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Elite Model Management London Ltd (“Elite”, “we” or “us”) is committed to protecting the privacy and security when processing your personal data, in compliance with the applicable data protection laws. This Privacy Notice describes how we collect and use personal data in relation to the scouting process (“Scouting”), which is aimed at finding new talents for our modelling services, and it applies to talents, as data subjects, and, where applicable, parents or legal guardians of minors. The processing carried out by Elite will be based on the principles of lawfulness, fairness, transparency, purpose and storage limitation, data minimization, accuracy, integrity, and confidentiality. It is important that you read and keep this document so that you are aware of how and why we are using your data and what your rights are under the applicable data protection laws

   

1. Controller

Elite Model Management London Ltd, with registered office in 3rd Floor, 74 Margaret St, Fitzrovia, London W1W 8SU, United Kingdom, part of the Elite World Group (“EWG” or “Group”), is responsible for the personal data you provide to us and/or we collect from you. In accordance with the applicable data protection laws, Elite is the “Controller”, as it determines the purposes and means of the processing of personal data.

   

2. Data Protection Officer

Elite has appointed a data protection officer (“DPO”). The DPO is available for any information regarding the processing of personal data carried out by Elite. You can contact the DPO by writing to dpo@elitemodelworld.com.

   

3. Type and source of personal data

By processing of personal data, we mean any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

We inform you that the personal data we process for Scouting include your name, email address, your photos and other data that can identify you or make you identifiable (hereinafter referred to as ““Personal Data””).

In particular, the Personal Data we process for Scouting include the following categories:

   

  • Common categories of Personal Data
    These include: your name, date of birth/age, gender, email address, country, city, telephone, videos and photographs, body measurements, social media accounts and any other data which we may collect during the Scouting process.
  • Special categories of Personal Data
    For the activities we perform in relation to Scouting, we do not collect special categories of Personal Data. However, with regard to data relating to your health, we may process such data, if it has been made public by you.

   

We may collect Personal Data directly from you (for example, when we meet you at an event or if you voluntarily come to our office) and/or from a modelling agency/agent you rely on to promote your image as a potential talent.

We may also collect Personal Data directly on your public accounts on social networks.

   

4. Purpose of processing, related legal basis, and data retention period

This section describes the processing of Personal Data carried out by Elite for Scouting, the purposes of each processing, the relevant legal basis, and information on the relevant data retention periods. Please note that once the relevant data retention period has ended, we delete your Personal Data from our systems and files or anonymize it so that it no longer identifies you.

   

  • Finding Potential New Talents
    The legal basis for this processing is our legitimate interest in finding potential new talents among those who have voluntarily made their Personal Data public because they want to promote their image. Where the data collected includes special categories of Personal Data, such data may still be processed as it has been directly made public by the data subject. This purpose includes the following processing of Personal Data:

       

    • Examining content made available on data subjects’ public accounts on social networks (e.g., videos, photographs, reels and posts). When we find possible interest, we take note of the Personal Data that may be useful for our Scouting process;
    • Collecting Personal Data directly from the data subject when we meet potential new talents in person (for example, at events);
    • Contacting the potential new talents, using the Personal Data that has been made publicly available (in relation to point. i. above) or requested to the data subjects (in relation to point ii. above);
    • Managing all the activities we perform in relation to Scouting, including assessing your potential as a model.

       

    Retention Period: Personal Data processed for this purpose will be retained for the time strictly necessary to assess the potential as a model and, in any case, no longer than 6 months from the submission of the application. Furthermore, we may also retain Personal Data for the time permitted by our local laws to protect our interests in legal proceedings.

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  • Satisfying Your Request
    The legal basis for this processing is the need to implement pre-contractual measures taken at your request, when you, as data subject, provide us your Personal Data (directly or through agents/agencies). The provision of Personal Data for this purpose is optional, but failure to provide it would make it impossible to satisfy your requests. This purpose includes the following processing of Personal Data:

       

    • Entering in contact with you when you, or someone you relied on to promote your image, voluntarily send us your Personal Data;
    • Managing all the activities we perform in relation to Scouting, including assessing your potential as a model.

       

    Retention Period: Personal Data processed for this purpose will be retained for the time strictly necessary to assess the potential as a model and, in any case, no longer than 6 months from the submission of the application. Furthermore, we may also retain Personal Data for the time permitted by our local laws to protect our interests in legal proceedings.

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  • Law Obligations
    The legal basis for this processing is the compliance with a legal obligation which we are subject to. Please note that it is not possible to object to this processing as it is required by law. This purpose includes the following processing of Personal Data:

       

    • To fulfil legal obligations which we are subject to;
    • Comply with a regulatory provision or an order from the competent authorities, where applicable.

       

    Retention Period: Personal Data processed for this purpose will be retained until the time specified by the specific obligation or applicable law.

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  • Direct Marketing
    The legal basis for this processing is your freely given consent. Not providing consent will not affect the evaluation on your potential as model. This purpose includes the following processing of Personal Data:

       

    • To send you advertising material, commercial information, by email and/or SMS, about existing and new services and special offers related to Elite or EWG.

       

    Retention Period: Personal Data processed for this purpose will be retained until consent is revoked and, in any case, for a maximum of 3 years from the date of consent.

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  • Third-party Sharing for their Marketing Purposes
    The legal basis for this processing is your freely given consent. Not providing consent will not affect the evaluation on your potential as model. This purpose includes the following processing of Personal Data:

       

    • To allow Elite transferring your personal data to third parties with whom has contractual relationships (e.g., partners, sponsors) so that you may receive special offers about their services or other information from them.

       

    Retention Period: Personal Data processed for this purpose will be retained until consent is revoked and, in any case, for a maximum of 3 years from the date of consent.

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  • Scouting-related Administrative Purposes
    The legal basis for this processing is our legitimate interest in:

       

    • i. Transmitting your Personal Data within our Group for evaluating your potential as model.

       

    Retention Period: Personal Data processed for this purpose will be retained for the time strictly necessary to assess the potential as a model and, in any case, no longer than 6 months from the application date. Furthermore, we may also retain Personal Data for the time permitted by our local laws to protect our interests in legal proceedings.

   

5. Personal Data Recipients

Your Personal Data may be shared, solely for the purposes referred to in paragraph 4 above, with the following third parties (collectively, “Recipients”):

   

  • Entities operating as suppliers on behalf of Elite, acting as data processors, as they process personal data on our behalf, pursuant to the applicable data protection laws;
  • Entities, bodies, or authorities, typically acting as data controllers, to whom it is mandatory to disclose your Personal Data pursuant to legal provisions or orders from authorities;
  • Individuals authorized by Elite to process Personal Data necessary to perform activities strictly related to the Scouting, who have committed themselves to confidentiality or have an adequate legal obligation of confidentiality, such as Elite employees or collaborators;
  • Other companies belonging to the Group, of which Elite is a part.

   

6. Personal Data Transfers

Some of your Personal Data is shared with Recipients who may be located outside the European Economic Area (EEA). Elite ensures that the processing of your Personal Data by these Recipients is carried out in compliance with applicable data protection laws. Therefore, such transfers may be based on an adequacy decision of the UK Government or on the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses. In their absence, the transfer will only take place if specific derogations apply, such as in the case where the transfer is necessary for the execution of a contract with an Elite’s prospect or client, in the interest of the Model.

   

7. Data subjects’ rights

At any time, you may exercise the following rights to the extent they are applicable pursuant to the data protection laws:

   

  • Know if we store/process Personal Data relating to you, and if so, have access to them and obtain a copy of such data (right of access);
  • Obtain the rectification of Personal Data, if they are incorrect, or supplement them (right of rectification);
  • Obtain the erasure of such data under the conditions set forth by the applicable data protection laws (right of erasure);
  • Request to us to restrict the processing only to certain categories of Personal Data, as permitted by the applicable data protection laws;
  • Request and receive Personal Data concerning you in a structured format, or to have such data transmitted to another controller (right to data portability), as permitted by the applicable data protection laws;
  • opporsi in qualsiasi momento al trattamento dei propri Dati personali.

   

To exercise these rights, or for any other information or concerns regarding the processing of your Personal Data, you can either contact our DPO at the following email address: dpo@elitemodelworld.com. In any case, you always have the right to lodge a complaint with the competent privacy authority.