Privacy Policy

Last updated: [Month Year]

This Privacy Policy explains how [Company Legal Name, S.L.], trading as BEMBE ("BEMBE", "we", "us"), with registered address at [Street, Number, Postal Code, Barcelona, Spain], processes personal data collected through this website, in compliance with Regulation (EU) 2016/679 ("GDPR") and Spanish Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights ("LOPDGDD").

1. Data Controller

2. What Data We Collect and Why

We collect personal data directly from you when you interact with this website. The tables below set out each processing activity, the data involved, the legal basis under Article 6 GDPR, and how long we keep it.

2.1 General Contact Enquiries

When you use our contact form, we collect your name, email address and message content in order to respond to your enquiry. Legal basis: your consent (Art. 6(1)(a) GDPR), given via the consent checkbox on the form. We retain this data for as long as needed to handle the enquiry and for [12 months] afterwards, unless a longer period is required by law.

2.2 Talent Applications

If you apply to be represented by BEMBE Talent, we collect the information you submit — which may include your name, contact details, photographs, portfolio material, physical characteristics relevant to casting, and career history. Legal basis: taking steps at your request prior to entering into a contract (Art. 6(1)(b) GDPR) and, where photographs or video are involved, your consent (Art. 6(1)(a) GDPR). This data is retained for as long as your application or representation is active, and for [24 months] after our last contact if no representation agreement is signed. You may withdraw your application and request deletion at any time.

2.3 Brand and Partnership Enquiries

If you contact us on behalf of a brand or company regarding a partnership, campaign or collaboration, we collect your name, business email, company name and the details of your enquiry, in order to evaluate and respond to potential collaborations. Legal basis: steps taken at your request prior to a possible contract (Art. 6(1)(b) GDPR) and our legitimate interest in business development (Art. 6(1)(f) GDPR). We retain this data for [24 months] from our last contact, unless a business relationship is established, in which case standard contractual and accounting retention periods apply.

2.4 Event Registrations

If you register for a BEMBE Collective event, we collect your name, email and, where relevant, ID or age-verification information required for entry and venue safety. Legal basis: performance of the arrangement to attend the event (Art. 6(1)(b) GDPR) and, where applicable, legal obligations related to venue safety (Art. 6(1)(c) GDPR). Event photography or video capturing attendees may also be processed on the basis of our legitimate interest in promoting our events (Art. 6(1)(f) GDPR); where reasonably possible, event materials will indicate that filming is taking place. This data is retained for [12 months] after the event.

2.5 Newsletter (if and when offered)

Should we introduce a newsletter, we will collect your email address (and optionally your name) to send you updates about BEMBE Talent and BEMBE Collective. Legal basis: your consent (Art. 6(1)(a) GDPR), given via an opt-in checkbox at the point of sign-up. You may unsubscribe at any time using the link included in every email or by contacting us directly. We retain this data until you unsubscribe or, if you do not engage with our emails, for a maximum of [24 months] of inactivity.

3. Cookies

This website uses cookies. Non-essential cookies (such as analytics or marketing cookies) are only set after you give your consent via our cookie banner. Full details are provided in our Cookie Policy. You can review or change your preferences at any time via the "Cookie Settings" link in the footer of this website.

4. Who We Share Data With

We do not sell your personal data. We may share it with trusted service providers who process it on our behalf under a data processing agreement — for example, website hosting providers, email delivery services, and, where applicable, analytics providers (only once you have consented). Where a talent application is shared with a prospective client or brand for casting purposes, this will only take place with your knowledge as part of the representation service, and, where necessary, your specific consent. We may also disclose data where required by law or to protect our legal rights.

5. International Transfers

Where a service provider we use is located outside the European Economic Area, we ensure an adequate level of protection through mechanisms recognised by the GDPR, such as an adequacy decision by the European Commission or Standard Contractual Clauses. [To be completed with specific providers and safeguards once finalised.]

6. Your Rights

Under the GDPR, you have the right to:

• Access the personal data we hold about you;
• Request rectification of inaccurate data;
• Request erasure of your data ("right to be forgotten");
• Request restriction of processing;
• Object to processing based on legitimate interest;
• Request data portability;
• Withdraw consent at any time, without affecting the lawfulness of prior processing.

To exercise any of these rights, contact us at [privacy@bembe.com]. If you believe your data protection rights have not been respected, you have the right to lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos, AEPD) at www.aepd.es, or with the supervisory authority in your own country of residence.

7. Data Security and Retention

We apply appropriate technical and organisational measures to protect your personal data against unauthorised access, loss or misuse. Retention periods for each type of data are set out in Section 2 above; where no specific period is stated, we retain data only for as long as necessary for the purpose it was collected for, or as required by law.

8. Children

This website is not directed at children under 16. If you believe a child has provided us with personal data without appropriate parental or guardian consent, please contact us so that we can remove it.

9. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The "Last updated" date at the top of this page indicates when it was last revised. We encourage you to review this page periodically.

10. Contact

For any questions about this Privacy Policy or our data practices, contact us at [privacy@bembe.com] or by post at [Street, Number, Postal Code, Barcelona, Spain].