Privacy Policy

Effective: 28 September 2026 Version: 1.2 Legal basis: UK General Data Protection Regulation (UK GDPR), Data Protection Act 2018, Privacy and Electronic Communications Regulations 2003 (PECR).

1. Who we are

Eternal Elegance Models Limited ("the Agency", "we", "us") is the data controller for personal data processed through the Eternal Elegance platform.

• Company No. 17115788, registered in England and Wales.
• Registered office: 71-75 Shelton Street, London, WC2H 9JQ, United Kingdom.
• Data Protection contact: the GDPR Data Subject Rights form at eternalelegancemodels.com.
• ICO registration: ZC156242 (registered with the Information Commissioner's Office as a data controller).

The Eternal Elegance platform (operated by the Agency) is the technology layer through which we process your data. Eternal Elegance acts as a data processor for some activities and a joint controller for others; this policy treats the combined operation as the Agency's single controller responsibility for simplicity.

2. Who this policy applies to

• Models, photographers, designers (talent and providers) with Eternal Elegance Accounts
• Brand users (Admin and Member) with Eternal Elegance Accounts
• Agency staff (Bookers, Finance Admins, Platform Admins)
• Visitors to our public-facing website, including the public model directory
• Senders of enquiries to hello@ or talent@ without accounts
• Complainants submitting complaints to the Agency
• People who register an interest on our website before the platform opens

3. What personal data we collect

3.1 Account registration

• Identity data — full name, date of birth, nationality (for models — for age verification and right-to-work)
• Contact data — email address, phone number, location (city/region)
• Authentication data — password hash (for email/password accounts), Firebase UID, OAuth identifiers, MFA device registrations (for staff)

3.2 Identity verification (models and providers)

• ID documents — passport, driving licence, EU national ID, or US passport. Processed via Veriff.
• Biometric data — face match (processed within Veriff; no biometric templates retained by the Agency).
• Veriff outputs — extracted data (name, DOB, doc number, expiry), match score, authenticity decision.

3.3 Profile and portfolio (talent)

• Profile data — bio, measurements, experience level, languages, availability calendar
• Portfolio imagery — photographs and videos you upload, plus AI-generated metadata (alt text, category tags, scoring)

3.4 Provider profile

• Business data — studio location, equipment, rate card, specialisms, social media links
• Portfolio imagery — for photographers on paid tiers

3.5 Bookings, contracts, and communications

• Booking data — dates, locations, rates, usage rights, stage transitions, check-in/check-out timestamps
• Contracts — signed PDFs and associated metadata
• Messaging — message content, timestamps, participants (within the Booker-mediated messaging hub)

3.6 Financial data

• Commission and payout records — amounts, dates, counterparties
• Invoices — issued and paid amounts, payment status
• Stripe Connected Account ID — bank account details are stored only by Stripe, never by us

3.7 Usage data

• Platform activity — logins, actions taken, state transitions (anonymous analytics where possible)
• IP address, user agent, device information — for security and abuse prevention
• Audit logs — records of all consequential actions

3.8 Sensitive / special category data

• Image consent — explicit consent for image processing (UK GDPR Art. 9 consent)
• Disability disclosure — voluntary disclosure for chaperone accommodation under the Equality Act 2010 (processed only with explicit consent)
• Biometric data — during Veriff identity check (processed by Veriff under their terms)

We do not routinely collect or process health data, political opinions, religious beliefs, sexual orientation, or genetic data.

3.9 Interest registrations

If you register your interest on our website, we collect your first and last name, your email address, your phone number if you choose to give it, whether you are a model, photographer, designer, brand, member of the press or something else, and anything you choose to tell us in the optional note. We also keep a record of when you agreed to hear from us and the words you agreed to. If you give a phone number, you also agree separately to be called or texted, and we keep a record of that agreement in the same way; we will not call or text you without it.

4. Lawful bases for processing

We rely on the following lawful bases (UK GDPR Article 6, and Article 9 for special category data):

5. Who we share your data with

5.1 Service providers (processors)

• Google Identity Platform (Google Cloud) — authentication (data residency pinned to eur3 EU multi-region)
• Google Cloud Platform — application hosting (region: europe-west2)
• Stripe / Stripe Connect — payment processing, bank details, Connected Account management
• Veriff — identity document verification and biometric face match
• DocuSeal (self-hosted on our infrastructure) — e-signature
• Resend — transactional email delivery (sent from its EU region, Ireland)
• Anthropic (Claude API) — AI agent processing (Onboarding, Portfolio Review, Booking Orchestrator, Contract, Payments, Communications, Dispute Resolution)

Each processor is bound by a data processing agreement. We limit the data shared to what is necessary for each service.

5.2 Clients and providers

• Brand users, photographers, designers booking you: first name, photographs, comp card details (measurements, experience, location) — never full name, never contact details
• Signed booking contracts: contain the party names (client side may see full legal name on the contract PDF; the client is bound by the contract's confidentiality clause)

5.3 Other third parties

• Regulators and law enforcement — where required by law (Employment Agency Standards Inspectorate, ICO, HMRC, courts, police)
• Professional advisers — accountants, solicitors, insurers, auditors — under confidentiality obligations
• Prospective successors — in the event of a merger, acquisition, or business transfer, data may be transferred with the business, subject to prior notification

5.4 International transfers

• Primary processing takes place in the United Kingdom and European Economic Area.
• Some processors (Anthropic, Resend, Stripe) may process data in the United States or other third countries, under either a UK Adequacy Regulation or Standard Contractual Clauses with appropriate supplementary measures.

6. How long we keep your data

After the applicable retention period, data is either deleted or anonymised.

7. Your rights (UK GDPR Articles 15–22)

You have the right to:

• Access the personal data we hold about you (Article 15)
• Correct inaccurate data (Article 16)
• Request deletion (Article 17) — subject to our legal obligations to retain certain records
• Restrict processing in some circumstances (Article 18)
• Data portability — receive your data in a structured, commonly used format (Article 20)
• Object to processing, including direct marketing (Article 21)
• Not be subject to automated decisions with legal or similarly significant effects (Article 22)

To exercise any of these rights, submit a request through the GDPR Data Subject Rights page.

We respond within 1 calendar month. Where the request is complex or we receive multiple requests, we may extend this by a further 2 months, notifying you of the reason.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) — ico.org.uk, helpline 0303 123 1113.

8. Image consent and withdrawal

Model images are processed under explicit consent (UK GDPR Article 9(2)(a)). Consent is captured during onboarding and covers:

• Public website display (anonymous tier — no name visible)
• Provider-facing display (first name visible)
• Search engine indexing of the public model directory
• AI agent processing (Portfolio Review Agent — scoring, tagging, alt text, content policy)
• Sharing with clients via booking contracts
• Agency marketing — comp cards, agency website, agency social media

You can withdraw image consent at any time via account settings. On withdrawal:

• All portfolio images are permanently deleted within 30 days.
• Your profile is hidden from public and provider view immediately.
• Images already shared with clients via completed bookings are not retroactively recalled — those usages are governed by the signed booking contract.

9. Security

We implement appropriate technical and organisational measures aligned with ISO 27001 (Annex A controls) and UK GDPR. These include:

• Encryption in transit (TLS 1.3) and at rest (AES-256)
• Role-based access control with separation of duties
• Mandatory multi-factor authentication for agency staff
• Regular security scanning (OWASP ZAP, CodeQL)
• Audit trail for all consequential actions
• Incident response procedures with breach notification (to ICO within 72 hours of confirmed breach, and to affected individuals where required)

10. Cookies and tracking

Eternal Elegance uses strictly necessary cookies only — authentication session, session ID, CSRF token. No analytics, tracking, or advertising cookies are used.

See our Cookie Policy for details.

11. Changes to this policy

We may update this Privacy Policy from time to time. Material changes are notified to you via email and in-platform notice, at least 30 days before taking effect. Previous versions are retained in the policy version history (available on request).

12. Contact

For any privacy question, concern, or data subject rights request:

Contact: the GDPR Data Subject Rights form at eternalelegancemodels.com Post: Eternal Elegance Models Limited, 71-75 Shelton Street, London, WC2H 9JQ, England.

Information Commissioner's Office: ico.org.uk, helpline 0303 123 1113, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

Eternal Elegance — Privacy Policy | Version 1.0 | Eternal Elegance Models Limited | Company No. 17115788