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Privacy Policy

Last updated: April 3, 2026  |  Effective date: April 3, 2026

1. Data Controller

The data controller responsible for your personal data is:

• Company: Cleopatra Management LLC
• Email: mailymodel111@gmail.com
• Country: United States

For any questions regarding this policy or your personal data, please contact us at the email address above.

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2. What Data We Collect

We may collect the following categories of personal data:

• Contact and identification data: name, email address, Instagram username, age, country of residence
• Professional information: previous work experience, preferred working model, current earnings, social media follower counts
• Technical data: IP address, browser type, operating system, referring URLs, pages visited, session timestamps
• Cookie and tracking data: advertising identifiers, click IDs, behavioral data via Meta Pixel (see Section 7)

3. Purposes and Legal Basis for Processing

We process your personal data for the following purposes and on the following legal bases:

• Recruitment / application processing — processing your application form and contacting you about collaboration opportunities. Legal basis: contract performance / pre-contractual steps (Art. 6(1)(b) GDPR).
• Communication — responding to enquiries and providing information about our services. Legal basis: legitimate interest (Art. 6(1)(f) GDPR).
• Website analytics — understanding how our website is used to improve user experience. Legal basis: legitimate interest (Art. 6(1)(f) GDPR).
• Advertising and remarketing via Meta (Facebook/Instagram) — running targeted advertising campaigns to reach potential candidates. Legal basis: consent (Art. 6(1)(a) GDPR) obtained via our cookie consent mechanism.

4. Meta Pixel and Advertising

Our website uses the Meta Pixel (formerly Facebook Pixel), a tracking tool provided by Meta Platforms Ireland Ltd., 4 Grand Canal Square, Dublin 2, Ireland.

The Meta Pixel may collect the following data when you visit our website:

• Browser information (user agent, language, screen resolution)
• IP address (which may be used to determine your approximate location)
• Cookie identifiers (_fbp, _fbc)
• Pages visited and actions taken on our website

This data is transmitted to Meta's servers, which may be located in the United States. This data is used to:

• Measure the effectiveness of our advertising campaigns
• Display relevant advertisements to users on Facebook and Instagram
• Build custom audiences and lookalike audiences for advertising purposes

For more information about Meta's data practices, see Meta's Privacy Policy.

5. Cookies

We use the following categories of cookies:

• Strictly necessary cookies: Required for the website to function. No consent needed.
• Analytics cookies: Help us understand how visitors use our site. Activated only with your consent.
• Marketing cookies: Used for targeted advertising via Meta. Activated only with your consent.

You can manage or withdraw your cookie consent at any time through your browser settings or by contacting us.

6. Data Sharing and Recipients

We may share your personal data with the following categories of recipients:

• Meta Platforms Ireland Ltd. — for advertising and remarketing (see Section 4)
• EmailJS (Alessio Moretti) — a third-party email delivery service used to send form submissions to us. EmailJS Privacy Policy
• Our team members — who need access to the data to process your application

We do not sell your personal data to third parties.

7. International Data Transfers

Some of our service providers (including Meta) are based in the United States. Transfers of personal data to the United States are carried out on the basis of the EU-US Data Privacy Framework and/or Standard Contractual Clauses approved by the European Commission, which provide appropriate safeguards for your personal data.

8. Data Retention

• Application data: Retained for up to 12 months from submission, or longer if a working relationship is established.
• Communication data: Retained for up to 3 years.
• Cookie and tracking data: As defined by the respective service providers (typically 90 days for Meta Pixel cookies).

9. Your Rights Under GDPR

If you are located in the European Economic Area (EEA), you have the following rights regarding your personal data:

• Right of access — request a copy of the personal data we hold about you
• Right to rectification — request correction of inaccurate or incomplete data
• Right to erasure ("right to be forgotten") — request deletion of your personal data
• Right to restriction of processing — request that we limit how we process your data
• Right to data portability — receive your data in a machine-readable format
• Right to object — object to processing based on legitimate interests or for direct marketing
• Right to withdraw consent — withdraw consent at any time (does not affect lawfulness of prior processing)

To exercise any of these rights, contact us at: mailymodel111@gmail.com

You also have the right to lodge a complaint with the supervisory data protection authority in your country. For EEA residents, you may contact your national Data Protection Authority.

10. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. All form data is transmitted over encrypted connections (HTTPS).

11. Children's Privacy

Our services are intended exclusively for individuals aged 18 and over. We do not knowingly collect personal data from persons under 18 years of age.

12. Changes to This Policy

We may update this Privacy Policy from time to time. The updated policy will be posted on this page with a revised "Last updated" date. We encourage you to review this policy periodically.

13. Contact

For any questions, requests, or concerns regarding this Privacy Policy or our data processing practices, please contact: