1. INTRODUCTION

Up North Model Management AB (reg. no. 559123-7499, c/o Trifo Business & Space AB, Göteborgsvägen 3, 434 32 Kungsbacka), in its capacity as controller, attaches great importance to protection and respect of your privacy.

The purpose of this Privacy Policy is to explain how Up North Model Management AB:

a. collects, uses and stores personal data relating to its customers, employees, models, and any physical person in contact with Up North Model Management AB, including prospective customers and prospective models;
b. transfers or discloses these data;
c. is committed to respecting your data protection rights;

"Personal data" is all personal data about you: any information that can identify you directly or indirectly as a physical person.

"Data processing" is any transaction or set of transactions made, applied to your personal data. The concept of treatment covers all aspects relating to the collection, recording, organization, preservation, adaptation or modification, extraction, consultation, use, broadcast communication or any other form of provision, reconciliation or interconnection, and the archiving, erasure or destruction of such personal data.

In no case does this statement modify any existing contractual conditions applicable between you and Up North Model Management AB, which remain unchanged.

Up North Model Management AB processes your data in a transparent manner and in compliance with all applicable data protection and privacy laws, including the "GDPR" (Regulation 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data).

2. PERSONAL DATA COLLECTED

Up North Model Management AB is required to collect your personal data when you visit our website (www.upnorthmanagement.se) and our social media pages, when you apply as a candidate model, within the framework of the management entrusted to us of your modeling career, when you search for models, when you participate in a contest or another event, or when you interact with our services. The categories of information that we are likely to collect are the following:

a. identification data: surname and first name, date of birth, number and identification number where required by law.
b. contact data: personal address, email address, phone numbers, any social media profile;
c. tax data and bank and payment references;
d. Physical data: Sex, size, body measurements, physical characteristics (eye color, hair, tattoos, etc.), photos, videos, etc.;
e. information about your use of our website and / or mobile application, social networks;
f. other voluntary provided information, limited to what is necessary for the specified purpose;

Moreover, we will ask you if you suffer from allergies and if you follow food restrictions in order to avoid that in certain photographic or advertising services you may run into health problems.

Personal information relating to your physical and mental health, data relating to offenses and criminal convictions are considered "sensitive" personal data in accordance with the data protection laws in force. We will only process this data if you have given your explicit consent, or where legally required.

In order to verify and / or complete our databases, information may be collected directly from you or, in particular, from the following sources:

a. publications made accessible by the official authorities;
b. databases made public by third parties;
c. third parties such as other agencies, our customers and our suppliers;
d. websites, social networks containing information that you have made public

3. WHY WE USE YOUR PERSONAL DATA

We process your data based on the following legal grounds:

a) Compliance with legal obligations

We process your data to comply with applicable legal requirements, including tax, social security, and employment laws.

b) Performance of contract or pre-contractual measures.

We use your data to enter into and execute our contracts including:

a. to execute a contract concluded by you or to carry out pre-contractual measures at your request
b. provide information about the models practicing within the agency,
c. management of the modeling career as part of the mandate entrusted to us,
d. study your application as a model,
e. provide the products and services requested,
f. to attend you and answer your requests,
g. to communicate with you when sending details for a booking, a go and see, a test shooting, a trip.
h. for billing.

c) For legitimate interests

Your data is also processed:

a. to communicate with you, especially as part of our Newsletter,
b. for customer satisfaction studies and to help us improve your and our experience,
c. to provide updates on policy changes, MIF terms and conditions and any other questions we may have to provide you,
d. if necessary, to analyse your online interactions (collected using cookies), for the purpose of improving business proposals,
e. for and during the resolution of all disputes, claims or investigations relating to the use of the Site, the mandate entrusted to us with regard to the management of your career or as part of your application as a model,
f. establishment of statistical and commercial analyses,
g. send someone information about our products and services at the request of another person,
h. marketing by sending you proposals (from models to agencies and offers like shoots to models).

If we rely on legitimate interest, we will conduct a balancing test of interests according to GDPR.

d) Consent (where required)

We will obtain explicit consent for direct marketing communications when legally required and for the processing of such sensitive data as mentioned under section 2.

You can withdraw consent at any time without affecting the lawfulness of processing before withdrawal.

Only individuals aged 16 or over can give their own consent. For individuals under 16, the consent of parents or legal guardians is required. For individuals 16, we will process personal data only with verifiable parental or guardian consent and strictly for purposes necessary to provide our services. Parents or guardians can contact us to provide or withdraw consent at any time.

4. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We can’t store your personal data beyond the time required for the treatment for which it was collected. In concrete terms, we distinguish a retention period and an archival period.

a. The retention period is the maximum period of use of your data for a specific treatment. When it expires (either the purpose pursued has been completed or has disappeared, or your right to oppose has been successful), your data is erased from our database.
b. The archiving period meets our legal obligations (for example, to meet our accounting and tax obligations, we are required to keep your billing data for 7 years maximum) or the legal need to keep your data beyond the retention period for evidentiary purposes.

As soon as we no longer need your personal data, we delete or destroy it safely. We are also attentive to any possibility of reducing the time of use of personal data and anonymization of your personal data so that they can no longer be associated with you or identify you, in which case we may use this information without further formalities.

5. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

We share personal data only when necessary and in compliance with GDPR requirements. This includes:

a) Service providers under contractual agreements ensuring GDPR compliance (e.g., IT providers, payment processors, agencies)
b) Clients, agencies and partners when necessary for bookings or collaborations.
c) Legal and regulatory authorities when required by law.

We do not sell or rent personal data to third parties.

6. TRANSFER OF PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (“EEA”)

We transfer personal data outside the EEA only if:

a) The recipient country has an adequacy decision by the European Commission.
b) We have appropriate safeguards in place, such as Standard Contractual Clauses (SCCs) approved by the European Commission.
c) You have given explicit consent, or the transfer is necessary for the performance of a contract

7. HOW DO WE PROTECT YOUR PERSONAL DATA?

Up North Model Management AB takes all the technical and organizational measures necessary to protect your personal data against loss, abuse, disclosure, unauthorized access or alteration of such data.

Up North Model Management AB undertakes to limit access to personal data to situations in which such access is essential. The number of employees in our company with access to your personal information is limited and carefully selected. These employees have access to your personal information as long as they need this information to properly complete their assignments. These employees have been trained and informed of their data protection obligations.

In addition, we apply various technical measures to protect your data, including, among others, password protection, hard disk encryption software, firewalls, antivirus, intrusion and anomaly detection, and access control for our collaborators. In case of data leakage with adverse consequences for your personal data, we will notify affected individuals and authorities as required by GDPR.

In addition, these security measures are regularly reviewed and adapted to ensure an adequate level of protection.

8. LINK TO SOCIAL MEDIA PAGES

Our website contains links to social media pages we use (e.g., Facebook, Instagram). If you follow a link to any of these social media pages, please note that these sites have their own privacy policies and that your personal data may be processed according to those platforms’ privacy policies, and we are not responsible for these policies. We invite you to read the terms of these policies before sending any personal data to these websites.

9. WHAT ARE YOUR RIGHTS AND HOW CAN YOU EXERCISE THEM?

Right to information

You have the right to obtain clear, transparent, understandable and easily accessible information on how we use your personal data and your rights.

Right to access

You have the right to access the personal data that we have about you and to obtain a copy to verify that we are legally processing this data.
We may charge a reasonable fee that reflects the administrative costs incurred in providing the information. Visibly unfounded, excessive or repeated requests may not be answered.

Right to rectification

You have the right to require your personal data to be rectified if they are inaccurate or out of date and / or for them to be completed if they are incomplete.

Right to erasure (or “right to be forgotten”)

In some cases, you have the right to have your personal data deleted or removed. This is not an absolute right, as we may be forced to keep your personal data for legal or legitimate reasons. Individuals under 16, or their parents/guardians, may request data erasure at any time, such requests will be handled as a priority under GDPR Article 17 and the provided data will be deleted unless retention is required by law.

Right to limitation of treatment

You have the right to request that we limit the processing (retention and non-processing) of your personal data. This right applies in special circumstances provided by the GDPR, namely:

a. when you dispute the accuracy of the personal data we process about you. In this case, our processing of your personal data will be limited for the duration of verification of the accuracy of the data;
b. when you object to our processing of your personal data for the purposes of our legitimate interests. You may request that the data be limited while we verify our reasons for processing your personal data;
c. when your data has been unlawfully processed by us, but you prefer us to limit their processing rather than delete them;
d. when we no longer need to process your personal data but are still needed for the ascertainment, exercise or defense of rights in court;

Right of opposition

You may object to the processing of your data for reasons related to your personal situation. Up North Model Management AB will stop the processing of your personal data unless it can demonstrate that there are compelling legitimate reasons for the treatment that prevail over your right to object. You have the absolute right to oppose the processing of your personal data for direct marketing purposes.

Right to data portability

You have the right to request the transfer of your data for your benefit or for the benefit of another controller in an electronic and structured format where technically possible. This right applies only to the data you provide, when the processing is based on your consent or contract and is performed using automated processes.

Right to withdraw your consent

If you have given your consent to the processing of your personal data, you may withdraw it at any time. For individuals under 16, parents or guardians can contact us to withdraw consent at any time

How to exercise your rights?

To exercise your rights, you must send us a written request and proof of identity, by mail to Up North Model Management AB, c/o Trifo Business & Space AB, Göteborgsvägen 3, 434 32 Kungsbacka or by email to info@upnorthmanagement.se. We will respond as soon as possible, and no later than 1 month after receipt of the request (subject to the extensions granted to us by law).

10. CHANGES TO OUR PRIVACY POLICY

In a world of constant technological change, this Privacy Policy may be subject to change. We invite you to consult the latest version of this document on our website and we will inform you of any substantial changes via our website or other usual channels of communication. If we make any changes to how we process data of individuals under 16, we will notify both the individual and their parents/guardians.

11. QUESTIONS AND COMPLAINTS

If you have any questions about the use of your personal data covered by this Privacy Policy, you can contact us by mail to Up North Model Management AB, c/o Trifo Business & Space AB, Göteborgsvägen 3, 434 32 Kungsbacka or by email to info@upnorthmanagement.se. If you are not satisfied with the processing of your personal data by Up North Model Management AB, you have the possibility to lodge a complaint to the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten - IMY) or any other competent supervisory authority in the country of residence.