This Privacy Notice explains the types of personal data we may collect about you when you interact with Agora Models. It also explains how we’ll store and handle that data, and keep it safe. We hope the following will answer any questions you have but if not, please get in touch with us.

Legal Basis

The law on data protection sets out a number of reasons which a company may collect & process your personal data, including:

Consent

In specific situations, we can collect and process your data with your consent. For example, when you tick a box to receive email newsletters.

Contractual obligations

In certain circumstances, we need your personal data to comply with our contractual obligations.
For example, if you order an item from us, we’ll collect your address details to deliver your purchase, and pass them to our courier.

Legal compliance

If the law requires us to, we may need to collect and process your data. For example, we can pass on details of people involved in fraud or other criminal activity.

Legitimate interest

In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.
For example, we will use your purchase history to send you or make available personalized offers.
We will also use your address details to send you direct marketing information by mail, telling you about products and services that we think might interest you.

When do we collect your data?

• When you visit any of our websites, and use your account to buy products.
• When you make an online purchase and check out as a guest (transaction-based data).
• When you create an account with us.
• When you purchase a product by phone but don’t have an account.
• When you engage with us on social media.
• When you join an Agora Models loyalty program
• When you contact us by any means with queries, complaints, assistance etc.
• When you ask us to email you information about a product.
• When you enter prize draws or competitions.
• When you choose to complete any surveys we send you.
• When you comment on or review our products.
• When you fill in any forms.
• When you’ve given a third party permission to share with us the information they hold about you.
• Browsing data related to services offered through the Site and collected through cookies, according to the Cookie Policy.

What personal data do we collect?

• If you have a web account with us: your name, gender, date of birth, billing/delivery address, orders and receipts, email and telephone number. For your security, we’ll also keep an encrypted record of your login password.
• Details of your interactions (e.g. notes from conversations) with us through contact centers, webchat, or online
• Copies of documents you provide to prove your age or identity where the law requires this.
• Details of any preferences that you give or set.
• Details of your visits to our website, and which site you came from to ours.
• Information gathered by the use of cookies in your web browser.
• Personal details which help us to recommend items of interest. For example, if you have purchased a car model, we may suggest other car models to you. We’ll only ask for and use your personal data collected for recommending items of interest and to tailor your shopping experience with us.
• Payment card information.
• Your comments and product reviews.
• To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered.
• Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.

How do we use your personal data?

We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you.
We then use this to offer you promotions, products and services that are most likely to interest you. In the case of loyalty scheme members, we’ll also offer you relevant rewards.
The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.
If you would like to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.
• To process any orders that you make by using our websites. If we don’t collect your personal data during checkout, we won’t be able to process your order and comply with our legal obligations.
• To allow you to register on the Site by creating a Personal Account; to perform all the activities regulated by the Terms of Use and the Terms and Conditions of the Site, including purchases on the Site; to enjoy all the services offered on the Site, including participation to online contests and games and customer services and to participate in the forum.
• To respond to your queries, refund requests and complaints. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
• To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest.
• To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
• When Users give their consent, to send newsletters, marketing communications through traditional and other means, including email, SMS, MMS, social network, instant messages, mobile applications, banner, fax, mail and phone, to promote and/or sell products and/or services. You are free to opt out of hearing from us by any of these channels at any time.
• To send you communications required by law or which are necessary to inform you about our changes to the services we provide you.
• To display the most interesting content to you on our website or apps, we’ll use data we hold about your favorite brands or products. We do so on the basis of your consent to receive app notifications and/or for our website to place cookies or similar technology on your device.
• To carry out activities which are functional to the transfer of branches, acquisitions, mergers, divisions or other changes and to perform such operations (defined as: “Legitimate Interest for Business Purposes”).
• To comply with our contractual or legal obligations to share data with law enforcement.
• For loyalty club members, to provide you with tailored offers based on an analysis of previous purchases, using computer algorithms. We do this on the basis of our legitimate interest to show you relevant offers. You are free to choose whether to take advantage of them.

Communication of Personal data

For the purpose of using your personal data, Agora Models may communicate users’ data, when strictly necessary, in the following instances:
a) Employees, collaborators and suppliers of Agora Models, within the performance of their tasks and/or contractual obligation and in relation to the commercial relations with the Users;
b) Sub-suppliers and/or subcontractors within the activities connected to the performance of services and products offered by Agora Models;
c) To Postal Offices and couriers to send and deliver products purchased by the Users and/or other materials related to the services offered by Agora Models;
d) To legal, administrative and fiscal consultants, within the limits of what is necessary or functional to the activities of Agora Models;
f) To financial institutions for the management of revenues and payments deriving from the performance of the contract with the User.
Personal Data of the Users can be freely transferred outside the national territory to other European Countries, but they may also be transferred outside the European Union, and in particular in United Kingdom, Australia, New Zealand, Norway, Japan and USA, Canada and Mexico.
Whenever Agora Models transfers personal data outside the United Kingdom, it will take reasonable steps and appropriate safeguards to keep the personal data safe.
Users will have the right to obtain a copy of the Data held abroad and to receive information on the place where the Data are kept, by asking directly to the Controller, through the contact details provided.

Security

We secure access to all transactional areas of our websites using ‘https’ technology.
Access to your personal data is password protected, and sensitive data is secured and tokenized to ensure it is protected.
We regularly monitor our system for possible vulnerabilities and attacks.

Your Rights

In relation to their personal data, the User will be able to exercise, with no additional charge and at any time, the following rights:
• To obtain confirmation as to whether or not personal data concerning the user is being processed, and, where that is the case, access to the personal data.
• To know the origin of the data, the purposes and the way in which they are processed and the logic applied to processing by automated means.
• To ask for the update, rectification or the integration of the data.
• To ask for the erasure, the anonymization or the blocking of data unlawfully processed or to object to the processing for legitimate reasons.
• To object, fully or partially, to the processing of data for purposes of direct marketing carried out either through automated or more traditional ways.
• To withdraw their consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
• In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation.
Users will be able, at any time, to exercise their right, to modify their contact details, to notify Agora Models of changes and updates regarding their data, to obtain further information by writing an email to the following address: customerservice@AgoraModels.com
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice.
If you have authorized a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

How long do we keep your data?

We will retain personal data for no longer that is necessary to fulfill the purpose for which data have been collected. Also, the following retention periods will apply for these specific purposes:
• Personal data collected for Contractual Purposes will be retained for the duration of the contract and for 10 years after its termination to exercise/defend a right of Agora Models, both in court and outside, where a claim should arise in relation to the contract.
• Personal data collected for Marketing Purposes of Agora Models shall be retained for the duration of the service provided, the participation to the contest and/or the collection; and for 2 years after the collection and/or the termination of the service offered.
• Personal data collected for Purposes of Marketing of Others and Profiling Purposes shall be retained for 12 months after the collection.
• Personal data collected for Purposes of Legitimate Interest of Marketing should be retained for all the duration of the registration of the User on the Site through his/her Account end/or the participation to an online contest end/or the collection and for 2 years after the cancellation/deactivation of the Account.
• Personal data collected for Purposes of Legitimate Interest of business will be retained for 10 years from the moment of their collection.