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QUEUEVISION’S PRIVACY POLICY
1. INTRODUCTION
1.1 This privacy policy explains how personal data of users of this Komi profile
including any of the content, products, events, experiences, tickets, gift
capabilities, subscription offering services, or other materials or services posted to
the Komi profile (“Services”) will be processed by the Talent who operates this
Komi profile (“Talent”).
1.2 This policy explains the basis on which personal data collected from you will be
processed by the Talent in accordance with the General Data Protection Regulation
2016/679 and the General Data Protection Regulation as it forms part of the laws
of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the
European Union (Withdrawal) Act 2018 (together, the “GDPR”).
1.3 The Services may contain hyperlinks to websites owned and operated by third
parties. These third-party websites may have their own privacy policies and it is
recommended that you review them. The Talent and Komi do not accept any
responsibility or liability for the privacy practices of such third parties and your
use of their services is at your own risk.
1.4 You have the right to object to the processing of your personal data, including
where your personal data is being processed for direct marketing purposes.
Further information on this right, and your other rights, is set out below.
2. WHAT IS KOMI’S ROLE WHEN PERSONAL DATA IS PROCESSED?
2.1 Where Talent decides the purposes and means for the processing of your personal
data, the relevant Talent is the “controller” for the purposes of the GDPR. This
means that Talent is generally a controller for the processing of all personal data
in connection with their Talent profile page on Komi.
2.2 There will be many instances where Talent decide the purposes and means for the
processing of your personal data, and Komi simply processes your personal data
according to the Talent’s instructions and on the Talent’s behalf. In such
circumstances Komi is the “processor” and the Talent is the “controller”. This
means Komi is generally a processor for the processing of personal data through
an individual Talent’s Komi page, for example when you sign up to a Talent
newsletter, click on links to purchase Talent merchandise, or interact with Talent
on their page.
2.3 This policy addresses the processing of personal data that the Talent undertakes
as a controller. This policy does not explain how personal data is processed by
Komi. This is detailed instead in the Komi privacy policy available here:
https://komi.io/privacy-policy. Komi takes no responsibility for any Talent’s
processing of personal data.
3. WHAT INFORMATION WILL BE COLLECTED ABOUT ME?
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3.1 The table below explains what data may be collected, how it is used, and which
recipients it might be shared with.
Your data How it is used Recipients
Service purchase
information (information
provided by you when
purchasing Services)
• Full name
• Shipping address
• Contact details
including email,
address, and phone
number
• Billing information
including card details,
and details relating to
your payment for
Services
• Order details relating
to the Services you
purchase including, for
example, sizes
ordered, and quantity.
This information is processed in
order to fulfil your orders for the
Services.
Legal Basis
We process this information in
accordance with the terms of our
contract for purchase with you. For
example, we need your shipping
address details to ensure your order
is sent to you.
More information
If you choose not to provide this
information, we may be unable to
complete your order and/or deliver
the relevant Service to you.
Your personal data
may be shared with
our payment service
providers, including
Rye Pay and Stripe,
or order fulfilment
partners (i.e. those
who help package
and deliver physical
or digital goods).
Komi may process
or receive this
information on
Talent’s behalf.
Service analytics (collected
from your device and
interaction with the
Services)
• How often you use the
Services, the
purchases you make
through the Services.
• Which content, pages
and application
screens you go to, and
which Service features
you use
• Your IP address, and
device identifiers
communicated by your
device
• Device and browser
operating system,
version, make and
model
This information may be processed
(on its own or together with your
Service purchase information) for:
(i) better understanding of the
usage of the Services and
improvement of the Services; (ii)
the marketing of Services to you;
(iii) identification and solving of
problems with the Services; and
(iv) development of new Services or
content based on interest and
engagement levels.
Legal basis
This processing with be undertaken
on the basis of your prior consent.
More information
You are under no obligation to
provide your consent to the
processing of this information.
Talent may make
use of analytics
service providers in
order to collect and
process this
information, such as
Google Analytics.
Komi may process
or receive this
information on
Talent’s behalf.
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• Which website/service
you came from to use
the Services
Marketing information
(information provided by
you when signing up to
newsletter or marketing
communications)
• Name
• Email address
• Mobile number
• Other information
collected and clearly
identifiable to you at
the point of your
signing up to
newsletter, marketing
or feature update
communications
• Mailing preferences
Legal basis: Consent-based mailing
lists
This information may be processed
(on its own or together with your
Service purchase information,
Service analytics information
and/or competition and promotion
entry information) in order to make
suggestions and recommendations
to you about: (i) news and updates
relating to Talent, Talent partners
or products, services and content
Talent thinks will be relevant to
you; (ii) content, goods, services,
experiences and other offerings
available in or from Talent; and (iii)
other promotional activity and
events which may be of interest.
In such circumstances (and
provided the ‘soft opt-in’ – see
below – does not apply), your daya
will be processed on the basis of
your consent.
Legal basis: ‘Soft opt-in’ mailing
lists
In some instances (such as when
you have purchased something
from Talent before) the law may
permit Talent to process your
personal information in order to
send information to you by
marketing messages that it thinks
are of interest for you on the basis
of Talent’s legitimate interests,
being the legitimate business
interests in marketing Talent
activities and promoting the success
of Talent’s business and Talent,
content, products and services.
If the information is not of interest
for you, you can opt-out at any time
by contacting us using the details
outlined in the ‘Contact Us’ section
below.
More information
You are not required to provide us
with this information, but if you do
not, we may not be able to provide
Komi may process
or receive this
information on
Talent’s behalf.
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you with our newsletter or
marketing emails.
Support / enquiry
information (information
received when you get in
touch for support)
• Name
• Contact details (email,
address, phone
number)
• Other personal data
you choose send to us
• Mailing preferences
This information is processed in
order to respond to your support
requests and other enquiries.
Legal basis
This information may be processed:
• in accordance with the terms of
our contract with you where
this information is required to
provide the Services to you;
• in pursuit of Talent’s legitimate
interests in responding to your
enquiry including: (a) interest
in responding to enquiries to
ensure smooth operation of
Talent business and Services;
and (b) interest in
understanding your use of the
Services and improving the
Services, by taking onboard
your feedback; or
• (in respect of mailing
preferences information)
because the law requires this to
the extent the information will
be used to send direct
marketing to you.
More information
You are under no obligation to
provide any of this information, but
it may not be possible to respond to
your enquiry if you do not.
Komi may process
or receive this
information on
Talent’s behalf.
Talent may also
share this
information with
vendors who assist
with managing
customer service
enquiries.
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Competition and promotion
entry information
(information received when
you enter a competition /
prize promotion via the
relevant Komi profile):
• Name (and/or your
social media unique
user name)
• Contact details for
entry processing (such
as email, address,
phone number if
required to send you a
prize)
• Information submitted
as part of your entry
This information is processed for the
purposes of managing and fulfilling
the competition and promotion.
Legal basis
This information will be processed
on the legal basis of performance of
a contract, being the applicable
terms governing the competition /
promotion.
More information
You are under no obligation to
provide this information, but it may
not be possible to process your
entry to the competition or prize
promotion if you choose not to.
Talent may share
this information
with relevant
partners who are
assisting with the
competition or
promotion delivery.
Komi may process
or receive this
information on
Talent’s behalf.
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Service monitoring
information
• All information listed
above
This information may be processed
for the prevention of harassment,
fraud and other unacceptable or
illegal activity.
Where the Talent suspects that you
have engaged in unlawful or
fraudulent activity, the Talent may
investigate and keep a record of
such investigation, its conclusion
and the implementation of any
consequences.
Where the Talent reasonably
believes that you are or may be in
breach of any of the applicable laws
or regulations, the Talent may use
your personal data to inform
relevant third parties, your
email/internet provider or law
enforcement agencies about the
content.
Legal basis
Your information may be processed
for the legitimate interests of
ensuring that use of the Services is
lawful and non-fraudulent, does not
disrupt the operation of the
Services, does not harass the
Talent, the Talent’s personnel,
other users or other individuals, and
to enforce the Talent’s legal rights
and comply with legal and
regulatory obligations, including
compliance with anti-money
laundering regulations (if and where
applicable).
The Talent may process information
for the legitimate interest of
complying with HMRC requirements
by retaining records of customer
purchases and transactions.
The Talent may also process this
information for these purposes on
the legal basis of compliance with
applicable laws.
Talent may share
this information
with law
enforcement
agencies, regulators
and/or Komi where
necessary.
3.2 Please note that some of the information referred to above is essential to the
provision of the Services and whilst you are under no obligation to provide such
information, it may not be possible to provide the relevant Service to the extent
you do not.
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4. DATA SHARING
4.1 Other than as set out under ‘Recipients’ above, Talent may disclose your personal
data to:
4.1.1 Talent management, group companies, and subcontractors. Talent may
disclose personal data to its management (including agents), any member
of its corporate group, its personnel, or subcontractors insofar as it is
reasonably necessary for the purposes set out in this policy, and on the
legal basis of meeting its obligations under its contract with you, or its
legitimate interests in outsourcing certain functionality to subcontractors
or corporate group members.
4.1.2 Government authorities. In addition, we your personal data may be
disclosed to the extent that Talent is required to do so by law (which may
include to government bodies and law enforcement agencies); in
connection with any legal proceedings or prospective legal proceedings;
and to establish, exercise or defend our legal rights (including providing
information to others for the purposes of fraud prevention). In each case,
Talent will do so on the basis of its legal obligations, or legitimate interests
in complying with the guidance and policies of such government
authorities and ensuring use of its Services is safe, harmless and
legitimate.
4.1.3 Potential acquirers or investors. If Talent is a business, or is part of a
business, and that business is involved in a merger, acquisition, or sale of
all or a portion of the business or assets, personal data held by Talent
may be shared based on the legitimate interests of Talent, its
shareholders, customers, and other parties to the transaction, unless
those interests are outweighed by prejudicial impacts upon you.
4.1.4 Enforcement. We may also disclose your personal information to third
parties in order to enforce or apply the terms of agreements, to
investigate potential breaches, or to protect the rights, property or safety
of Talent, Talent personnel or customers, or others. Talent does this on
the legal basis of its legitimate interests in ensuring the Services are used
lawfully and in accordance with Talent policies, and in ensuring the rights
of others are not (negatively) impacted by anyone’s use of the Services.
4.1.5 Suppliers and service providers. Talent may use a range of suppliers and
service providers to operate its business or Services. Suppliers who may
receive your personal data for the reasons set out in this notice may
include the following: order fulfilment partners, payment processors, IT
service providers, and/or professional advisers. In addition, Komi will
process your personal data on the Talent’s behalf.
5. YOUR RIGHTS IN RELATION TO THE PERSONAL DATA PROCESSED BY
TALENT
5.1 You have the following rights over the way your personal data is processed, the
Talent aims to comply without undue delay with any requests by you:
5.1.1 for a copy of the personal data the Talent is processing about you and to
have inaccuracies corrected;
5.1.2 to ask the Talent to restrict, stop processing or to delete your personal
data;
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5.1.3 for a machine-readable copy of your personal data, which you can use
with another service provider. Where it is technically feasible, you can ask
for this information to be sent directly to another provider if you prefer;
5.1.4 where the Talent processes your personal data on the basis of your
consent, to withdraw your consent at any time; and
5.1.5 to make a complaint to a data protection regulator (in the UK this is the
Information Commissioner’s Office).
5.2 Please send your requests to exercise any of these rights to the Talent.
6. DATA RETENTION
6.1 The Talent will hold your personal data for as long as is necessary for the relevant
purpose and to maintain business records for tax, legal and regulatory reasons, or
as otherwise described in this privacy policy.
6.2 To determine the appropriate retention period for personal data, the Talent will
consider the amount, nature, and sensitivity of the personal data, the potential
risk of harm from unauthorised use or disclosure of your personal data, the
purposes for which your personal data is processed and whether those purposes
can be achieved through other means, and the applicable legal and regulatory
requirements.
6.3 In some circumstances the Talent may anonymise your personal data (so that it
can no longer be associated with you) for research or statistical purposes in which
case this information may be used indefinitely without further notice to you.
7. SECURITY
7.1 Reasonable technical and organisational precautions will be taken to prevent the
loss, misuse or alteration of your personal data.
7.2 Please be aware that no security system can prevent all potential security
breaches. In particular, the transmission of information and data via the Internet
is not completely secure and whilst every effort is made to protect your personal
data, the Talent cannot guarantee the security of any information or data
transmitted to or through the Services.
8. INTERNATIONAL DATA TRANSFERS
The Talent may store your personal data in jurisdictions outside of the EEA or UK,
for example because their data hosting servers are located there. Where your
personal data is transferred outside of the EEA or UK (for example, in respect of
the transfer to service providers or affiliates), such transfers will only be made in
accordance with applicable data privacy laws, and subject to appropriate
safeguards to protect your personal data, such as ensuring there is an agreement
in place with the transferee which includes standard data protection clauses
adopted by a data protection regulator and approved by the European
Commission. If you would like to find out more about the safeguards deployed,
please contact the Talent using the contact details on their Komi profile.