Policies

Last Modified: 06/01/2021

INTRODUCTION

This Privacy Policy explains what we do with your personal data. It describes how we collect, use and process your personal data, and how, in doing so, we comply with our legal obligations to you. Your privacy is important to us, and we are committed to protecting and safeguarding your data privacy rights.   

This Privacy Policy applies to the personal data of our contributors; contractors, agency and temporary workers; customers and clients; advisors and consultants; potential recruits, job applicants and candidates; suppliers; complainants, respondents and enquirers; and website users.  It also applies to the emergency contacts of our staff.  This policy does not apply to employees of Iyuno-SDI. If you are an employee you should refer to the Staff Privacy Policy which is available on the Iyuno-SDI intranet.

For the purpose of applicable data protection legislation (including but not limited to the General Data Protection Regulation (Regulation (EU) 2016/679) (the GDPR), the company responsible for your personal data (“Iyuno-SDI” or “us”) can be found here.

It is important to point out that we may amend this Privacy Policy from time to time. Please visit this page if you want to stay up to date, as we will post any changes here.

You have certain legal rights in relation to the matters dealt with in this Privacy Policy and so, where relevant, we have described these as well.

This Privacy Policy applies in relevant countries throughout our international network. Different countries may approach data privacy in slightly different ways and so we also have some country-specific parts to this Privacy Policy. You can find country-specific terms for your jurisdiction here. This allows us to ensure that we're complying with all applicable data privacy protections, no matter where you are.

WHAT KIND OF PERSONAL INFORMATION DO WE COLLECT?

The kind of personal data that we collect differs widely depending on the kind of relationship that you have with us.

We collect a wide range of data on contributors (freelance dubbing actors, freelance authors, directors, translators, timecoders, transcribers), contractors, agency and temporary workers. In this context, we collect data to enable us to ensure that our r runs smoothly and so that we are each able to comply with our contractual and other duties to each other. For this purpose we collect master data relating to the person (name, age, gender, contact data, staff number) but also data relating to other aspects of the relationship like our payments (e.g. remuneration and bank details), the performance or the professional development of our counterpart (like e.g. CV, education details). We also collect data in order to comply with our duties to third parties such as tax authorities and government agencies (like marital status, immigration status, social security number).

We also collect a wide range of data on potential recruits, job applicants and candidates in order to run our selection and recruitment process and comply with legal requirements in that context. For this purpose, we collect master data relating to the person (name, age, gender, contact data) and in addition mostly data relating to the professional development (like e.g. CV, education details),

By contrast, we collect only very limited data on customers and clients, advisors and consultants as well as suppliers as we only need to hold some data in order to ensure that the relationship to these counterparts runs smoothly. We may also hold extra information that someone in the organisation of our counterpart has chosen to tell us.

On complainants, respondents and enquirers, we only collect the names and contact details and whatever information these persons choose to tell us.

On people whose data we receive from candidates and contractors, agency and temporary workers (such as referees, emergency contacts and dependants) we only collect such data that enables us to support the purpose of their involvement.

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  • CONTRIBUTORS’ DATA (freelance dubbing actors, freelance authors, directors, translators, timecoders, transcribers)

Depending on the relevant circumstances and applicable local laws and requirements, we will collect some or all of the information listed below to enable us to work with contributors and provide services to customers and clients.

(In some jurisdictions we are restricted from processing some of the data outlined below. In such cases, we will not process the data in those jurisdictions.)

  • Name and contact details (title, first name, surname, phone number, email address, postal address, country of residence)

  • Age (and birthdate, if required for compliance purposes)

  • Qualification data and other information from CVs (school, further education and vocational training details and qualifications; and information relating to social interests)

  • Sex/gender;

  • Photograph

  • Marital status

  • Emergency contacts and details of any dependants

  • Criminal background check information

  • Trade union membership (if required)

  • Social security number (or equivalent in your country) and any other tax-related information

  • Referee details

  • Immigration status (whether you need a work permit)

  • Nationality/citizenship/place of birth

  • Start date or availability date

  • A copy of your driving licence and/or passport/identity card

  • Bank details

  • Diversity information including racial or ethnic origin

  • Religious affiliation if relevant for tax reasons

  • Disability-related information

  • Next-of-kin details

  • Performance data (e.g. staff assessments and other information that relates to your interaction with colleagues)

  • Staff number/other identifier

  • Details of any grievance or disciplinary matters, whether brought by or against you or in which you are or have been otherwise involved

  • Information regarding communications with and services provided to clients

  • Log data on the use of Iyuno-SDI’s IT systems Some dubbing project contributors may be under 18, in which case Iyuno-SDI will hold the name and contact details of their parent or guardian

  • Extra information that you choose to tell us

  • Extra information that your referees choose to tell us about you

  • Extra information that our clients may tell us about you, or that we find from other third party sources such as social media, LinkedIn or job sites

  • IP address

  • The dates, times and frequency with which you access our services, CCTV footage if you attend our premises

If any situation arises where we collect additional data, we will inform you.To the extent that you access our website or click through any links in an email from us, we will also collect certain data from you. If you would like more information about this, please click here.

  • CONTRACTORS’, AGENCY AND TEMPORARY WORKERS’ DATA

Depending on the relevant circumstances and applicable local laws and requirements, we will collect some or all of the information listed below in order to ensure that our relationship runs smoothly and that we are able to comply with our contractual and other duties to each other, and to our clients and customers, and our duties to third parties such as tax authorities and government agencies.

(In some jurisdictions, we are restricted from processing some of the data outlined below. In such cases, we will not process the data in those jurisdictions.)

  • Name and contact details (title, first name, surname, phone number, email address, postal address, country of residence)

  • Age (and birthdate, if required for compliance purposes)

  • Qualification data and other information from CVs (school, further education and vocational training details and qualifications; and information relating to social interests)

  • Sex/gender;

  • Photograph

  • Marital status

  • Emergency contacts and details of any dependants

  • Criminal background check information

  • Trade union membership (if required)

  • Social security number (or equivalent in your country) and any other tax-related information

  • Referee details

  • Immigration status (whether you need a work or residence permit)

  • Nationality/citizenship/place of birth

  • Start date or availability date

  • A copy of your driving licence and/or passport/identity card

  • Bank details

  • Financial information (where we need to carry out financial background checks as far as relevant for the position of the contractor or worker)

  • Details of any sickness absence during the relationship including health related information if relevant for workplace safety or re-integration management

  • Diversity information including racial or ethnic origin,  ,

  • disability-related information

  • religious affiliation if relevant for tax reasons

  • Next-of-kin details

  • Performance data (e.g. staff assessments and other information that relates to your employment, your interaction with colleagues and employment-related issues that arise)

  • Information regarding communications with and services provided to clients

  • Log data on the use of Iyuno-SDI’s IT systems

  • Staff number/other identifier

  • Details of any grievance or disciplinary matters, whether brought by or against you or in which you are or have been otherwise involved

  • Details of any leave you take or request, or sickness absence including health-related information

If any situation arises where we collect additional data, we will inform you. A number of elements of the items listed above are required to enable us to fulfil our contractual duties to you or to others. Some, for example your social security number (or equivalent) are required by statute or other laws. Other items may simply be needed to ensure that our relationship can run smoothly, or to run our business.

Depending on the type of personal data in question and the grounds on which we may be processing it, should you decline to provide us with such data, we may not be able to fulfil our contractual requirements or, in extreme cases, may not be able to continue with our relationship.

  • CUSTOMER AND CLIENT DATA

    This category covers our customers, clients and others to whom Iyuno-SDI provides services in the course of its business or whom Iyuno-SDI reasonably considers would be interested in our services.

    The data we collect about customers and clients is actually very limited. We generally only need to have your contact details or the details of individual contacts at your organisation (such as their names, telephone numbers and postal and email addresses) to enable us to ensure that we can provide our services to you and ensure our relationship runs smoothly.

    We may also hold extra information that someone in your organisation has chosen to tell us.

    To the extent that you access our website or click through any links in an email from us, we will also collect certain data from you. If you would like more information about this, please click here.

  • ADVISORS’ AND CONSULTANTS’ DATA

    We don’t collect much data about advisors and consultants – we simply need to make sure that our relationship runs smoothly. We'll collect the details for our contacts within your organisation, such as names, telephone numbers and postal and email addresses. We'll also collect bank details, so that we can pay you. We may also hold extra information that someone in your organisation has chosen to tell us.

    To the extent that you access our website or click through any links in an email from us, we will also collect certain data from you. If you would like more information about this, please click here.

  • POTENTIAL RECRUITS’, JOB APPLICANTS’ AND CANDIDATES’ DATA:

    Depending on the relevant circumstances and applicable local laws and requirements, we will collect some or all of the information listed below to communicate with you in the context of recruitment. (In some jurisdictions we are restricted from processing some of the data outlined below. In such cases, we will not process the data in those jurisdictions.)

    • Name and contact details (title, first name, surname, phone number, email address, postal address, country of residence)

    • Age (and birthdate, if required for compliance purposes)

    • Qualification data and other information from CVs (school, further education and vocational training details and qualifications; and information relating to social interests)

    • Sex/gender;

    • Photograph

    • Marital status

    • Criminal background check information

    • Trade union membership (if required)

    • Social security number (or equivalent in your country)

    • Referee details

    • Immigration status (whether you need a work or residence permit)

    • Nationality/citizenship/place of birth

    • Start date or availability date

    • A copy of your driving licence and/or passport/identity card

    • Bank details

    • Financial information (where we need to carry out financial background checks as far as relevant for the position of the applicant)

    • Diversity information (racial or ethnic origin

    • disability-related information

    • Details about remuneration and benefits arrangements at a previous employer

      We may also collect other information about you, for example, where we have found you by searching LinkedIn or other job sites, we might collect information such as your employment history, education, qualifications, skills and interests, as well as any extra information which you have included on a profile or in a CV which you have uploaded to one of these sites.

      To the extent that you access our website or click through any links in an email from us, we will also collect certain data from you. If you would like more information about this, please click here.

  • SUPPLIER DATA

    We don't collect much data about suppliers – we simply need to make sure that our relationship runs smoothly. We'll collect the details for our contacts within your organisation, such as names, telephone numbers and postal and email addresses. We'll also collect bank details, so that we can pay you. We may also hold extra information that someone in your organisation has chosen to tell us.

    To the extent that you access our website or click through any links in an email from us, we will also collect certain data from you. If you would like more information about this, please click here.

  • COMPLAINANTS AND RESPONDENTS; ENQUIRERS

    We’ll only collect your name and contact details (title, first name, surname, phone number, email address, postal address) and whatever other information you choose to tell us.

  • PEOPLE WHOSE DATA WE RECEIVE FROM CANDIDATES AND CONTRACTORS, AGENCY AND TEMPORARY WORKERS (SUCH AS REFEREES, EMERGENCY CONTACTS AND DEPENDANTS)

    All we need from referees is confirmation of what you already know about a prospective member of staff. Emergency contact details give us somebody to call on in an emergency. To ask for a reference, we'll obviously need the referee's contact details (such as name, email address and telephone number). We'll also need these details if a potential recruit has put you down as their emergency contact so that we can contact you in the event of an accident or an emergency.

    We will collect your date of birth, contact details and potentially some health information if a contributor who is under 18 has put you down as a dependant. We may also be provided (by inference) with some limited information about your sexual orientation if a contributor or contractor identifies you as a spouse or partner when putting you down as a dependant, next of kin or emergency contact.

    The information described above is of course in addition to any personal data we are required by law to process in any given situation

View Summary

HOW DO WE COLLECT YOUR PERSONAL DATA?

We generally obtain personal data direct from individuals via email, post or telephone. 

Some information is obtained from other sources like agencies, referees, colleagues, clients, customers, suppliers, tax authorities or other third parties.

To the extent that you access our website or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we will also collect your data automatically or through you providing it to us.

We collect your data automatically via cookies, in line with cookie settings in your browser. If you are potential recruit, job applicant or candidate we will use data from your use of our websites to enhance other aspects of our communications with or service to you.

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  • We generally obtain personal data direct from individuals via email, post or telephone.

  • Some information is obtained from other sources.

    • Agencies provide us with information about job applicants

    • Your referees may disclose personal information about you to us We may obtain information about you from third party service providers who undertake background checks about you on our behalf at the start of our relationship

    • Your colleagues may share personal information about you with us

    • Other third parties like your local tax authority may share your personal data with us

    • Our clients and customers may share personal information about you with us. We obtain some personal data from online sources such as LinkedIn.

    • Some information about suppliers is obtained through engagement with studios (e.g. during supplier onboarding) or from the supplier’s invoice.

  • To the extent that you access our website or read or click on an email from us, where appropriate and in accordance with any local laws and requirements, we will also collect your data automatically or through you providing it to us. For more information please click here.

  • We collect your data automatically via cookies, in line with cookie settings in your browser. If you are potential recruit, job applicant or candidate we will use data from your use of our websites to enhance other aspects of our communications with or service to you. If you would like to find out more about cookies, including how we use them and what choices are available to you, please click here.

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HOW DO WE USE YOUR PERSONAL DATA?

Having obtained data about you, we then use it in a number of ways. The ways we use your personal data depend on the type of relationship we have with you.

In general, we use your personal data in order to perform the contract as far we have a contractual relationship with you (as a contributor, contractor, agency or temporary worker, customer, client, advisor or consultant, supplier). In that context, we use your personal data primarily in order to provide or to receive services, to make or receive payments, to help us establish, exercise or defend against legal claims and perform legal and regulatory obligations.

As far as you are a complainant, responder or enquirer, we use your personal data primarily in order to act on your complaint, response or enquiry, to perform legal and regulatory obligations and to establish, exercise or defend against legal claims.

As far as you are a person whose data we receive form others (such as a referee, emergency contact or dependant) we use your personal data in ways that enable us to support the purpose of your involvement

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Having obtained data about you, we then use it in a number of ways.

  • CONTRIBUTORS’ DATA: We generally use contributors data in the following ways:

    • to perform the contract we have concluded with you

    • To provide advice and assistance

    • To provide services to customers and clients

    • Store your details (and update them when necessary) on our systems so that we can contact you

    • Review your information to work out whether and how your services might be relevant

    • To help us establish, exercise or defend legal claims

    • To perform certain legal and regulatory obligations

    • Storing details (and updating them when necessary) on our systems

  • CONTRACTORS’, AGENCY AND TEMPORARY WORKERS’ DATA: We use these categories of data:

    • To communicate with contractors, agency and temporary workers in order to establish and manage Iyuno-SDI’s relationship with those individuals and organisations (e.g. in relation to projects and production and dubbing management), including assessing performance, and to help us to help you and understand our legal obligations if you suffer from a health condition or disability.

    • to perform the contract we have concluded with you

    • To pay contractors, agency and temporary workers

    • Store your details (and update them when necessary) on our systems so that we can contact you

    • Review your information to work out whether and how your services might be relevant

    • To establish, exercise or defend against legal claims

    • To perform certain legal and regulatory obligations

    • Storing details (and updating them when necessary) on our systems

  • CUSTOMER AND CLIENT DATA: We use this information:

    • To perform the contract we have concluded with our customers and clients

    • To facilitate the provision of services by Iyuno-SDI to our customers and clients (e.g. keeping records of our conversations and meetings, so that we can provide targeted services to you)

    • To receive payment from customers and clients

    • To establish, exercise or defend against legal claims

    • To perform certain legal and regulatory obligations

    • Storing details (and updating them when necessary) on our systems

      We will use your personal data for these purposes if we deem this to be necessary for our legitimate interests. If you would like to know more about what this means, please click here.

      If you are not happy about this, in certain circumstances you have the right to object and can find out more about how and when to do this here.

  • ADVISORS’ AND CONSULTANTS’ DATA: We use this information:

    • To perform the contracts we have concluded with advisors and consultants

    • To communicate with third parties such as consultants and advisors in the course of our relationship with them, and government agencies (e.g. tax authorities)

    • To pay suppliers and service providers

    • To establish, exercise or defend against legal claims

    • To perform certain legal and regulatory obligations

    • Storing details (and updating them when necessary) on our systems

  • SUPPLIER DATA: We use supplier data:

    • To perform the contracts we have concluded with our suppliers

    • To store (and update when necessary) your details on our database, so that we can contact you in relation to our agreements

    • To offer services to you or to obtain support and services from you

    • To perform certain legal obligations

    • In more unusual circumstances, to help us to establish, exercise or defend legal claims.

      We will use your personal data for these purposes if we deem this to be necessary for our legitimate interests. If you want to know more about what this means, please click here.

      If you are not happy about this, in certain circumstances you have the right to object and can find out more about how to do so here.

      Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements. For more information in relation to your jurisdiction, please click here.

  • COMPLAINANTS AND RESPONDENTS; ENQUIRERS: We use this information:

    • To store (and update when necessary) details on Iyuno-SDI’s systems so that Iyuno-SDI can communicate with relevant individuals in relation to their complaint, response or enquiry

    • To perform certain legal and regulatory obligations

    • To establish, exercise or defend against legal claims

  • PEOPLE WHOSE DATA WE RECEIVE FROM OTHERS, SUCH AS REFEREES, EMERGENCY CONTACTS AND DEPENDANTS: We will only use the information that prospective recruits give us about you for the following purposes:

    • If you are nominated by a member of staff as an emergency contact, we'll contact you in the case of an accident or emergency affecting them; or

    • If you were nominated by a member of staff as a next of kin or dependant we will store your personal data to ensure the personnel records of that member of staff are correct

    • If you were nominated by a prospective staff member as a referee, we will contact you to get a reference or give your details to a third party to do this on our behalf.

      We will use your personal data for these purposes if we deem this to be necessary for our legitimate interests or in accordance with applicable employment law. If you would like to find out more about what this means, please click here.

      If you are not happy about this, you have the right to object and can find out more about how to do so here.

View Summary

WHO DO WE SHARE YOUR PERSONAL DATA WITH?

Where appropriate and in accordance with local laws and requirements, we may share certain of your personal data: within the Iyouno-SDI group which means with group companies and colleagues within Iyuno-SDI, and for the conduct of business outside the Iyuno-SDI group with clients, customers and suppliers as well as for the performance of a contract with tax, audit or other authorities. We may also share your personal data with other recipients like for example third party service providers who perform functions on our behalf, third party outsourced IT and document storage providers or third parties who we have retained to provide services such as reference, qualification and criminal convictions checks,

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Where appropriate and in accordance with local laws and requirements, we will share your personal data, in various ways and for various reasons, with the following categories of people:

  • Customers and clients as far as necessary for performing contracts \

  • Any of our group companies

  • Appropriate colleagues within Iyuno-SDI (this may include colleagues in overseas offices)

  • Current, past or prospective employers (for example, when providing a reference, where permissible in accordance with local laws and requirements);

  • Suppliers as far as necessary for performing contracts

  • Individuals and organisations as far as necessary to obtain information related to your reference or application to work for us, such as information from current, past or prospective employers, educators and examining bodies and employment and recruitment agencies

  • Tax, audit or other authorities, when we believe in good faith that the law or other regulation requires us to share this data (for example, because of a request by a tax authority or in connection with any anticipated litigation)

  • Service providers (whether third parties or our group companies) who perform functions on our behalf (including external consultants, business associates and professional advisers such as lawyers, auditors and accountants, administration functions, technical support functions and IT consultants carrying out testing and development work on our business technology systems)

  • Third party outsourced IT and document storage providers where we have an appropriate processing agreement (or similar protections) in place

  • In the case of prospective recruits and their referees: third parties who we have retained to provide services such as reference, qualification and criminal convictions checks, to the extent that these checks are appropriate and in accordance with local laws

  • If Iyuno-SDI merges with or is acquired by another business or company in the future, (or is in meaningful discussions about such a possibility) we may share your personal data with the (prospective) new owners of the business or company at an appropriate stage of the transaction as far as the transfer of anonymous or pseudonymous data is not sufficient.

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HOW DO WE SAFEGUARD YOUR PERSONAL DATA?

We put in place appropriate measures that are designed to prevent unauthorised access to, and misuse of, your personal data. These include measures to deal with any suspected data breach.

If you suspect any misuse or loss of or unauthorised access to your personal data please let us know immediately. Details of how to contact us can be found here.

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  • We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access. We do this by having in place a range of appropriate technical and organisational measures. These include measures to deal with any suspected data breach.

  • If you suspect any misuse or loss of or unauthorised access to your personal information please let us know immediately. Details of how to contact us can be found here.

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HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?

If you are a contributor, customer, client or a supplier we will retain your personal data in order to provide you with services or to receive services from you.

If we engage you as a contractor or agency or temporary worker, we will ordinarily process your data throughout the course of your relationship with us and will then retain it for a period after we have parted ways. The precise length of time will depend on the type of data, our legitimate business needs and other legal or regulatory rules that may require us to retain it for certain minimum periods.

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  • If you are a contributor, customer, client or a supplier we will retain your personal data in order to provide you with services or to receive services from you.

  • If we engage you as a contractor or agency or temporary worker, we will ordinarily process your data throughout the course of your relationship with us and will then retain it for a period after we have parted ways. The precise length of time will depend on the type of data, our legitimate business needs and other legal or regulatory rules that may require us to retain it for certain minimum periods. For example, we may be required to retain certain data for the purposes of tax reporting or responding to tax queries. We may also retain it if it might be relevant to any potential litigation. In jurisdictions that allow it, we will generally retain personal data relating to you where necessary to enable us to provide you or a future employer with a reference.

  • In determining the appropriate retention period for different types of personal data, we always consider the amount, nature, and sensitivity of the personal data in question, the potential risk of harm from unauthorised use or disclosure of that personal data, the purposes for which we need to process it and whether we can achieve those purposes by other means (in addition of course to ensuring that we comply with our legal, regulatory and risk-management obligations, as described above).

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HOW CAN YOU ACCESS, AMEND OR TAKE BACK THE PERSONAL DATA THAT YOU HAVE GIVEN TO US?

One of the GDPR’s main objectives is to protect and clarify the rights of EU citizens and individuals in the EU with regard to data privacy. To get in touch about these rights, please contact us.

The GDPR gives you the following rights in relation to your personal data:

Right to object

In general, this right enables you to object to us processing your personal data where we do so because it is in our legitimate interests.

Right to withdraw consent

Where we have obtained your consent to process your personal data for certain activities (for example, in order to use cookies in certain jurisdictions), you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to, unless we consider that there is an alternative legal basis to justify our continued processing of your data for this purpose.

Right to submit a data subject access request (DSAR)

You may ask us to confirm what information we hold about you at any time, and request us to modify, update or delete such information.

Right to erasure

You have the right to request that we "erase" your personal data in certain circumstances.

Right to restrict processing

You have the right to request that we restrict our processing of your personal data in certain circumstances.

Right to rectification

You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you.

Right of data portability

You have the right to transfer your personal data that we hold on you to another third party. This right applies to: (i) personal data that we process automatically; (ii) personal data provided by you; and (iii) personal data that we process based on your consent or in order to fulfil a contract.

Right to lodge a complaint with a supervisory authority

You also have the right to lodge a complaint with your local supervisory authority. Details of how to contact them can be found here.

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  • One of the GDPR's main objectives is to protect and clarify the rights of EU citizens and individuals in the EU with regards to data privacy. This means that you retain various rights in respect of your data, even once you have given it to us. These are described in more detail below.

  • To get in touch about these rights, please contact us. We will seek to deal with your request without undue delay, and in any event within one month (subject to any extensions to which we are lawfully entitled). Please note that we will, where necessary, keep a record of your communications to help us resolve any issues which you raise.

  • Right to object: this right enables you to object to us processing your personal data where we do so for our legitimate interests. We have explained above where we do this. If your objection relates to us processing your personal data because we deem it necessary for your legitimate interests, we must act on your objection by ceasing the activity in question unless we can show that we have compelling legitimate grounds for processing which overrides your interests or we are processing your data for the establishment, exercise or defence of a legal claim.

  • Right to withdraw consent: Where we have obtained your consent to process your personal data for certain activities (for example, in order to use cookies in certain jurisdictions), you may withdraw this consent at any time and we will cease to carry out the particular activity that you previously consented to unless we consider that there is an alternative reason to justify our continued processing of your data for this purpose in which case we will inform you of this condition.

  • Data Subject Access Requests (DSAR): You may ask us to confirm what information we hold about you at any time, and request us to modify, update or delete such information. We may ask you to verify your identity and for more information about your request. If we provide you with access to the information we hold about you, we will not charge you for this unless your request is manifestly unfounded or excessive. If you request further copies of this information from us, we may charge you a reasonable administrative cost where legally permissible. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.

  • Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding data subject access requests and may refuse your request in accordance with such laws. For more information in relation to your jurisdiction, please click here.

  • Right to erasure: You have the right to request that we erase your personal data in certain circumstances. Normally, the information must meet one of the following criteria:

    • the data are no longer necessary for the purpose for which we originally collected and/or processed them;

    • where previously given, you have withdrawn your consent to us processing your data, and there is no other valid reason for us to continue processing;

    • the data has been processed unlawfully (i.e. in a manner which does not comply with the GDPR);

    • it is necessary for the data to be erased in order for us to comply with our legal obligations as a data controller; or

    • if we process the data because we believe it necessary to do so for our legitimate interests, you object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.

  • Please note that in certain of the jurisdictions in which we operate, we comply with additional local law requirements regarding data subject right to erasure and may refuse your request in accordance with local laws. For more information in relation to your jurisdiction, please click here.

  • We would only be entitled to refuse to comply with your request for one of the following reasons:

    • to exercise the right of freedom of expression and information; or

    • to exercise or defend a legal claim.

  • When complying with a valid request for the erasure of data we will delete the relevant data.

  • Right to restrict processing: You have the right to request that we restrict our processing of your personal data in certain circumstances. This means that we can only continue to store your data and will not be able to carry out any further processing activities with it until either: (i) one of the circumstances listed below is resolved; (ii) you consent; or (iii) further processing is necessary for either the establishment, exercise or defence of legal claims, the protection of the rights of another individual, or reasons of important EU or Member State public interest.

  • The circumstances in which you are entitled to request that we restrict the processing of your personal data are:

    • where you dispute the accuracy of the personal data that we are processing about you. In this case, our processing of your personal data will be restricted for the period during which the accuracy of the data is verified;

    • where you object to our processing of your personal data for our legitimate interests. Here, you can request that the data be restricted while we verify our grounds for processing your personal data;

    • where our processing of your data is unlawful, but you would prefer us to restrict our processing of it rather than erasing it; and

    • where we have no further need to process your personal data but you require the data to establish, exercise, or defend legal claims.

  • If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.

  • Right to rectification: You also have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. Where appropriate, we will also tell you which third parties we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.

  • Right of data portability: If you wish, you have the right to transfer your personal data between controllers. To allow you to do so, we will provide you with your data in a commonly used machine-readable format that is password-protected so that you can transfer the data to another online platform. Alternatively, we will directly transfer the data for you. This right of data portability applies to: (i) personal data that we process automatically (i.e. without any human intervention); (ii) personal data provided by you; and (iii) personal data that we process based on your consent or in order to fulfil a contract.

  • Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with your local supervisory authority. Details of how to contact them can be found here.

  • If you would like to exercise any of these rights, or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), details of how to contact us can be found here. Please note that we will, where necessary, keep a record of your communications to help us resolve any issues which you raise.

  • It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during the period for which we hold your data.

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WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL DATA

You can find out which Iyuno-SDI entity is responsible for processing your personal data and where it is located by following this link.

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  • You can find out which Iyuno-SDI entity is responsible for processing your personal data and where it is located by following this link.

  • If you have any comments or suggestions concerning this Privacy Policy please follow this link. We take privacy seriously so we'll get back to you as soon as possible.

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HOW DO WE STORE AND TRANSFER YOUR DATA INTERNATIONALLY?

In order carry out the purposes described in this Privacy Policy, your data may be transferred to recipients located outside of your jurisdiction:

To ensure that your personal information receives an adequate level of protection, we have put in place data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal data.

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  • In order to carry out the purposes described in this Privacy Policy, your data will be transferred:

    • between and within Iyuno-SDI entities (appropriate colleagues within Iyuno-SDI);

    • to third parties (such as advisers or other service providers to Iyuno-SDI)

    • to overseas clients, where applicable

    • to clients within your country, where applicable, who may, in turn, transfer your data internationally

    • to a cloud-based storage service provider

    • to other third parties, as referred to here.

  • We want to make sure that your data is stored and transferred in a way which is secure. We will therefore only transfer data outside of the European Economic Area or EEA (i.e. the Member States of the European Union, together with Norway, Iceland and Liechtenstein) where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data, for example:

    • by way of data transfer agreement, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal data by data controllers in the EEA to data controllers and processors in jurisdictions without adequate data protection laws; or

    • transferring your data to a country where there has been a finding of adequacy by the European Commission in respect of that country's levels of data protection via its legislation; or

    • where it is necessary for the conclusion or performance of a contract between ourselves and a third party and the transfer is in your interests for the purposes of that contract (for example, if we need to transfer data outside the EEA in order to meet our obligations under that contract if you are a client of ours); or

    • where you have consented to the data transfer.

  • To ensure that your personal information receives an adequate level of protection, we have put in place appropriate procedures with the third parties we share your personal data with to ensure that your personal information is treated by those third parties in a way that is consistent with and which respects the law on data protection.

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OUR LEGAL BASES FOR PROCESSING YOUR DATA

Under the GDPR, we can process your data where it is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights or freedoms which require protection of personal data.

For contributors, customers and clients, and suppliers, we will also process personal data because it is necessary for the performance of a contract with you (or in order to take steps at your request before to entering into a contract).

We also have other legal obligations that we need to comply with and the GDPR states that we can process your personal data where this processing is necessary for compliance with a legal obligation to which we are subject.

Sometimes it will be necessary for us to process personal data and, where appropriate and in accordance with local laws and requirements, sensitive personal data in connection with exercising or defending legal claims. The GDPR allows this where the processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.

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  • The GDPR says that we can process your data where it is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights or freedoms which require protection of personal data. We process personal data relating to contributors, customers and clients, suppliers and others who provide information to us such as referees, emergency contacts and dependents, on this basis. You have the right to object to us processing your personal data on this basis – if you would like to know more about how to do so, please click here.

  • For contributors, customers and clients, and suppliers, we will also process personal data because it is necessary for the performance of a contract with you (or in order to take steps at your request before to entering into a contract). This enables us to perform our part of our contract with you and our obligations to third parties, and to ensure that you are properly fulfilling your obligations to us. As a simple example, we may process your bank account details and name (and other verifying information) in order to pay you in accordance with your contract.

  • We also have other legal obligations that we need to comply with and the GDPR states that we can process your personal data where this processing is necessary for compliance with a legal obligation to which we are subject. An example of a legal obligation that we need to comply with is our obligation to co-operate with tax authorities, including providing details of your remuneration and tax paid.

  • Sometimes it will be necessary for us to process personal data and, where appropriate and in accordance with local laws and requirements, sensitive personal data in connection with exercising or defending legal claims. The GDPR allows this where the processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity. This will arise for example where we need to take legal advice in relation to legal proceedings or are required by law to preserve or disclose certain information as part of the legal process.

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ANNEX 1 – HOW TO CONTACT US

Country in which you use Iyuno-SDI services or supply Iyuno-SDI with servicesIyuno-SDI entity responsible for processing your personal dataHow you can get in touch with us: • to access, amend or take back the personal data that you have given to us;
• if you suspect any misuse or loss of or unauthorised access to your personal information;
• to withdraw your consent to the processing of your personal data (where consent is the legal basis on which we process your personal data);
• with any comments or suggestions concerning this Privacy Policy
BelgiumIyuno-SDI Belgium BVNinovesteenweg 198, 9320 Aalst, Belgium
DenmarkIyuno-SDI Denmark A/SFarvergade 2, 1th; 1463 Copenhagen K, Denmark
FinlandIyuno-SDI Finland OyTallberginkatu 2 B, 00180 Helsinki, Finland
FranceIYUNO-SDI France S.A.S.6 rue des Bretons 93210 St Denis La Plaine, France
GermanyIyuno-SDI Germany GmbHEUREF-Campus 10-11, 10829 Berlin, Germany Phone:+ 49 30 767870  | E-Mail: info@berliner-synchron.de
Hong KongIyuno-SDI HONG KONG Ltd.8/F, Continental Electric Industries Building, 17 Wang Chiu Road, Kowloon Bay, Hong Kong SAR
HungaryIyuno-SDI Hungary KftBudapest, Soroksári út 48. 10. ép. 3. em. 7., 1095, Hungary
ItalyIyuno-SDI Italy S.r.l.Via Nevio, 1 00136 Roma IT, p. IVA 06056531004, REA 947837
KoreaIYUNO-SDI Global Inc.12F Dream tower, 19, World Cup buk-ro 56-gil, Mapo-Gu, Seoul
MalaysiaI-YUNO Malaysia Sdn BhdE-05-01, Menara SUEZCAP 2, KL Gateway, No 2 Jalan Kerinchi, Gerbang Kerinchi Lestari, Kuala Lumpur
NetherlandsIyuno-SDI Netherlands B.V.Franciscusweg 219D, 1216SE Hilversum, Netherlands
NorwayIYUNO-SDI Norway ASGjerdrumsvei 14, 0484 Oslo, Norway
PhilippinesIyuno-SDI Philippines, Inc. 7F, Multinational Bancorporation Centre, 6805 Ayala Avenue, Makati City
PolandIYUNO-SDI Poland Sp. z o.o.Postepu 6, 02-676 Warszawa, Polska
RomaniaIyuno-SDI Romania S.r.lBd. Corneliu Coposu nr. 5, Bloc 103, Scara 2, Etaj 3, Apt. 32, București, cod poștal 030602, România
SingaporeI-YUNO ASIA PTE. LTD.8 Tomlinson Road, 11-01 Hana, Singapore
SwedenIyuno-SDI Sweden ABKungsbro Strand 15a 112 26 Stockholm, Sweden
UKIyuno-SDI UK Ltd.3rd Floor, 578-586 Chiswick High Road, London W4 5RP
USAIyuno-SDI US Inc. 3601 W Olive Avenue, Suite 650, Burbank, CA 91505, USA
WalesIyuno-SDI Trosol Ltd.1 Cwrt-y-Parc, Parc Ty Glas, Llanishen, Cardiff CF14 5GH

ANNEX 2 – HOW TO CONTACT YOUR LOCAL SUPERVISORY AUTHORITY

CountryDetails of your local supervisory authority
BelgiumData Protection Authority Rue de la Presse - Drukpersstraat 35 1000 Brussels Belgium Telephone: +32 (0)2/274.48.00 Email: commision@privacy commission.be Website: www.gegevensbeschermingsautoriteit.be/ (Dutch) www.autoriteprotectiondonnees.be/ (French) www.dataprotectionauthority.be/ (English)
BulgariaPeronal Data Protection Commission 15 Acad. Ivan EvstatieV Geshov Blvd., Sofia 1431, Bulgaria Telephone: +359 2 91 53 515 Email: kzld@government.bg Website: www.cdpd.bg
DenmarkDatatilsynet (The Data Protection Agency) Borgergrade 28, 5 DK-1300 Copenhagen K Telephone: +45 33 19 32 00 Email: dt@datatilsynet.dk Website: www.datatilsynet.dk
FinlandThe Data Protection Obmudsman (Teitosuojavaltuutettu) The Office of the Data Protection Ombudsman Ratapihantie 9 00520 Helsinki Finland Telephone: +358 29 56 66700 Email: tietosuoja@om.fi Website: www.tietosuoja.fi
FranceCommission Nationale de L'informatique et des Libertés (CNIL) 3 Place de Fontenoy TSA 80715 75334 Paris CEDEX 07 Telephone: 01 53 73 22 22 Website : www.cnil.fr
GermanyBerliner Beauftragte für Datenschutz und InformationsfreiheitMaja Smoltczyk Friedrichstraße 219 10969 Berlin Telefon: 030/138 89-0 Telefax: 030/215 50 50 E-Mail: mailbox@datenschutz-berlin.de
Hong KongPrivacy Commissioner for Personal Data 12/F 248 Queen’s Road East Wanchai Hong Kong Telephone: +852 2827 2827 Email: enquiry@pcpd.org.hk
HungaryPresident of the NAIH 22c Szilágyi Erzsébet fasor Budapest H-1125 Hungary Telephone: +36 (1) 391-1400 Email: ugyfelszolgalat@naih.hu Website: www.haih.hu
ItalyGarante per la protezione dei dati personali Piazza di Monte Citorio n. 121 00186 Rome Italy Telephone: +39 06.69677.2917 Email: garante@gpdp.it Certified email: protocollo@pec.gpdp.it Website: www.garanteprivacy.it
KoreaPersonal Information Protection Commission 4th Floor Government Complex (03171) 209 Sejong-daero, Jongno-gu Seou
MalaysiaPersonal Data Protection Commissioner www.pdp.gov
NetherlandsCollege Bescherming Persoonsgegevens (Data Protection Commission) Juliana van Stolberglaan 4–10 2595 AJ Den Haag PO Box 93374 2595 CL Den Haag The Netherlands Telephone: +31 70 888 8500 Email: info@cbpweb.nl Website: www.cpbweb.nl
NorwayThe Data Inspectorate PO Box 8177 Dep N-0034 Oslo Norway (mail) Tollbugt 3 Oslo Norway (visitors) Telephone: +47 22 39 69 00 Email: postkasse@datatilsynet.no Website: www.datatilsynet.no
PolandPrezes Urzędu Ochrony Danych Osobowych ul. Stawki 2,00-193 Warsaw Telephone: +48 22 531 03 00 Email: kancelaria@giodo.gov.pl
RomaniaThe National Supervisory Authority for Personal Data Processing Bucharest, Romania, 28-30 G-ral Gheorghe Magheru Bld., District 1, post code 010336 E-mail: anspdcp@dataprotection.ro Telephone: +40.318.059.211
Sweden
SingaporePersonal Data Protection Commission 10 Pasir Panjang Road #03-01 Mapletree Business City Singapore 117438 Telephone: +65 6377 3131 Email: qsm@imda.gov.sg Website: www.pdpc.gov.sg
UKThe Information Commissioner's Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Telehone: 0303 123 1113 Email: casework@ico.org.uk Website: www.ico.gov.uk
USAN/A

ANNEX 3 – COUNTRY-SPECIFIC VARIATIONS TO OUR PRIVACY POLICY

PRIVACY POLICY TOPIC JURISDICTIONCOUNTRY-SPECIFIC LEGAL REQUIREMENT
WHAT KIND OF PERSONAL INFORMATION DO WE COLLECT? HOW DO WE USE YOUR PERSONAL DATA?DenmarkDenmark holds personal data solely for customers and suppliers (name and contact details, telephone numbers, email and postal addresses), for invoicing purposes only.
WHAT KIND OF PERSONAL INFORMATION DO WE COLLECT ADDITONALLY? HOW DO WE USE YOUR PERSONAL DATA? GermanyIn addition to the information specified above, in Germany we may also collect the following personal data in respect of contributors, and contractors, agency and temporary workers: place of birth, number of children.
WHAT KIND OF PERSONAL INFORMATION DO WE COLLECT?FranceIn addition to the information specified above, in France we may also collect the following personal data in respect of contributors, and contractors, agency and temporary workers: national ID.
WHAT KIND OF PERSONAL INFORMATION DO WE COLLECT?MalaysiaIn addition to the information specified above, in Malaysia we may also collect information relating to family particulars (spouse and children information, where this is required by law).
WHAT KIND OF PERSONAL INFORMATION DO WE COLLECT? HOW DO WE USE YOUR PERSONAL DATA?RomaniaIn addition to the information specified above, in Romania we also collect CNP (assigned at birth), CI / BI series and number (identification card for all citizens), photograph, copy of CI, birth certificate of the child (if applicable, e.g. to identify child voice actors where the contract is made with parent or guardian). Where contributors are under 18, statements are obtained from a parent or guardian as to their legal responsibility, social health insurance, maintenance arrangements etc. (if applicable). Personal data is transmitted to ANAF (National Agency for Fiscal Administration); Revisal Labor Inspectorate; banks at each payment, in accordance with local law.
OTHER