Privacy Notice Last updated: 14 July 2021 Summary Below is our detailed privacy notice which provides you with information on how we use your personal data. We understand, however, that people have busy lives and so we have produced this summary to give you an overview about what we do and how it involves your personal data – this is an overview only so please do make sure that you take the time to read the full privacy notice. Personal data is information relating to an identified or identifiable individual. It can include information about you such as your likes and interests as well as things you have done and where you have been. Names and email addresses are the most common identifiers to which your personal data will relate. Avalon is primarily involved in television production and distribution, talent management and live entertainment but we also operate websites on behalf of artists (primarily comedians) and we allow people to apply to be in television audiences via our websites. Our general day-to-day business does not require a large amount of personal data from our website and app visitors. Mainly we receive personal data from individuals when they sign up for services including, and without limitation, when they apply to be in an audience, when they request newsletters about the artists that we manage, when they sign up to our webpage(s), or when they contact us. This personal data is used primarily to facilitate these requests – i.e. considering and arranging for audience participation, sending out newsletters, accessing webpage(s) replying to communications or as otherwise communicated to you. Further information can be found below. Sometimes our websites and apps may contain links to sites and services that are not part of the Avalon Group. These sites and services have their own privacy policies. If you follow a link to these non Avalon-Group websites and apps, you should read the privacy policy shown on their site. If you have any questions at all, please do feel free to contact us at: dataprotection@avalonuk.com Who we are This privacy notice sets out how the Avalon group of companies (Avalon Group, we, us) processes your personal data. The websites that the Avalon Group operates and through which it may collect personal data are set out in the Schedule at the end of this privacy notice (websites). The website that you engage with us through will determine which Avalon Group member is your controller, and this is set out in the Schedule. “Controller” is a legal term under data protection legislation and means the entity that is responsible for how your personal data is used (i.e. who determines the purposes for which the data are processed and the means of processing). What personal data do we collect and from where? We collect personal data that you submit to us when interacting with our websites. The personal data we collect will differ depending on the services you are requesting and the websites that you visit. For example: when you register an account on one of our websites we may collect your name, email address, password, address, contact number and date of birth and/or any other related information; when you sign up to a newsletter we may only collect your email address and/or other information as requested by us when signing up; when you apply for a role at Avalon we may collect personal data related to your CV, relevant experience and/or other related information; and/or if you wish to participate in an audience we may collect your form and may ultimately capture footage of you and/or other related information. We may also collect personal data about you ourselves. This may include information we collect from cookies on our websites (please see our cookies policy). We may also receive your personal data through Ticketmaster, See Tickets and/or other similar websites when you provide them with your consent for your personal data to be shared with us. We may also receive your personal data through Facebook, Google or otherwise. How do we use your personal data? In accordance with data protection laws, we will only process your personal data if we have a lawful basis for doing so. In respect of your personal data, these bases are: (i) if it is necessary to provide services to you under the performance of the contract we have with you; (ii) if we are required to do so in accordance with legal obligations; (iii) if you have given your consent; and/or, (iv) if it is in our legitimate interests to process your personal data, provided that none of these prejudice your own rights, freedoms and interests. The following is a list of the purposes for which we process your personal data, and the lawful basis on which we carry out such processing. Where indicated, specific purposes and lawful bases may apply to the processing of personal data collected through the relevant websites, in addition to the purposes and the lawful bases that may apply to any and all of our websites. Where we have not indicated specific websites, the purposes and lawful bases may apply to the processing of personal data to any and all of our websites. Purpose Lawful Basis Avalon websites To review your application to gain access to Avalon Distribution’s screening room Consent TVRecordings To make performance related information available to you, including with regards to audience tickets for TVRecordings events Consent When you appear in an audience we may film footage of you from which you can be identified. This footage may also be broadcast as part of the broadcast of the production Legitimate interests to allow us to include audience reaction in programming Any and all websites (including all of the above websites) To set-up, administer and manage your account with us (where applicable) Necessary for the performance of a contract To take payment from you, fulfill orders and produce invoices for you Necessary for the performance of a contract To notify you about event critical information, including cancellations and venue changes Necessary for the performance of a contract To conduct market research Legitimate interests of better understanding our customers’ areas of interest and the services they find most useful To respond to communications, including customer support queries Legitimate interests so that we can deal with queries and complaints To record and analyse customer communications for training purposes Legitimate interests of improving our customer service To send you service messages and updates about our websites and services Necessary for the performance of a contract To send you newsletters and marketing information that you have requested Consent To advertise our websites and artists, including via social media custom audience tools. This processing may also involve automated decision-making regarding the type of ads you receive although this decision-making will not have any legal effect or similar significant effect Legitimate interests in order to better advertise our websites and information about our artists to those that have shown an interest To prepare and analyse statistics relating to the use of our websites and services by you and other customers, to investigate complaints and to seek and analyse feedback Legitimate interests of ensuring our services and website are as enjoyable as possible To run our everyday operations, e.g. communications between employees in connection with the provision of our services and exchanges of information between different members and companies within the Avalon Group Legitimate interests of running our business To administer and protect our business and websites including troubleshooting, data analysis and system testing Legitimate interests of running our business, provision of administration and IT services, including network security To administer a sale or possible sale of the whole of or part of our business or the restructuring of our business Legitimate interests of facilitating any such possible or actual transaction or restructuring To assist law enforcement agencies in their investigations Legitimate interests of the law enforcement agencies provided that this does not affect your rights To conduct legal proceedings, including defending ourselves legally and making claims Necessary to comply with legal obligations To consider any job applications we may receive Consent We may also process your personal data for purposes which are compatible with those listed above and below. When we do this we will update this privacy notice. Marketing Our marketing is carried out as follows: • Sending out newsletters to those that have signed up to receive them; • Engaging with social media platforms to deliver personalised ads to people that have shown an interest in our websites and/or artists by subscribing to relevant newsletters; • Or as otherwise notified to you when signing up to our websites and apps. Our newsletters contain an ‘unsubscribe’ feature. This can be used to object to receiving future communications. When you unsubscribe we will also cease processing your personal data unless we have lawful grounds to continue with such processing. Please note, when you unsubscribe from our marketing, we will keep your email address to ensure that we do not send you any marketing in the future. If we no longer need your data, we will delete it or make it anonymous by removing all details that identify you. You can also contact us to opt-out of the forms of marketing. When do we disclose your personal data? We may, for the purposes outlined above, disclose your personal data to any of the following recipients: • Companies within the Avalon Group (including to their employees and sub-contractors) which assists us in providing our services or which otherwise have a need to know such information. • Third parties which assists us in providing our services (known as processors) (including, without limitation, Dotmailer and Vimeo). In each case we will have contractual protections in place to ensure that such processors only process your personal data on our instructions. • Social media sites, including Facebook, for the purposes of sending you relevant ads on those sites if you have expressed an interest in our goods and services. In each case we will have contractual protections in place to ensure that such companies only process your personal data on our instructions. Please note, some of our websites use social plug-ins from other organisations (such as the Google + function). These other organisations may receive and use personal date about your visit to our sites or apps. If you browse our sites or view contact on our apps, information they collect may be connected to your account on their site. For more information on how these organisations use personal data, please read their privacy policies. • External professional advisors who need to access such information for the purpose of advising us. • Law enforcement bodies which may have any reasonable requirement to access your personal data. • Potential purchasers of our business or investors in it or in any company within the Avalon Group (including in the event of insolvency). We may also be required to transfer your personal data outside of the EEA (including the UK). To assist us in providing our services we may transfer your personal data to Avalon Television, Inc. and Avalon Management, Inc. (both members of the Avalon Group), but we have in place standard contractual clauses or Article 28 GDPR terms to ensure that adequate safeguards are in place to keep your personal data secure. We may also disclose your personal data to companies in the US, such as Facebook, but we will also have adequate safeguards to protect your personal data, including disclosing your personal data to companies that are certified under the EU-US Privacy Shield Framework. How long do we keep your personal data for? We keep your personal data for only as long as we need to. How long we need your personal data depends on what we are using it for, as set out in this privacy policy. For example, we may need to use it to answer your queries when contacting us and as a result may keep your personal data while you are still in contacting with us regarding your query. If we no longer need your data, we will delete it or make it anonymous by removing all details that identify you. If we have asking for your permission to process your personal data and we have no other lawful grounds to continue with that processing, and you withdraw your permission, we will delete your personal data. However, when you unsubscribe from marketing communications, we will keep your email address to ensure that we do not send you any marketing in the future. Your rights You have the following rights under data protection legislation. If you have any questions about your rights, or you wish to exercise any of these rights, please email dataprotection@avalonuk.com We may require you to provide forms of identity should you wish to exercise one of your rights below. • Access: You are entitled to confirmation that we process your personal data and a copy of such personal data. • Rectification: If the personal data we hold on you is incorrect, you have the right for this to be rectified. You may also update your personal data through your account settings. • Erasure: You can request us to erase your personal data if there is no compelling reason to continue processing. • Restriction: You may request a restriction on the processing we undertake on your personal data. This will only apply if we have no lawful basis to process your personal data, your personal data is inaccurate or to comply with an objection request (see below). • Objection: You may object to our processing of your personal data if our processing is carried out on the basis of legitimate interests. Please note, however, that should we determine that our interests are so compelling as to override your objection we may continue to process your personal data. • Objecting to direct marketing: You may object to receiving direct marketing at any time. • Portability: You have the right to receive some of your personal data in machine readable format. This right extends to you being able to request that such data is sent to a third-party controller. • Withdrawing consent: If the lawful basis we rely on to process your personal data is consent you have the right to withdraw this consent. Please email us at dataprotection@avalonuk.com to withdraw consent for the processing of your personal data. • Complaining to a supervisory authority: Further information about your rights can also be obtained from your national data protection regulator – in the UK, this is the ICO (https://ico.org.uk). If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with your national data protection supervisory authority, although we would ask that you contact us in the first instance. • Your right to be informed: You can contact us to find out more or to ask any questions you may have about our use of your personal data. Please note that your rights above are not absolute and we may be unable to comply with your request (in whole or in part). Please also note that if we reasonably determine that your request is manifestly unfounded we reserve the right to refuse to comply with your request. When you make a request we may have to ask you to prove your identity. Schedule Our websites: Avalon websites Controller entity http://avalonuk.com/ Avalon Promotions Limited (“APL”) http://avalontelevision.com/ APL http://distribution.avalontelevision.com/ Avalon Distribution Limited (“ADL”) http://avalonedinburgh.com/ APL http://argtalent.com/ ARG http://www.topicaltelevision.co.uk/ Topical Television Limited https://avaloncorporate.events/ APL TVRecordings https://tvrecordings.com/ APL Show brand websites https://taskmaster.tv/ APL http://www.grumpyoldwomenlive.com/ APL Artist websites https://www.russell-howard.co.uk/ APL https://chrisramseycomedy.com/ APL http://frankskinnerlive.com/ APL https://iaindoesjokes.com/ APL https://edgamble.co.uk/ APL https://www.davidbaddiel.com/ APL https://thehornesection.com/ APL https://thepublandlord.com/ APL https://www.mattforde.com/ APL https://www.robdelaney.com/ APL http://philwang.co.uk/ APL www.taniaedwardscomedy.com APL We'll assume you're ok with this, but you can opt-out if you wish. 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