PRIVACY POLICY
MARKHAM FROGGATT & IRWIN LIMITED of 28-29 Haymarket London SW1Y 4SP (“We” “our”, “us”) manage and administer this website. For the purposes of data protection laws, our ultimate parent company Original Talent Limited (“Original Talent”) is the “controller” (often known as a “data controller”) in respect of the Personal Data (as defined below) submitted by you when you visit our website markhamfroggattandirwin.com (the “Website”), and we are the “data processor”. In this privacy policy “Group Company” means us, Original Talent, our subsidiaries or holding companies from time to time and any subsidiary of any holding company from time to time (as subsidiary and holding company are defined in s.1159 Companies Act 2006).
“Personal Data” means information which identifies you as well as any information relating to you.
This privacy policy sets out the fair and lawful basis upon which we (acting on Original Talent’s behalf) collect and process personal data. This privacy policy was last updated on 20 May 2022.
WHAT PERSONAL DATA DO WE COLLECT?
When you visit our Website we may ask you to provide or otherwise collect the following Personal Data about you and your interests:
| Personal Data Category | Personal Data |
| “Submissions Information”
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–Showreels, photos, scripts, treatments and other creative or visual/audio-visual material submitted via the Website (or other means) for us to review. – Professional details, cover letters, contact information, CVs. |
| “Employment Information”
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– Job title, prior experience, references, CV and or other information relating to your personal professional employment history.
|
| “Technical Information” | – Details of specific content and or pages you visit on our Website (including duration of visits), technical information including the Internet Protocol (IP) address used to connect your computer to the Internet, device(s) you use to access our Website, and your geographical location.
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HOW WE COLLECT PERSONAL DATA
We receive information including Personal Data about you in three ways: (i) you may provide us information; (ii) we may collect information about you in the course of your visiting our Website; and (iii) third parties may provide us information about you where you have given them consent to do so or they have another lawful basis to share this information with us.
WHY WE COLLECT AND HOW WE USE PERSONAL DATA
We can only use your Personal Data if we have a lawful basis to do so under data protection law. This means we will only use your personal data: (i) where we need to in relation to a contract you we are entering into with you; (ii) where you have given us your consent for a particular use; or (iii) where we need to for purposes in our, or a third party’s, legitimate interests. When relying on the ‘legitimate interests’ basis, we consider our interests and the potential impact on your rights and weigh this up. We will also use your Personal Data where we need to in order to comply with a legal obligation we are under. You can find out more about why we use your Personal Data below.
Information you give us.
This is information about you, including under any or all of the above Personal Data Categories, that you give us by filling in forms or submitting information on the Website or corresponding with us by phone, email or otherwise.
We use this information because you have asked us to do something/provide you information, because it is otherwise necessary in relation to a contract or transaction that you are entering into with us, or for the other purposes set out in this Privacy Policy in our legitimate interests. This includes:
- Where you submit Submissions Information in order for us to review and assess materials at our invitation and to inform you whether or not your submission has been accepted;
- Where you submit Employment Information in order to apply for a position with us and for us to review your application;
Information we collect about you.
We also use cookies (which are small text files stored in your browser) and cookie-like software. These collect information that tell us how you use our Website as well as providing other Technical Information. This helps us make our Website relevant to your interests and needs. We may use a persistent cookie (a cookie that stays linked to your browser) to record your details so we can recognise you if you visit the Website again. You can choose to refuse cookies or set your browser to let you know each time a website tries to set a cookie.
If you use our Website we understand that to mean that you consent to our use and placement of cookies for the purposes of collecting and processing Technical Information in the manner described below:
| COOKIE TYPE | COOKIE PURPOSE | HOW LONG IS IT STORED? |
| GOOGLE ANALYTICS | We use this analytics tool to monitor website traffic. | 2 years |
WHEN IS PERSONAL DATA SHARED WITH THIRD PARTIES
We may share Personal Data about you with the following service providers who we engage to process such Personal Data for the purposes described herein.
| Type of third party service provider | Name(s) of service provider |
| Website Performance Service Providers: | Google Analytics |
| Data Storage Providers: | Dropbox |
The Personal Data that we collect from you may be transferred to and stored at a destination outside the European Economic Area including but not limited to the USA. We will take all steps reasonably necessary and available to us to safeguard and ensure that your Personal Data is treated securely and in accordance with applicable laws, which may include having in place a contract with the recipient to ensure the security of your personal data in accordance with data protection laws or only transferring to US companies who have certified under Privacy Shield to keep your personal data secure.
We may also share Personal Data about you if we are required to do so in order to comply with any legal obligation or to protect our legal rights (or those of our clients).
YOUR RIGHTS
We try to be as open as we reasonably can about the Personal Data that we process. If you would like specific information, just ask us at [email protected].
You have legal rights (i) to make a “subject access request” to access your Personal Data; (ii) to request and be given your Personal Data in machine readable format for the purposes of your passing such data to third parties; (iii) to request rectification or removal of your Personal Data and/or to have its processing restricted; and (iv) to object to processing of your Personal Data for a particular purpose where we rely on “legitimate interests” as our legal basis for that particular use (as we’ve pointed out to you in this Privacy Policy), in which case you should let us know your reason for your objection. Please note that we may still process your Personal Data where there are other relevant lawful bases we rely on or where we have compelling grounds to continue processing your Personal Data, despite your objections.
If you would like to exercise any of these rights, or otherwise have any questions about how we handle data, please contact us at [email protected], with details of your request. In the case of subject access requests please ensure that you add “subject access request” into the subject line of your email.
In relation to subject access requests, we will respond as soon as possible but no longer than one month after such request is received, or longer where permitted by and applicable under law. Please note the rights above are not absolute and there may be circumstances where we are unable to comply with your request (either wholly or in part). In such cases we will explain why we cannot comply with the request. We may need to request specific information from you to help us confirm your identity and your right to access the information (or to exercise any of your other rights). This is an appropriate security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.
We will store and process your Personal Data only for as long as is reasonably necessary for us to perform the services/activities we are undertaking and to comply with our legal obligations. Once data is anonymised we may hold it indefinitely, without further notice to you.
Please note that our Website may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.
As you probably know, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data once transferred to us; any transmission is at your own risk. Once we have received your Personal Data, we will use strict procedures and security features to try to prevent unauthorised access.
If you have complaints relating to our processing of your Personal Data, you should contact us in the first instance at [email protected]. You may also raise complaints with the Information Commissioner who is the statutory regulator.