REEL ONE ENTERTAINMENT

POLICY – PRIVACY OF PERSONAL INFORMATION

 INTRODUCTION

REEL ONE ENTERTAINMENT, which for the purposes hereof includes its subsidiaries and other related companies (collectively the “Company”) is responsible for the Personal Information it collects, uses, and discloses (“Processes”) about persons interacting with the Company (“You”). We have implemented the present privacy policy (“Policy”) and appointed a Chief Privacy Officer (“CPO”) to oversee our compliance with Personal Information protection legislation. You are always welcome to contact the Company’s CPO at the following coordinates: Cbenoit@reeloneent.com.

 

INTERPRETATION

 

For the purposes of this policy, the terms in the left-hand column of the following table have the meaning in the corresponding right hand column:

 

Consent Agreement which must be freely given, specific, informed and be an unambiguous indication of the person’s wishes by which they, by a statement or by a clear positive action, signify agreement to the Processing of Personal Information relating to them. To the extent permitted by applicable laws, consent includes implied consent.
Data Controller The organization that determines when, why and how to Process Personal Data. The Company is the Data Controller of all Personal Data relating to Personal Data used in its business for the Company’s commercial purposes.
Service Provider Request A request by an individual to enforce rights listed in this Policy.
Explicit Consent Consent which requires a very clear and specific statement (that is, not just action).
Personal Information Any information identifying a natural person either directly or indirectly. Personal Information includes Sensitive Personal Information.

Personal Information can be factual or an opinion about that person’s actions or behaviour.

Personal Information Breach Any act or omission that compromises the security, confidentiality, integrity or availability of Personal Information or the physical, technical, administrative or organisational safeguards that the Company or its employees put in place to protect it. The accidental or unlawful destruction, loss, alteration, or unauthorised access, use, disclosure or

acquisition, of Personal Information is a Personal Information Breach.

 

 

Process or Processing Any activity that involves the use of Personal Data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organizing, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring Personal Data to third parties.
Sensitive Personal Information Information that, due to its nature, in particular its medical, biometric or otherwise intimate nature, or the context of its use or communication, entails a high level of reasonable expectation of privacy.

 

In the UK Sensitive Personal Information means Information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the Processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

 

In California, Sensitive Personal Information means Personal Information that reveals an individual’s: i) social security, driver’s license, state identification card, or passport number; ii) account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; iii) precise geolocation; iv) racial or ethnic origin, religious or philosophical beliefs, or union membership, v) mail, email, and text messages content unless the business is the intended recipient of the communication; vi) genetic data. It includes the Processing of biometric information for the purpose of uniquely identifying an individual; i) Personal Information collected and analyzed concerning an individual’s health; ii) Personal Information collected and analyzed concerning an individual’s sex life or sexual orientation.

UK GDPR The General Data Protection Regulation as set out in the United Kingdom’s Data Protection Act 2018.

 

THE PERSONAL INFORMATION WE PROCESS AND WHY

 

We Process the following information for the following reasons.

 

Personal Information Reason for Processing
Resumé, engagement contract including amendments and performance evaluations. Creating,     administering,     and                   terminating         the engagement relationship.
Name, coordinates, date of birth, social insurance number. For payment of fees or other consideration, and compliance with fiscal reporting obligations.
Bank Account Details For payment of fees or other consideration purposes and reimbursement of expenses, if applicable.

 

 

Proof of citizenship and/or residency For film production tax credit qualification

 

HOW WE COLLECT PERSONAL INFORMATION

 

We may collect Personal Information in a variety of ways. For example, information might be collected from applicable forms or résumés, from government-issued or other identity documents such as your driver’s license; from forms completed by you at the start of or during your engagement; from correspondence with you; or from interviews, meetings or other assessments.

 

HOW WE CLASSIFY PERSONAL INFORMATION

 

The Company has elected to treat all Personal Information as “Confidential”:

 

As such Personal Information that is “Confidential” will be limited to only those persons within the Company who are tasked with treating this Personal Information, and to third party services, organizations and agencies who require such Personal Information in order to carry out their duties. “Confidentiality” may also be provided by the Company if required by an arbitral or judicial process, or by order of a government body.

 

CONSEQUENCES OF FAILURE TO PROVIDE PERSONAL INFORMATION

 

You have obligations under your engagement contract to provide us with your Personal Information. In particular, you may be required to provide information about disciplinary or other matters under the implied duty of good faith. You may also have to provide us with your Personal Information in instances in which a failure to do so may mean that you are unable to exercise your rights.

 

Certain information, such as contact details, your right to work in a given country and payment details, have to be provided to enable us to enter into a contract of engagement with you. If you do not provide this information, it will hinder our ability to administer efficiently the rights and obligations arising as a result of the engagement relationship.

 

LIMITING PROCESSING

 

We limit the Personal Information we Process about individuals to what is necessary for the purposes of the engagement relationship, namely decisions concerning the creation, performance, and termination of the engagement relationship.

 

Your Personal Information may be shared internally with other employees and agents if access to the information is necessary for the performance of their roles.

 

Your Personal Information may also be shared with a party to a commercial or business transaction – as defined by applicable privacy legislation – in which we are engaged and to whom we assign or novate any of our rights and obligations.

 

IMAGE AND VOICE RECORDING

 

Recording of images and voices without your clearly given consent is not permitted by the Company. Your recording of the image or voice of any employee or other representative of the Company is also prohibited unless the Company has provided you with its clearly given consent.

 

PROCESSING OUTSIDE YOUR JURISDICTION OF RESIDENCE

 

The Company and other third parties to whom we disclose information under the Policy may perform activities outside of your jurisdiction (“Foreign Jurisdiction”).

 

Any Personal Information that is Processed in a Foreign Jurisdiction may be subject to the laws of that Foreign Jurisdiction. As a result, Personal Information may be disclosed in response to valid demands or requests from government authorities, courts, or law enforcement officials in a Foreign Jurisdiction. You may seek additional information regarding the Processing of your Personal Information in a Foreign Jurisdiction by contacting the Company’s CPO.

 

RETENTION

 

We will not retain Personal Information longer than is necessary to fulfil the purpose for which it was collected. As this purpose varies depending upon the Personal Information involved, we invite you to contact the Company’s CPO for any inquiries pertaining specifically to you. You should already know that your Personal Information will be retained for the duration of the period required by the revenue agency in your jurisdiction, to audit your tax returns.

 

ACCURACY

 

We use reasonable efforts to ensure that an individual’s Personal Information is kept as accurate, complete, and up-to-date as possible. We will not routinely update your Personal Information, unless such a process is necessary. In order to help us maintain and ensure that your Personal Information is accurate and up to date, you must inform us, without delay, of any change in the information you provide us.

 

SAFEGUARDS

 

We are committed to protecting the confidentiality, integrity, and availability of Personal Information provided to us. We employ security safeguards that are customary in the entertainment industry and appropriate to the sensitivity of the information, including physical, organizational, and technological measures. Examples of such measures include restricted access to offices, training of personnel, limiting access to information on a “need-to-know” basis, using passwords and well-defined internal policies and practices.

 

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of information transmitted to our internet site. Any transmission you initiate is at your own risk.

 

Once we have received your information, we will apply our security practices to prevent unauthorized access, use and /or disclosure.

 

YOUR RIGHTS

 

Depending upon the jurisdiction in which an individual resides and, if applicable, is rendering services, you have various rights with respect to the Company’s use of your Personal Information. These include:

 

  • Access: You have the right to request whether we hold Personal Information on you and to request a copy of such information. To do so, please contact the Company’s CPO. There are exceptions to this right, so that access may be denied if, for example, making the information available to you would reveal Personal Information about another person, or if we are legally prevented from disclosing such information.

 

  • Accuracy: We aim to keep your Personal Information accurate, current, and We encourage you to contact the Company to let us know if any Personal Information is not accurate or changes, so that we can update your Personal Information.

 

  • Withdraw consent: If you have provided your consent to the Processing of your Personal Information, you have the right to fully or partly withdraw you Once we have received notification that you have withdrawn your consent, we will no longer Process your Personal Information for the purpose(s) to which you originally consented unless there is another legal ground for the Processing. Please note that withdrawal of consent to Personal Information necessary to administer our engagement relationship with you will affect our ability to effectively respond to your rights under such an agreement.

 

  • Cessation of dissemination: You have the right to request that we cease disseminating your Personal Information if the dissemination is contrary to the law or a court order.

 

You also have the right to request that we cease disseminating your Personal Information where the following conditions are met:

 

  • the dissemination of the information causes you serious injury in relation to your right to have your reputation or privacy respected;

 

  • the injury is clearly greater than the public’s interest in knowing the information or the interest of any person’s right to express themselves freely; and

 

  • the cessation of dissemination requested does not exceed what is necessary for preventing the perpetuation of the injury.

 

  • De-indexation: You have the right to request that we de-index any hyperlink attached to your name that provides access to information by technological means if the dissemination is contrary to the law or a court order.

 

You have the right to request that we de-index a link providing access to information where the following conditions are met:

 

  • the dissemination of the information causes you serious injury in relation to your right to have your reputation or privacy respected;

 

  • the injury is clearly greater than the public’s interest in knowing the information or the interest of any person’s right to express themselves freely; and

 

  • the cessation of dissemination requested does not exceed what is necessary for preventing the perpetuation of the injury.

 

  • Re-indexation: You have the right to request that we re-index a link providing access to information where the following conditions are met:

 

  • a failure to do so causes you serious injury in relation to your right to have your reputation or privacy respected;

 

  • the injury caused by the failure to re-index is clearly greater than the public’s interest in knowing the information or the interest of any person’s right to express themselves freely; and

 

  • the re-indexation requested does not exceed what is necessary for preventing the perpetuation of the injury.

 

  • Erasure: You have the right to request that we erase your Personal Information. This means that in certain cases prescribed by law we will delete your Personal This includes situations where your Personal Information is no longer necessary for the purposes for which it was originally Processed and situations where your Personal Information was Processed unlawfully. Due to the way in which we maintain certain services, it may take some time before backup copies are erased.

 

  • Restriction of Processing You have the right to request that we suspend the Processing of your Personal Information for a certain period. Circumstances which may give rise to this right include situations where the accuracy of your Personal Information is contested, and we need some time to verify its (in)accuracy. This right does not prevent us from continuing to store your Personal We will inform you before the restriction is lifted.

 

  • Object: If we are Processing your Personal Information for our “legitimate interest” – as this term is understood in the UK GDPR – you have the right to object to its Processing of your personal data. You can object to direct marketing at any time and at no cost to you if your Personal Information is Processed for this purpose. If you exercise this right, we will no longer Process your Personal Information for such

 

  • Mobility: You have the right to request that computerized Personal Information collected from you be communicated to you in a commonly used technological format as well as to any person or body authorized by law to collect such To the extent permitted by local law, this right does not extend to information that was created or inferred from your Personal Information and we are under no obligation to communicate such information if doing so raises serious practical difficulties.

 

  • Limit the use of Sensitive Personal Information: In certain circumstances you have the right to request that we limit the Processing of your Sensitive Personal

 

  • Right to opt-out of the sale of your Personal Information: to exercise this right, please contact the CPO.

 

  • Complaints: If you believe that your Personal Information protection rights may have been violated, you have the right to lodge a complaint with the applicable regulatory authority including the Commission d’accès à l’information (Québec), the Attorney General (California), the Information Commissioner’s Office (UK), or to seek a remedy thought the court.

 

Other than the right to lodge a complaint, that should be directed to the applicable regulatory authority, you may, at any time, exercise any of the above rights, by contacting the Company’s CPO.

 

We will generally respond to all access requests within 30 days of the receipt of all necessary information. In circumstances where we are not able to provide access, or if additional time is required to fulfill a request, we will advise you in writing.

 

We may not release certain types of information based upon exemptions specified in applicable laws. Where possible, we will sever the information that will not be disclosed and provide you with access to the remaining information. Should we be unable to provide access to or disclose Personal Information to you, we will provide you with an explanation, subject to restrictions.

 

In certain circumstances, such as where the request is excessive or unfounded, we may charge you an administration fee for access to your Personal Information. We may also charge for additional copies. We will advise you of any fees before proceeding with a request.

 

RESOLVING CONCERNS

 

Any report, concern, complaint or incident of which we become aware that involves conduct that may contravene the Policy will be treated confidentially to the extent possible. However, some disclosure may be necessary to adequately address issues raised, aid enquiry, and implement solutions, as appropriate.

 

ISSUE REPORTING AND ESCALATION PROCESS

 

We take all potential or actual Personal Information issues seriously. You may report your concerns about the Processing of your Personal Information directly to the CPO. The CPO will engage the appropriate levels of management to assist with resolution of the issue. Issues raised by former providers of personal information about the collection, use, disclosure, retention or destruction of their Personal Information should be directed to the Company’s CPO. Issues raised by applicants for engagement about the collection, use, disclosure, retention or destruction of their Personal Information should be directed to the CPO.

 

ALTERNATIVE ACTIONS

 

While we are committed to resolving all Personal Information matters internally, nothing in the Policy precludes you from contacting the appropriate federal or provincial information and privacy commissioner.

 

PROHIBITION AGAINST RETALIATION

 

We will not retaliate against an individual who, in good faith and on the basis of reasonable belief, raises questions or concerns regarding their Personal Information.

 

ROLES AND RESPONSIBILITIES

 

The Company is responsible for communicating the Policy and ensuring that You understand the Policy and accompanying guidelines.

 

You. You are responsible for:

 

  • ensuring the accuracy of Your Personal Information provided to the Company; and

 

  • informing the Company’s CPO whenever You become aware of processes or practices that appear to contravene the Policy or applicable laws.

 

Company. The Company is responsible for:

 

  • ensuring that both it, and all individuals providing it with Personal Information, comply with the requirements of the Policy and any accompanying guidelines; and

 

  • ensuring that Personal Information is handled in a manner consistent with the

 

Business and Infrastructure Units. Business or infrastructure units that Process Personal Information other than as required, are responsible for ensuring that these activities comply with the Policy.

 

Chief Privacy Officer. The CPO is responsible for:

 

  • for answering questions about the Policy and/or guidelines, including responding to request from past and present providers of Personal Information for access thereto;

 

  • developing the Company’s Personal Information protection strategy;

 

  • developing and maintaining the Policy, accompanying guidelines and any other policy or procedure related to Personal Information and ensuring they comply with applicable law; and

 

  • serving as the official liaison with the federal and provincial