Privacy Policy

Effective Date: March 1, 2025 | Last Updated: March 1, 2025

Ebony Luxe Dubai ("we," "us," "our," or the "Company") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website ebonyluxedubai.com (the "Site") or use our services.

By accessing or using our Site, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access the Site or use our services.

1. Information We Collect

1.1 Personal Information You Provide

We collect personal information that you voluntarily provide to us when you:

• Submit casting applications or model registration forms
• Contact us through our contact forms or email
• Subscribe to our newsletters or updates
• Register for events or services
• Participate in surveys or promotions

This information may include:

• Full name and date of birth
• Email address and phone number
• Mailing address and location information
• Physical measurements and appearance details (for modeling applications)
• Photographs and portfolio materials
• Social media handles and professional information
• Payment and billing information (when applicable)
• Any other information you choose to provide

1.2 Automatically Collected Information

When you visit our Site, we automatically collect certain information about your device and browsing behavior, including:

• IP address and geographic location
• Browser type and version
• Operating system and device information
• Pages visited, time spent on pages, and navigation paths
• Referring website or source
• Date and time stamps of visits

1.3 Cookies and Tracking Technologies

We use cookies, web beacons, pixels, and similar tracking technologies to collect information about your browsing activities. These technologies help us:

• Remember your preferences and settings
• Understand how you use our Site
• Improve Site performance and user experience
• Deliver personalized content and advertisements
• Analyze Site traffic and usage patterns

You can control cookie preferences through your browser settings. However, disabling cookies may limit your ability to use certain features of our Site.

2. How We Use Your Information

We use the information we collect for various legitimate business purposes, including:

2.1 Service Provision and Management

• Processing and evaluating modeling applications
• Managing model representation and bookings
• Communicating about opportunities, castings, and assignments
• Facilitating client connections and project collaborations
• Providing customer support and responding to inquiries

2.2 Marketing and Communications

• Sending newsletters, updates, and promotional materials
• Informing you about new services, events, or opportunities
• Conducting surveys and gathering feedback
• Personalizing marketing content based on your interests

2.3 Analytics and Improvement

• Analyzing Site usage and user behavior
• Improving Site functionality, content, and user experience
• Developing new services and features
• Conducting research and statistical analysis

2.4 Legal and Security

• Complying with legal obligations and regulations
• Protecting against fraud, unauthorized access, and security threats
• Enforcing our terms and conditions
• Resolving disputes and addressing violations

3. Legal Basis for Processing (GDPR Compliance)

For users in the European Economic Area (EEA), we process personal data based on the following legal grounds:

• Consent: You have given clear consent for processing your personal information for specific purposes
• Contract Performance: Processing is necessary to fulfill our contractual obligations to you
• Legitimate Interests: Processing is necessary for our legitimate business interests, provided these don't override your rights
• Legal Obligation: Processing is required to comply with applicable laws and regulations

4. Information Sharing and Disclosure

We do not sell, rent, or trade your personal information to third parties. We may share your information in the following circumstances:

4.1 With Your Consent

We may share your information with third parties when you have given explicit consent, such as sharing model portfolios with potential clients.

4.2 Service Providers

We engage trusted third-party service providers to perform functions on our behalf, including:

• Website hosting and maintenance
• Email delivery and marketing automation
• Payment processing
• Analytics and data analysis
• Customer support services

These providers have access only to information necessary to perform their specific functions and are contractually obligated to protect your data.

4.3 Business Clients

For represented models, we may share portfolio information, measurements, and availability with potential clients for casting and booking purposes. This sharing is integral to our modeling agency services.

4.4 Legal Requirements

We may disclose your information when required by law, court order, or government regulation, or when we believe disclosure is necessary to:

• Comply with legal processes
• Protect our rights, property, or safety
• Protect the rights, property, or safety of others
• Prevent fraud or illegal activities

4.5 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your information may be transferred to the acquiring entity. We will notify you of any such change and the choices you may have.

5. International Data Transfers

Ebony Luxe Dubai operates in the United Arab Emirates. If you are accessing our Site from outside the UAE, please be aware that your information may be transferred to, stored, and processed in the UAE or other countries where our service providers operate.

We take appropriate measures to ensure that international data transfers comply with applicable data protection laws, including implementing standard contractual clauses and other legally recognized transfer mechanisms.

6. Data Retention

We retain personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Specific retention periods depend on:

• The nature of the information collected
• The purpose for which it was collected
• Legal, regulatory, or contractual requirements
• Legitimate business needs

When personal information is no longer needed, we securely delete or anonymize it in accordance with our data retention policies.

7. Your Rights and Choices

7.1 Access and Correction

You have the right to access, review, and correct your personal information. Contact us to request access to the personal data we hold about you.

7.2 Data Portability

You may request a copy of your personal information in a structured, commonly used, and machine-readable format.

7.3 Deletion

You may request deletion of your personal information, subject to certain legal exceptions. We will respond to deletion requests in accordance with applicable data protection laws.

7.4 Opt-Out Rights

• Marketing Communications: Unsubscribe from promotional emails using the link provided in each message or by contacting us directly
• Cookies: Manage cookie preferences through your browser settings
• Analytics: Opt out of analytics tracking using available browser extensions or tools

7.5 Restriction of Processing

You may request that we restrict processing of your personal information in certain circumstances, such as while we verify the accuracy of disputed data.

7.6 Objection to Processing

You have the right to object to processing of your personal information based on legitimate interests or for direct marketing purposes.

8. Security Measures

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit and at rest
• Secure server infrastructure and firewalls
• Access controls and authentication procedures
• Regular security assessments and updates
• Employee training on data protection
• Incident response and breach notification procedures

While we strive to protect your information, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security but remain committed to maintaining industry-standard protections.

9. Children's Privacy

Our Site and services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have inadvertently collected personal information from a child under 18, we will take steps to delete such information promptly.

For modeling applications from individuals under 18, we require verifiable parental or guardian consent before collecting or processing any personal information.

10. Third-Party Links and Services

Our Site may contain links to third-party websites, services, or applications. This Privacy Policy applies only to our Site and services. We are not responsible for the privacy practices or content of third-party sites. We encourage you to review the privacy policies of any third-party services you access.

11. California Privacy Rights

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA):

• Right to Know: Request information about personal data collected, used, disclosed, or sold
• Right to Delete: Request deletion of personal information
• Right to Opt-Out: Opt out of the sale of personal information (Note: We do not sell personal information)
• Right to Non-Discrimination: Exercise privacy rights without discriminatory treatment

To exercise these rights, contact us using the information provided below. We will verify your identity before processing requests.

12. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by:

• Posting the updated Privacy Policy on our Site
• Updating the "Last Updated" date
• Sending email notifications for significant changes (when applicable)

Your continued use of our Site after changes are posted constitutes acceptance of the updated Privacy Policy. We encourage you to review this Privacy Policy regularly.

13. Contact Information

14. Supervisory Authority

If you are located in the EEA and believe we have not adequately addressed your privacy concerns, you have the right to lodge a complaint with your local data protection supervisory authority.

15. Consent and Acceptance

By using our Site and services, you acknowledge that you have read this Privacy Policy and understand how we collect, use, and protect your personal information. You consent to the collection, use, and disclosure of your information as described in this Privacy Policy.

If you do not agree with this Privacy Policy, please discontinue use of our Site and services immediately.

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