We fully endorse and adhere to data protection law across Europe in the form of the General Data Protection Regulation (GDPR), the gold standard of data protection legislation, and the equivalent data protection laws in the UK. We have registered as a data controller under the UK Data Protection Act, and can be found in the Data Protection Public Register. We also work in accordance with relevant standards including the UK\u2019s Age Appropriate Design framework.<\/span><\/p>\nRelationships when we are not your Data Controller<\/b><\/h4>\n
If you are a performer, young performer or graduate who has purchased or subscribed to Spotlight\u2019s Services (“Spotlight Member<\/strong>“) please note that your authorised agent (“Agent<\/strong>“) (if you are represented) or training establishment may also act as your Data Controller both for the supply of your information to Spotlight and its use in submissions made by your Agent on your behalf via one of our Services, The Spotlight Link, and additionally for any third party tools your Agent or training establishment may employ to administer your data. It is your responsibility to ensure that your Agent or training establishment only processes your personal information in accordance with your wishes. Casting professionals that have purchased or subscribed to Spotlight\u2019s Services (“Casting Subscribers<\/strong>“) also act as your Data Controller where they determine the purposes for the administration of personal information in finding and hiring professional performers, working with agents, and collaborating with other project members. Please do contact them with any queries you have in respect of their processing of your personal information.<\/span><\/p>\nIn addition, we may also offer Spotlight Members the option of having their profiles made available online by our third-party partners, in which case that third party partner may also act as your Data Controller. For more information about how a third-party partner will process your personal information, please visit their privacy policy.<\/span><\/p>\nHow do we make sure your data is used lawfully?<\/b><\/h4>\n
We will only collect, use, store, share (and any other of the defined uses of processing data) where we have a lawful basis to do so, as defined by data protection legislation, and do not collect more information than we need to fulfil the specific purpose. We document which lawful bases are relied upon for our processing activities. Lawful bases include where you have given consent, where processing is necessary for the performance of a contract with you, when complying with law and where there we have legitimate interests to do so. More information on how we apply these lawful bases is provided below:<\/span><\/p>\n\n- Consent \u2013 In certain situations we process your data with your consent. Where we process data based on your consent, we will ask you for your explicit consent (you have to take an action) which you can withdraw at any time, but it will not affect the lawfulness of processing before then. If you are under 16, consent will be obtained from your parent or guardian.<\/span>\n
\n- For example, you tick a box to receive email marketing communication from us.<\/span><\/li>\n<\/ul>\n<\/li>\n
- Contract \u2013 In certain situations, we need your personal information to comply with our contractual obligations.<\/span>\n
\n- For example, if you become a Spotlight Member we will collect and process your information so we can deliver Services to you.<\/span><\/li>\n<\/ul>\n<\/li>\n
- Complying with law \u2013 we may need to process your personal information if the law requires us to.<\/span>\n
\n- For example, we may have to pass on information of people in fraud or other criminal activity to law enforcement.<\/span><\/li>\n<\/ul>\n<\/li>\n
- Legitimate interest \u2013 We will only rely on legitimate interests where the processing of your data is not overridden by your interests or rights and freedoms. This means that we may need your information and use in a way that can reasonably be expected as part of us running Spotlight and does not materially impact your rights, freedoms or interests.<\/span>\n
\n- For example, we may use your information to build a more accurate picture of you to better inform our business decisions, or to provide you with relevant product or service offerings.<\/span><\/li>\n<\/ul>\n<\/li>\n<\/ul>\n
When do we collect your personal information?<\/b><\/h4>\n
We will collect personal information from you when you:<\/span><\/p>\n\n- Visit and\/or use our Platform and\/or Services;<\/span><\/li>\n
- Sign up to or use Platform and\/or Services (e.g. as a Spotlight Member);<\/span><\/li>\n
- Purchase or subscribe to a product or Service from us (e.g. a room bookings or editing sessions);<\/span><\/li>\n
- Book to attend an event;<\/span><\/li>\n
- Complete a survey or feedback form;<\/span><\/li>\n
- Provide feedback or review our Platform and\/or Services;<\/span><\/li>\n
- Correspond with us on social media;<\/span><\/li>\n
- Contact us with a form of query, compliment or complaint (plus other types of enquiries) via phone, email, post or otherwise; or<\/span><\/li>\n
- Enter a competition or prize draw.<\/span><\/li>\n<\/ul>\n
What personal information do we collect?<\/b><\/h4>\n
We will only ever ask you for the necessary information needed to process your data. We may process your data including the following personal information:<\/span><\/p>\n\n- Name and previous names;<\/span><\/li>\n
- Gender;<\/span><\/li>\n
- Date of birth;<\/span><\/li>\n
- Address(es) or location data;<\/span><\/li>\n
- Email;<\/span><\/li>\n
- Telephone number(s);<\/span><\/li>\n
- Information pertaining to disability, ethnicity and heritage;<\/span><\/li>\n
- Physical details such as height;<\/span><\/li>\n
- Training and skills;<\/span><\/li>\n
- Information\/ documents to enable us to vet an application;<\/span><\/li>\n
- Information\/ documents you provide to prove age, identity or other requirement where the law requires this to confirm discount eligibility;<\/span><\/li>\n
- Technical information such as your browser or device type, or your IP address;<\/span><\/li>\n
- Information gathered by the use of cookies;<\/span><\/li>\n
- Telephone call recordings (for training and monitoring purposes);<\/span><\/li>\n
- Photographs, video and audio clips, and metadata relating to this such as copyright information;<\/span><\/li>\n
- Career history;<\/span><\/li>\n
- URLs and links to social media;<\/span><\/li>\n
- Bank and payment data;<\/span><\/li>\n
- Closed Circuit Television (CCTV) footage in accordance with Spotlight\u2019s CCTV Policy;<\/span><\/li>\n
- For security, a robustly-asymmetrically encrypted record of your login password.<\/span><\/li>\n<\/ul>\n
Please note, that as many of our Services are primarily promotional tools, personal information included in these public profiles may be accessible by other Spotlight users and\/or the public via wide circulation or redistribution, and via our historical archives. Therefore you should never include any personal information on your profile that you would wish to remain private.<\/span><\/p>\nHow will we use your personal information?<\/b><\/h4>\n
We (or third-party data processors acting on our behalf) may collect, store, use and share your personal information for the following purposes:<\/span><\/p>\n\n- To provide you with the Spotlight Services, including making your public profile information available (including via our third-party partners if you have requested that we do so), and searchable where applicable, to other users of the Services;<\/span><\/li>\n
- To fulfil orders for products or Services (including recognising returning members, returning customers and previous member applicants);<\/span><\/li>\n
- To keep your details and records up-to-date and accurate;<\/span><\/li>\n
- To provide you with important service communications relating to our products or Services;<\/span><\/li>\n
- To provide you with alerts and notifications to you based on your preferences including via email and push notifications;<\/span><\/li>\n
- To communicate with you regarding professional industry enquiries;<\/span><\/li>\n
- To invite you to and manage your attendance at Spotlight and our partner events;<\/span><\/li>\n
- To answer\/respond to your enquiries and complaints or otherwise communicate with you;<\/span><\/li>\n
- To process and share audio and visual content including self-tape and audition videos;<\/span><\/li>\n
- To vet your professional background when you are joining as a Spotlight Member\/Agent\/Casting Subscriber or purchasing a restricted access product;<\/span><\/li>\n
- To enable agents to find performers seeking representation;<\/span><\/li>\n
- Internal record keeping;<\/span><\/li>\n
- To notify you of other products and\/or services that we think will be of interest to you (you can unsubscribe from these communications at any time by managing your notifications within your account or by submitting a <\/span>request<\/span><\/a> to our Support team);<\/span><\/li>\n
- To inform you of latest developments within Talent Systems companies and the wider industry (provided that we have your consent to do so);<\/span><\/li>\n
- To contact you as an expired member or subscriber about how you can rejoin Spotlight (provided that you have not indicated that you no longer wish to receive communications from us);<\/span><\/li>\n
- To assist in the creation and editing of audio and visual content;<\/span><\/li>\n
- To improve our products and Services;<\/span><\/li>\n
- To understand information which may better inform business decisions;<\/span><\/li>\n
- To verify your identity;<\/span><\/li>\n
- For market research and analysis, such as receiving opinions and feedback on our products and Services;<\/span><\/li>\n
- To administer prize draws or competitions where you have entered into;<\/span><\/li>\n
- To process payments and identify or prevent fraudulent transactions;<\/span><\/li>\n
- To develop, test and improve our Platforms, Services and products that we provide to you;<\/span><\/li>\n
- For training and monitoring purposes;<\/span><\/li>\n
- To provide you with access to specific search facilities;<\/span><\/li>\n
- To provide you with useful information and statistics about your and other users of the Platforms\u2019 activities;<\/span><\/li>\n
- To comply with any legal obligation such as to share data with law enforcement;<\/span><\/li>\n
- To ensure the safety of staff, visitors and Spotlight\u2019s buildings and offices;<\/span><\/li>\n
- To provide guest WiFi services within Spotlight offices in accordance with the Guest WiFi Terms of Use;<\/span><\/li>\n
- To improve and personalise our Platform and Services to you; and<\/span><\/li>\n
- To facilitate the historical archiving of information, including Spotlight public profiles\/titles both in print and digital formats and media footage.<\/span><\/li>\n<\/ul>\n
What personal information do we share?<\/b><\/h4>\n
We share personal information with carefully selected and trusted third parties when required. Wherever possible only information contained within your public profile would be released to such third parties. To keep your data safe and maintain your privacy we have the following approach:<\/span><\/p>\n\n- We implement appropriate legal, procedural and technical controls;<\/span><\/li>\n
- We only provide the information they need to undertake that service;<\/span><\/li>\n
- We ensure that they can only use the information for that specific purpose;<\/span><\/li>\n
- We maintain a close relationship to make sure that your data is protected and your privacy maintained;<\/span><\/li>\n
- We mandate that if or when the service stops, they must return or delete any information held.<\/span><\/li>\n<\/ul>\n
Here are the examples of the types of trusted third parties we work with:<\/span><\/p>\n\n- Within the <\/span>Talent Systems Group<\/span><\/a>;<\/span><\/li>\n
- Spotlight network partners who may, for example, circulate breakdown information via their casting platforms in other territories, provide the opportunity for Spotlight Members\u2019 profiles to be made available on the partner\u2019s own website, or provide the ability for users to access their platform. More information can be found on our network partners by visiting https:\/\/www.spotlight.com\/our-partners\/<\/a>;<\/span><\/li>\n
- Subcontractors assisting us in providing our service to our users;<\/span><\/li>\n
- IT companies who help us deliver our Platforms and services;<\/span><\/li>\n
- Google APIs \u2013 we use Google APIs to help us provide better services to you, such as the Google Places API which enables you to provide consistent location data in a secure and non-intrusive way. Please note that you are bound by Google\u2019s <\/span>Terms of Service<\/span><\/a> and <\/span>Privacy Policy<\/span><\/a> when you use parts of our service which are powered by Google;<\/span><\/li>\n
- Third parties who provide service enhancements or additional functionality to our users related to how they use our services;<\/span>\n
\n- More information: In order to facilitate certain users of Spotlight with their workflow management processes or other functionality, Spotlight may from time to time provide or authorise the use of certain third-party software or applications to facilitate additional off-site access to the professional materials and content otherwise available via the Services. An example of this would be third party tools used by Agents to administer their client submissions to casting services alongside diary management etc, or software used by casting directors during the audition process. Such third-party packages or systems should only be used subject to the written approval of Spotlight. You acknowledge that your personal information may be used in this way. Please note however that Spotlight does not endorse and is therefore not responsible for any such third-party packages or systems, and Spotlight will not be liable for any loss of information, materials, data or otherwise that may occur due to the use of your information within them.<\/span><\/li>\n<\/ul>\n<\/li>\n
- Third parties who are involved in furthering research and technology in areas connected with our service;<\/span>\n
\n- More information: We are constantly looking for new ways to change and upgrade our Services and functionality. This may involve partnering with selected and trusted research organisations and technology providers to contribute to their research and innovation projects. Often the most innovative developments come from other industries or fields of research outside of our own, and the outputs of the research may have a broader application beyond the improvements from which we directly benefit. As part of this research our trusted partners may be given access to our systems and data and\/or be provided with copies of our data, including member photos, video and audio clips, and other professional information from their public profile. In all such circumstances our partners\u2019 access to and use of this information will be comprehensively documented and strictly limited to specific research projects that may include benefits for Spotlight and our Services to you, and will be under secure, confidential, temporary conditions, and closed testing environments. Under no circumstances will this information be used for any commercial or live operational activity, other than to develop and test the specific technology and functionality, without your prior consent.<\/span><\/li>\n<\/ul>\n<\/li>\n
- Marketing and advertiser partners to improve and personalise our Platform and Services to you.<\/span><\/li>\n
- Law enforcement in complying with the law, or to enforce our Terms and Conditions or to protect the rights, property, or safety of ourselves, our customers or other third parties.<\/span><\/li>\n
- If we acquire any new business, and\/or sell all or part of our business;<\/span><\/li>\n
- Third party payment service providers; and<\/span><\/li>\n
- Third parties as detailed within your specific Membership Terms.<\/span><\/li>\n<\/ul>\n