We are ENGINE. Depending on where you are based, our contact and other details are set out at the end of this policy. We are the data controller in relation to the personal data processed in accordance with this policy (except where this policy explains otherwise). Engine includes our media exchange business, EMX.
We collect and process personal data as follows:
If you are a client or ours (or you work for a client of ours)
We may collect your individual contact information to enable us to communicate with you in relation to the provision of services by us (for example, in relation to the management and administration of the provision of the relevant services) and other personal information relating to you to in the course of providing the services concerned (for example, bank account or other financial details, personal description and photograph and other information relating to you that is included in any communications between us and you or anyone you work with in the course of provision of the services).
If you provide goods or services (or you work for, or are agent for, someone who supplies goods or services) to us or to any of our clients (for example, in relation to an advertising campaign). This may include actors, performers, designers, artists and people in other creative fields, as well as sports people and others who are involved in licensing, endorsement or promotion to or on behalf of us or our clients
We may collect your individual contact information to enable us, our clients or other suppliers of ours or our clients to communicate with you in relation to the provision of goods or services by you or the person that you work for (for example, in relation to the management and administration of the provision of the relevant goods or services) and other personal information relating to you to in the course of provision of the goods or services concerned. This may include, for example, bank account or other financial details, personal description and photograph, physical details such as body measurements where clothing or equipment is being provided, and other information relating to you that is included in any communications between us and you or anyone you work with in the course of provision of the goods or services.
If we are assessing your suitability or ability to provide goods or services to us or to any of our clients
We may collect relevant personal information relating to you to the extent necessary to enable that assessment to take place – for example, if we need to assess or confirm your age, your right to work in the jurisdiction, your skills and previous experience, your qualifications or whether there is anything (for example, relating to your past history, your health or your conduct or reputation) that would adversely affect your suitability or ability to provide the goods or services concerned. This will be explained to you in more detail at the time we collect the personal data and, where appropriate, will be subject to your prior consent.
If you are invited to, or attend, an event organised or managed by us.
We may collect your individual contact and related information (as well as that of anyone who is attending the event with you) as necessary to enable you and any other relevant individuals to be invited to, and to attend, the event and to facilitate your attendance (for example, dietary or special access requirements).
If we have to provide or arrange any facilities, resources, travel, accommodation or anything else necessary to enable or assist you to provide goods or services to us or our clients
We may collect relevant personal information relating to you in order to enable us to do so (for example, your passport details if we have to arrange travel or accommodation for you).
If we have to arrange insurance relating to you
We may collect relevant personal information relating to you to the extent necessary to enable that insurance to be obtained (for example, information relating to your current state of health if that is necessary in relation to the insurance concerned.
If you are a respondent to any survey, research, interview or other enquiry carried out by us
We may collect personal information from you as part of surveys or other research carried out by us, in which case we will provide you at the time with information on how we propose to process and use the personal information concerned. In Australia Engine’s research participants have additional rights as described in the Market and Social Research Privacy Code and as outlined here.
If you are a public official, otherwise act in official capacity, work for a public body, are a journalist or otherwise involved in the media and we need to contact you in the course of providing public relations or related services for our clients
We will collect your contact details to enable us to communicate with you on behalf of or in relation to our clients.
If you browse any of our websites
If we wish to send you advertising, marketing or promotional material
We may collect your individual contact details in order to send you direct marketing material in order to advertise, market or promote our services (either to you or the person that you work for, as appropriate). We may combine this with other information we obtain about the things you are interested in and that are relevant to the services provided by us (for example, when you browse our website and view particular content) in order to help us ensure that marketing material that we send you is relevant to what you are interested in.
If you apply for a position with us
We may collect personal information in relation to you in connection with any application by you for a position with us. In that case, we will explain in more detail at the time how and for what purposes we intend to process the relevant personal information.
If you are a customer or other contact of any of our clients
If requested to do so by a client, we may collect your individual contact information or other information relevant to your dealings with, or of other relevance to, our clients (for example, goods or services that you have obtained from our client or relevant social media interaction relevant to our client) for the purpose of contacting you on our client’s behalf. In doing this, we will normally be acting as a data processor on behalf of the relevant client, and any processing of your personal data by us will be solely in accordance with our client’s instructions and under our client’s control.
We normally process personal data only in Australia, Hong Kong and Singapore (“APAC”).
Where necessary in order to provide our services (for example, when providing services in relation to an international campaign) we may share relevant personal data with our associated companies outside APAC (for example, in the UK where our headquarters is based), but only to the extent necessary in order to provide the services concerned.
Where personal data is transferred in relation to providing our services we will take all steps reasonably necessary to ensure that it is subject to appropriate safeguards. We require that all third parties that act as “data processors” for us provide sufficient guarantees to implement appropriate technical and organisational measures, only process personal data for specified purposes and have committed themselves to confidentiality in the same way as we do.
All personal data processed by us is stored securely by one of two ways, either in-house or with a third party (the level of security being appropriate to the nature of the data concerned and the other relevant circumstances). Any payment transactions administered by us will be encrypted using appropriate technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website or systems, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website and any transmission is at your own risk. Once we have received your information, we will use appropriate procedures and security features to try to prevent unauthorised access.
We may where appropriate share your personal data with:
We may disclose your personal data to third parties:
The legal basis on which we process your personal data is as follows:
We process personal data only for so long as is necessary for the purpose(s) for which it was originally collected, after which it will be deleted or archived except to the extent that it is necessary for us to continue to process it for the purpose of compliance with legal obligations to which we are subject or for another legitimate and lawful purpose.
There are several ways you can stop receiving direct marketing communications from us. Click the ‘unsubscribe’ or ‘opt-out’ link in any email communication that we send you, or contact us via the details as set out at the end of this policy. We will then stop any further marketing related emails from Engine. Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated. In relation to any third-party marketing, we will get your express opt-in consent before we share your personal data with any third party outside of Engine Group for any marketing purposes.
You have the following rights in relation to personal data relating to you that we process but these do differ across the jurisdictions in which Engine operates:
In addition to these rights, in Australia, research participants have additional rights as described in the Market and Social Research Privacy Code, and as outlined here.
To exercise any of your rights (including withdrawing relevant consents or obtaining access to your personal data), you should contact us as set out below.
If you have a complaint about any processing of your personal data being conducted by us, you can contact us as set out below or lodge a formal compliant with the authority most relevant to you as set out below.
Australia: The Office of the Australian Information Commissioner [ https://www.oaic.gov.au/ ]
Hong Kong: The Privacy Commissioner for Personal Data [ https://www.pcpd.org.hk/ ]
Singapore: The Personal Data Protection Commission [ https://www.pdpc.gov.sg/ ]
United Kingdom (if you are a EU resident): The Information Commissioner [ https://ico.org.uk/
ENGINE Australia; and EMX Australia
459 Little Collins St
+61 3 8639 5100
ENGINE Hong Kong
2nd Floor Tai Yip Building
141 Thomson Road
+852 2882 3042
#10-01/02, The Globe
100 Cecil Street
+65 6323 5060
This policy was last updated on 8 March, 2019.