Privacy Policy

MP Management recognizes the importance of protecting Personal Data and is committed to processing it responsibly and in compliance with applicable Data protection laws in all countries in which MP Management operates.

MP Management in this caption refers to the global organization of agencies MP Paris Sarl, MP Atlanta LLC, MP Los Angeles LLC, MP Mega Miami Inc, MP Factor LLC and MP Stockholm AB each of which is a separate legal entity, agency is a data controller and we’ve listed them in point 14.Personal Data Access.

MP Management complies with all the applicable privacy policy principles and has taken the necessary actions. In this regard, MP Management has adopted a Privacy Policy, describing in detail the company’s compliance with Privacy Principles.

This Privacy Policy is effective as of 25th May 2018 and describes MP Management’s general privacy practices applied to Personal Data collected in the following chapters:

  1. General principles for processing Personal Data
  2. What MP Management collects
  3. How MP Management collects
  4. Why MP Management collects
  5. Models, Talents, Employees, Clients, and Suppliers Personal Data Rights
  6. Special categories of Personal Data
  7. Data Integrity and Purpose Limitation
  8. Security and Confidentiality
  9. Equipment and Information Security
  10. Transfer of Personal Data
  11. Accountability for Onward Transfer of Personal Data
  12. Retention Period
  13. Enforcement Rights and Mechanism
  14. Personal Data Access
  15. Recourse, Enforcement, and Liability
  16. Right to Lodge a Complaint
  17. Obligation Towards Data Protection Authorities
  18. MP Management’s Website and Online Services Privacy Policy
  19. Marketing

The aim of this Privacy Policy is to provide adequate and consistent safeguards for the handling of Personal Data by MP Management in accordance with local laws.

MP Management recognizes that certain laws might be modified to require stricter standards than those described in this Policy, in which case the stricter standards shall apply.

MP Management will handle Personal Data in accordance with local law at the place where the Personal Data is processed. If applicable law provides for a lower level of protection of Personal Data than that established by this Policy, then this Policy shall prevail.

his Policy is designed to provide compliance with all the following relevant applicable laws:

France Loi informatique et libertés (LIL) de 1978, 2004, Loi pour la confiance dans l’économie numérique (LCEN) 2004

Sweden Personuppgiftslagen – SFS 1998:204 EU 95/46/CE 29/04/1998.

Italia Decreto legislativo 30 giugno 2003, n. 196

Estonia Personal Data Protection Act 22.04.2010 RT 2010 I 22,108

Florida Information Protection Act Effective the Florida Information Protection Act of 2014 (“FIPA”)

Illinois Personal Information Protection Act. (815 ILCS530/)

Georgia Privacy Act SB135

Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the protection of individuals with regard to the processing of Personal Data and on the free movement of such Data,

Directive 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such Data, and repealing Directive 95/46/EC (General Data Protection Regulation)

Children’s Online Privacy Protection Act (Coppa) 1998, 15 U.S.C. 6501.6505

California Constitution, Article 1, section 1. “Shine the Light” law California Civil Code §§ 1798.90.5-1798.90.55, 1798.29, 1798.82. California Reader Privacy Act (SB 602).

and all the relevant transposing legislation of the Directive in the European Union/European Economic Area, as such laws may from time to time be amended and validated during the application of this Policy, and any other privacy laws, regulations and principles concerning the collection, storage, transfer and other processing of Personal Data transferred from the European Economic Area to the United States including but not limited to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such Data, and repealing Directive 95/46/EC (“the General Data Protection Regulation”) as of its entry into force on 25 May 2018.

1. General principles for processing Personal Data

MP Management’ legal basis for Data collecting, processing and transfer is its necessity in the context of a contract or the intention to enter into a contract: the legitimate purpose for processing Data is a matter of necessity for the performance of a contract to which the Data subject is party or in order to take steps at the request of the Data subject prior to entering into a contract or working under an existing contract.

When the Data subject initiates activities with MP Management, processing is necessary even before entering into a contract in order to evaluate the business opportunities at the request of the Data subject rather than being initiated by MP Management.

MP Management respects the privacy of Models, Talents, Employees, Clients and Suppliers and is committed to protecting Personal Data in compliance with the applicable legislation. This compliance is consistent with MP Management’s desire to keep its Models, Talents, Employees and Clients and Suppliers informed and to recognize and respect their privacy rights.

MP Management will observe the following principles when processing Personal Data:

Data will be processed fairly and in accordance with applicable law.

Data will be collected for specified, legitimate purposes and not processed further in ways incompatible with those purposes.

Data will be relevant to and not excessive for the purposes for which they are collected. For example, Data may be rendered anonymous if deemed reasonable, feasible and appropriate, depending on the nature of the Data and the risks associated.

Data will be accurate and, where necessary, kept up up-to-date. Reasonable steps will be taken to rectify or delete Personal Data that is inaccurate or incomplete.

Data will be kept only as it is necessary for the purposes for which it was collected and processed: those purposes shall be described in this Policy.

Data will be deleted or amended following a relevant request by the concerned Data subject, should such a request comply with the applicable legislation on each occasion.

Data will be processed in accordance with the individual’s legal rights provided by aforementioned laws.

Appropriate technical, physical and organizational measures will be taken to prevent unauthorized access, unlawful processing and unauthorized or accidental loss, destruction or damage to Data. In case of any such violation with respect to Personal Data, MP Management will take appropriate steps to end the violation and determine liabilities in accordance with applicable law and will cooperate with the competent authorities.

2. What MP Management collects

MP Management collects or has access to Personal Data to carry out and support its model and talent management business, collecting personal information provided directly including but not limited to application to become a model, talent or employee, to place a booking, to e-mail us, to authenticate an order or to request information or automatically received through Internet, including but not limited to internet protocol (IP) address, information about browser “cookie” and “web beacon” or “web bug” information.

As permitted by local laws, the Personal Data relating to Employees may include the following:
name, gender, contact information; date of birth; government-issued identification information, passport or visa information; educational history; employment and military history; legal work eligibility; information about job performance and compensation; financial account information; and other information Employees may provide.

As permitted by local laws, the Personal Data relating to Clients and Suppliers may include the following:

contact information such as: name; postal address; email address and telephone number; contact details, position or job title; contractors, advisors and authorized partners, financial account information; company details such as registered office, vat and signature power.

As permitted by local laws, the Personal Data relating to Models and Talents may include the following:

name; gender; contact information; date of birth; government-issued identification information, passport or visa information; tax and social residential status; educational history; legal work eligibility statements; information about previous performance and compensation; financial account information; other information Model and Talent may provide MP Management such as, availability to be part of shooting with animals, furs, fully or in part naked; personal statistics (measurements such as height, bust, waist, shoes size, hair colour, eye colour ); presence of tattoos or scars; body mass index (BMI); presence of cosmetic or plastic surgery, photos and videos; occupation; interests; other forms of electronic address (Website, Social Media Platforms).
According the local laws, (France Loi Manequinn 26.01.2016) Models and Talents, will need to provide MP Management with a doctor’s certificate attesting that their health is “compatible with the practice of the profession” and to their overall physical health, with special regard to their body mass index (BMI), a measure of weight in relation to height.

MP Management also may obtain Models’ and Talents’ Personal Data in other ways for which MP Management provides specific notice at the time of collection (including but not limited to scouting contests etc.).

3. How MP Management collects

MP Management does not obtain any personal information about Models, Talents Employees, Clients and Suppliers unless the Model, Talent, Employee, Client and Supplier has provided that information to MP Management in a way providing for their clear and unequivocal consent to do so including but not limited to a completion of a written application.

Models, Talents, Employees, Clients and Suppliers may choose to submit Personal Data by facsimile, regular mail, e-mail, or electronic transmission over our internal Website, interoffice mail, or personal delivery, as each of these methods may be deemed applicable each time.

MP Management can also obtain personal data where it is necessary for legitimate interests or when it is necessary to perform our business, from different sources including but not limited to other third parties involved in the Model, Talent’s management such as Mother Agencies and from other companies within MP Management global organization of agencies.

4. Why MP Management collects

MP Management processes Personal Data for business legitimate purposes and contractual relationships with partners related to human resources, managing, improving, developing and promoting the image of those who work or intend to work as a Model or Talent.

The limitation of purposes shall be taken into consideration before any type of processing of Personal Data and shall not be subject to any changes without prior notification.

These principal purposes for Employee Personal Data include:

Human resources purposes including but not limited to recruiting and hiring job applicants; managing employee communications and relations; providing compensation and benefits; administering payroll; processing corporate expenses and reimbursements; managing employee participation in human resources plans and programs; carrying out obligations under employment contracts; managing employee performance; conducting training and talent development; facilitating employee relocations and international assignments; managing employee headcount and office allocation; managing the employee termination process; managing information technology and communications systems, such as the corporate email system and company directory; conducting ethics and disciplinary investigations; administering employee grievances and claims; managing audit and compliance matters; complying with applicable legal obligations, including government reporting and specific local law requirements; and other general human resources purposes. MP Management may also obtain and process Personal Data about Employees emergency contacts and other individuals (such as family members and beneficiaries) to the extent Employees provide such information to MP Management.

For Employee Personal Data, MP Management is committed to cooperate with the different national Data Protection Authorities (DPA) and comply with the dispute resolution procedures such Data Protection Authorities may indicate in cases of complaints by Employees with any regulations or guidelines such DPAs may issue from time to time in in accordance with State Data protection legislation. MP Management undertakes to register and keep its registration updated as a Data controller and processor in all jurisdictions where MP Management maintains entities.

These principal purposes for Clients and Suppliers Personal Data include:
running day-to-day business relationships; marketing activities; management of financial accounts; development activities; conduct of transactions or facilitation of offering of the services provided; conduct of surveys, market research, inbound and outbound client and supplier communications and education. Contacting MP Management (online or offline) in connection with a request for information, to book a Model or Talent MP Management represents, MP Management collects information necessary to fulfill the request, to provide support and to be able to contact back. For instance, MP Management collect name and contact information, details about request and agreement with MP Management and the fulfillment, delivery and invoicing of an order may include client satisfaction information. MP Management retains such information for administrative purposes and in connection with the business relationship.

These principal purposes for Model and Talent Data include:
managing Model and Talent careers with the aim of promoting their image and seeking, finding, negotiating and developing contractual relationships with third parties (by way of an example, advertising agencies, companies working in fashion or similar sectors, editorial, etc.) regarding the services of the Model and Talent and the granting of the relevant rights to the commercial usage of their image all across the world; processing related payments; conducting training and talent development; complying with applicable legal obligations, including government reporting, specific local law requirements, Visa support applications and taxes obligations; other general human resources purposes.

According to the local laws decreeing that models working in certain countries must possess a medical certificate deeming them fit to work, clients using Models’ and Talents’ services need to receive Models a medical certificate, valid for up to two years, confirming their general physical well-being and the fact they are not excessively underweight.

MP Management may also obtain and process Personal Data about a Model’s and Talent’s emergency contacts and other individuals (such as, family members and beneficiaries) to the extent Models and Talents provide such information to MP Management.

MP Management will only use Personal Data for the purposes for with they are collected and with further another reason compatible with the original purpose.

MP Management may also process Personal Data without consent where this is required or permitted by law.

5. Model’s, Talent’s, Employee’s, Client’s and Supplier’s Personal Data Rights

Any person has the right to be provided with information as to the nature of the Personal Data stored or processed about him or her by MP Management and may request deletion or amendments.

Models, Talents, Employees, Clients and Suppliers can have access to their own Personal Data and may correct or amend it as needed.

Models, Talents, Employees, Clients and Suppliers can get in touch in any moment with privacy@mpmanagement.com to review, update, and revise their Personal Data.

If a Model, Talent, Employee, Client and Supplier demonstrates that the purpose for which the Data is being processed in no longer legal or appropriate, the Data will be deleted, unless the applicable law requires otherwise.

If MP Management introduces a new process or application that will result in the processing of Personal Data for purposes that go beyond the purposes described above, MP Management will inform the concerned Data subjects of the new process or application or new purpose for which the Personal Data are to be used, and the categories of recipients of the Personal Data.

Automated decisions are defined as decisions about individuals that are based solely on the automated processing of Data and that produce legal effects that significantly affect the individuals involved. MP Management does not make automated decisions for Models, Talents, Employees, Clients and Suppliers Personal Data. If automated decisions are made, affected persons will be given an opportunity to express their views on the automated decision in question and object to it.

6. Special categories of Personal Data

MP Management does not intentionally collect any special categories of Personal Data (Sensitive Personal Information) unless in a specific country MP Management are legally required to do so, for example, for recruitment purposes. Sensitive Personal Information includes: information revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade-union membership; the processing of genetic or biometric data for the purpose of uniquely identifying a natural person; information concerning a natural person’s sex life or sexual orientation.

7. Data Integrity and Purpose Limitation

MP Management does not process Models’, Talents’, Employees’, Clients’ and Suppliers’ Personal Data in ways that are incompatible with the purposes for which the information was collected or subsequently authorized by the relevant Model, Talent, Employee, Client and Supplier. In addition, to the extent necessary for these purposes, MP Management takes reasonable steps to ensure that the Personal Data the company processes is reliable for its purpose, and is accurate, complete and current. In this regard, MP Management relies on its Models, Talents, Employees, Clients and Suppliers to update and correct Personal Data to the extent necessary for the purposes for which the information was collected or subsequently authorized by the Model, Talent, Employee, Client and Suppliers. Models, Talents, Employees, Clients and Suppliers may contact MP Management as indicated in this Policy to request that MP Management updates or corrects relevant Personal Data. Subject to applicable laws, MP Management retains Models’, Talents’, Employees’, Clients’ and Suppliers’ Personal Data in a form that identifies or renders identifiable the relevant Personal Data only for as long as it serves a purpose that is compatible with the purposes for which the Personal Data was collected or subsequently authorized by the Employee or Client and Supplier.

8. Security and Confidentiality

MP Management is committed to taking appropriate technical, physical and organizational measures to protect Personal Data against unauthorized access, unlawful processing, accidental loss or damage and unauthorized destruction. MP Management takes reasonable and appropriate measures to protect Personal Data from loss, and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Data.

9. Equipment and Information Security

The importance of security for all Personal Data is of highest concern. MP Management is committed to safeguarding the integrity of Personal Data and preventing unauthorized access to information maintained in MP Management’s Databases. These measures are designed and intended to prevent corruption of Data, block unknown and unauthorized access to our computerized system and information, and to provide reasonable protection of Personal Data in MP Management’s possession. All employee files are confidentially maintained in the HR department in secured and locked file cabinets or rooms. Access to the computerized Database is controlled by a log-in sequence and requires users to identify themselves and provide a password before access is granted. Users are limited to Data required to perform their job function. Security features of our software and developed processes are used to protect Personal information from loss, and unauthorized access, disclosure, alteration, and destruction. To safeguard against unauthorized access to Personal Data by third parties outside MP Management all electronic Personal Data held by MP Management are maintained on systems that are protected by up-to-date secure network architectures that contain firewalls and intrusion detection devices. The Data saved in servers is backed up (i.e. the Data are recorded on separate media) to avoid the consequences of any inadvertent erasure, destruction or loss. The servers are stored in facilities with high security, access protected to unauthorized personnel, fire detection and response systems. The location of these servers is known to a limited number of MP Management Employees.

MP Management will be responsible for conducting adequate training sessions regarding the lawful, enumerated intended purposes of processing Personal Data, the need to protect and keep information accurate and up-to-date, the lawful purposes of collecting, handling and processing Data that is transferred from the EU to the US and from the US to the EU and the need to maintain the confidentiality of the Data to which Employees have access. Authorized users will comply with this Policy and MP Management will take appropriate actions in accordance with applicable law, if Personal Data are accessed, processed in any way that is inconsistent with the requirements of this Policy.

10. Transfer of Personal Data

As a global organization with business processes, management structures and technical systems that cross borders, MP Management has implemented global policies, along with standards and procedures, for consistent protection of Personal Data. As a global company, MP Management may share information with subsidiaries world-wide and transfer it to countries in the world where MP Management does business in accordance with this Privacy Statement. In connection with the activities described, MP Management may transmit Personal Data to MP Management different offices around the world and to MP Management affiliated entities.

Moreover, Personal Data might be sent to the following third parties:

Selected Third Parties: MP Management will not disclose or share any Personal Data with any external entity or third party, except to an Employee’s designated insurance provider, employee benefits administrator, travel professionals, clients to illustrate experience and qualifications for business purposes, external authorized CPA for tax purposes, external authorized Lawyer for legal purposes, debt collections agencies, credit reference agencies.

MP Management will not disclose or share any Personal Data with any external entity or third party, except to Model’s or Talent’s clients for business purpose connected with the Model’s and Talent’s job confirmation such us insurance and rights management, clients to illustrate experiences and photos, hotel airline or travel agency to book tickets, external authorized CPA for tax purposes, external authorized Lawyer for legal purposes. According to the local laws, clients booking a Models or Talents, might have the right to receive a doctor’s certificate attesting Models’ or Talents’ overall physical health, with special regard to their body mass index (BMI) – a measure of weight in relation to height.

MP Management, managing, advising, counseling, promoting and negotiating, on Model’s and Talent’s behalf, in all areas and modes of professional modeling and the entertainment industry, including print media, photography, advertising, runway, fitting, live show, and commercial work which includes SAG-AFTRA bookings in advertising, television, video, mobile, internet, film and any other media, is requested to share with the Clients Models’ and Talents’ Personal Data for the purpose of the Models’ and Talents’ job confirmation.

MP Management, with the aim of promoting Models’ and Talents’ images, will share on www.mpmanagement.com and with the Clients upon request Models’ and Talents’ Images or Videos portfolios with Personal Data such us name, gender and measurements such as height, bust, waist, shoes size, hair color, eye color.

Other Third Parties: MP Management may be required to disclose certain Personal Data to other third parties: as a matter of law (e.g. to tax and social security authorities); to protect MP Management’s legal rights; in an emergency where the health or security of an employee is endangered); to Law Enforcement Authorities in accordance with the local relevant legislation in the different States including but not limited to legislation transposing EU/2016/1148 concerning measures for a high common level of security of network and information systems across the Union (“the Network Information Security Directive”).

United States Parties: Personal data MP Management collects can be transferred to, processed, and stored in the US. The Data protection laws in the United States may differ from those of the country in which Personal Data owner is located, and this Data may be subject to access requests from governments, courts or law enforcement in the United States according to the laws of the United States. By providing MP Management with the information, the Personal Data owner consents to this transfer, processing, and storage of information in the US.

Prospective or Purchasers parties: If MP Management decides to sell, buy, merge or otherwise reorganize business in some countries, such a transaction, this may involve the disclosure of Personal Data to prospective or purchasers, and the receipt of such information from sellers. It is MP Management’s practice to require appropriate protection for Personal Data in these types of transactions.

In certain circumstances, Personal Data may be subject to disclosure to government agencies pursuant to judicial proceedings, court orders, or legal processes. MP Management may also share Personal Data to protect the rights or property of MP Management, Models and Talents, Suppliers or Clients, and others when MP Management have reasonable grounds to believe that such rights or property have been or could be affected. MP Management may disclose or share any Personal Data with external service providers to assist with, for example, information technology and other administrative support services to collect, MP Management, analyze, and otherwise process Personal information.

11. Accountability for Onward Transfer of Personal Data

Except as permitted or required by applicable law, MP Management provides Models, Talents, Employees, Clients and Suppliers with an opportunity to opt out of sharing their Personal Data with third-party.

MP Management requires third parties to whom it discloses Personal Data, to contractually agree to only process the Personal Data for limited and specified purposes consistent with the consent provided by the relevant Models, Talents, Employees, Clients and Suppliers and also requires to provide the same level of protection for Personal Data and to notify MP Management and cease processing Personal Data (or take other reasonable and appropriate remedial steps) if the third party determines that it cannot meet its obligation to provide the same level of protection.

MP Management is not required to enter into a contract to transfer Personal Data to certain third parties for occasional operational needs of the company, such as booking flights or hotel rooms.
MP Management remains liable under the Privacy Policy if the company’s third party transfers recipients process the relevant Personal Data in a manner inconsistent with MP Management’s Privacy Policy, unless MP Management proves that it is not responsible for the event giving rise to the damage.

12. Retention Period

MP Management will not retain Personal Data longer than necessary to fulfill the purposes for which it is processed, including the security of our processing complying with legal and regulatory obligations (e.g. audit, accounting and statutory retention terms), handling disputes, and for the establishment, exercise or defense of legal claims in the countries where MP Management does business.

13. Enforcement Rights and Mechanism

MP Management will ensure that this Privacy Policy is observed and duly implemented. All persons who have access to Personal Data must comply with this Policy. Violations of the applicable Data Protection legislation may lead to penalties and claims for damages.

If at any time a person believes that Personal Data relating to him or her has been processed in violation of this Policy, he or she may report the concern to the competent MP Management office.

14. Personal Data Access

MP Management will communicate this Privacy Policy to current and new Models, Talent, Employees, Clients and Suppliers by posting it on the www.mpmanagement.com Website and by providing a link to the Privacy Policy on information technology applications.

MP Management reserves the right to modify this Privacy Policy as needed, for example, to comply with changes in laws, regulations or requirements introduced. If MP Management makes changes to the Privacy Policy, the amended Privacy Policy will be released according to the relevant applicable provisions of the law. MP Management will inform Models, Talents, Employee, Clients and Suppliers and other persons (e.g. persons accessing Website to enter Personal Data such as job application information or a model or talent application) of any material changes in the Privacy Policy.

Effective with the implementation of this Privacy Policy, all existing and applicable company privacy guidelines relating to the collection and/or processing of Personal Data will, where in conflict, be superseded by the terms of this Privacy Policy. No other internal policy that conflicts with this Policy shall be applicable with respect to the protection of Personal Data handled by MP Management. All parties to such agreements will be notified of the effective date of the implementation of the Policy.

Models, Talents, Employees, Clients and Suppliers may request access to their Personal Data by contacting MP Management as indicated in this Policy by email at privacy@mpmanagement.com or by email to the separate legal entity at the following addresses:

MP Stockholm AB
Grev Turegatan, 18
114 46 Stockholm Sweden
VAT: SE556655515601

MP Management s.r.l.
Via Fontana 25
20122 Milan Italy
VAT: IT06280080968

MP Paris SARL
14 Rue Favart
75005 Paris, France
VAT : FR08452221500

MP Mega Miami Inc
420 Lincoln Road Suite 408, Miami Beach,
Miami Beach, FL 33139 US
TAX ID : 80-0656185

MP Factor, LLC
400 N. Michigan Ave Ste700
Chicago, IL 60611 US
Tax ID 82-3119125

MP Atlanta, LCC
500 Bishop St NW Suite A-2
Atlanta, GA 30318 US
Tax ID 82-3149331

MP Los Angeles LLC
7250 Melrose Ave #4
Los Angeles, CA 90046 US
Tax ID 82-3134168

The message will be forwarded to the appropriate member of MP Management’s Data Privacy Team.

For the purposes of the EU General Data Protection Regulation (GDPR), the controller of Personal information is MP Management srl Via Fontana 25 20122 Milan Italy.

Where MP Management or a subsidiary it controls (not established in the European Economic Area) is required to appoint a legal representative in the EEA, the representative for all such cases is MP Management Srl Via Fontana 25 20122 Milan Italy.

Models, Talents, Employees, Clients and Suppliers may have additional rights pursuant to local law applicable to the processing. For example, if the processing of Personal Data is subject to the EU General Data Protection Regulation (“GDPR”), and Personal information is processed based on legitimate interests, Personal Data owners have the right to object to the processing on grounds relating to each specific situation. Under GDPR Personal Data owners may also have the right to request to have Personal Data deleted or restricted and ask for portability of Personal Data.

15. Recourse, Enforcement, and Liability

MP Management has mechanisms in place designed to effect compliance with the Privacy Policy. MP Management conducts an annual self-assessment of all its Personal Data practices to verify that the attestations and assertions MP Management makes about its Privacy Shield privacy practices are true and that MP Management’s privacy practices have been implemented as represented and in accordance with the Privacy Policy Principles.

16. Right to Lodge a Complaint

In the event Models, Talents, Employees, Clients and Suppliers consider our processing of Personal Data not to be compliant with the applicable Data protection laws, they may lodge a complaint directly with MP Management by sending an email to privacy@mpmanagement.com or with the competent Data Protection Authority.

MP Management will take steps to remedy issues arising out of its alleged failure to comply with the Privacy Policy Principles.

If a complaint cannot be resolved through MP Management’s internal processes, MP Management will cooperate with the panel Data Protection Authorities established pursuant to the Privacy Policy to address relevant complaints and provide appropriate recourse free of charge.

Special Notice to California Residents
California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers regarding the businesses’ practices related to disclosing Personal Data to third parties for the third parties’ direct marketing purposes. Alternatively, such businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information sharing. We have such a policy in place. Sections Accountability for Onward Transfer of Personal Data and Access explain MP Management’s practices and how to opt-out of having Personal Data shared with third parties for the third parties’ direct or indirect marketing purposes, in accordance with such laws.

Special Notice to Canada Residents
Through Canada’s “Privacy Act” law, R.S.C., 1985, c. P-21 Canadian residents also have certain rights to know how Personal Data may be shared with third parties who engage in direct marketing activities. Again, Sections Accountability for Onward Transfer of Personal Data and Access explain MP Management’s practices and how to opt-out of having Personal Data shared with third parties for the third parties’ direct or indirect marketing purposes, in accordance with such laws.

Special Notice to European Union Residents
Directive 95/46/EC of the European Parliament and all the relevant transposing legislation of the Directive in the European Union/European Economic Area (“EU/EEA”), regulate the processing of personal data inside the EU and of EU residents. The Regulation separates responsibilities and duties of data controllers and processors, obligating controllers to engage only those processors that provide “sufficient guarantees to implement appropriate technical and organizational measures” to meet the Regulation’s requirements and protect data subjects’ rights. MP Management’s Privacy Policy, starting from 25th May 2018 complies with Directive 95/46/EC of the European Parliament.

For the avoidance of doubt, these opt-out options are available for all users and are not limited to Californian, European Unions and Canadian users.

17. Obligation Towards Data Protection Authorities

MP Management will respond diligently and appropriately to requests from Data Protection Authorities (DPAs) about this Privacy Policy or compliance with applicable Data protection privacy laws and regulations. MP Management’s Employees who receive such requests should contact their human resources manager or business legal counsel. MP Management will, upon request, provide DPAs with names and contact details of relevant persons. With regard to transfers of Personal Data between MP Management entities, the importing and exporting MP Management entities will cooperate with inquiries from the DPA responsible for the entity exporting the Personal Data and respect its decisions, consistent with applicable law and due process rights. With regard to transfers of Personal Data to third entities, MP Management will comply with DPAs’ decisions relating to it and cooperate with all DPAs in accordance with applicable legislation.

18. MP Management’s Website and Online Services Privacy Policy

MP Management website www.mpmanagement.com will not knowingly collect or identify information from children younger than 13.

By accessing or using the Website you agree to the terms of this Policy. If you do not agree with any of these terms please do not use the Website.

This Website Policy only applies to data collected on the Website and does not apply to websites of affiliated companies. We reserve the right to modify the Website Policy at any time without notice. Any changes to our website Policy in the future will be posted on the Website. You are responsible for regularly reviewing the website Policy or any updates and/or changes to the website Policy.
When entering www.mpmanagement.com or an online platform, registration is not required.
If you are merely a visitor, we do not collect any Personal information about you, except to the limited extent through the MP Management of cookies, which are described below. There may be circumstances in which you choose to register and receive ongoing updates from MP Management. In these cases, MP Management may contact registrants to invite them to special events, provide them with information about our Model or talent represented, publications and products, or for other marketing purposes.

For example, you may choose to register for:

Email alerts
MP Management can decide to offer an email alert service (DEM) to site visitors, in which MP Management sends subscribers email updates when new Models or Talents are represented by MP Management or (NEWSLETTER) when MP Management issues an online publication. If you decide to subscribe, MP Management will collect basic contact information about you, such as your name and email address. You can always opt out from receiving Email alert through the opt out option in each email.

Expressing an interest in working for MP Management
Our Site enables you to register your interest in working for MP Management or applying for an advertised vacancy. Most information MP Management collects about you comes from your direct interactions with MP Management.

Expressing an interest in being represented by MP Management
To send an application to be represented by MP Management, Personal Data processing is necessary for the performance of a future representation contract to which the Data subject is party or in order to take steps at the request of the Data subject prior to entering into a contract.

If you are 13 years of age or younger, MP Management is sorry but you may not apply to MP Management.

If you are a minor between the ages of 14 and 18 you are welcome to apply online but MP Management ask that you please do so with your parent’s or legal guardian’s written consent to be annexed to your submission.

When you register, you may be asked for Personal information (name, contact information, measurements, pictures etc.). The type of information collected will vary.

Cookies
Our Site uses cookies and other technologies such as CAPTCHA’s to improve Our Site’s performance and to enhance your browsing experience. Certain areas of Our Site also uses cookies to understand more about you, so MP Management can offer you a more Personalized browsing experience. The law states that we can store cookies on your device if they are strictly necessary for the operation of this site. For all other types of cookies we need your permission.
If you do not accept our Cookie Policy please do not use this site.

How do I disable cookies?
If you do not want to receive a cookie from Our Site, you have the option of setting your browser to notify you when you receive a cookie, so that you may determine whether to accept it or not. Please be aware that if you do turn off ‘cookies’ in your browser, you will not be able to fully experience some of Our Sites.

Social Media Platforms
MP Management may also provide links to other social media platforms (Instagram, Facebook, Twitter, Linkedin) maintained on separate servers by individuals or organizations over which MP Management has no control. MP Management makes no representations or warranties regarding the accuracy or any other aspect of the information located on such servers. The main aim of these Social Media Platforms is to facilitate and allow you to see our content. MP Management cannot be held responsible if you share Personal information on Social Media Platforms.
MP Management recommend reviewing the privacy statement of each third-party site linked to our Site to determine their MP Management of your Personal information.

19. Marketing

Most information MP Management collects about you comes from our direct interactions with you. When you contact MP Management for a booking for example, MP Management may collect information based on a legitimate interest: processing is necessary for the performance of a contract or in order to take steps prior entering a contract.

MP Management combines the Personal information MP Management collects to develop aggregate analysis and business intelligence for conducting the business and for marketing purposes. You can choose to receive information by email, telephone or postal mail about our products and services, or signup for subscriptions.

MP Management may use Personal Data for direct marketing purposes to provide updates regarding its business through dem or newsletters after receiving explicit consent and only to recipients who have given their prior consent, opt in. MP Management uses third party tools to send dem or newsletters and each recipients can opt out of receiving dem or newsletters at any time with the option included at the end of any dem or newsletter.

You can always opt out from receiving personalized communication by sending an e-mail to privacy@mpmanagement.com.