Privacy Policy

1. Data Controller

The controller for the processing described in this policy is:

RALIA SOLUTIONS FOR MARKETING OPERATIONS, a sole proprietorship registered in Abu Dhabi, United Arab Emirates, operating under the brand Opale, as well as the "Opale Agency," "FAIR by Opale," and "+PaidMembers" solutions.

Economic License: CN-6680708
Unified Registration Number: 101-2026-200117525
Business Address: Baniyas Towers, Al Falah St - Saeed Bin Ahmed Al Otaiba St - Abu Dhabi
Personal Data Email: contact@opaleagency.fr
Website: www.opaleagency.fr

In this policy, Ralia Solutions is referred to as "Opale" or "we."

2. Purpose of the policy

This policy explains how Opale collects, uses, stores, shares, and protects personal data:

• website visitors;
• candidates, models, and UGC creators;
• FAIR by Opale clients;
• +PaidMembers clients;
• brand and company representatives;
• prospects, partners, and professional contacts;
• individuals whose public content may be analyzed as part of a monitoring service.

Processing is carried out in accordance with applicable laws, in particular the United Arab Emirates legislation regarding personal data protection.

Where applicable, Opale also complies with the European Union's General Data Protection Regulation.

3. Data collected

3.1 Site visitors

We may collect:

• IP address;
• device and browser type;
• pages visited;
• connection dates and times;
• referral source;
• interactions with the site;
• cookie preferences;
• data submitted via a form;
• messages sent to customer service.

3.2 UGC creators and models

We may collect:

• full name;
• contact details;
• date of birth;
• country of residence;
• nationality when necessary;
• languages spoken;
• information regarding experience;
• availability;
• professional preferences;
• links to social media profiles;
• pseudonyms or usernames;
• photographs and videos;
• portfolio;
• measurements and characteristics relevant to casting;
• motivations and introduction;
• correspondence with the Talent Advisor;
• history of opportunities shared;
• billing and payment information.

Photographs and videos are used to evaluate and showcase the talent's profile. They are not used for biometric identification, except where specific information and a legal basis are provided.

3.3 FAIR by Opale clients

We may collect:

• identity and contact details;
• company or brand name;
• names of products, executives, or individuals to monitor;
• keywords and monitoring topics;
• URLs, social profiles, and usernames;
• alert preferences;
• information regarding reported risks or incidents;
• instructions and support requests;
• publicly accessible content associated with the monitored scope;
• billing and payment data.

FAIR can analyze content made public on the Internet, including posts, reviews, articles, comments, search results, or public discussions.

3.4 +PaidMembers Clients

We may collect:

• professional identity and contact details;
• business information;
• website and social media profiles;
• offer, services, and pricing;
• positioning and target audience;
• business goals;
• acquisition channels;
• campaign data;
• audience and conversion statistics;
• marketing messages or content;
• prospect information provided by the Client;
• billing and payment data.

3.5 Brands, prospects, and partners

We may collect:

• professional identity;
• job title;
• company;
• business email address;
• business phone number;
• public profile;
• communication history;
• professional interests;
• responses to communications sent.

3.6 Payments

Payments may be processed by Stripe or another payment provider.

Opale generally does not receive the full credit card number. We may receive:

• the payer's name;
• their billing address;
• their email address;
• the amount and currency;
• the transaction status;
• the references required for payment tracking.

4. Data sources

Data may come from:

• directly from the data subject;
• the Client ordering a service;
• online forms;
• email, messaging, or telephone communications;
• publicly accessible websites, social networks, and platforms;
• brands or partners;
• analytics tools and cookies;
• technical service providers;
• lawfully accessible professional databases or lists;
• information made public by the data subject or their organization.

When a Client provides data concerning third parties, they guarantee that they are authorized to share it and have provided the required information to the individuals concerned.

5. Purposes of processing

We use data to:

E-commerce Models & UGC

• review applications;
• organize interviews;
• create and manage profiles;
• support talent;
• search for opportunities;
• present profiles to brands;
• facilitate networking;
• communicate service progress;
• manage memberships and payments.

FAIR by Opale

• configure the monitoring scope;
• search for and centralize public content;
• analyze tone and topics;
• identify risk signals;
• generate scores and indicators;
• send alerts;
• provide recommendations;
• assist the Client in assessing a situation;
• improve the relevance of analyses.

+PaidMembers

• analyze the Client's activity;
• design a marketing strategy;
• identify channels and audiences;
• carry out prospecting activities;
• track campaigns;
• measure performance;
• recommend optimizations;
• communicate with prospects when applicable;
• provide reports or deliverables.

General management

• respond to requests;
• perform contracts;
• manage payments and billing;
• prevent fraud;
• secure services;
• comply with legal obligations;
• handle complaints;
• establish, exercise, or defend legal claims;
• improve the site and services;
• send marketing communications when permitted.

6. Legal bases

Depending on the situation, processing is based on:

• the performance of a contract or pre-contractual measures;
• the individual's consent;
• the legitimate interests of Opale or a Client, provided that the rights of the individuals are respected;
• compliance with a legal obligation;
• the establishment, exercise, or defense of legal claims;
• any other basis authorized by applicable legislation.

Consent is requested in particular when required by law for:

• certain cookies;
• certain commercial communications;
• certain public uses of images;
• certain specific processing activities.

Individuals may withdraw their consent at any time. This withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.

7. Processing of public data in FAIR

The fact that information is publicly accessible does not mean it can be used without any rules.

FAIR limits processing to the monitoring, analysis, and e-reputation management purposes provided by the service.

Content may originate from, among other sources:

• public social networks;
• review sites;
• search engines;
• blogs;
• media outlets;
• forums;
• publicly accessible communities;
• institutional or professional websites.

FAIR is not intended to illicitly access private accounts, bypass access restrictions, or collect confidential communications.

Any person subject to an analysis may contact Opale to request information regarding the processing of their data, subject to legal limitations and the rights of third parties.

8. Artificial intelligence and automated analysis

Opale may use automated tools or artificial intelligence to:

• classify content;
• analyze sentiment;
• identify topics;
• generate summaries;
• assess risk levels;
• assist with writing;
• identify opportunities;
• analyze marketing data.

These tools may produce incomplete or inaccurate results. Scores and classifications are intended as decision-support indicators.

Unless otherwise stated, Opale does not make decisions that produce significant legal effects on an individual based solely on automated processing.

Human review may be requested when a decision or classification has a significant impact.

9. Data recipients

Depending on the service, data may be shared with:

• authorized personnel within Opale;
• employees and service providers involved in the service;
• brands and companies to whom a talent is to be introduced;
• partners necessary for facilitating connections;
• hosting providers;
• payment service providers;
• customer relationship management tools;
• email and messaging service providers;
• providers of analytical or artificial intelligence tools;
• professional advisors, insurers, or auditors;
• competent authorities when required by law;
• an acquirer or successor in the event of a lawful business restructuring.

Only data that is reasonably necessary is shared.

Service providers acting on Opale’s behalf are required to process data in accordance with appropriate instructions and confidentiality obligations.

10. Opale’s role regarding data provided by a business Client

For certain +PaidMembers or FAIR services, the Client may determine the purposes and essential means of processing for data they provide.

In this case:

• the Client may act as a data controller;
• Opale may act as a service provider or data processor;
• the Client remains responsible for the lawfulness of the collection and the instructions;
• a supplementary agreement regarding data processing may be concluded when necessary.

The Client warrants, in particular, that it will:

• have a valid legal basis;
• have properly informed the individuals;
• respect their rights;
• not transmit data that has been purchased or collected unlawfully;
• comply with rules regarding electronic marketing.

Opale may refuse any instruction that is clearly unlawful.

11. International transfers

Opale is established in the United Arab Emirates and may provide its services internationally.

Data may be processed or accessed from the United Arab Emirates, the European Union, or other countries where our clients, partners, or service providers are located.

When applicable law requires safeguards for an international transfer, Opale implements appropriate measures, which may include:

• contractual clauses;
• confidentiality agreements;
• technical and organizational measures;
• the use of a provider subject to a recognized transfer mechanism;
• any other warranty authorized by applicable regulations.

12. Retention period

Data is kept only for the time necessary to fulfill the intended purpose and to comply with legal obligations.

For information purposes:

Talent applications

Data from an unsuccessful application may be kept for a maximum of six months, unless consent is given for a longer retention period or there is a legal obligation.

Talent and active clients

Data is kept for the duration of the contractual relationship, and subsequently for the time necessary to manage claims, accounting obligations, and potential legal rights.

FAIR data

Monitoring data is kept for the duration of the service and, when necessary, for a limited period to establish requested trends, reports, and histories.

Prospecting

Prospecting data is kept for a duration proportionate to the professional relationship, interactions, and applicable rules.

Billing and payment

Invoices and transactional data are kept for the periods required by tax, accounting, and commercial regulations.

Cookies

The retention period depends on the specific cookie and is specified in the cookie management tool where applicable.

Data may be archived for longer periods when necessary for the defense of legal claims or to comply with a legal obligation.

13. Security

Opale implements reasonable technical and organizational measures to protect data against:

• unauthorized access;
• loss;
• destruction;
• alteration;
• disclosure;
• unlawful use.

These measures may include:

• access restrictions;
• user authentication;
• account security;
• use of recognized service providers;
• data backups;
• awareness training for authorized personnel;
• encryption where appropriate;
• incident management.

No system offers absolute security. Anyone using our services must also protect their passwords, devices, and access.

14. Individual Rights

Subject to the conditions and exceptions provided by applicable law, an individual may request:

• access to their data;
• correction of inaccurate data;
• updating their information;
• erasure of certain data;
• restriction of processing;
• objection to certain processing;
• data portability when this right is applicable;
• withdrawal of consent;
• information about recipients;
• human intervention regarding certain automated processing;
• stopping commercial communications.

To exercise a right, the request must be sent to:

contact@opaleagency.fr

The request must allow for the identification of the person and the processing concerned. Reasonable proof of identity may be requested to prevent fraudulent disclosure.

Opale will respond within the timeframes required by applicable law.

Certain requests may be limited when they infringe upon the rights of a third party, a legal obligation, security, confidentiality, or the defense of legal claims.

15. Complaints

Any questions or complaints regarding data may be sent to:

contact@opaleagency.fr

The person may also contact the competent data protection authority when this right is provided for by applicable regulations.

When the GDPR applies, a person located in the European Union may, in particular, contact the supervisory authority of their place of residence or work.

16. Commercial communications

Opale may send information regarding its services when:

• the person has consented to it;
• communication is necessary for a contractual relationship;
• a legitimate interest or another legal basis permits this communication.

Every electronic commercial communication includes a way to unsubscribe where required.

You may also request to stop receiving communications by contacting:

contact@opaleagency.fr

Operational messages required for the performance of a contract may continue to be sent even if you opt out of promotional communications.

17. Cookies

The site may use:

Necessary cookies

These are necessary for site operation, security, remembering essential choices, and processing forms.

Analytics cookies

These help us understand how the site is used and improve its performance.

Functional cookies

These allow for the personalization of certain features.

Advertising or marketing cookies

These may be used to measure campaign performance or display tailored content.

When required by law, non-essential cookies are only placed after consent is given.

Users can change or withdraw their choices using the cookie management tool. They can also configure their browser settings, although blocking certain cookies may affect how the site functions.

18. Social networks and third-party platforms

When a user interacts with Opale on a social network or third-party platform, that platform may process their data according to its own policy.

Opale is not responsible for any processing carried out independently by these platforms.

Users are encouraged to check their privacy settings.

19. Minors

Unless otherwise agreed in writing, Opale's paid services are intended for adults.

When a minor's profile is accepted, information and authorizations must be provided by their legal representative. Opale may request:

• proof of parental authority;
• written authorization;
• information necessary for the protection of the minor.

Opale does not knowingly collect data from a child without a legal basis or appropriate authorization.

20. Policy updates

Opale may modify this policy to account for:

• changes in services;
• regulatory changes;
• new service providers;
• new features;
• changes in processing activities.

The update date is shown at the top of the page. Additional information may be provided when the change is significant.

21. Contact

For any questions regarding this policy or your personal data:

RALIA SOLUTIONS FOR MARKETING OPERATIONS
Baniyas Towers, Al Falah St - Saeed Bin Ahmed Al Otaiba St - Abu Dhabi, United Arab Emirates

Email: contact@opaleagency.fr
Website: www.opaleagency.fr