1. WHO THIS NOTICE IS FOR
 
This notice applies if you are in the European Economic Area, the United Kingdom, or Switzerland and you visit www.themodelclub.net, register as a model or a brand, join a membership, book a service, or take part in our community.
 
It sits alongside our Privacy Policy and our Cookie Policy. Where this notice and the Privacy Policy differ, this notice applies to you.
 
2. WHO THE CONTROLLER IS
 
The Model Club, operated by The Mr. Coleman Group, is the controller of your personal data.
 
Email: info@themodelclub.net
Website: www.themodelclub.net
 
We have not appointed a Data Protection Officer, because we are not required to. Requests and questions should go to the address above and will be handled by our team directly.
 
3. WHAT PERSONAL DATA WE PROCESS
 
Identity and contact data: your name, email address, phone number, city and country, and account credentials.
 
Profile and comp card data: photographs, digitals, and portfolio images; height, measurements, and sizes; your date of birth or age; social media handles; the market you work in; and your experience and availability.
 
Brand and partner data: contact name, company or brand name, industry, email address, phone number, location, and website.
 
Transaction data: the membership plan you hold, billing history, invoices, and booking records. Card details are handled by our payment providers, not stored by us.
 
Communications data: your emails, form submissions, enquiries, and our replies.
 
Community data: messages and content you post in our channels, workshops, and events.
 
Technical data: IP address, browser and device type, operating system, referring page, pages viewed, and timestamps, collected through cookies and similar technologies.
 
We do not seek to process special category data. Photographs are not biometric data as we use them, because we do not run facial recognition or any other technique intended to uniquely identify you from them.
 
4. WHY WE PROCESS IT, AND ON WHAT LEGAL BASIS
 
To create and run your member account and profile - performance of a contract (Article 6(1)(b)).
 
To produce comp cards, directory listings, and the materials in your tier - performance of a contract.
 
To deliver workshops, mentorship, events, and bookings you have signed up for - performance of a contract.
 
To take payment, issue invoices, and manage renewals - performance of a contract, and legal obligation for tax and accounting records (Article 6(1)(c)).
 
To present you to brand partners in connection with an opportunity - performance of a contract where it is part of your tier, and your consent (Article 6(1)(a)) where we ask you about a specific opportunity.
 
To use your image in our public marketing - your consent.
 
To send newsletters, casting announcements, and marketing by email, SMS, or community channels - your consent, or our legitimate interests where you are an existing member and the message relates to what you have already bought (Article 6(1)(f)).
 
To keep the Site and community secure, prevent fraud and abuse, and diagnose faults - our legitimate interests in protecting our members and our service.
 
To measure and improve how the Site performs - your consent for non-essential cookies, and otherwise our legitimate interests.
 
To establish, exercise, or defend legal claims and to comply with the law - our legitimate interests and legal obligation.
 
Where we rely on legitimate interests, we have considered whether our interest is overridden by your rights, and we will share that assessment with you on request.
 
5. WHERE THE DATA COMES FROM
 
Almost all of it comes from you. We also receive confirmation of payment outcomes from our payment providers, interaction data from social platforms when you engage with our accounts, information from brand partners in connection with an opportunity, and referrals from other members.
 
6. WHO WE SHARE IT WITH
 
Processors acting on our instructions: our website platform and host, and our email, scheduling, forms, invoicing, and payment providers.
 
Brand partners and clients, where you have applied for or agreed to an opportunity, or where you hold a directory listing.
 
Collaborators delivering a session you are attending, such as photographers, educators, and venues.
 
Professional advisers, and authorities where the law requires it.
 
An acquirer, if the business is sold or reorganised.
 
We do not sell personal data and we do not use it for cross-context behavioural advertising.
 
7. INTERNATIONAL TRANSFERS
 
We are established in the United States, so your personal data is transferred outside the EEA and the UK.
 
Where we make such a transfer, we rely on appropriate safeguards under Chapter V of the GDPR, principally the European Commission's Standard Contractual Clauses together with the UK International Data Transfer Addendum, supported by a transfer risk assessment and, where relevant, our providers' certification under the EU-US Data Privacy Framework. You may request a copy of the safeguards we rely on.
 
8. HOW LONG WE KEEP IT
 
Account, profile, and portfolio data: for the life of your membership, then deleted or anonymised within a reasonable period after closure, or sooner on request.
 
Payment and invoicing records: for the period required by tax and accounting law.
 
Marketing contacts and consent records: until you withdraw consent, plus a short period to evidence the withdrawal.
 
Community content: for as long as the channel or record is kept, subject to your deletion request.
 
Technical and cookie data: for the lifetimes set out in the Cookie Policy.
 
Backups are overwritten on a rolling schedule.
 
9. YOUR RIGHTS
 
You have the right to:
 
Be informed about how we use your personal data, which is what this notice and the Privacy Policy do.
Access a copy of the personal data we hold about you.
Rectify data that is inaccurate or incomplete.
Erase your data where one of the grounds in Article 17 applies.
Restrict processing while a dispute about accuracy or legitimate interests is resolved.
Data portability, for data you gave us that we process by consent or contract, in a structured, commonly used, machine-readable format.
Object to processing based on legitimate interests, and an absolute right to object to direct marketing at any time.
Not be subject to a decision based solely on automated processing that produces legal or similarly significant effects. We do not carry out such decision-making or profiling.
Withdraw consent at any time, without affecting the lawfulness of processing before withdrawal.
 
10. HOW TO EXERCISE THEM
 
Email info@themodelclub.net and tell us which right you wish to exercise. You can also unsubscribe from marketing email using the link in any message, reply STOP to text messages, and change your cookie preferences from the banner or your browser settings.
 
We respond within one month. If your request is complex or you have made several, we may extend by up to two further months and will tell you why within the first month. There is no charge unless a request is manifestly unfounded or excessive.
 
We may ask for information to confirm your identity before we act, and we will only ask for what is needed to be sure.
 
11. IF YOU ARE NOT SATISFIED
 
Please come to us first at info@themodelclub.net so we can put it right.
 
You also have the right to complain to a supervisory authority. In the EEA this is the authority in the country where you live, work, or where the issue arose, and the full list is published by the European Data Protection Board. In the UK it is the Information Commissioner's Office at ico.org.uk. In Switzerland it is the Federal Data Protection and Information Commissioner.
 
12. CHANGES TO THIS NOTICE
 
We may update this notice as our services and the law change. We will revise the effective date and version number at the top of this page and, where the change is material, tell you through the Site, by email, or by other reasonable means.
 
13. CONTACT
 
The Model Club
Email: info@themodelclub.net
Website: www.themodelclub.net