Privacy Policy

Last updated: 17 February 2026

1. Who We Are

Exemplar Models (“we”, “us”, “our”) is a model agency operating in the United Kingdom. We act as an intermediary between models and third parties and are responsible for verifying, managing, and retaining legally required records relating to our models.

For the purposes of UK data protection law, Exemplar Models is the Data Controller.

2. Information We Collect

We collect and process personal data necessary to operate our services and comply with legal obligations. This may include:

• Full legal name
• Date of birth
• Government-issued identification (passport, driving licence, national ID)
• Proof of address
• Photographic records required for age verification
• Contact details (email address, telephone number)
• Contracts, consent forms, and related documentation
• Account, login, and audit metadata

We do not collect unnecessary data, and access to sensitive information is strictly limited.

3. Purpose of Processing

We process personal data for the following purposes:

• Age verification and identity confirmation
• Compliance with UK law and applicable international regulations
• Providing proof of age or identity to law enforcement agencies, courts, regulators, and other legally entitled authorities
• Contract administration and record-keeping
• Fraud prevention, safeguarding, and risk management
• Business continuity and audit requirements

4. Legal Basis for Processing

We process personal data under one or more of the following lawful bases under UK GDPR:

• Legal obligation – where processing is required by law
• Contractual necessity – to perform our obligations as an agency
• Legitimate interests – safeguarding, compliance, and operational security
• Explicit consent – where required and obtained

Age-verification and identity data is processed primarily under legal obligation.

5. Disclosure of Information

We may disclose personal data only where legally required or legally permitted, including to:

• Law enforcement agencies
• Courts and tribunals
• Regulatory and supervisory authorities
• Legal advisers acting under confidentiality obligations

We do not sell, rent, or trade personal data.

6. Data Security

We implement appropriate technical and organisational security measures, including:

• Role-based access controls
• Secure storage environments
• Monitoring and audit logging
• Encryption of data in transit and at rest where appropriate

Where personal data is no longer actively used but must be retained for legal reasons, it is archived and protected using encryption at rest.

7. Data Retention

We retain personal data only for as long as required by applicable law, regulation, or legitimate legal purpose.

Certain records, including age-verification, identity documentation, and compliance records, may need to be retained for extended or indefinite periods in order to:

• Demonstrate ongoing legal compliance
• Defend or respond to legal claims
• Satisfy lawful requests from authorities

Where data is no longer legally required, it will be securely deleted or irreversibly anonymised.

8. Your Rights

Under UK GDPR, you have rights including:

• The right to access your personal data
• The right to rectification of inaccurate data
• The right to restrict processing in certain circumstances
• The right to lodge a complaint with the Information Commissioner’s Office (ICO)

Some rights may be limited where data is retained to comply with legal obligations.

9. International Transfers

Where personal data is transferred outside the United Kingdom, appropriate safeguards are implemented in accordance with UK data protection law.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect legal, regulatory, or operational changes. The current version will always be made available through our website.

11. Contact

For any data protection or privacy-related enquiries, including GDPR requests, contact:

Exemplar Models
Email: GDPR@exemplarmodels.co.uk