Privacy policy

PRIVACY NOTICE

This Notice sets out how the Insanity Group ('we'/'us'/'our') will collect, use, share and measures we take to protect personal information relating to you. It also explains how you can contact us and control the way we use your data.

Our website is not intended for children and we do not knowingly collect data relating to children, unless we represent them pursuant to a management, agency or recording contract.

It is important that you read this policy together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This policy supplements the other notices and is not intended to override them.

Table of Contents

1. WHO WE ARE AND HOW TO CONTACT US
2. WHAT INFORMATION WE COLLECT
3. HOW WE USE YOUR INFORMATION
4. WHAT LAWFUL BASES WE RELY ON TO PROCESS YOUR DATA
5. HOW WE PROTECT SHARE YOUR INFORMATION
6. INTERNATIONAL DATA TRANSFERS
7. YOUR DATA PROTECTION RIGHTS
8. RETENTION
9. CHANGES

1. WHO WE ARE AND HOW TO CONTACT US

The Insanity Group is made up of different legal entities:

1. Insanity Group Limited (registered number: 9712931)
2. Insanity Talent Management Limited (registered number: 6288733)
3. Annex97 Limited (registered number: 8006559)
4. **ITM Live Limited (registered number: 09907715) (Insanity Studios is a trading style of ITM Live Limited)
5. Insanity Records Limited (registered number: 9597152)
6. Insanity Publishing Limited (registered number: 9597226)
7. Insanity Group LLC (registered in California, USA. State File No. 201805710172

All of our UK companies are registered in England & Wales and have their registered office at 27 Mortimer Street, London, W1T 3BL.

We are the data controller of your personal data. This means that we decide when, why and how to process your personal data and we are responsible for looking after it and protecting your rights. If you have questions about this Notice or our privacy practices or need help exercising your data protection rights, please contact us at [email protected].

2. WHAT INFORMATION WE COLLECT

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Personal Details may include first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data may include address, email address, social media details and telephone numbers.
• Financial Data may include bank details and other financial information such as information relating to invoices or other payments and income.

• Tax Data may include information about your VAT number, NI number and any other relevant tax information.

• Special Category Data may include information about your dietary requirements, health data, information about your race, ethnicity, and sexual orientation, etc. We will collect and process this data in limited circumstances only and based on your explicit consent.

• Client Data covers the personal data about our clients which may be provided to us by our clients in the course of the provision of our services which may include their photographs, videos and biography/work experience, etc.
• Usage Data may include information about how you interact with our website.
• Technical Data may include internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
• Marketing and Communications Data may include your preferences in receiving marketing from us – such as newsletters – and your communication preferences.

Use of non-personal data

We may also share non-personal information in an aggregated and anonymised form that cannot reasonably be used to identify you, but which displays some general trends (eg, demographic or statistical data). This may be disclosed publicly or to third parties.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel service you have with us, but we will notify you if this is the case at the time.

3. HOW WE USE YOUR INFORMATION

We use your information for the following purposes:

• To provide you with our services

Using the information we collect about you, we are able to deliver our services and perform our contract with you. For example, we need your Personal Details, Contact Data, Tax and Financial Data to register you as our new client and make payments to you. Depending on the circumstances, we may also need to collect and process other information about you (Client Data) to perform our contract with you (eg, we may process your photograph, video clip and biography to create and publish your portfolio on our website in order to showcase your work for potential contractors).

• To accommodate to your needs and make arrangements on your behalf

Where you have given us explicit consent, we may use information about you including your Special Category Data (such as allergies and dietary requirements) to make sure that your needs are accommodated for at various events or on trips. Similarly, we may share your contact details and other information with third parties to make other arrangements (eg, the delivery of gifts).

• Improve and personalise our services

Using the information we collect about you, we are able to improve and personalise our service and implement updates to our Website to provide a better user experience. For example, we may use this data to identify and remove any technical errors, develop new features, etc. We may also use this information for troubleshooting, data analysis, testing, research, statistical and survey purposes.

• Communicate with you

Where appropriate, we may use your Contact Data to send you notifications (for example, about any changes to this Notice) and to respond to you when you contact us.

• To send you marketing communications

If you are an existing client, we may use Contact Data that you shared with us to send you marketing communications about similar services where this is permitted by applicable law (unless you have opted out).

In other cases, we ask for your consent to use your contact details to send you personalised marketing communications, including newsletters.

• To keep our services safe and secure and to protect our or others' rights, property or safety

We may also collect and process personal data to prevent, detect or investigate abuse, illegal use, fraud, violations of our Terms & Conditions and to comply with applicable law, court orders or governmental requests.

• General research and analysis

We use data about how users use our Website to understand user behaviour and preferences.

4. WHAT LAWFUL BASES WE RELY ON TO PROCESS YOUR DATA

To process your personal data, we rely on various lawful bases depending on your interaction with our Website and our relationship with you.

• We generally rely on a contract to process your personal data.
• In limited circumstances, we may also ask for your consent, which will be clearly communicated to you. For example, we will obtain your prior written consent to process information about your health/dietary requirements.
• We also rely on other lawful bases such as legitimate interests. These may include, for example, improving, personalising and developing our services and products; protecting our or others' rights, property and safety as well as for the purposes of testing, general research, survey and analysis. When relying on legitimate interests, we take measures to make sure that our interests are balanced against your interests, rights and freedoms. If requested, we are happy to explain how we do this.
• We may also process your personal data to comply with a legal obligation or to protect vital interests.

5. HOW WE PROTECT SHARE YOUR INFORMATION

Security

We work hard to make sure that your data is safe with us. We use different technical and organisational measures, including encryption and multi-factor authentication, to ensure that your information is secure. 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.

However, please be aware that no method of storing or transferring data is completely secure. If you have concerns related to security, please contact us using the contact details above.

Sharing your information

We do not sell information about our clients and share it only in strictly defined circumstances as described below:

• If you consent or instruct us so

You may instruct us to share your personal data with a third party (for example, by giving us your consent to transfer information about your allergies/dietary requirements to event/trip organisers). Please remember that, in this case, how your information will be used will be governed by the terms & conditions and privacy notices of these third parties.

• To perform a contract with you

As part of your contract between you and us, we may share your personal information with various individuals and third-party organisations such as brands, PR agencies and production companies to secure engagements for you.

• To identify and offer interesting opportunities

We will share your personal information within the Insanity Group to identify and offer various opportunities that we may think will be relevant to or interesting for you.

• To use third-party suppliers, service providers and other processors

We will share your information with our suppliers, service providers and other partners who process it for us and according to our instructions, in line with this Notice and appropriate confidentiality and security measures. The above third parties may include providers of services relating to information technology, payments, data analysis, etc.

• For legal reasons or to prevent harm

We may keep or share information about you to comply with a law, regulation, legal process, or governmental request; to assert legal rights or defend against legal claims; or to prevent, detect, or investigate illegal activity, fraud, abuse, violations of our contract with you, or threats to the security of our services or the physical safety of any person. In this case, we will notify you unless we are prohibited by law from doing so. In particular, we may share your information with regulators, courts, government agencies, competent law enforcement bodies or other third parties (including insurers and legal advisers) where we believe disclosure is necessary: (1) to comply with a government request, a court order or applicable law or to assist in investigations; (2) to prevent illegal uses of our website or violations of our contract with you and this Notice; (3) to detect, prevent or otherwise address security, fraud or technical issues; (4) to exercise, establish or defend our legal rights (including to collect amounts owed to us); (5) to protect your rights or vital interests or those of any other person.

Other disclosures

We may share your personal information in the context of any actual or proposed merger, acquisition or reorganisation, sale of company assets, insolvency, or any other similar process in which case we will put in place contractual measures to make sure that the recipient's use of such data is in line with this Notice and limited to what is necessary for the relevant purpose.

Links to third-party websites

Our website 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.

6. INTERNATIONAL DATA TRANSFERS

We have put in place appropriate access controls to make sure that, when sharing your personal data within the Insanity Group, your personal data are not transferred outside the UK.

Many of our third-party service providers are based within the European Economic Area (EEA), so their processing of your personal data will not involve a transfer of data outside the EEA.

However, there may be circumstances where our processing may involve a transfer of your personal information to countries outside the EEA (such as the US). In these cases, we will take a variety of measures to ensure that transfers take place in line with this Notice and the applicable law. For example, to make sure that your information receives a similar degree of protection according to data protection rules, these measures will include the use of various instruments such as the International Data Transfer Agreement and the Addendum approved by Information Commissioner's Office

7. YOUR DATA PROTECTION RIGHTS

You have several rights under the data protection law. However, please remember that these rights are not absolute.

Access your data

You can request access to your personal data that we hold about you. This is usually provided free except for in very limited circumstances. We will advise you if you need to pay a fee when we receive your request.

If you wish to receive a copy of the information that we hold about you, please submit a request at the contact details above. We will respond to your request within one month unless the request is unusually complex and is likely to take longer, in which case we will advise you how long it is likely to take us.

Please be aware that, whilst in most cases we would be happy to provide you with a copy of the personal information that we hold about you, we nonetheless reserve the right to refuse your request if one of the conditions under the law apply.

Request a transfer of your personal information (data portability)

You can ask us to transfer your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information to the use of which you initially consented or where we processed this information to perform a contract with you.

Request correction

If you think any of your personal data is incomplete or inaccurate, you can request us to correct it. However, we may need to verify the accuracy of the new information you provide to us.

Object to processing of personal data

You can object to processing of your personal information where we're relying on our legitimate interests (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms.

You also have the right to object where we're processing your personal information for direct marketing purposes.

In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing

You can request us to restrict the processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following situations:

• if you want us to establish the information's accuracy;
• where our use of the information is unlawful but you do not want us to erase it;
• where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or
• you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.

Request deletion

This enables you to ask us to delete or remove personal information where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see above), where we may have processed your information unlawfully or where we're required to erase your personal information to comply with the law. Note, however, that we may not always be able to comply with your request for erasure in some circumstances (which will be notified to you, if applicable, at the time of your request).

Withdraw consent

If we have collected your personal information based on consent, you have the right to withdraw it at any time. This will not affect the lawfulness of any processing carried out before withdrawing your consent.

If you choose to withdraw your consent, we will no longer process your information for the purpose(s) you agreed to unless we have another lawful basis for doing so. We will advise you if this is the case at the time you withdraw your consent.

Make a complaint

You have the right to make a complaint at any time to the ICO, the UK supervisory authority for data protection issues (ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO.

Change your marketing communications preferences

You can opt out of receiving marketing communications form us by:

• clicking on the unsubscribe link/following the opt-out instructions included in the email that we sent to you; or
• sending an email to us at [email protected].

If you opt out of receiving emails from Us at any time, it may take up to 10 business days for us to comply with your request. During that time, you may continue to receive emails from us.

Further information

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information 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.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

8. RETENTION

Your personal information will be retained for as long as is necessary to carry out the purposes set out in this Notice (unless the law requires us to store it longer). For example, by law we have to keep basic information about our clients (including Contact Data, Personal Details, Financial Data and Tax Data) for six years after they cease being customers for tax purposes.

We will also keep your information for as long as necessary to fulfil our contract with you or for our legitimate interests, legal reasons or to prevent harm.

Insanity Group manages catalogue rights, intellectual property portfolios and other rights which make is necessary to retain data for longer than 6 years.

9. CHANGES

We may need to update our Notice from time to time. Any changes we make to our Notice in the future will be posted on this page.

To obtain the revision history of this Notice, please contact us at [email protected].