1.1. Definitions. For the purposes of this Policy:

• "Personal Data" means any information that identifies or could reasonably identify an individual.
• "Sensitive Personal Data" means information that is afforded special protection under applicable law, such as government identifiers, biometric data, or precise geolocation.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, or deletion.
• "Business" means a User that searches for, books, or pays for modeling services.
• "Model" means a User that offers modeling services through the Platform.
• "Service Providers" means third parties that process Personal Data on KAAT's behalf to support the Platform.
• "User Content" means any photos, videos, text, messages, or other materials submitted to the Platform by Users.

2.1. Scope. This Policy applies to all Users of the Platform, regardless of location, and governs the collection and processing of Personal Data in connection with the Platform.

2.2. Third-Party Services. The Platform may include links to third-party websites or services. KAAT is not responsible for the privacy practices of third parties. We encourage you to review their privacy policies before providing information.

2.3. Relationship to Terms. This Policy is incorporated by reference into our Terms of Service. Capitalized terms not defined in this Policy have the meanings set forth in the Terms.

We use Personal Data to operate, improve, and protect the Platform, including to:

• Provide Services: Create and manage accounts, enable bookings, and facilitate messaging.
• Process Payments: Facilitate transactions, payouts, and refunds through payment processors.
• Verify Identity: Conduct verification and fraud prevention checks.
• Improve the Platform: Analyze usage to enhance features, user journey, and performance.
• Communicate: Send service notifications, confirmations, and support responses.
• Marketing Use of Uploaded Photos and Information: Use, reproduce, and display photos and information you upload to the Platform for KAAT’s marketing, advertising, and promotional purposes (including on the Platform, social media, press materials, and paid campaigns), subject to your rights and choices in Article 10.
• Comply With Law: Meet legal obligations and enforce our Terms and policies.

Where required by applicable law, KAAT relies on the following legal bases:

• Contractual Necessity: To perform our contract with you, including providing the Platform.
• Consent: When you consent to a specific processing activity, such as marketing communications.
• Legitimate Interests: To improve the Platform, prevent fraud, and ensure security.
• Legal Obligation: To comply with regulatory, tax, or legal requirements.

We disclose Personal Data only as described below:

• With Other Users: Your profile, portfolio, and booking details are visible to other Users to facilitate bookings.
• With Service Providers: We share data with vendors for hosting, analytics, payments, communications, and identity checks.
• For Legal Reasons: We may disclose information to comply with law, respond to legal requests, or protect rights and safety.
• Business Transfers: In connection with a merger, acquisition, or asset sale, your data may be transferred.
• With Your Consent: We may share information at your direction or with your explicit permission.

KAAT operates globally. Your Personal Data may be transferred to, stored in, or processed in jurisdictions outside your country of residence, including the United Arab Emirates and other countries where our Service Providers operate.

We implement appropriate safeguards to protect cross-border transfers, such as contractual protections and security measures. By using the Platform, you acknowledge and consent to these transfers.

We retain Personal Data for as long as your account remains active or as needed to provide the Platform. We may retain information for longer periods to comply with legal obligations, resolve disputes, enforce agreements, or maintain security.

When retention is no longer necessary, we delete, anonymize, or de-identify Personal Data in accordance with applicable law and our internal policies.

We maintain administrative, technical, and physical safeguards designed to protect Personal Data. These safeguards include access controls, encryption where appropriate, and monitoring for suspicious activity.

No system is completely secure. You acknowledge that we cannot guarantee absolute security and that you are responsible for maintaining the confidentiality of your account credentials.

We use cookies and similar technologies to operate the Platform, remember preferences, analyze performance, and improve the user journey. These technologies may be controlled through your browser settings or device controls.

Some features may not function properly if you disable cookies. We do not currently respond to browser "Do Not Track" signals.

12.1. Service Communications. We may send you transactional messages regarding your account, bookings, security alerts, and policy updates. You cannot opt out of these messages without closing your account.

12.2. Marketing Communications. Where permitted by law, we may send promotional messages. You may opt out at any time by following the unsubscribe instructions or adjusting your account settings.

We may use automated tools to detect fraud, enforce safety policies, or prioritize support. These tools do not make decisions that have legal or similarly significant effects without appropriate human oversight.

If you believe an automated decision has impacted you, you may contact us to request review.

The Platform is not intended for individuals under 18 years of age. We do not knowingly collect Personal Data from children. If we learn that a child has provided Personal Data, we will delete it promptly.

We may update this Policy from time to time. We will post the updated version on the Platform and update the "Last Updated" date above. Material changes may be communicated via email or in-app notice.

Your continued use of the Platform after changes take effect constitutes acceptance of the revised Policy.