Privacy Policy

Grail Talent Privacy Policy - Last Updated: April 5, 2023

Welcome to Grail Talent. This Privacy Policy applies to anyone using the grail-talent.com website, any creators onboarded to the Grail Talent platform, any managers or users onboarded to the Grail Talent platform. Where we refer to “Grail Talent”, “we” or “us” in this Privacy Policy, we mean the relevant Grail Talent entity that is responsible for your personal data, as set out below:

  • If you are located in the European Economic Area (“EEA”), Switzerland or the UK (together, the “European Region”) or Rest of the World, Associated Talent Limited (a UK company) is responsible for your personal data.
  • If you are located in the US, Associated Talent Inc. (a US company) is the controller responsible for
    • your personal data.

1. The types of personal data we use

We collect the following types of information:

  • Registration and account information. We collect information from you when you register with Grail, such as your phone number, email address, mailing address, and information about your social media accounts
  • Activity with Grail Talent. When you receive bookings, we collect your activity on your bookings for the purposes of keeping track of your bookings and confirming your earnings
  • Communications with us. When you contact us, for example by email or phone, we may record your interactions, comments and opinions.

2. How do we use your personal data

We use your personal data for our legitimate interests to allow us to register Creators to Grail talent, and to contact you and provide you with support. Where applicable, we also use your personal data in this way to perform our contract with you. We also use your personal data where it is in our legitimate interests to do so for verification and risk management purposes and to prevent and respond to abuse, fraud, illegal activity and other potentially harmful content. We will process your personal data for our legitimate interests to optimize and improve the features and functionality of Grail Talent. We may use your information to send you information about our events, announcements, promotions or other marketing campaigns to ensure you can be timely notified of any developments and improvements we have made for Grail Talent. (We will obtain your consent to send you messages where required by law.)

3. How we share your personal data

We may share your personal data with the following:

  • Creators and/or Brands. If you choose to work with Grail Talent we will use your data to match you with Creators or Brands
  • Service providers that perform services for us or on our behalf, which may include providing professional services, such as legal and accounting services, mailing, email or chat services, fraud prevention, web hosting, or providing analytic services.
  • Law enforcement, the courts, or other regulatory or public authorities if we believe this is necessary to comply with law, to protect the vital interests of any person, or for the establishment, exercise or defence of legal claims.
  • Purchasers and third parties in connection with a business transaction: your personal data may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control or acquisition of all or a portion of our business.

4. How we store and retain your information

The personal data we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third-party service providers have operations. If you are using our Platform from the European Region, your personal data will be processed outside of the European Region. Where we transfer your personal data to countries outside the European Region, we ensure that the personal data is transferred to countries recognized as offering an equivalent level of protection or the transfer is made pursuant to standard data protection clauses adopted by the European Commission. We retain personal data collected under this Privacy Policy only where we have an ongoing legitimate business need to do so.

When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymize it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.

5. Your data protection rights

In accordance with applicable privacy law, you may have the rights to access, correct and delete your personal data that we hold, by sending a request through the manners disclosed in Section 8 of this Privacy Policy. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. If you are using Grail Talent from the European Region, in accordance with applicable privacy law, you have the following data protection rights:

  • If you wish to access, correct, update or request deletion of your personal data, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below.
  • In addition, you can object to processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below.
  • Similarly, if we have collected and process your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to the relevant data protection authority, namely the Irish Data Protection Commission if you are in the EEA, or the UK Data Protection Commission if you are in the UK.

If you are a California or Virginia resident, you may submit a request to know, access, correct or delete the information we have collected about you to info@grail-talent.com. You may appeal any decision we have made about your request by following the instructions in the communication you receive from us notifying you of our decision. You may also exercise your rights to know, access, correct, delete, or appeal by sending your request to the physical address provided in Section 8 “How to contact us” of this Privacy Policy. Your right to know includes what personal information we have collected about you, including the categories of sources from which the personal information is collected, the business or commercial purpose for collecting or sharing personal information, the categories of third parties to whom we share the personal information, and the specific pieces of personal information we have collected about you. We do not discriminate based on the exercise of any privacy rights that you might have. You may be entitled, in accordance with applicable law, to submit a request through an authorized agent. To designate an authorized agent to exercise choices on your behalf, please provide evidence that you have given such agent power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. We will respond to your request consistent with applicable law and subject to proper verification. We will verify your request by asking you to send it from the email address associated with your account or to provide information necessary to verify your account. While some of the information that we collect and use may constitute sensitive personal information, we only process such information in order to provide the Platform and within other exemptions under applicable law. For example, we may process your financial information in order to provide you the services you request from us or your driver’s license number in order to verify your identity. No Sales or Shares for Cross- Context Behavioural Advertising. If you are a California resident, we do not and have not in the last twelve (12) months sold or shared personal information about you as defined by the California Consumer Privacy Act (“CCPA”). Do Not Track. Given a lack of industry consensus and standardization, we do not respond to browser ‘Do Not Track’ (DNT) signals.

6. Security of your personal data

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. We have appropriate technical and organizational measures to ensure a level of security appropriate to the risk that may be posed to you. We maintain these technical and organizational measures and will amend them from time to time to improve the overall security of our systems.

7. Updates to this Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the top of this Privacy Policy.

8. How to contact us

If you have any questions or concerns about our use of your personal data, contact us using the following email address: info@grail-talent.com.