1.
Purpose of this policy
1. Purpose of this policy
1.1.
The purpose of the privacy policy is to inform you how Fine Management ApS (“we”, “us”) process your personal data. With this policy, we wish to make you aware of the information we collect and process and, for how long we store it. This privacy policy regulates the processing of personal data by Fine Management ApS in connection with trading, interaction, or other exchange of personal data with us.
The purpose of the privacy policy is to inform you how Fine Management ApS (”we”, ”us”) process your personal data according to the General Data Protection Regulation (GDPR) and the Danish Data Protection Act (DDPA). It is our goal that you are aware of which information is collected and processed and, if possible, for how long they are stored.
2.
Description of processing
2. Description of processing
2.1.
Fine Management ApS process your information for one or more specific purposes and in accordance with the data protection regulations. We process your personal data if you are a client, potential client, visitor to our website or our social media sites, and if you apply for a job with us. The information will generally come directly from you, and we will only process your information for as long as it is necessary for the purpose for which it was collected. However, the information can also be processed and stored longer in anonymised form.
Below you can read more about the types of processing we do.
Client management
We process your personal data in order to enter into potential management contracts with you for the purpose of promoting, exposing and marketing you for roles in films, TV-series and theatrical releases, and to negotiate employment contracts on your behalf with potential employers.
For these specific purposes, we process data regarding your name, birth year, address, phone no., e-mail, educational papers, CV, singing voice, detailed description of appearance, biography, work schedule, calendar, portrait picture, film clips, show reels, self-tapes, bank details, previous salary, passport information, Personal Identification (CPR) No., trade union membership, religious beliefs, racial origin and ethnic origin.
We process your personal data on the legal basis of fulfilling a management contract with you, cf. GDPR article 6(1)(b). When we process your Personal Identification (CPR) No., we do so based on our legal obligations, cf. the Danish Data Protection Act § 11(2)(1). The legal basis for processing your sensitive personal data is your explicit consent, cf. GDPR article 9(2)(a). You can withdraw your consent at any time by contacting Fine Management at the contact information below.
As part of the management contract, we share your personal data on Fine Management’s Instagram, website, and with relevant third parties, namely potential employers, film producers, film casters and artistic media outlets. We do not share your personal data with third parties in connection with entering into the management contract. We mainly collect the information directly from you as a data subject; however, we may also collect the data from public sources such as IMDb.com and social media.
We store your personal data for as long as we maintain a client relationship and up to 5 years after we have concluded the client relationship.
2.1.1 Client management
We process your personal data in order to enter into potential management contracts with you for the purpose of promoting, exposing and marketing you for roles in films, TV-series and theatrical releases, and to negotiate employment contracts on your behalf with potential employers.
For these specific purposes, we process data regarding your name, birth year, address, phone no., e-mail, educational papers, CV, singing voice, detailed description of appearance, biography, work schedule, calendar, portrait picture, film clips, show reels, self-tapes, bank details, previous salary, passport information, Personal Identification (CPR) No., health information, trade union membership, religious beliefs, racial origin and ethnic origin.
We process your personal data on the legal basis of fulfilling a management contract with you, cf. GDPR article 6(1)(b). When we process your Personal Identification (CPR) No., we do so based on our legal obligations, cf. DDPA § 11(2)(1). The legal basis for processing your sensitive personal data is your explicit consent, cf. GDPR article 9(2)(a). You can withdraw your consent at any time by contacting Fine Management.
As part of the management contract, we share your personal data on Fine Management’s website and with relevant third parties, namely potential employers, film producers, film casters and artistic media outlets. We do not share your personal data with third parties in connection with entering into the management contract. We mainly collect the information directly from you as a data subject; however, we may also collect the data from public sources such as IMDb.com and social media.
We store your personal data for as long as we maintain a client relationship and up to 5 years after we have concluded the client relationship.
2.2.
Job applicants
If you apply for a job with us, we process your personal data to assess if you are qualified for an existing or future position. We process the data that you provide on your application, your CV and any attachments, including name, contact information, birthdate, work related and educational background information and references. In some cases, we also ask for a residence permit and a driver’s license.
We process your information to enter into an employment contract with you based on your request for our processing of the application, cf. GDPR Article 6(1)(b). We also process your data if we assess that our interests in processing your personal data outweigh your interests in them not being processed, e.g., information collected from social media published by you or information acquired from concluding a personality test, cf. GDPR Article 6(1)(f).
We share your personal data with the employees involved in the recruitment process and possibly recruitment companies.
Unsolicited applications are kept for 6 months after the recruitment process is completed. If we wish to store your information beyond the recruitment process, we will collect your consent hereto.
2.1.2. Job applicants
When you apply for a job at Fine Management, we will process your personal data for recruitment purposes, including for evaluation of your qualification for present or future position.
We process the personal data that appear on your application, your CV and any attachments, including educational papers. This may include names, contact details, birthdays, education, references, bank details and other common personal data. In some cases we also ask for a residence permit, a driving license. If you have carried out personality tests in the recruitment process, we store the results of this test as well.
Your data will only be processed by relevant employees at the Fine Management. The processing is done for purpose of entering into a contract with you or on the basis of balancing of interests. The result of personality tests is based on your consent, which you at any time have the right to withdraw by writing us at susanne(at)finemanagement.dk or by calling us at +45 3144 3204.
Your personal data is deleted as the purposes for which they were collected are terminated, i.e. that your information, if you are not offered a position, is deleted when the specific position is occupied and the recruitment process is completed. Job applications will be stored for up to 6 months where after they are deleted. If we want to keep your information for a longer period, we will collect your explicit consent to this.
2.3.
Cookes and website
In connection with the regular operation of our website, we collect personal data about you via cookies to improve the website's appearance and user experience, as well as to compile statistics. The information we collect via cookies includes your IP address, browser type, device (type, version, operating system, etc.) as well as user behaviour, including page views.
We only collect your personal data if you have given your consent hereto, cf. GDPR Article 6(1)(a). You can withdraw your consent at any time. You can read more about this in our cookie policy here.
Our website also includes integrated plugins from social media platforms that may also collect data from you if you have given your consent hereto. In this connection, we have a joint data controllership with every media platform. We use integrated plugins from Facebook and Instagram.
Social media
We use certain social media, including LinkedIn, Facebook and Instagram, to get in touch with our clients and potential clients, as well as promote our marketing initiatives. If you have been to these sites and “liked” or “followed” our fan page or have been in contact with us through these sites, we will process your personal data. We only process information about your name and email.
If you contact us via social medias, we process your information based on our interest in being able to contact you and respond to your inquiries, cf. GDPR Article 6(1)(f). The information will come from you and the social media through which you contact us.
We have a so-called joint controllership with the social medias that we use as we both use your data for our own purposes. You can read more about the social media´s processing of your personal data in the following links:
Information processed in connection with social media that involves direct communication via the social media is deleted immediately. Posting on, for example, Facebook pages or in public groups are not deleted as a post or comment on Facebook pages or in public groups is considered public spaces. You can read about public spaces here.
Marketing
We only process your personal data for marketing purposes, i.e., to send out newsletters, if you have given your consent in accordance with GDPR Article 6(1)(a). The scope of our processing is stated in the specific consent.
If you have consented to receiving marketing initiatives from us, we generally process data about name and email.
You have the right at any time to withdraw your consent by unsubscribing via the link that appears in each newsletter or by sending an email to susanne(at)finemanagement.dk or calling at +45 31 44 32 04.
We keep documentation of your consent for as long as you receive our marketing initiatives or participate in our marketing.
2.1.3. Website
In connection with the regular operation of our website, we collect personal data about you via cookies to improve the website's appearance and user experience, as well as to compile statistics. We only collect your personal data if you have given your consent to it. You can withdraw your consent at any time. Read more about this in our cookie policy.
3.
Notice of statutory or required processing
3. Notification by statutory processing
3.1.
In cases where we process your personal data based on a legal obligation or a requirement under a contract or a requirement that must be met to enter a contract, you are obliged to provide us with the information so that we can maintain client relationship, fulfill the contract and invoice you for our services, etc. If you do not wish to provide us with the information we need to comply with our obligations, the consequence may be that we are unable to establish or continue the client relationship or fulfill a contract with you.
You are not obliged to provide us with your information in other cases, e.g., where we process your personal data by your explicit consent. The consequence of not giving us your information in this regard, however, is that you cannot, i.e., receive marketing initiatives from us.
In cases where we process your personal data based on a legal obligation or a contract or a claim that must be met to enter into a contract, you are required to provide us with the data so that we can maintain client relationships, fulfil the contract, and invoice you for our services etc. If you do not wish to provide us with the data that we need to comply with our obligations, the consequence may be that we cannot establish or maintain the client relationship or fulfil a contract with you.
4.
Recipients of personal data
4. Recipients of personal data
We process your personal data with confidentiality and we generally do not disclose your information with third parties. However, we may further disclose your personal data if you have given your consent hereto or if we have a legitimate interest in the disclosure.
We may entrust your personal data to our system suppliers who process personal data on our behalf and according to our specific instructions in accordance with the data processing agreements we have entered.
In some cases, we use data processors outside the EU/EEA in which a transfer to a third country occurs, e.g., in connection with the use of cloud services. In this case, we have made sure that a legal transfer basis has been prepared (for instance the use of EU Commission Standard Contractual Clauses (SCC’s)). The transfer takes place only in compliance with the necessary security guarantees as required by applicable data protection legislation and an individual assessment is always made regarding the need for additional measures. You may contact us at susanne(at)finemanagement.dk to get information on the specific legal transfer basis in this connection.
5.
Your rights
5. Your rights
When we collect information about you, you have several fundamental rights in the personal data regulations that you can use. Your rights include the right to request access to and rectification or erasure of your personal data, restriction and objection to our processing, and the right to receive your data in a structured, commonly used, and machine-readable format (data portability).
The above-mentioned rights may be associated with conditions and restrictions. Whether you as a data subject can request, i.e., getting your personal data deleted will in any case depend on a specific assessment.
If you have consented to our processing of your information, you have the right to revoke this consent at any time.
If you are dissatisfied with our processing of your personal data, you may file a complaint with the Danish Data Protection Agency via their website www.datatilsynet.dk/english or by calling at +45 33 19 32 00.
6.
Our contact information
6. Contact information
The company responsible for processing your personal data is:
Fine Management ApS
Company Registration No.: 35 63 55 05
Tordenskjoldsgade 21, 4600 Køge
Denmark
Phone: +45 31 44 32 04
Email: susanne(at)finemanagement.dk
7.
Revision
7. Revision
We reserve the right to revise and modify this privacy policy. In case of significant changes, we will contact you via email or via a visible notification on our website.
This privacy policy was last revised on 5 July 2023