Privacy policy

1. Who is responsible and what this policy covers

SIA Satin Agency, Latvia (Satin, we, us), is responsible for personal information used to run our website, manage our business relationships and administer our private workspace. Contact help@satin.agency, with “Privacy” in the subject if convenient. Our registered details appear in the Legal notice.

This policy covers website visitors, people contacting us, creators, applicants, contractors and other people whose information we handle in those activities. The Creator enquiry privacy notice, Recruitment privacy notice, Workforce and onboarding privacy notice and Cookies and analytics policy provide additional information for particular activities. A collection-specific notice explains the relevant workflow; it does not silently authorise unrelated processing.

We may also process fan or account information solely on a creator's documented instructions. For that processing, the creator may be the controller and Satin a processor under a separate agreement. A platform may act as an independent controller for its own services. Roles depend on the actual activity: these descriptions do not make every creator a controller for everything or permit Satin to use fan information for its own unrelated purposes.

2. Information we handle and its sources

Website and security information. Our hosting and security services receive information needed to deliver requests and protect systems, including network addresses, request times, browser/device signals and security events. Optional analytics records limited visit and engagement information only after your browser choice permits it. We do not describe network identifiers as anonymous merely because they are hashed.

Enquiries and correspondence. We receive your name, email, country, preferred contact channel, contact details you supply, follower estimates, optional public profile links and requested call times. We retain relevant follow-up notes, status and notice acknowledgements. We receive information from you and, where appropriate, an authorised referrer whose identity and purpose we will explain.

Recruitment and contractor information. Applications can contain age and residence details, availability, experience, public work evidence, role exercises and measured typing or connection-test results. Engagement records may contain identity and contact details, contract and invoice information, assignments, schedules, work records, approved expenses, earnings calculations and communications. We do not need unrelated private messages, medical histories or other people's intimate content in an application.

Creator and account information. Under an agreed management scope we may receive the creator's business and contact details, authorised platform identifiers and permissions, content instructions, approved media, account performance, transaction and reconciliation information, and operational communications. Platform records may include fan usernames, messages, purchases and interaction histories. Access is limited to the actual agreed work; it is not permission to collect an entire fan's online history.

Onboarding, signing and workspace information. These records include legal name, date of birth, supplied address, private recovery email, username, verification outcome/reference, reviewed and signed contract versions, permissions, profile picture, preferences, tickets, operational messages and audit records. Identity verification and signing providers collect additional information in their own interfaces, as explained before their use. The identity integration keeps results and references rather than storing raw face captures in the Satin member record.

Sources include you, an authorised agency colleague or creator, approved platform records, verification and signing providers, and relevant public professional profiles. If we obtain information indirectly and must give you a notice, we do so within the legally required period, generally no later than one month and sooner where our first communication or disclosure requires it.

3. Purposes and lawful bases

Where the GDPR applies, we identify a basis for each purpose rather than treating acceptance of this policy as universal consent:

• Responding to your enquiry and preparing an agreement: steps you request before entering a contract, under Article 6(1)(b). When you act for another organisation, our legitimate interest in communicating with its representative may apply instead.
• Delivering agreed management or contractor arrangements: performance of our contract with you where the processing is necessary, under Article 6(1)(b). Separate instructions and processing terms govern work performed for a creator as processor.
• Recruitment: requested pre-contract steps and, for proportionate assessment and recruitment administration, our legitimate interest in selecting suitable adult personnel. Applicable employment duties may supply a legal obligation for particular records; we do not treat every recruitment field as legally mandatory.
• Security, fraud prevention, access administration and service reliability: our legitimate interests in protecting people, confidential information and systems, under Article 6(1)(f), subject to your rights and reasonable expectations; specific legal duties may also apply.
• Accounting and legally required records: the applicable legal obligation under Article 6(1)(c). Contract administration and the establishment or defence of legal claims may separately rely on contract or legitimate interests. We will identify the relevant obligation when a record is required by law.
• Optional website analytics: consent under Article 6(1)(a), together with the applicable rules on storing or accessing information on your device. Declining does not prevent an enquiry or application.
• Optional marketing or public testimonials: a separately explained lawful basis and, where required, specific consent. An enquiry, contract, privacy acknowledgement or identity check does not subscribe you to promotional messages or authorise publication of your likeness.
• Complaints and rights requests: legal obligations to address applicable rights and our legitimate interest in resolving concerns, documenting decisions and protecting people.

Where we rely on legitimate interests, we consider necessity, less intrusive alternatives and the impact on you. You can ask for information about that assessment and object as described below. Information needed to answer a request, establish an account, verify eligibility or perform an agreement may be required for that activity; if it is missing, we may be unable to proceed. Optional fields and choices remain optional.

4. Sensitive information and creator content

Intimate media and some fan communications can reveal sex life, sexual orientation or other sensitive information. Biometric matching used to identify someone uniquely can also involve special-category information. Such processing needs an applicable additional condition under Article 9, as well as an Article 6 basis. A service contract, public profile or platform account alone does not supply that condition.

Before starting a workflow involving sensitive information, we identify its permitted purpose, recipients and applicable condition and provide a specific notice. Where we rely on explicit consent, we ask separately for a clear choice explaining what processing is authorised and how to withdraw. We do not assume that a creator can consent for every fan or co-performer. A person who chooses not to undergo a consent-based biometric process may contact us to discuss available lawful alternatives; an alternative cannot be guaranteed until eligibility and operational requirements are assessed.

Public forms are not a channel for identity documents or intimate media. Please do not submit them there. Consent to perform, permission to publish, a copyright licence and consent to process sensitive data are distinct matters. Withdrawal may affect work that cannot lawfully continue, but does not by itself erase records that must be retained on a separate valid basis.

5. Access and recipients

Authorised personnel receive access according to their duties and current assignments. Colleague profiles and ordinary operational views do not give every contractor access to legal identities, recovery addresses, private documents or all creator accounts. Confidential information may be shared with advisers, accountants, insurers or authorities where necessary and lawful, and with a prospective business acquirer only under appropriate confidentiality and data-minimisation arrangements.

Providers used for the relevant functions include:

• Cloudflare: website and application delivery, security/Turnstile, private file infrastructure, email routing and consent-based analytics infrastructure.
• Convex: application database and backend workflows, including access-controlled operational records.
• Resend: transactional email such as enquiry receipts, call updates, recovery and service notices where enabled.
• Google/Gmail: the receiving inbox used by authorised personnel for forwarded correspondence.
• Didit: identity-document and biometric verification in its hosted workflow when real onboarding is lawfully enabled; test workflows are separate.
• SignWell: new electronic-signature requests under the configured integration; Dropbox Sign continues to handle requests originally created with that provider and their evidence.
• Creator platforms and communication channels you use or authorise: account operations or communications within the agreed scope; these services also have their own notices.

The data sent depends on the function. A signing provider receives the assigned contract, signer identity/contact information and signing evidence; it does not receive the full staff database merely because we use its service. A referral to another agency requires a separate discussion and appropriate authority. We do not sell enquiry lists or grant providers a general licence to exploit private creator content.

6. International processing

Satin is established in Latvia. Providers and authorised contractors may operate in other countries, and remote access from outside the EEA can be an international transfer even when the database is hosted in Europe. Worldwide recruitment does not automatically authorise access to personal information from every country.

Where required, a transfer must be supported by an applicable adequacy decision or appropriate safeguards, such as suitable European Commission standard contractual clauses together with the necessary assessment and supplementary protections. An adequacy arrangement may cover only specified organisations or activities; we do not assume that an entire country or every provider is covered. Exceptions are assessed narrowly and are not a routine substitute for safeguards.

Contact us for the countries, recipient arrangements and a copy or explanation of safeguards relevant to your information, with confidential details redacted where necessary. A proposed Dubai or Hong Kong operation is not a current transfer mechanism or an automatic replacement for the Latvian controller. We will provide appropriate notice and establish the necessary arrangements before a relevant change.

7. How long we keep information

We retain information for its stated purpose and any applicable legal retention or documented claim-preservation requirement. Access termination, operational deletion and removal from backups are different events. The following rules apply to the existing workflows:

• Creator enquiries and staff notes: 84 days from the latest staff update, or the scheduled end of a future confirmed call under the enquiry workflow. The dedicated notice explains rescheduling and subsequent updates.
• Recruitment applications, exercises and reviewer notes: 84 days after the latest recruitment update, including an application marked hired. A later engagement has separate records.
• Abandoned onboarding: normally scheduled for cleanup after 84 days without onboarding activity. Uncertain or partly signed contracts, unavailable providers and unresolved deletion results place the affected records on a reconciliation hold. Completed contracts are retained separately; an account is not treated as unsigned merely because access was disabled.
• Verification evidence: the minimum approved result and reference remain while the account exists, subject to lawful erasure and any necessary evidence retention. Provider-held identity resources require separate deletion handling.
• Analytics: session details and event receipts expire within 24 hours; daily reporting covers 90 UTC dates; limited conversion digests used to prevent duplicate counting are kept for 90 days. The saved browser choice lasts 180 days. Scheduled physical cleanup may follow expiry.
• Transactional email queue: message content is removed after provider acceptance or the end of delivery attempts; limited delivery metadata remains for seven days. Provider logs and inbox copies have separate retention.

For signed agreements, invoices, approved earnings, work records, security logs and complaints, retention is determined by the applicable accounting, contractual, employment-status and limitation requirements, the ongoing need for the record and any specific legal hold. We review these categories and remove or de-identify records when their purpose and applicable retention have ended. Ask us for the criterion applicable to a particular record. We do not apply one arbitrary period to every category or promise immediate removal from all provider backups.

8. Security and confidentiality

We use access controls, private document delivery, session controls and validation appropriate to the service. Access is limited by role and assignment. Sensitive documents should be submitted only through the designated private process. No service can guarantee absolute security. We investigate suspected breaches and notify affected people or authorities where required by law.

Keep credentials secure and report suspected disclosure promptly. Do not include a password or a full identity-document image in an ordinary support email.

9. Decisions and monitoring

The enquiry and recruitment workflows use human review; a typing result or unavailable connection test is not by itself an automatic rejection. Security controls may block suspicious requests. Identity-provider checks can determine whether an onboarding step passes or needs review, and server rules prevent access before required steps are complete. Contact us to challenge inaccurate information or request review of a verification problem.

We do not use the website analytics system to make legally significant decisions about individual visitors. Any new solely automated decision with legal or similarly significant effects requires its own assessment, information and safeguards before activation. The workforce notice explains operational records and visibility; it does not authorise undisclosed surveillance.

10. Your rights

Depending on the processing and applicable law, you may request access, correction, erasure, restriction or portability, object to legitimate-interest processing, and withdraw consent. You may object to direct marketing at any time. Withdrawal affects future consent-based processing without invalidating earlier lawful use. Rights have legal conditions; for example, a required accounting record may need to be retained despite a deletion request.

Email help@satin.agency. No particular form is required. We may seek proportionate verification where necessary. We normally respond within one month; where the GDPR permits a further two months for complexity or volume, we explain the extension within the first month. Requests are normally free; any permitted fee or refusal must be justified and explained with available complaint rights.

You may complain to Latvia's Data State Inspectorate, another competent supervisory authority, or seek a judicial remedy. Contacting us first is optional. Where we act only as a processor, we will assist or refer your request to the relevant controller rather than independently deciding a matter outside our instructions.

11. Children, links and changes

Our business services and workspace are for adults. If you believe a child has supplied information, contact us so that we can assess protective and deletion steps. We do not knowingly solicit applications from minors.

Other websites and platforms have their own privacy practices. We provide relevant notices before handing you to an identity or signing workflow. A link does not make us responsible for all independent processing by its operator.

We will update this policy when material practices change and provide additional notice or request fresh consent where required. A revised policy does not retroactively authorise an incompatible use or change the controller without the necessary legal steps.