PRIVACY NOTICE FOR X2 PRODUCTION (the “Company”)

Last updated: January 2023

Welcome to the x2 Production privacy policy.

X2 Production (collectively referred to as "we", "us" or "our" in this privacy policy) are committed to protecting and respecting your privacy. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

1. IMPORTANT INFORMATION AND WHO WE ARE

1.1 Purpose of this privacy policy

This privacy policy aims to give you information on how X2 Production collects and processes your personal data through your use of our website, including any data you may provide us when you get in touch on behalf of your organization (our client or business partner/ supplier) to obtain information about our services, sign up to our newsletter, make an enquiry to us, or interact with us by any other means. This policy will also address how we handle personal data that is provided to us by suppliers (for example, modeling agencies and photographers with whom we partner with for the provision of the services, such as the development of client’s campaigns). In this case, the collection and processing of your personal information will also be subject to their own privacy policies, for which X2 Production have no control or responsibility.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

1.2 Controller

This privacy policy is issued on behalf of the X2 Production

X2 Production is the “data controller” for the purpose of data protection legislation and it is responsible for this website.

1.3 Changes to this privacy policy

We may review this privacy policy from time to time and we will notify you of any changes by uploading the new version of it on our website. We will send you an e-mail or post an update notice on our website so that you become aware of the updated version of this policy. The “Last updated” date at the top of this policy will also be adjusted accordingly.

You are advised to review this privacy policy periodically for any changes. Changes to this policy are effective when they are posted on our website. Your continued use of the services and products after the effective date of any change will constitute your acceptance of all of the changes.

1.4 Your duty to inform us of changes

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.

1.5 Third-party links

This 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 policy of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you as follows:

Identity Data: such as first name, last name, age, date of birth, passport details, driver license.
Contact Data: such as home/ work address, email address and telephone numbers.
Professional Data: such as name of your employer, business contact details, job title/ type, professional qualifications, education and/or work history, industry, location of employment.
Billing Data: such as billing address and credit card details.
Technical Data: such as internet protocol (IP) address, your login data, 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 to access the website.
Profile Data: such as your interests, preferences, feedback and survey responses.
Usage Data: such as information about how you use our website and services.
Marketing and Communications Data: such as your preferences in receiving marketing from us and our third parties and your communication preferences.

On a few occasions, we may collect Special Categories of Personal Data where such information is necessary for the performance of our services (for example, this may include health-related data such as food allergies or dietary preferences where we need to make a restaurant booking for you, or information about ethnicity or body measurements if we are considering your profile for a modeling role in a client’s campaign).

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

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.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Billing Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
get in touch with us to obtain information about our services;
sign up as a client;
subscribe to our service or publications;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us feedback or contact us.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
Third parties. We may collect personal data about you from various third parties, such as:

analytics and search information providers such as Google Analytics; and
business partners (e.g modeling agencies, crews and talent service providers) which assist us with the provision of the services.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use (this is, process) your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
To give you information about our services that you request through the website.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we are subject to certain legal requirements which may require us to process your information. We may also be obliged by law to disclose your information to a regulatory body or law enforcement agency.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before processing special category of data about you via email. You have the right to withdraw consent to such processing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver the services requested by you including:

(a) Contact you in response to a request made on the website

(b) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(d) Billing

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about services that may be of interest to you

(a) Identity

(b) Contact

(d) Technical

(e) Usage

(f) Profile

(g) Marketing and Communications

Necessary for our legitimate interests (to develop our services and grow our business)

Marketing

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, Professional, Technical, 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 services may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details at some other time and, in each case, you have not opted out of receiving that marketing.

If you have already purchased goods or services from us, we may send you electronic marketing communications about services we feel may interest you (based on your prior experience with us) if you have not opted out from that marketing messages.

Third-party marketing

We do not sell or otherwise share your personal data with any third party for marketing purposes and we will get your express opt-in consent if we decide to do so.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

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.

5. DISCLOSURES OF YOUR PERSONAL DATA

We will never sell your personal data to marketers or other third parties. We may disclose or otherwise provide anonymized/aggregated data to third parties.

Additionally, we may share your personal data with the following third parties (a) if you ask us to, (b) if it is necessary for the provision of the services, (c) if we have a legal duty to disclose it or (d) if applicable law allows us to do so for legitimate interests (e.g business reasons):

Internal Third Parties:

External Third Parties:

Service Providers (including business partners/ suppliers):

We engage a variety of service providers to enable us to provide the services to you. Those may be used to support IT and system administration services, distribute marketing materials, conduct marketing research, perform audits and provide professional advice.

We also partner with modeling and talent agencies with whom your personal information may be shared with. We may also need to disclose your information to organize car hire, flights, hotels, visas or carry out any other administrative task in relation to the provision of our services.

Third-Party Acquirers:

We may sell your personal data to parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

Government Authorities:

If we believe it is necessary or appropriate, we may share your personal data with government authorities, regulatory bodies or other third parties, including for purposes of: (i) enforcing the contractual arrangement we’ve entered into with you or other applicable agreements or policies; (ii) protecting our rights, property, privacy, or security, or that of others; or (iii) complying with applicable law, legal process, or government orders.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our service providers to use your personal data for their own purposes and only permit them to process your personal data for the specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

Our business operates globally and so we may need to transfer your personal information to outside of the United States. Below are a few occasions where your data may be transferred and processed overseas:

Where we share your data with other companies within X2 Production Group (which will occur to the extent that there is a legitimate interest in doing so to support out business goals)
Where our agents and/ or services providers are based outside of the United States (for example, our data is stored at a cloud server platform provided by Google, a U.S company.

Whenever we transfer your personal data out of the United States, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
Where we transfer data to outside of the United States, we may use specific contracts approved for use in the United States which give personal data the same protection it has in the United States.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the US.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

8. DATA RETENTION

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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 unauthorized 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, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity and Billing Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9. CONTACT DETAILS

If you have any questions about this privacy policy or our privacy practices, please contact us by e-mail at hello@x2production.com.

Additional Information if you are a California Resident

This section provides additional details about the personal data we collect about California users and the rights afforded to them under the California Consumer Privacy Act or “CCPA”.

For more details about the personal data we have collected over the last 12 months, including the categories of sources, please see “The Data we Collect about You” section above. We collect this information for the business and commercial purposes described in the “Purposes for which we will use your personal data” section above. We share this information with the categories of third parties described in the “Disclosure of Your Personal Data” section above.

We do not sell and have not sold personal data in the preceding 12 months, as “sale” is defined in the CCPA.

Subject to certain limitations, the CCPA provides California users with the right to request more details on the categories or specific pieces of personal data we collect (including how we use and disclose this information), to delete their personal data, and to opt out of any “sale” of personal data that may be occurring.

California users may make a request pursuant to their rights under the CCPA by contacting us at the e-mail address provided in this policy and we will not discriminate against any users who exercise such rights under the CCPA. We will verify your request using the personal data available to us, including email address. Users can also designate an authorized agent to exercise these rights on their behalf.