Privacy Policy - RSL Media

We respect your privacy and believe everyone deserves transparency and control over their information. This Privacy Notice explains how RSL Media (“RSL Media,” “we,” “our,” or “us”) collects, uses, and shares your personal information when you use our website rslmedia.org (“website”) and related services, including our consent registry (the “Registry” and collectively, the “Services”). When you provide personal information to us or use the Registry, you are indicating your understanding and acceptance of the terms of this Privacy Notice. If you do not agree to be bound by all the terms herein or any subsequent modifications, you should not access or use our Registry, and you should not provide your personal information. If you are providing information on behalf of another person, you represent and warrant to us that you have all necessary rights and permissions to provide us with their personal information and to agree to this Privacy Notice on their behalf.

Information We Collect

We collect the following types of personal information when you use the website and the Registry:

Information You Provide Directly

We will collect information that you provide directly to us, including:

Registration and verification information, including your name and email address, which are required to verify and send your consent registration;
Creative works, personas, stage names, aliases, identities, characters, or marks you represent;
Contact or representative information such as information about your manager, agency, union, label, or legal representative information;
Professional or employment information;
Information you provide about the applicable Rights Holder(s) (as defined in our Terms of Service), if you are registering on someone else’s behalf;
Account data, such as username, password, account preferences, and other information you provide when creating or managing an account on the Registry;
Any content or notes you include when filling out forms on our websites, including in any search features on our websites; and
Records and copies of your correspondence (including email addresses and phone numbers), if you contact us.

Information Collected From Third Parties

We may also collect information from third parties, such as vendors that host our website or the Registry, data analytics service providers, and email, survey, feedback, and other communications service providers.

We may also collect information from your manager, agency, union, label, or other legal representative whom you authorize to grant permissions and consents about your information and rights.

Automatically Collected Information

We collect information automatically about your device and your browsing and usage activity and patterns as you interact with our website and the Registry. This may include information about your interactions with content or features that you access or technical data, including:

Date and time of any visit or information you enter;
Page views and referral URLs;
Browser, device, and operating system types;
Country-level geographic data;
IP addresses; and
Device identifiers, device attributes, network connection type, and other device and network information.

We use Cloudflare Web Analytics for this purpose. To provide this service, Cloudflare may collect certain information about you from your device using cookies. You can learn more about Cloudflare and how it collects and processes data by visiting https://www.cloudflare.com/privacypolicy/.

Cookies and Other Tracking Technologies

We, or third parties, may use cookies, web beacons, and other tracking technologies to collect data automatically when you interact with the websites and the Registry. We may use cookies which are small files placed on your device that help us remember your preferences, improve your experience, and analyze how visitors use our website.

We may also use embedded technologies (such as web beacons, scripts, tags, and pixels) in our emails or messages to allow us to understand how you interact with those communications.

We may work with third-party vendors who set and access their own tracking technologies on your device in connection with analytics services. Some of these third parties may collect personal information over time across different websites and services. For more information about your choices regarding cookies and tracking technologies, please see Section 4 (Your Rights and Choices) below.

How We Use Information

We use your personal information for the following purposes:

Operating the Registry. We will use your personal information to operate our Registry, including making the Registry and website available to you; creating, verifying, and managing your profile or registration; sending communications to designated representatives or partners on your behalf; and providing a record of submissions for your reference.
Communicating with you. We will use your personal information to communicate with you, including to communicate updates, confirmations, or administrative notices related to your activity, and respond to questions you may have.
Improving the Registry. We may use your personal information to analyze the website and the Registry, including analyzing trends and statistics regarding visitors’ use of website and the Registry, and to analyze and enhance our communications and strategies.
Protecting us and others. We may use your personal information to enforce our rights arising from any contracts entered into between you and us, including the Terms of Service, to identify, investigate, and help to protect against fraudulent, harmful, unauthorized, unethical, or illegal activity, including security incidents, and to help protect the rights, property, or safety of us or others.
Complying with applicable legal requirements. We may use your personal information to comply with applicable laws and regulations and respond to lawful requests and communications from law enforcement and other government officials.
With your consent. In some cases, we may specifically ask for your consent to collect, use, or share your personal information, such as when required by applicable law.

We may share or disclose your information in the following ways:

Registry participants. As part of the Registry, we will maintain and publish a registry that includes your identity (including your name, image, or likeness), your creative works or other intellectual property, and the terms on which others may use your information and intellectual property. We do not control how others will use this information or their privacy practices.
Service providers. We may provide your personal information to our vendors and service providers who assist us in operating the Registry, conducting our business, or servicing you, such as a web hosting company whose services we use to host the Registry, vendors to help us communicate with you or to support the promotion and advertising of the Registry, or analytics providers who help us gather information about how you and other users engage with the websites and the Registry. We may also provide your personal information to professional advisers such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services they provide to us.
A successor or other entity. If we engage in merger, acquisition, sale of assets, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings) we may share your personal information in connection with that transaction.
With your authorization. We will share personal information with others to whom you expressly request or authorize us to disclose your information.
To comply with law and to protect ourselves and others. We may share personal information to comply with our legal obligations including any court order, law, or legal process, and to respond to any government or regulatory request. We may also share personal information if necessary to enforce our rights arising from any contracts entered into between you and us, including the Terms of Service, or to protect the rights, property, or safety of us or others.

Your Rights and Choices

You have the ability to make certain decisions about how your personal information is collected and used.

Opting Out of Cookies and Other Tracking Technologies

You can opt out of certain cookies and tracking technologies on our website or Registry in various ways, as described below. Please note, however, that if you opt out, your experience with our website or Registry may be impaired and some features may not work as they were intended. Additionally, your cookie settings are domain and browser specific. If you use a different browser, or use a new or different device, you may need to renew your cookie preferences.

Browser Settings. You can also control cookies by adjusting the settings within your internet browser. Instructions for blocking or deleting cookies in browsers may be available in each browser’s privacy or help documentation.
Mobile Device Settings. If you are using a mobile device, the mobile operating system of your device may provide an option in the device settings to limit ad tracking associated with the device ID they may share with us. Please reference your mobile operating system’s help center to learn more.

Some web browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals.

Marketing Communications

If you have supplied your email address, you agree that we may communicate with you by email to provide you with information, to inform you of new services, to solicit your feedback, or to keep you up to date about us. You may choose not to receive marketing communications from us. To unsubscribe from marketing communications, please click the “unsubscribe” link included in our marketing emails. Please note that even if you choose not to receive marketing communications from us, you still may receive communications regarding your account and any other service-related issues and updates that will allow us to provide you with the optimal user experience and other matters that are not marketing.

Data Security

We employ reasonable technical, administrative, and physical safeguards designed to protect the security and integrity of your personal information. However, no method of transmission over the Internet or method of electronic storage is completely secure, and we cannot guarantee absolute security. Any transmission of information is at your own risk. It is your responsibility to safeguard any passwords, ID numbers, or other access credentials associated with your use of the Registry, and you are responsible for all access to the Registry using your credentials.

Data Retention

We will retain your personal information as long as is necessary for the business purposes set out in this Privacy Notice. We will retain and use your personal information to the extent necessary to comply with our legal, accounting, or reporting obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. Additionally, we may continue to store your personal information contained in any of our back-up systems.

Children’s Privacy

Our website and the Registry are not for use by children under the age of 18, and we do not knowingly collect personal information from children under 18. By using the Registry, you represent that you are at least 18 years old. If you do not meet this age requirement, then you must not access or use the Registry; please do not use the Registry, and do not provide information to us. If we become aware that we have collected personal information from children under 18 without verification of appropriate consent, we will take reasonable steps to remove that information from our servers.

Notice to Non-U.S. Users Regarding Data Transfers

Your personal information may be transferred to and maintained on computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside the United States and choose to provide personal information to us, please note that we are a United States company, and we may transfer personal information to the United States for processing. Your consent to this Privacy Notice followed by your submission of such information represents your agreement to that transfer.

Links to Other Websites

The website and Registry may contain links to external third-party websites that are not operated by RSL. This Privacy Notice does not apply to the information practices of those third-party websites. If you click on one of these links, you will be taken to websites we do not control. We have no control over the content and practices of third-party websites and are not responsible for their content, privacy policies, actions, or security. We encourage you to carefully review the privacy policies of any third-party websites you visit. By providing a link to a third-party website, we are not endorsing or attempting to associate with any other entity, their content or services, or the persons or entities associated with those websites.

Changes to This Privacy Notice

We may update this Privacy Notice from time to time to reflect operational or legal changes. Please review this Privacy Notice periodically for any updates or changes. Any updates will appear on this page with a revised effective date. Your continued use of the Registry or website after updates constitutes your acceptance of the revised Privacy Notice.

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Notice, please contact:

Email: privacy@rslmedia.org

U.S. Consumer Privacy Notice

Depending on where you reside, you may make certain requests with respect to your personal information in accordance with applicable law, including:

Access: You may request to confirm whether we process your personal information. Subject to certain exceptions, you may also request a copy of your personal information.
Deletion: You can request that we delete your personal information that we maintain about you, subject to certain exceptions.
Correction: You can request that we correct inaccurate personal information that we maintain about you, subject to certain exceptions.
Opt-Out of Sale: You may request to opt out of the sale (as defined in the applicable state privacy law) of your personal information to a third party.

Residents of certain states can make these requests by emailing us.

We do not sell personal information for money, but to the extent our disclosure of personal information is a “sale” (as defined in the applicable state privacy law), we may “sell” certain categories of personal information described in Section 1 (Information We Collect) above, to the categories of parties described in Section 3 (How We Share Your Information) above, including for the purposes described in Section 2 (How We Use Information). For purposes of this paragraph, “sell” means the sale of your personal information to a third party for monetary or other valuable consideration, subject to certain exceptions set forth in applicable state laws. Please note that if you would like to opt-out of sales through certain cookie-based tracking, you will need to separately set your preferences. Your selections are specific to the device, website, and browser you are using. Your selections are deleted whenever you clear your cookies or browser’s cache.

We will take reasonable steps to verify your identity prior to responding to your requests. The verification steps will vary depending on the sensitivity of the personal information and whether you have an account with us. Depending on where you reside, you may designate an agent to submit an opt-out of sale request on your behalf. Proof to verify your identity and the authorized agent’s authority to submit requests on your behalf are required, or we may deny the request. We may deny certain requests, or fulfill a request only in part, based on our legal rights and obligations. Depending on where you reside, if you are not satisfied with the outcome of your request, you may submit an appeal by sending us an email with “Data Privacy Appeal” in the subject line.

Note that for purposes of these requests under this section, personal information does not include information of employees and other representatives of third-party entities we may interact with; or information we have collected as a service provider to our clients.

EU, Switzerland, and UK Privacy Rights

For the purpose of EU, Switzerland, and UK data protection laws, RSL Media acts as a controller in connection with certain personal information described in this Privacy Notice. As detailed below, to the extent provided by the law of your jurisdiction, you may have legal rights in relation to the personal information about you that RSL Media holds. We may require you to prove your identity with approved identification if you request this information.

Lawful Basis for Processing Your Personal Information

We process on the following legal bases:

Contract: It is necessary for our performance of the contract you have agreed to enter with us. If you do not provide your personal information to us, we will not be able to carry out our obligations under the terms of the contract.
Legitimate Interests: We process your personal information if it is based on our legitimate interests. For example, we may process personal information in reliance on a legitimate interest in the effective and lawful operation of our business, the effective delivery and improvement of the Registry, and our platforms, information security operations, compliance with laws and regulations, compliance with requests for disclosure to law enforcement, courts, and regulatory bodies, and to prevent and detect fraud or suspected fraud. In relation to general inquiry and complaints you send us, our legitimate interest is to provide you with information you have requested and to provide customer support.
Consent: Where you have given us consent to do so, we provide you, or permit third parties to provide you, with information about goods or services which we feel may interest you. You have the right to withdraw your consent. Please see the section “Rights of data subjects” below to find out how.
Legal Claims: We need to process your personal information to defend or establish a legal claim (for example, claims relating to the sale of our goods and services under contract law).

Rights of Data Subjects

Data subjects in the EU, Switzerland, and UK have the following rights, where provided under applicable law, regarding your information (each of which is subject to various exceptions and limitations):

The right to be informed: You have the right to be provided with clear, transparent, and easily understandable information about how we use your information and your rights. This is why we are providing you with the information in this Privacy Notice.
The right of access: You have the right to obtain access to your information (if we are processing it), and certain other information (similar to that provided in this Privacy Notice).
The right to rectification: You have the right to have your information corrected if it is inaccurate or incomplete.
The right to erasure: You have the right to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
The right to restrict processing: You have rights to restrict further use of your information. When processing is restricted, we can still store your information.
The right to data portability: You have rights to obtain and reuse your personal information for your own purposes across different services and platforms.
The right to object: You have the right to object to certain types of processing, in particular processing based on our legitimate interests.
The right to refuse or withdraw consent: You have the right to refuse to provide and withdraw your consent to processing of your personal information at any time with effect for future processing.

If you are not satisfied with our response to your complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to a supervisory data protection authority. If you are a UK resident, you can make a complaint to the UK Information Commissioner’s Office (ICO): https://ico.org.uk/concerns/.

Please note your rights in relation to your personal information are not absolute. We may, for example, deny you access to your personal information when required or authorized by law, or if granting access would have an unreasonable impact on another individual’s privacy. We will retain and use your personal information as described in this Privacy Notice, including as necessary to comply with our legal and business obligations, resolve disputes, and enforce our agreements. You can submit a request regarding your personal information by contacting us.