Who are we?
London Sapphires are Data Controllers for purposes of the GDPR and Data Protection Act 2018 and are responsible for the manner the data you provide us with is processed.
We may collect the following Personally Identifiable Information, from you:
- date of birth;
- contact Information such as email addresses and telephone numbers;
- identification documents such as passport, citizen card and / or driving license;
- financial information such as bank account, credit / debit card numbers;
- IP address (automatically collected);
How we collect Data
We will collect your Data when:-
- when you contact us through the Website, via mobile applications, by telephone, post, e-mail or through any other means;
- when you register with us as a model;
- when you use our services;
Our use of Data
Any or all of the above data may be required by us from time to time in order to provide you with the best possible service. Data may be used by us for the following reasons:
- internal record keeping;
- user application process;
- age verification;
- country of residence verification;
When you register with us and set up an account to receive our services, the legal basis for processing is the performance of a contract.
Who we share Data with
We may share your Data with the following groups of people for the following reasons:
- Our third party service provider; AdultWork.com, who provide an advertisement service to us and you which requires the processing of personal data for proof of age and nationality in order to work in conjunction with their terms and conditions;
- Our bank in order to make payments.
- Our accountant
Keeping Data secure
We will use appropriate technical and organisational measures to protect your data, for example:
- access to your account is controlled by a password and a user name that is unique to you.
- we store your data on secure servers.
- A Data Privacy Officer (DPO) has been externally appointed.
If you suspect any misuse or loss or unauthorised access to your data, please let us know immediately by contacting us via email@example.com
We will retain any data you submit for the required time it takes to process the user application or until the user application is terminated.
Some data may persist on backup or archival media for legal, tax or regulatory purposes.
Your legal rights over your personal data
You have the rights under the data protection laws in relation to your personal data including:
Request access to your personal data (commonly known as a ‘data subject access request’). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or out of date data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no Business or legal reason for us continuing to process it.
Object to processing of your personal data. Where we are relying on a Legitimate Interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent. Where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
Please email us on via firstname.lastname@example.org requesting for Data Subject Access Request if you wish to exercise any of these rights.
No fee in most cases – You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. There is the possibility that we will refuse to comply with your request in these circumstances.
What we may need from you – to protect your personal data we will ask you to verify your identity before proceeding with your request to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
If you have authorised a third party to submit a request on your behalf, we will request proof that they have your permission to do so.
Time limit to respond – We will respond to all legitimate requests within 1 calendar month from the date of receipt of your request. Occasionally it may take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. Where you are sending us a request via post rather than email we recommend you send it via recorded delivery to guarantee safe delivery.
We take any complaints about our collection and use of personal information very seriously.
If you think that our collection or use of personal information is unfair, misleading or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance.
To make a complaint, please contact our data privacy officer.
Alternatively, you can make a complaint to the Information Commissioner’s Office:
- Report a concern online at https://ico.org.uk/concerns/
- Call 0303 123 1113
- Or write to: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
If you have any questions, concerns or would like more information about anything mentioned in this privacy notice, please contact our Privacy Officer: