1. Introduction
Celvenza Agency ("we," "us," or "our") 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 capacity. This policy is designed in compliance with the Saudi Arabia Personal Data Protection Law (PDPL), Royal Decree M/19 dated 9/2/1443H (corresponding to September 16, 2021), and its implementing regulations.
By accessing our website or using our services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with its terms, please discontinue use of our website and services.
2. Data Controller
The data controller responsible for your personal data is:
- Company: Celvenza Agency
- Address: King Abdullah Financial District, Tower 3, Riyadh 12345, Saudi Arabia
- Email: [email protected]
- Phone: +966 11 555 7890
3. Personal Data We Collect
We may collect the following categories of personal data:
3.1 Information You Provide Directly
- Identity Data: Full name, date of birth, nationality, Saudi national ID number or Iqama number, gender
- Contact Data: Email address, phone number, postal address, social media handles
- Professional Data: Portfolio images, measurements, professional experience, skills, educational background
- Financial Data: Bank account details, payment information (for talent payroll and client billing)
- Communication Data: Any correspondence, inquiries, or feedback you send to us
3.2 Information Collected Automatically
- Technical Data: IP address, browser type and version, device type, operating system
- Usage Data: Pages visited, time spent on pages, click patterns, referral sources
- Cookie Data: Information collected through cookies and similar tracking technologies (see our Cookie Policy)
4. Legal Basis for Processing
Under the PDPL, we process your personal data on the following legal bases:
- Consent: Where you have given clear consent for us to process your personal data for specific purposes
- Contractual Necessity: Where processing is necessary for the performance of a contract with you
- Legitimate Interest: Where processing is necessary for our legitimate business interests, provided these do not override your fundamental rights
- Legal Obligation: Where processing is necessary to comply with Saudi laws and regulations
5. How We Use Your Personal Data
We use your personal data for the following purposes:
- Processing talent applications and managing our model roster
- Matching talent with client requirements and booking opportunities
- Processing payments and managing financial transactions
- Communicating about bookings, events, and service updates
- Marketing and promotional activities (with your consent)
- Improving our website, services, and user experience
- Complying with legal and regulatory obligations in Saudi Arabia
- Protecting our legal rights and preventing fraud
6. Data Sharing and Disclosure
We may share your personal data with:
- Clients: Professional portfolio data shared with potential booking clients (talent only, with consent)
- Service Providers: Third-party vendors who assist with IT, payment processing, photography, and other operational services
- Legal Authorities: When required by Saudi law, court order, or government regulation
- Business Partners: For joint events, campaigns, or collaborative projects (with appropriate data protection agreements)
We do not sell your personal data to third parties.
7. International Data Transfers
In accordance with the PDPL, personal data of Saudi residents is primarily stored and processed within Saudi Arabia. If transfer outside the Kingdom is necessary (e.g., for international bookings), we ensure adequate protection through:
- Ensuring the receiving country provides adequate data protection
- Implementing appropriate contractual safeguards
- Obtaining your explicit consent where required
- Complying with SDAIA (Saudi Data & Artificial Intelligence Authority) transfer guidelines
8. Data Retention
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including:
- Active talent profiles: Duration of representation agreement plus 3 years
- Client records: Duration of business relationship plus 5 years
- Financial records: 10 years as required by Saudi commercial law
- Website analytics: 2 years
- Marketing consent records: Until consent is withdrawn plus 1 year
9. Your Rights Under the PDPL
Under the Saudi Personal Data Protection Law, you have the following rights:
- Right to be Informed: Know what personal data we collect and why
- Right of Access: Request a copy of your personal data we hold
- Right to Correction: Request correction of inaccurate or incomplete data
- Right to Destruction: Request deletion of your personal data when no longer necessary
- Right to Withdraw Consent: Withdraw previously given consent at any time
- Right to Object: Object to processing for direct marketing purposes
- Right to Data Portability: Request your data in a structured, commonly used format
To exercise any of these rights, contact us at [email protected]. We will respond within 30 days.
10. Data Security
We implement appropriate technical and organizational measures to protect your personal data, including:
- SSL/TLS encryption for data in transit
- Encrypted storage for sensitive personal data
- Access controls and authentication measures
- Regular security assessments and audits
- Employee training on data protection practices
- Incident response procedures for data breaches
11. Data Breach Notification
In the event of a personal data breach that poses a risk to your rights, we will:
- Notify the Saudi Data & Artificial Intelligence Authority (SDAIA) without undue delay
- Inform affected individuals if the breach is likely to result in high risk
- Document all breaches and remedial actions taken
12. Children's Privacy
Our services are not directed at individuals under 18 years of age. We do not knowingly collect personal data from minors without verifiable parental or guardian consent. If you believe we have collected data from a minor without appropriate consent, please contact us immediately.
13. Changes to This Policy
We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated "Last updated" date. We encourage you to review this policy periodically. Material changes will be communicated via email or prominent website notice.
14. Contact & Complaints
For privacy-related inquiries or complaints:
- Email: [email protected]
- Phone: +966 11 555 7890
- Mail: Data Protection Officer, Celvenza Agency, KAFD Tower 3, Riyadh 12345
If you are not satisfied with our response, you have the right to lodge a complaint with the Saudi Data & Artificial Intelligence Authority (SDAIA).