1. Data Controller
   New Chapter Management sp. z o.o.
   ul. Saperska 1/30, 01-735 Warszawa, Poland
   NIP: 5253027983
   Email: info@newchapter.management
   Phone: +48 535 215 371
2. Legal Basis for Processing
   We process personal data in accordance with the General Data Protection Regulation (GDPR). The legal bases for processing include:

• Performance of a contract (Art. 6(1)(b) GDPR)
• Compliance with legal obligations (Art. 6(1)(c) GDPR)
• Legitimate interests (Art. 6(1)(f) GDPR)
• Consent, where required (Art. 6(1)(a) GDPR)
• Processing of physical attributes, measurements, and photographs based on explicit consent (Art. 9(2)(a) GDPR)

3. Categories of Processed Data
   We may collect and process the following personal data:

• Name, surname, contact details (email, phone number)
• Date and place of birth, gender, nationality
• Bank account details (for payment processing)
• Identification documents (ID, passport)
• Tax identification number (NIP)
• Physical attributes, measurements, and photographs (for talent representation, based on explicit consent)

4. Purpose of Data Processing
   Personal data is processed for the following purposes:

• Talent recruitment, representation, and client collaboration
• Responding to inquiries and applications
• Contract execution and financial settlements
• Compliance with legal obligations (e.g., accounting, taxation)
• Ensuring website security and fraud prevention
• Sending marketing communications (subject to consent)

5. Data Retention Period
   We retain personal data only for as long as necessary for the specified purposes, in accordance with legal obligations and industry standards:

• Contractual data: Retained for the duration of the contract and relevant limitation periods
• Marketing data: Retained until consent is withdrawn
• Accounting and tax records: Retained for legally required periods

6. Rights of Data Subjects
   You have the following rights regarding your personal data:

• Access, rectification, and deletion
• Restriction of processing
• Data portability
• Objection to processing based on legitimate interests
• Withdrawal of consent (where applicable)

To exercise your rights, contact us at info@newchapter.management.

7. Data Transfers and Third-Party Sharing
   We may share personal data with:

• Clients and partners for model representation and collaboration
• Service providers (e.g., accounting, IT, legal advisors)
• Authorities where required by law

Data may be transferred outside the EU only if appropriate safeguards (e.g., standard contractual clauses) are in place.

8. Cookies and Tracking Technologies
   Our website may use cookies and similar tracking technologies to enhance user experience, analyze website traffic, and support marketing activities. Users can manage cookie preferences through their browser settings.
9. Updates to This Policy
   We may update this Privacy Policy from time to time. The latest version will always be available on our website.

For any questions, please contact us at info@newchapter.management.