Privacy Notice
This notice describes how we use your personal information.
This Privacy Notice last changed on 24 May 2018
We are AVANT MODELS, a division of International Management Group (MOSCOW, POLAND, GERMANY) Limited, and its affiliates (“AVANT MODELS”) and respect your privacy.
We take our obligations under applicable law seriously. We respect your privacy and value the trust you place in us when you share your personal information with us. This Privacy Policy sets out how we collect, hold, use, process and disclose your personal information, why and with what legal reasoning we process it, with whom and for what purposes we share it, the rights to which you may be entitled and your choices about our use of your personal information.
Your personal information is collected by AVANT MODELS Limited and its affiliates (“we”/”us”/”our”).
Contact details are as follows:
If you have questions, please contact:
E-mail: accounting@avantmanagement.net
Post: Obozowa 20 street, 107 apt. 01-161 Warsaw, Poland
Data collection and usage
We will collect store and use your personal information
a) to conduct our business;
b) to allow access to this website, register / subscribe / buy / use our products and services;
c) to meet our legal obligations;
d) to fulfil any purpose we make known to you when we collect your personal information; and
e) to fulfil other purposes set out in more detail in this section.
Certain types of personal information are more sensitive than others. “Special information” about you includes information about health, disability, race, ethnicity, or biometrics. We may collect and receive special information about you.
We have identified here the types of information we may collect or receive, how we will use it and why we will use it.
What information we collect
We collect your personal information in a number of ways:
• when you set up a user account;
• when you subscribe to email updates, newsletters or other subscriptions and features made available on our website from time to time; and
• when you participate in our contests, promotions, sweepstakes, surveys or live voting features on our website.
Specifically, we collect personal information you give us such as your name, address, social media account details, e-mail address, password, account settings and preferences.
We also collect your information when you attend or register to attend one of our events.
Specifically, we collect personal information you give us such as your name, address, e-mail address. We may also collect your photograph, audio and video records, and your date of birth.
We collect your contact details, photos and other information when you make an application to us to become a Model.
Information about the way you use our services:
the content that you have viewed and/or purchased;
• the things that we’ve provided, or you’ve purchased;
• when and where you have accessed content and/or made the purchases (including where information can be identified from your IP address);
• what you paid and how;
• whether you’ve opened
electronic communications
from us;
• whether you’ve clicked on
links in electronic
communications from us;
your marketing preferences.
Information when you communicate with us whether in person, through our website, Apps or via email, over the phone, through social media or via any other medium, including:
your contact details (this may include your social media account if that’s the way you communicate with us);
• the details of your communications with us (including when you sent it, when we received it and where you sent it from (such as our website, Apps, via email, through social media)); and
• the details of our messages to you.
Information that we collect through your use of the website:
• technical information, including IP address, login information, browser type and version (e.g., Internet Explorer, Firefox, Safari, etc.), time zone setting, browser plug-in types and versions, operating system you are using (e.g., Vista, Windows XP, Mac OS, etc.), platform, device type, hardware model, MAC address, unique device identifiers and mobile network information;
• information about your visit, including the full URL clickstream to, through and from our website (including date and time);
• information about your network, such as information about devices, nodes, configurations, connection speeds, and network and application performance; and
• pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse- overs), and methods used to browse away from the page.
Information that we collect from third party partners and corporate customers which includes:
• payment processing companies;
• your employer, contractor, agent;
• your bank;
• other entities in our group;
and
• publicly available sources
such as the electoral roll. This information includes:
• Name and title, contact details, company name, business title, email address;
• Where our contacts have online accounts, log-in and similar credentials and information about use of these services;
Communications with our business contacts.
Information that we collect incidentally from other sources or public sources, including:
• information available in the media;
• information presented on our social media or wider social media platforms including Facebook, Twitter and Instagram; and
information collected by security systems (such as CCTV) when you visit our premises or attend our events.
Information that we collect from individuals representing organisations, including:
• contact details of individuals working for organisations;
other personal information regarding such individuals.
Special Categories of Information that you give us or that we receive when using our services:
• Specifying certain dietary requirements that imply specific religious beliefs or medical conditions;
• Health records; and
Biometric data.
How we use your data
We use this information to:
• create an account for you to use our website;
• provide our services;
• manage and administer
our systems;
• help us ensure that our
customers are genuine
and to prevent fraud;
• identify how you’d like to
use your account;
• send you our
newsletters;
• administrating the
competition or prize
draw;
• contact you and provide
you with the prize if you win the competition or prize draw;
• announce the winner of the competition or prize draw on our Website or Apps;
• request that you be involved in other publicity for us or third parties; and
share this information with third parties if you have provided your consent to this.
We use this information to:
• provide you with information about the event that you are attending;
• ensure your eligibility to attend events;
• manage and administer our events efficiently;
• help us ensure that visitors to event are genuine and to prevent fraud;
• identify how you’d like to use your account;
• send you our newsletters;
• administrating the competition or prize draw;
• contact you and provide you with the prize if you win the competition or prize draw;
• announce the winner of the competition or prize draw on our website or Apps or in our events;
• request that you be involved in other publicity for us or third parties;
share this information with third parties if you have provided your consent to this.
• For the preliminary evaluation of your application; and
To keep in touch with you through the email address you have provided.
identify products and services that may be of interest to you (e.g. offering recommended relevant content to you);
personalise our service to you to provide you with, make available, and show you more of the things which interest you, based on your activity and feedback;
do statistical analysis and research with the purpose of allowing us to better understand the breakdown of our customers, the products / services being bought, the demographics of those buying our products and services, what attracts our customers to our products and services, where our customers have come from online (such as from links on other websites or advertising banners);
improve our services and efficiency of service delivery to help us meet your needs and expectations;
develop new services based on what we learn from your activity and the activity of other customers;
monitor the way our website is used; and
combine this information with other types of information mentioned above to allow us to make our services more personal and tailored to each customer’s preferences and habits.
We use this information, including to:
answer any issues or concerns;
monitor customer communications for quality and training purposes;
develop new services which is based on the information your provide;
• improve our services based on the information and feedback you provide and the information and feedback provided by others; and
personalise our service to you to take account of the information and feedback you have provided.
We use this information to:
• provide our services; provide and adapt our services to take account of the technical capabilities of our users and to ensure content is presented in the most effective manner;
• Analyse site traffic and understand
customer needs and trends;
• improve our services based on recent
visits to and how you move around different sections of our website;
• personalise our services to you: to provide you with, make available, and show you more of the things which interest you, based on your activity and feedback;
• identify products and services that may be of interest to you; (e.g. offering recommended relevant content to you);
• develop new services based on recent
visits to and how you move around different sections of our website or Apps;
• identify issues with the website and
user’s experience of
them;
• do statistical analysis
and research with the purpose of allowing us to better understand the breakdown of our customers, the products / services being bought, what attracts our customers to our products and services, where our customers have come from online (such as from links on other websites or advertising banners), and the way in which our website or App is used by different users groups; and
• monitor the way our website is used.
combine this information with other types of information mentioned above to allow us to make our services more personal and tailored to each customer’s preferences and habits.
• provide our services;
• manage and administer
our systems;
• take payment from or
give you a refund;
• help us ensure that our customers are genuine
and to prevent fraud;
• personalise our service
to you;
• statistical analysis and
research so that we can better understand our customers and allow us to develop and improve our services; and
• combine this information with other types of information mentioned above to allow us to make our services more personal and tailored to each customer’s preferences and habits.
maintain market awareness;
• build and maintain social media branding; and
• provide security to our sites.
• build relationships with other organisations;
• provide marketing communications to these individuals;
improve our services and develop new services based on the preferences and behaviours of these individuals.
Provide our services;
• Verify our customers’ identities and prevent
fraud.
Why we use your information
• this is necessary to enter into or perform our contract with you;
• this is necessary to comply with legal or regulatory requirements;
• we have a legitimate business interest to:
• tell you about the
various products and
services we can offer;
• understand how you
use our products, services, platforms, Apps and websites;
• ensure you remain engaged with our services via competitions and prize draws;
• understand and respond to customer feedback;
• research and analyse the services our
customers want;
• improve our services
based on what we learn from your activity and the activity of others on recent visits to our website or Apps;
• postal marketing; or
direct marketing to business contacts.
In addition to the above, where we have obtained your consent to use the data, then we can rely on that consent.
this is necessary to enter into or perform our contract with you;
• we have a legitimate business interest to:
• understand and
respond to customer
feedback;
• manage and
administer our events
efficiently; or
• direct marketing to
business contacts.
In addition to the above, where we have obtained your consent to use the data, then we can rely on that consent.
We will use your information where we have obtained your consent.
this is necessary to enter into or perform our contract with you;
• we have a legitimate business interest to:
o tell you about the various products and services we can offer;
o understand how you use our products; services, Apps and websites
o understand the type of products and services our customers buy and how they use them;
o understand and respond to customer feedback;
o research and analyse the
services our customers
want;
o improve our services;
o ensure that we are better
able to personalise our
offers to you;
o postal marketing; or o direct marketing to
business contacts.
• In addition to the above, where we have obtained your consent to use the data, then we can rely on that consent.
• this is necessary to enter into or perform our contract with you;
this is necessary to comply with legal or regulatory requirements;
we have a legitimate business interest to:
o understand customer feedback and respond to customer communications in a consistent manner;
o ensure that we are better able to personalise our offers to you;
o research and analyse the services our customers want;
o improve our services based on the feedback you provide;
o provide security over our business and who we trade with;
o prevent and detect fraud; o use artificial intelligence
to route customers to the most appropriate part of the organisation; or
o verifying customer details.
In addition to the above, where we have obtained your consent to use the data, then we can rely on that consent.
We use this information because:
• this is necessary to enter into or perform our contract with you;
• this is necessary to comply with legal or regulatory requirements;
• we have a legitimate business interest to:
o understanding how our customers use our products, services, Apps and websites
o tell you about the various products and services we can offer;
o ensuring network and information security;
o fraud prevention and detection;
use of artificial intelligence to route customers to the most appropriate part of the organisation;
o assessing the number of visitors, posts, page views, reviews and followers in order to optimise future marketing campaigns;
o postal marketing; or o direct marketing to business contacts.
In addition to the above, where we have obtained your consent to use the data, then we can rely on that consent.
this is necessary to enter into or perform our contract with you;
• this is necessary to comply with legal or regulatory requirements;
• we have a legitimate business interest in:
o developing and
maintaining relationships with vendors, partners and other companies and dealing with individuals who work for them;
o conducting research to improve our services; o ensuring network and
information security; o fraud prevention and
detection;
o providing security over
our business and who
we trade with;
o direct marketing to business contacts.
in addition to the above, where we have obtained your consent to use the data, then we can rely on that consent.
• this is necessary to enter into or perform our contract with you;
• this is necessary to comply with legal or regulatory requirements;
• we have a legitimate business interest to:
o providing security over our business;
o maintaining a public profile within the
media;
maintaining the accuracy of data we hold;
o conducting research to improve our services; o ensuring network and
information security; o fraud prevention and
detection;
o providing security over
our business and who
we trade with; o developing and
maintaining relationships with vendors, partners and other companies; or
o dealing with individuals who work for them.
In addition to the above, where we have obtained your consent to use the data, then we can rely on that consent.
We use this information because:
• we have a legitimate business interest to:
o develop and maintain relationships with vendors, partners and other companies;
o deal with individuals who work for them;
o tell you about the various products and services we can offer; or
o conducting research to improve our services
Some personal information is treated as falling into a special category. This includes information about health, disability, race, ethnicity, political opinions, biometrics or religion and used to be known as sensitive personal data.
We will use your health or biometric data where:
we have your explicit consent for the relevant purpose;
this is necessary to protect your vital interests in an emergency or those of another person;
• the relevant information has been made public by you;
this is necessary or in connection with legal claims or court proceedings.
If you would like to have more information about our legitimate interests to process your personal data, please contact us as set out below.
We will also receive information about you (including your personal information) if you use any other websites or apps operated or other services provided by us or our group companies. In this case, that information will be shared within the group and combined with information collected on this website.We will also receive and display information and content which you make publically available on your social media accounts.
Some information is processed because you’ve given your consent to that (where consent is required). You can withdraw your consent at any time (in your account preferences or settings) or by contacting accounting@avantmanagement.net .
Sources of data
Your personal information is either (a) provided by you (e.g. via our website / platform /social media pages); (b) obtained from third parties (such as other entities in our group; (c) obtained from publicly available sources (e.g. the Internet, Companies House).
In particular, data may be obtained from the following third parties: social networks, payment processing companies, Google Adwords, Linkedin, Google Analytics, Adobe Analytics and display partners.
Legal and other requirements
In some cases we need to collect or retain personal information for legal reasons
Some of the personal information we request is required to provide the services and if it is not provided, we may not be able to provide the relevant products and services to you or provide information you have requested from us. If the personal information is needed to participate in an activity on our website, you may not be able to do so if you do not provide that personal information to us.
In other cases, for example, when we request your personal data to send you marketing and promotional communications or to personalise your experience with our services, the lack of such information will mean it is impossible to send you these communications or to personalise your experience, but it will not have any consequence to the primary purpose of the data collection (to provide the services).
Your personal information may also be processed if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency, or in order to investigate, prevent or take action regarding suspected illegal activities or fraud, to enforce or apply our Terms of Use and other agreements, , to protect the rights, property or safety of group companies, customers, clients and others or in the defence of legal claims. We will not delete personal information if relevant to an investigation or a dispute or until applicable law allows for it to be deleted. It will continue to be stored until those issues are fully resolved and it can be lawfully deleted.
Any personal information you supply to us through our website must be complete and accurate. You also agree to allow us to contact you to verify your personal information, if we need to.
How long do we keep your information
We generally keep information as needed to provide services and to deal with legal claims
We will keep your information for as long as it is reasonably necessary and to deal with claims. It will depend on factors such as whether you’ve got an account with us, have interacted with recent offers or have attended our recent events. We will also retain your information as necessary to comply with legal, accounting or reporting requirements.
We will also retain a copy of your contact details if you object or opt-out of receiving direct marketing communications from us. We will add your details to our suppression list to ensure you do not receive any future marketing communications from us. Also, we will not delete personal data if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.
Information we share
There are certain circumstances where we transfer your personal data to employees, contractors and to other parties.
• We share information about you with other members of our group of companies so we can provide the best service across our group. They are required to keep and use your information in accordance with this Privacy Notice.
• We will:
o share aggregated, anonymised or other de-identified data with advertisers, advertising
networks and social networks that require the data to select and serve relevant adverts to you and others. We will also use aggregate information to help advertisers reach the kind of audience they want to target.
o make use of the personal information we have collected from you to help our advertisers display their advertisements to a target audience and to present our promotional messages to you including using Facebook Custom Audience. This means you will be presented with advertisements that are more relevant to you as a result of the personal information we hold about you.
o share your personal data with and access information from analytics and search engine providers that assist us in the improvement and optimisation of the website and the app and for better personalisation of content and advertising.
• We share your information with certain contractors or service providers. They may process your personal data for us, for example, if we use a marketing agency. Other service providers include advertising agencies, IT suppliers, database providers, backup and disaster recovery specialists, email providers and outsourced call centres. Our suppliers and service providers will be required to meet our standards on processing information and security. The information we provide them, including your information, will only be provided in connection with the performance of their function. They will not be permitted to use your information for any purposes other than those outlined in this Privacy Notice.
• We also share your information with certain third parties. We will do this either when we receive your consent or because we need them to see your information to provide products or services to you.
Your personal information may be transferred to other third party organisations in certain scenarios:
• if we discuss selling or transferring part or all of our business – the information may be transferred to prospective purchasers under suitable terms as to confidentiality;
• if we are reorganised or sold, information may be transferred to a buyer who can continue to provide services to you;
• if we’re required to by law, or under any regulatory code or practice we follow, or if we are asked by any public or regulatory authority – for example the Police;
• if we are defending a legal claim your information may be transferred as required in connection with defending such claim
• if there is an emergency including which requires us to share your data to protect the health
and safety of our website’s or App’s users or the general public.
Your personal data may be shared if it is made anonymous and aggregated, as in such circumstances the information will cease to be personal data.
Where your information will be held
Your information may be transferred outside the European Economic Area.
The information that we collect from you may be transferred to and stored at a destination outside the European Economic Area (EEA), including the USA which does not have equivalent data protection laws to those applicable to Europe. It may also be processed by staff operating outside the EEA who work for us, for one of our affiliated companies, or for the organisation that hosts our website.
However, to ensure your personal information is properly protected in line with EU data protection law, the transfer of this information is governed by a contract including Standard Contractual Clauses (SCCs) approved by the European Commission in accordance with Article 46(2)(c) of the General Data Protection Regulation.
We will only transfer data to jurisdictions outside the scope of the European General Data Protection Regulation (GDPR) where the appropriate safeguards set out in the GDPR are in place.
If you would like to obtain copies of the regulator-approved SSCs please contact us on the contact details below.
Your Rights
You have certain rights in relation to your information. The availability of these rights and the ways in which you can use them are set out below in more detail.
Some of these rights will only apply in certain circumstances. If you would like to exercise, or discuss, any of these rights, please contact the accounting@avantmanagement.net.
• Access: you are entitled to ask us if we are processing your information and, if we are, you can request access to your personal information. This enables you to receive a copy of the personal information we hold about you and certain other information about it.
• Correction: you are entitled to request that any incomplete or inaccurate personal information we hold about you is corrected.
• Erasure: you are entitled to ask us to delete or remove personal information in certain circumstances. There are also certain exceptions where we may refuse a request for erasure, for example, where the personal data is required for compliance with law or in connection with claims.
• Restriction: you are entitled to ask us to suspend the processing of certain of your personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Transfer: you may request the transfer of certain of your personal information to another party.
• Objection: where we are processing your personal information based on a legitimate interest (or those of a third party) you may challenge this. However, we may be entitled to continue processing your information based on our legitimate interests or where this is relevant to legal claims. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Consent: where we are processing personal data with consent, you can withdraw your consent. If you want to exercise any of these rights, please contact AVANT MODELS in writing at
accounting@avantmanagement.net
You also have a right to lodge a complaint with a supervisory authority, in particular in the Member State in the European Union where you are habitually resident where we are based or where an alleged infringement of Data Protection law has taken place.
Right to object
You have a right to object to us processing your information in certain circumstances.
Objection: where we are processing your personal information based on a legitimate interest (or those of a third party) you may challenge this. However, we may be entitled to continue processing your information based on our legitimate interests or where this is relevant to legal claims. You also have the right to object where we are processing your personal information for direct marketing purposes.
Direct Marketing
As described above, you can opt-out of receiving direct marketing from us at any time.
We may use the information you give us on our website for direct marketing purposes to provide updates; newsletters; events; or other communications that we think may interest you. We will only do this with your consent (where required by law).
You can opt-out of receiving direct marketing from us at any time. You can do this by changing your marketing preferences on your online accounts settings page, clicking on the “unsubscribe” link included at the end of any marketing email we send to you, or by contacting AVANT MODELS at accounting@avantmanagement.net
Analysis and Marketing
We use third party tools to personalise the advertising displayed to you on our website.
We use third party tools, to make the advertising we show you on our website, and / or our partner websites more relevant and interesting to you. We also use third party tools to provide advertising to you on third party non-partner websites (including social media websites such as Facebook).
Please see our Cookies Policy for further information.
You may opt-out at any time from the collection and use of your data by contacting AVANT MODELS at accounting@avantmanagement.net
Do Not Track
You can enable a ‘Do Not Track’ feature in your browser’s settings, if your browser supports that feature. When Do Not Track is turned on, your browser will send a Do Not Track request to the sites you visit. The Do Not Track request lets these sites know that you prefer not to have your browsing activity tracked. You can take similar steps in mobile.
To submit a Do Not Track request on mobile using an iOS device:
• launch the Settings app on your iPhone → Privacy → Advertising.
• toggle ON the switch next to Limit Ad Tracking.
• now that you have opted out of receiving ads targeted to your interests, based on your Apple
ID on that device, you will be removed from the list of users receiving targeted ads. To submit a Do Not Track request on mobile using an Android device
• open Google Settings,
• select AdsPrivacy. and toggle ON the switch next to Do Not Track to opt out of Ads
Personalization. Do Not Track is now enabled on your Android device.
• Apps are then instructed not to use your advertising ID to build profiles or show you
personalized ads.
Some devices may require a different procedure, so please check your instructions.
Cookies and Similar Technologies
We and our advertising agency partners use cookies and “web beacons” that identify your browser.
Cookies collect and store information when you visit our website including information about how you use it through which it is possible to monitor your use of the website, as well as provide you with a better service and experience when browsing the website and for analytics.
Web beacons (also known as “single pixel GIFs”, “clear GIFs” or “tags”) are small graphic images that may be included on our website. Web beacons:
• allow us to optimise our products and services;
• provide us and third-party partners with analytics information, such as how many visitors our
website receives; and
• are used by us in our email correspondence to determine whether you open them or take any further action.
We also work with other organisations to place our cookies and web beacons on their websites or in their advertisements. We do this to help us develop statistics on how often clicking on an advertisement on our websites results in a purchase or other interaction on the advertiser’s website.
For more information about cookies and how we use them, please see our Cookie Notice. Security
The transmission of information via the internet is not completely secure. Although we will take reasonable measures to protect your personal information, we cannot guarantee the security of your information transmitted through our website and any transmission is at your own risk. Once we have received your personal information, we will use procedures and security features to try to prevent unauthorised access.
Links to third party website
Our website, newsletters, email updates and other communications may, from time to time, contain links to and from the websites of others including our partner networks, advertisers and other group companies and/or social networks as offered to you and supported by your browser.
The personal data that you provide through these websites is not subject to this privacy notice and the treatment of your personal data by such websites is not our responsibility. If you follow a link to any of these websites, please note that these websites have their own privacy notices which will set out how your information is collected and processed when visiting those sites. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy notices of entities through which you choose to share.
Changes to this Notice
This notice may be changed from time to time.
If we change anything important about this notice (the information we collect, how we use it or why) we will highlight those changes at the top of the notice and provide a prominent link to it for a reasonable length of time following the change.
Once this notice is posted on our website, it will automatically come into force. The latest version of this notice will prevail over all previous versions
If you would like to access previous versions of this notice please contact AVANT MODELS at accounting@avantmanagement.net
How to contact us
If you would like more information about the way we manage personal information that we hold about you, or are concerned that we may have breached your privacy and wish to make a complaint, please contact us as set out below. We will do our best to resolve your complaint.
If you have any questions about this notice please contact our Accountant accounting@avantmanagement.net, Obozowa 20 street, 107 apt. 01-161 Warsaw, Poland
