CTZAR – Privacy Notice for Influencers and Talents

WHO WE ARE

CTZAR SAS is a simplified joint stock company incorporated under the laws of France (societe par actions simplifiee) registered at the Trade and Companies registry of Paris under the numbers 501 240 634, based in France, with its headquarter is located 69 bis rue de Vaugirard, 75006 Paris, France (together, “CTZAR”, "we", "us" or "our").

This is our Privacy Notice for Influencers and Talents. Please read this Privacy Notice to ensure you are aware of how and why we use your personal data and how we comply with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and all other applicable data protection laws (together, “Data Protection Laws”).

 

What we do?

CTZAR provides influencer marketing and content creation services for leading global brands on large-scale communications projects, specialising in designing social ecosystems that foster positive and authentic conversations about brands (“Services”).  In connection with these Services, we utilise an internal group database of influencers, talents, VIPs, performers, models and production cast and crew (together, “Influencers and Talents”) through The Independents partner Lefty (the “Database”) in order to enable our clients to identify and manage their engagement with Influencers and Talents and in respect of our clients’ social media content creation.

In this Privacy Notice, the terms “you” or “your” will apply to the extent CTZAR collects, stores and processes your personal data as an Influencer and Talent in connection with its Services.

CTZAR respects your privacy and is committed to protecting your personal data. This Privacy Notice will inform you (i) how we protect your personal data when it is used on the Database or otherwise, (ii) of your privacy rights and (iii) how the Data Protection Laws protect you.  Please also see a copy of Lefty’s Privacy Notice for Creators in respect of the Database available on its website at www.lefty.io or HERE

We act as a controller of the personal data which we obtain about you.

 

What data do we process and how is it obtained?

Personal data is any information about an individual which makes them identifiable. It does not include anonymous data – being where the identity is removed.

We collate, store and use different kinds of data available to us about Influencers and Talents.  In respect of Influencers and Talents, the majority of such data is provided directly by such Influencers and Talents to either us or our clients.  We may also collect certain personal data from third parties, such as clients, although we would never purchase such data.

Such personal data may include:

  • (i) Identification information (name, surname, pseudo, photo, date of birth, gender, nationality etc)

  • (ii) Contact information (profile on social networks, email address, postal address, phone number when this information are public etc)

  • (iii) Information on opinions and preferences (style of dress, interests, recent published content etc)

  • (iv) Information about working life (job, field of activity, website and social account, number of subscribers, likes, comments, recent published content etc);

  • (v) Bank account details for processing payments

  • (vi) Passport details for organising bookings where applicable; anD

  • (vii) any other information which may be relevant to our Services.

CTZAR does not carry out any automated decision-making in the processing. 

How is your personal data used?

We only use your personal data to the extent permitted by applicable laws. We use your personal data where it is necessary to pursue our legitimate interests which is to provide our Services to our clients and also for your benefit.  Your interests and underlying rights do not override such interests.

The CTZAR Services, the Database and other data it processes may benefit Influencers and Talents by facilitating connections with brands to enable such brands to expand such Influencer’s and Talent’s presence in the marketing environment.  This in turn allows Influencers and Talents to enhance their specialisms and expertise.

The CTZAR Services, which are made possible by the Database and other data it processes, therefore provides a mutual benefit to both brands and Influencers and Talents by empowering each to build important and strategic relationships for their shared benefit. Further, the CTZAR Services provides wider public benefit by enabling the development of and insight into the wider influencer marketing environment.

Your personal data may also be used (i) where you have provided consent to the processing (subject to your withdrawal at any time), (ii) where it is necessary for us to comply with a legal obligation, or (iii) where it is necessary to perform a contract.

 

For what purpose will your personal data be used?

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links may allow third parties to collect or share data about you. We do not control these third-party sites and are not responsible for their privacy notices. We encourage you to check the privacy policy and notices of every website you visit.

 

PurposeS

1. Identify relevant influencers based on campaigns offered by partner brands. 

2. Offer relevant influencer profiles to partner brands and partner brand campaigns to relevant influencers.

3. Enable the proper execution of campaigns in which the Influencers and Talents concerned participate (for example, sending products to influencers in connection with the campaigns, inviting events, consulting services etc) and the monitoring of campaigns in which the Influencers and Talents concerned participate (for example, reporting to partner brands).

4. To provide measures and statistics, in particular to improve CTZAR’s services and communications.

legal basis

1. Legitimate Interest

2. Legitimate Interest

 3. Performance of a contract

 4. Legitimate Interest

We consider that there is a legitimate interest to process your personal data in order to be able to provide our Services to our clients, commercial brands and partners, notably because the processing of your data in this way also has advantages for you, Influencers and Talents. Indeed, the collection and processing of your personal data allows you to have the opportunity to be connected with our clients, to participate in their campaigns and thus to develop / finance your own activity as an influencer.

 

Opting-out or Unsubscribing

In certain circumstances you may have the right to request that we stop processing your personal data. To seek to exercise any such right, please email DPO@the-independents.com.

CTZAR reserves the right to refuse any such request to the extent permitted by applicable law.

Potential disclosures of your personal data

The main ways in which we may share your personal data are as follows:

  • to our clients;

  • to our group companies;

  • to third party service providers providing us with IT and hosting related services; and

  • to our professional advisers or any other persons to whom we are under a legal, professional or contractual duty to disclose.

Where a disclosure needs to be made to a third party, we will use our reasonable efforts to ensure that such persons respect the security of your personal data and Data Protection Laws.  To the extent any party acts in a capacity as a “processor” of any data “controlled” by us, we request Data Protection Agreements to ensure they adhere to Data Protection Laws in respect of your personal data.

 

International transfer of personal data

Any personal data we collect may be transferred from time to time to throughout the world – to our group personnel or third parties. Further, the Database and other data CTZAR processes may be accessed anywhere in the world by authorised CTZAR employees, including countries which may not have equivalent data protection laws.

Where we transfer your personal data outside of the EEA to countries which do not ensure adequate protection of personal data, we seek to use specific contracts approved pursuant to Data Protection Law. This requires such parties to protect your personal data to the standards required in the European Economic Area pursuant to the GDPR. To the extent we seek to rely on another basis for safe transfer of your personal data outside of the EEA, we will keep you updated by way of an update to this Privacy Notice.

 

Data security

We operate appropriate security measures designed to prevent accidental or unauthorised loss or access to your personal data. Further, we restrict access to your personal data to only those persons who have a business need to know. Persons processing your personal data on our behalf will only process your personal data pursuant to our instructions and are subject to duties of confidentiality.

 

Data retention

We only retain your personal data for as long as necessary to fulfil the purposes for which it was obtained. For this we consider the amount, nature and sensitivity of the applicable personal data, as well as the potential risk from unauthorised use or disclosure, the purposes for which we process your personal data, whether those purposes can be achieved by other means and any other applicable legal requirements.

Your legal rights

 In certain circumstances, you may have specific rights under Data Protection Laws in respect of your personal data, including:

  • To request access to your personal data – enabling you to obtain a copy of the personal data we hold about you in order to check it is being lawfully processed.

  • To request correction of your personal data – enabling you to have us correct any incomplete or inaccurate data we hold about you.

  • To request erasure of your personal data – enabling you to have your personal data deleted where there is no good reason for us continuing to process it and where we are lawfully able to comply with your request.

  • To object to processing of your personal data – in particular where we rely on a legitimate interest you consider it impacts your fundamental rights and freedoms or constitutes “profiling”.

  • To request restriction of processing of your personal data – enabling you to ask us to suspend the processing of your personal data in certain scenarios.

If you wish to exercise any of these rights, please email DPO@the-independents.com. CTZAR reserves the right to refuse any such request to the extent permitted by applicable law.

 

Data requests

You will typically not be required to pay a fee to access your personal data or exercise any of your rights. However, we may be permitted to charge a reasonable fee or refuse to comply with your request to the extent your request is unfounded, repetitive or excessive.  We aim to respond to all legitimate requests within one month.

 

Privacy practices of third parties

This Privacy Notice only considers our collection, processing and use (including disclosure) of your personal data. Our clients and other third parties may have access to your personal data and use it in other ways in accordance with their own privacy practices. We encourage you to familiarize yourself with the privacy statements provided by any platform you use to publish any data.

 

Changes to this Privacy Notice

Please note that we continually review this Privacy Notice and it is updated from time to time.  Please be sure to check frequently for any updates.

 

Further assistance

Please contact DPO@the-independents.com to the extent you have any questions regarding this Privacy Notice.

You may have the right to make a complaint at any time to the applicable supervisory authority which regulates the processing of personal data in the country in which you are located. However, we would appreciate the opportunity to deal with any concern before you approach such supervisory authority and welcome you to contact us at DPO@the-independents.com in the first instance.

 

Updated: 6 February 2026