Casting Privacy Policy

11 Madison — Casting Application

1. Who We Are and What This Policy Covers

This Casting Privacy Policy (“Policy”) describes how 11 Madison Inc., a California corporation (“11 Madison,” “we,” “us,” “our”), collects, uses, discloses, and protects personal information that you submit through our online casting application (the “Application”) for a confidential unscripted production currently in development under the working title “Project Compass” (the “Program”). 11 Madison Inc. is the business responsible for the personal information collected through the Application. The Application is hosted on the Airtable platform; Airtable acts as our service provider, not as the entity responsible for your information.

This Policy is the privacy notice required by the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (collectively, the “CCPA”); the California Online Privacy Protection Act (“CalOPPA”); California Civil Code §1798.83 (“Shine the Light”); and analogous laws in other U.S. states. If you are a resident of a state with a comprehensive consumer-privacy law, additional rights apply to you as described in Section 9.

This Policy applies only to information collected through the Application. It does not replace any Participant Agreement, Appearance Release, talent contract, or background-check authorization that you may be asked to sign if you advance in the casting process. Those documents contain their own data and likeness terms and control as to the matters they address.

The Program is currently in confidential pre-production. The final title, format, talent attachments, distribution partners, and on-screen branding may differ from any working title or descriptions used in casting communications. By submitting the Application, you acknowledge that this Policy may be amended to reflect such changes; we will provide notice of any material change as described in Section 13.

2. Personal Information Collected on This Application

The Application requests the following information from you. Fields described as voluntary are not required to submit your Application; declining to provide them will not, by itself, disqualify you.

A. Identifying and Contact Information (required)

Full legal name
Date of birth
City and state of residence
Email address
Telephone number
Confirmation of whether you reside in Los Angeles

B. Education and Professional Information (required)

Occupation
College or university
Year in school
Major and minor

C. Social Media Information (required)

Instagram handle
TikTok handle

When you provide a public social media handle, we review only the publicly available content on those accounts to evaluate your Application. We do not request, store, or use your account passwords, and we do not access content that is not publicly visible. We do not use automated scraping tools to collect bulk content from your accounts.

D. Photograph (required)

A recent photograph of yourself, used solely by our casting team to evaluate your Application. We do not use submitted photographs for: (i) facial-recognition processing or facial analysis; (ii) generation of biometric templates or biometric identifiers; (iii) training, fine-tuning, or evaluation of any artificial-intelligence, machine-learning, or generative model; or (iv) sale or licensing to any third party. Photographs submitted by applicants who are not advanced in the casting process are deleted in accordance with the retention schedule in Section 7.

E. Pronouns, Gender Identity, and Race or Ethnicity (voluntary)

You may, at your option, share your pronouns, gender identity, and race or ethnicity. These fields are voluntary; you may write “Prefer not to say” or leave them blank, and your Application will be considered on its merits. We collect this information solely for audience-representation reporting, accommodation, and accessibility within the casting process.

Within our casting workflow, pronouns, gender identity, and race or ethnicity are segregated from the substantive evaluation of your Application and are not visible to the casting decision maker until after a finalist pool is identified. Casting decisions are based on creative, programming, and lawful suitability criteria and not on protected-class status, in accordance with the California Fair Employment and Housing Act.

F. Application Responses (required)

Your answers to questions concerning your views on artificial intelligence, including your strongest argument against AI and how you feel about AI in your professional or academic field.
Your availability for a one-day production shoot in June in Los Angeles. • Your application-stage acknowledgment regarding being recorded for a casting interview and the Program.

G. Internet, Device, and Form-Submission Metadata (automatically collected)

IP address, device identifiers, browser type, referring URL, and submission timestamp. • Approximate (city-level) location inferred from your IP address.
Form-platform metadata generated by Airtable in connection with your submission.

H. Information Collected Only From Advancing Candidates

If you advance to interview, finalist, or cast stages, we may also collect: government-issued identification (driver’s license, state ID, or passport); Social Security number or taxpayer identification number (only if you are offered paid participation, for tax-reporting and work authorization purposes); audition video and additional photographs; emergency contact information; and other information disclosed in a separate notice or agreement provided at that stage.

3. Sensitive Personal Information

The following categories of information collected through the Application constitute “sensitive personal information” (“SPI”) under Cal. Civ. Code §1798.140(ae):

Racial or ethnic origin (voluntary; Section 2(E)).
Government-issued identifiers, including driver’s license, state identification, passport, or Social Security number (collected only from advancing candidates; Section 2(H)). • Approximate geolocation derived from IP address (Section 2(G)); we do not intentionally collect precise geolocation.

We use SPI only for the purposes permitted by Cal. Civ. Code §1798.121 and the regulations of the California Privacy Protection Agency, including: (i) to perform the services you reasonably expect, namely evaluating your Application; (ii) for audience-representation reporting where you have voluntarily provided demographic information; (iii) to prevent, detect, and investigate security incidents or fraudulent activity; and (iv) for the specific purposes you authorize. We do not use SPI to infer characteristics about you beyond what you voluntarily provide. You may at any time direct us to limit our use of SPI as described in Section 8(E).

Information you voluntarily disclose in your Application that touches on religion, health, disability, sex life, sexual orientation, or citizenship/immigration status will also be treated as SPI and handled in accordance with this Section.

4. Sources of Personal Information

Directly from you when you complete the Application or correspond with our casting team.
From publicly available sources, including the public portions of your Instagram, TikTok, LinkedIn, and other public social media profiles you have identified or that we locate through reasonable search.
From the Airtable form platform that hosts the Application.
From third parties you authorize, including references, agents, or representatives.
From background-check providers (only for advancing candidates and only with your separate written authorization under the federal Fair Credit Reporting Act and the California Investigative Consumer Reporting Agencies Act).

5. How We Use Your Personal Information

To evaluate, screen, and select applicants for the Program, including reviewing Application responses, photographs, public social media content, and academic and professional background.
To communicate with you regarding your Application, scheduling, and casting decisions. • To conduct lawful due diligence on advancing candidates, including reference, public record, social-media, and (with separate written authorization) background checks. • To prepare for and conduct production, including talent payments, tax reporting, work authorization verification, and insurance for cast participants.
To support audience representation, accessibility, and reasonable accommodations within the casting process.
To protect the safety, rights, and property of 11 Madison, our personnel, our applicants, our viewers, and third parties.
To prevent, detect, and respond to fraud, security incidents, and violations of our terms. • To comply with applicable law and lawful process, and to exercise or defend legal claims.
To maintain and improve the casting process and recordkeeping.

We collect only personal information that is reasonably necessary and proportionate to these purposes. We will not use your personal information for materially different or unrelated purposes without first providing notice and, where required by law, obtaining your consent.

We do not use your personal information to train, fine-tune, or evaluate any artificial-intelligence or machine-learning model, and we do not authorize our service providers to do so.

6 .How We Share Personal Information

We disclose categories of personal information identified above to the following categories of recipients, in each case for the business purposes described in Section 5:

Our affiliated entities under common ownership, for internal casting administration and corporate-governance purposes.
Our personnel, casting consultants, producers, executive producers, and creative consultants, who are bound by confidentiality obligations.
Our service providers and contractors (as defined in CCPA §1798.140(ag) and (j)), including Airtable, Inc. (form platform), cloud-hosting and email providers, video conferencing providers, payments and payroll providers, insurance providers, and (for advancing candidates) background-check providers — all under written contracts that restrict use of personal information to providing services to us.
Online video distribution platforms (including major video platforms such as YouTube), with respect to applicants who appear in or are referenced in produced content. Once a Participant Agreement is signed, that agreement governs distribution use.
Sponsors, advertisers, or co-producers, only with respect to applicants who have agreed in a separately signed agreement to have their participation associated with such third parties.
Professional advisors (attorneys, accountants, insurers) in connection with our legal, regulatory, and risk-management obligations.
Governmental and regulatory authorities, in response to lawful requests and legal process.
Successors and assignees in connection with any merger, acquisition, financing, or sale of all or part of our business.

We do not “sell” your personal information for money, and we do not “share” your personal information for cross-context behavioral advertising, in each case as those terms are defined under the CCPA. We do not knowingly sell or share the personal information of consumers under 16 years of age. We will honor opt-out preference signals (including Global Privacy Control) where required by law.

7. How Long We Keep Your Information

We retain personal information collected through the Application only for as long as reasonably necessary to fulfill the purposes described in this Policy, and we apply the following retention criteria:

Applications not advanced past initial review (including all submitted photographs): retained for up to [18] months following the close of the applicable casting cycle, to enable re-consideration for future cycles and to defend against claims relating to the casting process, after which the records are deleted or de-identified.
Applications for advancing candidates, finalists, and cast participants: retained for the duration of the Program’s production, exhibition, and distribution lifecycle, plus the longest of (i) the applicable statute of limitations, (ii) the term required under any signed Participant Agreement, or (iii) [7] years.
Background-check results and underlying records: retained only for the period required by FCRA, ICRAA, and 11 Madison recordkeeping policy.
Tax and payment records for paid participants: retained for the period required under federal and state tax laws (typically [7] years).
Submitted photographs, audition recordings, and other media for cast participants: retained as part of the Program archive in accordance with any signed Participant Agreement and applicable distribution agreements.

We may retain de-identified or aggregated information indefinitely, provided it is no longer reasonably linkable to you.

8. Your California Privacy Rights

If you are a California resident, you have the following rights with respect to your personal information, subject to certain exceptions:

A. Right to Know.

You may request that we disclose: (i) the categories of personal information we have collected about you; (ii) the categories of sources; (iii) the business or commercial purposes for collecting, selling, or sharing it; (iv) the categories of third parties to whom we disclose it; and (v) the specific pieces of personal information we have collected about you.

B. Right to Delete.

You may request that we delete personal information we have collected from you, subject to exceptions including completing the transaction for which the information was collected, complying with legal obligations, exercising or defending legal claims, and other purposes permitted under Cal. Civ. Code §1798.105(d).

C. Right to Correct.

You may request that we correct inaccurate personal information we maintain about you.

D. Right to Opt Out of Sale or Sharing.

You may direct us not to sell or share your personal information. As noted in Section 6, we do not currently sell or share your personal information as those terms are defined under the CCPA. If our practices change, we will update this Policy and provide the required opt-out mechanism, and we will honor opt-out preference signals (including Global Privacy Control) where required.

E. Right to Limit Use of Sensitive Personal Information.

You may direct us to limit our use of your SPI to that which is necessary to perform the services you reasonably expect from us, or as otherwise permitted by Cal. Civ. Code §1798.121.

F. Right to Non-Discrimination.

We will not discriminate or retaliate against you for exercising any of your CCPA rights, including by denying you participation in the casting process, providing you with a different level or quality of service, or otherwise penalizing you.

G. Authorized Agents.

You may use an authorized agent to submit a request on your behalf. We may require the agent to provide signed written permission from you, may require you to verify your own identity directly, and may require you to confirm that the agent is authorized to act.

H. Verification.

We will take reasonable steps to verify your identity before responding to a request and will respond within the timeframes required by law (generally 45 days, extendable by another 45 days where reasonably necessary).

I. How to Exercise Your Rights.

You may submit a verifiable consumer request through any of the following methods: • Email: privacy@11madison.com

Mail: 11 Madison Inc., Attn: Privacy Officer, [Street Address], Los Angeles, CA [ZIP]

9. Other State Privacy Rights

Residents of other U.S. states with comprehensive consumer-privacy laws, including (without limitation) Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Delaware, Iowa, New Jersey, New Hampshire, Tennessee, Indiana, Minnesota, and Maryland, may have rights to access, correct, delete, and obtain a portable copy of personal information, and to opt out of targeted advertising, the sale of personal information, and certain profiling. To exercise any such right, contact us as described in Section 8(I). We will respond in accordance with the timeframes and exceptions set forth in the applicable law.

We do not currently solicit casting applications from outside the United States. If you submit an Application from outside the United States, you acknowledge that your personal information will be transferred to and processed in the United States.

10. California “Shine the Light” Disclosure

California Civil Code §1798.83 entitles California residents to request information about whether we disclosed personal information to third parties for the third parties’ own direct-marketing purposes during the preceding calendar year. We do not disclose personal information collected through the Application to third parties for their own direct-marketing purposes.

11. Minors and Parental Consent

You must be 18 years of age or older to submit this Application on your own behalf. If you are 17 years of age or younger, a parent or legal guardian must (i) submit the Application on your behalf or co-sign your submission, (ii) provide written consent to the collection of your personal information as described in this Policy, and (iii) provide additional consents and documentation that we may request before processing your submission. We do not knowingly collect personal information from children under 13 in violation of the Children’s Online Privacy Protection Act (“COPPA”). If we learn we have collected personal information from a child under 13 without verifiable parental consent, we will delete that information.

12. Data Security

We implement and maintain reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, and destruction, consistent with Cal. Civ. Code §1798.81.5. The Application platform (Airtable) is configured with access controls, including field-level permissions on the voluntary demographic fields described in Section 2(E). However, no system is completely secure, and we cannot guarantee the security of information transmitted to or stored on our systems. In the event of a security incident affecting your personal information, we will notify you in accordance with Cal. Civ. Code §1798.82 and other applicable law.

13. Changes to This Policy

We may update this Policy from time to time. When we do, we will revise the “Last Updated” date at the top of this Policy. Material changes will be communicated through the Application or by reasonable means consistent with applicable law. The Policy as in effect at the time of your submission governs the personal information collected at that time; subsequent amendments will not be applied retroactively in a manner that materially diminishes your rights.

14. Contact Us

11 Madison Inc.

Attn: Privacy Officer

Los Angeles, CA [ZIP]

Email: privacy@11madison.com