Privacy Policy

Introduction

This Privacy Policy explains how Models Cyprus collects, uses, shares, stores and protects personal data when individuals visit our website, create a profile, purchase a membership, apply for opportunities, participate in bookings or otherwise use our services.

Models Cyprus is operated by CREATEAGENCY LTD, which is the data controller responsible for the processing described in this Privacy Policy.

This Privacy Policy applies to models, junior models and their parents or legal guardians, creatives, clients, website visitors and other individuals who interact with Models Cyprus.

Use of the Models Cyprus platform is also subject to our Terms & Conditions.

This Privacy Policy is a transparency notice. It does not rely on an individual simply agreeing to the policy. Where consent is legally required, we will request it separately through an appropriate affirmative action.

We process personal data in accordance with the General Data Protection Regulation (EU) 2016/679, the Cyprus Law Providing for the Protection of Natural Persons with regard to the Processing of Personal Data and for the Free Movement of Such Data of 2018, Law 125(I)/2018, and other applicable data-protection legislation.

Data Controller

The data controller is:

Questions or requests concerning personal data may be sent to the email address above.

Our Data-Protection Commitments

We aim to ensure that personal data is:

• Processed lawfully, fairly and transparently;
• Collected for specific, explicit and legitimate purposes;
• Limited to what is reasonably necessary;
• Accurate and kept up to date where required;
• Retained only for as long as reasonably necessary;
• Protected against unauthorised access, loss, misuse or disclosure; and
• Processed in a manner that respects individuals’ legal rights.

Personal Data We Collect

The personal data collected depends on how an individual interacts with Models Cyprus.

4.1 Contact and Communication Information

We may collect:

• Name and surname;
• Email address;
• Telephone or WhatsApp number;
• Company or brand name;
• Social media username;
• Subject of the enquiry;
• Message content;
• Communication history; and
• Any information voluntarily provided during communications.

4.2 Account and Membership Information

We may collect:

• Name and surname;
• Email address;
• Telephone number;
• Account login and security information;
• Membership plan;
• Subscription status;
• Payment and renewal history;
• Account preferences;
• Acceptance records for our Terms & Conditions and policies; and
• Date, time and technical records relating to registration or acceptance.

4.3 Model Profile and Portfolio Information

We may collect and publish information supplied for a model profile, including:

• Professional or display name;
• Age or age range;
• Date of birth where required for verification;
• Gender or model category;
• General location or city;
• Nationality, languages and relevant experience;
• Height and professional modelling measurements;
• Clothing and shoe sizes;
• Hair and eye colour;
• Skills, interests and model categories;
• Portfolio photographs, videos and showreels;
• Social media links;
• Availability; and
• Other information voluntarily submitted for the profile.

Models should not provide unnecessary sensitive information or personal contact details for public display.

Published model profiles may be accessible to website visitors, search engines, brands, agencies, photographers, production companies and other potential clients.

4.4 Junior-Model and Guardian Information

Where a model is under 18, we may collect:

• The junior model’s name, age or date of birth;
• Portfolio and profile information;
• Parent or legal guardian’s name;
• Parent or legal guardian’s contact details;
• Evidence of parental responsibility or authority where required;
• Guardian approvals and consent records; and
• Booking, supervision and safeguarding information.

A junior model’s account, profile and bookings must be managed or approved by a parent or legal guardian.

4.5 Casting, Booking and Availability Information

We may collect:

• Casting applications;
• Availability;
• Client selections and shortlists;
• Booking dates, times and locations;
• Rates, fees and approved expenses;
• Wardrobe, styling and production requirements;
• Travel and accommodation information;
• Booking confirmations;
• Cancellation records;
• Attendance information;
• Communications between Models Cyprus, the model and the client; and
• Feedback, complaints and dispute information.

4.6 Commercial Usage Rights and Photoshoot Content

We may collect and process:

• Portfolio images and videos;
• Photographs, videos, audio and other content created during bookings;
• Content release forms;
• Model release forms;
• Commercial usage rights agreements;
• Model and guardian approvals;
• Agreed usage duration;
• Media and advertising platforms;
• Geographical territory;
• Exclusivity arrangements;
• Perpetual usage or full-buyout approvals;
• Commercial Usage Fees and renewal fees; and
• Records concerning usage extensions, infringements or disputes.

Commercial content will only be used or licensed in accordance with our Terms & Conditions, the relevant booking terms, Commercial Usage Rights Policy, Content Release and Usage Agreement, or another recorded written approval.

4.7 Payment, Invoicing and Commission Information

We may collect:

• Billing name and address;
• Invoice details;
• Subscription and booking payment records;
• Commission calculations;
• Commercial Usage Fee records;
• Bank or payment details required to remit funds;
• Transaction references;
• VAT and tax-related information; and
• Records of refunds, failed payments or payment disputes.

Payment-card information is generally processed directly by our payment provider. Models Cyprus does not normally receive or store complete payment-card details.

4.8 Website, Device and Analytics Information

When the website is used, we may collect:

• IP address;
• Device and browser type;
• Operating system;
• Approximate location derived from an IP address;
• Pages viewed;
• Referring website;
• Date, time and duration of visits;
• Website interactions;
• Cookie identifiers; and
• Technical and security logs.

Non-essential analytics and advertising technologies are used only where the required consent has been obtained.

4.9 Required Information and Consequences

Where information is required to enter into or perform a contract, complete a booking, meet a legal obligation or protect a junior model, we will identify it as required. If that information is not provided, we may be unable to create or maintain a profile, process a payment, assess an application or arrange a booking.

How We Collect Personal Data

We may collect personal data:

• Directly from the individual;
• From a parent or legal guardian;
• Through registration, membership, contact, casting and booking forms;
• Through email, telephone, WhatsApp or social media communications;
• From clients, photographers, production companies or booking partners;
• From payment and subscription providers;
• From website analytics and cookie technologies;
• From publicly available professional profiles or social media pages; and
• From another person authorised to provide the information.

Where someone provides personal data concerning another person, they must have the authority to do so and should ensure that the individual is informed about this Privacy Policy.

Where we obtain personal data indirectly, we will provide the information required by law within the applicable period, unless a lawful exception applies.

Why We Process Personal Data

We may process personal data for the following purposes:

• Responding to enquiries;
• Creating and administering accounts;
• Providing and managing memberships;
• Reviewing, creating and publishing model profiles;
• Promoting models and the Models Cyprus platform;
• Sending relevant casting and booking opportunities;
• Processing applications and availability;
• Facilitating and coordinating bookings;
• Communicating with models, guardians, creatives and clients;
• Preparing quotations, agreements and booking confirmations;
• Obtaining and recording booking and usage approvals;
• Administering Commercial Usage Rights;
• Issuing invoices and processing payments;
• Calculating, collecting and administering commissions;
• Paying amounts due to models;
• Managing subscriptions, renewals and cancellations;
• Maintaining accounting, tax and business records;
• Providing customer support;
• Managing complaints, cancellations and disputes;
• Detecting fraud, misuse and attempts to circumvent platform fees;
• Protecting the security and operation of the website;
• Measuring and improving website performance;
• Sending marketing communications where permitted;
• Establishing, exercising or defending legal claims; and
• Complying with legal and regulatory obligations.

Legal Bases for Processing

We rely on one or more of the following legal bases.

7.1 Performance of a Contract

We process personal data where necessary to:

• Create and administer a membership;
• Provide a model profile;
• Facilitate an application or booking;
• Administer payments and commissions;
• Manage Commercial Usage Rights; or
• Perform another agreement with the individual.

This also applies when taking steps at an individual’s request before entering into a contract.

7.2 Legal Obligations

We process certain information where necessary to comply with legal obligations, including accounting, taxation, fraud-prevention, regulatory and data-protection requirements.

7.3 Legitimate Interests

We may process personal data where necessary for our legitimate interests or those of a third party, provided those interests are not overridden by the individual’s rights.

These interests may include:

• Operating and improving Models Cyprus;
• Promoting active model profiles;
• Coordinating professional opportunities;
• Maintaining platform security;
• Preventing fraud and commission circumvention;
• Maintaining appropriate business records;
• Communicating with existing users and clients;
• Managing disputes; and
• Establishing, exercising or defending legal claims.

Individuals may object to processing based on legitimate interests in certain circumstances.

7.4 Consent

We rely on consent where required, including for:

• Non-essential cookies;
• Certain analytics and advertising technologies;
• Optional marketing communications;
• Particular promotional uses outside the agreed service;
• Processing specific sensitive information where explicit consent is required; and
• Certain uses of junior-model information where parental or guardian consent is required.

Consent may be withdrawn at any time. Withdrawal does not affect processing that was lawful before consent was withdrawn.

Withdrawal of data-protection consent does not automatically cancel an existing booking, payment obligation or valid commercial usage licence where another lawful basis applies.

7.5 Legal Claims and Substantial Legal Interests

Where necessary and legally permitted, information may be processed to establish, exercise or defend legal claims or protect the safety and legal rights of individuals.

Special Categories of Personal Data

Models Cyprus does not normally request special-category personal data such as medical information, racial or ethnic origin, religious beliefs, sexual orientation or biometric information used for identification.

A model or guardian should not provide this information unless it is genuinely necessary for a booking, accessibility requirement or safety purpose.

Where special-category information is required, we will identify an appropriate legal basis and, where necessary, request explicit consent.

Portfolio photographs and videos are personal data but will not ordinarily be treated as biometric data unless they are technically processed for the purpose of uniquely identifying an individual.

Public Profiles and Sharing With Clients

Information submitted for a published model profile may be publicly accessible through the Models Cyprus website and may appear in search-engine results.

We may share relevant profile, availability and booking information with potential or confirmed clients, including:

• Brands;
• Marketing and advertising agencies;
• Photographers and videographers;
• Production companies;
• Event organisers;
• Hotels and venues;
• Casting professionals; and
• Other parties involved in the relevant opportunity.

We will aim to share only the information reasonably necessary for the profile, casting or booking.

Personal contact, identification, payment or sensitive information will not normally be published as part of a model profile.

Clients receiving personal data may act as independent data controllers for their own processing and may be required to provide their own privacy information.

If a public profile is removed, cached copies or search-engine results may remain temporarily outside our direct control. Where required, we will take reasonable steps within our control to support removal or correction.

Service Providers and Other Recipients

We may share personal data with trusted service providers where reasonably necessary, including:

• Website hosting and technical-support providers;
• Payment and subscription providers;
• Email, messaging and communications providers;
• Customer relationship management and form providers;
• Cloud storage and document-management providers;
• Website security and fraud-prevention providers;
• Analytics providers, including Google Analytics where consent applies;
• Advertising providers, including Meta where consent applies;
• Accountants, auditors, insurers and professional advisers;
• Lawyers and debt-recovery providers;
• Government, tax, regulatory or law-enforcement authorities where legally required; and
• A purchaser, investor or successor where CREATEAGENCY LTD undergoes a genuine business sale, restructuring or transfer.

Service providers are permitted to process personal data only for the relevant services and must provide appropriate protection. Data-processing agreements are implemented where required by law.

We do not sell personal data.

International Data Transfers

Some service providers may process or store personal data outside Cyprus or the European Economic Area.

Where personal data is transferred outside the EEA, we will use an appropriate legal safeguard where required, such as:

• A European Commission adequacy decision;
• European Commission Standard Contractual Clauses;
• Additional contractual, organisational or technical safeguards; or
• Another legally recognised transfer mechanism.

Information about the applicable transfer safeguards may be requested by contacting us.

Data Retention

We retain personal data only for as long as reasonably necessary for the relevant purpose.

Our general retention periods are:

• Enquiries and general correspondence: normally up to 24 months after the last meaningful communication;
• Active account and membership information: for the duration of the account or membership;
• Profile and portfolio information: while the profile is active and normally for up to 12 months after account closure;
• Unsuccessful casting applications: normally up to 24 months after the relevant opportunity;
• Booking records, agreements, approvals and payment records: normally for up to six years after completion or payment;
• Commercial usage agreements and model releases: for the duration of the applicable licence and for a reasonable period afterwards where required to document, administer or defend the authorised usage;
• Invoices, commission records and accounting information: for the period required by applicable tax, accounting and legal obligations;
• Complaint, dispute and legal-claim information: until the matter has been resolved and any applicable legal period has expired;
• Marketing information: until consent is withdrawn or the individual unsubscribes, subject to retaining a minimal suppression record where necessary;
• Cookie and analytics information: for the periods stated in our Cookie Policy; and
• Security and technical logs: for a reasonable period based on security and operational requirements.

Information may be retained for longer where required by law, necessary for legal proceedings or reasonably required to establish or defend a legal claim.

Information contained in secure backups may remain temporarily until the relevant backup is overwritten or securely deleted.

Data Security

We use appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.

These measures may include:

• Access controls and account permissions;
• Password protection;
• Secure hosting and encrypted communications;
• Restricted staff access;
• Security monitoring;
• Software and system updates;
• Secure payment providers;
• Backups; and
• Procedures for responding to suspected data breaches.

No online service can guarantee absolute security. Users are responsible for maintaining the confidentiality of their login details and for notifying us of any suspected unauthorised account access.

Where a personal-data breach creates a legal notification obligation, we will notify the Office of the Commissioner for Personal Data Protection and affected individuals as required.

Cookies and Similar Technologies

We use cookies and similar technologies for:

• Essential website functionality;
• Security;
• Remembering preferences;
• Membership and account functionality;
• Analytics;
• Website improvement; and
• Advertising or campaign measurement where consent has been provided.

Essential cookies may operate without consent where they are strictly necessary.

Non-essential analytics, advertising and tracking cookies will be activated only after the user provides the required consent.

Users can accept, reject or manage non-essential cookies through the website’s cookie-consent tool. Consent can be changed or withdrawn at any time.

More information, including the cookies used and their retention periods, is available in our Cookie Policy.

Marketing Communications

We may send marketing emails, platform news, casting alerts or promotional communications where:

• The individual has provided consent;
• The communication is permitted under applicable law; or
• The communication concerns an existing membership or service and the individual has not opted out.

Marketing preferences can be changed at any time by:

• Selecting the unsubscribe link in an email;
• Adjusting available account preferences; or
• Contacting info@modelscyprus.com.

Important administrative, security, subscription and booking messages are not considered marketing and may still be sent where necessary.

Individual Rights

Subject to the conditions and limitations of applicable law, individuals have the following rights:

• Right to be informed about how personal data is processed;
• Right to request access to personal data;
• Right to request correction of inaccurate or incomplete information;
• Right to request erasure of personal data;
• Right to request restriction of processing;
• Right to receive certain personal data in a structured, commonly used and machine-readable format;
• Right to object to processing based on legitimate interests;
• Absolute right to object to direct marketing;
• Right to withdraw consent at any time;
• Right not to be subject to a solely automated decision that produces legal or similarly significant effects; and
• Right to lodge a complaint with a supervisory authority.

These rights are not absolute. For example, we may need to retain certain information to comply with legal obligations, document an existing usage licence, collect an outstanding payment or establish or defend a legal claim.

Exercising Data-Protection Rights

Requests may be submitted to:

info@modelscyprus.com

The request should provide sufficient information for us to identify the relevant individual and understand the request.

We may request reasonable proof of identity before providing, correcting or deleting personal data.

We will respond without undue delay and normally within one month of receiving the request. Where a request is particularly complex or numerous, this period may be extended by up to two additional months. We will notify the individual if an extension is necessary.

Requests are normally handled free of charge. A reasonable fee may be charged, or a request may be refused, where permitted by law and where it is manifestly unfounded or excessive.

If we do not take action on a request, we will explain the reasons without delay and normally within one month, and provide information about the right to lodge a complaint and seek a judicial remedy.

Automated Decision-Making

Models Cyprus does not currently use solely automated decision-making that produces legal or similarly significant effects concerning users.

The website may use filters, sorting or membership features to determine profile placement, visibility or the opportunities displayed. These functions do not independently make legally significant decisions about an individual.

If this position changes, this Privacy Policy will be updated and the required information and safeguards will be provided.

External Links and Third-Party Platforms

The website may contain links to social media platforms, payment providers, client websites and other third-party services.

These parties operate under their own privacy policies and may act as independent data controllers. Models Cyprus is not responsible for their independent privacy practices.

Users should review the privacy policy of any third-party service before submitting personal data.

Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes to our services, technology, processing activities or legal obligations.

The latest version will be published on this page with a revised “Last updated” date.

Where a change materially affects individuals or requires renewed consent, we will provide an appropriate notice or request new consent where required.

Complaints

Individuals are encouraged to contact us first so that we can attempt to resolve any privacy concern.

Individuals also have the right to lodge a complaint with:

The Commissioner’s website provides current contact details and instructions for submitting a complaint.

Contact Details

Models Cyprus is operated by: