Legal Stuff

Dr Pluto Privacy Policy 2019

 
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LEGAL STUFF

PRIVACY POLICY
Last updated 11 March 2019.
Dr Pluto Films Limited (registered nPRIVACY POLICY

Last updated 11 March 2019.

Dr Pluto Films Limited (registered number 10092766) (“us”, “our”, “we”, “Dr Pluto”) is the controller of your personal data. Dr Pluto is committed to protecting and respecting your privacy. This privacy policy (the “Policy”) sets out the types of personal data we collect from you when you apply to participate in or participate or appear in a programme developed and produced by us or otherwise conducting any business relationship with you and how we may use that data.

1. Introduction

This Privacy Policy explains who we are, why and how we process personal data collected from you and, if you are the subject of any of the personal data concerned, what rights you have and how to get in touch with us if you need to.

When you supply any personal data to us we have legal obligations towards you in the way we use that data. For ease of reading, we have divided this Policy into several sections:

1. Introduction

2. What information can we collect?

3. How is your personal information collected?

4. How and why do we use and share your personal information?

5. For how long do we keep your personal information?

6. Security

7. International Data Transfers

8. Your Rights

9. Contact Details

We reserve the right to revise or amend this Policy at any time to reflect changes to our business or changes in the law. Where these changes are significant we will endeavour to let you know. However, it is your responsibility to check this Policy periodically – for ease of reference the top of this Policy indicates the date on which it was last updated.

2. What information can we collect?

What is personal data?

Where this Policy refers to ‘personal data’ it is referring to data about you from which you could be identified – such as your name, your date of birth, your personal bank details (if applicable) and your contact details.

By law all organisations who process your personal data in Europe are obliged to process your personal data in certain ways and to ensure that you are given an appropriate amount of information about how they use it. You also have various rights to seek information from those organisations about how they are using your data, and to prevent them from processing it unlawfully. For more information about these rights, please see the ‘Your Rights’ section of this Privacy Policy.

What types of data we collect from you

The personal data we collect from you may include:

• Identity Data which may include your name, date of birth, gender, company name, social media account usernames and passport details.

• Contact Data which may include your e-mail address and postal address.

• Health Data which includes your medical history, health insurance claims and health conditions.

• Financial Data which includes your bank account details.

• Sensitive Data which includes you race, sexual orientation, ethnic origin, political opinions, religions and/or philosophical beliefs.

• Audio Visual Data which includes recordings of you, you skype interview and your performances.

• Visual Data such as your headshot.

• Marketing and Communications Data which includes your preferences in receiving marketing from us.

3. How is your personal information collected? Direct interactions

When you participate in a programme, apply to participate in one of our programmes, contact us by email or by post, take part in an online survey or enter into competitions, we may collect, store and use the personal data that you disclose to us.

Updating your information

If you want to update the information you have previously given to us, you can contact us at

info@drpluto.com.

4. How and why do we use/share your personal data?

Lawful basis for processing your information

We will only use your personal data when the law allows us to. Most commonly we will use your personal data in the following circumstances:

● Where you have asked us to do so, or consented to us doing so;

● Where we need to do so in order to perform a contract we have entered into with you;

Where it is necessary for our legitimate interests (or those of a third party) and your fundamental rights do not override those interests; and

● Where we need to comply with a legal or regulatory obligation.

Here are some examples about how we may use the information we collect about you and the lawful basis we rely on to do so.

Activity

Examples of the types of personal data we may collect

Lawful basis for processing Potential Participant, Participant & Talent

To contact you and assess your suitability to participate in a programme you have applied to participate in.

Identity, contact, health and sensitive information.

Legitimate interest to assess your suitability for the programme, check that you are legally able to participate in the programme and safeguard your welfare.

Your consent to process your sensitive personal data.

To take the necessary steps to arrange a contract with you.

To contact you about your participation in a programme, to make arrangements for the recording of the programme, record the programme and make payment to you.

Identity, contact, health and sensitive, audio visual, visual and financial information.

To take the necessary steps to arrange a contract with you.

To perform our contract with you.

Your consent to process your sensitive personal data.

To exploit the recordings and the programme, distribute, broadcast, publicise and otherwise exploit the programme (or parts of it) anywhere in the world, and by any means, including on TV, online, in DVDs, video, books, social media sites and magazines.

Identity, contact and audio visual and visual information.

To perform our contract with you.

To contact you about other programmes you may be interested in participating in, our prize draws, competitions, surveys, products and services.

Identity, contact, and marketing communications information.

We rely on “legitimate interest” to promote our prize draws, competitions, products, surveys, services and other programmes you may be interested in participating in to you.

To enable you to partake in a prize draw or competition.

Identity, contact, and marketing communications information.

Performance of a contract with you.

To respond to your enquiries where you have contacted us via e-mail and telephone or participated in any surveys.

Identity, contact, and marketing communications information.

We rely on “legitimate interest” and the legitimate interest is “responding and contacting you regarding the enquiries you have made in relation to the services we offer, our programmes, and reviewing your responses to our survey”

BUSINESS CONTACTS

To respond to your enquiries where you have contacted us via e-mail and telephone.

Identity and contact information.

We rely on “legitimate interest” and the legitimate interest is “responding and contacting you regarding the enquiries you have made in relation to our services and/or our programmes”

To perform the contract entered into between us.

Identity and contact information.

Performance of a contract with you.

Marketing

We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which programmes, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or previously applied to participate in one of our programmes and you have not opted out of receiving that marketing.

Opting Out of Marketing

To unsubscribe from marketing emails at any time, please click on the unsubscribe link at the bottom of any marketing email. You may also contact us if you do not wish to receive any marketing materials from us.

Sharing your personal data

Depending on how and why you provide us with your personal data we may share it in the following ways:

• with any member of our company group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;

• with the programme broadcaster. Should you wish to know more about how the broadcaster will manage your data please click here https://www.itv.com/_data/documents/pdf/ITV_Broadcasting_Privacy_Notice.pdf;

with selected third parties who we sub-contract to provide various services such as our insurers, accountants, auditors, lawyers and to companies who provide products and services to us (e.g. IT system suppliers, video production suppliers) (see “Service Providers” below); and

• with legal and regulatory authorities including OFCOM, HM Revenue and Customs, or the Border & Immigration Agency.

We may also disclose your personal data to third parties in the following events:

• if we were to sell or buy any business or assets, in which case we might disclose your personal data to the prospective seller or buyer of such business or assets as part of that sale;

• if Dr Pluto or substantially all of its assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;

• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or if we are asked to provide your details to a lawful authority in order to aid in the investigation of crime or disorder; and/or

• in order to enforce or apply our terms and conditions; or to protect the rights, property, or safety of our company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Service Providers

Our service providers provide us with a variety of administrative and technical services. We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this data and do not use it for any other purpose. We take these relationships seriously and oblige all of our data processors to sign contracts with us that clearly set out their commitment to respecting individual rights, and their commitments to assisting us to help you exercise your rights as a data subject. Please contact us at info@drpluto.comfor a list of our major service providers.

5. For how long do we keep your personal data?

We will hold your personal information on our systems only for as long as required to perform our contract with you and for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

In some circumstances you can ask us to delete your data: see ‘Your Rights’ below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

6. Security

Dr Pluto takes the protection of your information very seriously. We have put in place appropriate security measure to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed, including use of secure servers and passwords.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. International Data Transfers

Please note that some of our service providers may be based outside of the European Economic Area (the “EEA”). These service providers may work for us or for one of our suppliers and may be engaged in, among other things, the fulfilment of your request for information and the provision of services or support services.

Where we transfer your data to a service provider that is outside of the EEA we seek to ensure that appropriate safeguards are in place to make sure that your personal data is held securely and that your rights as a data subject are upheld. Transfers of personal data are made:

● to a country recognised by the European Commission as providing an adequate level of protection; or

● to a country which does not offer adequate protection but whose transfer has been governed by the standard contractual clauses of the European Commission or by implementing other appropriate cross-border transfer solutions to provide adequate protection.

By submitting your personal information, you agree to this transfer, storing or processing. If you would like more information about how the mechanism via which your personal data is transferred, please contact info@drpluto.com.

.

As a data subject you have a number of rights in relation to your personal data. Below, we have described the various rights that you have, as well as how you can exercise them.

8. Your Rights

Right of Access

You may, at any time, request access to the personal data that we hold which relates to you

(you may have heard of this right being described as a "subject access request").

Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.

You can exercise this right at any time by writing to us by contacting us and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request.

Your Right to Rectification and Erasure

You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. You may also ask us to erase personal data if you do not believe that we need to continue retaining it (you may have heard of this right described as the “right to be forgotten”).

Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is right. Further, we are not always obliged to erase personal data when asked to do so; if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to erase we will tell you what that reason is at the time we respond to your request.

You can exercise this right at any time by contacting us and telling us that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.

Your Right to Restrict Processing

Where we process your personal data on the basis of a legitimate interest (see the sections of this Policy which explain how and why we use your information) you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid.

You may also ask us to stop processing your personal data (a) if you dispute the accuracy of that personal data and want us verify that data's accuracy; (b) where it has been established that our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims.

Please note that if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to stop processing, we will tell you what that reason is, either at the time we first respond to your request or after we have had the opportunity to consider and investigate it.

You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have us stop processing the relevant aspect of your personal data and describing which of the above conditions you believe is relevant to that request. You do not have to fill in a specific form to make this kind of request.

Your Right to Portability

Where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format.

Because of the kind of work that we do and the systems that we use, we do not envisage this right being particularly relevant to the majority of individuals with whom we interact. However, if you wish to transfer your data from us to a third party we are happy to consider such requests.

Your Right to object to processing

You may object to processing of your personal data where we rely on legitimate interest for processing that personal data. We will comply with your request unless we have a compelling overriding legitimate interest for processing or we need to continue processing your personal data to establish, exercise or defend a legal claim.

Your Right to stop receiving communications

Where we send you e-mail marketing communications (or other regulated electronic messages) you have the right to opt-out at any time. You can do this by using the ‘unsubscribe’ link that appears in the footer of each communication (or the equivalent mechanism in those communications).

Alternatively, if for any reason you cannot use those links, or if you would prefer to contact us directly – you can unsubscribe by writing to us at info@drpluto.comand telling us which communications you would like us to stop sending you.

Your Right to object to automated decision making and profiling

You have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.

Exercising your rights

When you write to us making a request to exercise your rights we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity.

It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be, the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information then we may delay actioning your request until you have provided us with additional information (and where this is the case we will tell you).

Contact Details

If you have any queries regarding this Privacy Policy, if you wish to exercise any of your rights set out above or if you think that the Privacy Policy has not been followed, please contact us by emailing at info@drpluto.com.

You may also lodge a complaint to the supervisory authority about the way we process your

personal data. We would however, appreciate the chance to address your concerns before you approach the supervisory authority, so please contact us in the first instance.