GDPR Privacy Addendum

Last Revised: February 14, 2022

 

This GDPR privacy addendum supplements RUN’s privacy policy and contains additional information applicable to the processing of personal data which falls inside the scope of the GDPR or the UK GDPR (hereinafter together referred to as ‘GDPR’).

 

EU Representative

Our representative in the European Union (EU) for the purpose of European Union data protection laws is as follows.

Pembroke Privacy Ltd

Address: 3-4 Upper Pembroke Street, Dublin 2, D02 VN24 Ireland.
Email: EURep@pembrokeprivacy.com

 

UK Representative:

Our representative in the UK the purpose of UK GDPR data protection laws is as follows.

 

Privacy Culture Limited

Address: Room 313, Bouverie House, 154-160 Fleet Street, London, EC4A 2DQ

Data Protection Officer is: Steve Wright

Contact email: DPO@privacyculture.com

Telephone number: +44 (0) 207 112 9360

 

Marketing and promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). If required under the GPRD or EU or UK ePrivacy legislation we will obtain your prior consent for using your personal data for marketing purposes.

You will receive marketing communications from if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing. As a prospect, you may also opt-in to receive our offers.

International transfers

RUN Studios is located in the United States and many of our external third parties are based outside the EEA and/or the UK (‘GDPR Third Countries’). So this will involve the processing of your personal data outside the UK or EEA.  Please note that the collection of personal data of RUN Studios directly from you, does not constitute a transfer. Any data transfer shall always take place in compliance with Chapter V of the GDPR and additional recommendation or decision issued in this regard by the European Data Protection Board (‘EDPB’), European Commission (‘EC’) or other competent authority. In case the data is processed outside the EEA or UK, the transfer is legitimized in the manner described below. See this link for an overview of the EEA countries.

 

Legitimisation of transfers outside the UK and EEA.

Whenever we transfer your personal data to GDPR Third Countries, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

 

  • Transfers of your personal data to a country outside the EEA may be legitimized on the basis of a so-called EU adequacy decision. This is a decision in which the European Commission states that e.g. a certain country offers a level of data protection similar to the GDPR. See this link for the current list of adequacy decisions.

  • If and insofar as we transfer personal data to Third Countries to which no adequacy decision applies, we will conclude the applicable version of the model clauses to safeguard data protection as published by the European Commission, so called standard contractual clauses (‘Transfer SCCs’) or UK transfer agreement approved by the ICO. If deemed required under the Applicable Privacy Legislation, additional measures will be taken. This may concern technical, organizational and/or contractual measures.

 

Further information on our legitimization of data transfers to Third Countries will be provided upon your request. Please use our contact details to make such a request, as stated below.​

 

Data subjects rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

a.  Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you. Although this does not necessarily give you the right to receive a copy of the documents containing your personal data, you do have the right to receive a copy of your personnel file. Per your request, we will then also provide you with further specifics of our processing of your personal data.

b.  Request rectification of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Please note that this does not provide you with the right to “correct” documents in your personnel file with which you do not agree, such as an evaluation report. In such case, a written document detailing your own view on the matter, may be added to the personnel file.

c.  Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where: (i) the personal data is no longer necessary, (ii) you have withdrawn your consent, (iii) you have objected to the processing activities, (iv) the personal data is unlawfully processed, (v) the personal data needs to be erased on the basis of a legal requirement, or (vi) where the personal data has been collected in relation to the offer of information society services. Note, however, that we do not have to honor your request to the extent that the processing is necessary: (i) for exercising the right of freedom of expression and information, (ii) for compliance with a legal obligation which requires processing, (iii) for reasons of public interest in the area of public health, (iv) for archiving purposes, or (v) for the establishment, exercise or defense of legal claims.

d.  Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

e.  Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • Contesting the accuracy of data. If you want us to establish the data's accuracy.

  • Unlawful processing. Where our use of the data is unlawful but you do not want us to erase it.

  • Data no longer required. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

  • Pending an appeal. You have objected to our use of your data (right to object) but we need to verify whether we have overriding legitimate grounds to use it.

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f.  Request the transfer (right to data portability) of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies if it concerns processing that is carried out by us by automated means, and only if our processing ground for such processing is your consent or the performance of a contract to which you are a party.

 

g.  Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

 

h.  Not to be subject to automated decision-making. This means that you have the right not to be subject to a decision based solely on automated processing, which significantly impacts you (“which produces legal effects concerning you or similarly significantly affects you”). In this respect, please be informed that we do only make use of automated decision-making in the recruitment process to check whether your resume you have entered matches the job description (e.g. college degree or not).

 

i.  To lodge a complaint with a supervisory authority. In particular in the EU Member State of your habitual residence, place of work or where an alleged infringement took place. Please refer to this webpage for an overview of the supervisory authorities and their contact details. In the UK, the Information Commissioner's Office (ICO) is the regulator for data protection issues (www.ico.org.uk). We would appreciate the chance to deal with your concerns before you approach the regulator, so please contact us beforehand.

 

If you wish to exercise any of the rights set out above, please contact us by phone or by e-mail via the contact details stated in this privacy statement.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

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What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.