KBITNETWORK PRIVACY, COOKIES AND CONTRIBUTOR DATA POLICY
Version 2.0 Last updated: 29 July 2026
Controller: SIMIFRAN(UK) LTD trading as Kbitnetwork (Company No. 09318164) 20 Wenlock Road, London, England, N1 7GU | admin@kbitnetwork.uk | https://kbitnetwork.uk
This policy replaces the Kbitnetwork privacy policy dated 31 July 2023. It is designed to cover Kbitnetwork websites, platforms, products, services, events, broadcasts and productions, including KVV (Kbit Virtual Venue) and the activities described in the KVV Contestant and Contributor Release Agreement.
1. About this policy
This privacy policy explains how SIMIFRAN(UK) LTD, trading as Kbitnetwork, collects, uses, stores, shares and protects personal information. It also explains the rights available to individuals under applicable data-protection law.
It applies to Kbitnetwork websites, subdomains, applications, accounts, online communities, customer and support services, products, payment and licensing activities, radio, television, video and audio services, livestreams, social-media activity, marketing, events, competitions, auditions and productions. This includes Kbitnetwork, KbitPlay, KbitTV, MyReggaelives, JustTheMix, KVV (Kbit Virtual Venue), the Simifran Hub where used for Kbitnetwork activities, and associated authorised services.
This policy should be read with any service terms, competition rules, contributor or performer release, cookie settings, safeguarding information or additional privacy notice provided for a particular activity. An additional notice supplements this policy where more detail is required.
A contributor release grants contractual, copyright, performer and production permissions. It is not blanket consent to all processing of personal information. Kbitnetwork will identify an appropriate lawful basis for each processing activity.
2. Who we are and how to contact us
The controller responsible for personal information covered by this policy is:
SIMIFRAN(UK) LTD, trading as Kbitnetwork Company number: 09318164 Registered office: 20 Wenlock Road, London, England, N1 7GU Website: https://kbitnetwork.uk Privacy and information-rights enquiries: admin@kbitnetwork.uk Legal enquiries: legal@simifran.uk
Please write “Privacy Request” or “Data Protection Complaint” in the subject line where appropriate. We may ask for proportionate information to verify identity or authority before disclosing or changing personal information.
3. Who this policy covers
This policy may apply to website visitors, account holders, customers, subscribers, licence holders, community members, people who contact us, competition entrants, applicants, contestants, contributors, performers, presenters, interviewees, guests, artists, creators, event attendees, parents or guardians, business contacts, suppliers, contractors, job applicants and other people who interact with Kbitnetwork.
Where Kbitnetwork processes information solely on behalf of another organisation, that organisation may be the controller and its privacy notice will apply. We will explain this where relevant.
4. Personal information we may collect
The information collected depends on the service or activity. We may collect the following categories:
- Identity and contact information, including name, title, stage or professional name, username, postal address, email address, telephone number, country, date of birth and age or eligibility confirmation.
- Account and membership information, including login details, profile information, preferences, membership level, subscriptions, licences, licence keys and account activity.
- Transaction information, including orders, invoices, payment status, refunds, billing details and limited payment identifiers supplied by a payment provider.
- Technical and usage information, including IP address, device and browser information, approximate location derived from IP address, timestamps, referring pages, pages viewed, login and security logs, cookie identifiers and interactions with emails or content.
- Communications and submitted content, including enquiries, support messages, comments, reviews, survey responses, uploads, website URLs, social-media handles, images, recordings and other material supplied to us.
- Contributor and production information, including applications, audition details, date of birth, biographies, photographs, video, audio, voice, likeness, performance, interviews, rehearsals, backstage activity, livestream contributions, selection decisions, production notes, release agreements, electronic signatures, music or rights-clearance information, credits and publicity material.
- Event and safeguarding information, including attendance, access requirements, emergency contacts, welfare concerns, incidents and information needed to protect people, venues, systems or equipment.
- Business, supplier and recruitment information, including organisation, role, professional contact details, proposals, contracts, qualifications, work history and references.
- Legal and compliance information, including complaints, disputes, rights requests, fraud or security reports, alleged infringements and correspondence with advisers, regulators or authorities.
5. Information requiring additional protection
We may occasionally need health, accessibility, racial or ethnic, religious, biometric-identification or other special-category information, for example to provide access support, manage welfare or respond to an emergency. We collect this only where necessary and identify both an Article 6 lawful basis and an applicable Article 9 condition before processing it.
Depending on the circumstances, the additional condition may include explicit consent, vital interests where a person is incapable of giving consent, the establishment, exercise or defence of legal claims, or another condition authorised by law. Where a more specific explanation is required, we will provide it at or before collection.
We process information about criminal allegations, offences or convictions only where this is necessary, relevant and legally permitted, for example in connection with security, safeguarding, fraud prevention or legal claims. Access to sensitive information is restricted to people who need it.
6. How we obtain personal information
We collect personal information directly when a person creates an account, buys or licenses something, submits a form, applies for or participates in an event or production, signs a release, contacts us, posts content, interacts with our services or changes cookie settings.
We also receive information automatically from devices and browsers, and may receive it from payment providers, hosting and analytics services, production partners, venues, broadcasters, distributors, social-media platforms, referees, agents, parents or guardians, public sources and people who provide information about another person.
A person who supplies information about someone else should ensure that they are entitled to do so and, where appropriate, direct that person to this policy.
7. Purposes and lawful bases
We use personal information only where we have identified a lawful basis. The basis may vary according to the relationship and circumstances. The main activities and likely bases are shown below.
Where we rely on legitimate interests, our interests may include operating and improving Kbitnetwork, producing and distributing content, communicating with audiences, managing contributors and rights, protecting services and enforcing legal rights. We consider whether the processing is necessary and balance those interests against the rights and reasonable expectations of affected people.
Where we rely on consent, consent can be withdrawn at any time for future processing. Withdrawal does not make earlier processing unlawful and does not automatically cancel a separate contract or contributor release.
Activity
Purpose
Main lawful basis or bases
Operate websites, accounts and services
Create and manage accounts; authenticate users; deliver requested features, licences, products and services; maintain availability and performance.
Contract; steps before contract; legitimate interests in operating and improving our services.
Orders, subscriptions and payments
Process purchases, subscriptions, invoices, refunds, fraud checks and financial records.
Contract; legal obligation; legitimate interests in payment administration and fraud prevention.
Enquiries and customer support
Answer questions, resolve problems, administer requests and maintain service records.
Contract or steps before contract; legitimate interests in providing support and managing relationships.
Comments, communities and submitted content
Publish or moderate comments and content; operate communities; enforce rules; address misuse and complaints.
Contract; legitimate interests in operating safe, useful services; consent where specifically requested.
Auditions, competitions and contributor administration
Receive applications; verify eligibility; communicate decisions; schedule auditions, rehearsals and events; manage contestants, contributors and production logistics.
Steps before contract; contract; legitimate interests in selecting contributors and producing programmes; legal obligation where applicable.
Recording, editing, publication and distribution
Film, photograph or record contributions; edit, caption, subtitle, archive, livestream, broadcast, publish, distribute and promote programmes and related content.
Contract and legitimate interests in creating, distributing and promoting media; consent where relied upon; legal or special-purpose provisions where applicable.
Rights, credits and production records
Manage performer and copyright permissions, releases, clearances, credits, usage history, disputes and legal claims.
Contract; legitimate interests in rights management and protecting legal interests; legal obligation.
Safety, welfare and safeguarding
Protect participants and the public; make reasonable adjustments; manage incidents and emergencies; comply with safeguarding or venue duties.
Legal obligation; legitimate interests; vital interests in genuine emergencies; an additional Article 9 condition for special-category information.
Marketing and audience communications
Send requested updates, newsletters and promotions; measure campaign performance; maintain opt-out records.
Consent where required; the electronic-mail soft opt-in where legally available; legitimate interests for appropriate business-to-business or postal marketing.
Cookies, analytics and service improvement
Remember settings; secure accounts; measure use; diagnose faults; improve products and content; understand aggregated performance.
Consent for non-essential storage or access technologies; legitimate interests for essential security, administration and appropriately collected service data.
Security, fraud and legal compliance
Detect and prevent misuse, fraud and cyber incidents; enforce terms; respond to legal requests; establish, exercise or defend claims.
Legal obligation; legitimate interests in protecting people, systems, property and legal rights.
Suppliers, contractors and recruitment
Manage commercial contacts, contracts, access, recruitment, onboarding and records.
Steps before contract; contract; legal obligation; legitimate interests in operating the business.
8. KVV and other contributor, performer and production activities
This section applies to KVV and any other Kbitnetwork audition, event, programme, interview, performance, livestream, radio, television, video, audio or promotional production.
We may process a contributor’s identity, contact and eligibility details; application and audition material; image, voice, likeness, performance and statements; biographical and promotional information; backstage and rehearsal activity; production communications; safety and welfare information; rights-clearance records; and signed releases.
Recordings may be transmitted live or with limited delay and may be published, broadcast, streamed, promoted, licensed, archived or made available worldwide through Kbitnetwork services and authorised broadcasters, distributors, sponsors and platforms. Public material may be copied, reposted, indexed, archived or discussed by third parties outside our reasonable control.
The applicable contributor release explains the contractual and intellectual-property permissions granted to Kbitnetwork. This policy explains the related handling of personal information. Optional marketing permission is separate from participation and production rights.
We do not normally disclose a contributor’s private contact details to the public. We may publish a legal name, approved stage name, biography, image, voice, performance, social-media handle or other agreed publicity information where this forms part of the programme, event or promotion.
Requests relating to published or archived media will be assessed individually. Depending on the circumstances, removal or restriction may not be required where processing remains necessary for contract, legal claims, freedom of expression, journalism, artistic or literary purposes, or another lawful ground or exemption.
9. Cookies and similar technologies
We use cookies and similar storage or access technologies, including local storage, pixels and embedded-media technologies. Some are strictly necessary for security, login, shopping, consent management and core website functions. Others may be used for preferences, analytics, audience measurement, advertising or embedded third-party content.
We use Real Cookie Banner to present choices and maintain records of cookie preferences. Non-essential technologies should not be activated until the required consent has been obtained. The website should provide equally accessible options to accept, reject or customise non-essential technologies.
Cookie details, providers, purposes and durations are displayed in the Cookie Settings tool. A person can reopen Cookie Settings and withdraw or change a choice at any time. Browser controls may also block or delete cookies, but disabling essential cookies may prevent parts of a service from working.
Embedded content, such as video players, social-media posts or payment widgets, may allow the third-party provider to collect information when activated. Where consent is required, the content should remain blocked until consent is given.
10. Marketing communications
We may send marketing by email, text, telephone, post, social media or similar channels where permitted by law. For electronic marketing to individuals, we normally rely on consent unless the limited products-and-services soft opt-in applies.
Where the soft opt-in is used, contact details must have been obtained directly during a sale or genuine negotiation for a sale, marketing must concern Kbitnetwork’s own similar products or services, and an easy opt-out must be offered when details are collected and in every message.
Marketing consent is optional and is separate from an account, purchase, application, audition or contributor release unless marketing is genuinely necessary for the requested service. A person can opt out using the unsubscribe method in a message or by contacting us.
We may retain minimal suppression information after an opt-out so that we can respect the instruction. We do not sell or rent personal contact details to unrelated third parties for their own direct marketing.
11. Payments and financial information
Payments may be processed by PayPal or another payment provider identified at checkout. Unless we expressly state otherwise, full payment-card details are entered directly into the payment provider’s systems. Kbitnetwork generally receives transaction status, amount, payer or billing details and limited payment identifiers, but does not need to store the complete card number or card security code.
Payment providers may act as independent controllers for some processing and will provide their own privacy information. We may share information needed to process payments, prevent fraud, issue refunds and maintain accounting or tax records.
12. When providing information is required
Some information is required to create an account, complete a transaction, enter a competition, verify age or eligibility, participate safely in an event or production, sign a contributor release, comply with law or respond to a request. Required fields will normally be identified at collection.
A person is not obliged to provide optional information. However, if required information is not supplied, we may be unable to provide the requested service, process an application, complete a purchase or permit participation.
13. Who we share personal information with
We share only what is reasonably necessary for the relevant purpose. Recipients may include:
- SIMIFRAN(UK) LTD personnel, authorised Kbitnetwork team members, production crew, contractors and affiliated services.
- Website hosting, cloud storage, email, CRM, electronic-signature, communications, security, IT support, analytics and consent-management providers.
- Payment processors, banks, accountants, tax advisers and fraud-prevention services.
- Venues, event operators, production suppliers, broadcasters, distributors, streaming services, social-media and video platforms, publicity providers, sponsors and licensees where relevant to a production or event.
- Professional advisers, insurers, auditors, prospective purchasers or investors and parties involved in a restructuring, sale or transfer of business or assets.
- Police, courts, regulators, government bodies and other authorities where disclosure is required or permitted by law or reasonably necessary to protect rights, safety or security.
- The public, where information is intentionally published as part of a comment, profile, directory, event, programme, broadcast, livestream, recording, credit or promotion.
14. Service providers and other controllers
Service providers acting as processors are required to handle personal information only on documented instructions, protect it appropriately and assist with data-protection obligations. We review material providers and use suitable contractual terms.
Some recipients, including payment providers, social-media platforms, broadcasters and public authorities, may act as independent controllers. Their own privacy policies apply to their processing. In some projects, Kbitnetwork and another organisation may be joint controllers; where required, we will explain the arrangement and the main contact point.
15. International transfers and worldwide publication
Kbitnetwork operates online and media content may be accessible worldwide. Personal information may therefore be processed outside the United Kingdom by service providers, broadcasters, distributors, social-media services, video platforms or other authorised recipients.
Where UK transfer rules apply to a restricted transfer, we use an available lawful mechanism, such as UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to approved contractual clauses, or another legally permitted safeguard. We carry out any required transfer assessment and apply supplementary measures where appropriate.
A person may contact us for further information about the relevant transfer safeguards. Public worldwide availability of a programme or post is different from a restricted organisational transfer, although both may have privacy consequences.
16. How long we keep personal information
We keep identifiable information only for as long as reasonably necessary for the purpose for which it was collected, including legal, accounting, safety, rights-management and reporting requirements. We use the following normal periods or criteria and may shorten or extend them where justified and documented.
At the end of the relevant period, information is securely deleted, anonymised or retained in a restricted archive where there is a continuing lawful reason.
Record type
Normal retention period or criterion
Accounts and customer relationships
For the life of the account or relationship and normally up to 6 years afterwards where needed for contracts, tax, disputes, fraud prevention or legal claims.
Orders, invoices and financial records
Normally at least 6 years from the end of the relevant financial year, or longer where tax, accounting, audit or legal requirements apply.
Enquiries and customer-support records
Normally up to 2 years after the matter is closed, unless linked to an account, contract, complaint, incident or legal claim requiring longer retention.
Marketing records
Until consent is withdrawn, an opt-out is received or the record becomes inactive under our review process. Minimal suppression information may be retained for as long as necessary to honour an opt-out.
Website, login and security logs
Normally up to 12 months, with longer retention where needed to investigate an incident, prevent fraud or establish legal claims.
Cookie and consent-management records
For the period needed to remember and demonstrate the user’s choice, normally up to 3 years from the latest recorded preference, subject to the settings and legal requirements in force.
Unsuccessful production applications and unused audition material
Normally up to 24 months after the decision or relevant production, unless the applicant agrees to consideration for future opportunities or longer retention is needed for a complaint or legal claim.
Contributor releases, rights clearances, credits and exploitation records
For as long as the programme, recording or contribution is used, licensed, distributed or archived, and normally for at least 6 years afterwards, because these records evidence continuing rights and permissions.
Raw production footage and recordings
For as long as reasonably needed for production, editing, delivery, compliance, archive, future authorised use, rights management and legal claims. Holdings are reviewed periodically.
Completed programmes, published content and editorial archives
May be retained indefinitely as published media, an editorial or historical archive, and a record of Kbitnetwork’s activities, subject to applicable law and periodic review where appropriate.
Complaints, incidents, safeguarding and legal files
Normally 6 years after closure, or longer where required by safeguarding needs, limitation periods, an investigation, regulator, insurer, court or other legal obligation.
Recruitment records
Normally 6 months after the recruitment decision for unsuccessful applicants, unless a longer period is agreed or required. Successful-applicant information becomes part of the relevant work record.
17. Anonymised and aggregated information
We may create statistical, aggregated or anonymised information to understand audiences, improve services and report business performance. Information that has been irreversibly anonymised so that no individual is identifiable is not personal information and may be retained and used without the limits described in this policy.
18. Security and personal-data breaches
We use appropriate organisational and technical measures intended to protect personal information against accidental or unlawful loss, alteration, disclosure, access or destruction. Measures may include access controls, authentication, encryption where appropriate, backups, logging, staff confidentiality, supplier checks and incident-response procedures.
No internet or storage system can be guaranteed completely secure. Where a personal-data breach occurs, we assess the risk, take appropriate action and notify the Information Commissioner’s Office and affected people where the law requires.
19. Your data-protection rights
Depending on the processing and applicable law, a person may have the right to:
- be informed about how personal information is used;
- request access to personal information and obtain a copy;
- request correction of inaccurate or incomplete information;
- request erasure in circumstances where the right applies;
- request restriction of processing;
- object to processing based on legitimate interests and object at any time to direct marketing;
- receive certain information in a portable format where portability applies;
- withdraw consent at any time where consent is the basis for processing; and
- receive safeguards in relation to qualifying solely automated decisions.
20. Exercising rights and limits on rights
Rights are not absolute and may depend on the lawful basis, the type of information and applicable exemptions. We may need to retain or continue using information for contract, tax, safety, legal claims, regulatory duties, rights management, freedom of expression or other lawful reasons.
Where personal information is processed for journalistic, academic, artistic or literary purposes, data-protection law may restrict certain rights and obligations if the legal conditions for the special-purpose exemption are met. We consider any exemption case by case and document the reasons for relying on it.
Withdrawing marketing consent does not revoke a contributor release or require removal of a programme where another lawful basis, contractual right or exemption applies. Withdrawal of consent affects future processing based on that consent and does not invalidate earlier processing.
Requests should be sent to admin@kbitnetwork.uk. We normally respond without undue delay and within one month after receiving a valid request and any information reasonably needed to confirm identity or authority. Where permitted, we may extend the response period by up to a further two months if a request is complex or numerous, and will explain the extension within the first month.
We do not normally charge a fee. A reasonable fee or refusal may apply only where permitted by law, such as for a manifestly unfounded or excessive request.
21. Data-protection complaints
A person who is concerned about how Kbitnetwork has handled personal information may submit a data-protection complaint by emailing admin@kbitnetwork.uk with “Data Protection Complaint” in the subject line, or by writing to our registered office.
Please include contact details, a description of what happened, relevant dates, the information or service involved, supporting evidence where available and the outcome requested. A representative should also provide evidence of authority to act.
We will provide a clear way to complain, acknowledge receipt within 30 days, take appropriate steps to investigate without undue delay, keep the complainant informed where appropriate and communicate the outcome without undue delay.
A person may also complain to the Information Commissioner’s Office. The ICO can be contacted through its complaint service at https://ico.org.uk/make-a-complaint/, by telephone on 0303 123 1113, or by post at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. We encourage people to contact us first so that we have an opportunity to address the concern.
22. Children and young people
Some Kbitnetwork activities may be accessible to or created for young people. Where an online service is likely to be accessed by children, we will consider age-appropriate design, data minimisation, high-privacy defaults and clear information suitable for the intended age group.
The standard KVV Contestant and Contributor Release Agreement is intended for adults aged 18 or over. A person under 18 must not sign the adult release. Where minors are allowed to participate, Kbitnetwork will use a separate minor-contributor process, an age-appropriate privacy notice, appropriate parental or guardian involvement and safeguarding measures.
We do not knowingly rely on a child’s consent for an online service where parental authorisation is legally required without taking appropriate steps to obtain or verify that authorisation.
23. Automated decision-making and moderation
We may use automated tools to help identify spam, fraud, security risks, technical problems, content-policy issues or audience trends. We do not normally make contestant-selection, account-termination, employment or similarly significant decisions solely by automated means without meaningful human involvement.
If we introduce solely automated decision-making that produces legal or similarly significant effects, we will provide specific information about the logic, significance and expected consequences and make available any safeguards required by law, including human review where applicable.
24. External websites, social media and platform services
Our services may link to or embed third-party websites, social networks, video players, payment services or other platforms. Those organisations may collect information as independent controllers. Kbitnetwork is not responsible for their independent privacy practices, and users should read the relevant third-party privacy information.
25. Changes to this policy
We may update this policy to reflect changes in our activities, technology, suppliers or legal requirements. The current version and update date will be published on the Kbitnetwork website.
Where a change materially affects how we use personal information, we will take reasonable steps to bring it to the attention of affected people, for example by a website notice, account message or email.
26. Contact details
Privacy and information-rights requests: admin@kbitnetwork.uk Legal enquiries: legal@simifran.uk Postal address: SIMIFRAN(UK) LTD trading as Kbitnetwork, 20 Wenlock Road, London, England, N1 7GU Website: https://kbitnetwork.uk
END OF POLICY