Online Privacy Policy

Performing Innovations Ltd (“Performeo”, “we”, “us” or “our”) understands that your privacy is important to you and that you care about how your Personal Data is used. We respect your privacy and are committed to protecting your Personal Data. We are a ‘controller’ for the activities covered by this Privacy Policy.

We do not use, and do not authorise our subcontractors to use, your Personal Data to train generative AI models or systems designed to produce original content (such as text, images, videos, voice or your likeness).

What does this Privacy PolicyCover?

This Privacy Policy applies to our collection, use and sharing of your Personal Data when:

  • making available our websites that link to this Privacy Policy (“Website”),
  • providing you with access to our platform to connect actors, talent agents, casting directors, job creators, production studios (“Platform”),
  • collecting information about actors, talent agents and casting directors from other sources, such as publicly available information, to display it within the Platform, and
  • carrying out associated marketing activities, promotions and referral schemes and any other activities described in this Privacy Policy.

For reference, when we refer to “Personal Data”, we mean any information which identifies you as an individual or which otherwise renders you identifiable. When we use the term “GDPR”, we are referring to the UK General Data Protection Regulation.

What doesn’t this Privacy Policy cover?

This Privacy Policy does not cover our use of your Personal Data on behalf of talent agents, casting directors or our other business customers through their use of the Platform where we act as their ‘processor’.

Any processing we carry out as processors is governed by our ‘Data Processing Addendum’ or other similar agreements, addenda or terms agreed with such business customers.

If you have any questions about any of our business customer’s use of your Personal Data when they use our Platform, you can either review their own privacy policy(ies) and/or you can contact them directly.

What Personal Data we collect?

Sources of Personal Data. We may collect your Personal Data from different sources including:

  • Directly from or about you when you use the Website and/or the Platform, including:
    • Information you provide via or through your use of the Website or the Platform.
    • Information about you, your computer or mobile device, and your interaction over time with us or that we collect automatically. For more details on this type of data collection, you can visit our Cookie Policy for further details.
  • From certain third-party sources, including:
    • Agents and other users of the Platform – for example, if you are an actor represented by an agent, the agent may provide information about you to us.
    • Producers – for example, if you are an actor on a shortlist for a role, a producer may share comments or feedback about you.
    • Industry organisations – organisations that publish member lists of actors and talent, casting directors, agents and producers (such as talent agencies and creative industry unions). This information is publicly available.
    • Data providers – third-party data sources that we partner with and integrate into the Platform.
    • Other public sources – websites, social media platforms and other publicly available sources.
    • Partners – such as our marketing partners, organisations with whom we run promotions, and event co-sponsors.
    • Service providers – organisations that provide services on our behalf or help us operate the Platform or our business.

Categories of Personal Data. The Personal Data we may collect from or about you is outlined in the table below.

Category of Personal Data

What this means

Contact Data

Your name, email and telephone

Profile Data

Your role (such as an actor, talent agent or casting director) and professional experience

If you are a user of the Platform, your username and password, any information you import from your CV, and any other account information that you provide to us when using the Platform, including your name, contact details, photo, professional and education experience, skills and interests

Content Data

Content and materials that you upload, create, or use on the Platform (e.g. applications, calendar appointments, scripts and workflows that you create, NDAs and other contracts)

Communications Data

Messages that you send and receive on the Platform, including their content, information you exchange with us (e.g. when contacting us for support), your feedback and your communication preferences

Payment Data

If you are a talent agent or a casting director using the Platform, our payment processor Stripe will process your payment information. This may include your payment details, billing address and transaction history

Technical Data

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 when accessing the Website and/or Platform

Analytics Data

Statistical demographic or event-based analytics based on your use of the Website and the Platform collected through use of cookies (visit our Cookie Policy for further details)

Sensitive information. We may also collect sensitive types of Personal Data (e.g., health-related information, information related to racial or ethnic origin or membership with Equity or other trade union) as a part of your Profile Data. Where we do so, we will ask for your explicit consent unless applicable law allows us to process the Personal Data otherwise. You may also incidentally include sensitive information in your Communications Data. However, you are fully responsible for the information you include in your Communications Data.

No obligation to provide Personal Data. You do not have to provide Personal Data to us. However, where we need to process your Personal Data either to comply with applicable law or to deliver our Website or the Platform, and you fail to provide that Personal Data when requested, we may not be able to provide some or all parts of our Website and/or the Platform. We will notify you if this is the case at the time.

How we use your Personal Data andwhy?

We use yourPersonal Data for the purposes listed below and any associated sharing ofPersonal Data.

In respect of each of the purposes forwhich we use your Personal Data, the GDPR requires us to establish a legalbasis for that use. Our legal bases for processing your Personal Data describedin this Privacy Policy are listed below.

  • Where we need to perform a contract we have entered into with you or are about to enter into with you (“Contractual Necessity”)
  • Where it is necessary for our pursuit of legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”)
  • Where we need to comply with a legal or regulatory obligation (“Compliance with Law”)
  • Where we have your specific consent to carry out the processing for the purpose in question (“Consent”)

Purpose

Categories of Personal Data

Legal Basis

To provide, operate and secure the Website

  • Technical Data
  • Analytics Data

Legitimate Interests. We have a legitimate interest in ensuring the ongoing security and proper operation of our Website, our business and associated IT services, systems and networks.

To develop and improve the Platform, including by:

  • conducting research and populating our Platform with information about actors, talent agents and casting directors, and
  • analysing your usage and helping us understand user activity.

We do not use, and do not authorise any of our subcontractors to use, your Personal Data to train generative AI models or systems designed to produce original content (such as text, images, videos, voice or your likeness).

  • Technical Data
  • Analytics Data

Legitimate Interests. We have legitimate interests in developing and improving our Platform and enhance its productivity, reliability, quality and security.

To provide the Platform to users, including by:

  • facilitating interactions between actors, talent agents and casting directors,
  • analysing data provided to us and matching actors with available roles and other opportunities (including recommending roles you might want to audition for),
  • facilitating payments through our payment processor if you are a talent agent or a casting director,
  • communicating with you regarding roles and applications, and
  • providing associated support.
  • Contact Data
  • Profile Data
  • Content Data
  • Communications Data
  • Payment Data

Legitimate Interests. We have legitimate interest in providing the Platform to our users including actors, agents and casting directors, and delivering associated services.

Contractual Necessity. We also rely on Contractual Necessity for processing these categories of Personal Data.

To administer, operate and improve our business

  • Contact Data
  • Profile Data
  • Content Data
  • Communications Data
  • Technical Data
  • Analytics Data

Legitimate Interests. We have a legitimate interest in administering and operating our business (including associated analysis, adaptation and improvement).

To communicate with you, for example, if you have a question or if we send updates or announcements relating to the Platform, and to handle any issues that may arise from such communications

  • Contact Data
  • Communications Data

Legitimate Interests. We have a legitimate interest in communicating with you and dealing with your contacts with us, as well as handling any issues that may arise from such contacts.

To communicate with you for marketing purposes

  • Contact Data
  • Communications Data

Legitimate Interests. We have a legitimate interest in promoting our business and sending marketing.

Consent. Applicable in circumstances or in jurisdictions where consent is required under applicable data protection laws for sending of any given marketing communications.

To administer events, promotions, and contests, communicate with you about events, promotions, and contests in which you participate, and/or contact you after collecting your Personal Data at an event

  • Contact Data
  • Communications Data

Contractual Necessity to administer the events, promotions, and contests in accordance with the terms or rules thereof (including communicating with you as and where necessary).

In respect of promoting these events, promotions, and contests:

  • Legitimate Interests. We have a legitimate interest in promoting these activities, including associated publicizing of our business and operations.
  • Consent. In circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given promotional communications.

To comply with applicable laws, lawful requests, and legal process (such as to respond to disclosure orders or similar, as well as investigations or requests from government authorities)

Any and all data types relevant in the circumstances

Compliance with Law.

To protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); to audit our internal processes for compliance with legal and contractual requirements or our internal policies; to enforce the terms of agreements that govern access to the Website and/or the Platform; and to prevent, identify, investigate and deter fraudulent, harmful, unauthorised, unethical or illegal activity, including cyberattacks and identity theft

Any and all data types relevant in the circumstances

Legitimate Interests. We and any relevant third parties have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We and any relevant third parties may also have a legitimate interest of ensuring the protection, maintenance, and enforcement of our and their rights, property, and/or safety.

To facilitate or carry out any corporate events (including providing Personal Data to allow third parties to investigate – and, where relevant, to continue to operate – all or relevant part(s) of our operations)

Any and all data types relevant in the circumstances

Legitimate Interests. We and any relevant third parties have a legitimate interest in us providing information to certain third parties who are involved in or assisting with actual or prospective corporate event for these purposes.

Further uses beyond those described above, but we only do this with your consent or whether those further purposes are compatible with the initial purpose for which Personal Data was collected

Any and all data types relevant in the circumstances

The original legal basis, for ‘compatible further uses’.

Consent. Applicable for ‘non-compatible further uses’.

Who we share your Personal Data with?

We may share your Personal Data with the following categories of recipients and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.

  • Affiliates. Our subsidiaries and affiliates (from time to time).
  • Other Platform users. Users of the Platform (such as agents and casting directors, if you are an actor using the Platform).
  • Linked third-party services. Third parties that you use to connect in the Platform.
  • Service providers. Third parties that provide services on our behalf or help us operate parts of the Website and/or the Platform (such as our hosting providers, information technology/security providers, providers of large language models, customer support, email delivery, marketing providers, or payment processors).  We do not use, and do not authorise our service providers to use, your Personal Data to train generative AI models or systems designed to produce original content (such as text, images, videos, voice or your likeness).
  • Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
  • Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate in the circumstances.
  • Parties to corporate events. We may disclose Personal Data in the context of actual or prospective corporate events (e.g., investments in Performeo, financing of Performeo, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain Personal Data with prospective counterparties and their advisers. We may also disclose your Personal Data to an acquirer, successor, or assignee of Performeo as part of any acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which Personal Data is transferred to one or more third parties as one of our business assets.

Transfers outside the UK

We may share your Personal Data with third parties who are based outside the UK, including in the United States.

Where we share your Personal Data with third parties who are based outside the UK, we try to ensure a similar degree of protection is afforded to it by implementing one of the following mechanisms:

  • Transfers to territories with an adequacy decision. We may transfer your Personal Data to countries or territories whose laws have been deemed to provide an adequate level of protection for Personal Data by the UK Government (from time to time) (e.g., the European Union) or under specific adequacy frameworks approved by the UK Government (from time to time), such as the UK Extension to the EU-U.S. Data Privacy Framework.
  • Transfers to territories without an adequacy decision. We may transfer your Personal Data to countries or territories that are not considered to provide such an adequate level of protection. However, in these cases:
    • we may use specific appropriate safeguards, which are designed to give Personal Data effectively the same protection it has in the UK – for example, standard-form contracts approved by relevant authorities for this purpose, or
    • in limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your Personal Data to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.

You may contact us using the details below if you want further information on the specific mechanism used by us when transferring your Personal Data outside of the UK.

Security

We employ technical, organisational and physical safeguards designed to protect your Personal Data (including to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed). For example, we limit access to your Personal Data to only those employees and other staff who have a business need to have such access. All such people are subject to a duty of confidentiality.

In addition, we have put in place procedures to deal with potential personal data breaches affecting your Personal Data. In the event of any such breach, we have systems in place to notify and work with applicable regulators where required. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of more serious personal data breaches affecting your Personal Data.

Please note that despite the efforts described above, as our Website and Platform are hosted electronically, we can make no guarantees as to the security or privacy of your information.

Data retention

We are committed to only keeping your Personal Data for so long as we reasonably need to use it for the purposes set out above. This general rule applies unless a longer retention period is required by law.

To determine the appropriate retention period for Personal Data, we 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.

When we no longer require the Personal Data that we have collected about you, we will either delete or anonymise it or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.

Your rights

What are your rights?

The GDPR may give you certain rights regarding your Personal Data and how we process it in certain circumstances, meaning you may ask us to take the following actions in relation to your Personal Data:

  • Access. Provide you with information about our processing of your Personal Data and give you access to your Personal Data. This right always applies.
  • Correct. Update or correct inaccuracies in your Personal Data. This right always applies.
  • Delete. Delete your Personal Data where there is no good reason for us continuing to process it - you also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
  • Transfer. Transfer to you or a third party of your choice a machine-readable copy of your Personal Data which you have provided to us where we rely on Contractual Necessity or your Consent.
  • Restrict. Restrict the processing of your Personal Data, for example if you want us to establish its accuracy or the reason for processing it.
  • Object. Object to our processing of your Personal Data where we are relying on Legitimate Interests or where we are processing your Personal Data for direct marketing purposes.
  • Withdraw Consent. When we use your Personal Data based on your Consent, you have the right to withdraw that consent at any time.

Exercising your rights

To exercise any of the rights described above, please contact us using the contact details shown below.

We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfil any request you make will depend on a number of factors (e.g., why and how we are processing your Personal Data), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions. Typically, you will not have to pay a fee to exercise your rights; however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

Timing

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

Complaints

If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your Personal Data, please contact us using the contact details shown below.

If you feel that we have not addressed your complaint adequately, you have a right to complain directly to the UK Information Commissioner’s Office: https://ico.org.uk/make-a-complaint/

Contact details

You can email us at privacy@performeo.com.

Our registered address is: 71-75 Shelton Street, London, England, WC2H 9JQ.

Updates

Any changes to this Privacy Policy will be made available here (or another page we notify to you at a later date) and where applicable we might also notify you via email and/or on our Website.