PRIVACY POLICY

Last Updated: 10 November 2021

INTRODUCTION

Talenthouse IP LLC, a company registered in the United States under company number 6268714 and whose registered office is 827 Santa Barbara Dr., Farmington, NM, 87401, USA (“Talenthouse”, “we”, “us” or “our” in this policy), together with its group companies, operates the Talenthouse Media Foundry Platform available at the site [mediafoundry.talenthouse.com] and all iterations of the Talenthouse Media Foundry Platform (including, where available, the mobile and tablet apps) (together “Services”). The Talenthouse Media Foundry Platform is a collaboration platform for a community of game developers, art directors, technologists, financiers and members of all other disciplines associated with the advancement of new game concepts.

This Privacy Policy explains how we will process the personal data relating to the Services which allow:

  • Creators and Artists to use our Platform to submit creative works
  • Game Developers and Agencies to to find and accept creative works
  • Game Lovers to to see artwork and follow Creators from around the world

If you have any questions or comments about this Privacy Policy, please contact us at support@talenthouse.com

We are committed to protecting and respecting your privacy. The Privacy Policy explains the basis on which personal information we collect from you will be processed by us or on our behalf. Where we decide the purpose or means for which personal data you supply through the Services is processed, we are the “data controller.” We will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679 (“GDPR”) and the UK GDPR. Please read this Privacy Policy carefully as it contains important information about the following:

  • What information we may collect about you;
  • How we will use information we collect about you;
  • Whether we will disclose your details to anyone else; and
  • Your choices and rights regarding the personal information you have provided to us.

The Services may contain hyperlinks to services owned and operated by third parties. These third party services may have their own privacy policies and we recommend that you review them. They will govern the use of personal information that you submit or which is collected by cookies and other tracking technologies whilst using these services. We do not accept any responsibility or liability for the privacy practices of such third party services and your use of these is at your own risk.

We may make changes to this Privacy Policy in future, which will be posted on this page. Where appropriate we will notify you of changes through email or your account on the Platform.


INFORMATION WE MAY COLLECT ABOUT YOU

We collect and process the following information which may include your personal data.


WHEN YOU SIGN UP TO OUR NEWSLETTER

When you sign up to our Newsletter on our website, we will collect your email address.


WHEN YOU CONTACT US OR USE THE SUPPORT SERVICE

We provide our support services via our website and by email. Such information may include:

  • First Name and Last Name
  • Email address with which you have signed up to your Platform account
  • The element of the Services causing an issue for you A description and / or screenshots of the issue you are experiencing
  • Content files, where relevant
  • If you don’t provide this information, we may not be able to help.

Where you are a Creator/Artist using our Platform

You may give us information about you by filling in forms when setting up your Creator account with us. Such information may include:

  • First and last name
  • Email address
  • City/state and country
  • Month and year of birth
  • Creative Interests
  • Gender (optional)
  • Pronoun (optional)

On your profile page, you may provide additional voluntary information that is made visible on your profile to other users (being other Creators, Games Developers & Agencies and Games Lovers). This may include:

  • Profile picture
  • Social media channel links
  • Personal website
  • Upload your existing work

If you are selected by a Games Developer or Agency as a Selected Creator, or a finalist in a competition (i.e. Brief), we collect and store the following additional personal information:

  • Photo ID (driving license or passport)
  • Postal address
  • Bank account details for payment processing
  • Signed agreements or rights releases

WHERE YOU ARE A GAMES DEVELOPER/AGENCY USING OUR PLATFORM

You may give us information about you by filling in forms when setting up your Games Developer/Agency account with us. Such information may include:

  • First and last name
  • Email address
  • Job title and company
  • City/state and country
  • Date of birth
  • Gender
  • Creative interests

WHERE YOU ARE A GAMES LOVER USING OUR PLATFORM

You may give us information about you by filling in forms when setting up your Games Lover account with us. Such information may include:

  • First and last name
  • Email address
  • City/state and country
  • Month and year of birth
  • Gender (optional)
  • Pronoun (optional)

WHERE YOU USE COMMENT FUNCTIONALITY ON OUR SERVICES OR INTERACT WITH OTHER USERS

You may give us information about you by using the comment functionality or otherwise interacting with other users of the Services. The information you provide in this respect is entirely up to you. Please do not share personal data about third parties or any sensitive personal data about yourself.


INFORMATION COLLECTED FOR THE PURPOSES OF ANALYTICS

When you visit our Platform we collect technical information about your use of the Platform, including the number of visitors, where visitors have come to the Platform from and the webpages or app screens they visited while on the Platform. We collect the following data points: Average Pages per website sessions, where our users come from, device and operating system, time of day that the Platform is used, general location, average time on page, button clicks, number of views on a page, depth of scroll down a page, number and location of submissions to a Brief, email open and click through rate, whether a visitor is a new or returning visitor. Our Platform uses cookies and other mechanisms to collect and log this analytical information. To find out more about the use of cookies, please see our cookie policy here.


INFORMATION COLLECTED IN RELATION TO SOCIAL MEDIA CHANNELS

If you post or upload any content about our Services on Facebook, Twitter, Instagram or Twitter, this will be under these social media platform's respective privacy policies which can be found at on their websites.
Where you follow us or interact with our content, we may be able to see personal information from your social media profile (depending on your social media privacy settings), including:

  • Name (and/or your social media unique user name);
  • Email and/or postal address;
  • Location;
  • Telephone number(s);
  • IP or MAC address;
  • Gender and/or age;
  • Correspondence with us through those channels; and
  • General interests and preferences (e.g. Likes, Follows, Shares, Posts)

WHY WE COLLECT INFORMATION ABOUT YOU

TO SEND YOU OUR EMAIL MARKETING

We may process your name and email address for our mailing list in the following way:

  • Consent-based mailing lists: We may process your data to keep you updated with information on news, offers, and updates about us. We rely upon your consent in order for us to undertake this data processing activity. You can revoke your consent at any time. Please let us know by clicking unsubscribe at the bottom of any marketing email that you receive.
  • ‘Soft opt-in’ or B2B mailing lists: In some instances (such as with our existing UK customers) the law may permit us to process your personal information in order to send information to you by email that we think is of interest for you and/or your business on the basis of our legitimate interests, being our legitimate interest to promote our business. If you would like to be removed from that list please let us know by clicking unsubscribe at the bottom of any marketing email that you receive.

To provide our Services to you

We may use and retain your personal data where necessary to perform the contract we are about to enter into or have entered into with you, such as to:

  • Provide our website
  • Register you as a new user
  • Manage accounts
  • Administer briefs
  • Identify relevant and available creators for private briefs
  • Fulfill any awards to selected and commissioned Creators
  • Deliver our Services to you or to ensure that the Services function properly and deliver the features promised.

TO OFFER A FUNCTIONALITY TO INTERACT WITH OTHER USERS

We may offer comment functionality or similar forums where you and other users of the Services can communicate. Any information you share in a public forum is public information and may be seen or collected by anyone. We are not responsible for the effects of the distribution of any information you choose to publicly post or share through our Services. We will process information about you for delivering the functionality to you under the terms of use agreed between us. The processing of information in this way is necessary for us to ensure the Services deliver the features promised and function properly, so that you have the best experience when using this comment/ interaction functionality.


TO FULFILL OUR ANTI-MONEY-LAUNDERING OBLIGATIONS

We may request specific information from you to help us confirm your identity under the Know Your Customer (AML Regulations), to verify your identity prior to paying financial incentives to Selected Creators / Finalists or those providing commissioned work under the AML Regulations. We will process information about you in this way to comply with our legal obligations.


TO HELP US IMPROVE THE SERVICES AND FIX ANY PROBLEMS

We may process information about you so that we can analyse and improve our Services through knowledge of how the Services are used. This processing is based on your consent, or undertaken where it is necessary for us to pursue our legitimate interests of (i) ensuring that our Services function properly so that you and other users have the best experience; (ii) improving the quality of our Services; and (iii) identifying and correcting any bugs.

Our Services use cookies and other mechanisms to collect and log analytical information. To find out more about the use of cookies, please see our cookie policy here.


TO RESPOND TO YOUR ENQUIRIES AND REQUESTS FOR SUPPORT

We may process information so that we are able to properly respond to your enquiries and support requests. This processing is necessary for us to pursue our legitimate interests of (i) ensuring that our Services function properly so that you and other users have the best support and experience; (ii) improving the quality of our Services; and (iii) identifying and correcting any bugs.


TO PREVENT FRAUD AND ILLEGAL ACTIVITY

We process personal data for our legitimate interests of ensuring that any use of the Services is lawful and non-fraudulent, does not disrupt the operation of our services, does not harass our staff or other individuals, to enforce our legal rights, and to investigate complaints. We also process personal data to comply with our regulatory and corporate governance obligations. Where we reasonably believe that you are or may be in breach of any applicable laws or our terms of use, we may use your personal information to inform relevant third parties such as your law enforcement agencies about the content.


DATA SHARING

We will share your information with third parties only in the ways that are described in this Privacy Policy

Group members: We seek to keep your information confidential, but may disclose it to any member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006) insofar as it is reasonably necessary for the purposes set out in this Privacy Policy.

Suppliers: We also share your information with our carefully selected suppliers that carry out certain functions for us and we only provide them with as little personal data as possible to carry out these functions. The organisations that will receive your personal data, as part of our doing business are as per this list https://www.talenthouse.com/legal-affiliates.

Merger or acquisition: If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via, account message and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information. Required by law: In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention). Enforcement: We may also disclose your personal information to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches, or to protect the rights, property or safety of us, our users, or others.


YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU

You have the following rights over the way we process personal data relating to you, as set out in the table below. We aim to comply without undue delay, and within one month at the latest. To make a request, please let us know by sending an email to support@talenthouse.com.

Ask for a copy of data we are processing about you and have inaccuracies corrected

You have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected. We will use reasonable efforts to the extent required by law to supply, correct or delete personal information held about you on our files (and with any third parties to whom it has been disclosed to).


OBJECT TO US PROCESSING DATA ABOUT YOU

You can ask us to restrict, stop processing, or to delete your personal data if:

  • you consented to our processing the personal data, and have withdrawn that consent;
  • we no longer need to process that personal data for the reason it was collected;
  • we are processing that personal data because it is in the public interest or it is in order to pursue a legitimate interest of ours or of a third party, you don’t agree with that processing, and there is no overriding legitimate interest for us to continue processing it;
  • the personal data was unlawfully processed;
  • you need the personal data to be deleted in order to comply with legal obligations;
  • the personal data is processed in relation to the offer of a service to a child.

OBTAIN A MACHINE READABLE COPY OF YOUR PERSONAL DATA, WHICH YOU CAN USE WITH ANOTHER SERVICE PROVIDER

  • If we are processing data in order to perform our obligations to you, or because you consented, or if that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems.
  • If you request, we will supply you with the relevant personal data in a commonly used, machine-readable and interoperable format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.

MAKE A COMPLAINT TO A SUPERVISORY AUTHORITY

  • If you are unhappy with the way we are processing your personal data, please let us know by contacting us via the support services.
  • If you do not agree with the way we have processed your data or responded to your concerns, an alternative is to submit a complaint to a Data Protection Supervisory Authority. We are registered with the UK regulator, the Information Commissioners Office (ICO).

DATA RETENTION

We will retain your data for no longer than is necessary and in any event no longer than 7 years from the date of last use. In these limited circumstances we may retain your information after your relationship with us has ended. For example, we may need to take into consideration any regulations that we must fulfill, such as for auditing purposes or for legitimate business purposes.


CHILDREN

We do not use our Services to knowingly solicit information from or market to children under the age of 18. Our terms of use prohibit users aged under 18 years from accessing our Services. In the event that we learn that we have collected personal information from a child under 18 years of age we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 18 years of age please contact us at support@talenthouse.com.


SECURITY

We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal information.
Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.


INTERNATIONAL DATA TRANSFERS

Our servers are located in the United States. The entities within our group may receive your data, and it will be transferred outside of the European Union and the UK within our group and to our providers who deliver services to us. Where we transfer your information outside of the UK and/or EEA, we will have agreements in place with the recipient which include (where necessary) standard data protection clauses adopted by a data protection regulator and/or approved by the European Commission to ensure that appropriate safeguards are in place to protect your personal data. If you would like to find out more about these safeguards, please let us know by writing to support@talenthouse.com.

CONTACT INFORMATION

All questions, comments or enquiries should be directed to us at support@talenthouse.com