This Privacy Policy informs you of our policies and procedures regarding the collection, use and disclosure of personal information we receive from visitors and registered users of Westhaven International. This Privacy Policy applies only to information that you provide to us through this Site and explains in plain language what we do with that information, how we share it, and how we handle the content you place. It also explains your rights and the choices available to you regarding our use of your personal information and how you can access and update this information.

Our Privacy Policy may be updated from time to time, and we will notify you of any material changes by posting the new Privacy Policy on this site HERE and revising the “Effective Starting” date at the top of this policy page. We encourage you to review our Privacy Policy whenever you use this “Site” to stay informed about our information practices and the ways you can help protect your privacy. If you disagree with any changes to this Privacy Policy, you will need to stop using this “Site” and deactivate your account(s), as outlined below.

This Privacy Policy applies to the information that we obtain through your use of “Westhaven International’s website” (referred to as “Site”) via a “Device” or when you otherwise interact with Westhaven International. A “Device” is any computer used to access the “Site”, including without limitation a desktop, laptop, mobile phone, tablet, or other consumer electronic device. “Site” includes the Westhaven International web site and may include 3rd party links to sites but does not include any other own or third party products. In the case of our extended products and services via the Store/Boutique page or any other page, you should always review the policies of third party products and services to make sure you are comfortable with the ways in which they collect and use your information.

By registering for or using “Site” and accepting the Terms of Service you consent to the collection, transfer, processing, storage, disclosure and other uses described in this Privacy Policy.

1. Who We Are

Westhaven International: The Westhaven International group of companies (“Westhaven”) provide all around talent management and production services worldwide. “Westhaven International LLC”, located in the United States of America (8 The Green (STE A) Dover, DE 19901 USA tel. (+1) 646 770 1174) is responsible for the management, maintenance and operation of the “Site”. The Westhaven complies with Federal Trade Commission Act (15 U.S. Code § 41 et seq.). Westhaven will not knowingly do anything or permit anything to be done which might lead to a breach of the data protection laws.

Customers access the Westhaven service by registering with us through a semi formal email to our company, registering to the website, and providing a username and password unique to their profile. By gaining access to the service through this combination, the Customers are allocated a specific domain that is owned and managed exclusively by them. The Customer specifies, customizes and provides access to the service to the authorized users (“Users”) of his domain, consisting of their “talent profile” and “portfolio”. Additionally, the Customer may specify custom User roles for their domain. The registration instructions specify the content of the profiles, which may include text, images, video and audio files.

2. Collection: The Personally Identifiable Information We Collect

Visitors and Users: In the course of using this Site, you may provide us with personally identifiable information. This refers to information about you that can be used to contact or identify you, and information on your use of and activities at our Site that may be connected with you (“Personal Information”). Personal Information that we collect may include, but is not limited to, your name, email address, telephone number, birth date, body measurements, and skills. When you visit the Site, our servers automatically record information that your browser sends whenever you visit a website. This information may include, but is not limited to, your Internet Protocol address, browser type, the web page you were visiting before you came to our Site and information you search for on our Site. Like many websites, we may also use “cookies” to collect information. A cookie is a small data file stored by your browser at your Device’s hard disk for record-keeping purposes. We may also store cookies of third-party providers. In particular, Google stores a Google Analytics cookie in order to be able to differentiate between users and be able to show us how many times people visit the website on average (not individually) and information on what pages they’ve seen, how long the duration was, and so on; we do not identify who the visitor was, or what their profile on our “Site” is (if any). Westhaven does not collect, store or process data from third-party cookies. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, that is fine by us.
In some cases another Users (such as an administrator) may create an account on your behalf and may provide your information, including Personal Information (most commonly when Customers requests to use our service).

Customers: In addition to the data we collect for all Users, we may also acquire additional data through our Customers’ support requests to the extent this is required for us to resolve a technical issue or respond to a request or complaint. We also email to our Customers newsletters, announcements regarding Westhaven and our products, or marketing material. If you are a Customer and no longer wish to receive such emails you can remove yourself from the recipients list at any time by selecting the “unsubscribe” link provided within the e-mail footer or simply replying STOP to any messages you receive from us. If you are providing information (including Personal Information) about someone else, you must have the authority to act for them and to consent to the collection and use of their Personal Information (typically a parent or guardian signing up for their children). In case You use through Our Service any optional third-party service for content, such as YouTube, You explicitly agree to be bound by the respective Terms of Service (for YouTube); Our Service does not share any Personally Identifiable Information with YouTube.

Credit/Debit Cards: We do not store your credit/debit card information in our systems. All credit/debit card transactions are processed using secure encryption – the same level of encryption used by leading banks. Card information is transmitted, stored, and processed securely at gateways on a PCI-compliant network.

Content: We collect and store Content that you create, input, submit, post, upload, transmit, store or display in the process of using our “Site”. Such Content includes any Personal Information or other sensitive information that you choose to include (“incidentally-collected Personal Information”). Although Westhaven owns the code, databases, and all rights to the Westhaven service, Customers retain ownership, control and all rights to their records and data which are their property.

Other submissions: We collect other data that you submit to our “Site” or as you participate in any interactive features of the Westhaven Services, participate in a survey, contest, activity or event, request Customer support, or otherwise communicate with us.

3. How We Use, Process and Retain Personal Information

Personal Information is or may be used for the following purposes:

1. to provide and improve our Site, services, features and content,
2. to administer your use of our Site,
3. to enable you to enjoy and easily navigate the Site,
4. to better understand your needs and interests,
5. to fulfill requests you may make,

We use information we obtain by technical means (such as the logging performed by our servers) for the above purposes and in order to monitor and analyze use of the Site and our services, for the Site’s technical administration, to increase our Site’s functionality and user-friendliness, to better tailor it to your needs, to generate and derive useful data and information concerning the interests, characteristics and website use behavior, and to verify that visitors to the Site meet the criteria required to process their requests.

We collect and process personal data in a transparent manner, to the extent necessary for specified, explicit and legitimate purposes, and do not process it further in a manner incompatible with those purposes. We take care that the data we collect are accurate and, when necessary, updated. We take all reasonable steps to immediately delete or rectify personal data, if inaccurate. We process data in a way that guarantees their security, including their protection against unauthorized or unlawful processing and accidental loss, destruction or degradation, using appropriate technical or organizational measures. We are ready to prove at any moment how we adhere to the above principles. We take the appropriate technical and organizational measures for the security, confidentiality, integrity and availability of the data. We expressly declare that these measures ensure that, by definition, personal data are not made accessible without the intervention of the natural person to an indeterminate number of natural persons.

Each domain’s data are retained for as long as the Customer’s agreement to the service lasts. Upon contract termination, the data will be deleted or returned to the Customer if the Customer instructs us to. Alternatively, the domain will be rendered “inactive” and stored offline for 12 months so that a service reconnection is as smooth as possible; in case an agreement is not renewed after 12 months, the data may be permanently deleted.

4. Information Sharing and Disclosure

Users: We will display your Personal Information in your profile page and elsewhere on the Site as a feature. Any information you choose to provide should reflect how much you want other Westhaven Users to know about you. You can review and revise your profile information at any time. You should be aware that the administrator, as well as specially designated support personnel in order to provide support for technical issues you may face, may be able to: access information in and about your account; access communications history, including file attachments, for your account; disclose, restrict, or access information that you have provided or that is made available to you when using your account, including your Content; and control how your account may be accessed or deleted.

Third Parties: We do not sell your Personal Information or Content and will not share or disclose any of your Personal Information or Content with third parties. We do not share Personal Information about you with third parties for their marketing purposes (including direct marketing purposes).

Compliance with Laws and Law Enforcement: Westhaven cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Westhaven or a third party, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable.

Children: Our services are not directed to children. We do not knowingly collect Personal Information from children. If we become aware that a child has provided us with Personal Information, we will take steps to communicate with the parents/guardian of the child, and we may delete such information given by the child.

5. Your Rights

Westhaven respects your rights as a data subject. When Westhaven processes personal data on behalf of and as instructed by its Customers, our Customers are responsible towards the data subjects and you should contact the respective Customer to which the content of your service belongs for exercising your rights. In this case, Westhaven does not respond directly to your requests for the exercise of your rights that come to our knowledge, but we inform the Customer without delay and provide all reasonable and reasonable assistance to satisfy your requests in accordance with instructions of the Customer. The service has all the necessary features to enable our Customers to exercise the rights of the data subjects on their behalf.

A synopsis of your rights as a data subject is provided below.

Transparency, information and answers to requests: Westhaven adheres to the principle of transparency in processing. For any question regarding this policy you may contact us at info at westhaveninternational dot com. We will respond to requests without delay.

Access: You have the right to receive from Westhaven confirmation on whether your personal data are processed and in case this happens all required information thereof (processing means, goal, records etc.).

Rectification: You have the right to require the rectification of inaccurate data relating to you without undue delay, as well as to fill in incomplete data if necessary for processing. If you have an account on our Site you can update your account data through your profile by selecting “Edit Profile” from the options provided after you login.

Erasure: You have the right to ask for the erasure of personal data concerning you without undue delay. Westhaven by means of its designated personnel will erase the data where one of the following grounds applies: a) the personal data are no longer necessary in relation to the purposes of processing; or b) the person requesting the erasure withdraws consent on which the processing is based and there is no other legal ground for the processing; or c) the data subject objects to the processing and there are no overriding legitimate grounds for the processing or the data subject objects to processing for direct marketing; or d) the personal data have to be erased for compliance with a legal obligation. Westhaven will not proceed to the erasure of the personal data if the data must be maintained for compliance with a legal obligation or in cases where the processing is required for the establishment, exercise or defence of legal claims. If you receive marketing emails, you can remove yourself from the recipients list by selecting the “unsubscribe” link within the e-mail or by replying STOP.

Restriction of processing: You have the right to request restriction of processing if the accuracy of personal data is disputed, for that period of time that allows Westhaven to verify the accuracy of personal data or based on any other legitimate reason specified in applicable Data Protection Laws.

Data Portability: You have the right to receive your personal data in a structured, commonly used and machine-readable format as well as the right to request the direct transmission of personal data by Westhaven to another, if this is technically feasible.

Right to Object: You may oppose the processing of personal data which takes place without your consent. In this case, Westhaven no longer submits the personal data unless it demonstrates imperative and legitimate reasons for the processing that outweigh the interests, rights and freedoms of you as a data subject or for the foundation, exercise or support of legal claims. If you receive promotional emails, you can remove yourself from the recipients list by selecting the “unsubscribe” link within the e-mail content. You may also oppose processing at any time by contacting us at the email provided at the end of this Policy.

Complaint to Supervisory Authority: You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of your personal data infringes Data Privacy Laws.

6. Security

Westhaven is very concerned with safeguarding your information. We employ reasonable measures designed to protect your information from unauthorized access.

7. Data Ownership

Although Westhaven owns the code, databases, and all rights to the Westhaven service, Customers retain ownership, control and all rights to their records and data which are their property.

8. Contacting Us

If you have any questions about this Privacy Policy, please contact us at: info at westhaveninternational dot com.