privacy policy

Privacy Policy & Cookie Policy

Updated 10/September/2021

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1. General

This Policy describes how Genflow and other companies in the Genflow group (also referred to as “Genflow”, “we” or “us”) will make use of your data when you interact with us and our website and when we provide talent management, social media, brand and advertising management or other related services to you. It also describes your data protection rights, including a right to object to some of the processing which Genflow carries out. More information about your rights and options, and how to exercise them, is set out in the “Your rights” section at 3. below.

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Genflow Ltd is the data controller for your information. Further information on Genflow:

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Genflow Ltd
Registered number: 09083410
Registered address: Klaco house, 28 St John's Square, Clerkenwell, EC1M 4DN

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1. Collection of personal data

What information do we collect?

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We collect and process personal data about you when you interact with us and our website, and when we provide services to you. This includes:

• your name
• your gender
• your age/date of birth
• your home address, email address and phone number
• details of your social media presence including username, posts, profiles, number of followers/subscribers and details of your audience demographics
• your career and brand strategy and goals where we provide talent management services to you
• your email correspondence where we manage your commercial email communications as part of our services to you in order to maximise business opportunities on your behalf
• reviewing direct messages from your social media platform (e.g. Instagram) in order to fulfil our contract with you (e.g. customer support)
• details of advertisements and other marketing content which may feature you where we manage social media, email and other advertising campaigns on your behalf
• financial details such as sales and profits where we may be contracted to produce branded merchandise for you
• your payment details, including billing address and bank/debit/credit card details where you make commission or other payments to us

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What information do we receive from third parties?

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Sometimes, we receive information about you from third parties, as well as from publicly accessible sources. This may include internet (Google search relating to you) and social media research from YouTube, TikTok, Facebook, Instagram, Social Blade, or other public sources; details provided by other agency/ies; third party referrals/recommendations/references; your website(s); website use details provided by e.g. Google Analytics etc.; personal data as part of other analytics data on influencer followings.

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How do we use this information, and what is the legal basis for this use?

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We process this personal data for the following purposes:

• To fulfil a contract, or take steps linked to a contract: this is relevant where we provide talent management or other services to you, or where you may be interested in receiving these services from us. This may include:
• verifying your identity;
• gaining an understanding relating to your social media demographics;
• communicating with you and your other advisers or management agency;
• building your profile and brand via social media including helping you to create and launch your own brand, branded products, social media platform, mobile app or online platform;
• managing your commercial communications with third parties;
• sourcing and negotiating business opportunities on your behalf via our industry networks and resources including brand collaborations and commercial opportunities;
• managing digital marketing campaigns for you;
• taking commission or other payments;
• As required by Genflow to conduct our business and pursue our legitimate interests, in particular:
• we will use your information to provide the services you have requested, and respond to any comments or complaints you may send us;
• if you provide a debit, credit card or bank details as payment, we also use third parties to check the validity of the sort code, account number and card number you submit in order to prevent fraud (see “Transfers of your personal data” below);
• we use information you provide to investigate any complaints received from you or from others, about our website or our services;
• we will use data in connection with legal claims, and for compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation);
• we monitor use of websites we create and use your information to help us monitor, improve and protect our content, services and websites, both online and offline;
• we use information you provide to personalise websites we create and services for you;
• we use data of some individuals and customers (purchasing products from you) to invite them to take part in market research;
• Where you give us consent:
• we place cookies and use similar technologies on our website in accordance with our Cookies Notice and the information provided to you when those technologies are used; and
• on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time.
• For purposes which are required by law or regulation including:
• maintaining records, carrying out compliance checks, for fraud and crime prevention and detection and for reporting to relevant authorities e.g. for tax purposes; and
• in response to requests by government or law enforcement authorities conducting an investigation.

Withdrawing consent or otherwise objecting to direct marketing

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Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we may be able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.

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1. Your rights

You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine-readable format, and to ask us to share (port) this data to another controller.

In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).

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These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in both the GDPR and in the Data Protection Act 2018. We will inform you of relevant exemptions we rely upon when responding to any request you make.

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To exercise any of these rights, or to obtain other information you can get in touch with us using the details set out below. If you have unresolved concerns, you have the right to complain to the data protection authority where you live, work or where you believe a breach may have occurred. This is likely to be the UK Information Commissioner’s Office.

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Where we need to collect personal data by law or in order to perform a contract we have with you and you fail to provide that information when requested, we may not be able to fulfil the contract that we have or are trying to enter into with you. In this case, we may need to cancel the contract you have with us but we will always discuss this with you if this is the case at the time.

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1. Transfers of your personal data

We may share your personal data with Genflow group companies for cross-marketing purposes and group-wide analytics.

Should you engage with us for marketing services, we may share your data with third-party controllers such companies providing sponsorship business opportunities, and social networking providers such as Facebook, social media platforms such as Instagram and Twitter, online video sharing sites such as YouTube and TikTok and other similar third parties that operate apps and services for advertising, marketing, building your social media presence and your profile more generally, branding collaborations and other services related to talent management and to maximise business opportunities.

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Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.

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Personal data will also be shared with third party service providers, who will process it on Genflow’s behalf for the purposes identified above. In particular, we use third party providers of website maintenance, other IT services, advertising, and payment verification providers.

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In the event that the business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.

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We transfer personal data to certain countries outside the UK/EEA, including the USA.

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1. Retention

Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data so that we can respect your request in future.

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1. Cookies

As mentioned above, Genflow uses cookies on this website, which allow our website to recognise your device and “remember” it. We also use other similar forms of technology which serve a similar purpose to cookies and which allow us to monitor and improve our website and email communications. Further details of the types of cookies and the similar technologies that we use and why we use them can be found in our Cookie Notice.

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1. Changes

We reserve the right to update and change this Policy from time to time in order to reflect any changes to the way in which we process your personal data or changing legal requirements. Any changes we may make to our Policy in the future will be posted on this website and, where appropriate, notified to you by email.

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1. Contact

We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, you can get in touch at grace@genflow.com or by writing to us at Units 1A and 1B, 1st Floor, 6 Orsman Road, London N1 5QJ.

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