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© 2018 by Zsofi Kovacs. All rights reserved!

Privacy Policy

About this Privacy Policy

I know how important it is for you to understand how I use your data collected through my website. This Privacy Policy sets out how and why I collect, store, process and share your personal data. I will always be transparent with you about what I do with your personal data.
This Policy also tells you what your rights are in relation to the personal data you give me but - of course - If you have any questions about this Privacy Policy or your rights under it please contact me here.

My name is Zsofia Kovacs and I am the “data controller” of any personal data I may collect, process and hold about you, unless I inform you otherwise.



1. What personal data do I collect?

 

The personal data I may collect from you directly can include your name, email address, mobile/landline telephone number, address, and information you give me when you contact me, when you engage with my social media platform (for example by tagging me in a post on Instagram or Facebook) or when you sign up for a newsletter.
If you are using a mobile device I do not collect your IP address or any other device identifier, neither any other portable device information.



2. When do I collect your personal data?

 

* When you or your agent engage with me in an agreement for a co-operation online or over the phone;
* When you access my website or use my mobile App, however we do not use cookies;
* When you contact me or I contact you to take part in surveys or promotions;
* When you contact me online or over the phone;
* When you engage with me on social media (by mentioning/tagging me or by contacting me directly).

 

 

 


3. How do I use your personal data and what are my legal justifications for doing so?

To make my services available to you
I use your personal data to provide you with the information and services that you request from me (i.e. to complete certain tasks, processes or orders on my website or within my app, take payment online - where applicable - and deliver those services), and to communicate with you regarding those services that you purchase from me and respond to your questions and comments;
  
I may also use your personal data to measure how satisfied my customers are and provide customer service (including troubleshooting in connection with your requests for services or when you ask me questions on social media);
  
I rely on our contractual arrangements with you as the lawful basis on which I collect and process your personal data when you make an order for my services. Alternatively, in some cases, I rely on my legitimate interests as a business (for example, to measure customer satisfaction and troubleshoot customer issues). Where I rely on my legitimate interests, I will always make sure that I balance these interests against your rights.


For administrative and internal business purposes
I may use your personal data for my internal business purposes, such as enhancing  my site, improving my services and products and identifying trends. I may also use your data to monitor the use of my website and ensure that my website is presented in the most effective and relevant manner for you and your device;

It is in my legitimate interests as a business to use your personal data in this way. For example, I want to ensure my website is customer friendly and works properly and that my services are efficient and of high quality. I also want to make it easy for you to interact with me. Where I rely on my legitimate interests, I will always make sure that I balance these interests against your rights.


For security and legal reasons
I use your personal data to:
* ensure the personal and financial information you provide me is accurate;
* conduct fraud checks or prevent other illegal activity;
* protect my rights or property (or those of others);
* fulfill my legal and compliance-related obligations.
In some cases I will use your personal data because it's necessary for me to comply with a legal obligation (such as if I receive a legitimate request from a law enforcement agency). In other cases (such as the detection of fraud) I will rely on my legitimate interests as a business to use your personal data in this way. Where I rely on my legitimate interests, I will always make sure that I balance these interests against your rights.


To personalize your shopping experience and improve my operations
I use your personal data to:
* provide you news about my services you may be interested in;
* provide you with marketing material via Email.
When I may send you marketing material via SMS and email, I will rely on my legitimate interests as a business, always ensuring that your rights are protected.



4. Who do we share your personal data with?


I will never sell any of your personal data to a third party. However, in order for me to be able to provide my services to you, I may share your personal data with my trusted third party service providers (like a professional model agent). Whenever I share your personal data, I put safeguards in place which require these organization(s) to keep your data safe and to ensure that they do not use your personal data for their own marketing purposes.

Third party service providers: To fulfill orders for services
I work with a number of trusted model agencies and agents who carry out services on my behalf. When you purchase a service from me, the services provided by these organizations may include delivery, transportation and processing payments. It is in my legitimate interest as a business to work with these service providers since I may not have the capabilities to provide these services myself. In each case, I will ensure that the service provider is only allowed to use your personal data in order to provide the services to me and for no other purpose.
  
To prevent crime and comply with laws
I may share your financial information with third parties to ensure that your payment is safe and that your details are not being used fraudulently. This data sharing enables me to conduct fraud analysis which ensures that genuine and accurate payment details are provided to me for any purchase. I may share your information with credit agencies to make sure about your credibility.
  
There may be other scenarios where I am subject to a legal obligation to share or disclose your personal data, such as with law enforcement agencies or public authorities in order to prevent or detect crime or fulfill a legal requirement.


Other professional services
I may need to disclose your personal data to my insurer where I believe that it is required under our contractual relationship with my insurance provider to do so.
I work with carefully selected third parties, such as my delivery, transport or financial institution who assists me in providing you with a positive customer experience.

  
Transfer of your personal data outside the EEA
I never transfer your personal data outside of the European Economic Area (EEA).

 


5. Your rights
  
You have a number of rights relating to your personal information and what happens to it. You are entitled to:
* have your data processed in a fair, lawful and transparent way;
* be informed about how your personal data is being used, an example being this privacy policy;
* access personal data I hold about you;
* require me to correct any mistakes in your personal data;
* ask me to delete personal data concerning you in certain situations where there is no good reason for me to continue to process it;
* request that I transfer your personal data to you or another service provider in a simple, structured format;
* object at any time to processing of your personal data for direct marketing purposes;
* object to automated decision making which produces legal effects concerning you or similarly significantly affects you;
* object in certain other situations to the continued processing of your personal data;
* otherwise restrict or temporarily stop my processing of your personal data in certain circumstances.

You can read more about your rights and the new General Data Protection Regulation (GDPR), including the circumstances in which they apply, by visiting https://gdpr-info.eu
If you would like to speak to us in relation to any of your rights, please contact me here.



6. Changing your preferences
  
If you no longer wish to be contacted by me about my services, or for other marketing purposes, you can amend your preferences or unsubscribe by contacting me.
I want to ensure that all the information I have about my customers is factually correct and up to date. If you find that the personal data I have about you is inaccurate or needs updating (for instance, you may have changed your name or address) then please contact me so that I can correct it.



7. Security and retention of your personal data
  
Security of your personal data
I take the security of your personal data very seriously. I have implemented various strategies and controls to keep your data secure and keep these measures under close review. I protect your data by using encryption techniques and I use other safeguards such as firewalls and password protection. This means that your data is protected and only accessible by me. I also ensure that there are strict physical controls in my building which restricts access to your personal data to keep it safe.
  
Retention of your personal data
In broad terms, I will only retain your personal data for as long as is necessary for the purposes described in this Privacy Policy. This means that the retention periods will vary according to the type of the data and the reason that I have the data in the first place.
I have procedures in place regarding our retention periods which I keep under review taking into account my reasons for processing your personal data and the legal basis for doing so.



8. Changes to this Privacy Policy
  
I may update this Privacy Policy from time to time. If I make significant changes I will let you know, but please regularly check this policy to ensure you are aware of the most updated version.
This Privacy Policy was last updated on 25th of May 2018.