Privacy Policy
1. Introduction
1.1 This Privacy Policy explains how Apollo Artist Management Limited collects, uses and protects personal data through its website at https://apolloam.co.uk/ (the “Website”).
1.2 This Privacy Policy applies to visitors to the Website and to people who contact Apollo through the contact details published on the Website, including by email.
1.3 If you become a represented client of Apollo, Apollo’s separate Client Privacy Policy will also apply to personal data processed in connection with that client relationship.
1.4 Apollo Artist Management Limited of Mercury House, 109-117 Waterloo Road, London, SE1 8UL (“Apollo”, “we”, “us” or “our”) is the controller of personal data processed under this Privacy Policy.
1.5 Apollo processes personal data in accordance with applicable data protection law, including the UK General Data Protection Regulation and the Data Protection Act 2018.
2. What personal data do we collect?
2.1 Apollo may collect and use the following categories of personal data through or in connection with the Website:
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(a) technical and usage data, including IP address, browser type, device information, operating system, referring website, pages viewed, links clicked, and approximate location information derived from IP address;
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(b) cookie and analytics data, where you agree to analytics cookies on the Website (see our Cookie Policy);
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(c) contact and correspondence data, including your name, email address, telephone number and the contents of any email, enquiry or other communication you send to Apollo using the contact details published on the Website;
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(d) application and submission data, where you contact Apollo in relation to potential representation, including any information and materials you choose to send to Apollo by email, such as your Spotlight link, CV, headshot, cover letter, showreel, voice reel or other supporting material; and
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(e) any other personal data you choose to provide when contacting Apollo.
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2.2 Apollo does not intentionally collect more personal data through the Website than is reasonably necessary for the purposes set out in this Privacy Policy.
2.3 The Website is not intended for children, although Apollo recognises that individuals under 18 may visit the Website or contact Apollo. Where Apollo receives personal data relating to an individual under 18 through a website-related enquiry or submission, Apollo will handle that data in accordance with applicable data protection law.
2.4 When you make a choice on our cookie banner, we keep a record of it. The record contains a random ID (also stored in the “apollo_consent” cookie on your device), the date and time, what you accepted or rejected, the version of the banner and of the Cookie Policy you saw, the page you were on (without anything after the “?” in the address), a short description of your browser and device, and a shortened IP address with the last part removed. It does not contain your name or contact details. We keep it so that we can show we asked for your consent properly, which is a legal obligation (see 4.2(d)). It is stored on Apollo’s own server, hosted in Germany.
2.5 We also count visits to the Website with a visitor counter that runs on Apollo’s own server, without cookies. It records the pages viewed, the referring website, device and browser details, approximate location and the links clicked, grouped so that individual visitors cannot be identified, and keeps them for 2 years. We do this on the basis of our legitimate interest in understanding how the Website is used (see 4.3(b)). Section 4.5 of our Cookie Policy explains how to opt out.
3. Where do we get your personal data from?
3.1 Apollo obtains personal data:
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(a) directly from you when you visit the Website, use the Website, or contact Apollo using the details published on the Website;
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(b) automatically through your device and browser when you access and use the Website, including through cookies, analytics tools and server logs;
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(c) from third-party platforms or services used on the Website, including embedded or linked media providers and mapping services, where applicable; and
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(d) from the materials you choose to send to Apollo by email in response to information published on the Website.
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4. How do we use your personal data and what are our lawful bases?
4.1 Apollo may use personal data collected through or in connection with the Website for the following purposes:
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(a) to operate, maintain, secure and improve the Website;
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(b) to understand how visitors use the Website, including which pages are viewed and which links are clicked, where you have agreed to analytics cookies;
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(c) to respond to enquiries, messages and other communications sent to Apollo using the contact details published on the Website;
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(d) to consider whether to take someone on as a client where that person contacts Apollo in relation to representation;
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(e) to review and assess representation submissions and supporting materials sent to Apollo by email;
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(f) to protect Apollo’s Website, systems and business against misuse, unauthorised access, fraud or other harmful activity; and
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(g) to comply with legal obligations and to establish, exercise or defend legal claims.
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4.2 Apollo relies on one or more of the following lawful bases when processing personal data in connection with the Website:
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(a) legitimate interests, where processing is reasonably necessary for Apollo’s legitimate interests in operating, securing, monitoring and improving the Website, handling website-related enquiries, and managing potential representation enquiries, provided those interests are not overridden by your rights and interests;
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(b) pre-contract steps, where you ask Apollo to take steps before entering into a potential client relationship, for example by sending a representation enquiry or submission;
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(c) contract, where processing is necessary in connection with an existing relationship or arrangement resulting from a website-related contact;
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(d) legal obligation, where Apollo needs to process personal data to comply with a legal or regulatory obligation; and
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(e) consent, where Apollo specifically asks for your consent and relies on it, including in relation to non-essential cookies where required.
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4.3 Apollo’s legitimate interests in connection with the Website may include:
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(a) operating a professional talent agency website;
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(b) understanding how the Website is used and improving the Website’s performance and content;
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(c) presenting Apollo’s clients and services professionally to casting professionals, industry contacts and prospective clients;
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(d) responding to website-related enquiries and assessing prospective client approaches; and
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(e) protecting Apollo’s business, systems and records.
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5. Emails & Representation Submissions
5.1 The Website directs prospective clients and other visitors to contact Apollo by email rather than through a website form.
5.2 If you contact Apollo by email using an address published on the Website, Apollo may process the personal data contained in your email and any attachments in order to:
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(a) respond to your enquiry;
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(b) assess whether Apollo wishes to take you on as a client;
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(c) review any materials you choose to send, such as Spotlight details, CVs, headshots, cover letters, reels or other professional information; and
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(d) keep a record of the enquiry or submission for Apollo’s internal administration, review and business records.
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5.3 If your enquiry or submission does not lead to a client relationship, Apollo may retain it for a limited period where reasonably necessary for review, internal administration, record-keeping, or to protect Apollo’s legitimate interests, after which it will be deleted or anonymised where no longer required.
6. Who do we share your personal data with?
6.1 Apollo may share personal data collected through or in connection with the Website where reasonably necessary with:
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(a) website hosting, IT, maintenance and support providers;
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(b) analytics providers and other service providers involved in the operation of the Website, where applicable;
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(c) email and business communication providers, including providers used to receive and store email enquiries and submissions;
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(d) embedded or linked third-party content providers, such as video or mapping providers, where you choose to interact with that content;
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(e) professional advisers, including lawyers, accountants, insurers, auditors or consultants where reasonably necessary;
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(f) regulators, courts, law enforcement authorities or other authorities where disclosure is required or permitted by law; and
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(g) other persons where Apollo is otherwise lawfully entitled or required to share the data.
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6.2 Apollo does not sell personal data collected through the Website.
7. International Transfers
7.1 Some of Apollo’s website-related service providers may process personal data outside the United Kingdom.
7.2 Where Apollo transfers personal data outside the United Kingdom, Apollo will take reasonable steps to ensure that appropriate safeguards are in place where required by law.
7.3 Those safeguards may include:
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(a) transferring personal data to a country recognised as providing an adequate level of protection;
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(b) using approved contractual safeguards; or
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(c) relying on another lawful transfer mechanism where applicable.
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8. Retention
8.1 Apollo will keep personal data collected through the Website for no longer than is reasonably necessary for the purposes for which it was collected and processed.
8.2 Apollo will usually retain:
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(a) technical and analytics data for as long as reasonably necessary for website administration, analytics and security;
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(b) routine website-related correspondence for as long as reasonably necessary to deal with the enquiry and maintain appropriate business records;
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(c) representation enquiries and submissions for a limited period after review, unless a longer period is reasonably necessary for legal, administrative or record-keeping reasons; and
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(d) records of cookie choices (see 2.4) for 2 years, after which they are deleted automatically.
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8.3 Apollo may keep particular categories of personal data for longer where reasonably necessary to deal with a complaint, dispute, legal claim, security issue or regulatory requirement.
9. Security
9.1 Apollo takes reasonable technical and organisational measures to protect personal data collected against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.
9.2 Apollo limits access to personal data to those who reasonably need it for the relevant purpose.
9.3 Although Apollo takes appropriate security measures, no method of electronic transmission or storage is completely secure, and Apollo cannot guarantee absolute security.
10. Your Rights
10.1 Subject to applicable law, you may have the right to:
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(a) request access to your personal data;
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(b) request correction of inaccurate or incomplete personal data;
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(c) request erasure of your personal data in certain circumstances;
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(d) request restriction of processing in certain circumstances;
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(e) object to processing in certain circumstances, including where Apollo relies on legitimate interests;
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(f) request the transfer of certain personal data to you or another provider;
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(g) withdraw consent where Apollo relies on consent; and
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(h) complain to the Information Commissioner’s Office.
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