Privacy Policy

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1. Introduction

topgirlsbangkok.com ("we", "our", or "us"), located at Herengracht 420, 1017 BZ Amsterdam, the Netherlands, is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you visit our website, use our services, or interact with us in any way.

This policy is designed to comply with the General Data Protection Regulation (GDPR) (EU) 2016/679 and the Dutch Uitvoeringswet Algemene verordening gegevensbescherming (UAVG). By using our website and services, you acknowledge that you have read and understood this policy.

Data Controller: topgirlsbangkok.com
Contact: [email protected]
Data Protection Officer: [email protected]

2. Personal Data We Collect

We may collect and process the following categories of personal data:

2.1 Data You Provide Directly

  • Identity data: first name, last name, title, date of birth
  • Contact data: email address, phone number, postal address
  • Professional data: portfolio images, measurements, experience, agency history
  • Financial data: bank account details, invoicing information (for contracted talent only)
  • Communication data: content of emails, contact form submissions, and other correspondence
  • Event registration data: name, email, phone number when registering for events

2.2 Data Collected Automatically

  • Technical data: IP address, browser type and version, operating system, device type
  • Usage data: pages visited, time spent on pages, click patterns, referring URLs
  • Cookie data: as described in our Cookie Policy

3. Legal Basis for Processing

We process your personal data based on the following legal grounds under Article 6 of the GDPR:

  • Consent (Art. 6(1)(a)): When you have given explicit consent, such as subscribing to our newsletter or accepting cookies.
  • Contractual necessity (Art. 6(1)(b)): When processing is necessary to fulfil a contract with you or to take pre-contractual steps at your request, such as booking talent or managing your representation.
  • Legal obligation (Art. 6(1)(c)): When we must comply with a legal obligation, such as tax and financial reporting requirements.
  • Legitimate interest (Art. 6(1)(f)): When processing is necessary for our legitimate business interests, such as improving our services, marketing, and fraud prevention, provided these interests do not override your rights.

4. How We Use Your Data

We use personal data for the following purposes:

  • Processing talent bookings and client enquiries
  • Managing talent representation contracts and portfolios
  • Communicating about projects, events, and opportunities
  • Processing event registrations and sending confirmations
  • Sending marketing communications (with your consent)
  • Improving our website, services, and user experience
  • Complying with legal and regulatory obligations
  • Protecting against fraud and ensuring security

5. Data Sharing and Disclosure

We may share your personal data with the following categories of recipients:

  • Clients and partners: When necessary to fulfil bookings (e.g., sharing a model's portfolio with a client for casting purposes)
  • Service providers: Trusted third parties who assist in operating our website, payment processing, email delivery, and analytics
  • Legal authorities: When required by law, court order, or governmental regulation
  • Professional advisors: Lawyers, accountants, and insurers where necessary

We do not sell your personal data to third parties. All third-party service providers are contractually bound to process data only on our instructions and in compliance with GDPR.

6. International Data Transfers

Your data is primarily processed within the European Economic Area (EEA). If data is transferred outside the EEA, we ensure adequate protection through:

  • EU adequacy decisions
  • Standard Contractual Clauses (SCCs) approved by the European Commission
  • Other appropriate safeguards as required by Article 46 of the GDPR

7. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected:

  • Client and booking data: 7 years after the last transaction (in accordance with Dutch tax law)
  • Talent portfolios: Duration of representation plus 2 years
  • Contact form submissions: 2 years from submission
  • Event registrations: 1 year after the event
  • Website analytics: 26 months
  • Marketing consent records: Duration of consent plus 3 years

8. Your Rights Under GDPR

As a data subject, you have the following rights:

  • Right of access (Art. 15): Request a copy of your personal data
  • Right to rectification (Art. 16): Request correction of inaccurate data
  • Right to erasure (Art. 17): Request deletion of your data ("right to be forgotten")
  • Right to restriction (Art. 18): Request limitation of processing
  • Right to data portability (Art. 20): Receive your data in a structured, machine-readable format
  • Right to object (Art. 21): Object to processing based on legitimate interest or direct marketing
  • Right to withdraw consent (Art. 7(3)): Withdraw consent at any time without affecting the lawfulness of prior processing
  • Right to lodge a complaint: File a complaint with the Autoriteit Persoonsgegevens (Dutch Data Protection Authority) at [email protected]

To exercise any of these rights, please contact us at [email protected]. We will respond within 30 days.

9. Security Measures

We implement appropriate technical and organizational measures to protect your personal data, including:

  • SSL/TLS encryption for data in transit
  • Encrypted storage for sensitive data at rest
  • Access controls and authentication mechanisms
  • Regular security audits and vulnerability assessments
  • Staff training on data protection practices
  • Data breach response procedures in compliance with Articles 33 and 34 of the GDPR

10. Children's Privacy

Our services are not directed at individuals under the age of 16. We do not knowingly collect personal data from children under 16 without verifiable parental consent. If we discover we have collected data from a child under 16 without appropriate consent, we will delete it promptly.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by posting the new policy on our website and updating the "Last updated" date. We encourage you to review this policy periodically.

12. Contact Us

For any questions or concerns regarding this Privacy Policy or our data practices, please contact:

topgirlsbangkok.com
Email: [email protected]