Privacy Policy

Preamble

AE RÉSEAUX, operating under the commercial brands "ADOPTE UNE CONCIERGERIE" and "LES GRAINES NOBLES" (hereinafter "the Company" or "we"), is committed to protecting the privacy and personal data of all persons concerned by its activities.

This privacy policy is intended to inform candidates, models, mannequins, hosts and hostesses, as well as clients and visitors to our website (hereinafter "you"), about how we collect, use, retain and protect your personal data, in accordance with:

• Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data (GDPR)
• French Data Protection Act No. 78-17 of January 6, 1978, as amended
• Directive 2002/58/EC on privacy and electronic communications

Article 1 — Categories of Data Subjects

This policy applies to personal data collected from:

• Recruitment candidates: models, photo and video models, fashion models, reception hosts and hostesses, event hosts and hostesses, specialized personnel for fashion and luxury
• Registered providers: referenced models, regularly assigned staff
• Clients: companies, individuals, event organizers, agencies
• Website visitors

Article 2 — Personal Data Collected

2.1 Identification and contact data

• Title, surname, first name, stage name/pseudonym
• Date and place of birth, nationality
• Postal address, email address, phone number
• ID document number (for age and work eligibility verification)

2.2 Professional data and skills

• CV, cover letter, book, portfolio
• Previous professional experience, training, qualifications
• Specific skills (languages spoken, driving license, certifications)
• Professional references (with your consent)

2.3 Physical and visual data (specific to modeling)

• Photographs (portrait, full-length, profile), presentation videos
• Measurements: height, weight, bust, waist, hips (only if necessary for modeling)
• Shoe size, clothing size
• Eye color, hair color and length
• Distinctive physical features (only if relevant and with consent)

2.4 Financial and administrative data

• Bank details (IBAN/BIC for service payments)
• Social security number (for employees and intermittent workers)
• Professional status (employee, self-employed, intermittent entertainment worker)
• SIRET/SIREN number (for independents)
• Residence permit and work authorization (for non-EU nationals)

2.5 Presentation video selfie

As part of applications, we collect a 30-second video selfie to assess your presentation, speech and ease. This video is processed on the basis of your explicit consent and is retained in accordance with the periods specified in Article 6.

Article 3 — Purposes and Legal Bases of Processing

Your data is processed for the following purposes:

• Managing applications and recruitment of models, mannequins, hosts and hostesses
• Building and managing a profile database for staff placement
• Performing service contracts (staff provision, event organization)
• Verifying age and right to work
• Payroll management and social declarations
• Billing, accounting, unpaid debt management
• Anti-money laundering and counter-terrorism financing (AML-CTF/TRACFIN)
• Managing quote and contact requests
• Improving our services and anonymized statistics
• Communicating information about our services (with consent)

Article 4 — Sensitive Data

We do not, in principle, collect sensitive data within the meaning of Article 9 of the GDPR (racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic or biometric data, health data, sex life or sexual orientation).

Exception: In the specific context of modeling and artistic placement, certain information relating to physical appearance may be collected exclusively on the basis of your explicit consent and solely for matching your profile with proposed assignments.

Article 5 — Data Recipients

Your personal data may be communicated to the following categories of recipients:

5.1 Internal recipients

• Authorized Company personnel in charge of recruitment, assignment management and administration
• Management for placement-related decisions

5.2 External recipients

• Clients: limited transmission to information necessary for selection and assignment execution (first name, photos, relevant skills)
• Subcontractors and partners: technical service providers (web hosting, payment solutions, electronic signature), all bound by strict confidentiality clauses
• Social and tax bodies: URSSAF, pension funds, tax authorities (legal obligations)
• Public authorities: in case of legally founded judicial or administrative requisition
• TRACFIN: in case of suspicious activity report (AML-CTF)

5.3 Confidentiality commitment

All our subcontractors, employees and partners are bound by strict confidentiality and non-solicitation clauses. They may only use your data for expressly authorized purposes.

Article 6 — Data Retention Periods

We retain your data for the following periods:

• Unsuccessful applications: 2 years from last contact, unless objection or deletion request
• Active model/provider profiles: Duration of contractual relationship + 5 years (civil prescription)
• Completed assignment data: 5 years from end of assignment
• Accounting documents and invoices: 10 years (accounting obligation)
• Payroll data and pay slips: 5 years (social obligation)
• Electronically signed contracts: 10 years from complete contract execution
• AML-CTF data (identity verification): 5 years after end of business relationship
• Unsuccessful quote requests: 3 years
• Cookies and browsing data: 13 months maximum

At the end of these periods, data is deleted or irreversibly anonymized.

Article 7 — Data Security

We implement appropriate technical and organizational measures to ensure a level of security adapted to the risk, in accordance with Article 32 of the GDPR:

• Encryption: Data transmission via HTTPS/TLS protocol, encryption of sensitive data at rest
• Access control: Enhanced authentication, access rights management according to least privilege principle
• Physical security: Hosting on secure servers in the European Union
• Backups: Regular backups with restoration tests
• Awareness: Staff training on security and confidentiality best practices
• Audits: Periodic security reviews

In case of personal data breach likely to result in high risk to your rights and freedoms, we will notify you as soon as possible in accordance with Article 34 of the GDPR.

Article 8 — Data Transfers Outside the European Union

Your data is hosted and processed primarily within the European Union.

If transfer to a third country is necessary (e.g., use of a technical subcontractor), such transfer will only be made to countries recognized by the European Commission as ensuring an adequate level of protection, or on the basis of appropriate safeguards (European Commission standard contractual clauses, binding corporate rules).

Article 9 — Your Rights

In accordance with the GDPR and Data Protection Act, you have the following rights over your personal data:

Article 10 — Exercising Your Rights

To exercise your rights, you may contact us by:

We will respond within one month of receiving your request. This period may be extended by two additional months if necessary, given the complexity and number of requests.

For security reasons, we may ask you to prove your identity (copy of ID document).

Article 11 — Complaint to the CNIL

If you believe, after contacting us, that your rights are not respected or that processing of your data does not comply with regulations, you may lodge a complaint with the competent supervisory authority:

Article 12 — Cookies and Similar Technologies

Our website uses cookies to improve your browsing experience, analyze site usage and personalize content.

12.1 Types of cookies used

• Strictly necessary cookies: essential for site operation (authentication, security, language preferences)
• Performance/analytics cookies: measure audience and improve the site (with your consent)

12.2 Managing cookies

On your first visit, a banner informs you about cookie usage and allows you to accept or refuse non-essential cookies. You can change your preferences at any time via your browser settings.

Cookie lifespan does not exceed 13 months in accordance with CNIL recommendations.

Article 13 — Policy Modifications

We reserve the right to modify this privacy policy at any time, particularly to comply with legislative and regulatory changes or to reflect changes in our practices.

Modifications will be published on this page with the update date. In case of substantial modification, we will inform you by email or notification on our site.