Privacy Policy
Spotlight's Privacy Policy
Spotlight is committed to protecting the privacy of its users. This Privacy Policy sets out the type of personal information that we collect, what it is used for and the rights you have in relation to this information.
Definitions
Acceptance of this Policy and Spotlight Terms
Spotlight as your Data Controller
Changes to this Privacy Policy
How do we make sure your data is used lawfully?
When do we collect your personal information?
What personal information do we collect?
How will we use your personal information?
What personal information do we share?
How long do we keep your information?
Where your information is processed
Keeping your personal information up-to-date
More information and information in an accessible format
Definitions
In this Privacy Policy:
"you" means the user of our website or the Spotlight Services,
"we/us/Spotlight" means “Spotlight”, a trading name of Talent Systems Europe Limited, whose trading address and registered office is 7 Leicester Place, London WC2H 7RJ. VAT Number 200134486. Registered in England and Wales, Company Number 07664065.
"Services" means any of the services available from Spotlight, and
"Site" means the site located at spotlight.com and www.spotlight.com/contacts/ and other connected sites.
Acceptance of this Policy and Spotlight Terms
By using Spotlight's Services and/or this Site and/or Spotlight's software Application(s) you accept the terms of this Privacy Policy and your related Terms. This Privacy Policy should be read in conjunction with our terms and conditions.
Other terms and Privacy Policies that may be applicable to you are:
Rooms & Studio Bookings Service Terms see here.
Filming and Photography at Events Privacy Policy see here.
If you are a Parent or Guardian of a young performer/child you are a third party acting on behalf of your child and it is your responsibility to inform the child of their rights, and to act solely in your child’s best interests. Please review the Member Service Terms and also see the FAQs section for Young Performers alongside this Privacy Policy for more information. This Privacy Policy has been written in a way to be accessible to children, but if there is anything you or your child does not understand, please contact the Data Protection Officer.
Spotlight as your Data Controller
Spotlight is your Data Controller. Spotlight has a Data Protection Officer who can be contacted via [email protected] or by writing to Data Protection Officer, 7 Leicester Place, London WC2H 7RJ.
We fully endorse and adhere to data protection law across Europe in the form of the General Data Protection Regulation (GDPR), the gold standard of data protection legislation, and the equivalent data protection laws in the UK. As your Data Controller, Spotlight has registered as a Data Controller under the UK Data Protection Act, and can be found in the Data Protection Public Register. We also work in accordance with relevant standards including the UK’s Age Appropriate Design framework.
Relationships when Spotlight is not your Data Controller
If you are a Spotlight Member please note that your agent (if you are represented) or training establishment may also act as your Data Controller both for the supply of your information to Spotlight and its use in submissions made by your Agent on your behalf via The Spotlight Link, and additionally for any third party tools your Agent or training establishment may employ to administer your data. It is your responsibility to ensure that your Agent or training establishment only processes your personal data in accordance with your wishes. Casting Professionals also act as a Data Controller where they determine the purposes for the administration of their data in finding and hiring professional performers, working with agents, and collaborating with other project members.
Changes to this Privacy Policy
Spotlight keeps this Privacy Policy under regular review, and may change this policy occasionally by updating this page. Where practical we will notify you of changes to this Policy and prompt you to review these. However, you should check this page from time to time to ensure that you are happy with any changes. Your continued access and use of this site or other Spotlight services will mean that you agree to our current Privacy Policy.
This Privacy Policy was last updated on 1 November 2022.
How do we make sure your data is used lawfully?
We will only collect, use, store, share (and any other of the defined uses of processing data) where there is a lawful basis as defined by data protection legislation, and do not collect more information than we need to fulfil the purpose. We document what lawful bases are relied upon for our processing activities. Lawful bases include where you have given consent, where processing is necessary for the performance of a contract with you, when complying with law and where there are legitimate interests. More information on how we use these lawful bases is provided below:
- Consent – In certain situations we can process your data with your consent. Where we process data based on consent, we will ask you for your explicit consent (you have to take an action) which you can withdraw at any time, but it will not affect the lawfulness of processing before then. For children under 16, consent will be gained from the parent or guardian.
- For example, you ticking a box to receive email marketing communication from us.
- Contract – In certain situations, we need your personal information to comply with our contractual obligations. Where we rely on contract, we will ask you to agree to the use of your personal data necessary for entering into or the performance of your contract with us.
- For example, by becoming a Spotlight member we will collect information about you so we can deliver the service to you.
- Complying with law – we may need to process your personal information if the law requires us to.
- For example, we may have to pass on information of people in fraud or other criminal activity to law enforcement,
- Legitimate interest - We will only rely on legitimate interests where the processing of your data is not overridden by your interests or rights and freedoms. This means that we may need your information and use in a way that can reasonably be expected as part of us running Spotlight and does not materially impact your rights, freedoms or interests.
- For example, we may use your information to build a more accurate picture of you to better inform our business decisions.
When do we collect your personal information?
We will collect personal information from you when you:
- Visit and/or use our Site and/or Services;
- Sign up to or use Site and/or Services;
- Become a registered member with us;
- Purchase a product or service from us, such as a room booking or editing sessions;
- Book to attend an event;
- Complete a survey or feedback form;
- Provide feedback or review our Site and/or Services;
- Correspond with us on social media;
- Contact us with a form of query, compliment or complaint (plus other types of enquiries) via phone, email or post;
- Enter a competition or prize draw;
- Use other features of our site;
- Visit our premises.
What personal information do we collect?
We will only ever ask you for the necessary information needed to process your data. We may process data including the following personal information about you, where supplied:
- Name and previous names;
- Gender;
- Date of birth;
- Address(es) or location data;
- Email;
- Telephone number(s);
- Information pertaining to disability and ethnicity;
- Physical details such as height;
- Training and skills;
- Information/ documents to enable us to vet an application;
- Information/ documents you provide to prove age, identity or other requirement where the law requires this to confirm discount eligibility;
- Technical information such as your browser or device type, or your IP address;
- Information gathered by the use of cookies;
- Telephone call recordings (for training and monitoring purposes);
- Photographs, video and audio clips, and metadata relating to this such as copyright information;
- Career history;
- URLs and links to social media;
- Bank and payment data;
- Closed Circuit Television (CCTV) footage in accordance with Spotlight’s CCTV Policy;
- For security, a robustly-asymmetrically encrypted record of your login password.
Please note, that as many of our Services are primarily promotional tools, personal data included in these public profiles may be accessible by other Spotlight users and/or the public via wide circulation or redistribution, and via our historical archives. Therefore you should never include any personal data on your profile that you would wish to remain private.
How will we use your personal information?
We (or third party data processors acting on our behalf) may collect, store, use and share your personal information for the following purposes:
- To provide you with the Spotlight Services, including making your public profile information available to other users of the Services;
- To fulfil orders for products or Services (including recognising returning members, returning customers and previous member applicants);
- To keep your details and records up-to-date and accurate;
- To provide you with important service communications relating to Spotlight products or Services;
- To communicate with you regarding professional industry enquiries;
- To invite you to and manage your attendance at Spotlight and our partner events;
- To answer/respond to your enquiries and complaints or otherwise communicate with you;
- To process and share audio and visual content including self-tape and audition videos;
- To vet your professional background when you are joining as a Spotlight Member/Agent/Spotlight Casting Subscriber or purchasing a restricted access product;
- Internal record keeping;
- To notify you of other products and/or services that we think will be of interest to you (you can unsubscribe from these communications at any time by managing your subscriptions within your account or by writing to us or emailing us at [email protected] – please view our Marketing Privacy Policy for more information;
- To inform you of latest developments within Spotlight and the wider industry;
- To contact you as an expired member or subscriber about how you can rejoin Spotlight;
- To assist in the creation and editing of audio and visual content;
- To improve our products and services;
- To understand about information to better inform business decisions;
- To verify your identity;
- For market research and analysis, such as receiving opinions and feedback on our products and services;
- To administer prize draws or competitions where you have entered into;
- To process payments and identify or prevent fraudulent transactions;
- To develop, test and improve our sites, services and products that we provide to you;
- For training and monitoring purposes;
- To provide you with access to specific search facilities;
- To comply with any legal obligation such as to share data with law enforcement;
- To ensure the safety of staff, visitors and Spotlight’s buildings and offices;
- To provide guest WiFi services within Spotlight offices in accordance with the Guest WiFi Terms of Use;
- To customise our site to your interests;
- To facilitate the historical archiving of information, including Spotlight public profiles/titles both in print and digital formats and media footage.
What personal information do we share?
We share personal information with carefully selected and trusted third parties when required. Wherever possible only information contained within your public profile would be released to such third parties. To keep your data safe and maintain your privacy we have the following approach:
- We implement appropriate legal, procedural and technical controls;
- We only provide the information they need to undertake that service;
- They can only use the information for that specific purpose;
- We maintain a close relationship to make sure that your data is protected and your privacy maintained;
- We mandate that if or when the service stops, they must return or delete any information held.
Here are the examples of the types of trusted third parties we work with:
- Within the Talent Systems Group,
- Spotlight network partners, circulating breakdown information via their casting platforms in other territories,
- Subcontractors assisting us in providing our service to our users,
- IT companies who help us deliver our sites and services,
- Google APIs - we use Google APIs to help us provide better services to you, such as the Google Places API which enables you to provide consistent location data in a secure and non-intrusive way. Please note that you are bound by Google’s Terms of Service and Privacy Policy when you use parts of our service which are powered by Google.
- Third parties who provide service enhancements or additional functionality to our users related to how they use our services.
- More information: In order to facilitate certain users of Spotlight with their workflow management processes or other functionality, Spotlight may from time to time provide or authorise the use of certain third party software or applications to facilitate additional off-site access to the professional materials and content otherwise available via the Services. An example of this would be third party tools used by Agents to administer their client submissions to casting services alongside diary management etc, or software used by casting directors during the audition process. Such third party packages or systems should only be used subject to the written approval of Spotlight. You acknowledge that your personal information may be used in this way. Please note however that Spotlight does not endorse and is therefore not responsible for any such third party packages or systems, and Spotlight will not be liable for any loss of information, materials, data or otherwise that may occur due to the use of your information within them.
- Third parties who are involved in furthering research and technology in areas connected with our service.
- More information: We are constantly looking for new ways to change and upgrade our Services and functionality. This may involve partnering with selected and trusted research organisations and technology providers to contribute to their research and innovation projects. Often the most innovative developments come from other industries or fields of research outside of our own, and the outputs of the research may have a broader application beyond the improvements from which we directly benefit. As part of this research our trusted partners may be given access to our systems and data and/or be provided with copies of our data, including member photos, video and audio clips, and other professional information from their public profile. In all such circumstances our partners' access to and use of this information will be comprehensively documented and strictly limited to specific research projects that may include benefits for Spotlight and our Services to you, and will be under secure, confidential, temporary conditions, and closed testing environments. Under no circumstances will this information be used for any commercial or live operational activity, other than to develop and test the specific technology and functionality, without your prior consent.
- Law enforcement in complying with the law, or to enforce our Terms and Conditions or to protect the rights, property, or safety of ourselves, our customers or other third parties,
- If we acquire any new business, and/or sell all or part of our business,
- Third party payment service providers, and
- Third parties as detailed within your specific Membership Terms.
How long do we keep your information?
We will not keep personal information for longer than it is necessary, and will only retain information for as long as needed to carry out our functions and that purpose. Personal information is retained in line with our retention schedule.
Where your information is processed
The Brexit transition period was due to end on 31/12/2020, but this has been extended for a further period, therefore although Spotlight is mainly established in the UK - a country outside of the European Economic Area (EEA), during this further transition period transfers from EU to the UK will not be considered transfers of personal data to a third country and therefore will not be prohibited by the GDPR. The information that we collect from you may be transferred to, and stored at, a destination inside and outside the European Economic Area (EEA) in certain circumstances. For example, if we contract with service providers based outside the EEA, or if any of our servers are at any time based inside or outside the EEA (including 'cloud' service provision). For all personal data transfers we put in place safeguards to make sure that your information has the same level of protection as if it was inside the EEA. Where we would have to disclose your personal information to third parties, in any circumstances, we will always take all appropriate steps to ensure that such third parties are responsible and trusted and that your personal information will be treated in accordance with this Privacy Policy, and to European and UK Data Protection standards or equivalent.
Payment security
We will retain payment details briefly (the duration of time it takes to complete each transaction) whilst purchases are made through our online shop. Payment card details are not stored on our servers beyond this.
Our secure socket layer software (SSL) is the industry standard and among the best software available today for secure commerce transactions. It encrypts all personal information including credit card numbers, names and addresses. This encryption has the objective of ensuring that nothing can be read as it travels over the Internet to our chosen fully PCI DSS compliant payment service providers www.sagepay.com and https://worldpay.com/ for processing.
If you experience any payment problems when placing an order via our Site, we advise you to resubmit your payment details. If your payment still fails, please contact your card issuer, to ensure there are no problems with your account, before contacting our customer services team.
Links to other websites
Our site may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites such as social media websites and such sites are not governed by this Privacy Policy. You should exercise caution and look at the privacy policy applicable to the website in question.
Keeping your personal information up-to-date
Spotlight provides you with access to your personal information and tools to manage this. If you have provided us with personal information, it is your responsibility to ensure that it is correct and up to date. This will enable us to provide you with the best service possible. Please contact us as soon as possible if you believe that any information we are holding on you is incorrect or incomplete.
Your rights
You have a number of rights to your information that can be accessed by contacting the Data Protection Officer at [email protected]. Please note that due to the current COVID-19 pandemic there is no physical point of contact.
To make sure we protect you and your information, we will need to verify your identity for any requests we receive from you before we begin to process your request.
If you are based in the EU/EEA
If you are based in the European Union/European Economic Area, you can access your rights by contacting Spotlight’s EU data protection representative at [email protected]. Please note that due to the current COVID-19 pandemic there is no physical point of contact.
Children
As a Parent or Guardian representing a child, you are a third party acting on behalf of your child and it is your responsibility to inform the child of their rights, and to act solely in your child’s best interests. Parents or guardians have the right to exercise the below rights on behalf of the child that they represent.
Third party
If this is a third party acting on your behalf, we will request that they provide proof that they have your consent to represent you.
If we decide not to action your request we will explain our justification for refusal.
Rights available to you
- Access your information – you can request access to or a copy of your personal information and check what information we hold about you.
- Change or correct your information – if you wish to have any errors corrected, you can request this – although this is not an absolute right and we may request for further information.
- Take your information – you can ask for a copy of your personal information to be provided in a reusable and machine-readable form.
- Object to, limit or restrict the use of your information – you can ask that we stop using parts or all of your personal information or limit its use if you believe that this personal information is unlawfully held.
- Direct marketing – you can ask that we stop using your personal information for direct marketing. This can be by managing your privacy settings within your account; by clicking on an ‘unsubscribe’ link in an email or writing to the Data Protection Officer.
- Delete your information – you can ask that your personal information is deleted if you believe it is no longer necessary for the purposes it was collected.
- Legitimate interest – if we are processing your information on the grounds of legitimate interest, you can ask us to stop this if there are reasons related to your individual circumstances. We have to do this unless we believe we still have an overriding legitimate reason.
If you are unhappy
The theme throughout this Policy is that Spotlight treats your privacy with the utmost importance and we strive to meet the highest standards when collecting and using personal information. If, for whatever reason, you believe that our collection or use of your information is unfair or inappropriate, we encourage you to report this to our Data Protection Officer. We will take any complaints we receive about your privacy very seriously.
You also have the right to complain to your supervisory authority if you are unhappy with how your personal information has been collected, used or managed, which within the UK is the Information Commissioner’s Office (ICO) who can be contacted by calling 0303 123 1113 or by visiting www.ico.org.uk.
If you are based in the European Union (EU) or European Economic Area (EEA) you may complain to Spotlight’s appointed lead European supervisory authority by contacting the Irish Data Protection Commissioner (DPC) by visiting this webpage (https://www.dataprotection.ie/en/contact/how-contact-us).
Cookies Policy
How we use cookies and similar technologies.
What is a cookie?
A cookie is a piece of information that is stored on your computer's hard drive by your web browser. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.
Managing cookies
Most web browsers allow control over these cookies through the browser settings. If you are a Spotlight Member, Agent or Spotlight Casting Subscriber some cookies are vital to your effective usage of our Services; we use these to identify Spotlight Members/Agents/Spotlight Casting Subscribers, manage secure logins and authentication status, remember website preferences and also to ensure secure renewals and payments can be made. Therefore if you choose to disable these cookies you will not be able to use the Spotlight website.
Why do we use cookies?
Spotlight also uses cookies to track and analyse visits to our site and the use of video and audio material, with the aim of constantly improving our site services and ensuring that we are adequately supporting the growing number of visitors to our site. These may include third party cookies set by Google Analytics, Twitter, and BookingBug (our event booking service).
Third party cookies
Cookies from third parties may also be used by Spotlight to help us understand how our visitors engage with the website and to determine, for instance, the number of people who click on an advertisement and subsequently buy our services. To gather this information, Spotlight uses Google Analytics, Google AdWords and Hotjar. For more information on how Google uses cookies for analytics and conversion tracking click here. For Hotjar, click here. Spotlight also uses Google Analytics Measurement Protocol to track and analyse usage of the Spotlight Casting Mac application. More information is available here.
You can also see a full list of all third party cookies on your web browser by visiting Your Choices Online.
To see a comprehensive list of the cookies used on the Spotlight website, and their purpose, please click here.
For more information about cookies, including how to remove and disable them, visit this website.
How we use IP addresses
An IP address is a number which is automatically assigned to your computer whenever you access the internet. When you access the Spotlight site we will log your IP address. Third parties we work with such as our Payment Service Providers may also capture this information from you. We generally only use IP addresses to analyse trends, administer our website, track general user movements and gather broad demographic information for aggregate use, or where investigating possible criminal activity. However, we do link IP addresses to other information which could identify the user, for instance when assessing applications from new, re-joining and renewing members to ensure that they are provided with legal 'cooling off periods' where necessary. They will also be used to ascertain where members may be attempting to seek extended free periods on the Spotlight website by the misuse of our 'cooling off periods' or refund policy (see Terms & Conditions), or to identify potentially inappropriate or fraudulent membership applications. The IP information gathered for this purpose will only be used to 'flag up' possible misuse to Spotlight staff members.
Digital Editions
In relation to any digital edition/Application, previously or currently offered by us, please note that Apple, Google, Amazon or other providers may on occasion transfer some of your data to Spotlight. Spotlight may also gather information such as your name and email address within the app; such personal data will be administrated in line with this privacy policy.
More information and information in an accessible format
This Privacy Policy has been carefully written to try to provide clarity and understanding and to make sure the information contained within it is accessible for you. If there is information you do not understand, or if you require additional explanation, please contact the Data Protection Officer using the contact details within this Policy and we will be happy to assist you.
Queries
If you have any queries about the way your data is used by Spotlight, please contact:
Data Protection Officer
Spotlight
7 Leicester Place
London WC2H 7RJ
[email protected]
