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GENUINE: PRIVACY POLICY

Effective Date:  July 3, 2018

This Privacy Policy (“Policy”) describes how Strickman-Ripps, Inc. d/b/a GENUINE: The Real People Company (“GENUINE” or “we” or “our” or “us”) collects, stores, shares, and uses information, and your choices about privacy when you use our website, products, and services (collectively, “Services”). By accessing or using our Services in any way, you agree that your personal information may be collected, stored, shared, and used as described in this Policy. You may withdraw consent at any time in writing, however such withdrawal does not negate our right to process your data prior to your withdrawal. By using the Service, you agree to our collection, use, and disclosure practices, and other activities as described in this Privacy Policy. If you do not agree with this Privacy Policy, then do not use the Service.
When This Privacy Policy Applies
This Policy applies to all of our Services, regardless of how you use them.  This Policy only applies to how we collect, store, share, and use information. This Policy does not apply to any entity that we do not own or control, or to any person that we do not employ or manage. If, at any time during the course of using our Services, you are directed to a third-party site, you understand and agree that the policies of the third-party site govern.
Types of Information We Process
Information You Provide
We collect information that you voluntarily submit to us. For example, we collect information when you contact us to submit a questionnaire, respond to an opportunity to be cast, or e-mail us to provide the information. The information we collect may include information that identifies or could identify you (whether alone or in combination), such as your name, email address, or physical address. With your explicit permission, we collect information that personally identifies you including your photograph, likeness, image, voice and/or statements (collectively, “Likeness”).  Do not submit any information to us that we have not requested.
Special Notice to Talent
There are practical considerations relating to the need for third parties (e.g., advertising agencies, production companies, agents and clients) to review certain personal information to facilitate the casting process. By submitting your information for the purpose of possible casting, you understand that you are affirmatively choosing to post personally identifiable information about yourself, including contact information such as your phone number and e-mail address, as well as identifying information such as your height, weight, hair and eye color and other personally identifying information, including video or photographs of your likeness and/or recordings of your voice. By providing the aforementioned personally identifying information for potential casting, you are agreeing to have personally identifiable information revealed to third parties, and you are acknowledging the risks inherent in so doing.
Information We Process with Your Consent
Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, including job opportunities and our products and Services including casting opportunities, you provide your consent to us to process information that may be personally identifiable information.
Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to receive communications from us. In cases where we communicate with you by e-mail without having an established business relationship with you, there will be an opportunity to “unsubscribe” from receiving any further e-mails from us.
Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.
When we communicate with you about our business, we will use the contact information you provided to us to discuss technical issues, new Services, casting opportunities, and other information of interest to you.
Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.
We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.
You have a choice about whether or not you wish to receive communications from us. You may withdraw your consent at any time by instructing us using the contact information at the end of this Policy. However, if you do so, you may not be able to use our website or our Services further.  Additionally, email communications from us will have an option to “unsubscribe,” stopping further e-mails from us, unless specifically requested.
Information Collected Automatically. We may automatically collect certain information about how you access or use our Services, and by using our Services you consent to the collection of that information. Examples include but are not limited to Internet browser, operating system, device and application identifiers, IP address and geo-location information, access times and dates, referring and exit pages and URLs, clickstream data, search terms, pages viewed, time spent on pages, bounce rate and login frequency.
Information from Cookies, Web Beacons and Similar Technologies. We may collect information through the use of cookies, web beacons and similar technologies. These technologies help us to operate, improve and customize our Services, content and marketing, for example, by helping us to better understand how users access and engage with our Services, or content. We may also use third-party service providers (such as analytics or ad providers) that may use cookies, web beacons and similar technologies to help operate their services. Your browser may have settings that let you decline cookies, but please note that some of our Services may not be available if you decline cookies, as some of our Services require cookies to operate.
What These Technologies Are. “Cookies” are small data files placed on your computer or other device which record information. For example, a cookie could enable our Services to recognize your browser, while another cookie could store your account preferences and other information to help make our Services more customized. We may use two kinds of cookies, “session cookies” and “persistent cookies.” Session cookies normally expire when you close your browser, while persistent cookies remain on your device until they expire or are deleted. “Web beacons” (also known as “pixel tags” or “clear GIFS”) are pieces of code or pixels embedded in a web page or email to track engagement with and responses to emails, web pages or ads, or to access or communicate with cookies. “Tracking URLs” are special URLs that can be used to track engagement with and responses to emails or web pages.
Third-Party Analytics, and Services.  We may use third-party analytics and services providers who help us to better understand how our Services and content are accessed and used, including for web analytics, audience measurement, personalization and segmentation, and relationship management purposes. In turn, this information helps us to develop and improve our Services and content. Our third-party analytics and service providers include but are not limited to GoDaddy web hosting services. These providers may use cookies, web beacons and similar technologies to collect information about how users access or engage with our Services, content, emails, and ads on or off our Services.
Information from Other Sources. We may obtain information about you from third-party partners (such as other companies or clients on whose behalf we may conduct research, recruiting and casting, or companies with which we may jointly offer services or conduct promotional events), third-party service providers, including but not limited to demographic information, contact information, open data, publicly available data, background check and/or credit check information. We may use this information for legitimate business purposes, including the offering of casting opportunities, performance of a contract, customer support, along with other purposes described in this Policy.
How We Use the Information We Collect and Why
The information we collect helps us to operate, improve, protect, and customize our Services, and to develop new Services. The information we collect also helps us to provide customer support and make our Services more efficient for you and other users. For the sake of transparency, it is our responsibility to outline for you the legitimate business purposes for the collection of information, and the reasons why we do so, in order for you to make an informed decision regarding the use of our Services. In addition to the other uses of information described in this Policy, we may use all of the information that we obtain from or about you for the following purposes and reasons:
  • to provide our Services to you, including new Services we develop later (reason: legitimate business purpose and performance of a contract);
  • to provide you with customer support (reason: legitimate business purpose);
  • to facilitate your communications or transactions with us or other users (reason: to receive consent, and for legitimate business purpose);
  • to operate, improve, and customize our Services, content, and marketing, to develop new Services, and to understand how you use and interact with our Services and content, and the products, services, and content of others (reason: legitimate business purpose);
  • to promote and maintain a trusted, safer, and more reliable environment in the provision of our Services, and to help detect, prevent or otherwise address fraud, security or technical issues, conduct investigations or risk assessments, or verify actions taken by you or associated with your interaction with our website or your provision of information to us (reason: to protect the public interest and for legitimate business purpose);
  • to contact you (by email, postal mail, telephone, mobile devices, SMS text message, or as otherwise authorized by you) in order to address issues with your use of our Services, send you updates about our Services or policies, or for other purposes permitted by law (reason: performance of a contract and for legitimate business purpose);
  • to contact you (by email, postal mail, telephone, mobile devices, SMS text message, or as otherwise authorized by you) in order to send you marketing communications, promotional messages, and offers about our Services and content, and the products, services, and content of others (see below for information on how to opt out of receiving certain communications from us) (reason: to receive consent, and for legitimate business purpose);
  • to comply with our legal obligations, resolve disputes, or enforce other GENUINE policies or agreements with users (reason: compliance with a legal obligation);
  • to perform other functions as described when the information is collected or requested, or for other purposes with your prior consent (reason: legitimate business purpose).
How the Information is Stored
Data Retention. We will keep and use your data as described in this Policy for (i) as long as is necessary to comply with any tax, legal, and/or other regulatory requirements; and (ii) to protect and defend against potential legal claims. If you would like to request the deletion of your personally identifiable information or request that it be returned to you, please contact us at database@genuinerp.com.
Data Storage and Handling. GENUINE takes the security of your personal data very seriously. We take every effort to protect your personal data from misuse, interference, loss, unauthorized access, modification or disclosure.
Our measures include implementing appropriate access controls, the use of Secure Sockets layer (“SSL”) technology on our website, secure servers at our location, password protection and encryption and investing in the latest Information Security Capabilities to protect the IT environments we leverage, and ensuring we encrypt and anonymize personal data wherever possible.
Access to your personal data is only permitted among our employees and agents on a need-to-know basis and subject to strict contractual confidentiality obligations when processed by third-parties. Most importantly, we don’t share personal information or submit it to third parties (for example a client) without the knowledge and explicit consent of the person who provided the personal information.
With Whom Do We Share Personal Information?
Personal Information. Under this Policy, “Personal Information” means information that by itself can be used to identify or contact a specific person (for example, a person’s name, email address, postal address or phone number), and Personal Information does not include information that has been aggregated or made anonymous so that by itself it no longer identifies and can no longer reasonably be used to contact a specific person. We will only share your Personal Information with others in the ways described in this Policy, or otherwise with your prior consent. In addition to the other sharing of Personal Information described in this Policy, we may share your Personal Information with others in the following contexts.
Legal Purposes. We may access, preserve, and disclose your Personal Information and/or other information if we believe that such access, preservation or disclosure is reasonably necessary to: (i) comply with any law, regulation, legal process or governmental request (such as search warrants, subpoenas or court orders), which may include responding to legal requests from jurisdictions outside the United States; (ii) enforce our policies or agreements with users, or investigate potential violations; (iii) detect, prevent or otherwise address fraud, security or technical issues; (iv) protect or enforce the rights or property of GENUINE, you, or any other person or entity; or (v) prevent physical harm to any person, including situations involving possible violence or self-harm.
We may aggregate or make anonymous any Personal Information that we have obtained in any way from or about you or others so that such information no longer contains any Personal Information. We may use and share any aggregated, anonymous or other non-personally identifying information for any legitimate business purposes, including research and development, marketing, and to inform others about how our Services or content are engaged with or used.
Other Websites and Services
Our Services may include links to other websites or services that we do not own or control, and other websites or services that we do not own or control may include links to our Services. Our Services may also include features that enable you to share content on other websites and social media services. However, these links and features are not an endorsement by us of any other websites or services, or any of their privacy policies or practices. When you visit or use other websites or services, they may collect information from you, including through the use of cookies, web beacons or similar technologies. We cannot control the privacy policies of any third-party’s website. We encourage you to read the privacy policies of other websites and services that you visit or use to be informed of their practices.
International Processing
GENUINE is based in the United States. However, service providers, and other third parties you may interact with in connection with our Services, may be located in the United States and other countries around the world, including countries that may not offer the same level of protection for Personal Information as that offered in the United States. By accessing or using our Services in the United States or any other country or jurisdiction, you agree that your information may be transferred and processed in the United States and any other country or jurisdiction.
In cases of onward transfer to third parties of Personal Information of EU individuals received pursuant to the EU-U.S. Privacy Shield, GENUINE remains accountable for the onward transfer of such Personal Information.
Children’s Information
Our Services are not directed to children under the age of 13, and we do not knowingly collect Personal Information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) in a manner that is not permitted by COPPA. If a parent or guardian learns that a child has provided us with Personal Information, that child’s parent or guardian should email us at database@genuinerp.com or send us a letter to the mailing address in the section entitled “Contacting Us” below.
Parental Consent Regarding Casting Minors
Only a parent or legal guardian (or a professional representative acting with the explicit permission of a parent or legal guardian) of a child under the age of 18 years old may provide information regarding that child for potential casting opportunities, or for any other purpose. If the child is under 18 years of age, a parent or guardian (or a professional representative acting with the explicit permission of a parent or legal guardian) must affirm that the information they are sharing is made with the knowledge and consent of the parent or legal guardian of the child, and consents to the release of the child’s Personal Information consistent with the terms and conditions recited in the rest of this Policy.
Accessing and Correcting Your Child’s Personal Information
At any time, you may review the child’s Personal Information maintained by us, require us to correct or delete the Personal Information, and/or refuse to permit us from further collecting or using the child’s information.
You can review, change, or delete your child’s Personal Information by:
Sending us an email to database@genuinerp.com, or writing us at the address found at “contacting us.” To protect your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections.
Statutory Requests
Some jurisdictions have laws that give people the right to access or correct their Personal Information which a company has about them. We will honor any statutory right you may have to access or correct your Personal Information that we have in our records, and you can email such requests to database@genuinerp.com. Once we receive your request, we will let you know if an administrative fee will apply to fulfill your request, as permitted by applicable law. However, please note that even if you have a legal right to request access to information or to correct information, as permitted by applicable law, we may reject requests that are unreasonably repetitive, would require disproportionate technical effort (for example, developing a new system or materially changing an existing practice), would jeopardize the privacy of others, or would be extremely impractical to fulfill (for example, requests to access information located on backup systems).
Your California Privacy Rights
California’s “Shine the Light” law permits customers in California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under the law, a business should either provide California customers certain information upon request or permit California customers to opt-in to, or opt-out of, this type of sharing.
GENUINE may share Personal Information as defined by California’s “Shine the Light” law with third parties and/or affiliates for such third parties’ and affiliates’ own direct marketing purposes. If you are a California resident and wish to obtain information about our compliance with this law, please e-mail us at database@genuinerp.com or send us a letter to the mailing address in the section entitled “Contacting Us” below. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that GENUINE is not required to respond to requests made by means other than through the provided e-mail address or mail address.
Your European Privacy Rights
If you are a data subject in the European Economic Area (“EEA”), you have the right to access, rectify, or erase any personal data we have collected about you through the Service. You also have the right to data portability and the right to restrict or object to our processing of personal data we have collected about you through the Service.
To exercise any of these rights, please e-mail us at database@genuinerp.com or send us a letter to the mailing address in the section entitled “Contacting Us” below and specify which right you intend to exercise. We will respond to your request within 30 days. We may require additional information from you to allow us to confirm your identity. Please note that we store information as necessary to fulfill the purposes for which it was collected and may continue to retain and use the information even after a data subject request as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
If you have any issues with our compliance, you may have the right to lodge a complaint with an EEA supervisory authority.
EEA Withdrawal of Consent
If you are a data subject in the EEA, you have the right to opt out or withdraw your consent for us processing your personal data collected through the Service (or providing it to third parties to process) for direct marketing purposes (including promotional emails) or purposes materially different than for which it was originally collected or subsequently authorized by you. You may also withdraw your consent at any time for any data processing we do based on consent you have provided to us. Please note that withdrawal of your consent does not impact any data that was processed on the basis of that consent before it was withdrawn.
To exercise this right, please e-mail us at database@genuinerp.com or send us a letter to the mailing address in the section entitled “Contacting Us” below and specify your withdrawal of consent. We will make the requested changes in our active databases as soon as reasonably practical.
Changes to This Privacy Policy
Our business changes with time, and our Privacy Policy will change also. We reserve the right to change this Policy, including our cookie policy, without prior notice, at any time at our sole discretion. For example, and without limitation, we may change this Policy to reflect changes to the law or changes to our Services. All changes to this Policy will be effective when posted on our Services, or at such later date as may be specified in the updated Policy. We will notify you of any changes to this Policy by posting the updated Policy on our Services, and you agree to review this Policy regularly and inform yourself of all applicable changes. By continuing to use our Services after any changes to this Policy become effective, you agree to such changes and the updated Policy. Unless we notify you otherwise, the current version of this Policy will apply to all information that we have about you.
Contacting Us
If you have questions or comments about our Privacy Policy or practices, would like to know what Personal Information we hold about you, or would like to update, delete, or request access to such Personal Information, you may contact us by email sent to database@genuinerp.com or by postal mail sent to GENUINE: The Real People Company, 66 W. Broadway, Suite 602, New York, NY 10007, U.S.
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