Welcome to Scarlett Entertainments privacy policy.

Scarlett Entertainment respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use, store and protect your personal data, including when you:

• visit or use our website;
• make an enquiry or communicate with us;
• become a client, artist, performer, supplier or other business contact;
• apply for a role with us;
• subscribe to our communications;
• interact with us through social media or other online platforms; or
• have information about you made available to us through legitimate public sources, social media platforms or authorised application programming interfaces ("APIs").

It also explains your privacy rights and how the law protects you.

This Privacy Policy supplements any other privacy notices or fair processing notices we may provide on specific occasions and is not intended to override them.

Our website and services are not intended for children and we do not knowingly collect personal data relating to children except where this is legitimately required in connection with the provision of our services and appropriate safeguards are in place.

1. Important Information and Who We Are

Purpose of This Privacy Policy

This Privacy Policy provides information about how Scarlett Entertainment collects and processes personal data.

This may include personal data provided when you:

• make an enquiry;
• contact us by telephone, email, website form, social media or otherwise;
• book entertainment or other services;
• register or work with us as an artist, performer, supplier or partner;
• apply for employment or other opportunities;
• subscribe to marketing or other communications;
• interact with our website or digital services; or
• otherwise establish or maintain a business relationship with us.

We may also process information obtained from public sources, third parties and authorised APIs where permitted by applicable law and the relevant platform or service provider.

Controller

Scarlett Entertainment and Management Ltd is the controller responsible for your personal data and is referred to in this Privacy Policy as "Scarlett Entertainment", "we", "us" or "our".

Where another company within the Scarlett Entertainment group is responsible for processing your personal data in connection with a particular service or transaction, the relevant company may also act as a controller in relation to that processing.

Contact Details

Full name of legal entity:
Scarlett Entertainment and Management Ltd

Email:
scarlett@scarlettentertainment.com

Telephone:
01626 572 072

Postal address:
30-32 Courtenay Street
Newton Abbot
Devon
TQ12 2DT
United Kingdom

Privacy and data protection matters are managed internally by Scarlett Entertainment.

If you have any questions about this Privacy Policy, our use of your personal data, or wish to exercise your legal rights, please contact us using the details above.

Your Right to Complain

You have the right to make a complaint at any time to the Information Commissioner's Office ("ICO"), the UK supervisory authority for data protection matters.

We would, however, appreciate the opportunity to address your concerns before you approach the ICO, so please contact us in the first instance.

Further information is available from the Information Commissioner's Office at ico.org.uk.

Changes to This Privacy Policy

We keep this Privacy Policy under regular review and may update it from time to time to reflect changes in our services, technology, legal requirements or how we process personal data.

The date at the beginning of this Privacy Policy indicates when it was last updated.

It is important that the personal data we hold about you is accurate and current. Please inform us if your personal data changes during your relationship with us.

Third-Party Links

Our website may include links to third-party websites, services, plug-ins and applications.

Clicking on those links or enabling those connections may allow third parties to collect or process information about you.

We do not control third-party websites and are not responsible for their privacy policies or practices.

When you leave our website or use a third-party service, we encourage you to read the relevant third party's privacy information.

2. The Personal Data We Collect

Personal data means information relating to an identified or identifiable individual.

It does not include information that has been irreversibly anonymised so that an individual can no longer be identified.

Depending on your relationship with Scarlett Entertainment, we may collect, use, store or otherwise process the following categories of personal data.

Identity Data

Identity Data may include:

• first name;
• last name;
• title;
• preferred name;
• date of birth where relevant;
• username or social media name;
• account or profile identifiers;
• artist, performer or stage name;
• photographs or other identifying information where relevant to our services.

Contact Data

Contact Data may include:

• residential or business address;
• billing address;
• delivery address;
• email address;
• telephone or mobile number;
• social media contact information; and
• other contact details you provide to us.

Professional, Artist and Business Data

Where relevant to our entertainment and business services, this may include:

• occupation or professional role;
• employer or business name;
• artist or performer information;
• entertainment category or specialism;
• professional biography;
• skills, experience and credentials;
• geographic location or areas of operation;
• business or professional website;
• social media profiles;
• publicly available promotional material;
• photographs, videos and other media;
• publicly available performance or event information;
• publicly available reviews or professional information; and
• other information relevant to assessing, categorising, representing, recommending or working with an artist, performer, supplier or business.

Financial Data

Financial Data may include:

• bank account details;
• payment details;
• payment card information where processed by us or an authorised payment provider;
• payment status; and
• other financial information relevant to transactions with us.

Transaction Data

Transaction Data may include:

• details of payments made to or received from you;
• details of bookings;
• quotations;
• contracts;
• services purchased or supplied;
• entertainment booked;
• event information; and
• other transaction history.

Technical Data

Technical Data may include:

• Internet Protocol ("IP") address;
• browser type and version;
• device information;
• time zone;
• approximate location;
• browser plug-in information;
• operating system;
• platform;
• login information where applicable;
• cookie identifiers; and
• other technical information about the devices used to access our website or services.

Usage Data

Usage Data may include information about:

• how you use our website;
• pages you visit;
• links you follow;
• services you interact with;
• searches or enquiries you make; and
• how you interact with our digital services.

Marketing and Communications Data

Marketing and Communications Data may include:

• your preferences for receiving marketing from us;
• your communication preferences;
• your interactions with our marketing communications; and
• whether you have opted out of particular communications.

Publicly Available and Social Media Data

We may process information that has legitimately been made publicly available, including information from:

• public websites;
• professional directories;
• company websites;
• Companies House and other official registers;
• publicly accessible social media profiles;
• public posts and media;
• publicly available artist or performer profiles;
• public business profiles;
• search engines; and
• authorised APIs made available by online and social media platforms.

This may include public profile information, usernames, profile identifiers, professional information, public posts, photographs, videos, captions and other information made publicly accessible by the individual, business or platform concerned.

Aggregated and Anonymised Data

We may collect, use and share aggregated information such as statistical or demographic data.

Aggregated information may be derived from personal data but is not personal data where it does not directly or indirectly identify an individual.

For example, we may aggregate website usage information to understand how visitors use particular website features.

If we combine aggregated information with personal data in a way that allows an individual to be identified, we will treat the combined information as personal data and handle it in accordance with this Privacy Policy.

Special Category Data

We do not generally seek to collect special categories of personal data, such as information concerning:

• racial or ethnic origin;
• political opinions;
• religious or philosophical beliefs;
• trade union membership;
• genetic data;
• biometric data used for identification;
• health;
• sex life; or
• sexual orientation.

We also do not generally seek to collect information about criminal convictions or offences.

Where it becomes necessary for us to process such information for a legitimate purpose, we will only do so where permitted by applicable law and with appropriate safeguards.

3. How We Collect Your Personal Data

We use a variety of methods to collect personal data.

Direct Interactions

You may provide Identity, Contact, Financial, Transaction, Professional, Marketing or other information when you:

• make an enquiry;
• request a quotation;
• make or receive a booking;
• enter into a contract with us;
• register with us as an artist, entertainer, performer or supplier;
• create an account;
• subscribe to our publications or communications;
• request marketing;
• contact us by email, telephone, website form or social media;
• attend an event;
• enter a competition, promotion or survey;
• apply for employment or another role; or
• provide feedback.

Automated Technologies and Interactions

As you interact with our website, we may automatically collect Technical and Usage Data relating to your equipment, browsing actions and patterns.

We may collect this information using:

• cookies;
• server logs;
• analytics technology; and
• similar technologies.

Please see our Cookie Policy for more information about the cookies and similar technologies we use.

Third Parties

We may receive personal data from third parties such as:

• payment service providers;
• technology providers;
• hosting providers;
• analytics providers;
• advertising platforms;
• communication providers;
• event organisers;
• clients;
• artists;
• performers;
• suppliers;
• business partners;
• recruitment providers;
• professional advisers; and
• other organisations legitimately involved in providing or supporting our services.

Publicly Available Sources

We may obtain information from publicly available sources including:

• Companies House;
• other official registers;
• company websites;
• professional websites;
• entertainment and artist websites;
• search engines;
• public directories;
• news and media sources;
• publicly available social media profiles;
• publicly available posts and media; and
• other legitimate public online sources.

Authorised Platform APIs

We may use authorised application programming interfaces ("APIs") and similar tools made available by third-party platforms to access information the platform permits us to access.

This includes APIs provided by social media and online platforms such as Meta, Instagram and Facebook.

We only access information through such APIs in accordance with the functionality and permissions made available to us by the relevant platform and subject to applicable law.

4. Social Media and Platform API Data

Scarlett Entertainment may use official APIs and other authorised tools provided by social media and online platforms to access information for legitimate business purposes.

This may include platforms operated by Meta Platforms, Inc., such as Instagram and Facebook.

Information We May Access

Where permitted by the platform and applicable law, information may include:

• public profile or account information;
• public usernames;
• account or profile identifiers;
• account names;
• publicly available posts;
• publicly available images or videos;
• captions and associated public information;
• publicly available engagement information;
• publicly available business information;
• publicly available creator, artist or performer information; and
• other information made available to us through the relevant authorised API.

The precise information accessible to Scarlett Entertainment depends on the permissions and functionality made available by the relevant platform.

We do not use our API integrations to circumvent privacy settings or access information that the relevant platform has not authorised us to access.

Purposes for Using Social Media and API Data

We may use information obtained through authorised social media or platform APIs for purposes including:

• identifying entertainers, artists, performers, suppliers and businesses relevant to our services;
• researching entertainment options;
• maintaining and improving our internal artist, performer, entertainment and supplier information;
• categorising entertainment and suppliers;
• verifying or updating publicly available information;
• identifying potentially relevant entertainers or suppliers;
• improving our search and discovery systems;
• improving our internal technology and business systems;
• improving the quality, accuracy and relevance of the services we provide to clients;
• supporting our entertainment sourcing and recommendation processes; and
• other legitimate activities directly connected with operating and improving Scarlett Entertainment's services.

Where information obtained through a social media platform constitutes personal data, we will only process it where we have a lawful basis to do so.

This will commonly be where the processing is necessary for our legitimate interests in operating, developing and improving our entertainment agency, sourcing relevant entertainment and maintaining accurate business information, provided that those interests are not overridden by the rights and interests of the individual concerned.

Meta, Instagram and Facebook Data

Where we access information through Meta products, including Instagram or Facebook, we will do so using access authorised by Meta and subject to the permissions granted to our application.

Our use of information received through Meta APIs will also be subject to applicable Meta developer and platform requirements.

We will not knowingly use information obtained through Meta APIs in a manner prohibited by the permissions granted to us or applicable platform requirements.

Scarlett Entertainment is an independent business. Our use of Meta, Instagram or Facebook APIs does not mean that Scarlett Entertainment is affiliated with, endorsed by or sponsored by Meta Platforms, Inc.

Storage of Platform Data

Information obtained from third-party APIs may be stored within Scarlett Entertainment systems where reasonably necessary for the purposes described in this Privacy Policy.

We apply appropriate organisational and technical safeguards to personal data held within our systems.

Updating Platform Data

Information originating from public profiles or other online sources may change over time.

Where appropriate and reasonably practicable, we may update or remove information where:

• the underlying public information changes;
• we become aware that the information is inaccurate;
• the information is no longer required for the purpose for which it was collected;
• the relevant platform requires its deletion; or
• applicable law requires us to delete it.

5. How We Use Your Personal Data

We will only use personal data where we have a lawful basis to do so.

Depending on the circumstances, we may rely upon one or more of the following lawful bases.

Performance of a Contract

We may process personal data where necessary:

• to enter into a contract with you;
• to provide services you have requested;
• to fulfil a booking;
• to manage a booking;
• to pay an artist, performer or supplier;
• to receive payment from a client; or
• otherwise to perform our contractual obligations.

Legitimate Interests

We may process personal data where necessary for our legitimate business interests, provided that those interests are not overridden by your interests, fundamental rights or freedoms.

Our legitimate interests may include:

• operating and managing our business;
• providing entertainment agency services;
• sourcing entertainment;
• identifying suitable artists and suppliers;
• maintaining artist and supplier information;
• responding to enquiries;
• maintaining client relationships;
• developing and improving our services;
• improving our website and internal systems;
• conducting business research;
• maintaining accurate records;
• protecting our business and systems;
• preventing fraud;
• managing commercial risk;
• promoting our services; and
• growing our business.

Legal Obligations

We may process personal data where necessary to comply with legal or regulatory obligations.

Consent

Where required by law, we may process personal data on the basis of your consent.

Where we rely upon consent, you may withdraw that consent at any time.

Withdrawal of consent will not affect the lawfulness of processing carried out before consent was withdrawn.

6. Purposes for Which We Use Personal Data

Client Registration and Enquiries

We may use Identity and Contact Data to:

• register a new client;
• respond to an enquiry;
• prepare a quotation;
• discuss entertainment options;
• take steps towards entering into a contract; and
• manage our relationship with you.

The lawful basis will usually be:

• performance of a contract or steps taken before entering into a contract; and/or
• our legitimate interests in responding to enquiries and developing our business.

Artist, Performer and Supplier Registration

We may use Identity, Contact, Professional, Artist, Marketing and Communications Data to:

• register artists, performers and suppliers;
• assess suitability;
• categorise entertainment;
• create or maintain internal profiles;
• communicate regarding potential bookings;
• promote suitable entertainment options to clients; and
• manage our relationship with artists and suppliers.

The lawful basis will usually be:

• performance of a contract or steps taken before entering into a contract; and/or
• our legitimate interests in maintaining and developing our entertainment offering.

Public Entertainer, Artist and Supplier Research

We may use publicly available professional, business and social media information to:

• identify potentially relevant artists, performers, entertainers or suppliers;
• assess publicly available information regarding their services;
• classify or categorise entertainment;
• update existing information;
• improve our entertainment database;
• improve search and recommendation systems; and
• support the services we provide to clients.

The lawful basis will usually be our legitimate interests in operating and improving our entertainment agency and sourcing appropriate entertainment.

Bookings and Transactions

We may use Identity, Contact, Financial and Transaction Data to:

• process bookings;
• manage payments, charges and fees;
• arrange services;
• pay suppliers and performers;
• collect payments due to us;
• recover amounts owed to us; and
• manage contractual relationships.

The lawful basis will usually be:

• performance of a contract;
• compliance with legal obligations; and/or
• our legitimate interests in managing our business and recovering amounts due.

Managing Our Relationship With You

We may process Identity, Contact, Transaction and Marketing and Communications Data to:

• notify you about changes to our terms or Privacy Policy;
• communicate about bookings or services;
• ask you to provide feedback;
• handle complaints;
• maintain accurate records; and
• administer our relationship with you.

The lawful basis may include:

• performance of a contract;
• compliance with legal obligations; and
• our legitimate interests in maintaining customer and supplier relationships and accurate records.

Website and System Administration

We may process Identity, Contact, Technical and Usage Data to:

• administer and protect our business;
• operate and maintain our website;
• operate our internal systems;
• troubleshoot technical issues;
• perform testing;
• conduct data analysis;
• provide system support;
• protect network and information security;
• prevent fraud; and
• support business continuity and restructuring.

The lawful basis will usually be:

• our legitimate interests in operating and protecting our business; and/or
• compliance with legal obligations.

Analytics and Service Improvement

We may use Technical and Usage Data to:

• analyse website performance;
• understand how our services are used;
• improve our website;
• improve our products and services;
• improve customer experience;
• improve search functionality;
• develop our internal systems; and
• inform our business and marketing strategy.

The lawful basis will usually be our legitimate interests in improving and developing our business and services.

Where applicable law requires consent for particular cookies or tracking technologies, we will obtain consent before using those technologies.

Marketing and Recommendations

We may use Identity, Contact, Technical, Usage, Transaction and Marketing and Communications Data to:

• identify services that may be of interest to you;
• send relevant communications;
• make recommendations; and
• promote Scarlett Entertainment's services.

We will comply with applicable data protection and electronic marketing requirements.

7. Marketing

We aim to give you choices regarding how your personal data is used for marketing.

Promotional Communications

We may use information we hold about you to understand which products, services or entertainment options may be of interest to you.

You may receive marketing communications from us where permitted by law, including where:

• you have requested information from us;
• you have previously purchased services from us;
• you have otherwise established a relevant business relationship with us; or
• you have consented to receive marketing.

Where consent is required, we will obtain it.

Third-Party Marketing

We will not sell your personal data to third parties for their own marketing purposes.

Where applicable law requires us to obtain your express consent before sharing personal data with a third party for that third party's direct marketing purposes, we will obtain that consent.

Opting Out

You can ask us to stop sending marketing messages at any time by:

• using an unsubscribe link in a marketing communication where provided; or
• contacting us at scarlett@scarlettentertainment.com.

Opting out of marketing communications will not affect service messages or communications necessary to administer an existing booking, contract or business relationship.

8. Cookies and Analytics

Our website may use cookies and similar technologies to:

• operate essential website functions;
• remember user preferences;
• understand how visitors use our website;
• measure website performance;
• improve our services; and
• support advertising or marketing where applicable.

Where required by law, non-essential cookies will only be placed after obtaining appropriate consent.

You can configure your browser to refuse some or all cookies, although disabling certain cookies may affect website functionality.

Please see our Cookie Policy for more information.

Analytics Providers

We may use third-party analytics and technology providers to understand how people interact with our website and services.

Such providers may process technical and usage information on our behalf in accordance with applicable contractual and data protection requirements.

We may use services provided by organisations such as Google where appropriate, including analytics or advertising services.

The particular providers and cookies currently used should be identified in our Cookie Policy and cookie consent management system where required.

9. Disclosures of Your Personal Data

We may share personal data with third parties where reasonably necessary for the purposes described in this Privacy Policy.

These may include:

• artists and performers;
• entertainment suppliers;
• clients and event organisers where necessary to fulfil a booking;
• venues;
• production companies;
• logistics providers;
• payment providers;
• banks and financial institutions;
• IT and software providers;
• website hosting providers;
• cloud service providers;
• CRM and business system providers;
• analytics providers;
• communication providers;
• marketing technology providers;
• professional advisers;
• accountants;
• auditors;
• lawyers;
• insurers;
• regulatory authorities;
• tax authorities;
• law enforcement agencies where legally required; and
• other service providers who support our business.

We may also disclose personal data where necessary in connection with:

• a merger;
• acquisition;
• restructuring;
• sale of assets;
• investment;
• transfer of part or all of our business; or
• other corporate transaction.

If such a change occurs, the recipient may use personal data in accordance with this Privacy Policy or an equivalent privacy notice.

We require service providers processing personal data on our behalf to protect personal data appropriately and only process it for authorised purposes.

We do not permit our processors to use personal data for their own unrelated purposes.

10. International Transfers

Scarlett Entertainment operates internationally and may work with clients, artists, performers, suppliers, service providers and group companies located in different countries.

As a result, personal data may sometimes be transferred outside the United Kingdom.

Where personal data is transferred internationally, we take appropriate steps to ensure that it receives a level of protection consistent with applicable UK data protection law.

Depending upon the destination and circumstances, these safeguards may include:

• transferring information to a country recognised by the UK Government as providing an adequate level of data protection;
• using the UK International Data Transfer Agreement;
• using the UK Addendum to approved standard contractual clauses;
• implementing other legally recognised transfer safeguards; or
• relying on another lawful basis for the international transfer where permitted by applicable law.

We may also use service providers that store or process data internationally, including technology, cloud, communication, analytics and social media providers.

Please contact us at scarlett@scarlettentertainment.com if you would like further information about safeguards used in relation to international transfers of your personal data.

11. Data Security

We have implemented appropriate technical and organisational security measures designed to prevent personal data from being:

• accidentally lost;
• destroyed;
• altered;
• disclosed without authorisation;
• accessed without authorisation; or
• otherwise unlawfully processed.

We limit access to personal data to employees, workers, contractors, service providers and other parties who have a legitimate business need to access it.

Where third parties process personal data on our behalf, they are required to handle that information appropriately and in accordance with applicable contractual and legal obligations.

We maintain procedures for responding to suspected personal data breaches.

Where required by law, we will notify the ICO and/or affected individuals of a personal data breach.

12. Data Retention

How Long We Keep Personal Data

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including satisfying:

• legal requirements;
• regulatory requirements;
• accounting requirements;
• tax requirements;
• reporting obligations;
• contractual requirements;
• dispute resolution requirements; and
• legitimate business needs.

When determining an appropriate retention period, we consider:

• the amount of data;
• the nature of the information;
• its sensitivity;
• the risk of harm from unauthorised access or disclosure;
• the purposes for which it is processed;
• whether those purposes can be achieved through other means;
• our contractual obligations; and
• applicable legal requirements.

Different categories of information may therefore be kept for different periods.

Details of specific retention periods may be available from us on request where appropriate.

Public and Social Media Information

Information obtained from public sources or authorised APIs will only be retained for as long as reasonably necessary for the purposes for which it is being processed.

Where appropriate, information may be:

• updated;
• archived;
• anonymised; or
• deleted

when it is no longer required.

Anonymised Information

In some circumstances we may anonymise personal data so that it can no longer be associated with an identifiable individual.

We may use properly anonymised information for research, statistical, analytical or business purposes without further notice where permitted by law.

13. Meta, Instagram and Platform Data Deletion

If you believe Scarlett Entertainment holds personal data relating to you that was obtained through Meta, Instagram, Facebook or another social media platform, you may ask us to review or delete that information.

To make a request, email:

scarlett@scarlettentertainment.com

Please include sufficient information to allow us to identify the relevant data. Where possible, this should include:

• your name;
• the relevant social media platform;
• your public username, profile name or account identifier;
• the information you would like us to review or delete; and
• sufficient information for us to verify and locate the relevant record.

Please state that your request relates to social media or Meta/Instagram data.

Once we have identified the relevant information, we will assess the request in accordance with applicable data protection law.

Where we are required by:

• applicable law;
• an individual's valid exercise of their data protection rights;
• Meta or another platform's applicable requirements; or
• the permissions under which information was obtained

to delete the information, we will take reasonable steps to remove the relevant information from our systems.

There may be circumstances in which we are legally entitled or required to retain certain information, for example where it is needed:

• to comply with a legal obligation;
• for accounting or tax purposes;
• to establish, exercise or defend legal claims;
• to prevent fraud; or
• for another lawful purpose.

If such an exception applies, we will explain this where appropriate.

This section constitutes our instructions for requesting deletion of information obtained through Meta, Instagram, Facebook and other relevant platform integrations.

14. Your Legal Rights

Under applicable data protection law, you may have a number of rights in relation to your personal data.

These rights may include the following.

Right of Access

You may request access to personal data we hold about you.

This enables you to receive a copy of relevant personal data and check that we are processing it lawfully.

Right to Rectification

You may ask us to correct personal data that is inaccurate or complete information that is incomplete.

We may need to verify the accuracy of new information you provide.

Right to Erasure

You may ask us to delete or remove personal data in certain circumstances, including where:

• there is no longer a valid reason for us to continue processing it;
• you have successfully objected to processing;
• we have processed it unlawfully; or
• we are required by law to erase it.

The right to erasure is not absolute.

We may sometimes be legally entitled or required to retain information, in which case we will explain the relevant reason where appropriate.

Right to Object

You may object to processing based on our legitimate interests where you believe that processing affects your fundamental rights and freedoms.

In some circumstances, we may demonstrate compelling legitimate grounds to continue processing.

You also have the right to object to processing for direct marketing purposes.

Right to Restriction

You may ask us to restrict processing in certain circumstances, including where:

• you contest the accuracy of information;
• our processing is unlawful but you do not want the information deleted;
• you need us to retain information for legal claims even though we no longer need it; or
• you have objected to our processing while we assess whether our legitimate grounds override your objection.

Right to Data Portability

In certain circumstances, you may request that personal data you provided to us be transferred to you or another organisation in a structured, commonly used and machine-readable format.

This right generally applies where processing is automated and is based on consent or contract.

Right to Withdraw Consent

Where we rely on consent to process your personal data, you may withdraw your consent at any time.

Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.

Rights Relating to Automated Decision-Making

You may have rights in relation to decisions based solely on automated processing that produce legal effects or similarly significantly affect you.

Scarlett Entertainment does not generally make decisions about individuals that have legal or similarly significant effects solely through automated processing.

We may use technology, search tools, categorisation systems or artificial intelligence to assist staff with research, organisation, recommendations and business processes. Where these tools involve personal data, their use remains subject to applicable data protection requirements.

15. How to Exercise Your Rights

If you wish to exercise any of the rights described above, please contact:

scarlett@scarlettentertainment.com

No Fee Usually Required

You will not normally be required to pay a fee to exercise your data protection rights.

However, where permitted by law, we may charge a reasonable fee or refuse to act on a request if it is manifestly unfounded or excessive.

Information We May Require

We may request information necessary to confirm your identity and establish your entitlement to exercise the relevant right.

This is a security measure intended to ensure that personal data is not disclosed to someone who is not entitled to receive it.

We may also contact you for additional information where necessary to clarify or respond to your request.

Response Times

We aim to respond to legitimate requests within the time periods required by applicable data protection law.

In the UK this will generally be within one month.

Where a request is particularly complex or you have submitted a number of requests, the law may permit us additional time. If this applies, we will inform you.

16. Change of Purpose

We will normally use personal data only for the purposes for which it was collected.

Where we reasonably need to use personal data for another purpose that is compatible with the original purpose, we may do so where permitted by law.

If you would like further information about how we assess compatibility between different processing purposes, please contact us.

If we need to use personal data for a materially unrelated purpose, we will provide appropriate information about that purpose and the lawful basis for processing where required.

We may process personal data without your knowledge or consent where this is required or permitted by law.

17. External Service Providers and Third Parties

Third parties we may work with include:

• IT service providers;
• cloud hosting providers;
• website hosting providers;
• software and CRM providers;
• payment processors;
• banks;
• accounting systems;
• communication platforms;
• analytics providers;
• marketing providers;
• fraud prevention providers;
• data storage providers;
• professional advisers;
• insurers;
• lawyers;
• accountants;
• auditors;
• tax advisers;
• regulatory authorities; and
• other suppliers necessary for the operation of our business.

These third parties may be located inside or outside the United Kingdom.

Where a service provider processes personal data on our behalf, we take reasonable steps to ensure appropriate contractual and security protections are in place.

18. Lawful Basis Definitions

Legitimate Interests

Legitimate Interests means the interests of Scarlett Entertainment in conducting and managing our business in a way that enables us to provide, develop and improve our services.

Where we rely on legitimate interests, we consider and balance:

• the importance and necessity of the processing;
• the nature of the information;
• the reasonable expectations of the individual;
• the potential impact on the individual; and
• the individual's rights and freedoms.

We will not rely on legitimate interests where our interests are overridden by the individual's rights and freedoms unless another lawful basis applies.

You may contact us if you would like further information about our assessment of legitimate interests in relation to particular processing.

Performance of a Contract

Performance of a Contract means processing personal data where it is necessary:

• for the performance of a contract to which you are a party; or
• to take steps at your request before entering into a contract.

Compliance With a Legal Obligation

Compliance with a Legal Obligation means processing personal data where necessary for compliance with a legal or regulatory obligation that applies to us.

Consent

Consent means that you have freely given a specific, informed and unambiguous indication that you agree to a particular use of your personal data.

Where processing depends on consent, you can withdraw that consent at any time.

19. Contact Us

If you have any questions concerning this Privacy Policy, our use of personal data, social media or API data, or you wish to exercise any of your privacy rights, please contact:

Scarlett Entertainment and Management Ltd
30-32 Courtenay Street
Newton Abbot
Devon
TQ12 2DT
United Kingdom

Email:
scarlett@scarlettentertainment.com

Telephone:
01626 572 072

For requests concerning information obtained from Meta, Instagram, Facebook or another social media platform, please identify the relevant platform and account or profile when contacting us so that we can locate the relevant information.

20. Policy Review

We keep this Privacy Policy under review and may amend it to reflect:

• changes to our business;
• changes to our website or systems;
• new technology;
• new third-party services or APIs;
• changes to the platforms we integrate with;
• changes in data protection law; or
• regulatory guidance.

The latest version of this Privacy Policy will be made available on our website.

Last updated: 25 August 2026