Privacy policy
1. Introduction
INTERNATIONAL MODEL MANAGEMENT (hereinafter "IMM"), whose head office is
located at Spaces 70 rue aux laines 1000 Bruxelles registered with the
ECB under number 0475.648.111, 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 IMM:
− collects, uses and stores personal data relating to its customers,
employees, models, physical persons, and any physical person in contact
with IMM including potential customers, representatives of our moral or
physical customers;
− transfers or discloses these data;
− is committed to respecting your data protection rights;
"Personal data" are 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 the existing contractual
conditions applicable between you and IMM, which remain unchanged.
IMM processes your data in a transparent manner and in compliance with
all applicable data protection and privacy laws, including the "RGPD"
(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
IMM is required to collect your personal data when you visit our
Facebook page (or other social networks) or on the Internet site
(www.immbrussels.com), 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 an investigation or
contest or when you contact us.
The categories of information that we are likely to collect are the
following:
● identification data: surname and first name, date of birth, number and
information contained on your identity card and / or passport, bank
details and possibly business number;
● contact data: personal address, email address, phone numbers;
● Physical data: Sex, size, body measurements, physical characteristics
(eye color, hair, tattoos, etc.), photos, videos, etc. ;
● information about your use of our website and / or mobile application,
social networks;
● any other information you have provided to us regarding your request;
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
if necessary, or if you have deliberately made this data public.
In order to verify and / or complete our databases, information may be
collected directly from you or, in particular, from the following
sources:
− publications made accessible by the official authorities;
− databases made public by third parties;
− third parties such as other agencies, our customers and our suppliers;
− Website, social network containing information that you have made public
3. For what purposes are your personal data used and why we use your personal data.
a- We comply with our legal obligations
In particular compliance with applicable social security legislation, to respond to official requests from public or judicial authorities duly authorized.
b- To execute a contract concluded with you or to carry out pre-contractual measures at your request
We use this data to enter into and execute our contracts including:
− provide information about the models practicing within the agency,
− management of the modeling career as part of the mandate entrusted to us,
− study your application as a model,
− provide the products and services requested,
− to attend you and answer your requests,
− to communicate with you when sending details for a booking, a go and see,
a photo test, a trip ....
− for billing.
c- For legitimate interests
Your data is also processed:
− to communicate with you, especially as part of our Newsletter,
− for customer satisfaction studies and to help us improve your and our experience,
− to provide updates on policy changes, MIF terms and conditions and any
other questions we may have to provide you,
− if necessary, to analyze your online interactions (collected using cookies),
for the purpose of improving business proposals,
− 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,
− establishment of statistical and commercial analyzes,
− send someone information about our products and services at the request
of another person,
− marketing by sending you proposals (from models to agencies and offers
like shoots to models).
Only people aged 16 or over can give their own consent. For people under
16, the consent of parents or legal guardians is required.
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.
♣ 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.
♣ 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?
In order to fulfill the above purposes, we may share your personal data
with third parties. For some services, we use specialized partners who
act as subcontractors. They must follow our instructions and comply with
our Privacy Policy.
We may make your personal data available to other agencies, to our clients,
to our legal counsel, to external third-party service providers, such as
IT service providers, support, social networks, hosting and any supplier
who assist us in carrying out our activities.
6. Transfer of personal data outside the European Economic Area ("EEA")
In the case of international transfers from the EEA to a third country
for which the European Commission has made a decision of adequacy
recognizing a level of protection of personal data equivalent to the one
provided by the EEA legislation, your personal data will be transferred
on this basis.
For transfers to countries for which the European Commission has not
made a decision of adequacy, we rely on a derogation applicable to the
situation (example: for the management of your modeling career) and / or
we ask our partners to process your information securely and in
compliance with European data protection laws.
7. How do we protect your personal data?
IMM takes all the technical and organizational measures necessary to
protect your personal data against loss, abuse, disclosure, unauthorized
access or alteration of such data.
IMM 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 execute 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, you are personally notified
as a customer in the circumstances provided by law. In addition, these
security measures are regularly reviewed and adapted to ensure an
adequate level of protection.
8. Link to social networks
Our website contains links to social networks we use (Facebook, instagram). If you follow a link to any of these social media sites, please note that these sites have their own 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?
a- 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.
b- Right of 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.
c- Right of 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.
d-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.
e- 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: ♣ 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;
♣ 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;
♣ when your data has been unlawfully processed by us, but you prefer us
to limit their processing rather than delete them;
♣ when we no longer need to process your personal data but are still needed
for the ascertainment, exercise or defense of rights in court;
f- Right of opposition
You may object to the processing of your data for reasons related to your personal situation. IMM will stop the processing of your personal data unless it can demonstrate that there are compelling legitimate reasons for the treatment that prevails over your right to object. You have the absolute right to oppose the processing of your personal data for direct marketing purposes.
g- 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.
h- 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.
i- How to exercise your rights?
To exercise your rights, you must send us a written request and proof of identity, by mail to IMM Rue Jourdan 36, 1060 Brussels or by mail to [email protected]. 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.
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 IMM Rue Jourdan 36, 1060 Brussels or by email at ( [email protected]) If you are not satisfied with the processing of your personal data by IMM, you have the possibility to lodge a complaint with the Data Protection Authority (https://www.privacycommission.be/).