Talenthouse Ltd, a company registered in England under company number 13427568 and whose registered office is Templeman House C1 The Point Office Park, Weaver Road, Lincoln, Lincolnshire, United Kingdom, LN6 3Q (“Talenthouse”, “we”, “us” or “our” in this policy), together with its group companies, operates the Ello.co platform available at the site and all iterations of the Ello.co platform (including, where available, the mobile app) (together, the “Platform”) and the services available through the Platform including the launch of creative “Briefs”, submission, art giveaways, operation of the artist collective, our newsletter (“Artist Email”), and our Art Editorial, Not For Print and Underscore initiatives (together, the “Services”). The Platform is the creators’ network - a publishing and collaboration platform connecting and supporting a global community of artists.
- “Artists” to use our Platform to submit creative works, and engage in other services such as Art Giveaways, the Artist Collective and Art Editorial, Not For print and Underscore initiatives.
- “Brands”, “Agencies” and “Publishers” to find and accept creative works through the Services.
- “Fans” to see artwork and follow Artists from around the world.
- 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 data 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 data 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.
INFORMATION WE MAY COLLECT ABOUT YOU
We collect and process the following information which may include your personal data.
When you sign up to Artist Email
When you sign up to Artist Email on our Platform, we will collect your email address.
When you contact us or use our support Services
We provide our support Services via our Platform and by email. The information we may process in connection with this may include:
- First name, last name, and username;
- Email address with which you have signed up to your Platform account or which you contact us from;
- The element of the Services causing an issue for you;
- A description and / or screenshots of the issue you are experiencing; and
- Content files, where relevant.
If you don’t provide this information, we may not be able to help.
Where you are an Artist using our Platform
You may give us information about you by filling in forms when setting up your Artist account with us. Such information may include:
- First and last name;
- Email address;
- Creative Interests; and
- Your preferences for being contacted by: (i) Brands, Agencies and Publishers, and (ii) fellow Artists.
On your profile page, you may provide additional voluntary information that is made visible on your profile to other users (being other Artists, Brands, Agencies, Publishers and Fans). This may include:
- Profile picture;
- Social media channel links;
- Personal website links;
- Bio information;
- Location; and
- Uploads of your existing work and creative expression (such as the header you choose to display on your profile).
If you are selected by a Brand, Agency or Publisher as a Selected Artist, or a finalist in a competition (i.e. Brief), we collect and store the following additional personal data:
- Photo ID (driving license or passport);
- Postal address;
- Bank account details for payment processing; and
- Signed agreements or rights releases.
Where you are a Brand, Agency or Publisher using our Platform
You may give us information about you by filling in forms when setting up your Brand/Agency/Publisher 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; and
- Creative interests
Where you are a Fan using our Platform
You may give us information about you by filling in forms when setting up your Fan account with us. Such information may include:
- First and last name;
- Email address; and
- Creative interests.
Where you are invited to the Platform by an existing user
If one of our existing users invites you to the Platform we will process your email address in order to facilitate the invitation.
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 we receive, 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 from visitors: average pages per Platform session, where our visitors come from, visitors’ device and operating system, time of day that the Platform is used, general location, average time on a Platform page, button clicks, number of views on a Platform page, depth of scroll down a Platform page, number and location of submissions to a Brief, email open and click-through rate, and whether a visitor is a new or returning visitor.
Information collected in relation to social media channels
If you post or upload any content about our Services on social media channels such as Facebook, Twitter, Instagram or Twitter, this will be under these social media platforms’ respective privacy policies which can be found on their websites.
Where you follow us, interact with our content, or choose to link your social media channels to your account with us, we may be able to see personal data from your social media profile (depending on your social media privacy settings), including:
- Name (and/or your social media unique username);
- Email and/or postal address;
- 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 (including Artist Email)
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 data 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 and Platform 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 Platform;
- Deliver our Services to you;
- Register you as a new user;
- Manage accounts;
- Administer Briefs and other Service features such as Arts Editorial, Artist Collective, Not For Print and Underscore;
- Identify relevant and available Artists for private Briefs and other Service features such as Arts Editorial, Artist Collective, Not For Print and Underscore;
- Fulfil any awards to selected and commissioned Artists; and
- Ensure that the Services function properly and deliver the features promised.
To facilitate interaction 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.
To fulfil our Anti-Money-Laundering obligations
We may request specific information from you to help us confirm your identity under the Know Your Customer / Anti-Money-Laundering Regulations (“AML Regulations”), to verify your identity prior to paying financial incentives to selected Artists / 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.
To respond to your enquiries and requests for support
We may process information about you 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, enforcing our legal rights, and investigating complaints. We also process personal data to comply with our regulatory and corporate governance obligations.
Suppliers: We also share your personal data 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
Merger or acquisition: If we are involved in a merger, acquisition, or sale of all or a portion of our assets, we may be required to share your personal data with the buyer. You will be notified via account message and/or a prominent notice on our Platform of any change in ownership or uses of your personal data, as well as any choices you may have regarding your personal data.
Required by law: In addition, we may disclose your personal data 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 data 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 [email protected]
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 data 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 data 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; or
- 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.
We will retain your personal 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 personal data after your relationship with us has ended. For example, we may need to take into consideration any regulations that we must fulfil, such as for auditing purposes or for legitimate business purposes.
We will take all reasonable technical and organisational precautions to prevent the loss, misuse or unauthorised alteration of your personal data.
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 personal data, and it will be transferred outside of the EEA and the UK within our group and to our providers who deliver services to us.
Where we transfer your information outside of the EEA and / or UK, 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 [email protected].
All questions, comments or enquiries should be directed to us at [email protected]