UVE Digital Ltd t/a Uni-versal Extras (“Uni-versal Extras”, “we”, “our” or “us”) has created its unique website https://universalextras.co.uk and mobile application which we offer our agency services through (hereby collectively referred to as the “Software”).
We are committed to ensuring that your personal information remains confidential and secure in accordance with applicable Data Protection Legislation.
This policy sets out how we look after your personal data if you are a:
- Visitor to our Uni-versal Extras website;
- An Authorised User with a registered account;
- Supplier or business contact of UVE Digital;
- An Extra generally through us;
- A potential end client of UVE Digital;
- Any third-party organisation that uses UVE Digital;
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
We may update this notice from time to time, and you can find our latest version on our website or by asking us for a copy.
Due to the nature of our Services we provide, and the requirements of our clients, the decision to invite you to appear as an Extra in certain productions may be automated based on the information you provide on your profile; for example, your gender, ethnicity, measurements and location. When registering with us as an Extra, you acknowledge that the decision to invite you to appear as an Extra in certain productions may be automated and if you proceed you are doing so on the strict understanding that you have given us explicit consent for this.
Who are Uni-versal Extras?
UVE Digital Ltd t/a Uni-versal Extras, is a company incorporated in England and Wales, with its company number 15297560 and its registered office being the Stables, 23b Lenten Street, Alton, Hampshire GU34 1HG.
1. Collection of Information and how we use it
We will collect any information that you provide to us when you:
- Input forms in the Software, including any application forms;
- Input forms in the Software, including any application forms;
- place a booking in person, over the phone or by email;
- register to use our Services;
- make an enquiry, provide feedback or make a complaint to us over the phone, by email or via the Software;
- submit correspondence to us by post, email or via the Software;
- submit a CV;
- ‘follow’, ‘like’, post to or interact with any of our social media accounts including but not limited to Instagram, Facebook, Twitter, Snapchat, LinkedIn;
- Interact with us as to express an interest for work;
- Interact with us as a client or potential client.
1. 2. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together depending on your relationship with us (for instance, whether you are an Authorised User benefitting from our Services, visitors, or client of ours, or a supplier) as follows:
- Identity Data: includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Application Data: any data you may supply in your application with us on the Software, which may include specific profile data.
- Financial Information: details of bank account details for billing services and payment services.
- Contact Data: your email address, telephone number and postal address.
- Technical Log Data includes internet protocol (IP) address, device ID’s, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, geolocation data, social media preferences, operating system and platform and other technology on the devices you use to access the Software.
- Profile Data includes your authorised username and password, complaints, preferences, profile information relating to your image, such as hair and eye colour, height, measurements, photographs.
- Usage Data includes information about how you use the Software, and our services.
You can withhold your personal data from us, but we may not be able to provide our Services to you if you do so.
We may collect your personal data from different sources:
- We collect all the types of data listed above directly from you when you interact with us. This includes when you register or use the Software.
- We collect Technical Data automatically when you interact with the Software, by using cookies and other similar technologies.
1.3. We have no automatic deletion period for personal information. The nature of our business is such that our production clients have no limits or restrictions to their requirements so personal information which is infrequently or never used may still be required. See below our section on data retention.
2. Information we collect about you
2.1. Non-Personal information is used to help us monitor and improve our service, for example by showing how many people are visiting our website and which pages are most or least popular. Individual user patterns are not monitored.
2.2. We (or third-party data processors, agents and sub-contractors acting on our behalf) may collect, store and use your personal information by way of different methods to collect data from and about you including through:
Direct interactions. This is information (including Identity, Contact and Financial Data) you consent to giving us about you when you fill in forms and sections through the Software or send to us directly, or by corresponding with us (for example, by email or chat). It includes information you provide when you register for any of our Services, visit or use the Software, or when you create an account with us and finally when you report a problem with our Services, or with Uni-versal Extras. If you contact us, we will keep a record of that correspondence.
Information we collect about you and your device either automated or otherwise. Each time you visit or use the Software, we will automatically collect personal data including Technical Log Data. We collect this data using cookies and other similar technologies including server logs. We may also receive technical data about you if you visit other websites employing our cookies. We may also collect Technical Log Data if you contact us and use our services generally through Uni-versal Extras.
Financial information. We will collect information related to bookings and time worksheets. We will also collect information relating to payments to you such as bank details or other related transaction information.
We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions, which include strict confidentiality and contractual terms.
We will only use your personal data when the law allows us to. Most commonly we will use your personal data in the following circumstances:
- Where you have consented before the processing.
- Where we need to perform a contract, we are about to enter into, or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
2.3. When we need to comply with a legal or regulatory obligation. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
When we are acting as a data controller, we will use your personal data for the purposes set out in the table below.
The law sets out several different reasons for which we can collect and use your data. The legal grounds on which we collect and use your data are also set out in the table below. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose for using your data
|Legal ground for using your data for this purpose
|To allow you to access your account through the Software and to register an account with us. To enable access to and to enable you to benefit from our Services. This may include sharing your information with our website hosts and developers.
|Necessary for our legitimate interests (to allow those with an account in the Software to use it) / Performance of a contract with us. To comply with a legal obligation.
|To publish your portfolio and information in the Software when you agree to be represented by us if you are an Extra.
|Necessary on the basis of us performing our contract with you and for our legitimate interests in promoting our website and mobile application and Services as an extra’s agency.
|To manage any account with us and to enable us to deliver our Services, including making bookings, managing and making payments.
|Necessary for our legitimate interests (to recover debts due to us and to make payments) / Performance of a contract with us.
|To provide support to you when you contact us.
|Necessary for our legitimate interests (to respond to support calls as our users would expect) / Performance of a contract.
|Necessary for our legitimate interests (to provide important updates to our users)/ Performance of a contract.
|To administer and protect our business and the Software (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
|Necessary for our legitimate interests (to protect our business, software and website; to keep our services updated).
|To deliver relevant system, software and website content and advertisement and promotional activity to measure or understand the effectiveness of the business.
|Necessary for our legitimate interests (to study how Authorised Users use our products/services, to develop them, to grow our business and to inform our marketing strategy).
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.
|Necessary for our legitimate interests (to continuously improve our services for our customers and users).
|Marketing our Services to existing and former customers. To enable us to keep you informed of news, events and services that may be of interest
|For our legitimate interests, i.e. to promote our business to existing and former customers, or on the basis of consent where we have requested it. See “Marketing” below for further information.
|To create anonymous aggregated data, as set out below.
|Necessary for our legitimate interests (to provide additional benefits and functionality to our customers and users without disclosing personal data).
|To comply with policies, applicable laws and regulatory obligations.
|To comply with a legal obligation and on the basis of our legitimate interests to operate a safe and lawful business.
|Social media interactions. To enable us to interact with users on social media.
|On the basis of our legitimate interests in promoting our brand.
2.4. As outlined above, from time to time we may use your personal data to pursue legitimate interests of our own or those of third parties.
3. Who do we share your information with?
3.1. We may need to share your personal data when using your personal data as set out in the table above. We may share your personal data with the following third parties:
- Our professional advisers, including lawyers, auditors and insurers and any other third parties that may be necessary such as authorities, regulatory or other government agencies which may be required.
- Clients (for actual and potential assignments). There may be occasions where these clients are based outside of the United Kingdom and the EEA.
- Service providers who we work with to deliver our Services, who may act as processors and provide the following services (including, but not limited to) web development, hosting services, IT and system administration, marketing services, social media plug in services, payment services.
- Regulators and Government bodies.
Where any of your personal data is required for such a purpose, we will take all reasonable steps to ensure that your personal data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the Data Protection Legislation. This type of external data processing is always subject to contractual assurances that personal data will be kept securely and used only in accordance with our specific directions.
4. International Transfers
4.1. Subject to us complying with Data Protection Legislation and ensuring appropriate safeguards are in place, we may transfer your personal data to third parties providing services to us who are based outside of the UK and EEA without obtaining your specific written consent. This may include parties providing IT administration services and hosting services and other organisations which have products or services that are essential in the delivery of our Services; and finally, organisations providing assistance with managing our marketing databases.
4.2. Whenever we transfer your personal data outside of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
4.2.1. the personal data is transferred to or processed in a territory which is subject to adequacy regulations under the Data Protection Legislation that the territory provides adequate protection for the privacy rights of individuals such as the EEA; or
4.2.2. we participate in a valid cross-border transfer mechanism under Data Protection Legislation, so that we can ensure that appropriate safeguards are in place to ensure an adequate level of protection with respect to the privacy rights of individuals as required under the Data Protection Legislation; or
4.2.3. the transfer otherwise complies with Data Protection Legislation.
5. Retention Periods
5.1. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
5.2. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
5.3. For more details of our specific retention periods, please contact us.
6. Data Security
6.1. Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through the Software and through our business.
6.2. We have implemented significant security measures to maintain a high level of security.
6.3. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
6.4. Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to us data via the internet and you take the risk that any sending of that data turns out to be not secure despite our efforts.
6.5. If we give you a password upon registration and use of the Software, you must keep it confidential. Please don’t share it.
7. Sensitive Personal Information
7.1. “Special Categories” of particularly sensitive personal information require us to have higher levels of security in place. Sensitive personal information includes any details about your race or ethnicity, specific body measurements, hair colour, health data, genetic data, sexual orientation, religious or philosophical beliefs. As such, higher levels of protection are required in order for us to process these types of data. We may also require information from you about any criminal convictions.
7.2. We need further justification for collecting, storing and using these types of data and to do so, we implement safeguards and policies to ensure we can meet the requirements of the Data Protection Legislation. We therefore may process sensitive personal information in the following circumstances:
7.2.1. Where you might provide explicit consent;
7.2.2. Where processing is necessary for the purposes of carrying out our obligations and exercising your specific rights as either the data controller or the data subject; and
7.2.3. where we need to carry out our legal obligations.
8. Your rights to the information we hold about you
8.1. Under certain circumstances, you have rights under the Data Protection Legislation in relation to your personal data. These rights are set out below. If you wish to exercise any of the rights set out below, please contact us.
8.2. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
8.3. Your rights are as follows:
Right of access – you have the right to request a copy of the personal data that we hold about you and to check that we are lawfully processing it.
- Right of access – you have the right to request a copy of the personal data that we hold about you and to check that we are lawfully processing it.
- Right of rectification – you have a right to request that we correct personal data that we hold about you that is inaccurate or incomplete.
- Right to be forgotten / erasure – in certain circumstances you can ask for the data we hold about you to be erased from our records i.e., when there is no good reason for us continuing to process it.
- Right to restriction of processing – where certain conditions apply, you have a right to restrict or suspend the processing, for example if you want us to establish its accuracy or the reason for processing it.
- Right of portability – you have the right to have the data we hold about you transferred to another organisation.
- Right to object – you have the right to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
There are some exceptions to the above rights.
- Right to withdraw consent. In the limited circumstances where you have provided your consent to the collection, processing and transfer of the personal data referred to above, you may withdraw that consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent, or to processing carried out on other legal grounds. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
8.4. All the above requests will be forwarded to the relevant party should there be a third party involved in the processing of your personal data.
9. Privacy of Children
9.1. We do not knowingly collect personal information from children below the age of 16.
9.2. By sending us any information to us, registering to use our Services, or asking us to email you, you are confirming that your parent or guardian has consented to you doing so. We may be required to confirm this with your parent or guardian accordingly.
10.1. We will use your personal data to send you updates (by email, text message, telephone or post) about our products, including exclusive offers, promotions or new products.
10.2. We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
10.3. You have the right to opt out of receiving marketing communications at any time by contacting us at firstname.lastname@example.org
11. Complaints to the Information Commissioner’s Office
11.1. You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance by emailing us at email@example.com
13.1. If you have any queries or concerns, then please in the first instance contact firstname.lastname@example.org
13.2. You have the right to access or exercise any other statutory right by contacting us at email@example.com
13.3. At any time you have the right to bring a complaint to the Information Commissioner’s Office (https://ico.org.uk)
Head Office. UVE DIGITAL LTD t/a Uni-versal Extras, Pinewood Studios, Pinewood Road, Buckinghamshire SL0 0NH Registered in England No. 15297560 Registered Office. The Stables, 23b Lenten Street, Alton, Hampshire GU34 1HG