Legal

Privacy Policy

This Privacy Policy explains how hb creative agency collects, uses and protects personal data in connection with the HB Creatives Directory, the Agency Directory and related professional activities.

1. Controller

hb creative agency is the controller responsible for your personal data (referred to as “hb creative agency”, “HBCA”, “we”, “us” or “our” in this Privacy Policy).

If you have questions about this Privacy Policy or wish to exercise any of your data protection rights, please contact us:

hb creative agency
Email: info@hbcreativeagency.com
Postal address: Via Luigi Sordello 10, 20138 Milano, Italy
Telephone: +39 331 277 0186

You have the right to lodge a complaint with the Garante per la Protezione dei Dati Personali, the Italian supervisory authority for data protection. We encourage you to contact us first so that we have an opportunity to address your concerns.

Changes to this Policy

We may update this Privacy Policy from time to time to reflect changes to our services, systems, legal requirements or data processing activities.

It is important that the personal information we hold about you remains accurate and current. Please inform us if your information changes during your relationship with hb creative agency.

Third-Party Links

Our website may contain links to third-party websites, services, plug-ins or applications. Those third parties operate under their own privacy practices. hb creative agency does not control and is not responsible for their privacy policies or processing activities.

2. Personal Data We Collect

Personal data means information relating to an identified or identifiable individual.

Depending on your interaction with hb creative agency, we may collect, use, store and process the following categories of personal data:

Contact Data — Name, email address, telephone number and professional messaging contact details such as WhatsApp or WeChat, where voluntarily provided.

Professional Data — Professional role or discipline, company, studio or agency affiliation, city, country of residence, nationality, website or portfolio, professional social media profiles and other information relevant to your professional activity.

Directory Data — Information submitted to the HB Creatives Directory or Agency Directory, including professional profiles, roles, disciplines, location, representation and other information voluntarily provided for professional collaboration, briefs and booking requests.

Project Data — Information relating to professional enquiries, project briefs, availability, bookings, collaborations and previous professional interactions with hb creative agency.

Notes and Preferences — Professional preferences, instructions or other information you voluntarily provide in connection with your profile, projects or professional relationship with us.

Aggregated Data — We may create aggregated or statistical information for operational, analytical or reporting purposes. Where this information cannot directly or indirectly identify an individual, it is not personal data under applicable data protection law.

Special Categories of Personal Data

The HB Creatives Directory is not intended to collect Special Categories of Personal Data, including information concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data used for identification, health information, or information concerning a person’s sex life or sexual orientation.

We also do not intentionally collect information relating to criminal convictions or offences through the directory.

Please do not include this type of information in free-text fields or other voluntary submissions unless specifically requested by HB Creative Agency for a lawful and clearly communicated purpose.

3. How We Collect Personal Data

We collect personal data through:

Direct Interactions — You may provide personal data by submitting a profile to the HB Creatives Directory or Agency Directory, corresponding with us, responding to a project brief, working with us on a project, or otherwise communicating with hb creative agency.

Professional Interactions — We may create or update professional records through our direct relationship with you, including enquiries, projects, bookings, casting, production and collaborations.

Profile Updates — You may provide updated information when your contact details, professional role, location, representation, portfolio or other relevant professional information changes.

4. How and Why We Use Your Data

hb creative agency processes personal data only where permitted under applicable data protection law, including the General Data Protection Regulation (GDPR).

Depending on the processing activity, we rely on one or more of the following lawful bases:

Your consent.
Our legitimate interests, where those interests are not overridden by your fundamental rights and freedoms.
Performance of a contract or steps taken at your request before entering into a contract, where applicable.
Compliance with a legal or regulatory obligation.

We may use personal data to:

Maintain and manage the HB Creatives Directory and Agency Directory.
Review, classify and organise professional profiles.
Identify creatives, agencies and collaborators whose experience, discipline, location or professional profile may be relevant to a project.
Contact individuals regarding relevant projects, briefs, casting enquiries, collaborations and booking requests.
Coordinate casting, production and other professional activities.
Manage bookings, projects and professional relationships.
Maintain accurate records of professional interactions.
Administer, maintain and protect our website, directories, databases and business systems.
Comply with legal, regulatory, accounting and reporting obligations.
Send hb creative agency news or promotional communications where you have consented to receive them.
Produce aggregated or statistical information to understand and improve our services and operations.

Where we rely on consent, you may withdraw your consent at any time by contacting info@hbcreativeagency.com. Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.

HB Creatives Directory

The HB Creatives Directory is a private professional resource operated by hb creative agency.

It enables us to maintain relationships with creative professionals across disciplines and locations and to identify potential collaborators for shows, campaigns, editorial, productions, events and other relevant projects.

Submitting a profile does not guarantee selection, representation, employment or engagement by hb creative agency or its clients.

The directory is not intended to operate as a publicly searchable database.

5. Disclosure of Personal Data

We may share personal data where reasonably necessary for our professional activities with:

hb creative agency Personnel and Authorised Collaborators — Personnel and authorised collaborators involved in casting, production, project coordination, administration and related professional activities.

Clients and Project Partners — Relevant professional information may be shared with clients or project partners where reasonably necessary in connection with a specific project, brief, collaboration, casting or booking opportunity.

The HB Creatives Directory itself is private. Clients and members of the public are not provided with general access to browse the directory unless hb creative agency expressly introduces a separate authorised access service subject to appropriate privacy and access controls.

Service Providers — Third-party service providers acting on our behalf, including providers of website infrastructure, database and cloud hosting, email services, IT support, communications and other operational systems.

Professional Advisers and Authorities — Legal advisers, accountants, insurers, regulators, supervisory authorities, courts or other authorities where disclosure is required or permitted by law.

Where third parties process personal data on our behalf, we require appropriate contractual, confidentiality, security and data protection safeguards in accordance with applicable law.

We do not sell personal data contained in the HB Creatives Directory.

6. International Data Transfers

Some service providers or recipients may process personal data outside the European Economic Area (EEA).

Where personal data is transferred outside the EEA, HB Creative Agency will apply an appropriate transfer mechanism as required by the GDPR.

Depending on the destination and recipient, this may include:

A European Commission adequacy decision.
European Commission-approved Standard Contractual Clauses.
Other legally recognised safeguards or derogations where applicable.

Where required, additional technical, contractual or organisational measures may be implemented to provide an appropriate level of protection.

7. Data Security

hb creative agency applies appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.

Access to the HB Creatives Directory is restricted to authorised users and managed according to operational need.

Personnel, collaborators and service providers who are authorised to process personal data are required to respect its confidentiality and process it only for authorised purposes.

Where third-party processors are used, we require appropriate data protection and security obligations.

We maintain procedures for responding to suspected personal data breaches and will notify affected individuals and the competent supervisory authority where required by applicable law.

8. Data Retention

hb creative agency retains personal data only for as long as reasonably necessary for the purposes for which it was collected, including professional, operational, contractual, legal, accounting and reporting requirements.

Directory profiles may be periodically reviewed to ensure that the information remains relevant and reasonably current.

Where a profile has been inactive for an extended period, we may request updated information, archive the profile or delete information in accordance with our retention practices and applicable legal requirements.

Different retention periods may apply where information must be retained to establish, exercise or defend legal claims or comply with contractual, accounting, tax or other legal obligations.

You may request removal of your directory profile or deletion of your personal data at any time, subject to any information HB Creative Agency is legally entitled or required to retain.

Requests can be sent to:

info@hbcreativeagency.com

9. Your Data Protection Rights

Subject to the conditions and limitations established by applicable data protection law, you may have the right to:

Access — Request access to the personal data we hold about you and obtain information about how it is processed.

Correction — Request correction of inaccurate personal data or completion of incomplete information.

Erasure — Request deletion of your personal data in circumstances where the GDPR provides this right.

Restriction — Request restriction of processing in certain circumstances.

Objection — Object to processing based on legitimate interests in circumstances provided by applicable law.

Data Portability — Request the transfer of certain personal data to you or another controller where the legal requirements for data portability are met.

Withdraw Consent — Withdraw consent at any time where processing is based on consent.

Complaint — Lodge a complaint with a competent data protection supervisory authority.

To exercise your rights, contact:

info@hbcreativeagency.com

We may need to request information reasonably necessary to verify your identity before acting on a request.

We aim to respond within the time limits required by applicable data protection law. Where a request is particularly complex or multiple requests have been made, additional time may be permitted under the GDPR, and we will inform you where applicable.

10. Professional Communications

Submission to the HB Creatives Directory and consent to receive general hb creative agency marketing or promotional communications should be treated separately.

Where you have specifically opted in to receive hb creative agency news or promotional communications, you may withdraw that consent at any time.

Withdrawal from promotional communications does not automatically require deletion of a professional directory profile where another lawful basis applies to its continued processing.

You may separately request removal of your directory profile or exercise your other data protection rights by contacting info@hbcreativeagency.com.

11. Glossary

Legitimate Interest — The legitimate interests of hb creative agency in operating and developing its casting, production and creative services; maintaining relevant professional relationships and directories; identifying and coordinating suitable collaborators for projects; managing professional communications; protecting its systems and information; and operating its business efficiently, provided those interests are not overridden by the rights and freedoms of the individuals concerned.

Controller — The organisation that determines the purposes and means of processing personal data. For the processing described in this Privacy Policy, the controller is hb creative agency.

Processor — A third-party service provider that processes personal data on behalf of and under the instructions of hb creative agency.

GDPR — Regulation (EU) 2016/679, the General Data Protection Regulation.