PRIVACY POLICY
Last updated September 30, 2019
INTRODUCTION
This Privacy Policy applies to information that Coast to Coast Talent Group, Inc. and its parent, subsidiary and affiliated entities (individually referred to herein as “CTC” or “the Company” or “we” or “us” or “our”) collects about you in connection with the services provided by CTC to you and/or visit to the https://www.ctctalent.com/ website (each referred to herein as a “Site” and collectively, the “Sites”).
This Privacy Policy describes how we collect such information, how we use it and to whom and under what circumstances we may disclose it. Personal Information includes your name, postal address, zip or postal code, email address, telephone number, date of birth, payment information, demographic information, personal identification number, details on your bookings, deals and/or projects, and other information you choose to provide us, and for purposes of the California Consumer Privacy Act (CCPA), any information that directly or indirectly identifies, describes, relates to, is capable of being associated with, or can reasonably link to a particular consumer or household such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person (“Personal Information”).
The Personal Information we collect is stored and/or controlled by CTC. In Los Angeles, CA.
We may share and use your Personal Information with our parent, subsidiary and affiliated entities for use in connection with their services. If the Company becomes involved in a merger, acquisition, asset sale, or similar transaction, such as a sale of a particular product line or division of our business, CTC may share or transfer your Personal Information in connection with the transaction and your Personal Information may become subject to the privacy policy of another entity.
CALIFORNIA PRIVACY RIGHTS
Section 1798.83 of the California Civil Code provides that residents of California can obtain certain information about their personal information (as defined under Section 1798.83(e)(6) of the California Civil Code) that companies have shared with third parties for direct marketing purposes during the preceding calendar year, as well as the identity of those third parties. Personal information, as defined under the California Civil Code, includes, but is not limited to, data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, the possession of the data controller. To request a copy of your personal information maintained by us, please contact us at privacy@ctctalent.com
INFORMATION YOU PROVIDE TO US
We (or our service providers) collect information from you when you: (1) become a client of ours or otherwise use our services; (2) are booked on a job or placed on a project by us, (3) apply for a job with us; or (4) contact us, or otherwise communicate with us or provide information to us.
When you visit our website, we may also collect anonymous information such as your IP address or domain name to analyze website traffic, but this information is not personally identifiable. We may use this information to help diagnose problems with our server, to administer our website, or to display the content according to your preferences. Traffic and transaction information may also be shared with business partners and advertisers on an aggregate and anonymous basis.
In the event that you ever provide information to us about another person, you represent that you have the authorization of such person to provide us with such information.
We may combine your (and others’) information that we have collected from you (or others) with information we may receive from other sources, such as third-party social media platforms address update services and co-promotion partners. By accessing our website or accepting our services, you signify your consent to the above collection of your Personal Information.
If you do not want us to collect your Personal Information, please do not provide it to us. You can update your information with us at any time. In addition, you can revoke your consent to us using your Personal Information by contacting us at privacy@ctctalent.com, but doing so may prevent us from properly representing you or providing our services.
If you receive an email or other correspondence requesting that you provide any sensitive information via email or to a web site that does not seem to be affiliated with us or that otherwise seems suspicious to you, please do not provide such information, and report such request to us privacy@ctctalent.com
SITE INFORMATION & OTHER INFORMATION COLLECTED AUTOMATICALLY
As part of the standard operation of the Sites, certain information may be collected automatically or passively from or about you in connection with your visit to the Sites. Our servers may automatically gather some of the Site Usage Information (as defined below) or we (or our service providers) may use cookies and other tracking technologies to collect and track such information.
Site Usage Information includes, but is not limited to: (i) your browser type, device type, carrier (if applicable), device address, operating system, operating system address, IP address and the domain name from CTC you accessed a Site; (ii) information about your region, continent, country, city, zip code, time zone, and general location; and (iii) information about your browsing activities on and through a Site (also known as “Click Stream” data), such as (a) the date and time you visit one of the Sites, (b) the areas or pages of a Site that you visit, (c) the amount of time you spend viewing a Site or specific areas of a Site, (d) the number of times you return to a Site or a specific area of a Site, (e) the web sites or pages you visited prior to visiting a Site, (f) the websites or pages you visit after you leave a Site; (g) searches you have performed on a Site and on other websites that led you to our Sites; (h) social plug-ins with CTC you have interacted on our Sites; and (j) other similar Site usage data (collectively, the “Site Usage Information”).
We consider this Site Usage Information, on its own, to be non-personal in nature, unless required otherwise by applicable law. However, we may combine Site Usage Information about you with Personal Information about you, and we would consider the combined information to be “personally identifiable” or Personal Information for the purposes of this Privacy Policy.
COOKIES AND OTHER TRACKING TECHNOLOGIES
We and our service providers may use cookies, pixel tags, web beacons, Adobe Flash Technology and other similar technologies, which allow us to, among other things, optimize our Sites and to understand traffic and usage patterns. Additionally, if the settings on your location-aware device allow us to receive geo-location data or information, we may collect that information automatically.
A cookie is a small data file that is sent to your web browser and placed on your computer or device when you access a website. Cookies allow parties (including us, our service providers and others) to: (i) track your activities on the Sites, (ii) track clicks, orders and conversion; (iii) recognize your computer or device so that you are able to save your preference and stay logged in to the Sites without having to re-enter your Account credentials; (iv) deliver customized content, messages and advertising to you; (v) preserve the contents of your shopping cart; (vi) and otherwise enhance and personalize your experience on the Sites. If you do not want information collected through the use of cookies, most devices allow you to decline the use of cookies. We recommend that you leave cookies turned on because if you elect not to allow them, you may not be able to use or to enjoy all of the services and features of the Sites.
We may use Flash cookies and other similar technologies, which allow a website to store certain information locally on an individual’s computer or device and then access and use that information to enhance and facilitate certain Site experiences, processes and functionality. Flash cookies are different from other cookies and may not be removed in the same manner. More information about both kinds of cookies is available at www.allaboutcookies.org.
We also may use web beacons (also known as “clear GIFs” or “pixel tags”) for similar purposes as cookies. These beacons are typically one-pixel images that are embedded in the Site or in a communication, such as an email message. These technologies help us to verify when a certain page of a Site is viewed, when a message is opened and when links or other content in a message are clicked or viewed.
We may use third party web analytics services, such as Google Analytics and Adobe services, to help us track and analyze the use of our Site and to measure the effectiveness of our advertising, Site content, and communications.
DO NOT TRACK
We currently do not participate in any “Do Not Track” frameworks that would allow us to respond to signals or other mechanisms from you regarding the collection of your information. We may engage third parties, such as marketing or analytics partners, who may collect information about your online activities over time and across different websites when you use our website. To learn more about browser tracking signals and “Do Not Track,” please visit http://allaboutdnt.org.
INFORMATION USE
We may use the information we collect from and about you (including Personal Information) for a variety of purposes, including but not limited to the following:
(i) To represent you and provide our services to you; (ii) to provide you with offers and employment opportunities; (iii) subject to your communications preferences and, where required by applicable law, subject to your consent, to contact you (via postal mail, email and the like) with materials about us, our services and our events, as well as materials and information related to employment opportunities and relevant projects; (iv) to contact you when necessary or appropriate to discuss your career and related items, and to review and improve our services; (v) to protect the security or integrity of your information and our business; (vi) and otherwise, with your permission or as permitted by law.
If you provide us with information about another person (as described above in the “Information You Provide To Us” section), where permitted applicable by law, we use that information to fulfill your requests and treat such information in accordance with this Privacy Policy.
FINANCIAL INFORMATION
To use certain aspects of our services, such as collecting our commission and remitting your compensation to you from bookings, we may require bank account information and a check authorization request from you. By submitting such account information through us or our services, you expressly consent to the sharing of your information with third party merchants, billing processors, and payment processors. These third parties and the Company may store your account information so you can use our services in the future. While we require that such third party merchants, billing processors, and payment processors use reasonable procedures to help protect your account information, we cannot guarantee that transmissions of your account information or Personal Information will always be secure or that unauthorized third parties will never be able to defeat the security measures taken by us or our third-party service providers. We assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third-party access, or other causes beyond our control.
INFORMATION DISCLOSURE
We may disclose information we collect (including your Personal Information) in the following ways to third parties, to the extent permitted by law: To potential employers on your behalf, i.e., to submit you for auditions and for roles or other work in motion pictures, television shows, commercials and other entertainment projects to studios, production companies and similar parties;.
To our service providers and suppliers, who collect or use such information for us or on our behalf (such as website or database hosting companies, address list hosting companies, email service providers, analytics companies, distribution companies, fulfillment companies, and other similar entities that help us to operate the Site and/or provide functionality, content and services);
CTC companies and affiliated entities; Auditors and professional advisers like bankers, lawyers, accountants, personal and business managers and insurers solely as necessary and under obligations of confidentiality; As necessary, if we believe that there has been a violation of the Company policies, or if we have reason to believe that our rights or property, or the rights or property of any third party, may be or have been harmed; To respond to subpoenas or other judicial processes, or to provide information as requested by law; In the event that CTC or substantially all of its assets are acquired by one or more third parties as a result of an acquisition, merger, sale, consolidation, bankruptcy, liquidation or other similar corporate reorganization, where your information may be one of the transferred assets; and As otherwise, with your permission or as permitted by law.
Content and information that you submit on or through Facebook, Twitter, Instagram, Tumblr and other third-party platforms may appear on our website through feeds from and other interfaces with those platforms. We are not responsible for the information, content and/or privacy practices of any such third-party platforms.
We may also share data with 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 Policy
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YOUR CHOICES / YOUR PRIVACY RIGHTS / HOW TO UNSUBSCRIBE
If you would like to opt out of receiving direct mail from us, please contact us at privacy@ctctalent.com. Please understand that if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions and communications with us.
If you would like to opt out of receiving promotional emails from us, please follow the unsubscribe instructions located in each such email or contact us at privacy@ctctalent.com. Please understand that if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions and communications with us.
We do not sell or share your Personal Information with third-party marketers, but you may nonetheless confirm this by contacting us at privacy@ctctalent.com and/or clicking the Do Not Sell My Personal Information link on our website.
CONSENT
By consenting to this Privacy Policy you are giving us permission to process your Personal Information specifically for the purposes identified.
You may withdraw consent at any time by contact us at privacy@ctctalent.com. 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.
MAINTENANCE AND PROCESSING OF INFORMATION IN THE U.S. AND OTHER COUNTRIES
Your personal and other information may be stored, transferred and processed in and to the United States. By providing Personal Information to us, you consent to the collection, maintenance, processing and transfer of such information in and to the United States and other countries and territories, pursuant to the laws of the United States or such other jurisdictions, which may provide lesser privacy protection than the laws of other countries, and you acknowledge that your information may thus be subject to U.S. laws and accessible to the U.S. government, courts, law enforcement and regulatory agencies.
ACCESS TO YOUR PERSONAL INFORMATION
At any point while we are in possession of or processing your Personal Information, you have the following rights:
Right of access – you have a right to request disclosure of your Personal Information, and to receive additional details regarding the Personal Information we collect and its use purposes, including any third parties with which we share your Personal Information. You also have the right to request a copy of the information that we hold about you.
Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records and request that we instruct our third party service providers to do the same.
Right of portability – in response to a request for disclosure, you have the right to have the Personal Information we hold about you in a readily usable format.
Right to Opt-Out – you have the right to opt-out of sales of your Personal Information to third parties. Again, we do not sell your Personal Information to any third parties for marketing purposes, but pursuant to the CCPA, we are disclosing this right to you in our Privacy Policy.
Third parties must also give consumers explicit notice and an opportunity to opt out before re-selling personal information that the third party acquired from another business.
In the event that CTC does not taken action with respect to a request to exercise any of your rights listed above, we will provide you with a reason as to why.
SECURITY
We have implemented measures in an effort to safeguard the Personal Information in our custody and control. Such measures include, for example, limiting access to Personal Information only to employees and authorized service providers who need to know such information for us to provide our services to you and for the purposes described in this Privacy Policy, as well as other administrative, technical and physical safeguards. Additionally, our service providers are not authorized to use or disclose your Personal Information for any purpose other than providing the services to us or on our behalf, or as otherwise may be required by applicable law. While we endeavor to always protect our systems, due to the inherent nature of the Internet as an open global communications vehicle and other risk factors, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others, such as hackers.
CHILDREN’S PRIVACY
The CCPA prohibits us from selling any Personal Information of children under the age of 16 without express consent and if they are under the age of 13, without their parent or legal guardian’s express consent. Therefore, unless we have such consent, we will not under any circumstances sell such Personal Information. We do not “sell” any Personal Information of our minor clients, but we necessarily share such information with potential employers and buyers of those clients’ services so that we can adequately service such clients, with the necessary legal authorizations. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, please contact us at: privacy@ctctalent.com.
THIRD-PARTY WEBSITES
Our website may contain links (which may take the form of hyperlinks, widgets, clickable logos, plug-ins, images or banners) to websites and services operated by entities other than us. This Privacy Policy does not apply to such websites or services, so we recommend that you review their posted privacy policies so that you understand the relevant information collection, use and disclosure practices.
CHANGES TO THIS PRIVACY POLICY
We may change this Privacy Policy from time to time and the amended policy will be posted to our website. We reserve the right to update, change, amend or modify this Privacy Policy at any time and from time to time without prior notice. When we post changes to this Privacy Policy, we will revise the “Last Updated” date at the top of the Privacy Policy. Your continued use of the Sites after any changes or revisions to this Privacy Policy become effective shall indicate your agreement with the terms of such revised and then-current Privacy Policy.
RETENTION
We will process Personal Information for so long as reasonably required to provide our services.
HOW WE USE THE PERSONAL INFORMATION COLLECTED ABOUT YOU
We will process (collect, store and use) the information you provide in a manner compatible with the CCPA. We will endeavor to keep your information accurate and up to date, and not keep it for longer than is necessary. CTC is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of Personal Information should be kept may also be governed by specific business-sector requirements and agreed practices. Personal Information may be held in addition to these periods depending on individual business needs.
HOW TO FIND OUT PERSONAL INFORMATION HELD BY CTC
CTC at your request can confirm what information we hold about you and how it is processed. If CTC does hold Personal Information about you, you can request the following information:
Identity and the contact details of the person or organization that has determined how and why to process your data.
The purpose of the processing as well as the legal basis for processing.
If the processing is based on the legitimate interests of CTC or a third party, information about those interests.
The categories of Personal Information collected, stored and processed.
Recipient(s) or categories of recipients that the data is/will be disclosed to.
If we intend to transfer the Personal Information to a third country or international organization, information about how we ensure this is done securely.
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HOW LONG DATA IS STORED
Details of your rights to correct, erase, restrict or object to such processing.
Information about your right to withdraw consent at any time.
The source of Personal Information if it was not collected directly from you.
CTC accepts the following forms of identification when information on your personal data is requested: Passport or Driver’s License.
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GOVERNING LAW/DISPUTE RESOLUTION/ARBITRATION
All matters relating to the Site and this Privacy Policy and any dispute or claim arising therefrom or related thereto (in each case, including non-contractual disputes or claims), shall be governed by and construed in accordance with the internal laws of the State of California without giving effect to any choice or conflict of law provision or rule (whether of the State of California or any other jurisdiction).
By using the website or disclosing Personal Information to us, you agree that any dispute, claim or controversy arising out of or relating to this Privacy Policy or the breach, termination, enforcement, interpretation or validity thereof, including the determination of the scope or applicability of this agreement to arbitrate, shall be determined by arbitration in Los Angeles, California before a single neutral arbitrator. The arbitration shall be administered by Judicial Arbitration and Mediation Services, Inc. (“JAMS”) pursuant to its Comprehensive Arbitration Rules and Procedures. The parties to arbitration may use legal counsel at their own expense, and the prevailing party shall be entitled to its reasonable attorney’s fees. All costs of arbitration (including arbitrator fees) shall be paid by CTC, except only that if you bring the arbitration, you may be charged an initial filing fee that shall not exceed the filing fees that you would incur for bringing an action in court. Without limiting the generality of the foregoing, in the event that any party seeks injunctive or equitable relief with respect to any actual or threatened breach of this Privacy Policy, or with respect to public injunctive relief, such party may seek relief in a court of competent jurisdiction. Notwithstanding anything else in this Privacy Policy or the JAMS rules, any parties subject to this arbitration provision shall be barred from bringing or participating in any Class Action (as defined below) related to a dispute covered by this arbitration provision. Notwithstanding anything else in this Privacy Policy or the JAMS rules, it is agreed that the arbitrator is specifically denied the authority to consider or certify any Class Action under this Privacy Policy. However, if these Class Action restrictions are ever deemed illegal or unenforceable, they shall be severed from this arbitration provision. In that event, any Class Action shall by exempted from this arbitration provision and brought in court of competent jurisdiction, in connection therewith and each of the parties consent to the sole and exclusive jurisdiction of the state and federal courts of the State of California, County of Los Angeles, Central District. For purposes of this Privacy Policy, the term “Class Action” shall mean claims brought on behalf of or allegedly representing or including other persons or entities, including but not limited to any class, consolidated, representative, collective or private attorney general action. This arbitration provision is subject to the Federal Arbitration Act, and may be enforced in any court of competent jurisdiction.
CONFLICTS
In the event of a conflict between the provisions of this Privacy Policy and any provisions, terms or conditions of any General Services Agreement or representation agreement between you and the Company, the provisions, terms and/or conditions of such General Services Agreement or representation agreement between you and the Company shall control and govern.
CONTACT US
If you have any questions about this Privacy Policy, please contact us via email at privacy@ctctalent.com.