Privacy Policy - Meet Genie
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Privacy Policy

This Privacy Notice (“Privacy Notice”) sets out how Meet Genie Limited ( “we”, “us” or “our”) processes your personal data in connection with our business, including in connection with our platform which can be accessed via our website at www.meetgenie.co, our mobile and desktop applications, and via certain other third party sites and/or platforms (collectively, “Genie”).

This Privacy Notice applies to users of Genie and others that we interact with in connection with our business, including personnel of our clients and suppliers. To find out more please see the “Who we collect personal data about” section.

We will update this Privacy Notice from time to time to reflect any changes or proposed changes to our use of your personal data, or to comply with changes in applicable law or regulatory requirements. We may notify you by email of any significant changes to this Privacy Notice, but we encourage you to review this Privacy Notice periodically to keep up to date on how we use your personal data.

Where you are a user of Genie, your access to and use of Genie is subject at all times to the agreements that we have in place with you or the organisation that you represent.

1 - Purpose of this privacy notice

 

This Privacy Notice explains our approach to any personal data that we might collect from you or which we have obtained about you from a third party, and the purposes for which we process your personal data.
This Privacy Notice also sets out your rights in respect of our processing of your personal data.

 

When we talk about “personal data”, we mean any information which relates to an identified or identifiable living individual. Individuals might be identified by reference to a name, an identification number, location data, an online identifier (such as an IP address) or to other factors that are specific to them, such as their physical appearance.

This Privacy Notice is intended to inform and assist you in respect of your interactions with us. Please take a moment to read and understand it. It should be read in conjunction with our Cookie Policy.


This Privacy Notice only applies to the use of your personal data obtained by us, whether from you directly or from a third party. It does not apply to personal data collected by third parties during your communications with those third parties or your use of their products or services (for example, where you follow links we provide to third party websites over which we have no control, or you purchase goods or services from third parties that we refer you to).

In addition, this Privacy Notice does not apply when we process personal data on behalf and under the instruction of our clients in connection with Genie, for example where Client Users submit information to Genie relating to freelance services that have been provided by Talent Users for that client’s own internal purposes.

2 - About Us

 

Genie is made available by Meet Genie Limited. Meet Genie Limited is the data controller responsible for your personal data. Meet Genie Limited is an English company (no. 11847171) with its registered office at West Bush House, Hailey Lane, Hertford Heath, Hertfordshire, United Kingdom, SG13 7NY.

3 - How to contact Us

 

If you have any questions about this Privacy Notice or want to exercise your rights as a data subject set out in this Privacy Notice, you can contact us using the following methods:

Email

Send us an email at: data.controller@meetgenie.co

Post

Write to us at: West Bush House, Hailey Lane, Hertford Heath, Hertfordshire, United Kingdom, SG13 7NY

4 - Who we collect personal data about


We collect and process personal data from the following people:

Client User

A user that accesses Genie on behalf of one of our clients that are seeking to find and/or engage Talent Users via Genie.

Talent User

A user that accesses Genie in connection with (i) the supply or potential supply of freelance services to our clients; and/or (ii) the engagement or potential engagement with our clients as worker or employee, in each case in accordance with briefs posted to Genie by Client Users.

Genie Visitor

Client Users, Talent Users and any other (non-registered) user of Genie or any person that visits and/or interacts with us on social media.

People who contact us

If you contact us with an enquiry, to provide us with feedback, or to market services to us we will collect and process your personal data in connection with your communication.

People who work for our clients and suppliers

If you work for one of our clients (whether you are a Client User or otherwise) or suppliers and have responsibility managing our relationship with your organisation, we will process your personal data in connection with your organisation’s relationship with us.

Visitors to our office and other locations that we use

If you attend our offices or other locations (including in relation to any event that we host), we may process personal data that you volunteer in connection with your visit and any enquiries you make. For example, you may volunteer personal data when signing in as a guest. CCTV footage may also be collected for security purposes. We may also ask you to complete a registration or feedback form, or other document relating to the event or purpose for which you are visiting us.

Job applicants

If you apply for formal employment or other type of permanent or semi-permanent position with us we will collect and process your personal data in connection with your application.

5 - What personal data we collect


In providing Genie, we may collect and process different types of personal data about you for different processing purposes. The types of personal data we collect depends on who you are and how you use Genie and includes the following (as applicable):

Identity Data

First name; last name; job title; and organisation that you represent

Registration Data

email address; Genie username and password.

Contact Data

Home, work and/or billing addresses; email address; and telephone number(s).

Profile Data

Information relating to a Talent User’s Genie profile, including:

  • date of birth; gender; country of residence; nationality and eligibility to work (including documents and information that we may collect to verify this);
  • your interests and preferences (including personal and professional likes and interests); skills, awards, qualifications, training and work/employment history; photos and/or videos featuring you that you may post to Genie; any personal data that appears in your curriculum vitae; links to your social media and/or your work/portfolio (on your or third party websites);
  • any feedback that Client Users share with us in respect of freelance services or work that are provided (but not including information that Client Users post to Genie for their own purposes, which we process as a processor under instructions from the relevant client); and
  • any other personal data that you volunteer during your interactions with us or Genie.

Platform Data

Any personal data that:

  • we observe about, or otherwise collect from, Talent Users in connection with their use of Genie (for example acceptance/completion of a brief and/or feedback provided by the Talent User in respect of Genie or a client); and/or
  • we observe from Client Users in connection with their use of Genie.

This personal data may be collected via cookies (or other similar types of tracking technologies) that are used in connection with your browsing activity on and/or interaction with Genie and/or our emails. See the “Insight and analysis through Cookies” section for details.

Communications Data

The content of any emails or other communications that you send to us.

Marketing Data

Details of any marketing preferences that you have communicated to us.

Financial Data

Bank account details.

Transactional Data

Details about payments made between you, or the organisation you represent, and us; details of our client’s briefs; details of fees payable by clients to Talent Users in respect of freelance services and/or work.

Technical Data

IP address; browser type and version; operating system; geolocation, to ensure we’re showing you the correct notices and information; referring website address; and any unique numbers assigned to a device.

6 - How we collect and receive personal data


We collect and receive personal data using different methods:

Personal data you provide to us

You may give us your personal data directly, for example, when you contact us with enquiries, complete forms on Genie, subscribe to receive our marketing communications or provide feedback to us.

Personal data we collect using cookies and other similar technologies

When you access and use Genie, we may collect Platform Data and Technical Data by using cookies and other similar technologies (see the “Insight and analysis through Cookies” section).

Personal data received from third parties

We may receive personal data about you from third parties. Such third parties may include analytics providers, data brokers, third party directories and third parties that provide technical services to us so that we can provide Genie.

Publicly available personal data

From time to time, we may collect personal data about you (Identity Data, Contact Data or Profile Data) that is contained in publicly available sources (including open source data sets or media reports) or that you or a third party may otherwise make publicly available (for example through speeches at events or publishing articles or other news stories or posts on social media platforms).

7 - How we use your personal data


We use your personal data for the purposes set out in this section. If we wish to make any changes to these purposes, or if we wish to use your personal data for any purpose that is not listed in this section, we will notify you using the contact details we hold for you.


Use of Genie by Talent Users

To register your initial interest in Genie and assess your suitability to use Genie

If you submit an application to be registered as a Talent User of Genie, we will ask you to provide your Identity Data, Contact Data, Registration Data and some Profile Data in order to understand the type of representation you require and whether you are suitable to use Genie.


As soon as possible after completing your application, we will contact you using your Contact Data to let you know that we have received your application and if you are suitable for Genie, in which event you will be invited to complete your registration (see below).


We will also use your Profile Data on an ongoing basis to assess your continued suitability to be registered as a Talent User of Genie.


If we do not consider you to be suitable to be registered (or to continue to be registered) as a Talent User, we will notify you and reject your application for representation or terminate your use of Genie.


Our legal basis for processing


It is in our and our client’s legitimate interests to use your personal data to ensure that Genie is only used by Talent Users that are generally suitable for our client’s briefs.

To complete your Genie registration and to create and manage your profile

If you are invited to register to use Genie, we will ask you to create an account and complete your profile. You will be asked a series of questions which will include providing additional Profile Data that we did not request as part of the suitability process. We will use this in order to build and generate your Genie profile.


We may also ask for further information later if it is requested by our clients or if we think it may be useful, and we may provide you with functionality so that you can voluntarily provide (or delete) Profile Data through Genie at any time.


This data will be used to match you with client briefs (see below) so, if you do not provide it, you may not be matched to client briefs or selected by our clients to provide your freelance services and/or to otherwise work for our clients.


Our legal basis for processing


It is in our legitimate interest to use your personal data in such a way to register your account on Genie and onboard you. Where you provide any special category data (such as data concerning your health) to us as part of your application, it is necessary for us to process this to ensure that we and/or our clients are meeting the duty of care that is owed to you (i.e. to ensure that any briefs are suitable and do not put you at unnecessary risk) and to defend against any potential legal claim that may be issued against us or our clients.

To match you with client briefs and to share your personal data with our clients

Genie is proprietary machine learning matching algorithm. Genie automatically analyses your Profile Data and Platform Data to match you to client briefs that we think are right for you.


The nature of our clients’ briefs varies, and some Talent Users are better suited to certain briefs than others. Here are some examples of how Genie intelligently analyses your personal information to match you to client briefs:

  • some briefs may (for example) require Talent Users who have experience working with the Luxury or Fashion Industry sectors or who are interested in sport so, if that’s you, Genie might match you to those briefs;
  • Genie might assess whether you share similar characteristics with (or ‘look-like’) other Talent Users that we know are suitable to a client brief, so we might match you to those briefs;
  • where we have received positive (or negative) feedback about you from one client and we are allowed to use it for our own purposes, we may match you (or decide to not match you) to the brief of another client where we know that those two clients share similar preferences for Talent Users.

Where there is a match, we may use your Contact Data to notify you and, if you express an interest in a client brief, we will share some of your Identity Data, Contact Data and Profile Data. We do this so that Client Users can assess your suitability for their brief and so that Client Users can contact you about, and you can engage with them to provide, your freelance services and/or work for them. To find out what information has been shared with a Client User, please contact us using the details set out in the “How to contact us” section.


Please note, where we share your personal data with Client Users or you provide freelance services to and/or work for one of our clients, that client will be a separate controller of any of your personal data that they receive in connection with your supply of the freelance services and/or work, including any data that we share with that client. For information about how and why our clients process your personal data, please see their privacy policy or contact them for further information.


Our legal basis for processing


Use of your personal data in this way is a core part of Genie and, without doing this, we could not match you to client briefs. It is therefore necessary for us to use your personal data in this way in order to perform the contract that we have with you. It is also in our and our clients legitimate interests to use your personal data in this way to ensure that Genie is as effective as it can be and to ensure that clients only engage Talent Users that are a right fit for their brief.

To pay Talent Users on behalf of clients for freelance services and/or work

Where you have provided freelance services and/or work to a client and that client elects to be invoiced for those services or work through Genie (Genie Invoicing), we will use Transaction Data and Financial Data to pay you the fees that clients owe you for your freelance services or work.


Our legal basis for processing


It is necessary for us to use your personal data in this way in order to perform the contract that we have with you, and it is in our clients legitimate interests to use your personal data in this way so that we can efficiently manage the payment of fees from clients to you.

Use of Genie by Client Users and managing our client relationships

Use of Genie by Client Users

Where you are a Client User, we collect and maintain personal data that you provide to us or that we otherwise receive in connection with your use of Genie. We will use this for the purpose of supplying Genie to our clients.


The personal data we process may include your Contact Data, Financial Data and Transaction Data (where applicable and to the extent that this constitutes your personal data). We process this information so that we can fulfil the supply of Genie and for record-keeping purposes.


If you attend one of our offices, we will process personal data about you that we receive in connection with your visit or any enquiries that you have. This will usually include your Contact Data, and any other personal data you volunteer.


Note, use of Genie is also subject to separate terms and conditions between us and our clients.


Our legal basis for processing


It is in our legitimate interest to use personal data in such a way to ensure that we provide Genie and manage your visit to our office in an effective, safe and efficient way.

Managing our relationships and communicating with our clients and potential clients

When you make an enquiry (whether via email, telephone or otherwise) or we communicate with you in relation to our services and/or our client relationship, we will collect and process your Identity Data, Contact Data and, if applicable, Transaction Data, as well as any other relevant personal data you volunteer or that we otherwise receive. We use this information to respond to your enquiry and to manage the relationships that we have with our clients.

 

We may also record (including voice recordings of telephone conversations) and use the information referred to above to train our personnel so that they can effectively deal with enquiries.


Our legal basis for processing


It is in our legitimate interest to use your personal data in the ways described above to ensure that we are able to help you with your enquiry, provide a good standard of service and improve our client relationships.

Other use of Genie by Genie Visitors

If you browse Genie

When you browse Genie, we collect and process Platform Data and Technical Data to help us understand how you are using and navigating Genie. We do this so that we can better understand which parts of Genie are more or less popular and to improve the contents, structure and navigation of Genie.


Our legal basis for processing


Please see the “Insight and analysis through Cookies” section to learn about the legal basis that we rely on to collect data via the use of non-essential Cookies.
Where we collect Platform Data and Technical Data other than through the use of non-essential Cookies, it is in our legitimate interest to use personal data in such a way to ensure that we provide access to Genie in a secure and effective way and so that we can make improvements to Genie.

If you link to social media sites and interact with our social media pages

If you interact with our social media pages such as on Facebook (including interacting with any ‘like’ or similar embedded features on our social media accounts), the relevant social media platform may receive information relating to such interaction and may use that information to provide us with aggregated and de-identified statistics about how users are interacting with our social media pages.


The relevant social media platform will also be a controller in respect of the personal data that is collected via your use of our social media pages and may use that personal data for additional purposes. For details of how the relevant social media platform uses your personal data, please see the privacy policy of the relevant social media platform.


Our legal basis for processing


It is in our legitimate interest to use personal data in the ways described above to ensure that we provide Genie in an effective way and to promote Genie via social media.

To resolve technical issues concerning our Site

If you have a technical issue concerning Genie, we may collect and process Platform Data and Technical Data and any other information that you provide to us to help us diagnose and resolve the technical issues you are experiencing in an efficient way.


Our legal basis for processing


It is in our legitimate interest to ensure that Genie is operating effectively.

Contacting us, surveys and feedback

If you contact us for any reason

There are various ways in which you can get in touch with us voluntarily (see the “How to contact us” section). From time to time, you may also be able to submit specific enquiries on Genie, including in secure account areas.


When you contact us, we will collect and process your Identity Data, Contact Data, Communication Data and, if applicable, Profile Data, Transaction Data or any other personal data that is relevant to your enquiry. We use this information to manage and respond to your enquiry.


If you have a technical issue concerning Genie, we may also collect and process Platform Data and Technical Data to help us diagnose the technical issues you are experiencing and to help us resolve them in an efficient way.


We also may record (including voice recordings of telephone conversations) and use the information referred to above to train our personnel so that they can effectively deal with enquiries.


Our legal basis for processing


It is in our legitimate interest to use your personal data in the ways described above to ensure that we are able to help you with your enquiry and provide Genie in an effective and efficient manner.

If you complete our surveys or provide feedback on your experience of Genie

From time to time, we will invite you to provide feedback about us and/or Genie in the form of surveys. We will collect and process your Identity Data, Contact Data and, if applicable, Profile Data or Transaction Data, as well as any other personal data that you volunteer in your response.


We use this information to help us to monitor and improve Genie and to train our personnel.


Our legal basis for processing


It is in our legitimate interest to use the personal data provided by you so that we can improve Genie and provide our business in an effective way.

Hosting and managing events.

If you sign up for and/or attend one of our events

From time to time, we may organise and host events for the purpose of promoting our business or for charitable causes or other reasons. We may process your Identity Data and Contact Data to communicate with you about such events where you have specifically requested information about such events or where we have another lawful basis for sending that information to you.


If you attend one of our events, we may use your Identity Data and Contact Data to record your attendance at the event and for related record-keeping purposes and, if relevant, we may collect and process any dietary requirements you may have. You may also feature in photographs taken at our events and such photographs may appear in publications that we make available.


Our legal basis for processing


It is necessary for us to use your personal data in this way to perform our obligations in accordance with any contract that we may have with you where you have signed up to attend an event, or it is in our legitimate interest or a third party’s legitimate interest to use personal data in such a way to ensure that the event is operated in an effective way.


We may specifically ask your permission to use your photographs, quotes, testimonials, or other content that you make available or publish at the event. Where this is the case, our processing of your such personal data will be based on consent.

Prize draws, prize competitions and other promotions

If you participate in one of our promotions

From time to time we may run prize draws, prize competitions and other promotions on Genie and/or on our social media accounts. For the purposes of administering such promotions, we may process your Identity Data, Contact Data and any other personal data volunteered by you or that we ask for in relation to your promotion entry.


Our promotions are subject to separate terms and conditions, which you may be required to accept as a condition of entry.


Our legal basis for processing


It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you (e.g. the promotion terms and conditions) or it is in our legitimate interest to use your personal data to enable us to administer our promotion fairly and effectively and to ensure that we comply with self-regulatory codes governing the operation of promotions.

Insight and analysis through Cookies

We use cookies to help us understand more about you and your use of our Genie and to market Genie

We and our third-party partners use cookies, web beacons, pixel tags and other similar technologies (which we generically refer to as “Cookies”) to collect data from the devices that you use to access Genie and any emails that you receive from us. The data that is collected includes Platform Data and Technical Data. Please see our Cookie Policy for further information, including details of our third-party partners.


We and our third-party partners use this data to analyse how you use Genie and the effectiveness of Genie and our emails, including:

  • to analyse how you use, and the effectiveness of, Genie and our emails;
  • to count users who have visited Genie or opened an email and collect other types of information, including insights about visitor browsing habits, which helps us to improve Genie and the effectiveness of our emails;
  • to measure the effectiveness of Genie;
  • to learn what parts of Genie are most popular and what kind of features and functionalities our visitors like to see;
  • to help us understand the type of content that is most likely to appeal to our visitors and clients;
  • to help us improve and design Genie;
  • to remember your preferences.

In some of our email messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.


Our legal basis for processing


Where we use personal data collected through the use of analytics cookies to analyse how you use Genie and/or our emails, it is in our legitimate interest to use your personal data for the purposes described above.

Advertising and marketing to our clients and prospective clients

If we send our clients or prospective clients marketing communications by post and/or email/SMS

We use your Identity Data, Contact Data and Marketing Data (if any) to send you (or the organisation you represent) marketing communications relating to us and/or Genie by post and/or email/SMS, including information about events we may hold and the offers and promotions we offer from time to time.


Our marketing communications will include personalised and non-personalised marketing. Personalised marketing has been specifically tailored to you and will include content that we think is most relevant to you, based on what we know about you. Non-personalised marketing is marketing that is not tailored to you.


Our legal basis for processing


It is in our legitimate interest to use your personal data for marketing purposes, for example to decide what marketing content we think may appeal to you.


It is in our legitimate interest to use your personal data to send our marketing to you by post.


It is in our legitimate interest to use your personal data to send our marketing to you by email and/or SMS, except where we are required by applicable law to obtain your consent in which case we will only send marketing communications to you by email and/or SMS where you have consented to receive such communications.

Our internal recruitment activities

If we use your personal data in connection with our own internal recruitment activities)

We use your personal data for recruitment purposes, in particular, to assess your suitability for any of our positions that you apply for, whether such application has been received by us online, by email or by hard copy and whether submitted directly by you or by a third-party recruitment agency on your behalf. We also use your Identity Data and Contact Data to communicate with you about the recruitment process, to keep records about our recruitment process and to comply with our legal and regulatory obligations in relation to recruitment.


We will process any personal data about you that you volunteer, including during any interview, when you apply for a position with us. We may also process your personal data obtained from any third parties we work with in relation to our recruitment activities, including without limitation, recruitment agencies, background check providers, credit reference agencies and your referees.


The personal data we process may include your Identity Data, Contact Data, and Profile Data, or any personal data which is contained in any reference about you that we receive. Such information may also include special categories of personal data (such as information about your health, any medical conditions and your health and sickness records) and information relating to criminal convictions and offences if that information is relevant to the role you are applying for.


We also use your personal data for the purposes of reviewing our equal opportunity profile in accordance with applicable legislation. We do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment-related decisions are made entirely on merit.


Our legal basis for processing


Where we use your personal data in connection with recruitment, it will be in connection with us taking steps at your request to enter into a contract we may have with you or it is in our legitimate interest to use personal data in such a way to ensure that we can make the best recruitment decisions.
We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.

Receipt of products and services from our suppliers.

If we have engaged you or the organisation you represent to provide us with products or services

If we have engaged you or the organisation you represent to provide us with products or services (for example, if you or the organisation you represent provide us with services such as IT support or financial advice), we will collect and process your personal data in order to manage our relationship with you or the organisation you represent, to receive products and services from you or the organisation you represent and, where relevant, to provide Genie to others. The personal data we collect from you may include your Identity Data and Contact Data and any other personal data you volunteer which is relevant to our relationship with you or the organisation you represent.


Our legal basis for processing


It is necessary for us to use your personal data to perform our obligations in accordance with any contract that we may have with you or the organisation you represent, or it is in our legitimate interest to use personal data in such a way to ensure that we have an effective working relationship with you or the organisation you represent and are able to receive the products and services that you or your organisation provides, and provide Genie to others, in an effective way.

Business administration and legal compliance

If we need to use your personal data to comply with our legal obligations or in connection with the administration of our business

We may use your personal data: (i) to comply with our legal obligations; (ii) to enforce our legal rights or defend potential legal claims; (iii) to protect the rights of third parties; and (iv) in connection with a business transition such as a merger, reorganisation, acquisition by another company, or sale of any of our assets.


Our legal basis for processing


Where we use your personal data in connection with a business transition, to enforce our legal rights or to protect the rights of third parties, it is in our legitimate interest to do so. For all other purposes described in this section, we have a legal obligation to use your personal data to comply with any legal obligations imposed upon us, such as a court order.


We will not process any special (or sensitive) categories of personal data or personal data relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent.

8 - If you fail to provide your personal data


Where we need to collect your personal data, or we need to collect your personal data in connection with any contract we have with you or your organisation, and you fail to provide that personal data when we request it, we may not be able to perform any contract that we have or are trying to enter into or you or your organisation may be prevented from working with us. This may apply where you do not provide the personal data we need in order to process an application to register as a Talent. In these circumstances, we may have to cancel your application, in which case we will notify you.

9 - How we obtain your consent


Where our use of your personal data requires consent, you can provide such consent at the time we collect your personal data following the instructions provided, or by informing us using the contact details set out in the “How to Contact Us” section.

10 - Third-party links


This Privacy Notice only applies to personal data processed by us through your use of Genie and/or in connection with our business operations. However, from time to time, Genie may contain links to third-party websites and services. We have no control over these websites and services and this Privacy Notice does not apply to your interaction with the relevant third parties.


When you use a link to go from Genie to another website (even if you don’t leave our Genie) or you request a service from a third party, your browsing and interactions on any other websites, or your dealings with any other third-party service provider, is subject to that website’s or third-party service provider’s own rules and policies. For example, Genie invites you to connect with us on social media platforms such as Instagram, Twitter and LinkedIn. When you click on the links we provide to such third-party platforms, you will be transferred from Genie to the relevant third-party platform and the privacy notice (and other terms and conditions) of that platform will apply to you.


We do not monitor, control or endorse the privacy practices of any third parties. We encourage you to become familiar with the privacy practices of every website you visit or third-party service provider that you use in connection with your interaction with us and to contact them if you have any questions about their respective privacy notices and practices.

11 - Sharing personal data


We only share personal data with others when we are legally permitted to do so. When we share personal data with others, we put contractual arrangements and security mechanisms in place to protect the personal data shared and to comply with our data protection, confidentiality and security standards and obligations.


When processing your personal data, we may need to share it with third parties (including other entities within our group of companies), as set out in the table below. This list is non-exhaustive and there may be circumstances where we need to share personal data with other third parties.

Clients

Where you are a Talent User, we may share your personal data with our clients or prospective clients as described in the Use of Genie by Talent Users section.

Third-party suppliers who provide applications/ functionality, data processing or IT services

We share personal data with third parties who support us in providing Genie and help provide, run and manage our internal IT systems. Such third parties may also include, for example, providers of information technology, cloud-based software-as-a-service providers, identity management, website design, hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them. We also share your personal data with third-party service providers to assist us with insight analytics. These providers are described in our Cookie Policy.

Payment providers and banks

We share personal data with third parties who assist us with the processing of payments and refunds.

Delivery and courier companies

e share personal data with suppliers who assist us in the delivery of Genie to our customers.

Third-party post/email marketing and CRM specialists

We share personal data with specialist suppliers who assist us in managing our marketing database and sending out our post and email marketing communications and account-related communications.

Third-party suppliers who assist us in administering our promotions

We share personal data with specialist suppliers who assist us in administering our prize draws, prize competitions and other promotions.

Event partners and suppliers

When we run events, we will share your personal data with third-party service providers that are assisting us with the operation and administration of that event. If we are running an event in partnership with other organisations, we will share your personal data with such organisations for use in relation to the event.

Hotel and transport operators and other travel-related businesses

When you submit an enquiry to us about a hotel or transport provider, we will share your enquiry (including any personal data you volunteer) with that third party so that they can provide the information and assistance that you have requested

Recruitment agencies and related organisations

We share personal data with external recruiters, third-party providers that undertake background checks on our behalf and other entities within our group of companies.

Auditors, lawyers, accountants and other professional advisers

We share personal data with professional services firms who advise and assist us in relation to the lawful and effective management of our organisation and in relation to any disputes we may become involved in.

Law enforcement or other government and regulatory agencies and bodies

We share personal data with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation.

Other third parties

Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

12 - Transfers outside the UK and the European Economic Area (“EEA”)


Where necessary in order to provide Genie, we will transfer personal data to countries outside the UK and the EEA.


Non-EEA countries do not have the same data protection laws as the UK and the EEA. In particular, non-EEA countries may not provide the same degree of protection for your personal data, may not give you the same rights in relation to your personal data and may not have a data protection supervisory authority to help you if you have any concerns about the processing of your personal data. However, when transferring your personal data outside the UK or the EEA, we will comply with our legal and regulatory obligations in relation to your personal data, including having a lawful basis for transferring personal data and putting appropriate safeguards in place to ensure an adequate level of protection for the personal data. We will take reasonable steps to ensure the security of your personal data in accordance with applicable data protection laws.


When transferring your personal data outside the UK or the EEA, we will, where required by applicable law, implement at least one of the safeguards set out below. Please contact us if you would like further information on the specific mechanisms used by us when transferring your personal data outside the UK or the EEA.

Adequacy decisions

We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by UK and/or European Union authorities. For further details, see

 

https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.

Model clauses

Where we use certain service providers, we may use specific contracts approved by UK and/or European Authorities which give personal data the same protection it has in the UK and the EEA. For further details, see

 

https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

13 - How long we keep your personal data


We generally keep personal data for as long as we need it for the purposes described in this Privacy Notice.


In respect of personal data that we process in connection with the supply of Genie to our clients, we may retain your personal data for up to seven years from the date of supply and in compliance with our data protection obligations. We may then destroy such files without further notice or liability.


Where we process personal data in connection with your registration as a Talent, we may retain your personal data for as long as you are registered as a Talent and for the purposes described in this Privacy Notice (in particular the purposes described in the Use of Genie by Talent Users section as long as reasonably necessary to comply with any contract we may have with you or so that we can introduce you to opportunities in the future that we think might be of interest to you (and in compliance with our data protection obligations). We may then destroy such files without further notice or liability.


Where we process any other personal data, we will generally retain relevant personal data for up to three years from the date of our last interaction with you (and in compliance with our data protect obligations). We may then destroy such files without further notice or liability.


If any personal data is only useful for a short period (e.g. for a specific activity, promotion or event), we will not retain it for longer than the period for which it is used by us.


If you have opted out of receiving marketing communications from us, we will need to retain certain personal data on a suppression list indefinitely so that we know not to send you further marketing communications in the future. However, we will not use this personal data to send you further marketing unless you subsequently opt back in to receive such marketing.

14 - Confidentiality and security of your personal data


We are committed to keeping the personal data you provide to us secure and we have implemented information security policies, rules and technical measures to protect the personal data under our control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. In addition, all our employees and data processors (i.e. those who process your personal data on our behalf) are obliged to respect the confidentiality of the personal data of all users of Genie.

15 - Personal data of minors


Genie is not intended for use by, or targeted at, minors (individuals under the age of 18) and we do not knowingly collect personal data of minors. However, this does not prevent minors from providing personal data to us. If we do collect personal data of minors, we will comply with all applicable laws and regulations relating to the processing of personal data of minors.

16 - Your rights as a data subject


You have certain rights in relation to the personal data we hold about you. These rights include the right: (i) to obtain copies of your personal data; (ii) to have your personal data corrected or deleted; (iii) to limit the way in which your personal data is used; (iv) to object to our use of your personal data; (v) to transfer your personal data; (vi) not to be subject to decisions based on automated processing (including profiling); and (vii) to complain to a supervisory authority. If you would like to exercise any of these rights, please contact us using the details set out in the “How to Contact Us” section.

Your right of access

If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data (along with certain other details). If you require additional copies, we may charge a reasonable fee for producing those additional copies.

Your right to rectification

If the personal data we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have shared your personal data with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you who we’ve shared your personal data with so that you can contact them.

Your right to erasure

You can ask us to delete or remove your personal data in some circumstances, such as where we no longer need it or where you withdraw your consent (where applicable). If we have shared your personal data with others, we will let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we will also tell you who we have shared your personal data with so that you can contact them directly.

Your right to restrict processing

You can ask us to “block” or suppress the processing of your personal data in certain circumstances such as where you contest the accuracy of that personal data or you object to us processing it for a particular purpose. This may not mean that we will stop storing your personal data but, where we do keep it, we will tell you if we remove any restriction that we have placed on your personal data to stop us processing it further. If we’ve shared your personal data with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal data with so that you can contact them directly.

Your right to data portability

You have the right, in certain circumstances, to obtain personal data you have provided to us (in a structured, commonly used and machine-readable format) and to reuse it elsewhere or to ask us to transfer it to your chosen third party.

Your right to object

You can ask us to stop processing your personal data, and we will do so, if we are: (i) relying on our own or someone else’s legitimate interest to process your personal data, except if we can demonstrate compelling legal grounds for the processing; or (ii) processing your personal data for direct marketing purposes.

Your rights in relation to automated decision-making and profiling

You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.

Your right to withdraw consent

If we rely on your consent (or explicit consent) as our legal basis for processing your personal data, you have the right to withdraw that consent at any time. You can exercise your right of withdrawal by contacting us using our contact details in the “How to Contact Us” section or by using any other opt-out mechanism we may provide, such as an unsubscribe link in an email.

Your right to lodge a complaint with the supervisory authority

If you have a concern about any aspect of our privacy practices, including the way we have handled your personal data, please contact us using the contact details provided in the “How to Contact Us” section. You can also report any issues or concerns to the Information Commissioner’s Office (“ICO”). Contact details for the ICO can be found on its website at https://ico.org.uk.

17 - Reporting Fraud

 

We are committed to ensuring your information is secure. As part of our efforts to protect your information Genie will never send you emails asking for your personal information or for your registered password (if you are a registered user).


If you do receive such an email or are asked to disclose this information by someone claiming to work for Genie please contact us using the contact details provided in the “How to Contact Us” section.