1. Data Controller

The data controller responsible for the processing of personal data collected through this website is MD Model Academy:

MD Model Academy – Marina Dokic
Operational Headquarters of MD Model Academy: Via Ercole Oldofredi 41, 20124 Milan, Italy
Registered Office of the Data Controller: Corso Garibaldi 105, 20121 Milan, Italy
Tax Code: DKCMRN94L65Z158W
 

email: info@mdmodelacademy.com
 

To exercise their rights or request information regarding the processing of personal data, data subjects may contact the Data Controller at the email address indicated above.

The Data Controller has not appointed a Data Protection Officer (DPO), as the legal requirements for mandatory appointment do not currently apply.

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2. Categories of personal data processed

 

2.1 Identification and contact data

first and last name;

email address and telephone number;

city of residence or domicile;

date of birth and age;

details of a parent or legal guardian, where applicable;

information voluntarily entered in the forms.

 

2.2 “Get Scouted” application data

identification and contact data;

height, body measurements, clothing size, shoe size and profile characteristics;

professional experience and current agency, where applicable;

interest in a Mother Agency or Booking Agency;

social profiles, online portfolio or website;

natural face and full-body photographs;

other information provided by the applicant.

Photographs are personal data when they make a person identifiable. Users are requested not to include health data or other special categories of personal data that are not requested or necessary for the application.

 

2.3 Online consultation data

first and last name, email address and telephone number;

booking date and time;

topic or purpose of the consultation;

communications exchanged before or after the meeting;

details required for receipts or invoices;

technical data connected with the use of Zoom.

Online consultations are not recorded.

 

2.4 Payment data

identification and billing data;

transaction amount, date, status and identifier;

data required for administrative and tax obligations.

Payments may be made by PayPal, Apple Pay and credit or debit card. Full card details are not normally processed directly by MD Model Academy, but by the payment service provider used through Wix.

 

2.5 Browsing data

IP address;

device type, operating system and browser;

date and time of the visit;

pages viewed and referring URL;

online identifiers and data collected through cookies or similar technologies.

 

3. Purposes, legal bases and retention periods

 

3.1 Contact requests

Purpose: Data submitted through contact forms are processed to reply to requests, provide information and assistance, and manage any subsequent communications.

Legal basis: Performance of pre-contractual measures requested by the data subject.

Retention: Up to 12 months after the request has been completed, unless a contractual relationship is established or longer retention is required to protect legal rights.

 

3.2 “Get Scouted” applications

Purpose: Data, information and photographs are processed to receive and assess the application, check the completeness of the materials, contact the applicant, request additional information, organise interviews, open castings or scouting activities, and assess whether the profile is suitable for MD Model Academy’s activities.

Legal basis: Performance of pre-contractual measures taken at the applicant’s request.

Retention: For the time required to assess the application and in any event no longer than 12 months after the assessment has ended, unless consent is given for future opportunities.

 

3.3 MD Model Database and future opportunities

Purpose: With specific consent, the profile may be stored in the MD Model Database and MD Talent Network for future scouting opportunities, castings, courses, professional development programmes or requests from partner agencies.

Legal basis: The data subject’s consent.

Retention: Up to 24 months from the application or the last profile update. At the end of this period, the data will be deleted, anonymised or retained only after obtaining renewed consent.

 

3.4 Possible disclosure to partner agencies

Purpose: If this service is activated in the future and the profile is suitable for a specific opportunity, MD Model Academy may present data, measurements, photographs, portfolio and contact details to selected model management or booking agencies. Disclosure will take place only within the purposes described in this Policy and on the basis of the consents collected.

Legal basis: Performance of the requested service and, for future opportunities, the data subject’s consent.

Retention: For the time required to manage the specific opportunity and in accordance with the retention periods applicable to the MD Model Database.

 

3.5 Paid online consultation

Purpose: Data are processed to manage availability, booking through Wix Bookings, confirmations, reminders, payment, delivery of the Zoom link, the consultation itself, follow-up materials, cancellations, rescheduling and assistance.

Legal basis: Performance of a contract or pre-contractual measures.

Retention: Booking data and communications: up to 24 months after the consultation. Tax and administrative records: for the period required by law, generally 10 years.

 

3.6 Newsletter and marketing communications

Purpose: With consent, data are processed through Wix Email Marketing to send information about scouting, open castings, courses, consultations, events, development programmes and promotions.

Legal basis: The data subject’s consent.

Retention: Until consent is withdrawn and in any event no longer than 24 months after the last meaningful interaction, unless consent is renewed.

 

3.7 Analytics

Purpose: With consent, browsing data are processed through Google Analytics to measure traffic, analyse use of the website and improve content and features.

Legal basis: User consent collected through Usercentrics.

Retention: According to the retention settings configured in the service and the cookie preferences.

 

3.8 Security and protection of rights

Purpose: Data may be processed to ensure website security, prevent misuse or fraud, handle disputes and protect the Controller’s rights.

Legal basis: The Controller’s legitimate interests.

Retention: For the time necessary to manage the event and in accordance with the applicable limitation periods.

 

3.9 Legal obligations

Purpose: Data may be processed to comply with administrative, tax, accounting, judicial or public authority requirements.

Legal basis: Compliance with a legal obligation.

Retention: For the periods required by applicable law.

 

4. Provision of personal data

 

Providing data marked as mandatory is necessary to submit requests and applications or to book a consultation. Failure to provide such data prevents MD Model Academy from supplying the requested service. Consent for newsletters, marketing communications and retention of the profile for future opportunities is optional and may be withdrawn at any time.

 

5. Applicants under the age of 18

 

The “Get Scouted” programme is available from the age of 16. Applicants aged 16 or 17 must submit their application with the knowledge and authorisation of a parent or legal guardian. MD Model Academy may request the parent’s or guardian’s contact details and direct confirmation before arranging meetings, castings, professional activities or disclosure to agencies.

Authorisation to submit an application does not automatically authorise publication of the minor’s photographs or videos. Any public or promotional use requires a separate release.

 

6. Photographs, videos and image rights

 

Photographs submitted through “Get Scouted” are used solely to identify and assess the applicant and, where applicable, to present the profile to partners within the stated purposes.

Uploading photographs does not automatically authorise MD Model Academy to publish them on the website, social media, advertising campaigns or promotional materials. Such use requires a separate and specific image release; for minors, the parent’s or guardian’s authorisation is required.

 

7. Wix, Wix Bookings and Wix Email Marketing

 

The website is built and hosted through Wix. Wix may process data on behalf of MD Model Academy in connection with hosting, forms, CRM, Wix CMS, bookings through Wix Bookings, communications through Wix Email Marketing, security, technical management and payments.

Data entered into forms may be stored in Wix systems and its CRM. Wix governs its processing through its contractual and privacy documentation.

 

8. Consultations via Zoom

 

Consultations are provided through Zoom. To enable participation, the displayed name, email address, IP address, device identifiers, connection data, audio, video and chat messages may be processed.

Consultations are not recorded. Zoom processes data under its own privacy policy and may carry out international processing subject to the safeguards required by applicable law.

 

9. Live Chat Chatway

 

The website uses Live Chat Chatway to allow users to communicate with MD Model Academy. The chat may process the user’s name, contact details, message content, date and time, IP address and technical data. The service is configured through Usercentrics and is activated according to the user’s consent preferences.

 

10. Cookies, Google Analytics and Usercentrics

 

The website uses cookies and similar technologies that are necessary for operation and, with consent, for analytics, functionality and advertising purposes.

Wix CMS and Usercentrics for Wix: essential components;

Google Analytics, Google Tag Manager and Google Tag Services: tools activated according to the category and consent preferences configured;

Live Chat Chatway: third-party service activated according to the user’s preferences.

Usercentrics for Wix is used to display the cookie banner, collect and record preferences, block non-essential services before consent, and allow users to change or withdraw their choices.

Users can manage their preferences at any time through the “Manage cookie preferences” link available on the website. Further details about individual services and retention periods are available in the Cookie Policy and Usercentrics preference panel.

 

11. Recipients of personal data

 

authorised MD Model Academy personnel and collaborators;

teachers and consultants involved in providing the services;

Wix, Usercentrics, Zoom, Chatway and technical providers;

payment service providers, including PayPal and the entities processing Apple Pay and card transactions;

email and newsletter providers;

accountants, legal advisers and technical consultants;

model management or booking agencies, only when the service is activated and in accordance with this Policy and the consents collected;

public authorities or other parties where disclosure is required by law.

Personal data are not sold.

 

12. International data transfers

 

Some providers may process data outside the European Economic Area. Depending on the provider, transfers take place on the basis of adequacy decisions, the Data Privacy Framework, Standard Contractual Clauses or other safeguards under Articles 44 et seq. of the GDPR.

 

13. Processing methods and security

 

Data are processed by electronic means and, where necessary, on paper, in accordance with the principles of lawfulness, fairness, transparency, data minimisation, accuracy, storage limitation, integrity and confidentiality. Reasonable technical and organisational measures are adopted to protect personal data against loss, unauthorised access, unlawful use, alteration, disclosure or destruction.

 

14. Automated decision-making

 

MD Model Academy does not make decisions based solely on automated processing that produce legal or similarly significant effects. Applications are assessed with the involvement of authorised individuals.

 

15. Data subject rights

 

Data subjects may exercise the rights provided by Articles 15-22 of the GDPR, including access, rectification, erasure, restriction, objection, portability, withdrawal of consent and information about recipients and international transfers.

Requests may be sent to info@mdmodelacademy.com. The Controller may request information necessary to verify the requester’s identity and will respond within the time limits laid down by law.

 

16. Right to lodge a complaint

 

Data subjects may lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) or with the competent supervisory authority in the European country where they reside, work or believe the infringement occurred.

 

17. External links

 

The website may contain links to social networks, agencies, video platforms or other external services. Processing carried out by those parties is governed by their respective privacy policies.

 

18. Changes to this Privacy Policy

 

This Privacy Policy may be updated to reflect legal, technical or organisational changes or changes to the services used. The updated version will be published on this page with the revision date.

 

19. Contact details

 

For requests concerning this Privacy Policy or the processing of personal data:

 

info@mdmodelacademy.com