Privacy Policy

We ask that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.

Who we are

Shorts International Limited (“SIL” or “we”) collects, uses and is responsible for certain personal information about you. For the purpose of the Data Protection Law, the data controller is Shorts International Limited.

Data Protection Law means (i) Regulation 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data (General Data Protection Regulation) (also known as GDPR); and (ii) Directive 2002/58/EC concerning the processing of personal data and the protection of privacy in the electronic communications sector, and applicable national implementations of both (as may be amended, superseded or replaced).

The personal information we collect and use

Information collected by us

In the course of providing this website (the “Site”) and providing our services such as film distribution, channel broadcasting or content production (the “Services”), employing staff and managing recruitment processes, we collect the following personal information when you provide it to us depending on where you interact with us:

• Your name and email address if, for example, you subscribe to our marketing emails about our news and latest developments, including news about ShortsTV or other services that we launch, new programming coming to our services and competitions/ prize draws you may be interested in.
• Your name and email address, phone number and/or physical address if you enter our competitions or prize draws.
• Information that you voluntarily provide to us if you contact us by any means with queries, complaints, praise or information that you voluntarily post about yourself on public areas of our Site.
• Information that you provide to us when submitting a film to us for our review such as your name and email address.
• Information that you provide to us when entering into contracts with us for our Services, such as your name, address, phone number, email address, bank details.
• Information you provide to us during the recruitment process or in regards to your employment with us (and further detailed in our staff handbook).
• We also collect information about how you use the Site using cookies and similar technology. This includes your viewing history, IP addresses, browser information, operating system, device identifiers and information about how long you have stayed on certain pages or what pages you have clicked on. You can find more detailed information about this in our Cookies Policy.

Information collected from other sources

We also obtain personal information from other sources as follows:

• Your name, phone number, email address, age and/or gender (should you choose to share age and/or gender) from third parties who help us run competitions such as FilmFreeway. The information you give to these third parties is subject to the terms and conditions of those third party services.
• When you engage with us on social media.
• We also collect anonymised publicly available information from social networking sites such as Facebook and Twitter, for example likes, shares, tweets and posts about ShortsTV. This information is provided to us by a third party and is fully anonymised so we cannot see who has posted the information. This information is used for internal analysis purposes.

How we use your personal information

We use your personal information to:

• Send you marketing emails (if you have consented to receive them or we have a legitimate interest to send them). You can always opt out of receiving marketing emails at any time by following the instructions to unsubscribe in any of our email marketing communications. It may take up to 48 hours for your change in preference to take effect and the change will not affect any marketing emails which have already been scheduled to be sent in the future.
• Run competitions and prize draws, including selecting and contacting winner(s), sending prizes (if applicable). This data is only used for the purposes of the relevant competition and/or prize draw and will be subject to the terms and conditions of that competition and/or prize draw, which will be notified to you when you enter the competition and/or prize draw.
• (in respect of visitors to our Site) engage in targeted online advertising on our Site or serving targeted banners and ads to you when you are on other websites and apps by, for example, using Facebook Pixel. More details in our Cookie Policy, but note that Facebook is the data controller for this function and you can switch this function off within your own Facebook account settings.
• Respond to queries.
• Review and respond to film submissions.
• To help us monitor, analyse and improve our Site and services. We use this data to help us understand which content and services are most interesting and enjoyable for our users and to help us identify errors and test features. This helps us to make sure that we are providing you with the best possible products and services.
• Providing our Services such as film distribution, (pursuant to a contract between us).
• Recruit staff to Shorts International Ltd or one of our group which includes our subsidiary and parent undertakings, as defined in section 1162 of the UK Companies Act 2006 (“Group”).
• In respect of our staff, for business administration, staff management (such as maintenance of absence, disciplinary, and performance records and personnel folders), and legal and regulatory compliance.

Who we share your personal information with

We may need to share your personal data with some third parties in some circumstances. This includes where we use third party suppliers to perform various services for us such as information security service providers who help us to manage our IT systems and ensure that they are secure; third party marketing agencies to ensure our marketing is delivered effectively in accordance with this Privacy Policy; operational companies such as delivery companies to deliver a competition or prize draw prize.

We share your personal data with our professional advisers such as lawyers and accountants; government or regulatory authorities; professional indemnity or other relevant insurers; regulators/tax authorities/corporate registries.

In all cases, we provide only the information they need to perform their specific services; they may only use your data for the exact purposes we specify in our contract with them; we work closely with them to ensure that your privacy is respected and protected at all times and if we stop using their services, any of your data held by them will either be deleted or rendered anonymous.

We may disclose your personal data to any member of our Group.

We will also share your personal data with third parties where you have specifically consented to us sharing your data with a particular third party.

Some of these third party recipients may be based outside the European Economic Area — for further information including on how we safeguard your personal data when this occurs, see ‘Transfer of your information out of the EEA’.

If our business is sold or integrated with another business, your personal data may be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.

Please note this list is non-exhaustive and there may be other examples where we need to share with other parties in order to provide the Services as effectively as we can.

You should also be aware that if you choose to share or like content from our Site on social media via, for example, the Facebook, Instagram and/or Twitter share buttons, the relevant social media platform will know what page you are on in order to share that page. The use of that information will be governed by the social media platform’s own privacy policy and clicking the “share” buttons does not result in any other personal data being shared between our Site and the platform.

Whether information has to be provided by you, and if so why

The provision of your name, address, contact details, is usually required from you if you want to enter competitions (and, if you win, receive your prize), enter contracts with us (be it for receiving or providing Services to us, or for employment purposes (further details such as special data may be required as required by law or only with your explicit consent), or recruitment (along with further details such as your curriculum vitae).

The provision of your name and email address is required for us to (i) send you marketing emails (if you have consented to receive them); (ii) review film submissions you have made or (iii) respond to queries you may have made.

For the Site and services offered on the site such as competitions, if you choose not to provide us this personal data, we won’t be able to provide these particular services to you.

For our Services, employment and recruitment for example, certain data is required and we cannot provide the Services, or continue with recruitment, without the required data.

We will inform you at the point of collecting information from you, whether you are required to provide the information to us.

How long your personal information will be kept

Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.

For example, personal data relating to entrants to competitions or prize draws will be retained by us for a reasonable period after the competition or prize draw closes to assist us in operating competitions and prize draws in a consistent manner and to deal with any queries. Furthermore, if as a winner you have consented to take part in publicity, your personal data may be used for a longer period in line with that purpose (such consent may be withdrawn at any time after which your personal data will be deleted within a reasonably practical timeframe).

At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.

We may need to keep your personal data for limited purposes, for example if we need your data in order to respond to any complaints or claims that you make, to comply with applicable law, or for audit or regulatory purposes. If this is the case, we will only keep the data for as long as we need to in order to fulfil those purposes, after which it will be deleted or anonymised.

For data processed in relation to provision of our Services or employment, we will retain relevant personal information for at least six years from the date of our last interaction with you and in compliance with our obligations under the EU General Data Protection Regulation or similar legislation around the world, or for longer as we are required to do so according to our statutory obligations. We may then destroy such files without further notice or liability.

Data processed in relation to recruitment will only be kept for as long as need in relation to that particular recruitment process, at which point it will be deleted or anonymised, unless you have requested that we retain your details on file for future consideration or we feel we have a legitimate interest to retain the data for a limited period.

The legal basis for using your personal data

Data protection law says that we have to tell you the legal basis that we rely on to process your personal data for the purposes that we have notified to you. This section tells you what that legal basis is in relation to each of the purposes set out above.

Site, marketing and other communications

Consent and Legitimate interest (and when these interests are not overridden by your data protection rights)

We rely on consent and/or legitimate interest, as applicable, as the lawful basis on which we collect and use your name and email address for sending our marketing emails. You can withdraw your consent at any time by following the instructions to “unsubscribe” in any email marketing we send you.

We rely on consent to administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering.

We rely on legitimate interest (and when these interests are not overridden by your data protection rights) to provide advertising that is relevant to you to ensure that you have the best experience possible on our Site or to market our programming to you off our Site (e.g. on Facebook).

When it’s in our legitimate interests to do so (and when these interests are not overridden by your data protection rights) for the following purposes:

To analyse, develop, test and improve the systems, services and products we provide to you.

Ensuring the security and integrity of our Site.

Legal obligation

For example, to send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Policy.

Provision of our Services

Legitimate interest (and when these interests are not overridden by your data protection rights)

If you are a filmmaker and have contacted us, either to make a film submission or other matter, it may be in our legitimate interest to keep your contact details on file for a limited period for future contact – for example, to respond to your query, to follow up on a film project. You can always ask us to delete your personal data at any point.

Intra group transfers for internal administration purposes.

Where it’s necessary to fulfil a contract with you

For example:

-If you submit a film to us for our review, we will process the personal data that you provide to us in accordance with our Submissions Policy and use it to, if applicable, respond to you.

-If we enter into a contract with you for the licensing or distribution or financing of your film; payment of royalties, marketing and promotion of your film etc.

Recruitment

Where it’s necessary to fulfil a contract with you and legitimate interest

For recruitment purposes, in connection with us taking steps at your request to enter a contract we may have with you or it is in our legitimate interest to use personal information in such a way to ensure that we can make the best recruitment decisions.

Employment / business administration and legal compliance

Legal obligation:

For example, if we receive a request from law enforcement, regulators or government officials.

Human resources / business administration purposes such as payment of salaries, tax and national insurance, protection, pension contributions or enforcement of our legal rights, protection of third party rights, business mergers or acquisitions.

Where it’s necessary to fulfil a contract with you

For example, payment of salaries, pensions administration, provision of medical cover or other benefits.

Transfer of your information out of the EEA

Your personal information may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) and may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. For example, our newsletter is currently processed and sent to you by MailChimp, Inc., located in the USA.

Regardless of where your personal information is stored or processed we will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Policy.

We put in place European Commission approved standard contractual clauses to protect your information. A copy of these clauses is available for your review upon request to us using the detail provided below.

Other platforms

The Site may contain links to access services provided by third-party platforms that have their own terms of use and privacy policies. These third-party platforms do not operate under this Privacy Policy or our Terms. These third-party platforms may independently solicit and collect information, including personal information, from you. You should read and take note of any applicable third-party terms of use and privacy policies before you use their services.

Children

As noted in the Terms, we do not knowingly collect or solicit personal information from anyone under the age of 16. If you are under 16, please do not attempt to use this Site without the consent of your parent or guardian, or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us personal information, please contact us at [email protected].

Your rights

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

• fair processing of information and transparency over how we use your use personal information.
• access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address.
• require us to correct any mistakes in your information which we hold.
• require the erasure of personal information concerning you in certain situations.
• receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations.
• object at any time to processing of personal information concerning you for direct marketing.
• object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you.
• object in certain other situations to our continued processing of your personal information.
• otherwise restrict our processing of your personal information in certain circumstances.

If you would like to exercise any of those rights, please:

• email, call or write to us.
• let us have enough information to identify you.
• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill).
• let us know the information to which your request relates.

If you would like to unsubscribe from any marketing emails you can also click on the ‘unsubscribe’ button at the bottom of the email. It may take up to two days for this to take place.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to complain

We hope that we can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: 0303 123 1113.

Changes to this privacy notice

If our Privacy Policy changes in any way, we will place an updated version on this page (displaying a version date at the bottom of the page). Regularly reviewing this page ensures that you are always aware of what information we collect, how we use it and under what circumstances, if any, we will share it with other parties.

How to contact us

Please contact us if you have any questions about this privacy notice or the information we hold about you.

If you wish to contact us, please send an email to [email protected], write to Shorts International Limited, 64 Great Eastern Street, London, EC2A 3QR or call +44 (0)207 613 5400.

Last updated 14 June 2019