Privacy Policy

THIS SITE IS ADMINISTERED BY BLACKSTAR LONDON LTD – OUR PRIVACY NOTICE

Hello. This is our Privacy Notice. Please take some time to read it through.

Blackstar London is required under the General Data Protection Regulation 2016/679 (the “GDPR”) to notify you of how it collects and uses your personal data.

This Privacy Notice sets out the basis upon which we collect personal data from you, or which you may provide it to us, why we need it and how we will use it, in respect of your relationship with us as a visitor to our website, or as a client of ours, or as a consultant of Blackstar London. It also sets out what measures we have in place to ensure your data is safe.

In this Privacy Notice

“Blackstar” or “we” or “us” means Blackstar London Limited (company number 08002552) registered office address Osborn Works Unit 4a, Rutland Way, Sheffield, S3 8DG, trading office address 49 Brixton Station Rd, Brixton, London, J4Y 0B5

“You” means any individual, business / organisation or consultant whose personal data is controlled and / or processed by Blackstar.

General

Blackstar acts as a "data controller” and “data processor”, which means that we are responsible for deciding how to hold and use personal data about you.

We will take all reasonably necessary steps to ensure that your data is treated securely and in accordance with the GDPR, and also in accordance with the Privacy & Electronic Communications Regulations 2003 (“PECR”).

Lawful bases for controlling and processing your Personal Data

Under GDPR, Blackstar must identify a lawful basis for controlling and / or processing of your personal data. We have identified the following bases:

Performance of a contract agreed project and / or provision of creative, digital or social media services for you. If you are a business / organisation or consultant or other individual with a direct contractual relationship with Blackstar, we are entitled to control and / or process the personal data we require in order to fulfil our obligations to you under such contract or requested project for creative, digital and social media services.

The legitimate interests of Blackstar or a third party: Blackstar may control and / or process your personal data on the lawful basis that it is in its legitimate interests and/or those of a third party to do so. This will primarily apply when Blackstar provides services to its clients and/or in the management of its business. The proper performance of its role in providing creative, digital and social media services to its clients, the effective management of its business and compliance with Blackstar’s legal obligations includes:

Contacting individuals and organisations relevant to our work and our clients, which may involve the use of your personal data.
Compliance with legal obligations to which Blackstar is subject: In certain circumstances we may be obliged to control and / or process your personal data to comply with our legal obligations including, without limitation, controlling and / or processing required for accounting and tax purposes. For detailed information on these legal obligations, please see the Information Commissioner’s website (see below). Please note that Blackstar may control and / or process your personal data, without your knowledge or consent, where this is required or permitted by law.

What Personal Data do we collect from you?

Blackstar may collect, store, and use personal data about you, which will vary in nature depending on the basis of our relationship with you e.g. as a creative, digital and social media agency and supplier of services to you, or as a business where you are engaged as a consultant to us.

The types of personal data that we may collect, store and use are:

Personal contact details

such as your interest in working with us, your name, title, home and work addresses, telephone numbers, email addresses, emergency contact information. If you contact us online, we may keep a record of your email or other correspondence, and if you call us by telephone, we may record pertinent information relating to business opportunities, such as budget information and sign off processes regarding the call for account management reasons.

Personal data about you

such as date of birth, gender, nationality.

Personal data which may identify you

such as your driving licence, passport, utility bill(s), electronic signatures, photographs, videos or voice.

Personal data to process any payments Blackstar may need to make to you

such as bank account details, VAT numbers

Personal data relating to your work

such as your career history including work /engagement/project records, job titles, work history, details of the projects / engagements you are or have been involved in, including contracts.

Personal data relating to your relationship with Blackstar

such as a contract of business or consultancy, copies of right to work documentation, references, samples of work, information included in a CV or cover letter or interview for a consultancy role with us, or material provided to us for use in any of our digital and social media services (in any form including without limitation, images, video and documents).

How do we obtain your Personal Data?

Most of the personal data we collect, store and use about you will be provided directly by you (or third parties authorised on your behalf) including, but not limited to:

Where you provide us with your data during the course of your dealings with Blackstar and its consultants;
As part of and during the process of your joining Blackstar as a client or a consultant.
Where data is collected with your knowledge from your employees, or from other companies with whom you may have a relationship such as other agencies, companies with whom you work or organisations with whom you have had dealings and information or service providers;
data obtained from public sources or social media (e.g. Facebook, Twitter, LinkedIn, Instagram).
personal information provided by you to businesses / organisations and affiliated third parties with whom we provide digital and social media services for.

Why does Blackstar need to collect and use your Personal Data?

IF YOU ARE CLIENT, the controlling and / or processing of your personal data will be necessary to fulfil our obligations to you as your creative, digital and social media agency and supplier of services pursuant to our contract for services with you or to enable us to take steps to provide our creative, digital and social media services to a business / organisation at your request prior to agreeing its terms of business, including but not limited to in the following ways:

Administering your initial enquiry or brief for your business requirements and to enable us

to provide creative, digital and social media services to you.

Determining the terms of our agency client agreement with you.

To communicate with you regarding your enquiry including our team sending over or presenting further information regarding the relevant creative, digital and social media services available

To communicate with any third parties to provide or deliver solutions to enquiries, briefs or

for your business requirements

Keeping you up to date and reporting to you.

To demonstrate our working relationship together, creating case studies or profiles on our

website or agreed publicity sent to third party industry publications so that Blackstar can

demonstrate its work for future prospective clients.

To manage your social media channels or those of your partners.

To make payments on your behalf for any third party service that is required for the delivery

of an agreed scope of work, to deduct our costs and to account to you.

To otherwise make and / or receive payments.

To make arrangements for the termination of any agency client relationship.

To provide brand partnership opportunities, where marketing interests may complement

one another.

To generally promote Blackstar’s business and services

To send marketing correspondence about our services, similar to those you have previously bought from us or registered an interest in. You can opt out and object to Blackstar sending you electronic marketing information or contacting you over the phone at any time. See ‘Your Rights’ below, for details.

Business management and planning, including communicating with you when you have provided your contact details through our website.

Dealing with legal disputes involving you and / or Blackstar and its consultants.

Equal opportunities monitoring.

To monitor and keep records of our communications with you the client and our consultants.

For some direct communications mainly for the purpose of promoting projects in which Blackstar clients are involved.

Accounting and auditing of our business.

To comply with any legal obligations upon our business.

Reviewing correspondence and documents that have been disclosed to us and third parties which may contain your personal data and disclosing such correspondence and documents to various parties in furtherance of our mutual objectives.

Advising you and instructing third parties on behalf of you.

Ensuring that our systems and premises are secure and running efficiently.

For regulatory and legislative compliance.

For audit and reporting.

For general business development purposes.

To allow for all of the above, the secure management and storage of your personal data within our IT and, in some cases, hard copy filing systems.

IF YOU ARE A CONSULTANT, the controlling and / or processing of your personal data will be necessary to fulfil Blackstar’s obligations to you as your contracting partner including, without limitation:

To make a decision about whether we engage you as a consultant.
To determine the terms of your consultancy
To contact you.
To fulfil our obligations to you under the consultancy terms

Reviewing correspondence and documents that have been disclosed to us, our clients

and third parties which may contain your personal data and disclosing such

correspondence and documents to various parties in furtherance of our mutual

objectives.

Advising clients and instructing third parties on behalf of our clients.
Ensuring that our systems and premises are secure and running efficiently.
For regulatory and legislative compliance.
For audit and reporting.
For general business development purposes.
For insurance purposes.
For receiving payments and making payments.
To allow for all of the above, the secure management and storage of your personal data within our IT and, in some cases, hard copy filing systems.

Change of purpose

We will only use your personal data for those situations listed above, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If Blackstar needs to use your personal data for an unrelated purpose, you will be notified, and we will explain the legal basis which allows us to do so.

Collection and Processing of your personal data – some points.

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

When you give your personal data to Blackstar, some of the personal data you provide will need to be given to and processed and stored by relevant third parties and may also be shared with other companies for the purposes of providing services to you (or directly to your fans, followers, or customers if applicable) including but not limited to, the operation and maintenance of social media pages and websites. Blackstar requires such third parties to respect the security of your data and to treat it in accordance with GDPR and we will not share or use your personal data in a way you would not expect under our contractual relationship with you.

Some of these third parties may be based outside of the EEA.

When we transfer your information outside of the EEA in this way, we take steps to ensure that your personal information will be subject to one or more appropriate safeguards set out in data protection law including imposing contractual obligations on the recipient of your personal information or ensuring that the recipients are subscribed to ‘international frameworks’ that aim to ensure adequate protection, such as the US ‘Privacy Shield’ scheme.

These parties can be categorised, but are not limited to, those third parties set out in the table below.

Recipient / Relationship to us	Industry Sector (& subsector)	Location travel
Agency Clients	Media (marketing, advertising & PR departments of various industries including but not limited to music and entertainment services sectors)	EEA & USA
Cloud based hosting & storage services, marketing platforms, social & digital & email marketing tools & technologies, business management & file management platforms & tools, software system providers including database, email and document management providers.	IT (Cloud Services)	EEA & USA
Social Media Platforms	Media (Social Media)	EEA & USA

Blackstar will seek and secure your explicit consent for transferring your personal data outside the EU in circumstances where (a) the transfer is not necessary for the fulfilment of our obligations to you under any relevant agreement; (b) the EU Commission has not made an adequacy decision in respect of the country in which the recipient of the personal data is based; (c) the transfer of the personal data is not subject to appropriate safeguards as set out in Article 46 of the GDPR; (d) there are no binding corporate rules in place; or (e) no other derogation is applicable.

Sensitive Personal Data

Some of data held by us may fall within a so-called "special category" of more sensitive personal data such as: (a) information about your race or ethnicity, religious beliefs, sexual orientation and political opinions; (b) information about your health, including any medical condition, health and sickness records; (c) genetic information and biometric data.

The legal bases for Blackstar collecting, storing and/ or using more sensitive personal data and the circumstances in which this is permitted are:

With your explicit consent: to collect, hold and disclose data concerning your health to third parties e.g. where disclosure of your health records or a medical examination is a condition of your engagement as a consultant with us. Where we are controlling and / or processing such data with your consent, you have the right to withdraw such consent at any time.
Controlling and / or processing is necessary to protect your vital interests or those of another natural person. To collect, hold and disclose data concerning your health to third parties e.g. where disclosure of your health records is necessary for a medical emergency.
The personal data Blackstar wishes to process has manifestly been made public by you.
Controlling and / or processing is necessary for the establishment, exercise or defence of legal claims or whenever Courts are acting in their judicial capacity.
Controlling and / or processing is necessary for reasons of substantial public interest.

Keeping your Personal Data secure

The transmission of information via the internet is not completely secure, and although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted, therefore any transmission is at your own risk.

Blackstar has 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.

We limit access to your personal data to our consultants and contractors and other third parties who have a business need to know. They will only process your personal data on Blackstar’s instructions.

All the information you provide to us is stored securely on cloud-based servers via central / shared systems or under Blackstar consultant password protected email accounts and file systems provided by Google services, whereby each user has to enter a two factor authentication for added security.

Email accounts and IT systems are password protected and Blackstar consultants (and no one else) have access to those systems and accounts to which we have given them specific authorisation.

Blackstar has put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where it is legally required to do so.

Blackstar provides creative, digital and social media services for businesses / organisations, which include, but are not limited to, social media pages and websites which may contain external links or use of third parties. If you follow a link or otherwise use any of these other websites or third parties, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or for these third party services. Please check these policies before you submit any personal data to these websites.

We may need to request specific information from you to help confirm your identity and ensure your right to access the information (or to exercise any of your other rights – see below). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Personal Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of our contractual relationship with you and for satisfying any business, legal, accounting, or reporting requirements. Please refer to our Data Retention & Erasure Policy.

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 control and / or processes your personal data and whether or not we can achieve those purposes through other means.

In some circumstances Blackstar may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Notwithstanding that you may no longer be a client or consultant of Blackstar, we may retain your personal data, but for no more than the time required for the specific purposes for which it is controlled and / or processed by us, as set out in this Privacy Notice or where required by applicable laws and regulations. We will ensure that such data will continue to be treated in accordance with this Privacy Notice.

Cookies

Please refer to our Cookie Policy (insert link).

Your duty to us

It is important that the personal data we hold about you is accurate and current. Therefore, please keep us informed if your personal data changes so that we can update our records. Please inform your usual contact at Blackstar, or email us at [ privacy@blackstarlondon.com ].

Your rights regarding your Personal Data

You have the right to:

Request access to your personal data. You are entitled to receive a copy of the personal data we hold about you and to check that we are in fact lawfully processing it.

Request correction of the personal data that we hold about you.

Request erasure of your personal data. You may ask us to delete or remove personal data where there is no good reason for us to continuing to process it.

Object to us controlling and / or processing 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 controlling and / or processing on this ground.

Object to us controlling and / or processing your personal data for direct marketing purposes.

Request that we suspend controlling and/ or processing of your personal data in certain circumstances such as you want us to establish to you the reason for processing it.

Request the transfer of your personal data to another party.

If you wish to do any of the above, please email us your request to [ privacy@blackstarlondon.com ].

You will not normally 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 for access appears to be unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

You do not have to share your personal data with us. However, if you fail to provide certain information when requested, we may not be able to honour our obligations to you, whether contractual, legal or otherwise, such as paying you if you are a consultant or, if you are a client, providing creative, digital and social media services to you.

Your right to withdraw consent

Where you may have provided your consent to the collection, controlling, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific purpose at any time.

To withdraw your consent, please contact your usual contact at Blackstar or email [ privacy@blackstarlondon.com ]. Once we receive notification that you have withdrawn your consent, we will no longer control and / or process your personal data for the purpose or purposes you originally agreed to, unless we have another legal ground for doing so in law.

Updates to this Privacy Notice

We may change, revise, update this Privacy Notice at any time. We may also notify you in other ways from time to time about the controlling and / or processing of your personal data.

Questions, concerns, complaints

If you have any questions about this Privacy Notice, or questions or concerns or complaints about the way Blackstar controls and / or processes your data, please email us at [ privacy@blackstarlondon.com ].

You may also address a complaint to the Information Commissioner, who can be contacted the following address: Information Commissioner’s Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF or at www.ico.org.uk or on Helpline number 0303 123 1113.

Thank you!

BLACKSTAR LONDON.

This Privacy Notice was last updated in November 2019.