This policy applies to personal data which is collected and/or used by Flying Fox Limited in its capacity as a controller as that term is defined in the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (the “UK GDPR”).
Why we use personal data
As a motion picture, video and television programme post-production provider, we use the personal data of our clients, associates, business contacts, suppliers and our own personnel to enable us to provide high-quality services (together, the “Services”). This includes initiating, administering and undertaking post production services, to potential and existing clients and associates, managing relationships with our business contacts, managing internal administrative processes, recruitment processes and responding to any enquiries, complaints or claims which arise in relation to our Services or processing of the data.
How we collect personal data
We collect personal data in a range of different ways depending on our interactions with you. Those include:
- direct meetings or phone / video calls with you;
- via our website;
- from your direct enquiry to or engagement of us;
- via password software and any other software you choose to share with us;
- where provided by you;
- through publicly available sources, where appropriate;
- via trusted third parties, where appropriate; and
- you contacting us with any other enquiry, complaint or notice.
By using our website, you acknowledge your understanding of, and where necessary your agreement to, our use of your personal data.
What personal data we collect
For consultants, we collect your name, address, e-mail address, telephone number and any other
personally-identifiable information and other relevant information directly from you or your CV which is relevant to our engagement, or potential engagement, of you to assist with providing services to Flying Fox Limited. We may also obtain personal data about you from third parties as part of our reference checking processes.
For clients, suppliers and other professional contacts, we collect names, addresses, e-mail addresses, telephone numbers and any other personally-identifiable information and other information relevant and appropriate to managing our business relationship and undertaking our services , including without limitation:
- to carry out pre-engagement checks;
- carry out communication, service, billing and administration;
- deal with complaints; and
- administer claims.
We may also process any other personal data where this data is volunteered to us by you. You consent to us processing that personal data.
Our legal basis for processing personal data
UK GDPR requires that we have valid grounds for processing your personal data. The main grounds that we rely on in order to process personal data are as follows:
- the processing is necessary for the performance of a contract, or to take steps (at your request) to enter into a contract;
- the processing is necessary for us to comply with a relevant legal obligation;
- the processing is in our legitimate interests, subject to due consideration for your interests and fundamental rights (this is the basis we rely upon for the majority of the processing of personal data in connection with the provision of our Services, and also for the purposes of most client onboarding, administration and relationship management activities); or
- on the basis of your consent (this ground will only be used in limited circumstances).
Where we process your personal data on the basis of your consent, you have the right to withdraw that consent at any time. If you wish to withdraw your consent, please see the “Contact” section below.
Who we will share personal data with
We may share personal data with our trusted third party suppliers in connection with the Services we provide, including for internal administration purposes. We may also share your personal data with third parties as reasonably required in order for us to undertake the services which you have instructed us to undertake.
We may also be required to share your data:
- with a regulatory body or as required by law;
- in relation to the prevention and/or detection of crime;
- to establish legal rights or to investigate or pursue legal claims;
- a merger, acquisition or corporate restructuring to which Flying Fox Limited is subject; or
- to prevent risk of harm to an individual.
We will use reasonable endeavors to make sure that all third parties we share your data with are subject to appropriate obligations to ensure the protection of the data that we share with them.
Transfer of your data outside of the UK and/or European Economic Area (“EEA”)
We may sometimes use third party data processors that are located outside of the United Kingdom and European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where we transfer any personal data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK under the data protection legislation including:
- Using Standard Contractual Clauses “SCCs” as a mechanism to safely process data outside of the UK and EEA to “third countries” which have not been granted adequacy; or
- Is a Country that has been granted adequacy which confirms its data protection legislation is adequate to safeguard data processing.
In certain circumstances, we may be legally required to share certain data held by us, which may include your personal data, for example, where we are involved in legal proceedings, where we are complying with legal requirements, a court order, or a governmental authority.
How and where do we store your data?
We only keep your personal data for as long as we need to in order to use it as described in this policy, and/or for as long as we have your permission to keep it.
We will store some of your personal data in the UK. This means that it will be fully protected under the UK’s data protection legislation.
We will store some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.
We may store some or all of your personal data in countries outside of the UK and EEA. These are known as “third countries”. We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the data protection legislation. Data security is very important to us, and to protect your data we have taken suitable measures to safeguard and secure data collected through our website.
We use the following third-party software and some of your data may be stored on their servers:
- Google email servers;
- Google cloud storage;
- Frame IO
- Google Hangouts
- WhatsApp and
How long we will retain personal data
We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
- We will retain your contact details for as long as we contract with you and for 24 months thereafter;
- We will retain your contact details for 36 months if you have enquired about our products or services thereafter, they will be deleted;
- We will retain your contact details indefinitely if you have consented to receiving marketing materials from us and for a period of 3 months once you unsubscribe; and
- We will retain your personal data and financial information for as long as we contract with you and, thereafter, for the permitted period of time required by law.
Your rights in relation to your personal data
You have certain rights in relation to your personal data that we process. In order to validate any request that we receive to exercise those rights, we may ask you for additional information to confirm your identity before complying with your request or we may otherwise require additional information from you in order to respond to the request. We reserve the right to charge a fee for complying with a request where we are permitted to do so by law, for instance if your request is manifestly unfounded or excessive.
You can exercise your rights by contacting us (see the “Contact” section). We will make every reasonable effort to comply with your request within the required timeframes, but there are circumstances where we may not be able, or required, to fully comply with your request.
Right to Access: You have the right to access personal data which Flying Fox Limited holds about you, together with certain information about how and why your personal data is processed.
Right to Rectification: You have a right to request us to correct your personal data where it is inaccurate or out of date.
Right to be Forgotten (Right to Erasure): You have the right under certain circumstances to have your personal data erased. Your information can only be erased if it is no longer necessary for the purpose for which it was collected, and we have no other valid basis for processing the information.
Right to Restrict Processing: You have the right to restrict the processing of your personal data where its accuracy is contested, the processing is unlawful, it is no longer needed for the purposes for which it was collected but we still need it to establish, exercise or defend legal claims, or you have exercised the right to object and we have not yet established if there are any overriding grounds for retention.
Right to Data Portability: In certain circumstances you have the right to data portability, which requires us to provide personal data to you or another controller in a commonly used, machine readable format.
Right to Object to Processing: You have the right to object to the processing of your personal data at any time, but only where that processing is based on our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
We ensure that you are provided with opt-out options when we send you any marketing. To exercise any of the abovementioned rights, please see the “Contact” section. In addition, you may also have the legal right to make a complaint to the relevant supervisory authority or local data protection authority. In the UK, this is the Information Commissioner’s Office.
Information Security: We implement reasonable technical and organisational measures and safeguards to protect personal data from unauthorised loss, misuse, alteration, or destruction. This includes access limitation to systems, limiting access to your personal data on a "need to know" basis, and providing training to appropriate Flying Fox Limited staff. Despite these efforts, security cannot be absolutely guaranteed against all threats.
Contact: If you require any further information from us in relation to our processing of your personal data, including where you would like to make a complaint, please contact us at email@example.com. Alternatively, please feel free to write to us at: Data Protection Enquiries, Flying Fox Limited, 7 Bechervaise Court, London, E10 5HY.
Updates: This Policy may be updated at any time by Flying Fox Limited. Updates to the Policy will be notified to you via our website.
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