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Privacy Policy

Updated 9 August 2021

Talenthouse IP LLC owns the platform you are using called Untitled. Talenthouse IP, LLC, 827 Santa Barbara Dr., Farmington, NM, 87401, USA. Company number: 6268714 (“we/us/our”).

Talenthouse IP LLC owns the personal data collected from Untitled users. Users are Educators, Parent or Guardian and Young Creators. We are at times a data controller who determines the purpose and manner in which your personal data is used, and at other times a data processor, in which case someone else’s Privacy Policy would apply.

Talenthouse IP LLC and Untitled is committed to respecting all our users and will ensure that you privacy and the data we are responsible for is protected.

This Policy is effective from 9 August 2021 and all personal data passed to us will be treated in accordance with this Policy. The Policy which is applicable at any point in time will be displayed on our website untitled.talenthouse.com.

What personal data do we collect?

This depends on who you are and how you are interacting with our website.

For Educators we collect and store your personal identification information such as

  • Username and password
  • Display name (visible on Untitled)
  • First and last name
  • Email
  • City
  • Country
  • Employer (School / educational organisation) name
  • Role
  • Interests

For Parent/Guardians we collect and store your personal identification information such as

  • Username and password
  • Display name (visible on Untitled)
  • First and last name
  • Email
  • City
  • Country
  • Gender
  • Are you an educator as well? Yes / No
  • Interests

For Young Creators our third-party provider (SuperAwesome, see below) collects and stores your personal identification information such as

  • Display name (visible on Untitled)
  • Date of birth (day, month, year)
  • City
  • Country
  • Gender
  • Interests

Sensitive Data

This is personal data about an individual’s racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership (or non-membership), physical or mental health or condition, criminal offences, or related proceedings. We do not collect this kind of information. We ask that you not send us, and you not disclose, any sensitive personal on or through our Website or otherwise.

How do we collect your data?

Users directly provide us with most of the personal data we collect through this website. We collect and process this personal data when you

  • Visit and view our website via your browser’s cookies
  • Register and create an account online
  • Use services on our website
  • Communicate with by telephone, email and social media
  • Fill in forms, surveys or questionnaires

Where a Young Creator is below the age of digital consent in the country they live, we collect a Parent or Guardian email address during the registration process. We will store this in connection with the Young Creators’ profile, and we will only email the Parent or Guardian if their young creator is selected for a Creative Brief and we need to fulfil the prize. Note we won’t be collecting these creator’s own email due to their age.

How we use your data

We provide a creative community platform service to Young Creators and other users and your information can help us understand your needs. We only use the information we collect for the reasons you give it to us.

We also collect and use your personal data for our business or operational needs so that we can:

  • Manage accounts
  • Communicate with users, telephonically, by email or via social media
  • Administer Creative Briefs that have been have submitted
  • Fulfil any awards that may be won
  • Improve our services through knowledge of what is used and how it is used

Additionally, we may use your, or a Young Creator’s information in situations where Company has a good faith belief that such disclosure is necessary to:

  • Investigate complaints
  • Complying with our legal, regulatory and corporate governance obligations

We may use your personal data to market our business as long as we have consent from the Educator, Parent, or Young Creator’s Parent or Guardian if the user is below the digital age of consent, or the Young Creator themselves if they are above the digital age of consent.

Will your data be shared?

We do not sell your personal data to third parties and we use your personal data internally. We do not share your personal data outside of our own group of companies, except with our carefully selected service providers that carry out certain functions on our behalf and we only provide them with as little personal data as possible to carry out these functions. The companies in our Group, are Ello, Talenthouse, Zooppa.

The organisations that will receive your personal data, who are not affiliated to us, and as part of our doing business are

  • SuperAwesome Trading Limited (for managing Young Creator’s registration. UK registered, company number 03885555. US servers): 8 Duncannon Street, London, England, WC2N 4JF, United Kingdom
  • W2 GLOBAL DATA SOLUTIONS LIMITED (UK registered, company number 7669978): Clarence House, Clarence Place, Newport, NP19 7AA, UK
  • Asana, Inc: 1550 Bryant Street, Suite 200, San Francisco, CA 94103
  • Google, Inc: 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States
  • Amazon.com, Inc: P.O. Box 81226, Seattle, WA 98108-1226, United States
  • Heroku, Inc: 650 7th Street, San Francisco, CA 94103, United States
  • Onemorecloud, Inc: 84 Sycamore St, San Francisco, CA 94110, United States
  • 84codes AB: Kaptensgatan 7, 58212 Linköping, Sweden
  • Cloudinary Ltd: 21c Yegia Kapayim St., PO 3871, Petach Tikva 49130, Israel
  • New Relic, Inc: 88 Spear Street, San Francisco, CA 94105, United States
  • Keen Labs, Inc: 325 9th Street, San Francisco, CA 94103, United States
  • Papertrail, Inc: 1425 Broadway, Seattle, WA 98122, United States
  • Exceptional Cloud Services, LLC: 548 Market Street, San Francisco, CA 94104, United States
  • Facebook Pixel (a division of Facebook Inc): 1601 Willow Road, Menlo Park, CA 94025, United States
  • Quantcast Corp.: 795 Folsom Street, San Francisco, CA 94107, United States
  • Mixpanel Inc: 405 Howard Street 2nd Floor, San Francisco, California 94105, United States
  • Sendinblue: 7 rue de Madrid, 75008 Paris, France
  • Mobius Labs GmbH Bülowstr. 66 (Aufgang D3) 10783 Berlin, Germany

How do we protect and store your personal data?

We use commercially reasonable administrative, technical, and physical measures to safeguard information against loss, theft and unauthorized use, disclosure or modification. We also limit who has access to it.

Despite our best efforts, no security measures are perfect or impenetrable.

Whilst we take appropriate technical and organisational measures to safeguard your personal data, it is important that you keep your personal login details and devices protected from unauthorised access.

How long we store your data for

We will retain your data for no longer than is necessary and in any event no longer than 7 years from the date of last use. In these limited circumstances we may retain your information after your relationship with us has ended. For example, we may need to take into consideration any regulations that we must fulfil, for example for auditing purposes or for legitimate business purposes.

Application of Policy

This Policy applies to all our staff when they process your personal data and we will ensure that they are familiar with this Policy and comply with its terms.

Marketing

We would like to send marketing information, from time to time about our promotions, products or services but we will only do so when we have consent from you or your Parent or Guardian, and you can opt-out or change your notification settings of at any time.

What are your data rights?

We would like to make sure you are aware of all your data protection rights. Every user is entitled to the following

The right to access – You can request copies of your personal data

The right to rectification – You can request that we correct any information you believe is inaccurate. You can ask us to complete information you believe is incomplete

The right to erasure – You can request that we erase your personal data under certain conditions

The right to restrict processing – You can request that we restrict the processing of personal data under certain conditions

The right to restrict processing – You can request that we restrict the processing of personal data under certain conditions

The right to object to processing – You can object to us processing of personal data under certain conditions

The right to data portability – You can request that we transfer the data we have collected to other organisations, or directly to you, under certain conditions

If you make a request, we will have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email address below.

Transferring Data Internationally

Current Data Protection Legislation requires that during the transfer period when the UK leaves the EU until an Adequacy Decision has been reached, personal data will not be transferred outside of the European Economic Area (EEA) unless such transfer is to a country or jurisdiction where a) the EU Commission has approved it as having an adequate level of protection (including to the USA under a Privacy Shield agreement) or b) appropriate safeguards are in place as set out in Article 46 GDPR or c) equivalent provisions of subsequent Data Protection Legislation are in place or d) the transfer is otherwise allowed by applicable Data Protection Legislation (such as in the form of a derogation under Article 49 GDPR).

This platform has global reach. The Untitled server is based in the Unites States. The entities within our Group, may receive your data, and it will be transferred outside of the United States, to the European Union and the UK within our Group and to our trusted providers who deliver services to us. Where personal data will be transferred in this way, we will ensure that it is protected.

What are Cookies?

Cookies are small text files containing a unique identifier, which are stored on your computer or mobile device so that your device can be recognised when you are using a particular website or mobile app. They can be used only for the duration of your visit or they can be used to measure how you interact with services and content over time. Cookies help to provide important features and functionality on our Website, and to improve your customer experience. Cookies can also be used help us to detect fraudulent activity or to prevent security breaches and so we may record information about your device within the cookie.

What types of Cookies do we use?

We use cookies and similar technologies, (“Cookies”), to personalise and improve your customer experience as you use our website and to provide you with relevant online advertising. If you are concerned about the storage and use of cookies, you may be able to direct your Internet browser to notify you and seek approval whenever a cookie is being sent to your hard drive. You may also delete a cookie manually from your hard drive through your Internet browser or other programs. Please note, however, that some parts of our Services will not function properly or be available to you if you refuse to accept a cookie or choose to disable the acceptance of cookies.

Our Cookie Policy

Please refer to our Cookie Policy which can be found here.

Third-Party privacy policies and other websites

Clicking on links on this website may take you to a third-party website. At the point you enter the third-party website, the privacy and cookie policy of that third party will apply to all information that you provide. It is important at that point to read that third party’s privacy and cookie policy as we do not accept any responsibility or liability for websites of other organisations.

Changes to our Privacy Policy

We may supplement or amend this Policy from time to time. Any new or modified Policy will be circulated to staff before being adopted or appearing on our website. We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. Notice may be by email to you at the last email address you provided us, by posting notice of such changes on our sites and applications, or by other means, consistent with applicable law.

How to contact us

If you have additional questions regarding this privacy policy, please contact us at: hello.untitled@talenthouse.com.

How to contact the appropriate authority

We’d like the chance to resolve any complaints you have; however you also have the right to complain to the UK data protection regulator (the "ICO") about how we have used your personal data. Their website is https://ico.org.uk/your-data-matters/raising-concerns/.