PRINCIPLES OF PERSONAL DATA PROCESSING

Czechoslovak Models, s. r. o., with its registered office at Adria Palace, Národní 36/40, Prague 1, Company ID No.: 47122927, Tax ID No.: CZ47122927, a business company registered in the commercial register maintained by the Municipal Court in Prague, file number C13480 (hereinafter also referred to only as "CzM" or the "Data Controller") as a personal data controller in conjunction with the provision of its services (in particular, services consisting in the representation of models in the "full service" scope in the area of modelling, marketing and other services), processes personal data of represented and cooperating models, in the case of underage models, also of their legal representatives (collectively referred to also only as the "Data Subject").

The objective of these personal data processing principles of CzM (hereinafter referred to also as the "Principles" is to provide information about what personal data CzM, in its role of a data controller, processes about the Data Subjects, for what purposes and for how long in accordance with the applicable legal regulations, to whom and for what reason CzM may transfer these personal data, as well as to inform about what rights the Data Subjects have in relation to the processing of their personal data.

These Principles are issued in accordance with Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data (hereinafter referred to also as the "GDPR") in order to ensure CzM's duty to notify in its role of a data controller pursuant to Article 13, GDPR, and are effective from 25 May 2018

Contact Details of the Data Controller

Czechoslovak Models, s. r. o.
Adria Palace, Národní 36/40
110 00 Prague 1

Telephone: 222 366 377

Email: info@czModels.cz

Website: www.czModels.cz

Categories of Personal Data

As a Data Controller, CzM processes the following categories of personal data of the represented and cooperating models, i.e. persons with whom it has concluded a contract and whom it represents or whom it cooperates with as a modelling agency; and persons collaborating on marketing projects:

Name and surname, date of birth, permanent and temporary residence, nationality, passport number and period of its validity or a number of and information about the validity of another identity document serving as a valid document when travelling outside the CR, the bank account number, email, telephone, academic title, social network addresses; model´s standard and artistic photographs, body measurements, clothing size measurements, shoe size, information about the colour of hair, eyes, about special body features, including tattoos.

In the case of underage models, CzM processes the personal data of the legal representative of the model: the legal representative's name and surname, date of birth, permanent address, academic title, email, telephone number and bank account number.

In models that are natural persons doing business on the basis of a trade licence, CzM processes their identification number (Company ID no.), the VAT number and possibly the trade name.

For the purposes of concluding agency contracts or rather modelling contracts, including contracts with foreign agencies, the subject of which is similar activities to those under the contracts between the CzM and the model, CzM processes the model's signature and, in the case of minors, the signature of their legal representative. The signature is kept on hard copy documents and their electronic records in a jpg or pdf format.

Legal Reasons and Purpose of Personal Data Processing

The legal reasons for the processing of personal data are the performance of the contract entered into by the Data Controller with the Data Subject, the fulfilment of legal obligations and the legitimate interests of CzM.

The purposes, for which personal data are processed, are as follows:

  • Presentation of models to third parties, while, in order to make this presentation as effective as possible and as beneficial for the model as possible, the personal data are also placed on CzM's website, in promotional materials, etc. (performance of the contract)
  • Billing the services (performance of the contract)
  • Fulfilment of tax obligations (fulfilment of legal obligations)
  • Recovery of receivables from the model and other client disputes (legitimate interest)
  • Processes related to the identification of the Data Subject (performance of the contract)
  • Securing evidence in case it is necessary to defend CzM's rights (CzM's legitimate interest)

Personal data for these activities are processed to the extent necessary for the performance of these activities and for the period of time required to achieve them or for a period of time directly stipulated by the law. Personal data are then erased or anonymized.

Retention Period for Personal Data

Personal data are fully retained for the period of duration of agency contracts and modelling contracts (or any other agreements allowing for cooperation or representation) and subsequently for a period of 5 years after the termination of these contractual relationships. Subsequent retention of personal data after the termination of contractual relationships is necessary for contacting models and implementing contractual relationships with third parties (clients) in the event of renewal, extension and expanding the scope of licences that have been negotiated during the contractual relationship between CzM and the models. If the licence has been negotiated for more than 5 years, personal data are retained for the duration of this licence.

In the case of negotiations between CzM and and a potential model concerning the conclusion of a contract not resulting in the conclusion of a contract, CzM is entitled to process the personal data provided for a period of 3 months after the end of such negotiations.

Invoices issued by CzM and the personal data included in these invoices are in accordance with the provisions of Section 35 of Act No. 235/2004 Coll., On Value Added Tax, as amended, for the period of 10 years of their issuance. Due to the need to substantiate the legal reason for issuing invoices, contracts with the model are also archived over a period of 10 years of the date of termination of the contract.

The Manner of Retaining Personal Data

Personal data are processed manually and automatically and stored both as hard copies and in the electronic form.

CzM's internal system, containing the models' personal data, is accessible through the web interface and is secured by a unique account for each user. The administrator of the internal system can block access to any user immediately. The internal database is stored on a secured dedicated server. This server is not accessible to regular users but only to a maximum of 2 (two) administrators and a company executive.

Employees handling the personal data of represented and cooperating models are bound by a confidentiality agreement the force of which is not limited by the termination of the employment relationship.

The internal agenda for filing fees, costs of the models and model invoicing is only available to the accountant, the company executive, the company proxy and the administrator. The administrator can cancel access at any time. The server is located in a special folder while it is only the administrator who has the right of access.

Computers and mobile phones used by CzM's employees to manage the portfolio of models and fulfilment of contractual relationships between models and CzM are password protected, mobile phones are secured by a PIN or by the Apple ID.

The new user of the internal system must have access explicitly approved by the administrator and access can be withdrawn by the administrator at any time. In the case of termination of employment relationships of CzM employees, access to the internal system is withdrawn as at the date of termination of the employment relationship at the latest.

Personal data recorded on hard copy documents are kept in rooms equipped with safety locks, namely at the headquarters of the Data Controller and at the headquarters of the external provider of accountancy and tax services with whom CzM has concluded a contract on processing of personal data.

Categories of Personal Data Recipients

Personal data may be transferred or made available to the following categories of recipients:

  • Customers who ask for or have chosen, within their demand process, a model represented by CzM (especially, however, not only, casting agencies, media houses, production companies, fashion designers, companies representing fashion brands, etc., namely both from the Czech Republic and abroad)
  • Partner foreign agencies interested in representing the model on foreign markets
  • Suppliers implementing marketing projects for CzM for Mercedes-Benz Prague Fashion Week and Czechoslovak TopModel
  • PR agencies, PR consultants, media representatives who are interested in implementing a media performance with a model represented by CzM
  • External collaborators who ensure the management of the accounting, tax and legal agenda to CzM
  • Internal network administrators and website administrators, including the internal system of filing models
  • Labour offices, namely only in the case of an agenda permitting children's advertising activities

Sharing Personal Information with Other Data Controllers

CzM does not share personal data with other Data Controllers and is only allowed to pass them on to them with the consent of the Data Subject.

Information on the Rights of Data Subjects

To enable Data Subjects to have better understanding, this section is worded in such a way that you (the Data Subject) are informed by CzM as a Data Controller that you have the following rights under the GDPR:

1 Right of Access to Personal Data

You have the right of access to personal data which includes the right to receive a confirmation from us whether we process your personal data as well as information on the processing purposes, categories of personal data concerned, recipients to whom your personal data were or will be made available, the planned period of time when the processing will take place, the existence of the right to request from us a correction or erasure of your personal data or the limitation of the processing thereof or to raise an objection to such processing and the right to file a complaint with the supervisory authority.

You may exercise your right to receive confirmation of your personal data being processed and to be provided with information in writing or electronically using our above-mentioned contact information.

2 Right to Correct Inaccurate Data

You have the right to correct inaccurate personal data we process about you. On the other hand, however, you have a duty to notify us of any changes to your personal data and to prove that such changes have occurred. At the same time, you are required to provide us with cooperation if we find out that the personal data we process about you are not accurate. We will do the correction without undue delay, however, always with respect to the technical possibilities available. The request for correction of personal data can be applied in person at the registered office of CzM or in writing, provided that it is supported with evidence that the given request is justified.

3 Right to Erasure

You have the right to erasure of personal data that concern you unless we can prove that there are legitimate reasons for processing these personal data.

4 Right to Limited Processing

If you deny the accuracy of your personal data, the reasons for their processing or if you file an objection to their being processed, you have the right to limit the processing of your personal data until your complaint is resolved.

5 The Right to Be Notified of a Correction, Erasure or Limitation of Processing

In the event of a correction, erasure or limitation of processing of your personal data, you are entitled to be notified of such an entry. If personal data are corrected or erased, we will inform the individual recipients of your personal data of this fact, except for cases when this proves to be impossible or if it requires unreasonable effort. Based on your request, we can provide information about these recipients.

6 Right to Portability of Personal Data

You have the right to portability of the personal data that concern you and that you have provided to us, namely in a structured, commonly used and machine-readable format, and the right to ask us to forward these data to another data controller. You may also ask us to provide this information to you in this format.

7 Right to Raise an Objection to the Processing of Personal Data

You have the right to raise an objection to the processing of your personal data because of our legitimate interest. In the event that we fail to prove to you that there is a serious legitimate reason for the processing that prevails over your interests, rights and freedoms, we will terminate the processing of your personal data without undue delay.

8 Application of the Above Rights

CzM has no obligation to have a data protection officer and does not have such an officer. In order to exercise the above rights, you may contact us in writing at: Czechoslovak Models s. r. o., Národní 36/40 – Adria Palace, 110 00 Prague 1 or electronically at info@czModels.cz.

9 Right to Contact the Office for Personal Data Protection

You have the right to approach the Office for Personal Data Protection (www.uoou.cz) with complaints about the processing of your personal data.