1. INTRODUCTON

1.1 Studio RM Limited of 93 Shepperton Road, London N1 3DF (“Studio RM”/“we”/“us”/“our”) is committed to protecting and respecting your privacy.

1.2 This privacy notice (“Notice”) (together with any other contractual terms that may be in place between us and you) sets out the basis on which any personal data we receive from you, or that we gather in any other way, will be processed by us. It applies to any personal data gathered due to your use of studiorm.co.uk (our “Website”) or otherwise as a consequence of any dealings we may have with you. Please read and understand this Notice carefully to understand our views and practices regarding your personal data and how we will treat it.

1.2 For the purposes of this Notice, “UK GDPR” means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018, and “consent”, “controller”, “personal data”, “process”, “processing” “profiling”, and “third party” shall have the definitions prescribed to them under the UK GDPR. Where you are subject to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”), references to the UK GDPR under this Notice shall be deemed to be references to the GDPR.

For the purposes of the UK GDPR, we shall be the “controller”.

2. INFORMATION WE MAY COLLECT FROM YOU

2.1 During the course of our business (including our supply of services to you), we may collect and process personal data that you provide to us by filling in contact forms on our Website or by corresponding with us by phone, e-mail or otherwise. The personal data you give us may include, without limitation:

• personal identification information and employment details such as your name, age and job role;
• contact details such as your home or office address, e-mail address, and phone number; and
• any other information relevant to the work that we undertake (or plan to undertake) that you provide to us.

2.2 Certain personal data about you may be recorded and logged automatically when you access the Website. This is often referred to as "log data”, Each time you visit or use our Website we may automatically collect the following information about you or your devices:

• technical information, including the type of device(s) you use, a unique device identifier, the Internet protocol (IP) address used to connect your device(s) to the Internet, network information, browser type and version, time zone setting, browser plug-in types and versions and operating system and platform;
• information and details about your use of our Website (including but not limited to traffic data; location data; weblogs and other communication data; the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time); what you viewed or searched for; page response times, download errors; length of visits to certain pages; page interaction information (such as scrolling, clicks, and mouse-overs); and methods used to browse away from the page)); and
• we may receive personal data about you from other sources such as analytics providers and search information providers.

3. USES MADE OF THE INFORMATION

3.1 Your personal data is only collected and processed by us where we have a lawful basis under the UK GDPR to do so. The lawful bases are:

• you have consented to the processing of your personal data;
• we are required to process your personal data to comply with legal obligations which we are subject to;
• it is necessary to enable us to defend, prosecute or make a claim against you, us or a third party;
• it is necessary for us to process your personal data in order for us perform a contract we have entered into with you or to take steps (at your request) necessary to enter into a contract with you; or
• in certain cases, where we have a legitimate business interest in processing your personal data (i.e. when it is essential for us to process your personal data to enable us to operate the Website).

3.2 Specifically, we will use personal data given to us:

• to carry out our obligations arising from any contracts for post-production services entered into between our clients, or any suppliers, and us or in order to take steps at our prospective client’s or supplier’s request prior to entering into such a contract. Where the data subject is the client, supplier or prospective client, or prospective supplier, the contract or prospective contract forms the lawful basis of the processing. Where the data subject is not the client or supplier, but is otherwise involved in the delivery or receipt of the post-production services, including as an employee of the client, supplier or another party involved, then the personal data is processed on the basis of the legitimate interests of Studio RM and the client in completing said services for the benefit of both businesses;
• where you have provided consent to the same, to provide you with information about our services, in the form of a regular email newsletter;
• to facilitate, and if necessary, enforce any legal obligations you or a third party may owe to us, in respect of any contract;
• to develop and improve our business and services, to enable us understand and enhance the quality of services you receive, which is in our and your legitimate interests;
• in accordance with your and our legitimate interests, and the legitimate interests of other users of our services to ensure that our services are used in the most effective manner and for maximum benefit, to notify you about changes to our Website or services and to ensure that content on our Website is presented in the most effective manner for you and for your computer or mobile device; and
• in accordance with our legitimate interest, and the legitimate interest of any counterpart, to facilitate such sale or purchase as part of, or as reasonably necessary for the purpose of, any sale, purchase or restructuring of any of our business or assets of which the provision or offering of goods or services to you forms part.

3.3 In addition to the above, we will use the personal data we collect about you from the use of our Website, in accordance with our and/or your legitimate interests, in order to improve your experience of our Website, including:

• to administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• as part of our efforts to keep our Website safe and secure;
• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and
• to make suggestions and recommendations to you and other users of our Website about goods or services that may interest you or them.

3.4 We may combine the information we receive from other sources with the personal data provided by and collected from you for the purposes set out above (depending on the types of information we receive).

3.5 We do not use your personal data as part of any automated decision-making, including profiling, which produces legal or similarly significant effects concerning you.

4. DISCLOSURE OF YOUR INFORMATON

4.1 We do not sell, share, or transfer your personal data except as set out in this Notice.

4.2 We may share your personal data with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries (as applicable) from time to time.

4.3 We may share your personal data with selected third parties including:

• our mailing partner, to deliver messages to you in accordance with the purposes set out above;
• clients, business partners, suppliers and sub-contractors as is necessary for the performance of any contracts we enter into with them in relation to a project in which you are involved;
• analytics and search engine providers that assist us in the improvement and optimisation of our Website;
• suppliers of IT systems and services for the purpose of ensuring the correct operation, or enhancing the operation of IT systems, or to ensure the safety and security of personal data; and
• credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.

4.4 Examples of when we may disclose your personal data to third parties include, without limitation:

• in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
• if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets; and
• if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or obligations under other agreements, or to protect our rights, property, or safety, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

5. WHERE AND HOW WE STORE YOUR PERSONAL DATA

5.1 Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access. For example, we use secure servers to store all personal data you provide to us. Unfortunately, the transmission of any information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of any personal data transmitted on or via our Website; any transmission is at your own risk.

5.2 Personal data that we collect from or about you may be transferred to, and stored at, a destination outside the UK and the European Economic Area (“EEA”): as part of the operation of our customer relationship management system; as part of our mailing system; when necessary as an integral part of a cross-border work project; or in such circumstances where the transfer of personal data is necessary for the performance of a contract between us and you, or a contract between us and a third party concluded in your interest. Any personal data transferred internationally is subject to appropriate legally recognised safeguards such as the Standard Contractual Clauses approved by the European Commission, which ensure the lawful transfer of your personal data outside of the UK and EEA. We take all reasonable and appropriate steps to ensure the privacy and security of any personal data transferred internationally (whether by us or our partners), and we only transfer personal data to third parties whom have provided us the necessary assurances and protections in respect of the security of your personal data.

5.3 We will store personal data for as long as necessary to fulfil the purposes for which it is originally collected, as explained in this Notice, or for any other lawful or connected purpose subsequently communicated to you, and for other essential purposes such as complying with our obligations at law. The retention period may therefore vary for different types of personal data depending on how and why it was gathered. Criteria relevant to determine retention periods include:

• where the personal data is necessary for the performance of a contract, we will retain it whilst we perform our obligations under that contract, and for a period thereafter for the purposes of dispute resolution, enforcing our rights under the contract, or where additional connected contracts are likely to arise;
• where the personal data is processed pursuant to your consent only, and consent is withdrawn, we may delete such personal data immediately if we are unable to process that personal data on another legal basis, or we may cease processing and retain the personal data for a period thereafter if we have a need to keep it for dispute resolution or the enforcement of our rights; and
• where in certain cases we may be legally obliged to hold personal data for a certain period of time, or to delete the personal data at a certain time, including in accordance with the exercise of your rights as data subject as explained in this Notice.

6. YOUR RIGHTS

6.1 We will not use your personal data for direct marketing purposes unless you have provided your consent to us, or to a third party via which we have received the data. You have the right to ask us not to process your personal data for these purposes.

6.2 In certain circumstances, the UK GDPR may provide you with the right (subject to certain exceptions) to:

• request from us further details as to how your personal data is processed;
• request from us a copy of any personal data we hold about you;
• request that we rectify or complete your personal data, where it is inaccurate or incomplete for the purposes of our processing of the data;
• request that we erase your personal data where we have no legal basis to continue processing that personal data;
• request that we restrict how we process your personal data;
• object to any processing that is based solely on our, or a third party’s legitimate interests, upon which event we shall suspend processing until we demonstrate legitimate purposes that justify that processing. We may however continue to use your personal data for the purpose of the establishment, exercise or defence of legal claims; and
• withdraw your consent for future processing (where the processing is based on that consent).

6.3 We will always endeavour to support your rights as a data subject under the preceding paragraph, however the exercise of such rights shall at all times remain subject to certain exemptions set out at law and the rights and responsibilities we are subject to at law.

6.4 We will comply with any valid request for information under the rights explained above within one month, though we may tell you that this period is to be extended by a further two months where necessary, taking into account the complexity and number of the requests. This will normally be provided free of charge. If the request is manifestly unfounded, excessive or repetitive we may charge a reasonable fee or refuse to action the request.

6.5 The provision of personal data to us is not a statutory requirement. Where the provision of personal data to us is a contractual requirement, or a requirement necessary to enter into a contract, we will make that clear as part of the process by which the contract is concluded, which may include by way of terms of the contract. These provisions will also make clear the consequences of failing to provide such data.

6.6 Where you do not provide personal data to us where required, or should withdraw your consent to our processing of personal data, we may be unable to offer certain service benefits and website functionalities to you.

7. THIRD-PARTY WEBSITES

7.1 Our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which our Website is advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy notices and that we do not accept any responsibility or liability for these notices or for any personal data that may be collected through these websites or services. Please check these notices before you submit any personal data to these websites or use these services.

8. COOKIES

8.1 Like most websites and mobile applications, our Website uses cookies. A cookie is a small, often encrypted file of letters and numbers that we store on your browser, your computer, your mobile device or other device. They help us improve our Website and your general experience on it.

8.2 We may use the information we obtain from the cookie in the administration of our Website, to improve our Website’s usability and for marketing purposes. We may also use that information to distinguish you from other users of our Website and to monitor traffic on our Website.

8.3 If you do not want us to store cookies on your computer or other device for these purposes, you may change the settings on your internet browser to reject cookies. Please note that if you set your browser to reject cookies, you may not be able to use all of the features of our Website and/or may be prevented from accessing certain parts of our Website. For more information on cookies, including how to reject or delete them, please visit http://allaboutcookies.org

8.4 We, or our third party partners use cookies to:

• Measure and generate reports on use of the Website so that we can measure and improve performance including the number of page visits and traffic sources. To do this, we use third-party cookies from Google Analytics. All user data collected by these cookies is in an anonymous form. You can view Google’s practices and position on privacy across Google Analytics here: http://www.google.co.uk/intl/en/analytics/privacyoverview.html]
• Improve Security by identifying individual clients behind a shared IP address (for example when several devices are using the same WiFi connection) and applying security settings on a per-client basis. This cookie is provided by Cloudfare and is essential for the safe operation of the Website, and so cannot be disabled. This cookie does not store any personal data.

8.5 If you continue to use our Website, we will take that as your consent to the relevant cookies being stored on your computer or other device.

9. CHANGES TO THIS NOTICE

9.1 Any changes we may make to this Notice in the future will be posted on this page and, where appropriate, notified to you by e-mail or when you next use our Website. We encourage you to check this page regularly to take note of any changes we may have made.

10. COMPLAINTS

10.1 You have the right to make a complaint about how we process your personal data to the Information Commissioner (the UK’s data protection regulatory authority):

https://ico.org.uk/concerns/

Information Commissioner's Office

Wycliffe House, Water Lane, Wilmslow

Cheshire, SK9 5AF

Tel: +44 303 123 1113

11. CONTACT

11.1 Questions, comments and requests regarding this Notice and how we process your personal data are welcomed and should be addressed to [email protected]