing communications, we process personal data for marketing purposes as necessary for the purpose of our legitimate interests in promoting our services.
We may be required to use and retain personal information for legal and compliance reasons, such as the prevention, detection, or investigation of a crime; or fraud. We may also use personal information to meet our internal and external audit requirements, information security purposes, and as we otherwise believe to be necessary or appropriate: (a) under applicable law, which may include laws outside your country of residence; and (b) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence. Other purposes: We may be required to use and retain personal information for; loss prevention; and to protect our rights, privacy, safety, or property, or those of other persons in accordance with our legitimate interests.
3. How is the information shared
Based on your consent, your personal information may be shared by us internally and with third parties as required during the course of our work
We may from time to time, retain trusted third parties to process your information to provide us with services globally. As part our agreements with our partners, we may be required to share your personal information when we believe it is required, such as:
To comply with legal obligations and respond to requests from government agencies, including law enforcement and other public authorities, which may include such authorities outside your country of residence;
In the event of a merger, sale, restructure, acquisition, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings);
To protect our rights, users, systems, and Services.
4. Your rights
Under the General Data Protection Regulation, you, as a data subject have a number of rights which are detailed below. Some of these only apply in specific circumstances and are qualified in several respects by exemptions in data protection legislation. We will advise you in our response to your request if we are relying on any such exemptions.
Access to personal data: You have a right to request a copy of the personal information that we hold about you. Should you wish to make such a request, please contact us. You should include adequate information to identify yourself and such other relevant information that will reasonably assist us in fulfilling your request. Your request will be dealt with as soon as possible.
Correction of personal data: You can request us to rectify and correct any personal data that we are processing about you which is incorrect.
Right to withdraw consent: Where we have relied upon your consent to process your personal data, you have the right to withdraw that consent.
To opt out of marketing: You can use the unsubscribe link found in the marketing communication you receive from us.
Right of erasure: You can request us to erase your personal data where there is no compelling reason to continue processing. This right only applies in certain circumstances, it is not a guaranteed or absolute right.
Right to data portability: This right allows you to obtain your personal data that you have provided to us with your consent in a format which enables you to transfer that personal data to another organisation. You may have the right to have your personal data transferred by us directly to the other organisation, if this is technically feasible.
Right to restrict processing of personal data: You have the right in certain circumstances to request that we suspend our processing of your personal data. Where we suspend our processing of your personal data we will still be permitted to store your personal data, but any other processing of this information will require your consent, subject to certain exemptions.
Right to object to processing of personal data: You have the right to object to our use of your personal data which is processed on the basis of our legitimate interests. However, we may continue to process your personal data, despite your objection, where there are compelling legitimate grounds to do so or we need to process your personal data in connection with any legal claims.
Rights relating to automated decision making and profiling: You have the right not to be subject to a decision which is based solely on automated processing (without human involvement) where that decision produces a legal effect or otherwise significantly affects you. This right means you can request that we involve one of our employees or representatives in the decision-making process. We are satisfied that we do not make automated decisions of this nature.
5. Other useful privacy & data security related matters
Retention We retain personal information for as long as we reasonably require it for legal or business purposes. We will take all necessary steps to ensure that the privacy of information is maintained for the period of retention.
Security We are committed to employing security measures to protect your information from access by unauthorised persons and to prevent accidental or unlawful processing, disclosure, destruction, loss, alteration and damage. As the security of some communications via the internet is not completely secure, we cannot guarantee the security of any information that you disclose using your internet connection. You accept the inherent security implications of using the internet and we will accept no liability for any direct, consequential, incidental, indirect, or punitive losses or damages arising out of such an occurrence.
6. How to contact us
For any requests related to your personal information or any of your rights referenced above, please feel free to contact us:
Ponder Media Limited, Sandycove, Co Dublin A96E6X9, Ireland. email@example.com
Filing a complaint
If you are not satisfied with how we manage your personal data, you have a right to make a complaint to your local Data Protection Authority.
Published on 2/05/2021