1. Privacy Policy
Welcome to the website of Talisman Sports Marketing LLC, a United Arab Emirates limited liability company operating under license number 1032498 (Talisman or us). Talisman is a sales and marketing agency specialising in sports, entertainment, gaming and Web3 partnerships (Services). Talisman may provide its Services through its website, www.thetalismanagency.com, and its digital and social channels (together, Talisman Platforms).
This policy (Privacy Policy) explains how Talisman protects the Personal Data of Individuals. Talisman is committed to protecting the safety and security of the Personal Data of Individuals whose information Talisman has access to, including the customers and employees of prospective and current Talisman clients, and other persons with whom Talisman interacts (each an Individual or you).
When we collect and use Personal Data about Individuals, we may be subject to applicable laws depending on the location and citizenship of the Individual. For Individuals located in the UAE, we may be subject to the Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (United Arab Emirates) (PPD) and responsible as a ‘data controller’ for such Personal Data. This Privacy Policy describes specific provisions applicable to you, including your rights to your data as it may be processed by Talisman.
2. Personal Data
In this Privacy Policy, Personal Data means any information that relates to an individual and by which that individual can be identified, directly or indirectly, including, but not limited to, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
Talisman does not sell Personal Data. Talisman does not have actual knowledge that it sells the Personal Data of Individuals under 16 years of age.
3. When Talisman Collects Personal Data and What Talisman Collects
Talisman may collect Personal Data in three main ways:
- Directly from Individuals;
- Passively from Individuals; and
- From third parties in certain, specific circumstances.
3.1 Personal Data collected directly
Talisman may collect the following types of Personal Data directly in the following circumstances:
- When an Individual makes an enquiry or sends us an expression of interest, Talisman may collect:
i. Your name, email, phone number, organisation and role (Basic Contact Information);
ii. Enquiry information, such as the details of indications of interest in the Services, or other information provided by in an enquiry;
iii.Any content that you post and submit to Talisman website and our social media pages, which includes any content from third-party platforms.
- If an Individual is appointed as their organisation’s point of contact with Talisman, we may collect Basic Contact Information.
- If you access Talisman Platforms on behalf of a corporate entity, or through a third party service or platform (e.g. LinkedIn), we will collect information that is made available to Talisman by those services or platforms.
- When Individuals engage Services, we may directly and consensually collect the Personal Data outlined in the relevant correspondence. Ordinarily this will include Basic Contact Information required for our record keeping purposes.
- When Individuals respond to a survey we may directly and consensually collect the Personal Data in the survey form.
- When Individuals provide Talisman with unsolicited feedback or otherwise interact with Talisman on their own accord, we may collect any contact information provided (including Personal Data), as well as any feedback.
- When Individuals make an application for employment at Talisman, we may collect any Personal Data provided within that application, such as the contents of a personal statement made in support of an application.
3.2 Personal Data collected passively
As Individuals come into contact with, or otherwise interact with the Services or Talisman Platforms, we may collect the following types of Personal Data:
- Content that is posted and submitted, including posts on our social media accounts or in discussion threads, as well as similar content that is posted about Individuals by others;
- The following types of browser, system and device information Individuals use to access Talisman website:
i. Locational information, such as in the form of the IP address from which Talisman website is accessed;
ii. Web data tracking information, such as data from cookies stored on Individuals’ devices, including cookie IDs and settings, as well as logs of your usage of the Talisman website;
iii. Device information provided by devices Individuals link to the Talisman website (e.g. device information from a smartphone) which at times might result in us collecting other secondary information about Individuals; and
iv. System usage information, including logs of an Individuals’ access and use of the Talisman website.
3.3 Personal Data collected from third parties
In certain specific situations, Talisman will collect Personal Data about Individuals from third parties. The types of Personal Data collected include:
- Publicly available basic contact and biographical information (e.g. details available on LinkedIn, or any other biographical, display picture or other information).
- Web data tracking information that fit certain parameters of who we think could become Talisman clients.
- Personal Data through pseudo-anonymised data sets acquired from clients or other third parties. These data sets might contain Personal Data that is not immediately attributable to identifiable individuals, but might come to constitute Personal Data when combined with other information available to Talisman.
4. Why Talisman Collects Personal Data
Although Talisman collects Personal Data from Individuals in a number of circumstances, Talisman will only collect this data in order to provide the Services. Here are the main ways we use Personal Data to achieve these objectives:
- Communicating with Individuals
Talisman will use Basic Contact Information, enquiry and feedback in order to communicate with Individuals about their enquiries or feedback, interest in Services, and for other administrative purposes related to the specific reason for which the Personal Data was collected.
If Individuals have consented, Talisman will also use these types of Personal Data to share relevant news and updates about Talisman.
- Administration and delivery of Talisman Services
Talisman will use basic contact information and other organisational information (e.g. provided about an Individual by their organisation) to engage with Individuals effectively and efficiently in providing the Services. Talisman may also use these types of information for administrative purposes.
- Ensuring User safety
Talisman will use any type of information collected to prevent and address risks to all Individuals (e.g. Talisman will use information to investigate suspicious or threatening).
- Research and development
Talisman will use the following types of information to develop, test and improve the Services and Talisman Platforms:
Survey and feedback information, as well as any content that is submitted:
- Basic account preferences
- Background account, browser, system and device information; and
- Third-party account or web tracking information.
Together these types of Personal Data are used to provide us with an overview of how the Talisman Platforms and Services are being used, any shortcomings the Talisman Platforms or Services may have, and subsequently to highlight what will be the best means of improving experiences for all Individuals.
Talisman’ preference is to de-identify these types information first, and then use it for this purpose in conjunction with de-identified browser and device information.
5. Disclosing Your Personal Data
Where we have obtained your prior express consent, your Personal Data may be shared with, or transferred to, our subsidiaries, affiliated companies, and trusted third parties (including agents, subcontractors and suppliers who are directly involved in the provision of the Services). However, you always have the option to withdraw your consent by contacting us.
We may disclose your Personal Data without obtaining your prior express consent if:
- The disclosure is permitted by applicable laws and regulations;
- The disclosure is in response to legal process (e.g. police, emergency services, etc) in order to comply with a court order or applicable law or in connection with judicial proceedings or other legal process.
- The disclosure is necessary for the execution of the agreement between us and the provision of Services to you;
- we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation or to protect the rights, property, or safety of Talisman, our clients or others.
- We are required to comply with the laws of the UAE or the express instructions of a competent authority, or where it is deemed necessary in the interests of public or national security.
In addition, we may share aggregated and/or anonymised (non-personally identifiable) information, derived from your Personal Data, publicly and with certain parties, including our partners, publishers, and advertisers.
6. Treatment and Storage of Personal Data
Talisman is committed to information security. We will use all reasonable endeavours to keep the Personal Data we collect, hold and use in a secure environment. To this end we have implemented technical, organisational and physical security measures that are designed to protect Personal Data.
When Personal Data collected or used by Talisman is stored on third-party service providers, Talisman takes reasonable steps to ensure these third parties use industry standard security measures that meet the level of information security Talisman owes Individuals. As part of our privacy framework we endeavour to routinely review these security procedures and consider the appropriateness of new technologies and methods.
If an individual believes that their privacy has been breached, please contact Talisman using the contact information below and provide details of the incident so that it can be investigated. In the event of a data breach, Talisman will notify relevant authorities and Individuals of the data breach as required under applicable laws.
7. Retention and Management of Personal Data
Talisman retains Personal Data until it is no longer needed, or until the individual who the Personal Data concerns asks us to delete it, whichever comes first. You can request Talisman to permanently delete your Personal Data by contacting Talisman using the details available below.
However, Talisman may retain Personal Data in circumstances where we have legal and regulatory obligations to do so and anonymised information for analytic and service development purposes.
8. Marketing
Where Individuals have consented, or subject to law, Talisman will use basic contact, enquiry and organisational information to provide Individuals with relevant marketing materials and offers in accordance with applicable laws. To unsubscribe from Talisman’s e-mail database or opt-out of communications, please use the opt-out facilities provided in the communication or contact Talisman using the details below.
9. Your rights in connection with Personal Data
Subject to applicable laws, you have the following rights with respect to your Personal Data:
- Right to Obtain Information. This enables you to receive a copy of the Personal Data we hold about you upon submitting a request.
- Right to Request Personal Data Transfer. This enables you to ask us, in certain circumstances, to provide you with the Personal Data you have provided to us in a structured, commonly used and machine-readable format or to transmit the personal data that you have provided to us to another party, whenever this is technically feasible.
- Request for Correction or Erasure. This enables you to request for correction or erasure of the Personal Data that we hold about you. You can ask us to update any incomplete, inaccurate, or out of date information we hold about you, to be corrected or to delete or remove personal data where there is no good reason for us continuing to process it.
- Right to Restrict Processing. This enables you to ask us, in certain circumstances, to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
- Right to Stop Processing. This enables you to object to and stop the processing if the processing of your Personal Data is for direct marketing purposes, unless the processing is necessary to achieve the public interest.
- Right to Processing and Automated Processing. This right enables you not to be subject to a decision based solely on automated processing that produces legal effects concerning you or similarly significantly affects you.
- Right to Filing a Complaint. This enables you the right to file a complaint with UAE Data Office (established by virtue of Federal Decree-Law No. 44/2021), if you consider that the processing of your personal data infringes the PPD. UAE Data Office is the regulatory and enforcing authority responsible for the protection of the privacy of individuals.
If you are UAE resident and want to exercise a data subject right in connection to your Personal Data, please contact our Data Protection Officer using the contact details below.
10. Contacting Talisman
We have appointed a Data Protection Officer (DPO) to oversee compliance with applicable data protection laws and with this Privacy Policy. If you have any questions about this Privacy Policy or how we handle your Personal Data, please contact:
[email protected]
11. Changes to our Privacy Policy
Any changes we make to our Privacy Policy in the future will be posted on the Talisman website and shall be effective from that date. Please check our websites regularly to see any changes to our Privacy Policy. By continuing to use our services you acknowledge and agree to those changes.
This Privacy Policy was last updated on 23 August 2023.