Epsila Privacy notice

Privacy notice

How Epsila Ltd, a creator marketing agency, uses information about creators, business contacts, job applicants, people at our events and visitors to our website and portals.

The short version

Who we are

Epsila Ltd is a company registered in England and Wales (company number 17143067), with its registered office at 162-168 High Street, Rayleigh, England, SS6 7BS. We are the controller of the information this notice describes. Our founders, Spencer and Jack, lead on privacy, and we have no data protection officer.

We are registered with the Information Commission (ICO), the UK's data protection regulator, registration number ZC266738.

For any question, email admin@epsila.co.uk or write to us at our registered office. Our email addresses end in @epsila.co.uk, @epsilaagency.com, @helloepsila.com, @heyepsila.com, @joinepsila.com or @meetepsila.com. We update this notice before we use information in a new way.

If you are a creator

Where your information comes from

From you, your manager or agency, people who share creator lists with us, brands' campaign decisions and public sources: your channels and profiles, statistics sites, esports results and news. We use contact directories, such as Booking Agent Info and ContactOut, only to find a possible address. If we find your address on a directory or another lookup site, we mark it unconfirmed and email it only once we have confirmed it on your own channel, website or bio.

What we hold

Sensitive information

Our notes can touch on sensitive matters, such as adult content, politics or religion, where they affect which brands suit you. We record only what you have made public yourself, for example in your own videos or posts. The law allows this because you made the information public yourself.

Why we use it

To find creators who suit a brand, contact you about paid work, put you forward and run campaigns with you. Our lawful basis is our legitimate interest in connecting creators with brands and, once we work together, our contract with you. If we only hold your manager's or agency's address, we email them instead.

What brands see

When we put you forward for a brand's campaign, we share your name, channel links, audience figures and our price with that brand, which may be outside the UK.

Once your content is live, the brand also sees how it performs. Our portal never shows brands your contact details, bank details or what we pay you.

Our creator sign-up form

Creators and talent managers can send us their details at epsila.co.uk/join. The form marks the optional answers and cannot be sent without the others. If you tick "Remember my answers on this device", your browser keeps your unsent answers on that device for seven days after you last use the form. They are deleted when you send the form, start again or untick the box, or the next time you open the form after those seven days. If you leave the box unticked, nothing is kept once you leave the page.

Confirming your email

Before you can send the form, you enter a 6-digit code that we email to the address on it, or on a talent manager's form, to the manager's own address. This email only confirms the address. It does not count as our emailing you when we work out how long to keep your record. Our record of the code keeps only a scrambled (hashed) form of the address and the code. It is deleted after 48 hours, with the opened form and the address it confirmed. A sent sign-up keeps the confirmed address.

Checks when you send it

We check YouTube and Twitch links against the platform's public data, and read any business email the channel publishes. A sign-up joins a creator we already hold only if its confirmed email address is one we hold for that creator or their manager, one their channel publishes or, from a talent manager, one at their linked agency's web address. Otherwise a person on our team reviews it. These checks never decide whether we work with you.

To stop misuse, we keep a scrambled form of your network address for 48 hours.

Our lawful basis

You tick a box to say that you want us to consider you, or the creators you represent, for paid brand campaigns, and that you have read how the details are used. For creators sending their own details, our lawful basis is taking the steps you ask for before we may agree a contract with you. For creators a talent manager adds, it is our legitimate interest in considering them for campaigns.

When we work together

When you take part in a campaign or sign with us, we also hold your contracts, legal name and address, invoice and bank details, your welcome form answers, your drafts and results, and the brand's feedback. We pay you through Wise. We may feature your published work on our website, and we take it down if you ask.

Our lawful bases are our contract with you, our legal duty to keep financial records and, for featuring your work, our legitimate interest in showing what we do.

Business contacts and job applicants

If you are a talent manager, or work for a business we deal with, we hold your name, role, work contact details, company, our conversations and any questionnaire answers you give us. It comes from you, your colleagues, your company's website, LinkedIn, our founders' connections and introductions, and for talent managers, from the creators you represent and our sources for creators.

We use it to work with you and contact you about new work, as our legitimate interest in running our business, or under our contract with your company. You can object at any time. If we pay you or your company, we also hold your invoice and bank details, under that contract and our legal duty to keep financial records.

Applying for a job

If you apply to work with us, we use your application and interview notes to consider you, as steps you ask for before a contract and our legitimate interest in hiring well.

Emails, calls and events

Our emails with you are kept in our Google mailboxes and our email store, which links each email to the records it concerns, and copies of some sit in our working files, logs and team chat. For meetings we keep calendar details, Calendly bookings, Gemini's notes, Google Meet transcripts and any recording. Our lawful basis is our legitimate interest in keeping an accurate record of our business.

Photos and video at events

We take photos and video at events such as esports tournaments, where players, other people and our team can appear. We use them in our posts, on our website and in videos and decks for brands, and have used Higgsfield's AI video tools on some. Our lawful basis is our legitimate interest in showing our work. To have one of you taken down or deleted, email us.

Our website and portals

Cloudflare delivers our website, epsila.co.uk, which has no analytics or advertising tools and sets no cookies. Its videos play in YouTube's privacy-enhanced player, which may store information on your device if you play one. For an enquiry, we keep your name, work email, company and project details, your website and the services you want if you give them, and a scrambled form of your network address.

Brands and agencies use our portal, and the people we pay use our invoice portal. For a portal account we hold your name, work email, role, sign-in details and any profile photo, and we need your work email to set it up. We record what is done in a portal, when and from which network address. Portal cookies only keep you signed in or a form open, for up to 90 days, protect our forms and remember a trusted device, never for analytics or adverts.

Some pages, such as our invoice portal, load fonts or video pictures from Google, which sees your network address. Our lawful basis is our legitimate interest in answering enquiries and running secure services, or our contract with you.

YouTube and other platforms

We use YouTube API Services to read public channel information, such as subscriber and view counts, recent videos with their views, likes and comments, and any business email a channel publishes. We read public Twitch data the same way, and check these figures again, usually every day, while we hold your record.

From them we work out figures such as average views and engagement to estimate rates, and we have noted from video descriptions which brands sponsor a channel. Until YouTube approves it, we do not build scores of our own from YouTube data. YouTube's Terms of Service are at youtube.com/t/terms, and Google's Privacy Policy is at policies.google.com/privacy.

AI tools

These AI tools help us with our work and can handle information about you:

We may use them to read your public posts and videos when we judge whether a campaign suits you, and a person on our team always decides. Model training is switched off on our team's Claude and ChatGPT accounts. Anthropic's terms for our systems and Google's for our Workspace do not allow training on our data either. Higgsfield's terms let it use what we upload to train its models.

Anthropic deletes the text our systems send it within 30 days, or keeps it for up to 2 years if its safety systems flag it. Chats in our team's Claude and ChatGPT accounts stay there until we delete them.

Our Email Agent

Our Email Agent uses Claude to read emails filed on our records, and emails we could not place, to record the prices, answers and conditions in them and to file each one in the right place. Before any email reaches Claude, the agent removes phone numbers, postal addresses, bank details and email addresses from it.

The agent works under Anthropic's data processing terms. Anthropic stores what the agent sends at rest in the United States, and its model may run in any country unless we limit it to the United States. Anthropic deletes it within 30 days, or keeps it for up to 2 years if its safety systems flag it. Our own records stay on our server in Germany.

Who we share information with

Information outside the UK

We keep our records on our own server in Germany, run by Hetzner in Nuremberg, and our backups in the European Union, which UK law recognises as protecting information to the UK's standard.

When we use Claude on your details, Anthropic stores what we send at rest in the United States, and its model may run in any country unless we limit it to the United States. This is under Anthropic's data processing terms for our systems, and under its terms and privacy policy for our team's Claude accounts. Both use standard contract clauses approved for transfers from the UK. Google, Amazon Web Services, Slack, Cloudflare and Calendly are certified to the UK Extension to the EU-US Data Privacy Framework, and DocuSign, Instantly and HeyReach use the UK's International Data Transfer Addendum. OpenAI, Higgsfield and Namecheap, in the United States, have no such safeguard for our use of them. Email us for a copy of the safeguards named above.

How long we keep information

How we protect information

Our pages use encrypted connections, and our team sees only what their role allows. Portal users who can approve creators, rates or content, or manage their team's access, must use two-step sign-in. Bank details typed into our invoice portal are encrypted and shown only by their last four characters. Bank details sent by email stay with that email.

Your rights

You can ask for a copy of your information, and ask us to correct, delete or restrict it, apart from records the law makes us keep. Where we use it under a contract or with your consent, you can have what you gave us in a common format, and withdraw your consent at any time.

Your right to object

You can object at any time to our using your information for our legitimate interests, including to our contacting you about work. If you object, we note it on your record, and from then on we do not contact you about work or put you forward for brands' campaigns. We also stop anything else you object to, unless the law allows us to continue, and we tell you if it does. Our figure checks, and the searches we run on our records, cover every creator whose record we hold, so to stop those we delete your record. You can ask us to delete everything we hold about you at any time.

Using your rights

Email admin@epsila.co.uk. It is free. We may check who you are, and we reply within one month, or within three for a complex request. Our data deletion instructions explain what we delete and when.

A person on our team decides whom we contact and whom we put forward. No decision with legal or similarly significant effects on you is made by automated means alone.

Complaints

Please tell us first if you are unhappy with how we handle your information. You can also complain to the Information Commission (ICO), the UK's data protection regulator, at ico.org.uk/make-a-complaint or on 0303 123 1113.