Welcome to DotX Talent’s privacy notice. DotX Talent is a limited company incorporated in England and Wales and is a ‘controller’ under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
1. Purpose of this privacy notice
DotX Talent values your privacy and is committed to protecting your personal information. Below, we explain how we collect and process all of your personal data, including any data you may provide through this website. Any personal information you provide us is safe and confidential: we store all of your information on a secure server and never share any of your personal details with anyone outside of DotX Talent for mailing or marketing purposes.
2. Whose data do we hold?
Our policy is based on EU data protection principles. We may hold data about the following:
- Visitors to our website
- People who use our services e.g. customer, clients or other subscribers to our services
- Job applicants and our current employees
- Suppliers and service providers
- Advisers, consultants and other professional experts
- General enquirers and complainants
This policy describes:
- What personal information we collect about you
- How we obtain your personal information
- How we use your personal information
- On what basis we use your personal information
- How long we keep your personal information
- Who we share your personal information with
- How we protect your personal information
- Where your personal information is transferred to
- Your rights regarding your personal information
3. What personal information may we collect about you?
We will only collect information from you that is relevant to the matter we are dealing with in the course of our business, including through your use of our website, when you contact or request information from us, when you engage our services, or as a result of your business relationship with one or more of our staff and clients. In each case, the purpose for which you are invited to provide us with information is clear.
The personal information that we process includes:
- Identity Data, such as your name (including name prefix or title), the company you work for, your title or position and your relationship to a person, date of birth and gender. This may also include details about your family, lifestyle and social circumstances.
- Contact Data, such as your billing address, postal address, email address and phone number(s).
- Financial Data, such as payment-related information.
- Technical Data, this includes information from your visits to our website or in relation to materials and communications we send to you electronically.
- Information you provide to us for the purposes of attending meetings and events, including access and dietary requirements.
- Identification and background information provided by you or collected as part of our business acceptance processes.
- Personal information provided to us by job applicants, our staff, advisors or on behalf of our clients (or generated by us in the course or providing services to them), which may include ‘special categories’ of data. Special categories of data relate to physical or mental health details, racial or ethnic origin, religious beliefs or other beliefs of a similar nature, criminal convictions and sexual orientation.
- Any other information relating to you which you may provide to us.
4. How do we obtain your personal information?
We collect information from and about you and others as part of our course of business and about you and others as necessary in the course of providing talent management services.
We collect your personal information while monitoring our services, including our websites and email communications sent to and from DotX Talent.
We gather information about you when you provide it to us or interact with us directly.
We may collect or receive information about you from other sources, such as keeping the contact details we already hold for you accurate and up to date using publicly available sources.
5. How will we use your personal information?
We collect and process personal information about you in a number of ways, including through your use of our website and in the provision of services by us. We use that information:
- To provide and improve our website, including auditing and monitoring its use.
- To provide and improve our services to you and to our clients, including advising and acting on behalf of clients and handling the personal information of others on behalf of our clients.
- To provide information requested by you.
- To promote our services, including sending updates, publications and details of events.
- To manage and administer our relationship with you and our clients.
- To fulfil our legal, regulatory and risk management obligations, including establishing, exercising or defending legal claims.
- For the purposes of recruitment.
- To provide education and training to customers, clients and staff.
- To maintain accounts and records.
- To support and manage staff.
Use of our website
- Invites you to provide us with personal information, such as making queries about us or our clients, and applying for vacancies. The purpose of these facilities is apparent at the point that you provide your personal information, and we only use that information for those purposes.
- May include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Marketing and other emails
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. If you receive marketing communications from us and no longer wish to do so, you may opt-out of future communications at any time by emailing us at firstname.lastname@example.org.
We may from time to time conduct targeted direct marketing where we believe we have a legitimate interest in doing so. In particular we believe we have a legitimate interest in the targeted promotion of our services to those who are likely to be interested in making use of them because they are a player, caster, or creator, operating in gaming and/or esports, who we reasonably believe is not professionally represented.
When we carry out direct marketing of this nature, we rely on a Legitimate Impact Assessment (LIA). The LIA is a considered assessment carried out by us of the impact of us processing data in this manner, and whether that impact overrides the legitimate interest we are relying upon. This LIA is revisited at least annually ensure that a fair balance still exists between the impact of us processing the data, and the legitimate interest in question.
For more information on the LIA contact the Managing Director.
Meetings, events and seminars
We collect and process personal information about you in relation to your attendance at our offices or at an event organised by DotX Talent. We will only process and use special categories of personal information about your dietary or access requirements in order to cater for your needs and to meet any other legal or regulatory obligations we may have. We may share your information with IT and other service providers or business partners involved in organising or hosting the relevant event.
Legal and other services
We collect, create, hold and use personal information in the course of and in connection with the services we provide to our clients. We have very strict rules about who we can share your information with and this will be limited to other people who will assist with your matter. We will process identification and background information as part of our business acceptance, finance, administration and marketing processes, including anti-money laundering, conflict, reputational and financial checks. We also process personal information provided to us by or on behalf of our clients for the purposes of the work we do for them. The information may be disclosed to third parties to the extent reasonably necessary in connection with that work. Third parties may include solicitors, barristers, medical experts, healthcare professionals, financial and tax advisors, and courts and tribunals.
Where you authorise us to do so, we may also disclose your information to your family, associates or representatives and we may also disclose your information to debt collection agencies if you do not pay our fees.
6. How long will we keep your personal information for?
Your personal information will be retained in accordance with the requirements of applicable data protection laws and the purpose for which the information is collected and used, taking into account legal and regulatory requirements to retain the information for a minimum period, limitation periods for taking legal action, good practice and DotX Talent’s business purposes.
We normally keep your information throughout the period of time that we do work for you and afterwards for a period of six years as we are required to do by law and also by the regulations that apply to us.
In some cases, we may retain your information for a longer period and to determine the appropriate retention period, we will consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
More information is set out in our Data Retention Policy which is available on request from our Managing Director.
7. Who will we share your personal information with?
DotX Talent operates internationally however we strive to keep your personal data within the European Economic Area (the “EEA”). In specific situations where a transfer of your personal data is needed outside of the EEA, we ensure a similar degree of protection is afforded to it by ensuring that where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. Normally this will be necessary for the performance of your contract with us.
We may also share your personal information with certain trusted third parties in accordance with contractual arrangements in place with them, including:
- Morgan Sports Law Limited for the purpose of carrying out invoicing and other business support services
- Our professional advisers and auditors
- Suppliers to whom we outsource certain support services such as translation
- IT service providers, including 247 IT Services
- Third parties engaged in the course of the services we provide to clients and with their prior consent
- Third parties involved in hosting or organising events
Where necessary, or for the reasons set out in this policy, personal information may also be shared with regulatory authorities, courts, tribunals, government agencies and law enforcement agencies. While it is unlikely, we may be required to disclose your information to comply with legal or regulatory requirements. We will use reasonable endeavours to notify you before we do this unless we are legally restricted from doing so.
If in the future, should we re-organise or transfer all or part of our business, we may need to transfer your information to new DotX Talent entities or to third parties through which the business of DotX Talent will be carried out.
We do not sell, rent or otherwise make personal information commercially available to any third party, except with your prior permission.
Please contact our Managing Director should you need further information.
8. How do we protect your personal information?
We use a variety of technical and organisational measures to help protect your personal information from unauthorised access, use, disclosure, alteration or destruction consistent with applicable data protection laws. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Should we suspect personal data breach, we have in place procedures to ensure that the effects of such a breach are minimised and shall liaise with the ICO and with you as appropriate.
More information is available from our Managing Director.
Which countries we transfer your personal information to
In order to provide our services we may need to transfer your personal information to locations outside the jurisdiction in which you provide it. This may entail a transfer of your information from a location within EEA to outside the EEA, or from outside the EEA to a location within the EEA. Where this is the case, we will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection laws. Where our third party service providers process personal data outside the EEA in the course of providing services to us, our written agreement with them will include appropriate measures, usually standard contractual clauses.
9. Your rights regarding your personal information
The UK GDPR and other applicable data protection laws provide certain rights for data subjects.
You have the following rights under the UK GDPR:
- Right to request access to your personal data
- Right to request correction of your personal data
- Right to request erasure of your personal data
- Right to object to the processing of your personal data
- Right to request restriction of the processing of your personal data
- Right to request the transfer of your personal data
- Right to withdraw your consent.
Right of access
You are entitled to request details of the information we hold about you and how we process it. To access this you need to provide a request in writing to our Managing Director, together with proof of identity. Please contact our Managing Director for our Data Subject Access Request Form.
We will usually process your request free of charge and within 30 days however we reserve the right to charge a reasonable administration fee and to extend the period of time by a further two months if the request is manifestly unfounded or vexatious and/or is very complex.
Full details are available in our Data Subject Access Policy which is available upon request from our Managing Director.
Right of erasure
You may also have a right in accordance with applicable data protection law to ask us to have your data rectified or deleted, to restrict our processing of that information, to stop unauthorised transfers of your personal information to a third party and, in some circumstances, to have personal information relating to you transferred to another organisation.
We will deal with your request free of charge and within 30 days but reserve the right to refuse to erase information that we are required to retain by law or regulation, or that is required to exercise or defend legal claims.
To exercise your right to erasure please contact our Managing Director.
Who can you complain to?
If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.
Your objection (or withdrawal of any previously given consent) could mean that we are unable to perform the actions necessary to achieve the purposes set out above or that you may not be able to make use of the services offered by us. Please note that even after you have chosen to withdraw your consent we may be able to continue to process your personal information to the extent required or otherwise permitted by law, in particular in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
If your complaint remains unresolved then you can contact the Information Commissioner’s Office, details available at www.ico.org.uk.
We must ensure that your personal information is accurate and up to date. Therefore, please advise us of any changes to your information by emailing at email@example.com.
Name: Nick Williams
Email address: firstname.lastname@example.org