Privacy Policy for Talent Is Timeless LTD
Effective Date: July 28, 2023
At Talent Is Timeless LTD (“Talent Is Timeless,” “we,” “us,” or “our”), we are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, and disclose personal information when you access our songwriting membership website, competitions, retreats, and other services provided by Talent Is Timeless (collectively, the “services”).
We may collect and process the following types of personal information from you:
Contact Information: This includes your name, email address, postal address, and phone number.
Account Details: When you create a user account, we collect information such as your username and password.
Payment Details: If you choose to access certain services that require payment, we collect payment information, including credit card details, but we do not store credit card information on our servers.
Participation Data: We may collect data related to your participation in competitions, retreats, songwriting challenges, and other events or activities organized by Talent Is Timeless.
Communications: We may collect information from your communications with us, such as emails or messages you send to our support team.
We use the collected personal information for the following purposes:
Providing Services: To deliver the services you have requested, including granting access to the website and its features.
Communication: To communicate with you regarding account-related matters, updates, and notifications about the services.
Payment Processing: To process membership fees and payments for services you access.
Improving Services: To analyze and understand user preferences, usage patterns, and feedback, helping us enhance and optimize our website and services.
Research: To conduct research and gather insights into songwriting trends and interests, ensuring we offer relevant content and challenges.
Legal Obligations: To comply with applicable laws, regulations, or legal processes, including responding to legal requests and protecting our rights and property.
We may share your personal information under the following circumstances:
Service Providers: We may engage third-party service providers to assist in providing the services, such as payment processors, customer support, or analytics services. These providers have access to your information solely to perform their functions and are bound by confidentiality obligations.
Legal Compliance: We may share personal information when required by law or in response to valid legal requests, such as court orders or government inquiries.
Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, personal information may be transferred to the acquiring entity.
Consent: With your explicit consent, we may share certain personal information for specific purposes not covered by this Privacy Policy.
Your personal information may be transferred to and stored in countries outside the United Kingdom or the European Economic Area (EEA), where data protection laws may differ. We take steps to ensure that such transfers comply with applicable data protection regulations and maintain data security.
You have certain rights regarding your personal information, including:
Access: You can request access to the personal information we hold about you.
Correction: You can request corrections to any inaccurate or incomplete personal information.
Erasure: You have the right to request the deletion of your personal information under certain circumstances.
Objection: You can object to the processing of your personal information in certain situations.
To exercise these rights or inquire about your personal information, please contact us using the details provided in Section 8 below.
We will retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.
Usage of song submissions: We retain all song submissions including those that do not advance in the competition, for reference purposes only. This allows us to respond to any queries participants may have about their entries or the progress of their songs. Non winning entries will not be used for any other purpose without explicit consent.
Participants have the right to request the deletion of their song submissions at any time. Upon receiving such a request we will securely delete any specified data from our records.
We implement reasonable security measures to protect your personal information from unauthorized access, disclosure, or alteration. However, no method of data transmission over the internet or electronic storage is entirely secure, and we cannot guarantee absolute security.
If you have any questions or concerns about this Privacy Policy or wish to exercise your rights regarding your personal information, please contact us at:
Talent Is Timeless LTD 128 City Road, London, EC1V 2NX Email: [email protected], [email protected]
And just for reference, for you geeks out there, this was our old, more convoluted, less accessible privacy policy…
This Privacy Policy is effective Sept 29th, 2021.
1. Our Service
Welcome to Talent Is Timeless. Talent Is Timeless is where songwriters connect with each other to learn and socialise. We believe by bringing members together, we can cultivate a more creative world and make the collective point that there is no age limit to talent.
We invite you to read this Privacy Policy (“Privacy Policy”), which explains our privacy practices and how we handle your personal information collected through Talent Is Timeless, as well as through social media, our marketing activities, our live events, and other activities described in this Privacy Policy. This Privacy Policy also explains how we use and share such information and the choices you have.
We use “Talent Is Timeless” to refer to the Talent Is Timeless websites (also referred to as our “Services”). We also use “Talent Is Timeless,” “we,” “us,” and “our” to refer to the companies operating the Services as described in the Member Agreement.
Unless otherwise indicated, this Privacy Policy applies to all of our Services in all geographies in which Talent Is Timeless offers its Services. Certain portions of this Policy apply only to Services offered in particular geographies; please see Section 11 for additional information. Capitalised words used but not defined have the meanings described in the Member Agreement.
2. What information is collected?
We may collect personal information from you, through technology that automatically collects information from your browser or device, and from third party sources. See below for examples. Note that not all Talent Is Timeless account types and features are available in all locations, so some of the examples below may not apply where you live. We may also collect personal information that is not specifically listed below, which we use consistent with this Privacy Policy or as otherwise described at the time of collection.
2.1. From you.
● Your contact details.
○ When you sign up for Talent Is Timeless, you may provide your name, address, phone number, profile photo, email address, location, date of birth, gender, demographic information, and similar information.
○ If you want to join Talent Is Timeless, or use a Talent Is Timeless service, before it has been introduced to your location, then you can choose to give us your contact information and ask us to notify you when we introduce the service to your area.
○ If you contact support, you may provide us with your contact information and a description of the issue so we can respond.
● Data from other accounts. If you use a third party, like Facebook, Google, or Apple to log in to Talent Is Timeless (or later connect your third party account to your Talent Is Timeless account), then you authorise the third party to share your personal information with us, including your name, photo, email address, and any other information you agree to share.
● Posts, interests, location, and recommendations.
○ You may share information about yourself in your profile, including your interests, skills, a picture, biographical information (such as your job, hometown, time you have spent living in the area, etc.), emergency contact, or even what you love about music.
○ You may share information about your interests, including joining a Group or following a topic.
○ You may post on Talent Is Timeless, or send a private message. Posts may include, but are not limited to text, photos, or video, tagging people or places, and anything else you want to share.
○ You may choose to share information about local businesses in the form of a recommendation or comment.
● Payment information. If you make a payment either to or through Talent Is Timeless, then you are providing our third-party payment processors (for example, Stripe) with your payment card details and other payment information in order to complete the transaction.
● Survey data. We may contact some Members to request participation in a survey or other general research. If you choose to take part in these, you may provide information, feedback, and comments to us in response.
● Contests, sweepstakes, and prize drawings data. If you take part in a contest, sweepstakes, or prize drawing, then you may provide information, feedback, and comments in response.
● Messages and email data. We collect information about you when you send, receive, or engage with messages, emails or physical mail in connection with our Services, including whether you have opened or acted on those messages.
● Photos and videos. You may choose to grant the Services permission to collect images, video and other information from your device’s camera and photos, such as when you include images and video in your posts. These files may include metadata indicating how, when, where and by whom the files were created and how they are formatted. Metadata can make your files more searchable and interactive but it may be accessible to other Members or anyone else who can access the files.
● Contact lists. With your permission, we may sync your contacts with Talent Is Timeless, including their name, email address, physical address, and phone number. You may also manually enter the contact information of your members. We use this to help you see which of your contacts are already on Talent Is Timeless, invite contacts who aren’t on Talent Is Timeless to join, get notified when contacts join, and see more of what’s relevant to you through personalization.
● Geolocation. You may choose to grant the Services permission to access your device’s precise geolocation, which we use to confirm your address and help us operate or personalise our Services, including by tagging posts, adding information to a map, and helping us show you more relevant content or ads.
2.2. From your browser and device.
With your permission, where it is required by applicable laws, we, our service providers and partners collect technical information when you visit or use Talent Is Timeless, engage with our partners, or interact with our or our partners’ marketing communications, including:
● Device data, such as your device’s manufacturer and model, operating system and version, screen resolution, RAM and disk size, CPU usage, unique identifiers (including identifiers used for advertising purposes), crash data (if applicable), what device settings you’ve enabled, carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state or geographic area. Your device and software settings affect what information your device makes available to us.
● Online activity data, such as the date and time you visited, duration of access, the browser or app version you used (and its settings), the URLs you come from and go to, and how you used Talent Is Timeless and interacted with our emails and other messages (for example, how you navigated and which links you clicked on).
Some of the data collection described above is facilitated by cookies and similar technologies.
2.3. From third parties and public sources.
We may collect information from third parties (such as service providers and partners) and public sources. For example:
● Talent Is Timeless Members may sync their contacts with Talent Is Timeless, including their contacts’ email addresses, mailing addresses, and phone numbers.
● Vendors provide information about Members and their music for advertising, analytics, personalization, and measurement purposes.
● Advertisers provide us with information about their users or potential customers to help us personalise advertising and measure the performance of their advertisements.
● Public sources, such as census data, street addresses, property lot maps, and postal address change information, provide us with information that helps us understand our Members, improve our Services, and determine potential areas for expansion.
3. How is my information used?
We use personal information for the following purposes or as otherwise described at the time we collect it:
3.1. Establishing and developing songwriting communities
We use personal information to identify and invite potential new Members to Talent Is Timeless, and to set up new Talent Is Timeless communities. For example, you can ask us to send invitations to potential new Members and reminders on your behalf, send direct mail invitations, invite your friends, or notify you when we start offering the Services to your area.
3.2. Setting you up on Talent Is Timeless.
To get Members started on Talent Is Timeless, we use personal information to:
● Confirm Member accounts by employing several techniques, including checks against third party data and public records, verification codes, or geo-verification. We also use public registries to block registered sex offenders in the United States (and other countries where permitted by law) from signing up for the Services. In some circumstances, we may ask for additional information (such as government-issued identification and business documentation) to confirm Member accounts.
● Notify members of new Members as they join the community.
● Populate Member profiles and personalise Talent Is Timeless.
● Create and offer Business Services, which help Members learn about the businesses in their communities.
3.3. Provide and improve the Services.
We use both manual and automated systems to analyze and use your Content (as defined in the Member Agreement) and other information, including:
● To operate Talent Is Timeless, invite members, and improve our products and features.
● To help you create, publish, view, share, and respond to Content, including highlighting interesting posts.
● To highlight groups, topics or other resources.
● To administer and obtain feedback via surveys, sweepstakes, contests, or other promotional activities.
● To highlight businesses, ads, offers, products, and services you may be interested in.
● To provide Business Services, such as enabling Business Pages and promotional services.
● To personalise your experience.
● To understand the trends, usage statistics, and demographic data of the Members and areas we serve.
● To respond to your support requests and comments.
● To test and evaluate potential new products and features on Talent Is Timeless.
● To diagnose and resolve problems, analyze trends, and monitor usage and resource needs.
● To accept payments, through our third party payment processors.
● To facilitate sending urgent alerts.
● To communicate with you about the Service, including by sending announcements, updates, security alerts and support messages via email, notifications, and text messages.
3.4. Create and maintain a trusted environment.
We may use your information to help create and maintain a trusted environment on Talent Is Timeless, including:
● To detect and prevent fraud, spam, abuse, security incidents, and other harmful, unauthorised, unethical or illegal activity.
● To conduct security investigations, audits and risk assessments.
● To comply with our legal obligations.
● To confirm or authenticate information or identification.
● For the legal and safety reasons described below in Section 4.3.
3.5. Advertising.
We use your information to provide and improve advertisements and other commercial offerings both on and off the Services:
● To help personalise advertisements based on what we think may interest you.
● To provide and measure the effectiveness of personalised advertising, including whether it is interesting to Members and effective for the advertiser.
● To improve the personalization of advertisements.
● To send you promotional messages, marketing, advertising and other information that we think may interest you.
● To invite you to events and relevant opportunities.
We may customise advertising offers you see on Talent Is Timeless based on information from our advertisers or vendors, on the demographics of your location, or on your actions, selections, or preferences on Talent Is Timeless. For example, a home services company might provide a list of addresses eligible for a special deal that we may offer to Talent Is Timeless Members who live at those addresses. Or, if you search Talent Is Timeless for a particular product, we might show you advertisements for providers of that product or related or similar products. Our third party advertising partners also use cookies and similar technologies to collect information about Members for advertising purposes.
3.6. Research and Development.
We may use your personal information for research and development purposes. As part of these activities, we may create aggregated, de-identified and/or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.
4. Is my information shared with third parties?
We share personal information as follows:
4.1. Content shared on Talent Is Timeless.
Talent Is Timeless is a platform for members to share helpful information with each other. To that end, the Content you post on Talent Is Timeless, such as posts, replies, recommendations, messages, and your profile information, may be visible to other Members, businesses, governments and agencies, or the public, including Visitors (as defined in the Member Agreement) and search engines. Please be sure to read the options you have under the “What are My Choices” section below. If this information is cached by third party search engines or other third parties, please note we do not control the practices of these third parties, and they may use caches containing outdated information. Please consult these third parties’ privacy policies.
4.2. Account confirmation.
We may share your personal information with our verification partners, such as telecommunications providers (if you choose to confirm your account by providing your telephone number) and data providers to confirm your account.
4.3. Legal and safety reasons.
We may retain, preserve, or share your Content and personal information with law enforcement, government authorities, and private parties if we have a good-faith belief that it is reasonably necessary to: (a) respond, based on applicable law, to a legal request (e.g. a subpoena, a search warrant, court order, or other request from government or law enforcement); (b) detect, investigate, prevent, and address fraud and other unauthorised, illegal or unethical activity, security, or technical issues; (c) protect our or others’ rights, property, or safety; (d) enforce our Member Agreement or any other agreements we have with you; (e) prevent physical injury or other harm to any person or entity, including you and Members of the general public. For example, we may share your personal information with disaster relief agencies, first responders, and other individuals to facilitate disaster or emergency response efforts.
4.4. Advertising.
If you view, click on, or reply to an advertisement or other offer on the Services, we may share your reply and limited Member profile information with the advertiser, and we may log your interaction as part of tracking the overall effectiveness of the advertisement. We may also pre-populate replies to ads you click on with your contact details, but those details are not shared with the advertiser without your consent.
The Services are supported by third party advertising networks. With your consent, our advertising partners use cookies and similar technologies to collect information about our Members and their devices over time across Talent Is Timeless and other online services. Where permissible according to applicable law, we may share certain limited personal information, such as hashed emails and advertising identifiers, with our advertising partners that help serve targeted online advertising to those Members or to similar audiences. Our advertising partners may be able to associate this information with you based on your advertising identifiers or other personal information they have about you. Our advertising partners then use the information they collect to provide our Members with personalised ads on Talent Is Timeless and on different websites and services, and to measure the effectiveness of the ads.
4.5. Third party partners.
Talent Is Timeless may partner with third party companies to offer Members the ability to book a range of different services, such as studio facilities, online promotion of music and tutoring. These offers may be integrated into Talent Is Timeless, or Talent Is Timeless may contain links to other websites or apps featuring the offers. In order to tailor these offers to you, we may share limited personal information with such third parties, such as your Community or zip code, the business topic of the content you are viewing, or a business search query (for example, a search for “plumber”). When you engage with one of these offers, you may share additional information (such as contact information) directly with the third party partner. If you engage with third party partners through Talent Is Timeless, the third parties may share with us certain personal information about you to allow us to coordinate, assess, and improve the services provided to you. This may include information about a booking you make with the third party, including type of service, name and address of provider, and the time of booking. These third parties have their own privacy policies, which will apply to your activity if you click on or interact with their offers featured on Talent Is Timeless or other websites or apps.
4.6. Service providers.
We may also share your personal information with service providers and/or data processors to help us operate, provide, improve, understand, customise, support, and market our Services. These service providers and data processors are contractually required to use it only to provide their service to us, and are contractually prohibited from using it for their own purposes. They provide a variety of services, including payment processing, information technology, cybersecurity, fraud prevention, hosting, customer relationship management and support, communications delivery, marketing, advertising, and website and mobile application analytics.
4.7. Social Media.
Our Services include certain social media features, including social media share button. If you choose to share a post using the social media share button, information about that Content will be shared with the relevant social media platform.
4.8. Within the Talent Is Timeless corporate family.
We may share your information within our “corporate family” should we expand, to help provide, maintain, and improve Services. Some of these companies may not be located in your home country. As we grow and Talent Is Timeless becomes available in more countries, we may expand the corporate family within which we share your information by establishing local subsidiaries or other affiliates in these countries as needed to help us provide Talent Is Timeless there.
4.9. Business reorganization.
We may need to share your personal information with the relevant participants in transactions (or potential transactions) involving a corporate divestiture, merger, consolidation, acquisition, restructuring, reorganization, or sale or other disposition of some or all of the assets of, or equity interests in, Talent Is Timeless or our affiliates (including, in connection with a bankruptcy or similar proceedings).
4.10. Professional advisors.
We may share personal information with our professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
5. What are my choices?
You can choose the degree to which your personal information is shared in your personal profile and alongside your posts by using your account settings. You can modify these account settings at any time.
You can opt out of third-party personalised advertising by adjusting your cookie settings or changing the privacy settings on your mobile device. Our systems are not currently configured to accept browsers’ “Do Not Track” signals, as no industry-wide standard for handling them has been adopted.
See our jurisdiction-specific disclosures in Section 11 below for more information about legal rights you have if you live in a listed jurisdiction.
6. How long is my information kept?
We retain your information in our server logs, our databases, and our records for as long as necessary to provide the Services. We may need to retain some of your information for a longer period, such as in order to comply with our legal or regulatory obligations, to resolve disputes or defend against legal claims, or to enforce our Member Agreement.
7. How is my information protected?
7.1. Account security.
Talent Is Timeless uses technical and organizational measures intended to keep your data secure, including using https on our web pages to reduce the risk of unauthorised interception of your communications during your visits to the website and two-factor authentication where appropriate. However, the internet is not a fully secure environment and we cannot guarantee that your personal information won’t be intercepted or improperly accessed. Please ensure that you keep your password safe and do not share it with anyone.
7.2. Other services and websites.
When using Talent Is Timeless, you may come across links to websites and services operated by third parties that are not owned or controlled by Talent Is Timeless (for example, if a Member shares a link to a video on YouTube, or if an advertiser provides a link to a contest or sweepstakes). This Privacy Policy does not apply to information collected on any third-party site or application that may link to or be accessible from the Services. These third parties have their own privacy policies, which will apply to any personal information they collect. We do not accept any responsibility or liability for such external sites’ privacy and security practices.
8. Children
Children are not allowed to use the Services if they are under 13 years old or not old enough for Talent Is Timeless to process their personal information without parental or age-specific consent where they live. If you believe we might have collected personal information from a child in one of these categories, please contact us at [email protected], and if we learn that we have, we will delete their personal information.
9. Amendments to this Privacy Policy.
We may make changes to this Privacy Policy from time to time, so please review it periodically. If we materially change our Privacy Policy, we will take steps to notify you in advance of the change as required by applicable law, for example by emailing you or by posting a notice in your Community feed. If you object to any changes, you may close your account. You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Policy means that the collection, use, and sharing of your personal data is subject to the updated Privacy Policy, as of its effective date.
10. Contact us.
The Services are operated and provided to you by Talent Is Timeless Ltd., Royalty House, Soho Works, 72-74 Dean Street, London, W1D3SG. You may reach our Data Protection Officer at [email protected].
11. Jurisdiction-specific disclosures.
11.1. California.
If you are a California resident, this section applies to you. This section describes how we collect, use, and share your personal information in our capacity as a “business” under the California Consumer Privacy Act of 2018 (“CCPA”), and the rights that you have with respect to your personal information. For purposes of this section, “personal information” has the meaning given in the CCPA, but does not include information excluded from the CCPA’s scope.
11.1.1. Personal information we collect, use, and disclose.
The chart below summarises the personal information we collect by reference to the categories of personal information specified in the CCPA, and describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below. More information regarding the sources from which we collect personal information can be found in Section 2 above titled “What information is collected?”; business and commercial purposes for which we collect your personal information can be found in Section 3 above titled “How is my information used?”; categories of recipients with whom personal information is shared or sold can be found in Section 4 above titled “Is my information shared with third parties?”
Statutory category of Personal Information (PI) (Cal. Civ. Code § 1798.140) |
PI we collect in this category | Source of PI | Business/commercial purpose for collection | Categories of third parties to whom we “disclose” PI for a business purpose |
Identifiers (other than online identifiers) | Contact details | Network details | Data from other accounts | Posts, interests, location, and recommendations | Business information | Information from third parties and public sources | You | Third parties and public sources | Establishing and developing communities | Setting you up on Talent Is Timeless | Provide and improve the Services | Create and maintain a trusted environment | Advertising | Research and development | Public | Verification partners | Legal and safety-related third parties | Advertising partners | Third party partners | Talent Is Timeless corporate family | Business transferees | Professional advisors |
California Customer Records (as defined in California Civil Code section 1798.80) | Contact details | Network details | Data from other accounts | Posts, interests, location, and recommendations | Payment information | Business information | Information from third parties and public sources | You | Third parties and public sources | Establishing and developing communities | Setting you up on Talent Is Timeless | Provide and improve the Services | Create and maintain a trusted environment | Advertising | Research and development | Public | Verification partners | Legal and safety-related third parties | Advertising partners | Third party partners | Talent Is Timeless corporate family | Business transferees | Professional advisors |
Commercial Information | Contact details | Network details | Posts, interests, location, and recommendations | Payment information | Survey data | Contests, sweepstakes, and prize drawings data | Messages and email data | Business information | Online activity data | Information from third parties and public sources | You | Your browser and device | Third parties and public sources | Establishing and developing communities | Setting you up on Talent Is Timeless | Provide and improve the Services Provide and improve the Services | Create and maintain a trusted environment | Advertising | Research and development | Public | Verification partners | Legal and safety-related third parties | Advertising partners | Third party partners | Talent Is Timeless corporate family | Business transferees | Professional advisors |
Financial Information | Payment information | You | Provide and improve the Services | Create and maintain a trusted environment | Research and development | Legal and safety-related third parties | Third party partners | Talent Is Timeless corporate family | Business transferees | Professional advisors |
Online Identifiers | Messages and email data | Contact lists | Geolocation | Device data | Online activity data | Information from third parties and public sources | You | Your browser and device | Third parties and public sources | Establishing and developing communities | Setting you up on Talent Is Timeless | Provide and improve the Services | Create and maintain a trusted environment | Advertising | Research and development | Verification partners | Legal and safety-related third parties | Advertising partners | Third party partners | Talent Is Timeless corporate family | Business transferees | Professional advisors |
Internet or Network Information | Messages and email data | Device data | Online activity data | You | Your browser and device | Third parties and public sources | Establishing and developing communities | Setting you up on Talent Is Timeless | Provide and improve the Services | Create and maintain a trusted environment | Advertising | Research and development | Legal and safety-related third parties | Advertising partners | Third party partners | Talent Is Timeless corporate family | Business transferees | Professional advisors |
Geolocation Data | Geolocation | Device data | You | Your browser and device | Establishing and developing communities | Setting you up on Talent Is Timeless | Provide and improve the Services | Create and maintain a trusted environment | Advertising | Research and development | Legal and safety-related third parties | Advertising partners | Talent Is Timeless corporate family | Business transferees | Professional advisors |
11.1.2. What are my rights?
The following rights are not absolute and are subject to exceptions, and we may be required or permitted by law to decline your request. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
11.1.2.1. Access Categories of Information.
You may request the following information about how we have collected and used your personal information during the past 12 months:
● the categories of personal information we have collected about you;
● the categories of sources from which we collected the personal information;
● the business or commercial purpose for collecting or selling the personal information;
● the categories of third parties with whom we share the personal information;
● the categories of personal information that we sold or disclosed for a business purpose; and
● the categories of third parties to whom the personal information was sold or disclosed for a business purpose.
You may make this request by submitting a request via email to [email protected].
11.1.2.2. Access.
You can see much of your personal information by logging into your Talent Is Timeless account.
You may request a copy of the personal information we have collected about you during the past 12 months by submitting a request via email to [email protected].
11.1.2.3.
11.1.2.4. Deletion.
You can remove most content you have posted to Talent Is Timeless by logging into your Talent Is Timeless account.
You may request that we delete personal information we have collected from you by contacting us if you have an account. You may also submit a request via email to [email protected]
11.1.2.5. Opt-out of sales.
We are not intending to sell member data so there is nothing to opt out of.
11.1.2.6. Nondiscrimination.
You are entitled to exercise your rights described above free from discrimination as prohibited by the CCPA.
11.1.3. Requests by authorised agents.
Your authorised agent may make a request for information, access, and deletion on your behalf upon our verification of the agent’s identity and our receipt of a copy of valid power of attorney given to your authorised agent pursuant to California Probate Code Sections 4000-4465. If you have not provided your agent with such a power of attorney, you must provide your agent signed permission to exercise your CCPA rights on your behalf, provide the information we request to verify your identity, and provide us with written confirmation that you have given the authorised agent permission to submit the request. Authorised agents are required by California law to implement and maintain reasonable security procedures and practices to protect their clients’ information.
11.1.4. Verifying requests for information, access, and deletion.
We will need to verify your identity to process your information, access and deletion requests and reserve the right to confirm your California residency.
If you are a Member, you can verify your identity by submitting your request while logged into your Talent Is Timeless account.
If you are a Visitor or a Member who is unable to log in to your account, we may verify your identity by requiring you to provide government identification, give a declaration as to your identity under penalty of perjury, reply to a text message sent to the phone number we have in our records, and/or provide additional information.
11.1.5. Shine the light.
Under California’s Shine the Light law (California Civil Code Section 1798.83), California residents may ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes and the categories of personal information disclosed. You may send us requests for this information to Talent Is Timeless, Royalty House, Soho Works, 72-74 Dean Street, London, W1D3SG, UK. In your request, you must include the statement “Shine the Light Request,” and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, email, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.
11.2. Australia, Canada, UK, and Europe.
If you live in the UK or Europe, this section applies to you. If you live in Australia or Canada, you may have some of the following rights under applicable law.
11.2.1. On what legal basis do you collect my information?
To the extent required by applicable law, we will collect your personal information with your consent where required and in accordance with our legitimate need to provide you our Services.
Under EU law, Talent Is Timeless is required to rely on one or more legal bases to collect, use, share, and otherwise process the information we have about you. We describe these legal bases and some accompanying examples in more detail below.
● Performing the Member Agreement
Talent Is Timeless processes your information as is necessary to perform our contract with you, the Member Agreement. For example:
– we use your information in order to create your account and set you up as a Member on Talent Is Timeless;
– we transfer your information outside of the EU to the U.S., such as to Talent Is Timeless, Inc., in order to provide the Services.
● Your Consent
Talent Is Timeless processes certain information based on your consent, which you may revoke at any time. For example:
– we and our partners use cookies and similar technologies, as described in more detail in our Cookie Policy, based on your consent;
– where you choose a method of verification to confirm your address, we do so in accordance with your consent;
– if you decide to use location services in the context of Talent Is Timeless, we collect and process such location information based on your consent;
– we rely on your consent to tailor ads based on off-Talent Is Timeless actions and information, including based your activity on other websites and partner data, such as inferred interests;
– we will send you marketing communications where you have consented to receiving such communications in accordance with applicable law;
– where you ask us to notify you when Talent Is Timeless is available in your area, we do so based on your consent.
● Legal Obligation
Talent Is Timeless may process your information in order to comply with a legal obligation, a court order, or to exercise and defend legal claims. For example:
– we may preserve and disclose your information if it is necessary to respond, based on applicable law, to a valid legal request (e.g. a subpoena, search warrant, court order, or other binding request from government or law enforcement); and
– we may retain and process your information where it is necessary for compliance with applicable tax laws.
● Vital Interests
Talent Is Timeless might process your information in certain circumstances when it is necessary to protect your vital interests, or those of others. For example:
– we may need to process your information in order to protect your life or safety or the lives or safety of others, or otherwise prevent physical injury or other harm to any person, including you, other Members, Visitors, our staff, or the public;
– we may preserve or share your information with law enforcement and related authorities where we have a good faith belief that it is required in the context of an imminent threat;
– we may share your personal information with disaster relief agencies, first responders and other individuals to facilitate disaster or emergency response efforts.
● Legitimate Interests
We may process your information where it is necessary for the purposes of Talent Is Timeless’s or a third party’s legitimate interests, such as those of Visitors, Members or partners. In particular, we process your information in furtherance of the following legitimate interests:
– Keeping the Services safe and secure: We use your information because it is necessary to pursue our and our Members’ legitimate interests in ensuring Talent Is Timeless is secure, such as implementing and enhancing security measures and protections, protecting against fraud, spam and abuse, and enforcing our Member Agreement.
– Providing, improving, and developing the Services: We use your information to provide the Services, including any personalised services, and to understand and improve our business and our Member relationships. We do so as it is necessary to pursue our legitimate interests of providing an innovative and tailored offering to our Members on a sustained basis.
– Providing seamless Services across the Talent Is Timeless group of companies: Where the Services require the engagement of other Talent Is Timeless companies, we share your information with such affiliates to provide and improve the Services.
– Providing ads, and measurement and analytics services: We use your information to provide personalised ads both on and off Talent Is Timeless and to measure and analyze the success of those ads in order to provide accurate and reliable reporting to our advertisers. We do so as necessary to pursue our legitimate interests of marketing and monetizing our Services.
– Sending marketing communications: We rely on our legitimate interests in marketing and promoting our Services to use your contact information and send you marketing communications in accordance with applicable law, except where applicable law requires that we rely on your consent to send such communications.
– Sharing information for legal and safety reasons: Where required for legal and safety reasons, we may disclose information to law enforcement and related agencies and authorities in furtherance of the legitimate interests described further below.
As detailed in the Privacy Policy, where we process your information based on legitimate interests, you have the right to object to such processing. Where you exercise your right to object, we will cease processing your information for that specific purpose, unless there are compelling legitimate grounds overriding your objection or where your information is processed for legal reasons.
11.2.2. What are my rights?
You benefit from a number of rights in relation to your information that we process. While some of these rights apply generally, certain rights apply only in certain limited cases. We describe these rights below.
In certain cases, such as for access to, rectification or deletion of your information, please be sure to read the options you have under the “What are My Choices” section above.
11.2.3. Access.
If you are unable to obtain the desired information by logging into your Talent Is Timeless account, or if you are not currently a Talent Is Timeless Member, email us at [email protected] to request a copy of your Talent Is Timeless information. If requested and required to do so by applicable law, we will provide your information in an easily accessible format and assist in transferring some of this information to third parties as you request.
11.2.4. Rectify, restrict, delete.
You can access, rectify, and delete your Talent Is Timeless information by logging into your Talent Is Timeless account. If you cannot do this or you do not have a Talent Is Timeless account, please contact us and we will rectify, restrict, or delete your information if requested and if required to do so by applicable law.
11.2.5. Object.
If we process your information based on our legitimate interests explained above, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing (including if we are permitted to continue processing under applicable law) or where it is needed for legal reasons. Where we use your data for direct marketing, you can always object by using the unsubscribe link in such communications, changing your email account settings or, if you do not have an account, by contacting us.
11.2.6. Revoke consent.
Where consent is required for processing under applicable law, you may have the right to withdraw your consent to the processing of your information at any time. If you withdraw your consent to the use of your information for the purposes set out in this Privacy Policy, you may not have access to all (or any) of our Services and we might not be able to provide you all (or any) of the Services under this Privacy Policy and our Member Agreement. In certain cases, we may continue to process your information after you have withdrawn consent if we have a legal basis to do so, or if your withdrawal of consent was limited to certain processing activities.
11.2.7. Complaints.
If you have a UK or EU Member account and wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority or Talent Is Timeless’s lead supervisory authority, the Irish Data Protection Commission.
If you have an Australian or Canadian Member account, please contact us and provide us with as much detail as possible about your complaint. We take all privacy complaints seriously and will assess any complaint with the aim of resolving it in a timely and efficient manner. If you are not satisfied with the outcome of our assessment of your complaint, you may wish to contact the Office of the Australian Information Commissioner (for Australian Members) or the Office of the Privacy Commission of Canada (for Canadian Members).
11.3. Where is my information stored?
We transfer your personal information under these protections:
11.3.1. Standard contractual clauses.
We may use a legal mechanism known as “standard contractual clauses” to protect information transferred outside the EU and the UK. Standard contractual clauses refer to contracts between companies transferring personal information that contain standard commitments approved by the EU Commission protecting the privacy and security of the information transferred. To request a copy of the clauses, please email us at [email protected].
By continuing to use Talent Is Timeless, you understand that we may transfer and store your data outside your home country, including to and in the U.S., as described in this Privacy Policy. The privacy protections and the rights of authorities to access your personal information in some of these countries may not be the same as in your home country. Talent Is Timeless will only transfer personal data as permitted by law, and will take steps intended to ensure appropriate protection of your personal information. If you have questions, please contact us.