Entertainment Partners and its affiliates (“EP”, “we”, “us” or “our”) are committed to maintaining meaningful privacy protections for all individuals who interact with EP. This Global Privacy Notice (“Privacy Notice”) describes EP’s practices with respect to your personal information, including the types of information we collect, how we use and share that information, and your choices. This Privacy Notice covers information collected through:

• Our websites that link to this Privacy Notice (“Websites”);

• Our online applications, platforms, services, and tools that can only be accessed with valid login credentials (“Online Services and Platforms”);

• Our payroll and related services (“Payroll Services”) provided to EP’s clients to facilitate the payment of entertainment production workers (“Talent and Crew Members”); and/or

• Our background casting and related services (“Casting Services”).

Which EP entities are involved?

The EP entity responsible for your personal information will depend on your location, the product or service you use with us and whether EP is acting as a controller or processor/service provider. Where EP is acting as a processor/service provider, please inquire directly with the applicable controller entity if you are interested in learning more about its privacy practices.  EP is not responsible for the privacy or data security practices of our customers, which may differ from those explained in this Privacy Notice.

Please see EP’s Controller/Affiliates List for more information about our affiliated companies. 

EP collects information: (i) directly from you when you provide it to us voluntarily or involuntarily; (ii) automatically when you interact with our Websites and Online Services and Platforms; and (iii) from third parties such as our clients and business partners. The types of personal information that we collect from you will depend on who you are and your relationship with us.

Information you provide to us directly may include:

• Contact Information, such as postal address, email address and telephone number;

• Identity Information, such as name, photograph, and social security number;

• Online Credential Information, such as username and password;

• Demographic Information, such as date of birth/age, gender, nationality, and trade union membership;

• Diversity Information such as whether you have a disability;

• Financial Information such as bank account, credit card details, and other payment information;

• Insurance Information, such as national insurance number, policy number or coverage information for health or other personal insurance;

• Education and Employment Information, such as educational background, current and prior employment, job title, CV, right to work documentation, and results of criminal background checks;

• Internet and Other Network Activity Information, such as online identifiers such as IP address or device identifiers, browsing history, search history, and information about interactions with websites, applications, or advertisements;

• Marketing and Communications Information, such as correspondence and other information you sent to us, your preferences in receiving marketing from us and our third parties, and your communication preferences;

• Loan Out Information, such as information about your lender company, such as company name, registration number, registered office, lender signatory name and email; and

• [Limited] Health Information relating specifically to COVID-19.

Information you provide to us voluntarily includes:

• Family Information/ Emergency Contact Information, such as name and relationship status;

• Appearance Information, such as information about your appearance, including physical measurements;

• Talent Availability and Preferences Information, such as additional information provided by talent for use by other users of the Platforms, such as talent’s availability and professional preferences;

Information we collect automatically includes:

• Transaction Information, such as details about payments from you and other details of products and services you have purchased from us;

• Technical Information, such as IP address, browser type, internet service provider, operating system, date/time stamp, location, browser plug-in types and versions, mobile device identification numbers, cookies, web beacons, pixel tags and other technology on the devices you use to access our online platform(s); and

• Usage Information, such as information about how you use our online platforms and other services, such as the website you visit before and after visiting our website (including date and time), time and length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), search queries, and methods used to browse away from the page.

Information we collect from third parties includes:

• Publicly Available Information, such as information available from websites, directories, and other public sources;

• Financial Information;

• Tax Information; and

• Talent and Crew Information from our clients about their current, prospective, and former members, including name, address, email address, date of birth, social security number, telephone number, citizenship status, and information about their dependents and family members.

We use the information collected through our Websites, Online Services and Platforms, Payroll Services and Casting Services to:

• Provide and improve our products and services;

• Understand how you interact with our Websites, Online Services, and Platforms;

• Register users for our Online Services and Platforms, Payroll Services, and Casting Services

• Communicate with you, including by communicating with you through chat features, sending announcements, email alerts, event registrations, campaigns, newsletters, updates, and support and administrative messages;

• Authenticate users;

• Perform analytics;

• Prevent and detect fraud and misuse;

• Comply with legal requirements;

• Provide customer service support and respond to your inquiries

• Verify eligibility for certain opportunities, programs, or benefits;

• Conduct surveys;

• Generate leads;

• Conduct investigations regarding violations of our policies, terms of use, or other legal rights, in accordance with applicable law; and

• Perform any other function requested by you or our clients.

In many contexts, EP acts as a processor or service provider for a controller. In those situations, we process personal information only on documented legally compliant instructions from the applicable controller entity.

In situations where EP acts as a controller, we process your personal information: with your consent, where necessary to enter into or perform a contract with you, where processing is necessary for compliance with our legal obligations, or where doing so is necessary for purposes of our legitimate interests that are not overridden by your interest or by your fundamental rights and freedoms.

For the purposes of the General Data Protection Regulation, we rely upon a number of legal bases to enable our processing of your personal information. For more information, see our Legal Bases Tables for a detailed overview of why and how we use your personal information.

We may share and disclose your personal information as necessary for the purposes set out in this Privacy Notice:

• With our affiliates.

• With our third-party processors/service providers. All processors/service providers are governed by this Privacy Notice or are bound by confidentiality or data protection agreements that offer similar protections.

• With our companies that assist us in our marketing, advertising and promotional activities.

• Analytics and search engine providers that assist us in the improvement and optimisation of our online platforms.

• With our clients. In order to provide products or services to you or EP clients, we will disclose the personal information of Talent and Crew Members to EP clients receiving Payroll Services or Casting Services for those Talent and Crew Members.

• With third parties designated by our clients, such as banks, tax agencies and benefit providers.

• With government, competent authorities, law enforcement officials or the courts and as otherwise required to meet national security or law enforcement requirements or to prevent illegal activity (where required by law).

• Where required to establish, exercise or defend our legal rights, including to enforce or apply our Terms of Use or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person, or to prevent any illegal activity.

• To protect the rights, property or safety of EP, our staff, our customers/clients or other persons. This may include exchanging personal information with other organisations for the purposes of fraud protection and credit risk reduction.

• If EP merges, sells or buys any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets as well as to their legal, financial and other professional advisers.

EP may make third party applications available through its Websites, Online Services and Platforms. Collection of information by a third-party application is governed by the privacy policy of the third-party application provider.

EP’s Websites contains links to other sites. EP does not share your personal information with those sites and is not responsible for their privacy practices. If you submit personal information to any of those sites, your information is governed by their privacy policies.

EP’s Websites may contain links to third party sites co-branded with an EP logo, even though the sites are not operated or maintained by EP. EP is not responsible for the privacy practices of sites operated by third parties that are linked to our Websites.

EP’s Websites include social media features and widgets. Your interactions with these features are governed by the privacy policies of the companies providing them.

EP uses Plaid Inc. (“Plaid”) to gather your data from financial institutions. By using certain of our Online Services, you grant EP and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from your relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid End User Privacy Policy.

EP uses Stripe, Inc. (“Stripe”) to process credit card payments made to us. In connection with the processing of such payments, we do not retain any personal or financial information such as credit card numbers. Rather, all such information is provided to our third-party processor. If you use a credit card to pay for our Online Services and Platforms on our Website, the credit card payment processing services are provided by Stripe and are subject to the Stripe Terms of Service and the Stripe Privacy Policy, (collectively, the “Stripe Services Agreement”). By using the credit card processing services, you agree to be bound by the Stripe Services Agreement, as the same may be modified by Stripe from time to time. As a condition to our enabling credit card payment processing services through Stripe, you agree to provide us accurate and complete information about you, and you authorize us to share any such information with Stripe, as well as transaction information related to your use of the payment processing services provided by Stripe. In all cases, standard credit card or third-party processing fees apply in addition to the fees for the applicable services. We are not responsible for the performance of any third-party credit card processing or third-party payment services.

EP uses SheerID, Inc. (“SheerID”) to assist with verifying information you provide to us. Information provided will be processed by SheerID in accordance with their Privacy Policy.

EP uses Drift.com, Inc. to assist with customer engagement based on information you provide to us. Information provided is subject to potential monitoring and recording and processing by Drift.com is in accordance with our Global Privacy Notice.

We use industry standard security safeguards to protect our Websites, Online Services and Platforms, Payroll Services and Casting Services against unauthorised or unlawful access and against accidental loss, theft, disclosure, copying, modification, destruction or damage. We review our security policies and procedures on a regular basis and update them as needed to maintain their relevance. We require all third parties to whom we transfer personal information to maintain adequate security safeguards in compliance with applicable laws and standards to protect personal information.

If you have created a profile on one of our Online Services and Platforms, you play an important role in keeping your information secure. You should not share your username, password, or other account information with anyone.

In the course of provision of your personal information to us, your personal information may be transferred over the internet. Although we make every effort to protect the personal information which you provide to us, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your personal information transmitted to our website and that any such transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to prevent unauthorised access to it. An overview of our data security practices can be found in our “Security Features” page.

If you believe that the security of our systems or services has been compromised, please contact us immediately as detailed in the “Contact Us” section.

We retain your personal information in accordance with applicable laws and regulations and our retention policy based on these laws and regulations.

The period for which we keep your personal information is determined by a number of criteria, including for as long as your account is active, for as long as needed to provide you or our clients with the services requested, or as long as needed to comply with our legal obligations, resolve disputes, and enforce any agreements.

To exercise any rights you have, you can submit a request using our online form or by calling EP toll-free at (877) 437-8734. Alternatively, you can contact us as detailed in the “Contact Us” section to exercise any of your data protection rights. You may be required to provide additional information necessary to confirm your identity before we can respond to your request. The information you provide will not be used for any other purpose.

Depending on your location and subject to applicable law, you may have the following rights in relation to your personal information:

• Right of access. You can ask us for a copy of your personal information, confirmation whether your personal information is being used by us, and details about how and why it is being used.

• Right to rectify/update your information. You can ask us to correct any personal information that is inaccurate.

• Right to delete your information. You can ask us to delete your personal information in certain specific circumstances.

• Right to restrict use of your information. You can ask us to restrict the way that we process your personal information in certain specific circumstances.

• Right to object. You can ask us to consider any valid objections which you have to our use of your personal information in certain circumstances.

• Right to stop marketing. You can ask us to stop using your personal information for direct marketing purposes.

• Right to data portability. You can ask us to provide you with the personal information that you have provided to us, in a structured and commonly-used electronic format, or to transmit that information directly to another company if that is technically feasible. This right only applies where we use your personal information on the basis of your consent or performance of a contract, and where our use of your personal information is carried out by automated means.

• Right to withdraw consent. In circumstances where we process your personal information on the basis of your consent, you have the right to withdraw your consent at any time.

• Right to opt-out of sale of personal information. We do not sell personal information, therefore we do not offer an opt-out.

• Right not to be discriminated against for exercising these rights. We do not discriminate against individuals who exercise their privacy rights.

• Right to appeal any decision by EP relating to these rights. You have the right to lodge a complaint with a supervisory authority if you believe we have processed your personal information inconsistent with your rights.

Please note that some of these rights may be subject to exceptions under applicable data protection law (such as exceptions to ensure we can continue to use the information to comply with our own legal obligations or to establish, exercise or defend legal claims).

Where technically feasible and unless EP is permitted or required by law otherwise, EP makes it possible for you to review and update your personal information, either directly through the self-service feature on our Online Services and Platforms or by directing you to the applicable controller entity or EP client for access.

If you prefer not to receive cookies while browsing our Websites, you can set your browser to warn you before accepting cookies and refuse cookies when your browser alerts you to their presence. You can also refuse all cookies by turning them off in your browser, although you may not be able to take full advantage of our Websites if you do so. You may be required to accept cookies in order to complete certain actions on our Websites.

We may transfer your personal information from your country or jurisdiction to other countries or jurisdictions around the world.

When we transfer data to a different country or territory, we follow applicable data protection laws in doing so. In particular, when we transfer data from the EEA or UK across other international borders, we rely on adequacy decisions, data transfer agreements, or other EU-Commission or UK Information Commissioner’s Office-approved (as applicable) mechanisms for such transfers, including standard contractual clauses. You can contact us using the details set out in the “Contact Us” section to request more information about the mechanisms we use for international data transfers.

United States-California

As described in this Privacy Notice, “applicable law” includes the California Consumer Privacy Act of 2018 (“CCPA”) and any subsequent amendments thereto.

This Privacy Notice discloses the categories of personal information we have collected from California residents over the past twelve months, the categories of sources from which the information was collected, the business or commercial purposes for which the information was collected, and the categories of third parties with whom we shared that information. In the past twelve months, the categories of personal information that EP disclosed to third parties for business and commercial purposes are detailed in the “Collection of Information and Categories of Sources” section.

If you are a resident of California, we do not sell personal information to third parties and we have no actual knowledge of selling the personal information of minors under 16 years of age.

If you are a consumer located in California, we process your personal information in accordance with California law (e.g., the “CCPA”). EP uses cookies, including advertising cookies, as described in our “Your Rights” section.

You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Your agent may submit a request on your behalf using the methods described in the “Your Rights” section. We may still require you to directly verify your identity and confirm that you provided the authorized agent permission to submit the request.

Canada

As described in this Privacy Notice, “applicable law” includes the Federal Personal Information Protection and Electronic Documents Act (PIPEDA), and any subsequent amendments thereto.

United Kingdom

As described in this Privacy Notice, “applicable law” includes the Data Protection Act 2018, UK General Data Protection Regulation (GDPR) 2016/679, and any subsequent amendments thereto, and other laws and regulations of the United Kingdom.

If you are a resident of the United Kingdom or if we have identified EP as your data controller, and you believe our processing of your information is not in line with the General Data Protection Regulation (GDPR), you may direct your questions or complaints to the Information Commissioner’s Office, or the data protection regulator in the country where you live/work. If you are a resident of the UK, you may direct your questions or concerns to the UK Information Commissioner’s Office.

Ireland/European Union

As described in this Privacy Notice, “applicable law” includes the General Data Protection Regulation (GDPR) 2016/679, and any subsequent amendments thereto, and other laws and regulations of the European Union.

If you are a resident of the European Union or if we have identified EP as your data controller, and you believe our processing of your information is not in line with the General Data Protection Regulation (GDPR), you may direct your questions or complaints to the European Commission, or the data protection regulator in the country where you live/work.

Australia

As described in this Privacy Notice, “applicable law” includes the Australian Privacy Act 1988 (Cth), and any subsequent amendments thereto. If you are an Australian resident and you are dissatisfied with our handling of any complaint raised under this Privacy Notice, you may wish to contact the Office of the Australian Information Commissioner.

New Zealand

As described in this Privacy Notice, “applicable law” includes the New Zealand Privacy Act 2000 (NZ), and any subsequent amendments thereto. If you are a New Zealand resident and you are dissatisfied with our handling of any complaint raised under this Privacy Notice, you may wish to contact the Office of the Privacy Commissioner (Te Mana Mātāpono Matatapu).