MARV STUDIOS PRIVACY NOTICE
1.1. This privacy notice (Privacy Notice) sets out the ways in which we, Marv Studios Limited (we, us, our), collect and use your personal data (your personal information) in connection with our business. It also explains what rights you have to access or change your personal data.
1.2. We do not knowingly collect or maintain the personal information of children under the age of 13. We will take appropriate steps to delete the personal information of persons under the age of 13.
2. ABOUT US
2.1. We are a company registered in England under company number 05587621, with our registered address at 71 Queen Victoria Street, London, United Kingdom, EC4V 4BE.
2.2. You can contact us as follows:
Title of Data Privacy Manager: General Counsel
3. INFORMATION WE MAY COLLECT ABOUT YOU
3.1. Information that you provide to us.
3.1.1. We will collect any information that you provide to us when you:
(a) submit correspondence, make an enquiry, provide feedback or make a complaint over the phone, by email or by post;
(b) submit a business proposal to us, or request to work together on a project;
(c) meet with us;
(d) become involved with us in relation to one of our productions;
(e) register to and/or attend one of our events;
(f) submit a CV, a submission or request to work with us, an application to a job vacancy, or attend an interview or assessment; and
(g) ‘follow’, ‘like’, post to or interact with our social media accounts, including LinkedIn and Instagram.
3.1.2. The information you provide to us will include (depending on the circumstances):
(a) Identity and contact data: title, names, and home and business addresses, email addresses and phone numbers;
(b) Financial Data: if you are making any payments to us, or we are making any payments to you, you will also provide payment details, which may include billing addresses, credit/debit card details and bank account details;
(c) Employment and background data: if you are submitting a job application, or you want to work with us, you may also provide additional information about your academic and work history, qualifications, skills, projects that you are/have been involved in, references, proof of your entitlement to work (including passports and visas), your national insurance number, other identity document details, your driver’s licence, your current level of remuneration (including benefits), your background screening results and any other such similar information that you may provide to us; and
(d) Production related information: where relevant, you may also provide personal information such as photograph, likeness, voice, accent, biography, age, clothes size, measurements, complexion, film and sound recordings made in connection with a film or programme, and social media handles.
3.2. Information we collect about you:
(a) Information contained in correspondence: we collect any information contained in any correspondence between us. For example, if you contact us by post, by email or telephone, we may keep a record of that correspondence;
(b) CCTV footage: where you attend our premises, we collect audiovisual CCTV footage of you for security reasons;
(c) Automatic number plate recognition (ANPR): when you attend certain of our premises, we collected your vehicles number plate details through automatic number plate recognition technology; and
(d) Transactional data: we collect information related to your transactions with us, including the date and time, the amounts charged and other related transaction details.
3.3. Information we receive from third parties
3.3.1. In certain circumstances, we will receive information about you from third parties. For example:
(a) Employers, recruitment agencies and referees: if you are a job applicant or want to work with us, we may contact your recruiter, current and former employers and/or referees, who may be based inside or outsde the EU, to provide information about you and your application;
(b) Service providers: we may collect personal information from our IT support provider, payment services provider, and PR agency, who may be based inside or outside the EU;
(c) Publicly available sources: we currently use publicly available sources such as Companies House, and LinkedIn, for instance to carry out identity and compliance checks; and
(d) Business contacts: we may collect personal information from our business contacts, who may be based inside or outside the EU, for example, if they make business contact referrals to us.
3.3.2. Special category information: “special categories” of particularly sensitive personal information (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) and information about criminal convictions and offences requires higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data. We process special categories of personal information:
(a) in limited circumstances, with your explicit written consent;
(b) where we need to carry out our legal obligations or exercise rights in connection with employment;
(c) where it is needed for reasons of substantial public interest, such as for equal opportunities monitoring;
(d) where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent; or
(e) where you have already made the information public.
4. HOW WE USE INFORMATION ABOUT YOU AND RECIPIENTS OF YOUR INFORMATION
4.1. We will use your information for the purposes listed below either on the basis of:
4.1.1. performance of your contract with us and the provision of our services to you;
4.1.2. your consent (where we request it);
4.1.3. where we need to comply with a legal or regulatory obligation; or
4.1.4. our legitimate interests or those of a third party (see paragraph 4.3 below).
4.2. We use your information for the following purposes:
4.2.2. To conduct business with you or your employer, and manage and facilitate our business relationship with you or your employer;
4.2.3. To carry out film and TV production, including developing, producing, insuring, financing, publicising, advertising and exploiting a film or programme, any related products and materials, and any allied or ancillary rights (on the basis of performing our contract with you and our legitimate interest in ensuring the success of our productions and managing related risks);
4.2.4. To carry out our business operations, including maintaining unit and cast lists, data administration, crisis management, arranging travel and accommodation, managing environmental impacts, monitoring health and safety (on the basis of our legitimate interest in ensiring that our business is properly and efficiently administered and operated);
4.2.5. To process and facilitate transactions with us, and to collect and recover money owed to us (on the basis of performing our contract with you and on the basis of our legitimate interest to recover debts due);
4.2.6. For recruitment, including to process any job applications or requests to work with us, whether directly or via an agent or recruiter including sharing this with our third party recruitment agency (on the basis of our legitimate interest to recruit new employees or contractors);
4.2.7. For marketing, including to keep in contact with you about our news, events and new films that we believe may be of interest to you, and sharing your information with our marketing services provider (either on the basis of your consent where we have requested it, or our legitimate interests to provide you with marketing communications where we may lawfully do so);
4.2.8. To interact with you on social media platforms including LinkedIn and Instagram, for example, responding to comments and messages, posting, and ‘liking’ posts (on the basis of our legitimate interest in promoting our brand and communicating with interested individuals);
4.2.9. To make suggestions and recommendations, including sharing your information with selected third parties such as suppliers and partners, to enable them to contact you with information about things that may interest you (where we have your consent to do so);
4.2.10. To carry out research about the performance of our business (on the basis of our legitimate interest in assessing the success of our business);
4.2.11. For fraud and unlawful activity detection, to protect, investigate, and deter against fraudulent, unauthorised, or illegal activity, including identity fraud (on the basis of our legitimate interests to operate a safe and lawful business, or where we have a legal obligation to do so); and
4.2.12. For compliance with policies, procedures and laws, and to enforce our legal rights, or to protect the rights, property or safety of our employees and workers, and to share your information with our technical and legal advisors (on the basis of our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so).
4.3 As outlined above, in certain circumstances we may use your personal information to pursue legitimate interests of our own or those of third parties. Where we refer to using your information on the basis of our “legitimate interests”, we mean our legitimate business interests in conducting and managing our business and our relationship with you, including the legitimate interests we have identified in paragraph 4.2.
4.4. Where we use your information for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you. Our legitimate interests don’t automatically override yours and we won’t use your information if we believe your interests should override ours unless we have other grounds to do so (such as your consent or a legal obligation). If you have any concerns about our processing please refer to details of “Your Rights” in paragraph 8 below.
5. WHO WE MIGHT SHARE YOUR INFORMATION WITH
5.1. In connection with the purposes and on the lawful grounds described above and in addition to the recipients of your information as described above, we will share your personal information when relevant with third parties such as:
5.1.1. Partners and collaborators: our worldwide co-production partners and our brand licensees based in the UK, the USA and Europe;
5.1.2. Our service providers: service providers we work with to deliver our business, who are acting as processors and provide us with:
(a) IT, system administration and security services based in the UK;
(b) worldwide production service providers;
(c) worldwide travel and transport providers providers;
(d) marketing and advertising services based in the UK;
(e) identity verification, fraud prevention and detection services based in the UK;
(f) banking services based in the UK;
(g) worldwide talent agency services;
(h) recruitment service providers based in the UK;
(i) legal, accountancy, auditing and insurance services and other professional advisers based in the EU and USA;
5.1.3. Industry authorities: such as the British Academy of Film and Television Arts (BAFTA), Producers Allicance for Cinema and Television (PACT), Directors UK and other international equivalents;
5.1.4. Co-production companies: based in Europe and the USA;
5.1.5. Corporate affiliates: other affiliated and related companies of the Marv Studios group;
5.1.6. Regulators and governmental bodies: HM Revenue & Customs, regulators, governmental bodies and other authorities acting as processors or joint controllers worldwide who require reporting of processing activities in certain circumstances;
5.1.7. Marketing parties: any selected third party that you consent to our sharing your information with for marketing purposes;
5.1.8. Prospective sellers and buyers of our business: any prospective seller or buyer of such business or assets, only in the event that we decide to sell or buy any business or assets; and
5.1.9. Other third parties (including professional advisers): any other third parties (including legal or other advisors, regulatory authorities, courts, law enforcement agencies and government agencies) where necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure may be permitted or required by law.
5.2. We require third parties to maintain appropriate security to protect your information from unauthorised access or processing.
6. HOW WE LOOK AFTER YOUR INFORMATION AND HOW LONG WE KEEP IT FOR
6.1. We operate a policy of “privacy by design” by looking for opportunities to minimise the amount of personal information we hold about you. We use appropriate technological and operational security measures to protect your information against any unauthorised access or unlawful use, such as:
6.1.1. ensuring the physical security of our offices, premises, studios or other sites;
6.1.2. ensuring the physical and digital security of our equipment and devices by using appropriate password protection;
6.1.3. maintaining a data protection policy for, and delivering data protection training to, our employees and workers; and 6.1.4. limiting access to your personal information to those in our company who need to use it in the course of their work.
6.2. We will retain your information for as long as is necessary to provide you with the services that you have requested from us or for as long as we reasonably require to retain the information for our lawful business purposes, such as for the purposes of exercising our legal rights or where we are permitted to do. We operate a data retention policy and look to find ways to reduce the amount of information we hold about you and the length of time that we need to keep it.
7. INTERNATIONAL TRANSFERS OF YOUR INFORMATION
7.1. Our company is located in the UK.
7.2. We share your personal data with the affiliated and related companies within the Marv Studios group. This will involve a transfer of data outside the EEA.
7.3. Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
7.4. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following transfer solutions are implemented:
7.4.1. We will transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries;
7.4.2. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, European Commission: Model contracts for the transfer of personal data to third countries; and
7.4.3. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
7.5. Please contact us using the contact details at the top of this Privacy Notice if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
8. YOUR RIGHTS TO THE INFORMATION WE HOLD ABOUT YOU
8.1. You have certain rights in respect of the information that we hold about you, including:
8.1.1. the right to be informed of the ways in which we use your information, as we seek to do in this Privacy Notice;
8.1.2. the right to ask us not to process your personal data for marketing purposes;
8.1.3. the right to request access to the information that we hold about you;
8.1.4. the right to request that we correct or rectify any information that we hold about you which is out of date or incorrect;
8.1.5. the right to withdraw your consent for our use of your information in reliance of your consent (refer to paragraph 4 above to see when we are relying on your consent), which you can do by contacting us using any of the details at the top of this Privacy Notice;
8.1.6. the right to object to our using your information on the basis of our legitimate interests (refer to paragraph 4 above to see when we are relying on our legitimate interests) (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;
8.1.7. the right to receive a copy of any information we hold about you (or request that we transfer this to another service provider) in a structured, commonly-used, machine readable format, in certain circumstances;
8.1.8. in certain circumstances, the right to ask us to limit or cease processing or erase information we hold about you; and
8.1.9. the right to lodge a complaint about us to the UK Information Commissioner’s Office (https://ico.org.uk/) as well as a right to lodge a complaint with the relevant authority in your country of work or residence.
Please note that we may need to retain certain information for our own record-keeping and research purposes. We may also need to send you service-related communications even when you have requested not to receive marketing communications.
8.2. How to exercise your rights
8.2.1. You may exercise your rights above by contacting us using the details in paragraph 2 of this Privacy Notice, or in the case of preventing processing for marketing activities also by checking certain boxes on forms that we use to collect your data to tell us that you don’t want to be involved in marketing.
8.2.2. You may contact us viathe details at the top of this Privacy Notice if you wish to action any of these additional rights and we will comply with your requests unless we have a lawful reason not to do so.
8.3. What we need from you to process your requests
8.3.1. We may need to request specific information from you to help us confirm your identity and to enable you 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.
8.3.2. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We will try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
9. SHARING DATA DIRECTLY WITH THIRD PARTIES
9.1. You might end up providing personal information directly to third parties as a consequence of your interactions with us. For example, you may attend an event hosted by us where you communicate personal information directly with other attendees. We are not responsible for how such third parties use personal data provided by you.
10. CHANGES TO THIS PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
10.1. We may make changes to this Privacy Notice from time to time. We will post any changes to our site, or notify you of any material changes by e-mail or mail.
10.2. 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 by updating your personal information by contacting us via the contact details at the top of this Privacy Notice.
This Privacy Notice was last updated on 15 June 2018.