Privacy policy
Intone Films Limited - Privacy Policy (Published 25th May 2018)
Contents
1. Important information and who we are
2. The data we collect about you
3. How is your personal data collected?
4. How we use your personal data
5. Disclosures of your personal data
6. International transfers
7. Data security
8. Data retention
9. Your legal rights
10. Glossary
Introduction
Welcome to Intone Films Limited’s privacy notice.
Intone Films respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Intone Films Limited collects and processes your personal data.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Controller
Intone Films Limited is the controller and responsible for your personal data (collectively referred to as “Intone Films Limited”, "we", "us" or "our" in this privacy notice).
Contact details
Our full details are:
Full name of legal entity: Intone Films Limited
Email address: hello@intonefilms.com
Postal address: 465C, Unit 2 Hornsey Road, N19 4DR
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice
This privacy policy was published on 25th May 2018 and updated on 13th May 2021. The policy is reviewed annually. Any changes we make to our policy in the future will be posted on our website.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name and last name.
- Contact Data includes the billing address, email address and telephone numbers of your personal business or the company you work for.
- Financial Data includes the bank account details of your personal business or the company you work for.
- Transaction Data includes details about payments to and from you and other details of the services you have purchased from us.
We do not currently collect, use or share Aggregated Data such as statistical or demographic data for any purpose (aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity).
We do not collect any Special Categories of Personal Data about you (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). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you engage our services.
- Consent forms. You may give us your Identity and Contact information, along with an example of your signature, when signing a consent release form for image or voice recording.
4. How we use your personal data
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 we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Purposes for which we will use your personal data
We have set out below descriptions of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.
(i) Purpose/Activity: To register you as a new customer
- Type of data: (a) Identity; (b) Contact
- Lawful basis for processing including basis of legitimate interest: Performance of a contract with you
(ii) Purpose/Activity: To process and deliver your order including: (a) Manage payments, fees and charges; (b) Collect and recover money owed to us
- Type of data: (a) Identity; (b) Contact; (c) Financial; (d) Transactional
- Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you; (b) Necessary for our legitimate interests (to recover debts due to us)
(iii) Purpose/Activity: To manage our relationship with you which will include notifying you about changes to our terms or privacy policy
- Type of data: (a) Identity; (b) Contact
- Lawful basis for processing including basis of legitimate interest: (a) Performance of a contract with you; (b) Necessary to comply with a legal obligation
(iv) Purpose/Activity: To obtain further information about you, any company or organisation you represent, and the matter that is the subject of any services we have to provide
- Type of data: (a) Identity; (b) Contact
- Lawful basis for processing including basis of legitimate interest: It will be necessary for our legitimate interests to be aware of all relevant information
(v) Purpose/Activity: To use your image (photography or moving image) or audio recording in the production of video or audio content
- Type of data: (a) Identity
- Lawful basis for processing including basis of legitimate interest: We will only do this if you give us your consent
(vi) Purpose/Activity: To provide you with information about the services we provide
- Type of data: (a) Identity; (b) Contact
- Lawful basis for processing including basis of legitimate interest: If you specifically ask us to provide you with certain marketing communications, then it will be necessary for our legitimate interests to ensure we provide you with the appropriate information. In all other cases, we will only do this if you give us your consent
Change of purpose
- We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
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.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, but only where this is required or permitted by law.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in section 4 above.
- External Third Parties as set out in the Glossary.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for one of our service providers. In particular:
- Google, who provide cloud-based storage of emails, contact lists, calendars and documents, is registered with Privacy Shield, to ensure the security of your personal data in the U.S.A.: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI;
- Vimeo, who provide video hosting services to us, transfer personal data outside of the EEA based on the legal frameworks of legitimate business interests; consent; use of Standard Contractual Clauses (also known as “Model Clauses”) where appropriate; and self-certification with the EU-US and Swiss-US Privacy Shield frameworks. EU users of Vimeo have the rights to: opt out of cookies (Vimeo’s Cookie Policy is available at https://vimeo.com/cookie_policy); access, correct, delete, restrict or object to our use of their personal information; be forgotten; and data portability. Vimeo’s Data Transfer Statement is available at https://vimeo.com/transfer_statement; and
- Xero, who provide accounting services to us, has put in place European Commission approved clauses into our data processing agreements to ensure the security of your personal data. Google has also implemented these same clauses to ensure the security of your personal data to other non-EEA countries other than the U.S.A.
A copy of the European Commission approved model clauses is available at http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32010D0087&from=en
By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy, leveraging data protection features from our service providers where possible.
Where we have given you (or where you have chosen) a password which enables you to access certain content hosted by our service providers, you are responsible for keeping this password confidential.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. 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.
8. Data retention
How long will you use my personal data for?
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Request Erasure below for further information.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the end of this document to read more about these rights.
- Request access to your personal data
- Request correction of your personal data
- Request erasure of your personal data
- Object to processing of your personal data
- Request restriction of processing your personal data
- Request transfer of your personal data
- Right to withdraw consent
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
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.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right 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.
Time limit to respond
We 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.
10. Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
THIRD PARTIES
External Third Parties
- Professional advisers acting as processors including lawyers, bankers, auditors and insurers based in the United Kingdom, who provide banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or based in the United Kingdom who require reporting of processing activities in certain circumstances.
- Other business partners, suppliers and sub-contractors to the extent we consider it reasonably necessary for us to perform our services.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.