Our contact details are as follows:
First Floor, 17-19 Foley Street, London, United Kingdom, W1W 6DW
Email Address: firstname.lastname@example.org
For the purpose of the EU General Data Protection Regulation (GDPR), the GDPR as incorporated into English Law, and the Data Protection Act 2018 (together the Data Protection Laws) 78 Productions is the data controller of the personal information referred to in this policy.
About this Policy
We are committed to protecting and respecting your privacy. In this policy you will find information about the types of information we hold about you, how and why we collect it, how we use it, and how we keep it secure. This policy also tells you about your rights and how you can exercise them and how the law protects you. Please read it carefully to understand our views and practices regarding your personal information and how we will treat it.
What personal information we collect
We only collect the personal information that we need in order to carry out our business. Depending on who you are, this may include:
- Identity Data: first name, maiden name, last name, marital status, title, date of birth and gender;
- Contact Data: billing address, delivery address, email address and telephone numbers;
- Financial Data: bank account and payment card details;
- Transaction Data: details about payments to and from you and other details of products and services you have purchased from us or our affiliates;
- Profile Data: purchases or orders made by you, your interests, preferences, feedback and survey responses;
- Usage Data: information about how you use our (or our affiliates) products, services and websites
- Marketing and Communications Data: your preferences in receiving marketing from us and our third parties and your communication preferences. 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 goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How we collect your personal information
We collect your personal information:• When you provide it to us, including by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
o Subscribe to our service or publications;
o Request marketing to be sent to you;
o Enter a competition, promotion or survey; or to give us feedback or contact us;
- When it is provided to us by third parties;
- From publicly available sources;
If you are a supplier, when you provide services to us.
Why we process your personal information
We process your personal information so that we can:
- Perform our obligations under any contracts that we have with you;
To manage your relationship with us (including notifying you about changes to our terms or
- To enable you to participate in a prize draw, competition or complete a survey;
- To improve our products/services, marketing or customer relationships;
- To recommend products or services which may be of interest to you;
- Promote our own services;
- Engage with our suppliers and keep records of transactions we have with them;
- Comply with our legal and regulatory obligations; and
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us; have entered a competition and given your consent to receive marketing communications; or purchased goods from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of: you taking part in a competition; or sending us an enquiry; or product/service purchase; or product/service experience or other transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Legal basis for processing
There are a number of different legal grounds for processing personal information. Which one is applicable will depend on precisely how we are processing your personal information and for what purpose. Most commonly we will rely on one of the following legal grounds:
- For the performance of our contract with you or to take steps at your request before entering into a contract;
- To pursue our legitimate business interests (or those of a third party) and your fundamental rights do not override those interests. Our legitimate business interests may include our interests in keeping our records updated and to study how customers use our products/services, to develop them and grow our business, to define types of customers for our and/or our artist Louis Tomlinson's products and services, and to inform our marketing strategy, promoting our business, and carrying out our administrative and operational functions;
- Where you have given consent;
- To comply with our legal and regulatory obligations;
If we process any 'special categories' of your personal information (including, for example, information about your race, ethnicity or sexual orientation), we will usually rely on the fact that you have given us your specific consent to do so, unless there is otherwise a legal requirement for us to process such information, or you have put the information into the public domain.
You can withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
How we share your personal information
We may share your personal information with any of the following for the purposes described in this policy: production partners; financiers; licensees; retailers; merchandising manufacturers, ticket companies; record labels; music festivals; music venues; streaming services; governmental bodies; and agents, contractors, or service providers.
We may also share your personal information with law enforcement agencies, other governmental agencies or third parties if we are required by law to do so; our professional advisers; our service providers; other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity.
We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Transferring your personal information to outside of the UK and the EEA
Where we transfer your personal information to countries outside of the UK and the EEA we will ensure that it is protected and transferred in a manner consistent with legal requirements applicable to the personal information concerned. This can be done in a number of different ways, for example, the country to which we send the personal information may have been assessed by the European Commission as providing an “adequate” level of protection for personal information, or, the recipient may have signed a contract based on standard contractual clauses approved by the European Commission. In other circumstances, the law may permit us to otherwise transfer your personal information to countries outside of the UK and the EEA.
How long will we keep your information?
We will only keep the information we collect about you for as long as required for the purposes set out above or as required to comply with any legal obligations to which we are subject.
To prevent unauthorised access or disclosure, we have put in place suitable procedures to safeguard and secure the information we collect and store about you.
Changes to this policy and your duty to inform us of changes
Any changes we make to our policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our policy.
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.
This policy was last updated July 2023.