U.S. WEBSITE PRIVACY INFORMATION NOTICE

This information notice describes the means and purposes of processing of personal information of users who visit this website (hereinafter “Website”).

The information here provided does not concern other websites, pages or online services which may be accessed through links on this website.

TYPES OF PERSONAL INFORMATION PROCESSED AND PURPOSES OF PROCESSING

Navigation Data

Through IT systems and the software installed for the functioning of this Website, we collect user data, some of which may be personal information, and which transmission is implicit in the usage of internet communication protocols.

Included in this category of data are: IP addresses, domain name system, Uniform Resource Identifier/Locator of the requested resources, the hour of the request, the method used to submit the request to the server, the size of file obtained as reply, the numbering code which indicates the status of the reply given by the server (success, error, etc.) and other information relating to the operating system and the IT environment of the user.

This data is processed to facilitate navigation of the Website and the usage of any services provided through the Website.

The same data is also processed to obtain statistical information regarding the usage of the Website and services (e.g. most visited pages, number of visitors for time slot or day slot, geographical area of the request etc.) and enhance the use of the services.

In order to obtain additional information regarding the types of cookies that are used and how to disable them, please read the dedicated section.

Data provided by the user

The optional and voluntary sending of messages to us through the contact link on the Website, or the submission of forms, will involve the collection and processing of your contact data and all the data contained in your message, which is also necessary for us to reply.

BASIS OF THE PROCESSING

We collect navigation data through the Website to enable effective navigation and to obtain statistical information regarding the use of the Website (most visited pages, number of visitors for time slot or day slot, geographical area of the request etc.), and to enhance the user experience.

We also collect data you provide on a voluntary basis when you send messages to us via the website, and we use that information to generate our reply.

RECIPIENTS OR CATEGORIES OF RECIPIENTS OF PERSONAL INFORMATION

Personal information will only be processed by the individuals expressly authorized by us.

If necessary for the above stated purposes, personal information may be communicated to and/or shared with third parties such as providers of goods and services, including IT services, hosting providers, IT companies, commercial partners and public authorities.

DATA RETENTION PERIOD

We will process personal information collected to allow navigation on the website until the end of the connection session, and for the time necessary to comply with legal obligations and/or to defend or exercise a right in court. We shall retain personal information provided on a voluntary basis by the user through sending messages to the contract addresses of the company for the time strictly necessary to reply to such messages and for the additional time to comply with legal obligations and/or to defend a right in court.

NATURE OF THE COMMUNICATION OF PERSONAL INFORMATION AND CONSEQUENCES OF THE FAILURE TO COMMUNICATE DATA

Communicating personal information on a voluntary basis through messages to contact us is allows us to reply. If that data is not provided, we could not reply. With reference to the consequences of the withdrawal of consent or removal of cookies, please see our cookie policy.

RIGHTS OF THE USERS

Depending on your jurisdiction, you may be entitled to certain rights, in particular, to:

- Know if we store/process personal information relating to you, and if so have access to it and obtain a copy of it;

- Obtain the rectification of data, if they are incorrect, or supplement them;

- Obtain the erasure of such data under certain conditions;

- Request us to restrict the processing only to certain categories of personal information, if any, subject to certain conditions;

- Request and receive personal information concerning the user in a structured format, or to have such data transmitted to another company;

- Object at any time to the processing of personal information.

To exercise your right you can contact us at privacy@thesocietymanagement.com.

CHILDREN UNDER THE AGE OF 13

This website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to the website or use services provided through the website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information through this website or on or through any services provided through the website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact privacy@thesocietymanagement.com.

CALIFORNIA PRIVACY RIGHTS

If you are a California resident, California law may provide you with additional rights regarding the use of your personal information. California's "Shine the Light" law (Cal. Civil Code Section § 1798.83) permits users of the website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact privacy@thesocietymanagement.com.

Privacy Shield Information

The Society Model Management Inc. complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. The Society Model Management Inc. has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit www.privacyshield.gov.

In compliance with the Privacy Shield Principles, The Society Model Management Inc. commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact The Society Model Management Inc. at: privacy@thesocietymanagement.com

The Society Model Management Inc. has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you. The Society Model Management Inc. Is committed to cooperating with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship.

The Society Model Management Inc. is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) Under certain conditions, there is a possibility for the individual to invoke binding arbitration The Society Model Management Inc. may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements

The Society Model Management complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

CHANGES TO THIS PRIVACY NOTICE

Notice of any changes to this privacy notice will be made through a notice that the privacy notice has been updated on the Website home page. If we make material changes to how we treat our users' personal information, we will notify users through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page.

Effective Date: This privacy notice is effective as of February 1st, 2019.