We respect the privacy of every person who visits AKA’s website and/or uses the services made available by us from the AKA website (the “AKA Service”) and we are committed to ensuring a safe online experience.
1 Purpose of this Notice
This privacy notice explains our approach to any personal information that you might supply to us (or that might be collected from you) in connection with your use of the AKA Service and sets out your rights in respect of AKA’s processing of your personal information. For more information see below.
This privacy notice will inform you how you can verify which of your personal information is collected by us through the AKA Service and how you can request that we delete, update or transfer it.
Please also note that this privacy notice only applies to the use of personal information collected by us from your use of the AKA Service or during your communications with us. It does not apply to personal information collected during your communications with third parties.
2 Who are we and what do we do?
The AKA Service is operated by the AKA Group Limited (“AKA”) which is a global entertainment agency. For more information see below.
AKA is the data controller responsible for your personal information. AKA is registered at the UK Information Commissioner’s Office with registration number: [INSERT].
AKA is an English company with registered company number: 5492853 and whose principal address is 115 Shaftsbury Avenue, Cambridge Circus, London, WC2H 8AF.
3 How to contact us?
If you have any questions about this privacy notice or want to exercise your rights, please contact us by:
• sending an email to email@example.com;
• writing to us at AKA Group Limited, 115 Shaftsbury Avenue, Cambridge Circus, London, WC2H 8AF.
4 What personal information do we collect and how do we collect it?
Our primary goal in collecting personal information from you is to give you an enjoyable experience while allowing us to provide services and features that most likely meet your needs. In order to do so personal information may be collected from you in the following ways:
• Information you voluntarily provide to us. For more information see below.
We collect and maintain personal information that you voluntarily submit to us during your use of the AKA Service.
If you contact us, we may collect additional information from you such as a telephone number or email address.
• Information we collect through your use of AKA. For more information see below.
• IP address of device(s) used;
• browser type;
• operating system and device type;
• approximate location (e.g. London);
• access times and dates; and
• referring website addresses.
We may also collect personal information regarding your use of and activity on the AKA Service.
5 How do we use your personal information?
We collect and use your personal information to operate the AKA Service efficiently and to deliver you the very best service. In particular, we may use your personal information for the following purposes:
• Provision of the AKA Service. For more information see below.
We shall use your personal information to provide the AKA Service to you.
What is our legal basis?
It is necessary for us to use your personal information to provide the AKA Service to you and perform our obligations in accordance with any contract that we may have with you. It is also in our legitimate interest to use your personal information in such a way to ensure that we provide the very best service we can.
• Service administration. For more information see below.
We may use your personal information to:
- develop and improve the AKA Service;
- send you administrative e-mails about the AKA Service; and
- contact you to answer any queries you may have.
What is our legal basis?
It is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best service we can.
• User Data Analysis. For more information see below.
We may use your personal information on an anonymised basis to analyse, benchmark and conduct research on users and their interactions with the AKA Service and AKA.
What is our legal basis?
Where your personal information is completely anonymised, we do not require a legal basis as the information will no longer constitute personal information. However where your personal information is in a pseudonymised form, it is in our legitimate interest to continually evaluate that personal information to ensure we are aware of market trends and ensure that the services we provide are relevant to you.
• Internal record keeping and legal compliance. For more information see below.
What is our legal basis?
• Marketing by us. For more information see below.
Where you consent, we may use your personal information to contact you by e-mail about our products and/or services.
What is our legal basis? Your consent.
• Sharing information with third party processors. For more information see below.
We may share your personal information with third party processors in order to provide the AKA Service and associated products and services to you.
What is our legal basis?
It is in our legitimate interest to share your personal information in such a way to ensure that we provide the best service we can.
• Sharing information with professional advisors, governmental authorities & potential purchasers. For more information see below.
We may share your personal information with professional advisers or governmental or regulatory authorities:
- to enable them to process your personal information on our behalf in a manner consistent with this privacy notice;
- to comply with our legal obligations;
- to enforce our legal rights; or
- protect rights of third parties.
Your personal information may also be shared with prospective buyers if we go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.
What is our legal basis?
It is in our legitimate interest to share your personal information with such third parties to enable them to process your information on our behalf, to comply with and/or enforce our legal rights and obligations, to protect the rights of third parties and to facilitate business transitions.
Any other purposes for which we wish to use your personal information will be notified to you from time to time including the legal basis of such use.
6 How do we obtain your consent?
Where use of your personal information by us requires your consent, you can provide such consent:
• at the time we collect your personal information following the instructions provided; or
• by informing AKA by e-mail using the contact details set out in this privacy notice.
You are required to be at least 18 years old to use the AKA Service so we do not intentionally collect personal information from anyone under 18, and no one under 18 should attempt to submit any personal information to AKA. Should we discover that any such personal information has been delivered to any of the sites, we will remove that personal information as soon as possible.
9 Third Party Links and Services
The AKA Service may contain links to third party websites and services. Please remember that when you use a link to go from AKA to another website or you request a service from a third party, this privacy notice no longer applies. For more information see below.
Your browsing and interaction on any other website, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies.
We do not monitor, control, or endorse the privacy practices of any third parties.
We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.
This privacy notice applies solely to personal information collected by us through the AKA Service and does not apply to these third party websites and third party service providers.
The AKA Service may also contain advertisements for, and/or the opportunity for you to purchase products or services from third parties. If you would like more information about this practice and to know your choices about not having this personal information used by these companies, click here: http://www.advertising.com/Privacy.html
10 Transfers outside the EEA
Although our offices and servers are based within the European Economic Area, in certain circumstances we may transfer your personal information, for the purposes listed above, to our affiliates or other third parties that may be located in countries outside the European Economic Area, whose laws are not recognised by the EU Commission as providing an adequate level of protection to personal information.
11 How long do we keep your personal information for?
We keep your personal information only for as long as necessary to fulfil the purpose it was collected for, where we need to in relation to proving legal relationships or to comply with any of our legal obligations.
12 Confidentiality and security of your personal information
We are committed to keeping the personal information you provide us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration. For more information see below.
We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:
• unauthorised access;
• improper use or disclosure;
• unauthorised modification; and
• unlawful destruction or accidental loss.
All our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of the AKA Service.
13 How to access your information and your other rights?
You have the following rights in relation to the personal information we hold about you:
• Your right of access. For more information see below.
If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
• Your right to rectification. For more information see below.
If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
• Your right to erasure. For more information see below.
You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
• Your right to restrict processing. For more information see below.
You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.
• Your right to data portability. For more information see below.
With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere.
• Your right to object. For more information see below.
You can ask us to stop processing your personal information, and we will do so, if we’re:
- relying on our own or someone else’s legitimate interests to process your personal information except if we can demonstrate compelling legal grounds for the processing;
- processing your personal information for direct marketing; or
- processing your personal information for research unless such processing is necessary for the performance of a task carried out in the public interest.
• Your rights in relation to automated decision-making and profiling. For more information see below.
You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, and it produces a legal effect or similarly significantly affects you unless such profiling in necessary for entering into, or the performance of, a contract between you and AKA.
• Your right to withdraw consent. For more information see below.
If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.
• Your right to lodge a complaint with the supervisory authority. For more information see below.
If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.
To exercise your legal rights please notify us using the contact details provided in section 3 of this privacy notice.
14 Change to this privacy notice
We may make changes to this privacy notice from time to time. For more information see below.
To ensure that you are always aware of how we use your personal information we will update this privacy notice from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We may notify you by e-mail of any significant changes. However, we encourage you to review this privacy notice periodically to be informed of how AKA uses your personal information.