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Privacy Policy
Last Updated: 22nd August 2023
Introduction
Introduction You consent to receive communications from Heeblo electronically. We will communicate with you by email or by posting notices on the Websites. You agree that all agreements, notices, disclosures and other communications that we provide to you electronically satisfy any legal requirement that such communications be in “writing.” Notice will be deemed given 96 hours after it is posted on any of the Websites or sent via email. Alternatively, Heeblo may still decide to provide notice by certified mail to the address provided in a User’s payment information. 1. The Information We Collect and Use Heeblo collects Personal Data that you voluntarily provide us, when you register for Heeblo, create a talent profile, or create an employer profile. We also collect Personal Data when you sign up for email newsletters or alerts on Heeblo. Personal Data may contain your name, email, contact information, your location, as well as other information you provide to Heeblo. Heeblo collects billing information when processing payment on Heeblo.com in conjunction with posting casting notices and subscribing for membership. Heeblo may collect and store an image of your driver’s license or passport, and may extract and store information from the scanned image, such as your date of birth, in order to verify your identity and to confirm that you are 16 years of age or older, in compliance with the US Child Online Privacy Protection Act (COPPA), the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA) (collectively, “California Privacy Laws”), and Article 8 of the EU General Data Protection Act (GDPR). Heeblo may collect information from third parties, to the extent it is necessary to fulfill services requested. For example, we may utilize third party vendors to check your information on an ongoing basis against a variety of sources, which may include, but are not limited to, national criminal databases, criminal and fugitive watch lists, fraud watch lists, law enforcement reports, and other data to assist us in verifying the information you provide us (such as your name, date of birth, address, etc.) and the representations and warranties you make in the Terms of Use and on the Site. Heeblo logs your visits and use of Heeblo, such as when you view or click on content, casting notices, or ads, perform a search, install or update one of our mobile apps, or apply for roles. We use log-ins, cookies, web beacons, device information and internet protocol (“IP”) addresses to identify you, your location, and log your use. Heeblo collects and stores data about you when you use Heeblo’s messaging platform to communicate with other users. Heeblo may place a "cookie" and on your computer when you visit a Heeblo website. Heeblo may use cookies to personalize your experience using Heeblo, and to gather usage data that will help to improve the quality of the websites. There is a simple procedure in most browsers that allows you to deny, accept or delete cookies. In European Union and EEA countries, you must voluntarily consent to cookies before using the Heeblo websites as detailed in Section 6 below.  Heeblo may also obtain information about you through third party sources as permitted by applicable law, such as public databases, social media platforms, and marketing services. 2. How Heeblo Uses Your Data To create an account for you to use the Heeblo casting platform and services. To personalize Heeblo to give you a better experience, such as sending you targeted job postings based on your location. To respond to your requests or to manage user accounts. To receive product feedback and understand our users better in order to improve Heeblo. To monitor the safety and security of the heeblo service and casting platform. To use data and content about users for communications promoting membership, job posting, and engagement with heeblo, on heeblo properties and across other platforms. To target and measure the performance of advertisements displayed to our users directly by heeblo or through third party advertising partners, on and off heeblo. To verify that heeblo account owners are 16 years of age or older, in order to comply with COPPA, the California Privacy Laws, and the GDPR. To verify your identity, in order to protect the safety and security of our customers. heeblo may disclose your Personally Identifiable Information to third parties in connection with a corporate transaction where all or a portion of our business (e.g., a portion that includes our customer lists) is sold or transferred. We also may disclose your Personally Identifiable Information if disclosure is required by law or as part of a lawsuit or government investigation or proceeding, or in order to permit us to exercise or preserve our legal rights or take action regarding potentially illegal activities or to protect the safety of any person. heeblo reserves the right, but has no obligation, to monitor information, comments or other content that you voluntarily disclose and post to the Websites. heeblo reserves the right to remove any such information or material for any reason or no reason, including without limitation, if in our sole opinion such information or material violates, or may violate, any applicable law or the Terms of Use or to protect or defend our rights or property or those of any third party. heeblo also reserves the right to remove information upon the request of any third party. heeblo reserves the right to investigate abuses on the Websites and enforce and apply this Privacy Policy, the Terms of Use and any other terms or conditions applicable to the Websites or the use thereof. heeblo may disclose information about you to third parties if we have a good faith belief that such disclosure is reasonably necessary to (1) take action regarding suspected illegal activities; (2) enforce or apply the Terms of Use; (3) comply with legal process and law enforcement instructions and orders, such as a search warrant, subpoena, statute, judicial proceeding or other legal process served on us; (4) protect our rights, reputation, and property or that of our users or the public or (5) protect against legal liability. 3. How heeblo shares information Talent Profile You may choose to make your talent profile fully visible to all users on and heeblo, as well as publicly discoverable across the world wide web, or not publicly discoverable, where only logged in users can view it. You may modify the information you have provided to heeblo at any time through your heeblo profile. Messaging The heeblo service allows you to share information with other users by sending and receiving messages on the heeblo messaging system. When you send email or message heeblo customer support, heeblo will collect and store your name, email address and the content of your message so we can provide customer support. Participating in heeblo Community Forums When you post messages on the message boards on heeblo, the information contained in your posting will be stored on heeblo servers and will be openly available by other heeblo users and across the world wide web. Posting Casting Notices When a user posts a casting notice, the notice may contain personally identifiable information. By posting a casting notice on heeblo, you consent to share the contents of the casting notice with other heeblo users, as well as make the contents of your casting notice publicly discoverable across the world wide web. Other Parties Designated by You When using the heeblo Service, you may share your data with other parties designated by you. For example, when applying to a casting notice on heeblo, you may share personally identifiable data with the recipient of your application. When inviting a heeblo user to apply to your casting notice, you may also share personally identifiable information with that user. Service Providers From time to time, we may partner with unaffiliated companies or individuals for market research, product development, quality assurance testing, or similar purposes. These companies or individuals may be provided with access to personally identifiable information, but we will require by contract that they agree to maintain the confidentiality, security and integrity of such information. We also may subcontract with other companies and individuals to do work on our behalf; they may be provided with access to personally identifiable information, but only as needed to perform their functions. Data Processors heeblo, as a data controller, collects and shares data with different data processors in the following categories: Technology and Infrastructure: heeblo distributes data to processors in order to host, enable and support the heeblo platform and service. Analytics and Reporting: heeblo distributes data to analytics platforms to better understand user behavior and track key business metrics, in order to provide a better service to its users. Marketing: heeblo shares data with marketing companies to facilitate email marketing, IOS app messaging campaigns, on-site promotions, and social media, search, and display advertising campaigns for heeblo services.  Identity Verification: heeblo works with external data processors to verify the identity of users and to confirm their date of birth, in order to protect the safety and security of customers on the platform, and to comply with applicable laws such as COPPA, the California Privacy Laws, and the GDPR. You acknowledge that our vendors may provide us with certain sensitive information including your name, date of birth, and criminal history. heeblo does not purchase or sell data to data processors unless specifically instructed by you to complete a business transaction. Please direct your inquiries about any operator's privacy practices and use of children's information to the operator at its contact information provided. International Data Transfers Information, including information collected in the European Economic Area ("EEA") may be transferred, stored and processed by heeblo and its services providers in the United States and other countries whose data protection laws may be different than the laws of your country. We will protect your Personal Data in accordance with this Privacy Notice wherever it is processed and take appropriate steps to protect the information in accordance with applicable laws. Your Privacy Settings You can manage the content and information you share when using your account through the privacy settings you select. To change your Talent profile privacy settings, you may visit your account settings. a. Setting your Talent Profile to Private: Only you or the recipient of a talent application you submit will be able to view your Talent Profile. b. Setting your Talent Profile to Public: Your Talent Profile will be visible to users on heeblo.com and across the public internet. International Data Transfers Information, including information collected in the European Economic Area ("EEA") may be transferred, stored and processed by heeblo and its services providers in the United States and other countries whose data protection laws may be different than the laws of your country. We will protect your Personal Data in accordance with this Privacy Notice wherever it is processed and take appropriate steps to protect the information in accordance with applicable laws. 4. Children Under 16 The Children's Online Privacy Protection Act of 1998 and its rules (collectively, "COPPA") require us to inform parents and legal guardians (as used in this, "parents") about our practices for collecting, using, and disclosing personal information from children under the age of 13 ("children"). It also requires us to obtain verifiable consent from a child's parent for certain collection, use, and disclosure of the child's personal information. heeblo does not knowingly collect Personal Data on our Websites from children under the age of 16 without the prior consent of the child’s parent or guardian. This section notifies parents that (i) the types of information we may collect from children, (ii) how we use the information we collect, and (iii) our practices for disclosing that information is consistent with the other sections of this Privacy Policy. This section also notifies parents of (i) our practices for notifying and obtaining parents' consent when we collect personal information from children, including how a parent may revoke consent and (ii) all operators that collect or maintain information from children through Websites. This section only applies to children under the age of 16 and supplements the other provisions of this Privacy Policy. Only the other provisions of this Privacy Policy applies to teens and adults. Parental Consent Only a Parent or Legal Guardian of a child under the age of 16 years old may create an account on heeblo.com to promote their child’s performing arts career. When creating a heeblo Actor Profile on behalf of their child, the Parent or Legal Guardian will be asked to enter their child’s date of birth. If the child is under 16 years of age,a Parent must affirm that they are the Parent or Legal Guadian of the Child whose profile they are creating, and consent to the release of the child’s personal information within the heeblo Actor Profile. heeblo may require the Parent or Legal Guardian to transmit a scanned image or photograph of their driver’s license or other official identification, such as a passport, to verify their date of birth. Accessing And Correcting Your Child's Personal Information At any time, you may review the child's personal information maintained by us, require us to correct or delete the personal information, and/or refuse to permit us from further collecting or using the child's information. You can review, change, or delete your child's personal information by: Logging into your heeblo account and visiting your child’s account profile page. Sending us an email to dhruv@heeblo.com. To protect your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections. Operators That Collect or Maintain Information from Children Please direct your inquiries about any operator's privacy practices and use of children's information to the operator at its contact information provided. Only the Parent or Legal Guardian of a child under the age of 16 years old who is a resident in a country within the European Economic Area (“EEA”) may create an account on heeblo.com to manager their child’s performing arts career. When creating a heeblo Actor Profile on behalf of their child, the Parent or Legal Guardian will be asked to enter their child’s date of birth. If the child is under 16 years of age, a Parent must affirm that they are the Parent or Legal Guardian of the Child whose profile they are creating, and consents to the release of the child’s personal information within the heeblo Actor Profile. Children who live in EEA countries under the age of 16 are prohibited from using heeblo. 5. Data Retention heeblo retains personally identifiable information for the maximum period allowable by law, where there is a reasonable business need or legitimate interest to retain such data. You may contact us at dhruv@heeblo.com if at any time you would like to see the Personally Identifiable Information we hold about you, or to ask us to correct or update this information, or to ask us to delete it. Please contact us if you have questions or wish to take any action with respect to information to which this Privacy Policy applies (see below for contact information). 6. Additional Rights, Rules, And Provisions For European Economic Area Users If you are the resident of a country in the EEA, you may have additional privacy rights available to you under applicable laws. We will process your requests in accordance with applicable data protection laws. Right not to provide or withdraw consent: you have the right not to provide or withdraw your consent at any time. Right of access: you may have the right to access the Personal Data that you provided Us. Right of erasure: you may have the right to the erasure of Personal Data that we hold about you. Right to object to processing: you may have the right to request that heeblo stop processing your Personal Data and/or to stop sending you marketing communications. Right to rectification: you may have the right to require heeblo to correct any of your Personal Data. The right to lodge a complaint with a supervisory authority if you feel the above conditions aren’t being met. To make such requests regarding your personal data, please email the customer success team at dhruv@heeblo.com with the term “privacy” in the subject line. Please contact us if you have questions or wish to take any action with respect to information to which this Privacy Policy applies (see below for contact information). heeblo is a casting service for film, television, theatre, commercials and other performing arts productions. Users located in EEA countries may choose to enter personal data relating to their race or ethnicity, trade union membership, gender, and sexual orientation when using the service. This type of information is considered to be a part of the “Special Categories of Personal Data” under Article 9 of the GDPR. By choosing to enter the above categories of personal data on the heeblo service, you are giving explicit consent to the processing of this personal data for purposes referenced in this privacy policy on heeblo. heeblo has appointed James Reynolds as Data Protection Officer to oversee all aspects of our privacy and data security policies. If you would like to contact our Data Protection Officer, please send an email to dhruv@heeblo.com. In order for users from EEA countries to use heeblo websites, users must accept cookies. Users will be prompted at the beginning of their session to accept cookies. Users may withdraw consent by deleting their cookies from their browser settings at any time. 7. Links to other Websites This Privacy Policy applies only to the Websites. The Websites may contain links to other websites that heeblo may not own or operate. The links from the Websites do not imply that heeblo endorses or has reviewed these websites. The policies and procedures we describe here do not apply to these websites. We neither can control nor are responsible for the privacy practices or content of these websites. We suggest contacting these websites directly for information on their privacy policies. 8. Your California Privacy Rights California Civil Code Section §1798.83 permits users of Websites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to dhruv@heeblo.com. Privacy Notice for California Residents / Notice at Collection This Privacy Notice for California Residents supplements the information provided in the Privacy Policy and applies solely to all California residents (“consumers” or “you”) as defined by the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA) (collectively, “California Privacy Laws”). We are adopting this Notice to comply with the California Privacy Laws and any terms defined in the California Privacy Laws have the same meaning when used in this notice. We reserve the right to change this California Privacy Notice from time to time. Changes shall become effective on the date they are posted.  Information We Collect We collect personal information when you register with us for an account, when you use certain heeblo products or services, when you visit our websites, when you participate in a survey, when you ask to be included in an email or other mailing list, or when you submit your personal information to us for any other reason. We receive personal information from or on behalf of our customers in connection with our provision of products and services. We also receive personal information from subsidiaries, affiliates, business partners, and vendors. Depending on how you interact with heeblo, in the last twelve (12) months, we may have collected the following categories of information as summarized below: Identifiers (for example, name, address, email address, phone number, username) Personal information categories(for example, name, physical characteristics or description, address, phone number, employment history) Protected classification characteristics (for example, race, ethnicity, age, gender, or other demographic information)* Professional or employment-related data (position, role, occupation, previous work experience, or current or former employer, business contact information) Commercial information (for example, purchase history, financial information, billing information, Information that is generated through your other actions when you use our products and services and which is linked to your account) Internet or other similar network activity (for example, search history, information on a consumer’s interaction with a website, application, or advertisement) Geolocation data, to the extent it can be derived from other information collected from or about you (for example,  precise location data of your mobile device when enabled, general location, IP address)* Professional or employment-related information (for example, work history, union membership)* Account log-in or financial account information allowing access to an account (for example, financial account or credit card numbers in combination with any required access codes or passwords)* * Includes “sensitive personal information” as defined by the California Privacy Laws (not used or disclosed for any purpose requiring a consumer right to limit under the CPRA). We retain personal information for as long as needed or permitted in light of the purpose(s) for which it was collected. The criteria used to determine our retention periods include: The length of time we have an ongoing relationship with you (for example, for as long as you have an account with us) and the length of time during which we may have a legitimate need to reference your personal information to address issues that may arise. Whether there is a legal obligation to which we are subject (for example, if we are required to keep certain records for a period of time before we can delete them). Whether retention is allowed by applicable law (for example, based on litigation or regulatory investigations). Personal information does not include: Publicly available information. Deidentified or aggregated consumer information. Information excluded from the California Privacy Laws’ scope. Use of Personal Information We may use or disclose (to our customers, business partners, vendors, and others as required by law) the personal information we collect for one or more of the following business and commercial purposes: To fulfill or meet the reason a party provided the information. To create, maintain, customize, and secure your account with us. To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses. To help maintain the safety, security, and integrity of our websites, products and services, databases and other technology assets, and business. To provide, support, personalize, and develop our products and services. For testing, research, analysis, and product development, including to develop and improve our product, services and our websites. To respond to law enforcement requests and as required by applicable law. As described to you when collecting your personal information or as otherwise set forth in the California Privacy Laws. Other uses that we notify you about. heeblo will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice. heeblo does not sell (as defined by the California Privacy Laws) your personal information.heeblo may disclose your personal information for a business purpose to a third party with your consent or where required in order to provide products or services to you or our customers in accordance with federal and state law.  Access to Specific Information You have the right to request that heeblo disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you: The categories of personal information we collected about you. The categories of sources for the personal information we collected about you. Our business or commercial purpose for collecting, selling, or sharing that personal information. The categories of third parties to whom we disclose that personal information. The specific pieces of personal information we collected about you. If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: sales, identifying the personal information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained. Correction Requests You have the right to request that heeblo correct any inaccurate personal information about you that we maintain. Deletion Requests You have the right to request that heeblo delete your personal information that we collected and retained. However, due to the nature of the services that heeblo provides, we may be required to deny your deletion request due to legal and regulatory requirements and our contractual obligations with our vendors. In general, we may deny your deletion request if retaining the information is necessary for us or our service providers to: Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities. Debug products to identify and repair errors that impair existing intended functionality. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us. Comply with a legal obligation. Make other internal and lawful uses of that information that are compatible with the context in which you provided it. In the event that none of the above exceptions apply, we will delete your personal information from our records once we receive and confirm your verifiable consumer request for deletion. Opt-Out of Sharing You have the right to opt-out of the sharing of your personal information. Share is defined under the California Privacy Laws to include the transfer of personal information to third parties for cross-context behavioral advertising purposes. We use cookies, pixels, and similar technology, and we share certain information, such as your IP address or device identifiers, to certain third-party advertisers in order to improve your user experience and to optimize our marketing activities. You have the right to direct us not to share or use your personal information for cross-context behavioral advertising purposes. Exercising Your Rights To exercise the rights described above, please submit a verifiable consumer request to us by emailing dhruv@heeblo.com.  Only you may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must: Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which can include proof of identity and proof of address. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will review the information that you provide for authenticity and veracity against our records in order to confirm your identity. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will not discriminate or retaliate against you for exercising the rights described above. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. Response Timing and Format We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. If you have an account, we will deliver our written response to that account email. If you do not have an account, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. Where applicable, we will provide your personal information in a format is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. 9. Security of Your Data heeblo is committed to protecting the security of Your Personal Data. We use a variety of industry-standard security technologies and procedures to help protect Your personal data from unauthorized access, use, or disclosure. We attempt to follow policies and procedures that will protect against unauthorized access to your personally identifiable information. No amount of measures is 100% secure, however. We cannot make any promises or guarantees that your data will be safe, and you provide information to us at your own risk. 10. How To Contact Us You may contact heeblo regarding our privacy practices at the following address: dhruv@heeblo.com If you have any questions regarding heeblo’s privacy practices, need to access the policy in an alternative format due to a disability, or if you would like to access, update, or delete your personal information, please contact us here, dhruv@heeblo.com 11. Changes To The Privacy Policy heeblo reserves the right to change this Privacy Policy at any time. heeblo does not undertake to provide you with personal notice of any changes. In the event of material changes, heeblo will provide notice by means that are reasonable under the circumstances, such as by posting a notice on the websites. Your continued use of heeblo following the posting of changes to this Privacy Policy means you accept those changes.

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