Data protection law in the European Union (the EU) has changed with the implementation of the General Data Protection Regulation (GDPR). The GDPR applies to the processing of personal data of data subjects who are in the EU by a data controller or data processor not established in the EU, where the processing activities are related to:
This policy is therefore designed to ensure Insanity Group meets its obligations under the GDPR in relation to data subjects in the EU. Some of the rights described may not apply to individuals outside of the EU.
This policy aims to give you information on how Insanity collects and processes personal data including through the use of our website, including any data you may provide when you sign up to our newsletter, purchase a product or service.
Our website is not intended for children and we do not knowingly collect data relating to children, unless we represent them pursuant to a management, agency or recording contract.
It is important that you read this policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This policy supplements the other notices and is not intended to override them.
Insanity Group is made up of different legal entities:
Insanity Group Limited (registered number: 9712931);
Insanity Talent Management Limited (registered number: 6288733);
ITM Projects Limited (registered number: 8006559);
ITM Live Limited (registered number: 09907715) (Loco Talent and Orbit Talent are trading styles of ITM Live Limited);
Insanity Records Limited (registered number: 9597152); and
Insanity Publishing Limited (registered number: 9597226)
all of which are registered in England & Wales and have their registered office at 4th floor, 180 Great Portland St, Fitzrovia, London W1W 5QZ, UK.
Insanity Group Limited also owns Insanity Group, LLC which is incorporated and based in California.
This privacy notice is issued on behalf of Insanity Group, so when we mention “Insanity”, “we”, “us” or “our” in this policy we are referring to the relevant company in the Insanity Group responsible for processing your data. Insanity Group Limited is the controller responsible for our website.
We have appointed a point of contact who is responsible for overseeing questions in relation to this policy. If you have any questions about this policy, including any requests to exercise your legal rights, please contact the below representative using the details set out below. Insanity has considered whether it is required to appoint a Data Protection Officer, following consultation with the ICO, it has elected not to. Overall responsibility for compliance sits with the Board of Directors.
Insanity Group Limited
9 Derry Street, London W8 5HY
+44 20 7361 8800
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 issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
If you live or work outside the UK or you have a complaint concerning our activities outside the UK, you may prefer to lodge a complaint with a different supervisory authority.
This version was last updated on 24 May 2018 and historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
Unless it is provided to us during the course of our provision of services, we do not collect any Special Categories of Personal Data (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
Technical Data from the following parties:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email unless we send this to you on the basis of you being an existing customer or service user and the marketing is in relation to similar services. You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below, in table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new client or customer
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Performance of a contract with you
To carry out our services including:
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To manage our relationship with you which will include:
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To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
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To administer, maintain and protect our business, our digital platforms and our roster’s digital platforms (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
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Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
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Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you, including in respect of our client roster.
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Necessary for our legitimate interests (to develop our products/services and grow our business)
If at any time you decide that you do not wish to receive marketing communications from us or those providing services on our behalf, you may either use the unsubscribe function on any recent communication from us, or you may contact us via [email protected]
We may use your Identity, Contact, Usage, Communications, Marketing and Online 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.
You will receive marketing communications from us if you have requested information from us, signed up to newsletters or notifications or purchased goods or services from us or, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside the Insanity group of companies for marketing purposes, unless the relevant company is providing services for us as our consultant.
You can set your browser to refuse all or some browser cookies but please note that some parts of our platforms may become inaccessible or not function properly.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We share your personal data within the Insanity group and with external service providers. This will involve transferring your data outside the European Economic Area (EEA). We ensure your personal data is protected by requiring all our group companies and contractors to follow the same rules when processing your personal data.
Many of our external third parties and service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; and/or
We will use specific contract provisions approved by the European Commission which give personal data the same protection.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
Insanity manages catalogue rights, intellectual property portfolios and other rights which make is necessary to retain data for longer than 6 years. Insanity is currently reviewing technological options for improving how it retains and stores historic data.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
Insanity Group Ltd
9 Derry Street
London W8 5HY
+44 (0)20 7361 8800
Insanity Group LLC
915 N La Brea Ave #536
+1 310 819 0657
Insanity Group Limited (registered number: 9712931), Insanity Talent Management Limited (registered number: 6288733), ITM Projects Limited (registered number: 8006559), Insanity Records Limited (registered number: 9597152); Insanity Publishing Limited (registered number: 9597226). Insanity Group Limited, Insanity Talent Management Limited, ITM Projects Limited, Insanity Records Limited and Insanity Publishing Limited have their registered office at 4th floor, 180 Great Portland St, Fitzrovia, London W1W 5QZ, UK.