Privacy Policy

1. Who we are

Data controller:
Mr Edward Matthew Lewis (trading as Ed Lewis Photography and Model Haven)
116 Evelyn Street, Great Sankey, Warrington, Cheshire, WA5 1BJ
eddiemlewis@virginmedia.com

ICO registration:
We are registered with the UK Information Commissioner's Office (ICO).
Registration reference: ZC191443
Date registered: 06 July 2026
Registration expires: 05 July 2027
Payment tier: Tier 1

At present, we have not appointed a Data Protection Officer (DPO) because we are not yet legally required to do so. As the platform grows and our processing activities expand, we expect to appoint a DPO and will update this policy with their contact details.

2. What this site does

Model Haven is a model safety platform designed to:

• Provide a space where models can manage their information and engage with safety‑focused content.
• Allow registered members (for example, photographers, studios or other industry professionals) to access safety‑related information and model profiles in a controlled way.
• Promote safer working practices in the modelling and photography community.

To do this, we need to store and process certain personal information.

3. What personal data we collect and retain

We may collect and retain the following categories of personal data:

3.1 Account and identity information

• Name, display name, username
• Email address
• Optional phone number
• Optional social media handles or website links
• Password (encrypted), login history, account status
• Role information (model or member)

3.2 Profile information (models)

• Profile photo(s) and other images you upload
• Biography / description
• Location (city / region)
• Modelling categories / preferences
• Availability and general working preferences

All of this is provided by you and can be edited or removed from your profile.

3.3 Profile information (members)

• Business or trading name
• Portfolio links or website URLs
• Location (city / region)
• Short description of services

3.4 Safety‑related information

• Safety notes or reports submitted by users
• Internal flags or notes relating to misuse or breaches of terms
• Communication logs relating to safety concerns

We do not intend to store detailed criminal records or "special category" data. If such information is ever provided incidentally, we will treat it with extra care and minimise its use.

3.5 Technical and usage data

• IP address, browser type, device type, operating system
• Pages visited, actions taken, timestamps
• Cookies and similar technologies for login sessions, security, and basic analytics

4. What information is visible and to whom

We divide visibility into three main levels:

4.1 Public (non‑logged‑in visitors)

• Model display name or chosen alias
• Selected profile photo(s)
• City / region
• Modelling categories / genres
• Short public biography

4.2 Logged‑in members (photographers, studios, agencies)

Members may see:

• Additional profile information models choose to share
• Portfolio images
• Safety‑related information appropriate for community visibility
• Contact details only if the model has explicitly granted permission (see Section 5A)

4.3 Logged‑in models (their own accounts)

Models can see:

• All information in their own profile
• Any safety‑related information they have submitted
• Account settings and privacy controls

Models do not automatically see private information about other users.

5. Legal bases for processing

We process personal data under the UK GDPR and the Data Protection Act 2018 on the following lawful bases:

• Contract – to create and manage your account
• Legitimate interests – to maintain a safe community and protect users
• Consent – for optional features and for sharing contact details
• Legal obligation – where required by law

5A. Consent for sharing contact details (telephone numbers, email addresses, social links)

Because Model Haven is a safety‑focused platform, we do not automatically share any direct contact information (such as phone numbers, email addresses, or private social media accounts) with agencies, photographers, studios, or other members.

We will only share your contact details if you explicitly grant permission. This means:

• When you register as a model, your contact telephone number, email address, and any private social links are hidden by default.
• You must actively choose to make these visible to registered members.
• You may withdraw this permission at any time through your account settings.
• If you do not grant permission, your contact details will remain private and will not be shared.

We will never override your privacy settings or share your contact details without your consent unless required by law.

6. How we use your data

We use personal data to:

• Create and manage user accounts
• Display profiles and safety‑related information
• Support communication and safety‑focused interactions
• Monitor platform security
• Improve the Site
• Comply with legal and regulatory requirements

We do not sell your personal data.

7. Data sharing

We may share your data:

• With service providers who help us operate the Site
• With law enforcement or regulatory bodies when legally required
• With other users, but only according to your visibility settings and consent choices

We do not share your data with third parties for their own marketing.

8. International transfers

If any service providers are located outside the UK, we ensure appropriate safeguards are in place.

9. Data retention

• Account data is kept while your account is active
• Safety‑related information may be retained longer where necessary
• Technical data is retained for a limited period

10. Your rights

You have rights under UK data protection law, including access, rectification, erasure, restriction, objection, portability, and withdrawal of consent.

11. Cookies and tracking technologies

Used for login sessions, preferences, and basic analytics.

12. Security

We use appropriate technical and organisational measures to protect your data.

13. Complaints and contact

Email: eddiemlewis@virginmedia.com

You may also contact the ICO if you are unhappy with how we use your data.

14. Changes to this policy

We may update this policy from time to time. Significant changes will be communicated to users.