360PM — Privacy Policy

PRIVACY POLICY

Introduction

Welcome to the 360PM’s privacy notice.

360PM respects your privacy and is committed to protecting your personal data. This privacy notice 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. This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

IMPORTANT INFORMATION AND WHO WE ARE
THE DATA WE COLLECT ABOUT YOU
HOW IS YOUR PERSONAL DATA COLLECTED
HOW WE USE YOUR PERSONAL DATA
DISCLOSURES OF YOUR PERSONAL DATA
INTERNATIONAL TRANSFERS
DATA SECURITY
DATA RETENTION
YOUR LEGAL RIGHTS
GLOSSARY

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how 360PM collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter. 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 notice together with any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.

Controller

360PM is the controller and responsible for your personal data (collectively referred to as “360PM”, “we”, “us” or “our” in this privacy notice).

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact [email protected] using the details set out below.

Contact details

Our full details are:

Email address: [email protected]

Postal address: 2 Arundel street, 3rd floor, WC2R 3DA, London, UK.

Changes to the privacy notice and 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.

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 notice 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 only collect, use, store and transfer your Contact data (email address) for marketing and communication purposes.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

How is your personal data collected?

We collect data from and about you including through:

Direct interactions. You may give us your Contact data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes the personal data you provide when you:
subscribe to our service or publications; and
request marketing to be sent to you.

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 your personal data in the following circumstances:

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 need to comply with a legal or regulatory obligation.
Where we have obtained your consent.

You have the right to withdraw consent to marketing at any time by contacting us at [email protected].

Purposes for which we will use your personal data

We have set out below, 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 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(c) To provide you with our newsletter	Contact	(b) Necessary to comply with a legal obligation(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	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	Contact	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/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)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

You will receive marketing communications from us if you have requested information from us from us and, in each case, you have not opted out of receiving that marketing.

Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or emailing us at [email protected] 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 a service purchase, 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 at [email protected].

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.

6. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out above.

Internal Third Parties as set out in the Glossary.
External Third Parties as set out in the Glossary.
Third 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 notice.

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 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.

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 unauthorised 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.

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

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 unauthorised 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 requirements.

In some circumstances we may anonymise 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. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

10.1. Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

10.2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

10.3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

10.4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

10.5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

10.6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

10.7. 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.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

11. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at [email protected].

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

External Third Parties

Service providers who provide IT and system administration services.
Professional advisers including lawyers, bankers, auditors and insurers.

Health and Safety

INTRODUCTION

360PM has established new policies and practices to adopt on set and has developed a comprehensive production guide for upcoming photography and film shoots outlining protocols, recommendations and operational guidelines that are rooted in safeguarding the health of our crew, talents, artists, and clients.
All these measures are constantly being monitored and updated in light of the unprecedented, fast-changing COVID-19 situation. As part of our commitment to provide a safe working environment for everyone on set during the shoot ,we will ask everyone attending to confirm in writing their agreement with the production safety guidelines, and to sign a health declaration form to confirm they are not showing any COVID-19 symptoms nor have they been in touch with anyone carrying the symptoms in the previous 14 days. Thank you for your ongoing trust and support as we take these next steps.

HEALTH AND SAFETY

Our highest priority is the health and safety of our clients, artists and crew. As such, based on guidance from the world health organization (WHO) and the Government, we have put specific measures in place to reduce the risk of working together in a studio or on location. Some of these measurements include:

Social distancing/reducing the number of crew on set to only essential team members
Rotating crews to reduce physical contact and further maintain social distancing measures
PPE: masks and gloves provided for all crew to wear whilst on set in studio or on set/location
Enhanced sanitising, encouraging all crew to wash their hands frequently and providing sanitise stations
All talent and crew will be required to sign a liability release form
A Health & Safety dedicated team member to periodically disinfect surfaces during the shoot day and specific Health & Safety measures by Department.

SHOOT DAY

When possible we will consider and budget for separate days for video and stills to keep crew numbers down.
All shoot days where possible kept to 10 hour maximum
All studio set builds and set wraps on separate days.
Maximum four talents per day, avoiding group shots when possible
Number of Beauty and Style assistants reduced to minimum
In the event that a photograph or scene is being captured in a small space, only essential key crew may remain on set. Remote viewing will be provided for necessary members of the crew to view set activity. These will be set up outside, at a safe distance or remotely.
Interactions between agency/client & crew should be kept to a minimum, ideally using remote access as noted.
Each Department (Style, Hair & Make-up, Set, etc) will be provided with a specific dedicated set of guidelines.

LOCATION

STUDIO shoots are currently our recommended approach to allow control over proper cleaning and ventilation of spaces, stable internet connection for remote presence, and risk assessment. Studios to be cleaned thoroughly prior to shoot using bio fogging
LOCATION and EXTERIOR shoots: we will evaluate the requests in line with the local shoot permits. Location must pride and guarantee adequate sanitation, ventilation, and risk assessment. Interiors to be cleaned thoroughly prior to shoot using bio fogging .We will monitor and update this, subject to local government guidelines.
INTERNATIONAL SHOOTS: we are organising international shoots with our local production partners, subject to local COVID – 19 restrictions in place regarding travel and shoot, with local crew and talent.

LIVE REMOTE ACCESS

A key concern in this new era is to reduce the size of our crew in studios and on location to maintain social distancing guidelines, and also the restrictions on international travel, meaning clients are unable to travel.

Our suggestion to this is to provide broadcast-quality real-time remote access for our clients so that they can participate on set without being physically present- unite us even when we’re apart.

This remote access setup is customizable as per client’s needs and budget, and subject to the limits of location and internet connection.

SOCIAL DISTANCING & PERSONAL PROTECTIVE EQUIPMENT (PPE)

Crew will be required to adhere to govt guidelines for social distancing, which are generally 2m /4m2 of distance between individuals. Keep your distance and ask others to be considerate.
Each team will have dedicated area to minimize interaction. As such, crew on set to be rotated by need (per department) and kept at essential level only.
Desks and workstations will be separated by 2m or more or separated by a barrier.
We ask everyone on set to limit physical contact unless strictly necessary. Avoid handshakes, kisses, and hugging.
Facial coverings will be provided and must be worn by all crew whilst on set and when performing work duties or interacting with other persons. Gloves must be worn when possible.
Signages will be posted reminding crew of hygiene and safety guideline.

TRAVELS AND TRANSPORTATION

Due to the current travel restrictions, we request all crew and talent to be local, to avoid to travel at a distance which would require overnight accommodation. Any exceptions has to be discussed with production and we suggest to consider a local backup option.

We ask that all talent and crew avoid public transport where possible, crew will be asked to self-drive and account cars will be budgeted for all crew and talent.

All deliveries of EQ, wardrobe, set, etc, should be handled by the responsible department crew on prep day to avoid further congestion on shoot days ,when possible.

We are constantly monitoring travel guidelines and restrictions and will be informing our clients and artists to make sure all services complies with local requirements.

THANK YOU!

The COVID-19 pandemic has created major changes in the world as we know it. We are taking these unprecedented challenges head-on in the hope that not only will we help facilitate a return to normalcy, but also set our standards much higher.

Our safety production measures are being constantly monitored and updated in line with government guidelines and public health and safety requirements.

We ask everyone to be responsible and adhere to social distance and health measures and consider these measures in pre-production, production, and post-production for the safeguard of our crew, talents, artists, and clients.

Thank you, 360PM Team.

Privacy Policy

PRIVACY POLICY

Introduction

Welcome to the 360PM’s privacy notice.

IMPORTANT INFORMATION AND WHO WE ARE

THE DATA WE COLLECT ABOUT YOU

HOW IS YOUR PERSONAL DATA COLLECTED

HOW WE USE YOUR PERSONAL DATA

DISCLOSURES OF YOUR PERSONAL DATA

INTERNATIONAL TRANSFERS

DATA SECURITY

DATA RETENTION

YOUR LEGAL RIGHTS

GLOSSARY

1. Important information and who we are

Purpose of this privacy notice

Controller

360PM is the controller and responsible for your personal data (collectively referred to as “360PM”, “we”, “us” or “our” in this privacy notice).

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact [email protected] using the details set out below.

Contact details

Our full details are:

Email address: [email protected]

Postal address: 2 Arundel street, 3rd floor, WC2R 3DA, London, UK.

Changes to the privacy notice and 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.

Third-party links

2. The data we collect about you

How is your personal data collected?

We collect data from and about you including through:

Direct interactions. You may give us your Contact data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes the personal data you provide when you:

subscribe to our service or publications; and

request marketing to be sent to you.

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 your personal data in the following circumstances:

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 need to comply with a legal or regulatory obligation.

Where we have obtained your consent.

You have the right to withdraw consent to marketing at any time by contacting us at [email protected].

Purposes for which we will use your personal data

We have set out below, 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.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

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(c) To provide you with our newsletter

Contact

(b) Necessary to comply with a legal obligation(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

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

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

Contact

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

To use data analytics to improve our website, products/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)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

You will receive marketing communications from us if you have requested information from us from us and, in each case, you have not opted out of receiving that marketing.

Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or emailing us at [email protected] 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 a service purchase, service experience or other transactions.

Change of purpose

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.

6. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out above.

Internal Third Parties as set out in the Glossary.

External Third Parties as set out in the Glossary.

7. Data security

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

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

In some circumstances we may anonymise 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. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

10.1. Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

10.2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.