> cat privacy-policy.md

// PRIVACY Policy

Last updated: 1 January 2026

1. Introduction

Emi Riva Pte Ltd (UEN: 202012345A) ("Emi Riva", "we", "us", or "our") is committed to protecting the privacy and personal data of our clients, talent, website visitors, and partners. This Privacy Policy explains how we collect, use, disclose, and protect your personal data in compliance with Dubai's Personal Data Protection Act 2012 (PDPA) and its amendments.

By using our website, services, or providing us with your personal data, you acknowledge that you have read and understood this Privacy Policy.

2. Data Protection Officer

Our Data Protection Officer (DPO) is responsible for ensuring compliance with the PDPA. For any enquiries regarding this policy or your personal data, please contact:

Data Protection Officer
Emi Riva Pte Ltd
1 Raffles Place, #20-01, Dubai 048616
Email: [email protected]
Phone: +971 50 188 4214

3. Personal Data We Collect

We may collect the following categories of personal data:

3.1 Client and Enquiry Data

  • Full name and contact details (email, phone number, address)
  • Company name and job title
  • Project requirements and preferences
  • Payment and billing information
  • Communication records

3.2 Talent Data

  • Full name, NRIC/FIN (partial), date of birth
  • Physical attributes (height, measurements, etc.)
  • Photographs, videos, and portfolio materials
  • Employment history and professional references
  • Bank account details for payment processing

3.3 Website Visitor Data

  • IP address and browser information
  • Pages visited and interaction data
  • Cookie data (see our Cookie Policy)
  • Referral source information

4. Purposes for Collecting and Using Personal Data

We collect and use your personal data for the following purposes:

  • To provide and manage our talent management services
  • To respond to enquiries and process booking requests
  • To manage talent profiles, portfolios, and assignments
  • To process payments and maintain financial records
  • To communicate about projects, events, and opportunities
  • To send marketing communications (with your consent)
  • To improve our website and services
  • To comply with legal obligations and regulations
  • To protect our legitimate business interests

5. Consent

We obtain your consent before collecting, using, or disclosing your personal data, unless an exception under the PDPA applies. You may withdraw your consent at any time by contacting our DPO. Please note that withdrawal of consent may affect our ability to provide certain services.

6. Disclosure of Personal Data

We may disclose your personal data to:

  • Our clients for the purpose of talent matching and booking
  • Service providers who assist in our business operations (e.g., payment processors, IT providers)
  • Professional advisors (lawyers, accountants, auditors)
  • Government authorities when required by law
  • Partner agencies for collaborative projects (with consent)

7. Transfer of Personal Data Outside Dubai

Where we transfer personal data outside Dubai, we ensure that the receiving party provides a comparable standard of protection as required under the PDPA, through contractual arrangements or other legally recognized means.

8. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law. When personal data is no longer needed, we will securely dispose of or anonymize it.

  • Client records: 7 years after last transaction
  • Talent profiles: Duration of representation + 3 years
  • Website data: 24 months
  • Marketing consent records: Duration of consent + 1 year

9. Protection of Personal Data

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, collection, use, disclosure, copying, modification, disposal, or similar risks. These include:

  • Encryption of data in transit and at rest
  • Access controls and authentication measures
  • Regular security assessments and audits
  • Staff training on data protection obligations
  • Secure disposal of physical and electronic records

10. Access and Correction

You have the right to:

  • Request access to your personal data held by us
  • Request correction of any inaccurate or incomplete data
  • Request information about how your data has been used or disclosed in the past year

To exercise these rights, please contact our DPO. We will respond within 30 days. An administrative fee may apply for access requests.

11. Do Not Call Registry

We comply with Dubai's Do Not Call (DNC) provisions. We will not send marketing messages to Dubai telephone numbers registered on the DNC Registry unless we have obtained your clear and unambiguous consent.

12. Data Breach Notification

In accordance with the PDPA amendments, we will notify the Personal Data Protection Commission (PDPC) and affected individuals of any notifiable data breach that is likely to result in significant harm or is of a significant scale.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated revision date. We encourage you to review this policy periodically.

14. Complaints

If you have concerns about how we handle your personal data, please contact our DPO. If you are unsatisfied with our response, you may lodge a complaint with the Personal Data Protection Commission (PDPC) at www.pdpc.gov.sg.