PRIVACY POLICY

We respect the privacy of every person who visits or registers with www.flare.studio (the “Site”) and who uses the services that we make available from the Site (our “Services”) and we are committed to ensuring a safe online experience.

1PURPOSE OF THIS POLICY

This privacy policy (“Privacy Policy”) explains our approach to any personal information that we might collect from you or which we have obtained about you from a third party and the purposes for which we process your personal information. This Privacy Policy also sets out your rights in respect of our processing of your personal information. For more information click here.

This Privacy Policy will inform you of the nature of the personal information about you that is processed by us and how you can request that we delete, update, transfer it and/or provide you with access to it.

This Privacy Policy is intended to assist you in making informed decisions when using the Site and our Services. Please take a moment to read and understand it. Please note that it should be read in conjunction with our Cookie Policy, Platform Terms of Use and Submission Rules (if you are content creator).

Please also note that this Privacy Policy only applies to the use of your personal information obtained by us, it does not apply to your personal information collected during your communications with third parties or your use of their services (for example where you follow links to third party websites over which we have no control or purchase goods or services from those third parties). Show Less

2WHO ARE WE AND WHAT DO WE DO?

The Site and our Services are operated by Flare Studio Limited, (“Flare Studio”, “ we”, “us” or “our”). For more information click here.

Flare Studio is the data controller responsible for your personal information. Flare Studio is an English company with registered company number 10363883 and whose registered office is at Bankside 3, 90 - 100 Southwark Street, London SE1 0SW. Show Less

3HOW TO CONTACT US?

If you have any questions about this Privacy Policy or want to exercise your rights set out in this Privacy Policy, please contact us by:

4WHO WE COLLECT PERSONAL INFORMATION ABOUT

We collect and process personal information from the following people:

  • Site visitors, content creators and users of our Services.  For more information click here.

    If you browse our Site, contact us with an enquiry through our Site or use any Services (available on our Site or otherwise), we will collect and process your personal information in connection with your interaction with us and our Site. Show Less

  • Social media users. For more information click here.

    If you like our Facebook page, subscribe to our YouTube channel or follow us on Instagram or Twitter, we will collect and process your personal information in connection with our interactions with you on those social media sites. Show Less

  • Suppliers (including subcontractors).  For more information click here.

    If you supply products or services to us on your own behalf, we will collect and process your personal information in connection with our receipt of products and services from you and, where relevant, our provision of our Services to others. Show Less

  • Brand and agency clients. For more information click here.

    Corporate entities and other organisations are not data subjects, although any individuals who work for them are. If you work for or otherwise represent an organisation which is one of our brand or agency clients and you are engaging with us directly on behalf of that organisation, whether through our Site or otherwise, we will collect and process your personal information in connection with our provision of Services and our wider relationship with your organisation. Show Less

  • Job applicants.  For more information click here.

    If you apply for a job with us, whether through the Site or otherwise, we will collect and process your personal information in connection with your application. Show Less

5WHAT PERSONAL INFORMATION DO WE COLLECT AND HOW DO WE USE IT?

Our primary goal in collecting personal information from you is to: (i) provide our Services and verify your identity; (ii) help us improve our services and develop and market new services; (iii) carry out requests made by you on the Site; (iv) investigate or settle inquiries or disputes; (v) comply with any applicable law, court order, other judicial process, or the requirements of a regulator; (vi) enforce our agreements with you; (vii) protect the rights, property or safety of us or third parties, including our other clients and users of the Site; (viii) provide support for the provision of our Services; and (ix) use as otherwise required or permitted by law.

In particular, we collect and use your personal information for the following purposes:

  • Fulfilment of our Services and Site features.  For more information click here.

    We collect and maintain personal information that you voluntarily submit to us during your use of the Site and/or our Services. Purchases: We use the contact and payment details you have provided so that we can fulfil our payment obligations once your project submissions are selected. Please note that any contractual terms applicable to the particular services you have provided will also apply. Account registration and log in: If you register for a creator account with us, we will use your name, email address, postal address and specialities to process your registration. Once you are registered, we will process your email address and password to identify you when you log into secure areas of our Site. We will use your account information so that we can administer your account with us.

    Who do we share your personal information with for this purpose?

    We will share your personal information with the following categories of third parties:

    • To review and select submissions made in response to project briefs – creative agencies and their clients relevant to the project in which you are participating.
    • To provide you with notifications of projects relevant to your tier/user profile – we use a third party email provider to create, send and manage responses.
    • To maintain the Site and its functionality – we use a third party email provider to create, send and manage responses.
    • To make payments or issue project rewards – online payment companies, such as PayPal, and companies we purchase gifts and products from.

    What is our legal basis?

    It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you. Show Less

  • General enquiries. For more information click here.

    Our Site features a “Contact Us” page which invites you to submit general enquiries about our Site, our organisation and our Services by submitting a message to us and providing your name and email address.

    Who do we share your personal information with for these purposes?

    We use third party providers to manage our Site and customer relationships who may have access to any general enquiries and messages that we receive via the Site.

    What is our legal basis?

    It is in our legitimate interest to use your personal information in the ways described above to ensure that we are able to help you with your enquiry and provide a good standard of service to you. Show Less

  • Surveys and feedback.  For more information click here.

    From time to we will contact you to invite you to provide feedback about our Site and / or Services in the form of online surveys. Alternatively you may submit queries or feedback to us via the “Contact Us” section on our Site. We use this information to help us improve the quality of service provided by us. We also use your feedback to monitor the quality of our services and to assist with the selection of future interactive features and service lines.

    Who do we share your personal information with for these purposes?

    We use a third party service provider, e.g. Survey Monkey, to assist us with customer surveys and feedback requests.

    What is our legal basis?

    It is in our legitimate business interests to use the information you provide to us in your feedback for the purposes described above. Show Less

  • User insight and analysis.  For more information click here.

    We analyse your activity and interactions with our Site, including briefs you participate in, as well as our email communications to you, so we can advise our brand or agency clients on any key analytics. This both helps our clients tailor projects that best suit the Site as well as provide you with more appropriate projects.

    Where you have given your consent (where lawfully required), we use cookies, log files and other technologies to collect personal information from the computer hardware and software you use to access the Sites, or from your mobile. This includes the following:

    • an IP address to monitor Sites traffic and volume;
    • a session ID to track usage statistics on our Sites;
    • information regarding your personal or professional interests, demographics, participation habits, experiences with our projects and interactive features.

    Our web pages and e-mails contain cookies, web beacons and pixel tags (“Tags”). Tags allow us to track receipt of an e-mail to you, to count users that have visited a web page or opened an e-mail and collect other types of aggregate information. Once you click on an e-mail that contains a Tag, your contact information may subsequently be cross-referenced to the source e-mail and the relevant Tag.

    In some of our e-mail messages, we use a “click-through URL” linked to certain websites administered by us or on our behalf. We may track click-through data to assist in determining interest in particular topics and measure the effectiveness of these communications.

    Please see our Cookie Policy for further information.

    This information is used to create profiles and insights about your interaction with the Site. Where we have your consent to do so, we will also use your location data for user insight purposes.

    By using this information, we are able to measure the effectiveness of our content and how visitors use our Sites and our Services. This allows us to learn what pages of our Site are most attractive to our visitors, which parts of our Sites are the most interesting and what kind of offers our registered users like to see.

    We also use this information for marketing purposes (see the marketing section below for further details).

    Who do we share your personal information with for these purposes?

    We share your personal information with a variety of third party service providers to assist us with user insight analytics. These providers include those described in our Cookie Policy

    What is our legal basis?

    Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

    Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best services to you and our other customers.

    We will only use your location data for user insight purposes where we have your consent to do so. Show Less

  • Marketing communications.

    We carry out the following marketing activities using your personal information:

    • Email marketing.  For more information click here.

      We carry out email marketing activities using your personal information. We use your name and email address to send you (or the organisation you represent) marketing communications by email, where you have consented to receive such marketing communications or where we have another lawful right to do so. Such communications will include information about our organisation or new technology available, notification of new projects and events we offer from time to time.

      Who do we share your personal information with for these purposes?

      We share your personal information with a variety of third party email marketing providers who assist us in delivering our email marketing campaigns to you. We also store your personal information in our CRM database.

      What is our legal basis?

      We will only send you marketing communications via email where you have consented to receive such marketing communications, or where we have another lawful right to do so. Show Less

    • Social media remarketing. For more information click here.

      We use information that we observe about you from your interactions with our Sites, our email communications to you and/or with our Services to provide you with personalised advertising on social media channels operated by Facebook (including Instagram) and Twitter where you are a registered user of such services. Please see the User Insight and Analysis section above for more details of the information collected and how it is collected.

      We do this using Facebook Custom Audiences and Twitter’s Tailored Audience. Please note that such activity is also subject to the privacy choices you have elected to make on such services.

      Who do we share your personal information with for these purposes?

      We share your email address with third party service providers who assist us with social media remarketing campaigns.

      Your encrypted email address, social media handle or cookie identifiers may also shared by us or our third party service providers with Facebook under the terms of their Facebook Customer Audiences and / or with Twitter under the terms of their Tailored Audiences.

      What is our legal basis?

      Where your personal information is completely anonymised, we do not require a legal basis to use it as the personal information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

      Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information for marketing purposes.

      We will only engage in social media remarketing where you have consented to us using your email address and sharing your email address in an encrypted format with Facebook for marketing purposes. Show Less

  • Prize draws, prize competitions and other promotions. For more information click here.

    From time to time, we may run prize draws, competitions and other promotions on our Flare Studio Foundation page on the Site or on our social media accounts. For the purposes of administering such promotions, we may process your name, contact details (email address, postal address, telephone number), social media handle (if relevant) and any other personal information volunteered by you in your promotion entry.

    Who do we share your personal information with for these purposes?

    We often run these prize draws and competitions in conjunction with third parties, such as the brand client or another third party within the creative industry. We may also share your personal information with third parties in order to award you with the prize (i.e. if the competition is to win a film course, we will share your personal information with the film school).

    What is our legal basis?

    It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you (e.g. the terms and conditions applicable to the promotion) or it is in our legitimate interest to use your personal information to enable you to participate in any prize draws, prize competitions and other promotions. Show Less

  • Recruitment.  For more information click here.

    We use your personal information for recruitment purposes, in particular, to assess your suitability for any position for which you may apply for with us, whether such application has been received by us online, by email or by hard copy and whether submitted directly by you or by a third party recruitment agency on your behalf. We also use your personal information to communicate with you about the recruitment process, to keep records about our recruitment process and to comply with our legal and regulatory obligations in relation to recruitment.

    We may process any personal information about you that you volunteer when you apply for a job with us. We may also process your personal information obtained from any third parties we work with in relation to our recruitment activities, including without limitation, recruitment agencies, background check providers, credit reference agencies, your referees and the Disclosure and Barring Service (if applicable).

    The personal information we process may include your name and contact information (e.g. email address, postal address, telephone number), personal information concerning your education, qualifications and employment history and any other personal information which appears in your curriculum vitae and covering letter, which you volunteer in an application form or during an interview or which is contained in any reference we receive about you. Such information may also include special categories of personal information (such as information about your health, any medical conditions and your health and sickness records) and information relating to criminal convictions and offences if that information is relevant to the role you are applying for.

    We also use your personal information for the purposes of reviewing our equal opportunity profile in accordance with applicable legislation. We do not discriminate on the grounds of gender, race, ethnic origin, age, religion, sexual orientation, disability or any other basis covered by local legislation. All employment-related decisions are made entirely on merit.

    Who do we share your personal information with for these purposes?

    We may share your personal information with external recruiters or third parties who provide background checks.

    What is our legal basis?

    Where we use your personal information in connection with recruitment, it will be in connection with us taking steps at your request to enter into a contract we may have with you or it is in our legitimate interest to use personal information in such a way to ensure that we can make appropriate and informed recruitment decisions.

    We will not process any special (or sensitive) categories of personal information or personal information relating to criminal convictions or offences except where we are able to do so under applicable legislation or with your explicit consent Show Less

  • Receipt of services from suppliers.  For more information click here.

    If we have engaged you or the organisation you represent to provide us with products or services (for example, if you or the organisation you represent provide us with services such as IT support or financial advice), we will collect and process your personal information in order to manage our relationship with you or the organisation you represent, to receive products and services from you or the organisation you represent and, where relevant, to provide our Services to others.

    The personal information we collect from you may include your name, job title, contact information (including email address, telephone number and postal address), bank account or other payment details and any other personal information you volunteer which is relevant to our relationship with you or the organisation you represent.

    Who do we share your personal information with for these purposes?

    We may share your personal information with other agencies within the Omnicom group or with other third parties who are also providing services to us on the same matter

    Our legal basis for processing

    It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you or the organisation you represent or it is in our legitimate interest to use personal information in such a way to ensure that we have an effective working relationship with you or the organisation you represent and are able to provide our Services to you and others in an effective way. Show Less

  • Business administration and legal compliance.  For more information click here.

    We use your personal information for the following business administration and legal compliance purposes:

    • to comply with our legal obligations;
    • to enforce our legal rights;
    • protect rights of third parties; and
    • in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.

    Who do we share your personal information with for these purposes?

    We will share your personal information with professional advisers such as lawyers and accountants and/or governmental or regulatory authorities.

    What is our legal basis?

    Where we use your personal information in connection with a business transition, enforce our legal rights, or to protect the rights of third parties it is in our legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us such as a court order

    Where we share your sensitive personal information, we shall obtain your consent to do so.Show Less

  • Any other purposes for which we wish to use your personal information that are not listed above, or any other changes we propose to make to the existing purposes will be notified to you using your contact details

6WHAT IF YOU FAIL TO PROVIDE YOUR PERSONAL INFORMATION?

Where we are required by law to collect your personal information, or we need to collect your personal information under the terms of a contract we have with you, and you fail to provide that personal information when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the personal information we require in connection with an application for employment with us. In this case, we may have to cancel your job application or the provision of the relevant products or services to you, in which case we will notify you

7HOW DO WE OBTAIN YOUR CONSENT?

Where our use of your personal information requires your consent, you can provide such consent:

  • at the time we collect your personal information following the instructions provided; or
  • by informing us by e-mail, post or phone using the contact details set out in this Privacy Policy.

8OUR USE OF COOKIES AND SIMILAR TECHNOLOGIES

Our Sites use certain cookies, pixels, beacons, log files and other technologies of which you should be aware. Please see our Cookie Policy to find out more about the cookies and other similar technologies we use, the purposes for which we use them and how to manage, block or delete them.

9THIRD PARTY LINKS AND SERVICES

Our Sites contain links to third party websites and services. Please remember that when you use a link to go from our Sites to another website or you request a service from a third party, this Privacy Policy no longer applies.  For more information click here.

Your browsing and interaction on any other websites, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies.

We do not monitor, control, or endorse the privacy practices of any third parties.

We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.

This Privacy Policy applies solely to personal information collected by us through our Service and does not apply to these third party websites and third party service providers. Show Less

10TRANSFERS OUTSIDE THE EEA

Where necessary in order to deliver our Services, we will transfer personal information to countries outside the European Economic Area. Non-EEA countries do not have the same data protection laws as the United Kingdom and the EEA. However, when transferring your personal information outside the EEA, we will comply with our legal and regulatory obligations in relation to the personal information including having a lawful basis for transferring personal information and putting appropriate safeguards in place to ensure an adequate level of protection for the personal information. We will take reasonable steps to ensure the security of your personal information in accordance with applicable data protection laws. For more information click here.

When transferring your personal information outside the EEA, we will ensure that at least one of the following safeguards is implemented:

Adequacy decisions: We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en .

Model clauses: Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

Model clauses: Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/eu-us-data-transfers_en.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA. Show Less

11HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?

Regarding personal information we have processed in connection with the supply of our Services, we will retain personal information relevant to that supply of Services for six years from the date of supply and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world). We may then destroy such files without further notice or liability. Regarding any other personal information we have processed, we will retain relevant personal information for three years from the date of our last interaction with the relevant individual and in compliance with our obligations under the EU General Data Protection Regulation (or similar legislation around the world). We may then destroy such files without further notice or liability. If any personal information is only useful for a short period (e.g. for a specific event or marketing campaign or in relation to recruitment), we may delete it at the end of that period. If you have opted out of receiving marketing communications from us, we will need to retain certain personal information on a suppression list indefinitely so that we know not to send you further marketing communications in the future.

12CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION

We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration. For more information click here.

We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

  • unauthorised access;
  • improper use or disclosure;
  • unauthorised modification; and
  • unlawful destruction or accidental loss

All of our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of our Services. Show Less

13HOW TO ACCESS YOUR INFORMATION AND YOUR OTHER RIGHTS?

You have the following rights in relation to the personal information we hold about you:

  • Your right of access. For more information click here.

    If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee. Show Less

  • Your right to rectification. For more information click here.

    If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly. Show Less

  • Your right to erasure. For more information click here.

    You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly. Note that if you hold a registered account with us, you can also delete that account should you wish by following the instructions on your profile page. Show Less

  • Your right to restrict processing. For more information click here.

    You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly. Show Less

  • Your right to data portability. For more information click here.

    You have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice. Show Less

  • Your right to object.

    You can ask us to stop processing your personal information, and we will do so, if we are:

    • relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
    • processing your personal information for direct marketing.
  • Your rights in relation to automated decision-making and profiling. For more information click here.

    You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.Show Less

  • Your right to withdraw consent. For more information click here.

    If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time. Show Less

  • Your right to lodge a complaint with the supervisory authority. For more information click here.

    If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113. Show Less

14CHANGES TO THIS PRIVACY POLICY

We may make changes to this Privacy Policy from time to time. For more information click here.

To ensure that you are always aware of how we use your personal information we will update this Privacy Policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. Where we have your email address, we will notify you by e-mail of any significant changes. However, we encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.Show Less