Privacy Policy

The purpose of this privacy policy is to inform you about how Ghenemo Model Management Limited (henceforth referred to as “Ghenemo Models”, “we”, “us”, “our”) collects and uses personally identifiable data and information (henceforth referred to as “Personal Data”)

General

At Ghenemo Models, your privacy is respected. We recognise the importance of protecting any Personal Data and information shared with us and we are committed to processing any such Personal Data responsibly and in compliance with relevant data protection laws in all countries that we operate in - this includes the General Data Protection Regulation (EU) 2016/679 (GDPR) active in the European Union and the European Economic Area.

This Privacy Policy was last amended on 24th June 2021.

Legal

We collect Personal Data in order to conduct and support our model management business. This data includes, but is not limited to, evaluating applications to become a model, processing information of talent or existing employees, bookings with clients, communications electronically or otherwise, authentications, information requests and so forth.

The collected Personal Data is processed as follows: When the owner of the Personal Data has given their consent for one or multiple purposes; When the processing of Personal Data is required in order to perform a contractual and/or pre-contractual negotiation or obligation; When processing is required for legitimate interest on the part of either the Personal Data owner or Ghenemo Models; When processing Personal Data is required to comply with a legal obligation.

Do We Collect Personal Data?

We do not collect any Personal Data unless you have provided that data to us and given us clear and unequivocal consent to collect said data. This can, but does not have to be, in the form of a written application or approval.

Visitors to this website may choose to submit Personal Data to Ghenemo Models via e-mail, post or through other methods on the website, such as a form. Ghenemo Models’ models, employees, clients, applicants and suppliers may also choose to submit Personal Data to Ghenemo Models using the same methods described above.

Personal Data may also be acquired when necessary for legitimate interests or when required in order to conduct our business. Sources of the Personal Data include, but are not limited to, third parties in the modelling industry such as other modelling agencies, clients and suppliers.

What Sort of Personal Data Do We Collect?

The Personal Data occasionally collected by us can include the following: Personal Data relating to models may include: name; sex; date of birth; contact information; official identification information; passport information; visa information; tax and residential status; work eligibility status; performance and compensation information; information on willingness to shoot naked, partially naked and with animals or furs; personal attributes such as height; presence of scars, tattoos, cosmetic or plastic surgeries; photos and videos; occupation; interests and other forms of electronic presence (social media platforms, websites, etc.). Personal Data relating to employees may include: name; sex; date of birth; contact information; official identification information; passport information; visa information; tax and residential status; work eligibility status; performance and compensation information; financial account information and other information employees may provide. Personal Data relating to clients and suppliers may include: name; email address; postal address; telephone number; other contact details; position or job title; contractors, advisors and authorised partners; financial account information and company details (registered office, VAT numbers and the like).

Special Personal Data

We do not intentionally collect special categories of Personal Data unless legally required to do so in a specific country, for example, for the recruitment process. Such data includes: race or ethnic origin; political positions; religious or philosophical beliefs; union membership; biometric or genetic data and sexual orientation or sex life.

Our Website and Social Media

We do not require you to provide any Personal Data to browse our website or Social Media accounts. To enter our website or Social Media platforms, registration is not required.

If you simply visit our media platforms, we do not collect any Personal Data other than to a very limited extend through our cookies as outlined in our Cookie Policy.

Occasionally, our website will contain tools or links connected to third party websites. These websites can include those of our partners, advertisers, clients and suppliers or to resources that may interest you - including third party Social Media platforms. As we do not have any control over these third parties, the collection and use of your Personal Data whilst visiting these sites is subject to the privacy notices of the respective sites. Ghenemo Models is not responsible for the the privacy notices, policies, practices and content on any third party site. To ensure that your privacy is protected, please review the privacy notices and/or policies of third party sites.

Direct Communication: Emails and Newsletters

You may choose to register to receive ongoing updates from Ghenemo Models. In such cases, we may contact those registered with information about the models that we represent, publications and products or for other purposes related to marketing.

We may also offer emails and newsletters that share information about our models, services and products. If you subscribe to an emailing list or newsletter, we will collect basic information such as your name and email address.

You can opt out of receiving emails and newsletters at any time.

Applications to Ghenemo Models

Through our website, you can register your interest in working with Ghenemo Models. The information collected about you in such cases comes as a result of direct interaction with us and processing this personal data is required to, at your request, evaluate the business opportunity.

In applying with Ghenemo Models, you acknowledge and accept this Privacy Policy and consent to the collection, storage, transfer and other processing of Personal Data by Ghenemo Models as outlined in this Privacy Policy.

Please keep in mind that, if you are successful in your application to become a model, parts or all of your application may be made publicly available by Ghenemo Models on this website and on our Social Media platforms. Please do not submit any information within your application that you do not have the authorisation to distribute or non-essential information that you do not want others to access.

Policy Towards Children

In order to independently submit an application to Ghenemo Models, registrants must be at least 18 years of age. Minors between the ages of 14 and 18 may only apply with the written consent of a parent or legal guardian attached to their application.

If you are 13 years of age or younger, we regret to inform you, that you cannot submit any application or Personal Data to Ghenemo Models. Please do not communicate or contact us if you are 13 years of age or younger.

Data Retention

We only retain Personal Data for as long as this retention serves a purpose that is compatible with the purpose for which the Personal Data was originally collected (including, but not limited to, for audit and legal defence) or if authorised to do so by the owner of the Personal Data.

Processing of Personal Data

We take all appropriate measures to ensure that there is no unauthorised access, unlawful processing, loss, damage or destruction of Personal Data.

Personal Data is processed in Ghenemo Models’ offices or in other places where parties processing the data are located. Personal Data will only be made available to people in charge or involved with the operation of Ghenemo Models. This can include third parties, subject to the following section.

Transfer of Personal Data

Primarily, Personal Data shared by Ghenemo Models will be to manage, advise, counsel, promote and negotiate the activities of models. Ghenemo Models is requested to share Personal Data with clients or prospective clients in all areas of the entertainment industry in order to confirm jobs.

On the website, Ghenemo Models also shares images, videos of models containing Personal Data such as name, sex and physical characteristics, with the aim of promoting their images and career.

Ghenemo Models does not disclose or share Personal Data with external entities or third parties except as strictly necessary in the following cases:

• In connection with business activities, for example, demonstrating experience or proficiency of a model to clients.
• In connection with tax or legal purposes, for example, data required by accountants to complete tax returns or by lawyers to address legal obligations.
• In connection with debt collection and credit reference agencies.
• In connection with travel, entertainment and accommodation, for example, booking restaurants, hotels or flights.
• In connection with IT or other administrative support.
• In connection with emergency situations where health and/or security of a person is threatened.
• In connection with law enforcement where a legitimate request is made.
• In connection with any business reorganisation, for example, sale, merger or acquisition.

Ensuring Observation of the Privacy Policy

Ghenemo Models will us every reasonable effort to ensure that this Privacy Policy is observed and implemented. All with access to Personal Data must comply with this Privacy Policy. In the event of a violation with respect to Personal Data, Ghenemo Models will take appropriate action to cease the violation as soon as reasonably possible.

If you believe that your Personal Data may have been processed in violation of this Privacy Policy or any applicable law, please report your concern to us at hello@ghenemomodels.com.

Your Rights Regarding Personal Data

In accordance with relevant laws, including GDPR and any other data protection laws and regulations, you have certain rights in relation to the Personal Data stored or processed about you by Ghenemo Models. These rights and the ways that they can be exercised are outlined below:

• Access - you may ask us if we are processing your information and, if we are, request access to this information. In this way you can obtain a copy of that information we have about you.
• Update - you may ask us to amend any incomplete or inaccurate information that we have about you to ensure information is up-to-date and correct.
• Suspension - you may ask us to suspend processing your information if you wish for us to check accuracy or the reason for processing your information.
• Transfer - you may ask us to transfer your information to another party.
• Erasure - you may ask us to remove information in certain circumstances, for example, if you believe the processing of said information is no longer appropriate or legal.
• Consent - where we are processing your information with your consent, you may withdraw this consent.

Updates to Our Privacy Policy

This Privacy Policy may be periodically updated. Please note that the latest version of this Privacy Policy prevails over all previous versions. You are responsible for regularly reviewing this Privacy Policy and any updates or changes to this website.

Contact

If you have any questions or queries related to this Privacy Policy, you can contact us by emailing hello@ghenemomodels.com with the subject ‘Privacy Policy’.

We will do our best to answer your questions and queries.

Cookie Policy

Ghenemo Models is committed to your privacy as described in our Privacy Policy, of which this Cookie Policy (“Cookie Policy”) is a part.

By consenting to this Cookie Policy, you acknowledge and consent to our website using cookies to improve both this website’s performance and your browsing experience.

If you do not accept this Cookie Policy, please do not use this website.

This Cookie Policy was last amended on 24th February 2023.

What are Cookies?

Cookies are small amounts of data that, if you agree, are stored via your browser on the hard drive of your computer or mobile device.

Cookies collect and store specific information about your interactions with a website such as IP addresses, ISP, browser type, referring and exit pages, OS and similar or related data.

In certain areas of a website, cookies can be used to better understand you or to improve and personalise your browsing experience. An example of this would be storing preferred options and settings.

What Type of Cookies do we Use?

At Ghenemo Models, we only use cookies that do not identify individual users. We use cookies to generate statistical data about how the visitor uses the website via a unique ID and in conjunction with Google Analytics, for example, to send data to Google Analytics about the visitor’s device and behaviour.

There also exist third party cookies (Facebook Group, Twitter, etc.) that may be stored on the visitor’s computer but require an intentionally performed action by the visitor beforehand such as clicking on a third party link. Such links will direct the visitor to a third party domain and the cookie will be installed from the third party domain and not from ghenemomodels.com.

Managing Cookies

If you do not want to receive any cookies from our website, depending on the browser that you are using, you may be able to turn off cookies. This option will be in the browser settings assuming it is supported. Please note that you may not be able to experience some content on our website fully if cookies are turned off.

There is also the option, once again depending on browser, to prevent tracking through a 'do not track’ setting. This option will be in the browser settings assuming it is supported. When enabled, this setting indicates to this website and third party websites that you would prefer not to have your browsing history tracked.

Within your browser, you can view the type of cookies that have been installed on your device and block or delete these cookies as you wish. The method to do this varies depending on the browser used, however the links below direct you to the relevant documentation for some popular browsers:

• Manage cookie settings in Chrome, in Chrome Android and Chrome iOS.
• Manage cookie settings in Firefox.
• Manage cookie settings in Internet Explorer.
• Manage cookie settings in Microsoft Edge.
• Manage cookie settings in Safari, Safari iOS.

Updates to Our Cookie Policy

This Cookie Policy may be periodically updated. Please note that the latest version of this Cookie Policy prevails over all previous versions. You are responsible for regularly reviewing this Cookie Policy and any updates or changes to this website.

Updates to Our Cookie Policy

If you have any questions or queries related to this Cookie Policy, you can contact us by emailing hello@ghenemomodels.com with the subject ‘Cookie Policy’.

We will do our best to answer your questions and queries.