Privacy Policy

1. Introduction

Serenity Models FZ-LLC ("we", "us", "our"), with registered office at La Mer South, Building 4, Jumeirah 1, Dubai, UAE, and Trade License No. 1234567, is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information in accordance with UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data ("PDPL") and applicable UAE data protection regulations.

2. Data Controller

The data controller responsible for processing your personal data is:

• Company: Serenity Models FZ-LLC
• Address: La Mer South, Building 4, Jumeirah 1, Dubai, UAE
• Email: [email protected]
• Phone: +971 4 553 1234
• Data Protection Officer: [email protected]

3. Data We Collect

We may collect and process the following categories of personal data:

3.1 Information You Provide

• Contact Information: Name, email address, phone number, postal address.
• Professional Information: Portfolio images, measurements, experience, agency history (for model applicants).
• Account Information: Login credentials, preferences, communication history.
• Payment Information: Bank details, billing address, transaction records.
• Communication Data: Emails, form submissions, chat messages, feedback.

3.2 Automatically Collected Data

• Device Information: IP address, browser type and version, operating system, device identifiers.
• Usage Data: Pages visited, time spent, click patterns, referral source.
• Cookie Data: As detailed in our Cookie Policy.
• Location Data: Approximate geographic location derived from IP address.

4. Legal Basis for Processing

We process your personal data on the following legal bases under the UAE PDPL:

• Consent: Where you have given explicit consent, such as subscribing to our newsletter or submitting a model application.
• Contractual Necessity: Where processing is necessary to perform a contract with you, such as a booking agreement or talent representation contract.
• Legitimate Interest: Where processing is necessary for our legitimate business interests, such as improving our services, marketing analytics, and fraud prevention.
• Legal Obligation: Where processing is required to comply with UAE law, including tax and accounting obligations.

5. How We Use Your Data

We use the collected data for the following purposes:

• To provide and manage our talent agency services
• To process bookings, contracts, and payments
• To evaluate model applications and manage talent portfolios
• To communicate with you regarding inquiries, bookings, and updates
• To send marketing communications (with your consent)
• To improve our website, services, and user experience
• To comply with legal and regulatory obligations
• To protect against fraud and ensure security

6. Data Sharing

We may share your personal data with:

• Clients and Partners: Model portfolios and contact details shared with potential booking clients (for represented talent only, with consent).
• Service Providers: Hosting providers, payment processors, email services, and analytics tools that help us operate our business.
• Legal Authorities: When required by law, regulation, or legal proceedings.
• Professional Advisors: Accountants, lawyers, and auditors as necessary.

We do not sell your personal data to third parties.

7. International Transfers

Your data may be transferred to countries outside the United Arab Emirates. When such transfers occur, we ensure appropriate safeguards are in place, including standard contractual clauses and transfers only to jurisdictions that provide an adequate level of data protection, in line with the UAE PDPL.

8. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected:

• Client and booking data: Duration of the business relationship plus 5 years (UAE tax and accounting law).
• Model applications (not selected): 12 months from submission, then deleted.
• Newsletter subscribers: Until consent is withdrawn.
• Website analytics: 26 months (anonymized after this period).
• Contractual records: 5 years from contract termination (UAE commercial law).

9. Your Rights

Under the UAE PDPL, you have the following rights:

• Right of Access: Request a copy of the personal data we hold about you.
• Right to Rectification: Request correction of inaccurate or incomplete data.
• Right to Erasure: Request deletion of your personal data ("right to be forgotten").
• Right to Restriction: Request limitation of processing in certain circumstances.
• Right to Data Portability: Receive your data in a structured, machine-readable format.
• Right to Object: Object to processing based on legitimate interest or direct marketing.
• Right to Withdraw Consent: Withdraw consent at any time without affecting prior processing.

To exercise your rights, contact us at [email protected]. We will respond within 30 days. You also have the right to lodge a complaint with the UAE Data Office at www.uaedataoffice.gov.ae.

10. Security Measures

We implement appropriate technical and organizational measures to protect your personal data, including:

• SSL/TLS encryption for data in transit
• Encrypted storage for sensitive data at rest
• Access controls and authentication requirements
• Regular security audits and vulnerability assessments
• Staff training on data protection practices
• Incident response and breach notification procedures

11. Children's Privacy

Our services are not directed to individuals under the age of 16. We do not knowingly collect personal data from children under 16 without parental consent. If we become aware that we have collected data from a child under 16 without verified parental consent, we will take steps to delete that information promptly.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the updated policy on this page with a revised "Last updated" date. We encourage you to review this policy periodically.

13. Contact

For any questions or concerns regarding this Privacy Policy or our data processing practices, please contact:

Serenity Models FZ-LLC
Data Protection Officer
La Mer South, Building 4, Jumeirah 1, Dubai, UAE
Email: [email protected]
Phone: +971 4 553 1234