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PRIVACY POLICY

Last Updated: August 2026

ABOUT THIS PRIVACY POLICY

Noemi James Management Ltd (“Noemi”, “we”, “us” or “our”) respects your privacy and is committed to protecting personal information.

This Privacy Policy explains how Noemi collects, uses, stores, shares and protects personal information when you:

  • visit or interact with our website;

  • contact Noemi;

  • submit an enquiry;

  • apply or express an interest in representation;

  • apply for a role or opportunity with Noemi;

  • communicate with members of our team;

  • work or seek to work with Noemi as a Client, creative, supplier or professional contact; or

  • otherwise interact with our business.

Additional privacy information may apply to particular relationships. Models represented by Noemi should also read our Model Privacy Notice, which provides more detailed information about how personal information is processed during representation, development, Bookings and Placements.

This Policy is intended to operate in accordance with applicable UK data-protection law, including the UK General Data Protection Regulation (UK GDPR), Data Protection Act 2018 and Data (Use and Access) Act 2025, together with other applicable privacy and electronic-communications requirements.

WHO WE ARE

The data controller responsible for personal information covered by this Policy is:

Noemi James Management Ltd
Company Number: 16949188

Email: info@noemijamesmgmt.com

Noemi James Management Ltd determines why and how personal information covered by this Policy is processed.

WHO THIS POLICY APPLIES TO

This Policy may apply to personal information concerning:

  • Website visitors;

  • prospective Models;

  • individuals making representation enquiries;

  • Clients and prospective Clients;

  • casting professionals;

  • photographers, stylists and other creatives;

  • Receiving Agencies and other modelling or talent agencies;

  • suppliers and service providers;

  • job, internship and work-experience applicants;

  • members of Noemi's professional network;

  • individuals contacting Noemi; and

  • other people interacting with our business.

Represented Models are additionally covered by Noemi's Model Privacy Notice.

INFORMATION WE MAY COLLECT

The information we collect depends upon how you interact with Noemi.

INFORMATION YOU PROVIDE TO US

We may collect information such as:

  • full name;

  • email address;

  • telephone number;

  • business or professional contact information;

  • social-media handles;

  • city, location or address where relevant;

  • information contained in enquiries and correspondence;

  • information submitted through Website forms;

  • application information;

  • professional experience;

  • CVs and portfolios;

  • photographs and professional materials;

  • model measurements and appearance information where relevant to an application;

  • agency representation information;

  • availability;

  • information concerning a proposed Booking, collaboration or project;

  • company or Client information; and

  • other information you choose to provide.

We ask that you do not provide sensitive personal information unless it is genuinely necessary and appropriate for the relevant purpose.

MODEL APPLICATIONS AND SCOUTING

Where Noemi accepts applications or considers prospective Models, we may collect information including:

  • name;

  • age and date of birth;

  • contact details;

  • location;

  • height and measurements;

  • photographs and digitals;

  • social-media or portfolio information;

  • previous modelling experience;

  • previous or existing representation; and

  • information provided as part of the application or assessment process.

Noemi currently accepts applications from and represents individuals aged 18 and over only.

Applicants must provide accurate information concerning their age and date of birth.

Where an individual progresses into representation with Noemi, further information will be collected and processed in accordance with our Model Privacy Notice and applicable representation documentation.

Submitting an application does not guarantee representation, a meeting, development, Booking or Placement.

CLIENTS, CASTING PROFESSIONALS AND INDUSTRY CONTACTS

Where you interact with Noemi in a professional capacity, we may process:

  • your name;

  • job title;

  • organisation;

  • professional email address;

  • telephone number;

  • professional social-media information;

  • correspondence;

  • Booking enquiries;

  • briefs;

  • casting information;

  • rates and commercial negotiations;

  • contractual information;

  • invoices and payment records; and

  • records relating to our professional relationship.

We may retain appropriate records of professional relationships and communications for legitimate business, contractual, accounting and legal purposes.

JOB, INTERNSHIP AND TEAM APPLICATIONS

Where you apply to work with Noemi, we may process information including:

  • your name and contact information;

  • CV;

  • education;

  • employment history;

  • portfolio;

  • professional experience;

  • skills;

  • references where appropriate;

  • interview information;

  • availability;

  • correspondence; and

  • other information supplied as part of your application.

Information concerning successful applicants may subsequently be processed under separate staff, contractor or team privacy arrangements where appropriate.

INFORMATION COLLECTED THROUGH OUR WEBSITE

Our Website is built and hosted using Wix.

When you access or interact with the Website, information may be collected automatically by Wix and/or technologies operating through the Website.

Depending upon your device, settings, consent choices and the Website functionality being used, this may include:

  • IP address;

  • browser type;

  • device information;

  • operating system;

  • approximate geographic information;

  • referring Website or source;

  • pages visited;

  • date and time of visits;

  • Website interactions;

  • session information;

  • cookie identifiers; and

  • Website performance and diagnostic information.

The use of cookies and similar technologies is explained further in our Cookie Policy.

Where consent is required for non-essential cookies or similar technologies, those technologies should only operate after the appropriate consent has been provided.

INFORMATION WE RECEIVE FROM OTHER SOURCES

Noemi may sometimes receive personal information from sources other than the individual concerned.

These may include:

  • Clients;

  • casting directors;

  • Receiving Agencies;

  • modelling and talent agencies;

  • photographers and other creatives;

  • professional referrals;

  • professional industry platforms;

  • publicly accessible professional websites;

  • social-media platforms;

  • suppliers and service providers; and

  • other legitimate professional sources.

Where information is obtained from another source, Noemi will provide appropriate privacy information where required.

The ICO currently states that where personal information is obtained indirectly, privacy information generally needs to be provided within a reasonable period and no later than one month, subject to applicable exceptions.

HOW WE USE PERSONAL INFORMATION

Noemi may use personal information to:

OPERATE OUR WEBSITE

Including to:

  • provide Website functionality;

  • maintain security;

  • identify technical problems;

  • understand Website performance;

  • improve Website content and usability; and

  • administer cookie preferences.

RESPOND TO ENQUIRIES

Including to:

  • respond to general enquiries;

  • respond to Client enquiries;

  • consider collaboration requests;

  • respond to agency or placement enquiries; and

  • maintain appropriate records of communications.

ASSESS MODEL APPLICATIONS

Including to:

  • determine eligibility;

  • assess potential suitability for representation;

  • review photographs and professional information;

  • communicate with applicants;

  • arrange meetings or interviews where appropriate; and

  • maintain appropriate application records.

REPRESENT AND PROMOTE MODELS

Where an individual becomes represented by Noemi, information may be used for representation, development, submissions, Bookings, promotion and Placements as explained more fully in our Model Privacy Notice.

ADMINISTER CLIENT RELATIONSHIPS AND BOOKINGS

Including to:

  • receive and respond to briefs;

  • identify suitable Models;

  • arrange castings and Bookings;

  • negotiate commercial arrangements;

  • administer contracts and usage;

  • issue invoices;

  • manage payments; and

  • maintain professional records.

RECRUIT AND MANAGE OUR TEAM

Including to:

  • consider applications;

  • communicate with candidates;

  • conduct interviews;

  • assess suitability;

  • manage recruitment; and

  • maintain appropriate recruitment records.

PROTECT NOEMI AND COMPLY WITH LAW

Including to:

  • maintain business records;

  • protect our Website and systems;

  • prevent fraud and misuse;

  • investigate complaints;

  • manage disputes;

  • establish, exercise or defend legal claims;

  • comply with regulatory requirements; and

  • respond to lawful requests from authorities.

OUR LAWFUL BASES

Noemi will only process personal information where we have an appropriate lawful basis.

Depending upon the circumstances, this may include:

CONTRACT

Where processing is necessary to take steps at an individual's request before entering into a contract or to perform a contract.

For example, this may apply to representation arrangements, Client Bookings, professional services or supplier relationships.

LEGAL OBLIGATION

Where processing is necessary for Noemi to comply with applicable law or regulatory requirements.

LEGITIMATE INTERESTS

Where processing is necessary for Noemi's legitimate business interests or those of another person, provided those interests are not overridden by the individual's rights and interests.

Our legitimate interests may include:

  • operating and developing Noemi;

  • responding to professional enquiries;

  • assessing appropriate applications;

  • maintaining professional relationships;

  • managing our roster;

  • maintaining Client and industry relationships;

  • improving our Website and services;

  • maintaining appropriate business records;

  • protecting our business and systems;

  • preventing fraud and misuse;

  • managing disputes and complaints; and

  • establishing, exercising or defending legal claims.

CONSENT

Where appropriate, we may rely upon consent.

This may include certain marketing communications, cookies or particular optional uses of information.

Where we rely upon consent, you may withdraw it at any time. Withdrawal does not affect processing lawfully carried out before consent was withdrawn.

Submitting a form to Noemi does not mean that consent is automatically the lawful basis for every subsequent use of the information submitted.

The ICO requires organisations to explain the applicable lawful bases and, where legitimate interests are relied upon, the interests being pursued.

SPECIAL CATEGORY PERSONAL INFORMATION

Certain information receives additional protection under UK data-protection law.

This may include information concerning:

  • health or disability;

  • racial or ethnic origin;

  • religious or philosophical beliefs;

  • political opinions;

  • trade-union membership;

  • genetic or biometric information used for identification;

  • sex life; or

  • sexual orientation.

Noemi does not seek to collect unnecessary special category information through its general Website.

Where such information is genuinely necessary and processed by Noemi, we will identify both an appropriate lawful basis and an applicable special-category processing condition.

Access and use will be limited appropriately.

MARKETING

Noemi may occasionally communicate with professional contacts about our services, Models, Agency developments or relevant professional opportunities where permitted by law.

Where consent is required for a particular form of direct marketing, we will obtain the appropriate consent.

You may opt out of marketing communications at any time using an unsubscribe facility where provided or by contacting us.

Operational communications relating to an existing enquiry, Booking, contract or professional relationship are not necessarily marketing communications.

WHO WE MAY SHARE INFORMATION WITH

Noemi does not sell personal information.

Where appropriate and lawful, personal information may be shared with:

  • Clients and prospective Clients;

  • casting directors and casting professionals;

  • production companies;

  • photographers, stylists and other professional creatives;

  • Receiving Agencies and other modelling or talent agencies;

  • professional advisers;

  • accountants and bookkeepers;

  • insurers;

  • payment providers;

  • website, email, cloud-storage and IT providers;

  • contractors and authorised members of the Noemi team;

  • regulators;

  • courts;

  • law enforcement; and

  • public authorities where required or permitted by law.

We seek to share only information reasonably necessary for the relevant purpose.

Where another organisation processes information on Noemi's behalf, appropriate contractual and organisational measures will be used where required.

WIX AND SERVICE PROVIDERS

Noemi uses Wix to provide Website hosting and related functionality.

Information processed through the Website may therefore be processed using Wix's infrastructure and services.

We may also use other providers for functions such as:

  • business email;

  • cloud storage;

  • forms;

  • analytics;

  • accounting;

  • payment administration;

  • document management; and

  • other business systems.

The particular providers used by Noemi may change as the Agency develops.

Where service providers process personal information on our behalf, we will take reasonable steps to use providers capable of meeting applicable data-protection requirements.

INTERNATIONAL TRANSFERS

Noemi operates within an international industry.

Personal information may therefore be transferred outside the United Kingdom where necessary, including where:

  • a Model is submitted to an international Receiving Agency;

  • an international Client or casting professional considers a Model;

  • Noemi works with an international professional partner; or

  • a technology or service provider processes information internationally.

Where UK personal information is transferred internationally, Noemi will use an appropriate transfer mechanism where required by law.

This may include:

  • UK adequacy regulations;

  • recognised contractual safeguards;

  • the International Data Transfer Agreement;

  • the UK Addendum to approved contractual clauses; or

  • another lawful transfer mechanism.

Further information about applicable safeguards may be requested from Noemi.

The ICO requires privacy information to explain international transfers and relevant safeguards where applicable.

HOW LONG WE KEEP PERSONAL INFORMATION

Noemi does not intend to retain personal information indefinitely.

Information will be retained for as long as reasonably necessary for the purpose for which it was collected and to satisfy applicable legal, regulatory, contractual, accounting and legitimate business requirements.

Retention periods will depend upon the type of information and relationship involved.

For example:

Website enquiries may be retained for as long as reasonably necessary to respond to and maintain an appropriate record of the enquiry.

Model applications may be retained for an appropriate period following the application and subsequently deleted or anonymised where no longer required, subject to applicable legal record-keeping requirements.

Represented Model information may be retained throughout representation and for appropriate periods afterwards, as explained further in the Model Privacy Notice.

Client, Booking, contractual, financial and accounting records may be retained for applicable legal, tax, regulatory and evidential periods.

Recruitment information relating to unsuccessful candidates will be periodically reviewed and deleted where it is no longer reasonably necessary.

Information may be retained for longer where reasonably necessary because of an outstanding payment, complaint, dispute, investigation, legal claim or regulatory requirement.

Where personal information is no longer required, it will be securely deleted, anonymised or otherwise appropriately disposed of.

HOW WE PROTECT PERSONAL INFORMATION

Noemi uses appropriate technical and organisational measures designed to protect personal information against:

  • unauthorised access;

  • accidental loss;

  • inappropriate disclosure;

  • misuse;

  • alteration; and

  • destruction.

Measures may include:

  • access controls;

  • password protection;

  • multi-factor authentication where appropriate;

  • restricted access to sensitive information;

  • appropriate cloud and business systems;

  • internal confidentiality requirements; and

  • separation of particularly sensitive identity and financial information from ordinary operational records.

Access to personal information should be limited to members of Noemi's team and service providers who reasonably require it for their role or service.

No system can guarantee absolute security, but Noemi will maintain measures proportionate to the nature and risks of the information processed.

YOUR DATA-PROTECTION RIGHTS

Depending upon the circumstances and lawful basis involved, you may have rights including:

Access — to request information about personal data Noemi holds about you and obtain a copy.

Rectification — to ask us to correct inaccurate information or complete incomplete information.

Erasure — to request deletion of personal information in certain circumstances.

Restriction — to request restriction of processing in certain circumstances.

Data Portability — to receive certain information in a structured, commonly used and machine-readable format where the right applies.

Withdrawal of Consent — where processing is based on consent, to withdraw that consent at any time.

Automated Decision-Making Rights — rights may apply where significant decisions are made solely through automated processing.

Noemi does not currently intend to make solely automated decisions producing legal or similarly significant effects regarding Model representation or professional selection.

These rights are not absolute and may apply differently depending upon why information is being processed.

The ICO requires organisations to explain the rights available to individuals and specifically requires the right to object to be brought clearly and separately to people's attention.

YOUR RIGHT TO OBJECT

You have the right to object to certain processing of your personal information where Noemi relies upon legitimate interests.

You also have the right to object to the use of your personal information for direct marketing.

Where you object to other legitimate-interest processing, Noemi will consider your request and whether there are compelling legitimate grounds or other lawful reasons for the processing to continue.

To object, contact info@noemijamesmgmt.com.

EXERCISING YOUR RIGHTS

If you wish to exercise a data-protection right or ask a question about personal information Noemi holds about you, contact:

info@noemijamesmgmt.com

Please provide enough information for us to identify the relevant records and understand your request.

Noemi may request reasonable evidence of identity where necessary before disclosing personal information.

We will respond within the timescale required by applicable law.

PROVIDING PERSONAL INFORMATION TO NOEMI

Some information may be necessary for Noemi to:

  • respond to an enquiry;

  • assess an application;

  • enter into a contract;

  • provide representation;

  • administer a Booking;

  • process a payment; or

  • comply with a legal requirement.

Where required information is not provided, we may be unable to proceed with the relevant application, service, Booking, representation or other professional relationship.

Where information is optional, we will seek to make this clear where appropriate.

COOKIES AND SIMILAR TECHNOLOGIES

Our Website uses cookies and similar technologies.

Some technologies are necessary for Website operation and security. Others may support analytics, functionality or marketing and may require consent before they are used.

Please see our Cookie Policy for information about:

  • the categories of cookies we use;

  • Wix cookies;

  • third-party technologies;

  • cookie consent;

  • changing your preferences; and

  • withdrawing consent.

THIRD-PARTY WEBSITES

Our Website may contain links to websites, platforms or services operated by third parties.

Noemi is not responsible for the privacy practices, security or content of independent third-party websites.

We encourage you to review the privacy information provided by those organisations before providing personal information to them.

DATA BREACHES

Where Noemi becomes aware of a personal-data breach, we will assess its nature, scope and potential consequences and take appropriate action.

Where required by applicable law, Noemi will notify the Information Commissioner's Office and/or affected individuals within the applicable legal timescales.

COMPLAINTS

If you have concerns about how Noemi has collected or used your personal information, please contact us first so that we can investigate and respond.

You also have the right to complain to the UK's data-protection regulator, the Information Commissioner's Office (ICO).

Information Commissioner's Office — Make a Complaint

Making a complaint does not affect any other rights or remedies available to you.

CHANGES TO THIS PRIVACY POLICY

Noemi may update this Privacy Policy where necessary to reflect:

  • changes in applicable law or regulatory guidance;

  • changes to our Website;

  • changes to our business or services;

  • changes to the personal information we process;

  • changes to technology or service providers; or

  • changes to the way information is used.

The date at the top of this Policy will be updated where appropriate.

Where Noemi intends to use existing personal information for a materially new purpose, we will provide appropriate privacy information before beginning that processing where required.

The ICO says privacy information should be regularly reviewed and that new uses of existing personal information should be brought to people's attention before the new processing starts.

CONTACT US

For privacy questions, concerns or requests:

Noemi James Management Ltd
Company Number: 16949188

Email: info@noemijamesmgmt.com

Last Updated: August 2026

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