Legal

Privacy Policy

This policy explains what personal information we collect through the WTSN Group website and when you contact us, why we use it, and the rights you have over it.

Last updated
Operated by
WTSN Digital Ltd, company number 15895739

Who we are

WTSN Group is operated by WTSN Digital Ltd, a company registered in England and Wales under company number 15895739. Our registered office is 3rd Floor, 86-90 Paul Street, London, England, EC2A 4NE.

WTSN Digital Ltd is the controller of the personal information described in this policy. That means we decide how and why it is used, and we are responsible for looking after it under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

WTSN Agency, WTSN PR and WTSN Finance are the divisions of WTSN Group, and all three are operated by WTSN Digital Ltd.

How to contact us

For any question about this policy or your personal information, email apply@wtsndigital.com or write to us at WTSN Digital Ltd, 3rd Floor, 86-90 Paul Street, London, England, EC2A 4NE.

We have not appointed a data protection officer, because the law does not currently require us to. The contact details above reach the people responsible for data protection at WTSN.

What this policy covers

This policy applies to personal information we collect:

  • when you visit this website
  • when you apply to work with us, or make an enquiry, through the website or directly
  • when you contact us by email or another channel

It does not cover the personal information we handle for clients under an agreement with us.

Visiting the website

The website does not ask you to register, and you can browse it without giving us any personal information.

Like any website, it can only be delivered to your device if your browser sends some technical information to the server that hosts it. This includes your IP address, browser and device type, the page you asked for, the page that referred you and the date and time of the request. Our hosting provider records some of this, such as the page requested, the time, the response and your browser type, in logs that we can view to keep the website working and secure and to investigate faults or misuse. The application form does not write your answers into these logs.

  • Hosting provider: Vercel Inc., based in the United States
  • How long logs are kept: 30 days

We do not use this information to identify you, build a profile of you or market to you.

Cookies and similar technologies

The website does not currently set any cookies and does not use analytics, advertising or tracking technologies. It loads no third-party scripts, and its fonts are served from our own website rather than an external service.

If we introduce cookies or similar technologies that are not strictly necessary, we will update this policy first and ask for your consent where the Privacy and Electronic Communications Regulations 2003 require it.

Applications and enquiries

Our application form asks only for the information we need to see whether we are the right fit for one another:

  • your full name and email address
  • a link to your social media profile or website, if you choose to give one
  • which part of WTSN you are enquiring about
  • your answers about yourself, your current position, what you want to achieve and why you are interested in WTSN, and anything else you choose to tell us
  • your confirmation that you are 18 or over, and that you have read this privacy information

When you submit the form, your answers are sent by email, through our email delivery provider, to our team’s inboxes, with the date and time you submitted it. We do not store them in a database on the website. We will usually also send you a short email to confirm your enquiry has reached us. If that email cannot be sent, your enquiry has still reached us.

To keep the form free of automated spam, it includes a hidden field that people do not see, and it checks how long the form took to complete. Your IP address is used briefly to limit repeated submissions. It is held only in the working memory of the server that receives your enquiry and is not saved by us.

If you email or message us directly, we will receive whatever you include, along with your contact details.

We use this information to:

  • review your application or enquiry and decide whether we can help
  • reply to you, ask follow-up questions and arrange a conversation
  • keep a record of our correspondence
  • prepare for an agreement with you if we both decide to work together

We do not ask for passwords, account log-in details, payment card details, identity documents or financial records through the website. Please do not send them.

Sensitive information

We do not ask for special category information, such as details of your health, ethnicity, religion, sex life or sexual orientation. However, because many of the creators we work with produce adult content, information you share about your work may reveal details of your sex life or sexual orientation, which UK GDPR protects more strictly.

Where this happens, we use the information only to assess and respond to your application or enquiry.

Age

WTSN Agency, WTSN PR and WTSN Finance work only with adults aged 18 or over, and our application form asks you to confirm your age. We do not knowingly collect personal information from anyone under 18, and if we learn that we have, we will delete it.

Our lawful bases

UK GDPR requires us to have a lawful basis for each way we use personal information. We rely on the following:

  • Steps before entering into a contract. When you apply or ask about our services, we use your information to assess your application and discuss working together, because you have asked us to.
  • Legitimate interests. We use information to respond to general enquiries, keep records of our correspondence, run and protect the website, and establish or defend legal claims. Our interests are running and protecting our business and handling enquiries properly. We only rely on this basis where those interests are not outweighed by your rights and interests.
  • Legal obligation. We keep some information where the law requires it, for example for tax and accounting purposes if we go on to work together.
  • Consent. Where we ask for your consent, such as for cookies that are not strictly necessary in future, we will rely on it. You can withdraw consent at any time, and this will not affect anything we did before you withdrew it.

We do not send marketing emails, and we do not sell personal information.

Who we share information with

We share personal information only where necessary, and only with:

  • Service providers who help us run the website and our business. They act on our instructions and may not use your information for their own purposes. They are:
    • Vercel Inc., which hosts the website and runs the application form
    • Resend, which sends the emails containing your application and our confirmation to you
    • Namecheap, Inc., whose PrivateEmail service hosts our email inboxes, including apply@wtsndigital.com
  • Professional advisers, such as lawyers and accountants, where we need their advice.
  • Authorities and regulators, where the law requires it, or to protect our rights, property or safety, or those of others.
  • A buyer or successor, if all or part of our business is sold or reorganised, subject to the same protections described in this policy.

We will not pass your details to the media, brands or other third parties as part of an application or enquiry without first agreeing it with you.

International transfers

Vercel, Resend and Namecheap are based in the United States, and information you submit through the website, including the emails containing your application, is processed and stored there. UK data protection law allows this only where the transfer is protected:

  • Vercel and Resend: each one’s data processing terms include the UK’s approved contractual safeguards (the European Commission’s standard contractual clauses with the UK Addendum), and each is certified under the UK Extension to the EU-US Data Privacy Framework.

How long we keep information

We keep personal information only for as long as we need it for the purposes described in this policy:

  • Applications and enquiries that do not lead to working together: we delete them, including the emails in our inboxes and any notes we made, within 30 days of our last contact with you. We do this by hand; it is not automatic.
  • Correspondence with people who become clients: for the length of our relationship, and then as set out in your client agreement and as required for legal, tax and accounting purposes

Some copies are held by our service providers under their own retention rules, which we do not control:

  • Our email delivery provider (Resend) keeps the emails it sends, including their content, for 30 days, and its backups for up to 7 days, under its standard plans.
  • Our hosting provider (Vercel) keeps its logs for the period described in “Visiting the website” above.
  • Our inbox provider (Namecheap PrivateEmail) may keep backups of our mailboxes for a period after we delete an email.

When information is no longer needed, we delete it or anonymise it securely.

Keeping information secure

We use appropriate technical and organisational measures to protect personal information against loss, misuse and unauthorised access, and we limit access to the people who need it to do their work. No method of sending information over the internet is completely secure, so please do not send us sensitive details we have not asked for.

If a personal data breach occurs that is likely to put your rights at risk, we will report it to the Information Commissioner’s Office where required, and tell you where the law requires us to.

Your rights

Under UK data protection law, you have the right to:

  • Access the personal information we hold about you and receive a copy
  • Rectification, to have inaccurate or incomplete information corrected
  • Erasure, to ask us to delete your information in certain circumstances
  • Restriction, to ask us to limit how we use your information in certain circumstances
  • Object to our use of your information where we rely on legitimate interests
  • Data portability, to receive information you gave us in a structured, commonly used format, or have it sent to someone else, where our use is based on consent or a contract
  • Withdraw consent at any time, where we rely on your consent

We do not make decisions about you based solely on automated processing.

To exercise any of these rights, contact us using the details in “How to contact us”. You will not usually have to pay a fee. We may need to confirm your identity before we respond, and we will reply within one month. If your request is complex, or you make several requests, we may need up to two further months, and we will tell you if that is the case.

Complaints

If you are unhappy with how we have handled your personal information, please contact us first so we can try to put it right.

You also have the right to complain to the Information Commissioner’s Office, the UK regulator for data protection:

  • Website: ico.org.uk/make-a-complaint
  • Telephone: 0303 123 1113
  • Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

If the website links to another website or platform, that website has its own privacy policy, and we are not responsible for how it handles your information.

Changes to this policy

We will update this policy when the website or the way we use personal information changes, for example when we add a new form or service provider. The date at the top shows when it was last updated. If we make a significant change, we will make it clear on the website.