Effective date: October 28th, 2022
Last modified: October 28th, 2022
The Company is committed to protecting your privacy and handling your personal data in an open and transparent manner. The personal data that we collect and process will vary depending on how you use the Website.
We obtain your personal data mainly through any information you provide directly to us through our Website. Sometimes your personal data can also be shared with us, if for example you use an authentication system to Log in. Below is a list of ways we collect your personal data:
It does not apply to information collected by:
Where we need to collect and process your personal data in order to provide you with our services and you fail to provide that data when requested, we may not be able to provide you with access to our Website and/or the services we offer. In this case, we may have to suspend your access to the Website or, if you are a Member, prohibit any access to non-public areas of the Website or restrict the operation of your account and the services we provide to you.
Where we need to collect and process your personal data in order to enable you to use our Website as a Model and you fail to provide that data when requested, we will not be able to provide you with final approval to appear on the Website or, if such approval was provided to you in the past, we may withdraw such approval and suspend the operation of your account.
If you are a Browser or Member, we may process sensitive data in relation to your ethnic origin or your sexual orientation, provided that we have first obtained your explicit consent to do so. We will never request that you disclose your sexual orientation to us, however, we may infer such information from your use of the Website.
If you are a Model, we will process sensitive data in relation to your health or your racial or ethnic origin, provided that we have first obtained your explicit consent to do so. Please note if you refuse to provide your consent, or if you withdraw your consent to us collecting and processing such data, you may not be able to use, or continue using, your account on the Website.
As you navigate through and interact with our Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect these data by using cookies and other similar technologies. We may also use these technologies to collect information about your online activities across third-party websites. Please see our Cookies Policy for further details.
We will most commonly use your personal data in the following circumstances:
Below, we describe these circumstances in further detail.
We may collect and process your personal data where it is necessary in order to present our Website and its contents to you, including any interactive features on our Website and to provide you with information, products or services that you request from us.
Please note that if you do not agree to provide us with the requested information, it may not be possible for us to continue to operate your account and/or provide you with the services we provide to our Members.
We may collect and process your personal data where it is necessary in order to manage a Member’s account, to provide customer support and notices to Members about their account and/or subscription, including expiration and renewal notices, and inform you about any notices about changes to our Website or any products or services we offer or provide through it.
We may collect and process your personal data where it is necessary to administer our relationship with you, manage your account and provide you with support about your account, including expiration and renewal notices, and inform you about any changes to the Website that may affect the services that you provide to us.
We may collect and process your personal data where it is necessary in order to perform research and analysis about your use or, or interest in, our Website content and/or services, so as to develop and display content and advertising tailored to your interests on our Website.
We may collect and process your personal data where it is necessary in order to determine whether users of the Website are unique, or whether the same user is using the Website on multiple occasions, and to monitor aggregate metrics such as total number of visitors, pages viewed and demographic patterns.
We may collect and process your personal data where it is necessary to diagnose or fix technology problems, and to detect, prevent, and respond to actual or potential fraud, illegal activities, or intellectual property infringement.
In addition to the above, we may process your data, to the extent required for our business needs in order to:
When you visit and/or use and/or register in our Website (and throughout your relationship with us), we are required to comply with certain legal and regulatory obligations which may involve the processing of your personal data. This may include processing to:
We will ask for your consent when we wish to provide marketing information to you in relation to our services which we believe may be of interest and of benefit to you, but only where you are a Browser.
You have the right to revoke your consent at any time. However, any processing of personal data prior to the receipt of your revocation will not be affected.
We may also disclose aggregated information about our users, and information that does not identify any individual, without restriction. We also may share aggregated information with third-parties for conducting general business analysis. This information does not contain any personal data and may be used to develop content and services that we hope you and other users will find of interest and to target content and advertising.
Please note that we have never sold and will never sell your personal data to third parties.
Financial information (including personal information) that you have provided to us will only be shared with our third-party processors in order to initiate and complete any orders placed on your account. All credit card transactions and such are processed with industry standard encryption through third party processors who only use your financial information and personal information for that purpose. All financial data and related personal information will not be shared by us with third parties except with your authorization or when necessary to carry out all and any transactions requested by you with the understanding that such transactions may be subject to rules, terms, conditions and policies of a third party. All such information provided to a third party is subject to their terms and conditions.
Members and/or Models should be aware that all information directly provided on the Website when they create an account is public and can be viewed by all other Members and Browsers of the Website, unless otherwise stated. Even if a Member’s and/or Model’s profile does not contain any personal information, there is a possibility of identification by others through other information on the Member’s and/or Model’s profile. Accordingly, Members and/or Models should understand that they are in control of all of the information they upload on the Website and/or display on their profile and are fully responsible for any consequences arising out of such information.
We take appropriate security measures (including physical, electronic and procedural measures) to safeguard your personal data from unauthorized access and disclosure. For instance, only authorized employees are permitted to access personal data, and they may do so only for permitted business functions. In addition, we use encryption in the transmission of your personal data between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your personal data. However, please be advised that we cannot fully eliminate security risks associated with the storage and transmission of personal data as we cannot guarantee that our security measures will prevent third-party hackers from illegally obtaining this information.
You are responsible for maintaining the secrecy of your unique password and account information at all times. We are not responsible for circumventions of any privacy settings or security measures contained on the Website.
Some of our external third parties are based outside the European Economic Area (“EEA”) so the processing of your personal data may involve a transfer of data outside the EEA.
Whenever we transfer your data outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We may additionally, in rare occasions, transfer your personal data to a party outside the EEA where we have your prior explicit consent to do so or where such transfer is necessary for the provision of our services to you.
We may process your personal data so as to inform you about existing and/or future services that may be of interest to you by sending you periodic announcements with details on existing and/or new services and/or programs.
You have the right to object at any time to the processing of your personal data for marketing purposes, by sending us an email at firstname.lastname@example.org or by clicking at the opt-out link at the bottom of any marketing emails we send you.
We can only use your personal data to promote our services to you if we have your explicit consent to do so, or in certain cases such as for example when you are a Member of our Website, if we consider that it is in our legitimate interest to do so. You may also occasionally receive marketing communications from our affiliates, but only provided you have given your explicit consent in receiving such communications.
Even if you inform us that you no longer wish to receive marketing material, you will still receive from us system notices and other information specifically related to your account from time to time.
We will only keep your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Where permissible, we will also delete your personal data upon your request. Information on how to make a deletion request can be found under the paragraph “Your data protection rights” below.
If you have questions about our data retention practices, please contact us electronically by sending as an email at email@example.com.
Subject to local law, you have certain rights regarding the personal data we collect, use or disclose and that is related to you. We want to make sure you are aware of your rights in relation to the personal data we process about you. We have described those rights and the circumstances in which they apply further below.
You also have the right to object where we are processing your personal data for direct marketing purposes. This also includes profiling in as much as it is related to direct marketing.
If you object to processing for direct marketing purposes, then we shall stop the processing of your personal data for such purposes.
Depending on the circumstances, we may need to restrict or cease processing your personal data altogether or, where requested, delete your personal data. Please note that if you object us processing your personal data, we may have to suspend the services we provide to you.
Please note that if you request us to restrict processing of your personal data, we may have to suspend the services we provide to you.
If we ask for your consent to use your personal data, you can withdraw your consent at any time. Please note that in case of a withdrawal of your consent you may no longer be able to use several functionalities of our Website and our services.
Please note that some requests to delete certain personal data will require the deletion of your account as a Member and/or Model and/or Studio Operator as the provision of Member and/or Model and/or Studio Operator accounts is inextricably linked to the use of certain personal data (e.g. your email address). Also note that it is possible that we require additional information from you in order to verify your authorization to make the request and to honor your request.
To exercise any of your rights, or if you have any other questions about our use of your personal data, please contact us electronically by sending us an email at firstname.lastname@example.org or by post at .
We endeavor to address all your requests promptly.
We remain dedicated to the protection of your data and we want to be clear about the type of information collected, helping you make choices about your privacy. You may:
We strive to provide you with choices regarding the personal information you provide to us.
If you wish to lodge a complaint about how your personal data is used by the Company, you may contact us electronically at the email address email@example.com or by post at .
Upon receipt of your complaint, we will investigate it and respond to you within a reasonable time.
We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the collection, use and disclosure of personal data that cannot be resolved by an individual and us.
You also have the right to complain to the data protection supervisory authority of the country in which you reside, provided that such country is a Member State of the European Union or is located within the EEA.
Our Website is not directed to individuals under the age of eighteen (18) or the applicable age of majority in the jurisdiction from which the Website is accessed and we do not knowingly collect personal data from minors. If you become aware that your child has provided us with personal data, please contact us electronically at firstname.lastname@example.org. If we become aware that a minor has provided us with personal data, we will take steps to remove such information and terminate that person’s account immediately.
We may permit users with accounts on certain third-party services, including but not limited to, social networking, search, sharing, and other services delivered by third parties, to bypass the standard applicable registration process. If you connect through an authorized third-party service, you will be able to use your third-party login information to log in to your account or access our content and Website. We are not responsible for the sharing, posting, commenting, or other content and information gathering practices of any third-party services that may be triggered by using these third-party login services. Please review their terms of service and privacy policies carefully before using third party login functionality to access our Website.
As of January 1, 2020, the California Consumer Privacy Act of 2018 (“CCPA”) provides California residents (“Consumer(s)”) certain rights with respect to their personal information, as this term is defined under the CCPA. In addition to the rights we state under this policy and subject to the exceptions found under the CCPA, Consumers have the right to:
This Website does not sell nor has it sold in the past 12 months personal information to third parties for monetary or other valuable considerations. We may however disclose certain personal information with third parties, service providers and entities within our corporate group in order to enable them to perform certain services on our behalf and namely to make the Website work properly. Regardless, we respect the California residents’ right to exclude personal information from such sharing arrangements and to thereby opt-out of any future sale of their personal information. If the CCPA is applicable to you and you would like to record such preference, please send us an email at email@example.com.