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FEDOREM Ltd

– Privacy Policy –

Fedorem Ltd respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. This privacy notice is provided in a layered format so you can get through to the specific areas set out below. You can go to the Glossary on paragraph 9. to understand the meaning of some of the terms used in this privacy notice.

IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY NOTICE This privacy notice aims to give you information on how Fedorem Ltd collects and processes your personal data through your use of this website, including any data you may provide through this website when filling in the form to join us as a prospective talent or services company. CONTROLLER Fedorem Limited is the controller and responsible for your personal data and this website. This privacy notice is issued on behalf of Fedorem Ltd so when we mention Fedorem, Fedorem Ltd, Fedorem Limited, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company responsible for processing your data. If you have any question about this privacy notice, including any request to exercise your legal rights, please email us at info@fedorem.com typing “GDPR” in the object field. CONTACT DETAILS Find the full company details below, Full name of legal entity: Fedorem Limited Email address: info@fedorem.com Postal address: 25th Floor, Workington Tower 78 Bonham Strand, Sheung Wan, Hong Kong CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES This version was last updated on 13/10/2019 It is important that the personal data we hold about you are accurate and current. Please keep us informed if your personal data changes during your relationship with us. THIRD-PARTIES Unless you informations are made public, we do not forward them without your prior consentment. Be informed this website might be featured on third party websites to the purpose of its promotion but your personal data won’t be disclosed unless you are being asked.

THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follow:

Identity Data includes first name, last name, gender, date of birth, nationality, location.
Contact Data includes email address, telephone number, social network accounts.
Profile Data includes models’ measurements, attributes, book pictures, résumé, skills and experience for proposing your services as a talented individual or company.
Financial Data includes bank account details.
Transaction Data includes details about payments to and from you.
Technical Data includes internet protocol (IP) address, your browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

We do not collect any Special Categories of Personal Data about you such as religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic or biometric data through this web-site. Nor do we collect any information about criminal convictions and offences. IF YOU FAIL TO PROVIDE PERSONAL DATA Where we need to collect personal data under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for instance the birthdate towards age verification). In this case, we may have to cancel a service you have with us yet you will be notified if this is the case at the time.

HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact by filling in forms or by corresponding with us by post, direct messages, phone, email or otherwise.

This includes personal data you provide when you:

apply for our services as talent;
request our services as client;
give us some feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using server logs and other similar technologies.

Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
Technical Data from analytics providers such as Google based outside the EU;

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using them. Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new client	(1) Identity (2) Contact	Performance of a contract with you
To register you as a talent	(1) Identity (2) Contact	Performance of a contract with you
To process and deliver our services including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(1) Identity (2) Contact (3) Financial (4) Transaction	(1) Performance of a contract with you (2) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you such as notifying you about changes to our terms or privacy policy	(1) Identity (2) Contact (3) Profile	(1) Performance of a contract with you (2) Necessary to comply with a legal obligation (3) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(1) Identity (2) Contact (3) Technical	(1) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (2) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(1) Technical (2) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(1) Identity (2) Contact (3) Technical (4) Usage (5) Profile	Necessary for our legitimate interests (to develop our products/services and grow our business)

COOKIES You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. All parts of this website will remain accessible and function properly. At time of writing we use cookies for all page. CHANGE OF PURPOSE We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please email us at info@fedorem.com

DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below.

Internal Third Parties as set out later in this document.
External Third Parties as set out later in this document.
Specific third parties.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

INTERNATIONAL TRANSFERS

We share your personal data within Fedorem Ltd. However, this may involve transferring your data outside the European Economic Area in order to conduct normal business with you or through you. We will ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. At time of writing, our external third parties may be based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR? We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. OR By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. In some circumstances you can ask us to delete your data (see below).

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You may request access to your personal data
You may request that your personal data be corrected
You may request erasure of your personal data
You may object to the processing of your personal data
You may Request restriction of processing your personal data
You may Request transfer of your personal data
You may withdraw consent for us to hold your personal data

If you wish to exercise any of the rights set out above, please email info@fedorem.com WHAT WE MAY NEED FROM YOU We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. TIME LIMIT TO RESPOND We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

GLOSSARY

LAWFUL BASIS Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to. THIRD PARTIES INTERNAL THIRD PARTIES Other companies in Fedorem Limited and providing IT and system administration services and undertake leadership reporting. EXTERNAL THIRD PARTIES

Service providers (acting as processors) based in the EEA or USA who provide IT and system administration services.
Professional advisers including lawyers, bankers, auditors and insurers (acting as processors) based in the EEA and USA who provide consultancy, banking, legal, insurance and accounting services.

YOUR LEGAL RIGHTS You have the right to: Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.