This privacy notice sets out the ways in which we, Michelle Kass Associates Ltd. collect and use your personal data (your personal information). It also explains what rights you have to access or change your personal data.
Our website is not intended for children. We do not knowingly collect or maintain the personal information of children under the age of 13. If you are under the age of 13, please do not access our website at any time or in any manner. We will take appropriate steps to delete the personal information of persons under the age of 13.
1) ABOUT US
We are a company registered in England under company number 07205508 with our registered address as set out below.
You can contact us as follows:
FAO: Michelle Kass Associates Ltd
Address: 85 Charing Cross Road, London, WC2H 0AA, UK
2) INFORMATION WE MAY COLLECT ABOUT YOU
Information that you provide to us.
We will collect any information that you provide to us when you:
- make an enquiry over the phone, by email, in writing or on our website;
- submit manuscripts or other content to us by post, email or via our website;
- submit an application to a job vacancy;
- follow’, ‘like’, post to or interact with our social media accounts, including Tumblr.
The information you provide to us will include (depending on the circumstances):
- Identity and contact data: Title, names, addresses, email addresses and phone numbers;
- Financial and contract data: If we represent you, you may also provide us with your bank details, VAT and tax information, immigration and residency information, your existing contracts (and related correspondence) with publishers or other licensees of your work;
- Employment and background data: If you are submitting a creative work for review or a job application, you may also provide additional information about your academic and work history, qualifications, skills, projects and research that you are involved in, references, proof of your entitlement to work in the UK, your national security number, your passport or other identity document details, your current level of remuneration (including benefits), and any other such similar information that you may provide to us.
Information we collect about you:
- Information contained in correspondence: We will collect any information contained in any correspondence between us. For example, if you contact us by email, post or telephone, we may keep a record of that correspondence;
- Website usage data: We will collect – but not analyse or use – information about your interactions with the website, including information such as IP address, page views, searches, requests, and other actions on the website;
- Technical data: We will also collect – but do not analyse or use – certain information about how you use our website and the device that you use to access our website. This might include your geographical location, device information, the data transmitted by your browser, number of page views and similar information. The information may be collected by a third – party website analytics service provider on our behalf and/or may be collected using cookies or similar technologies, without our explicit knowledge.
Information we receive from third parties
In certain circumstances, we will receive information about you from third parties. For example:
- Employers, recruitment agencies and referees: If you are a job applicant we may contact your recruiter, current and former employers and/or referees, who may be based inside or outside the EU, to provide information about you and your application;
- Publishers and other licensees of your work: If we represent you, you will normally authorise us to receive information about you from your publishers, production companies and other licensees such as information about your contracts, performance, royalties and other payments;
- Third parties who can verify submitted information: If you submit a manuscript to us for our review, we may use third party providers to verify the information that you provide to us in connection with that submission. For example, we will use third-party databases or websites such as IMDb to confirm your professional history.
- We might also receive information about you from third parties if you have indicated to such third party that you would like to hear from us.
3) HOW WE USE INFORMATION ABOUT YOU AND RECIPIENTS OF YOUR INFORMATION
We will use your information for the purposes listed below either on the basis of:
- the provision of our services to you;
- your consent (where we request it);
- where we need to comply with a legal or regulatory obligation; or
- our legitimate interests or those of a third party
We use your information for the following purposes:
- To provide access to our website: to provide you with access to our website in a manner convenient and optimal and with personalised content relevant to you including sharing your information with our website hosts and developers (on the basis of our legitimate interest to ensure our website is presented in an effective and optimal manner);
- To conduct business with you: to contact you and manage and facilitate our business relationship with you, (including administration of any contracts with third parties when we represent you on such contracts) and on the basis of our legitimate interests in maintaining our business contracts;
- User and client support: to deal with enquiries or complaints about the website and share your information with our website developer, IT support provider, as necessary to provide support (on the basis of our legitimate interest in providing the correct services to our website users and to comply with our legal obligations);
- Recruitment: to process any job applications you submit to us, whether directly or via an agent or recruiter including sharing this with our third party recruitment agency (on the basis of our legitimate interest to recruit new employees or contractors);
- Social media interactions: to interact with users on social media platforms including Tumblr and for example, responding to comments and messages, posting, ‘liking’ posts (on the basis of our legitimate interest in promoting our brand and communicating with interested individuals);
- Research: to carry out aggregated and anonymised research about general engagement with our website (on the basis of our legitimate interest in providing the right kinds of services to our website users);
- Fraud and unlawful activity detection: to protect, investigate, and deter against fraudulent, unauthorised, or illegal activity, including identity fraud (on the basis of our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so);
- Compliance with policies, procedures and laws: to enable us to comply with our policies and procedures and enforce our legal rights, or to protect the rights, property or safety of our employees and share your information with our technical and legal advisors (on the basis of our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so); and
As outlined above, in certain circumstances we may use your personal information to pursue legitimate interests of our own or those of third parties. Where we refer to using your information on the basis of our “legitimate interests”, we mean our legitimate business interests in conducting and managing our business and our relationship with you, including the legitimate interest we have in:
- personalising, enhancing, modifying or otherwise improving the services and/or communications that we provide to you;
- detecting and preventing fraud and operating a safe and lawful business;
- improving security and optimisation of our network, sites and services.
Where we use your information for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you. Our legitimate interests don’t automatically override yours and we won’t use your information if we believe your interests should override ours unless we have other grounds to do so (such as your consent or a legal obligation).
4) WHO WE MIGHT SHARE YOUR INFORMATION WITH
In connection with the purposes and on the lawful grounds described above and in addition to the recipients of your information as described above, we will share your personal information when relevant with third parties such as:
- Our service providers: third parties we work with to deliver our business (including, for example, hosting or operating the website and our databases and site analytics);
- Publishers, production companies, licensees, sub-agents, advisors and service companies: if we represent you, any publishers or other licensees of your work (or prospective publishers and licensees) as well as sub- or co-agents, advisors (such as your solicitor or accountant) and editorial service providers, where applicable.
- Other third parties (including professional advisers): any other third parties (including legal or other advisors, regulatory authorities, HMRC, courts, law enforcement agencies and government agencies) where necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure may be permitted or required by law.
We require third parties to maintain appropriate security to protect your information from unauthorised access or processing.
6) HOW WE LOOK AFTER YOUR INFORMATION AND HOW LONG WE KEEP IT FOR
We operate a policy of “privacy by design” by looking for opportunities to minimise the amount of personal information we hold about you. We use appropriate technological and operational security measures to protect your information against any unauthorised access or unlawful use, such as:
- ensuring the physical security of our offices, or other sites;
- ensuring the physical and digital security of our equipment and devices by using appropriate password protection and encryption
- maintaining a data protection policy for, and delivering data protection training to, our employees; and
- limiting access to your personal information to those in our company who need to use it in the course of their work.
We will retain your information for as long as is necessary to provide you with the services that you have requested from us or for as long as we reasonably require to retain the information for our lawful business purposes, such as for the purposes of exercising our legal rights or where we are permitted to do.
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it.
Please contact us using the contact details at the top of this Privacy Notice if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7) YOUR RIGHTS TO THE INFORMATION WE HOLD ABOUT YOU
You have certain rights in respect of the information that we hold about you, including:
- the right to be informed of the ways in which we use your information, as we seek to do in this Privacy Notice;
- the right to ask us not to process your personal data for marketing purposes;
- the right to request access to the information that we hold about you;
- in certain circumstances, the right to receive a copy of any information we hold about you (or request that we transfer this to another service provider) in a structured, commonly-used, machine readable format
- the right to request that we correct or rectify any information that we hold about you which is out of date or incorrect;
- the right to withdraw your consent for our use of your information in reliance of your consent;
- the right to object to our using your information on the basis of our legitimate interests and there is something about your particular situation which makes you want to object to processing on this ground;
- in certain circumstances, the right to ask us to limit or stop processing information about you, or erase information we hold about you; and
- the right to lodge a complaint about us to the UK Information Commissioner’s Office (https://ico.org.uk/), as well as with the relevant authority in your country of work or residence.
Please note that we may need to retain certain information for our own record-keeping and research purposes. We may also need to send you service-related communications relating to your website user account even when you have requested not to receive marketing communications.
How to exercise your rights
You may exercise your rights above by contacting us using the contact details at the top of this Privacy Notice
You may contact us via the details at the top of this Privacy Notice if you wish to action any of these additional rights and we will comply with your requests unless we have a lawful reason not to do so.
What we need from you to process your requests
We may need to request specific information from you to help us confirm your identity and to enable you 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.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We will 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) THIRD-PARTY LINKS
The 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.
9) CHANGES TO THIS PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
We may make changes to this Privacy Notice from time to time. We will post any changes to our site, or notify you of any material changes by e-mail.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us by updating your profile account information or contacting us via the contact details at the top of this Privacy Notice.
This Privacy Notice was updated on 24/05/2018.