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Website Privacy Policy for FINDA Global Limited

Updated 25 July, 2018

At FINDA Global Limited, we are committed to protecting the confidentiality and privacy of our clients and the models who we bring together via our innovative platform linking professional talent.

Our aim is to give you greater control. Control over whom you work with, when you work and, importantly, over your personal information.

1. THIS POLICY

Our website is set up to be as transparent as possible about the way we handle your personal information (or personal data).

This website privacy policy explains how we will process the data relating to you that you provide to us (or that we may collect via other sources, such as social media) when you visit our website at https://www.finda.co (Website).

The Website is operated by FINDA Global Limited (we, us, our, FINDA), a company incorporated in England & Wales with company number 11208182 . Where we decide the purpose or means for the processing of the personal data that you provide via our Website, we are the “data controller”. As data controller, we will comply with all applicable data protection laws.

This policy should be read together with our Platform Terms and Conditions of Use.

Our Website may contain hyperlinks to third party websites. These websites operate independently from us, and we cannot accept any responsibility or liability for the privacy practices of such third parties nor the availability of these external sites or resources. The appearance of such links on our Website is not an endorsement. Should you use any of these websites, such use is at your own risk and we would advise that you review their respective privacy policies.

2. WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?

When you visit our Website, we may collect and process the following information which may include your personal information.

While our Website does maintain public webpages (such as our Homepage, “About Us”, our “Join Now” invitation, “Forgot Password?”, FAQs and similar webpages), our Website is primarily a private website for FINDA's registered clients and professional talent. Our Website uses data analytics and cookies, so if you browse our public webpages, we may collect some of the types of information listed below in our section entitled “Cookies & Analytics”. Otherwise, we do not collect, use, store or otherwise process personal data about those website browsers who visit our public webpages.

OUR NETWORK OF PROFESSIONAL MODELS

Types of information collected and processed

Registration

When models register to create an account with our platform, we will collect and store the personal information you provide when completing the online registration form.

By clicking on "Join Now" and "I'm A Model", you will be directed to our secure online registration form where you are asked to provide the following initial personal data:

  • First and last names
  • Gender
  • Email address
  • Instagram “address” or username
  • Referral code (if applicable)
  • Password (which you create and which we cannot view or retrieve)

Once you have provided the above information and confirmed that you have read, understand and/or agree to our terms and conditions, you may submit your personal data by clicking on “Ok”.

To complete the registration process, you will be asked for more extensive personal data such as financial details or proof of identity. Proof of identity may include a photo or scanned copy of a passport, driving licence or other government issued identification card that includes photo identification, in order to create and personalise your own profile on our platform.

Model Profile

We collect personal information when models create their profiles and use FINDA website. More details about verified models’ personal data is available to verified models. They can access it at the Privacy Policy page when they log-in to their profiles at our website.

Purpose of the processing and legal basis for the processing

We may legally process the personal information that we collect on the basis that we have a legitimate interest and/or in the performance of a contract:

  • to provide you with information about our business, the benefits and responsibilities of joining our network of modelling professionals
  • to perform both our online and off-line model search and matching consultancy services;
  • to create your account with us, allowing us to perform background verification checks such as those required by law (e.g. right to work)
  • to maintain your account with us, which provides visibility of your physical description and portfolio to our client network supporting some of the UK’s top brands;
  • to keep you updated about activities on your account, such as booking notifications and payments, and about events and other opportunities offered to our registered models
  • to respond to your enquiries

FINDA seeks to always be at the cutting edge of the modelling industry with its digital platform, which means continually innovating and changing to meet the industry’s changing needs. As our business adapts and needs change, we may seek to use your personal information for new purposes, and we will inform you of such changes by updating this policy and, where practicable, via direct communication.

Who is this information shared with?

We keep your information confidential at all times. In order to conduct our business as a modelling talent platform, we will need to provide our own personnel and our registered clients/brands with access to the personal information on your personalised portfolio page. Additionally, we may need to disclose or provide access to personnel data to third party suppliers or subcontractors (including our independent consultants, data analytics providers and cloud-based data processing and hosting providers).

If we do share your information, we will only do so insofar as it is reasonably necessary for the purposes set out in this privacy policy, and provided that the recipients do not make independent use of the information and have agreed to adhere to the rules set out in this privacy policy.

In some instances, this data sharing may involve the transfer of information outside the EU. Please see our section on International Data Transfers below.

OUR NETWORK OF CLIENTS AND/OR BRANDS

Types of information collected and processed

Registration

When clients register their brands and/or companies in order to view our amazing network of professional models, including the models’ individual profiles, to search for and book models to meet their business needs, they will first need to register and create an account with our platform.

As part of the registration process, we may collect and store the following personal information:

Client Profile

  • First and last names
  • Date of birth
  • Email address
  • Telephone number
  • Nationality
  • Country of residence
  • Occupation
  • Website address (Company)
  • Company Name (which, for our freelance / sole trader clients, may be the same as client’s name)
  • Proof of identity (a photo or scanned copy) such as a passport, driving licence or other government issued identification card that includes photo identification.

Clients are also asked to provide information about your preferences about when they would like to be contacted and to create a password.

Dashboard and Projects

We collect personal information when clients create their profiles and use FINDA website. More details about verified clients’ personal data is available to verified clients. They can access it at the Privacy Policy page when they log-in to their profiles at our website.

Purpose of the processing and legal basis for the processing

We may legally process the personal information that we collect on the basis that we have a legitimate interest and/or in the performance of a contract:

  • to provide you with information about our business, the benefits and responsibilities of joining our network of clients and brands
  • to perform both our model search and matching consultancy services to provide you with prospective model candidates that are well suited to your requirements;
  • to create your account with us, including verification of prospective client’s identity as part of the account set-up process
  • to maintain your account and provide access to our online services, such as allowing you to post your specific project criteria, to access candidates’ profiles that match your selected criteria and to make bookings and payments via the site;
  • to respond to your enquiries or otherwise communicate with you in relation to your account, bookings and the provision of our services generally.

FINDA seeks to always be at the cutting edge of the modelling industry with its digital platform, continually innovating and changing to meet your needs and those of our other clients. As our business adapts to response to our clients’ changing needs, we may seek to use your personal information for new purposes, and we will inform you of such changes by updating this policy and, where practicable, via direct communication.

Who is this information shared with?

We keep your information confidential at all times. In order to conduct our business as a modelling talent platform, we will need to provide our own personnel and our trusted third party suppliers, sub-contractors and service providers, such as our payment, data analytics or cloud-hosting service providers, with access to personal information that you provide to us.

If we do share your information, we will only do so insofar as it is reasonably necessary for the purposes set out in this privacy policy, and provided that the recipients do not make independent use of the information and have agreed to adhere to the rules set out in this privacy policy.

In some instances, this data sharing may involve the transfer of information outside the EU. Please see our section on International Data Transfers below.

OUR SOCIAL MEDIA PAGES and our use of social media

Types of information collected and processed

Our Website contains links to FINDA’s social media pages on Facebook, Instagram, Twitter and LinkedIn. These links are only accessible on our Website when you visit and are not logged in to the Website. Once you log in to the Website, these links are no longer made available to you.

These third party websites have their own respective privacy policies (which we would advise you to read) for which those sites are solely responsible.

Facebook: https://www.facebook.com/privacy/explanation

Instagram: https://help.instagram.com/519522125107875?helpref=page_content

Twitter: https://twitter.com/en/privacy

LinkedIn: https://www.linkedin.com/legal/privacy-policy

Purpose of the processing and legal basis for the processing

If we do receive any personal information about you from these third party social media sites, we may use this information to find out more about our digital community so that we can better understand and serve our customers and website visitors (for example, to create bespoke content by analysing general interests). We will not process your information for the purposes of direct marketing unless you have provided your consent or it is otherwise lawful for us to do so (such as where we already have in place or are negotiating a contract for the supply of services with you).

If we send you marketing communications, this will be in respect of similar or related products or services that we believe may be of interest to you, and you may opt-out of such communications at any time by contacting us at support@finda.co.

For further information, please see our section below on “Our Approach to Marketing”.

How is this information shared between us and the Social Media sites?

We will not share with any third party the personal information that we obtain about you for the purposes of marketing.

If you would like us to delete the personal information that we have received about you from these sites, please email us at support@finda.co.

If you do not want us to receive further information about you from these sites, you should also contact the sites directly to turn off the ‘follow’ setting.

If you would like to have deleted the personal data that you’ve shared with our social media accounts that you have joined or that you follow, please contact the social media providers directly.

OUR APPROACH TO MARKETING

Types of information collected and processed

Our Website does not contain third party advertising.

We may collect information about you in order to send you our promotional or marketing communications, such as:

  • Name;
  • Email address;
  • Postal address;
  • Phone number(s);

While we do not permit third party advertising (or targeted advertising) on our Website, if you do link to one of our FINDA social media sites you may be subject to targeted marketing via that site.

Purpose of the processing and legal basis for the processing

If you are a registered account holder or where you have asked to be added to our mailing list, we may send you our e-newsletters or other promotional materials.

We engage a third party service provider called MailChimp (www.mailchimp.com), that helps us to produce, manage and distribute our newsletters and marketing communications. When we share your personal details with any third party service providers, we will keep these to the minimum required and ensure that those third parties have agreed to make no independent or further use of that data and to maintain its confidentiality.

We also make use of a third party service provider called SendGrid (www.sendgrid.com) solely for the delivery of emails from us to you in response to certain actions or preferences you have selected within your profile, such as sending email notifications about upcoming jobs. We do not share any information with SendGrid beyond that needed to deliver the email to your nominated email address, and SendGrid does not retain or store this information once the email has been delivered.

If you prefer to not receive these communications, you may opt-out at any time via the unsubscribe feature that appears in our emails or by contacting us at support@finda.co . If you prefer not to receive communications via email, you may request that communications are sent solely via your dashboard.

Who is this information shared with?

We will not share with any third party the personal information that we obtain about you for the purposes of marketing, unless you have provided your consent for us to do so and those third parties have agreed to make no independent or further use of that data and to maintain its confidentiality.

OUR APPROACH TO OBJECTIONABLE CONTENT

Types of information collected and processed

If you send us objectionable content, or behave in a disruptive manner when using our Website, we may process any personal information that you have submitted to us, including in your personal messages, to respond to and stop such behaviour.

Purpose of the processing and legal basis for the processing

We will only process personal information in this way for the following legitimate interests:

  • ensuring that the use of our Website is lawful;
  • ensuring that users do not disrupt or harass our staff, clients or other Website users; and
  • for the purpose of enforcing our legal rights and complying with our legal obligations.

Who is this information shared with?

Where we reasonably believe that you are or may be in breach of the law (i.e. the content you share on the Website amounts to harassment or is defamatory), we may use your personal information to inform relevant third parties about the content, such as:

  • your email or internet provider; or
  • law enforcement agencies

Where we process personal information in this way, we will hold that personal information on our systems for as long as is reasonably necessary to achieve these objectives.

3. COOKIES & ANALYTICS

Our Website uses cookies and other mechanisms to collect log and analytical information, to help analyse how visitors use the site and to compile statistical reports on Website activity. In particular, Facebook tracking cookies are in use on our Website. To find out more about the use of these and other cookies, and how to opt-out, please visit:

Our Website also uses website analytics, including Google Analytics as well as our own in-house analytics services, to evaluate and improve our Website, personalise your experience and to offer the best, most accessible service possible to all of our customers.

To find out more about Google Analytics and to learn how to opt out, please visit:

  • How Google uses data when you use our partners' sites or apps, or https://tools.google.com/dlpage/gaoptout/.
  • Analytics and tracking services from Google and Facebook are only enabled when you visit the Website and are not logged in. Once you log in to our Website, all third party analytics and tracking ceases.

    When you visit our Website and are not logged in, these analytics service providers may collect the following data, which will almost always be anonymised and aggregated before reporting back to us:

    • number of visitors to our Website
    • pages visited while at the Website and time spent per page
    • page interaction information, such as scrolling, clicks and browsing methods
    • websites where visitors have come from and where they go afterwards
    • page response times and any download errors
    • other technical information relating to end user device, such as IP address or browser plug-in

    We process this information to understand how visitors use our Website and to compile statistical reports regarding that activity (for example, your IP address is used to approximate the country from which you access our Website, and we aggregate this information together so we know that, for example, most of the visitors to our Website come from England).

    This processing is crucial to the running of our online business and we therefore undertake such monitoring in the pursuit of our legitimate interests in improving our Website to provide a better service and source of information to visitors.

    This information is not used to develop a personal profile of you.

4. YOUR RIGHTS

You have the following rights over the way we process personal data relating to you. We aim to comply without undue delay, and within one month at the latest:

  • to ask for a copy of data we are processing about you and have inaccuracies corrected;
  • to ask us to restrict, stop processing, or to delete your personal data;
  • to request a machine readable copy of your personal data, which you can use with another service provider. Where it is technically feasible, you can ask us to send this information directly to another provider if you prefer; and
  • to make a complaint to a data protection regulator. You may contact them at: https://ico.org.uk/concerns/

To make a request in relation to any of the aforementioned rights, please email us at support@finda.co.

If you are unhappy with the way that we are processing your personal data, please let us know. The best way to bring this to our attention is by emailing us at support@finda.co.

5. CHILDREN

Our services are for the provision of adult modelling talent only. FINDA.co does not presently register child models or models under the age of 18.

We do not knowingly use the Website to solicit data from or market to children under the age of 13.

If a parent or guardian becomes aware that his or her child has provided us with information or may be receiving communications from us without consent of a parent or guardian, we ask that this be brought to our immediate attention. We will make it our priority to address this situation and delete information relating to a child as soon as practicable. In such an event, please contact us at support@finda.co.

6. SECURITY

We will take commercially reasonable, appropriate technical and organisational measures to ensure a level of security appropriate to the risk that could be encountered via the use of our Website and services, taking into account the likelihood and severity those risks might pose to the rights and freedoms of our Website visitors.

In particular, we will take precautions to protect against the accidental or unlawful destruction, loss or alteration, and unauthorised disclosure of or access to the personal information transmitted, stored or otherwise processed by us. Please be aware that, while we make the security of our Website and your personal information a high priority and devote considerable time and resources to maintain robust IT security, no security system can prevent all security breaches. When you choose to share your personal information with us, you accept the aforesaid and provide your information at your own risk.

Safety of Credit card Information

FINDA does not collect, store or process any credit card information used for payments made on the FINDA website. This process is handled by Stripe, which includes providing and managing the payment popup that appears on the FINDA Website.

7. RETENTION

In accordance with data protection laws and good commercial practice, we do not retain data in a form that permits identification of the person(s) to whom it relates for any longer than is necessary. Once the purpose for which information has been collected has been fulfilled, we will either permanently delete your personal information or remove all identifiers within it so that it is no longer personal data. We may use such anonymised data for research and/or business analysis purposes.

If you would like us to stop using your personal information, please email us at support@finda.co.

8. INTERNATIONAL DATA TRANSFERS

Our servers are located in the European Union and the information that we collect directly from you will be stored in these servers. We may also transfer your personal data to our third party service providers, many of whom may be located outside of the EU, operate from multiple locations including non-EU based operations or engage sub-processors located outside the EU.

There are agreements in place to ensure that any international transfers of personal data to our affiliates or third party service providers have appropriate safeguards that meet the requirements of EU data protection laws.

If you would like to find out more about these safeguards or if you have any other queries or comments in relation to this policy, please let us know by emailing us at support@finda.co.

9. CHANGES TO THIS POLICY

This privacy policy may be updated from time to time. We will notify you of any changes to our privacy policy by posting the new privacy policy on our Website. You are advised to consult this privacy policy webpage regularly for any changes.

10. CONTACT US

Questions, comments and requests in relation to this privacy policy are welcome and should be addressed to support@finda.co.

Alternatively, you may address these to our Data Protection Officer by emailing martine@finda.co or kat@finda.co.