At WAG Entertainment Limited, we are committed to protecting the personal data that we obtain about you.
The Website is operated by WAG Entertainment Limited (we, us, our, WAG Entertainment), a company incorporated in England & Wales with company number 03556882 and registered office at 2D Leroy House, 436 Essex Road, London N1 3QP. Where we decide the purpose and means for the processing of the personal data that you provide via our Website, we are the “data controller”. As data controller, we will comply with all applicable data protection laws.
Our Website may contain hyperlinks to third party websites, including those of our e-shop third party service provider. These websites operate fully independently from us, and we cannot accept any responsibility or liability for the privacy practices of such third parties nor the availability of these external sites or resources. The appearance of such links on our Website is not an endorsement. Should you use any of these websites, such use is at your own risk and we would advise that you review their respective privacy policies.
Privacy Notice - Health Data – COVID-19
This Schedule describes how the Producer (“we”, “us” or “our”) will process and protect personal data relating to your health for the purposes set out in the Agreement (“Health Data”). This information supplements our privacy notice available via the Production Office.
When we collect and use your Health Data, we will likely do so as a “controller”. This means that we are responsible for deciding the purposes and means for which the Health Data that we hold about you is being processed. We will do so in accordance with the EU General Data Protection Regulation 2016/679 (“GDPR”) and Data Protection Act 2018 (“DPA 2018”) (together “Data Protection Laws”).
We receive Health Data directly from you or obtained from health checks and questionnaires. We use Health Data to ensure the health and safety of the production of the Programme.
Lawful Basis and conditions for processing Health Data
We rely on “legitimate interest” under Article 6(1)(f) of the GDPR as the lawful basis for processing Health Data. It is in your and our interest to protect your health and safety as well as the health and safety of the production of the Programme.
Health Data is considered as “special category data” and therefore granted higher levels of protection by Data Protection Laws. We rely on Article 9(2)(b) of the GDPR, as the additional basis for processing your Health Data, which relates to carrying out our health and safety obligations as a producer and the safeguarding of your fundamental rights.
In addition, we rely on the processing condition at Schedule 1 part 1 paragraph 1 of the DPA 2018: Employment, social security and social protection. This relates to ensuring the health, safety and welfare of our crew members and the production of the Programme.
How long we keep Health Data
We will only retain Health Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal requirements we have as a producer.
With who do we share Health Data
As a producer, it’s our duty to ensure the health and safety of all crew members. For this purpose, we may need to share Health Data with authorities for public health purposes, or with the police where necessary and proportionate. You understand that we may also share your information with our health and safety advisors, First Option Safety Group, and a copy of their Information Security Policy can be found here: https://www.firstoption.group/files/First_Option_-_GDPR___Data_Protection_Policy_-_March_2020_v3.0.pdf.
It is our obligation to be transparent and keep everyone on the Programme safe. For this purpose, we would keep crew members informed about potential or confirmed COVID-19 cases amongst their colleagues.
What personal information are we likely to collect about you?
In order to provide our online sales services and other related business activities, we will need to collect and process information about you.
Information provided by you
When you use our Website, whether for browsing to obtain program sales information and news about our productions or to make an online purchase or to upload your own content via the links to third party websites, you may be asked to provide some personal information. Should you contact us via the email link on our Contact Us web-page, we will obtain the following information:
- your name
- your email address
- your free-text message contained in your email (which may include personal data and/or special categories of personal data)
If you decide to make a purchase, we will not ask you for your details. Instead, our e-shop will direct you to our third party payment services provider, Amazon.co.uk, where you will be asked for your payment and billing details. This information will not be shared with WAG Entertainment.
We do not currently use data analytics on our Website, but we may choose to do so in the future with an aim to improving our Website and to offer the best, most accessible service possible to all of our customers.
Third party data analytics service providers (such as Google Analytics) provide visibility of website browser behaviour and navigation across a website. These third party data analytics service providers would only collect information on our behalf in accordance with our instructions and in line with their own privacy policies. Any data collected will almost always be anonymised and aggregated before reporting back to us.
Typically, data analytics service providers collect the following types of data:
- number of visitors to our Website
- pages visited while at the Website and time spent per page
- page interaction information, such as scrolling, clicks and browsing methods
- websites where visitors have come from and where they go afterwards
- page response times and any download errors
- other technical information relating to end user device, such as IP address or browser plug-in
To find out more, please read below about the use of analytics and cookies.
How do we use your personal data and on what basis?
When you visit our Website, whether to browse our content, to contact us about our services or make a purchase, we (or our third party service providers acting on our behalf) may use the personal information that you provide for the following purposes:
Providing our Products and Services
- entering into an agreement with you to provide our services or products
- performance of that agreement
We collect and use information from you to enable us to perform our sales contracts with you in relation to the production of our television series and program sales.
Customer Services & Enquiries
- providing you with information about the services and products we offer, including information about our team and relevant personnel to contact with your specific enquiries
- providing links to a platform via which you may share your CV with us (via our third party service provider)
- replying to your email queries or responding to concerns or complaints
If you contact us to make an enquiry or to raise a concern about our Website or any aspect of our online services, we aim to respond to you as promptly as possible and we do so on the basis that we have a legitimate interest in replying to you.
Tax and other legal obligations
- reporting VAT and other company tax reporting purposes (as required by law)
- complying with regulators, law enforcement agencies or in relation to any claims that may arise
We process personal information for the legitimate interests and under the legal obligation of ensuring that use of the Website and e-shop (i) is lawful and non-fraudulent, (ii) does not disrupt the operation of our services, (iii) does not harass our staff or other individuals, and (iv) to enforce our legal rights and comply with our legal obligations.
In accordance with our legal obligations, we may disclose your information to the extent required by law which may include for financial accounting and taxation purposes with our auditors, regulators or other government bodies such as HMRC. We may also disclose your information to third parties in order to enforce or apply our contractual terms, to investigate potential breaches, to protect the rights and freedoms, property or safety of our business or those of our customers and other individuals.
Where we reasonably believe that you are or may be in breach of any of the applicable laws, we may use your personal information to inform relevant third parties such as your email/internet provider or law enforcement agencies about the content.
If we are involved in a merger, acquisition, or sale of all or a portion of our business or assets, the information we hold may be included as part of that sale, in which case you will be notified via email and/or a prominent notice on the Site of any changes in ownership or use of your information, as any choices you may have regarding that information.
Analytics & Cookies
This information is not used to develop a personal profile of you.
All financial transactions via our e-shop are handled directly by our payment service provider. We will not share any personal information with these third party providers, nor will we receive any of the financial information that you provide to them. The payment service provider which we use is Amazon (www.amazon.co.uk).
Do we share your personal information with anyone else?
Personnel, Suppliers and Subcontractors
We will not pass your information on to third parties for marketing purposes.
Your choices and rights in relation to personal data which we process relating to you
You have the following rights over the way we process personal data relating to you. We aim to comply without undue delay, and within one month at the latest:
- to ask for a copy of data we are processing about you and have inaccuracies corrected;
- to ask us to restrict, stop processing, or to delete your personal data;
- to request a machine readable copy of your personal data, which you can use with another service provider. Where it is technically feasible, you can ask us to send this information directly to another provider if you prefer; and
- to make a complaint to a data protection regulator. You may contact them at: https://ico.org.uk/concerns/
To make a request in relation to any of the aforementioned rights, please email us at [email protected].
If you are unhappy with the way that we are processing your personal data, please let us know. The best way to bring this to our attention is by emailing us at [email protected].
We do not knowingly use the Website to solicit data from or market to children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information or may be receiving communications from us without consent of a parent or guardian, we ask that this be brought to our immediate attention. We will make it our priority to address this situation and delete information relating to a child as soon as practicable. In such an event, please contact us at [email protected].
We will take commercially reasonable, appropriate technical and organisational measures to ensure a level of security appropriate to the risk that could be encountered via the use of our Website and services, taking into account the likelihood and severity those risks might pose to the rights and freedoms of our customers and other individuals who might be impacted.
In particular, we will take precautions to protect against the accidental or unlawful destruction, loss, or alteration, and unauthorised disclosure of or access to the personal data transmitted, stored or otherwise processed by us.
Please be aware that, while we make the security of our Website and your personal information a high priority and we devote considerable time and resources to implementing and maintaining robust information technology security, no security system can prevent all security breaches. By choosing to share your personal information with us, you accept the aforesaid and provide your information at your own risk.
In accordance with data protection laws and good commercial practice, we do not retain data in a form that permits identification of the person(s) to whom it relates for any longer than is necessary. Once the purpose for which information has been collected has been fulfilled, we will either permanently delete your personal information or remove all identifiers within it so that it is no longer personal data. We may use such anonymised data for research and/or business analysis purposes.
For example, where we download a CV from our third party talent management service provider, The Talent Manager (www.thetalentmanager.co.uk), it will be kept on our servers (or those of our third party service providers) for no longer than necessary and, in any event, for a maximum of 12 months from date of download and deleted thereafter unless otherwise notified.
International Data Transfers
Our servers are located in the European Union and the information that we collect directly from you will be stored in these servers. We may also transfer your personal data to our third party service providers, many of whom may be located outside of the EU, operate from multiple locations including non-EU based operations or engage sub-processors located outside the EU.
There are agreements in place with all of our third party service providers to ensure that those parties process personal data using appropriate safeguards that meet the requirements of data protection laws. Such appropriate safeguards may include standard data protection clauses adopted by a data protection regulator and approved by the European Commission, such as the European Commission’s standard contractual clauses.
If you would like to find out more about these safeguards or if you have any other queries or comments in relation to this policy, please let us know by emailing us at [email protected].