CTZAR – Privacy Notice for Influencers and Talents
WHO WE ARE
CTZAR SAS is a simplified joint stock company incorporated under the laws of France (société par actions simplifiée) registered with the Paris Trade and Companies Register under the numbers 501 240 634, based in France, with its registered office at 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”).
This Privacy Notice supplements our General Privacy Notice and should be read together with it, including the Local Law Addendum and any applicable local privacy schedules made available on our website. The General Privacy Notice contains further information about our group structure, the relevant controllers, international transfers, data subject rights, local law requirements and how to contact us.
If there is any inconsistency between this Privacy Notice and the General Privacy Notice, this Privacy Notice will apply in relation to the specific processing described below, unless applicable local law requires otherwise.
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 may use an internal group database and tools provided by The Independents Group partner Lefty, including information relating to influencers, talents, VIPs, performers, models and production cast and crew (together, “Influencers and Talents”), to help our clients identify, analyse and manage potential collaborations, campaigns and social media content creation opportunities.
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
CTZAR acts as controller of the personal data that it collects, stores and processes about you in connection with the Services described in this Privacy Notice. Where another The Independents Group entity, Lefty, a client or another third party separately determines the purposes and means of processing your personal data, that entity may act as a separate controller and its own privacy notice may also apply.
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 is 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.
Some of the information we process may be treated as special category data, sensitive personal data or sensitive personal information under applicable law, for example dietary requirements where they reveal health information or religious beliefs, passport or identification details, or other information needed for travel, event access, accommodation, security, accessibility or health and safety purposes. We only process this information where necessary for the relevant purpose and where permitted by applicable law. Where applicable law requires consent or separate consent for this processing, we will obtain it.
Where we process information relating to minors, child performers, models or young talent, we do so only where necessary for the relevant campaign, production, booking, payment or legal/safeguarding purpose. We will obtain parent, guardian, agency or authorised representative consent where required and will apply enhanced safeguards.
CTZAR does not use your personal data to make decisions based solely on automated processing which produce legal or similarly significant effects on you, unless we notify you separately and do so in accordance with applicable law. Some tools used in connection with the Services may help us analyse Influencer and Talent profiles, public content, audience, engagement, relevance or suitability for campaigns. This may constitute profiling under applicable Data Protection Laws. You may object to profiling where applicable law gives you that right.
How is your personal data used?
We only use your personal data to the extent permitted by applicable law. Depending on the relevant activity, we may process your personal data on the basis of our legitimate interests, your consent, performance of a contract, compliance with legal obligations or other lawful grounds available under applicable local law.
Our legitimate interests include providing our Services to clients, identifying relevant Influencers and Talents for campaigns, managing campaigns, collaborations, events, productions, bookings, gifting and payments, maintaining industry and talent relationships, facilitating brand collaborations, sending relevant communications, improving our Services and managing our business. We have considered and balanced these interests against your rights and freedoms.
Where we rely on consent, including for certain marketing communications, processing of sensitive information, cookies or any processing requiring consent under local law, you may withdraw your consent at any time.
The CTZAR Services and the Database may benefit Influencers and Talents by facilitating connections and collaborations with brands, helping brands identify relevant profiles for campaigns and enabling Influencers and Talents to develop their visibility, specialist expertise, commercial opportunities and professional activity.
Further information about the lawful bases on which we rely is set out in our General Privacy Notice.
For what purpose will your personal data be used?
The purpose of the processing of your data is to enable Influencers and Talents to collaborate with brands in order to ensure the promotion of their products/services.
PurposeS
1. Identify relevant Influencers and Talents based on campaigns, productions or opportunities offered by partner brands or clients.
2. Present relevant Influencer and Talent profiles to partner brands and clients, and present relevant campaign opportunities to Influencers and Talents.
3. Enable the proper execution and management of campaigns, collaborations, events, productions, bookings, gifting, product sends, consulting services and related activities in which Influencers and Talents participate.
4. Monitor, report on and evaluate campaigns, including reporting to partner brands and clients.
5. Processing minors’ information for campaign, production, casting, travel, payment, safeguarding or legal purposes
6. Process payments and administer contracts, invoices and related financial records.
7. Produce measures, statistics, insights and analysis to improve CTZAR’s services, communications and campaign performance.
8. Comply with legal, regulatory, tax, accounting and reporting obligations.
CCPA category
1. Identifiers
2. Personal information
3. Commercial information
4. Internet or electronic network activity information
5. Geolocation data
6. Professional or employment-related information
7. Inferences
8. Sensitive personal information
Type of personal information
1. Business contact and relationship management data
2. Contract, project, procurement, invoicing and account records
3. Marketing contact data
4. Event attendance and preference data
5. Website analytics and cookie data
6. Compliance, sanctions, KYC and due diligence records
7. Complaints, disputes and legal claims records
EXAMPLES
1. Name, business email address, telephone number, employer, job title, business address, IP address, online identifiers
2. Business contact details, financial or transaction information, payment/invoicing details
3. Records of services provided or received, event attendance, business relationship information, purchase or transaction records
4. Website usage, cookie data, browsing interactions, device/browser information, analytics data
5. Approximate location inferred from IP address
6. Employer, job title, professional role, business contact details, work history where provided in a business context
7. Business interests, preferences, event interests, marketing preferences and relationship management notes
8. Account log-in details, government ID, financial account information or precise geolocation only where relevant and necessary
We do not knowingly, deliberately collect personal information from children under 16.
3. Sources of personal information
We may collect personal information from:
you directly;
your employer or organisation;
Agency Group companies and The Independents Group companies;
clients, suppliers, event partners and business partners;
publicly available sources, such as LinkedIn, professional directories, press sources, public registers and company websites;
cookies, analytics tools and website technologies;
service providers and contractors; and
compliance screening providers and professional advisers.
4. Purposes for which we collect and use personal information
We collect and use personal information for the purposes described in our General Privacy Notice, including:
managing business relationships;
communicating with you;
providing or receiving services;
administering contracts, projects, procurement, invoicing and accounts;
organising and managing events;
sending business updates, invitations and marketing communications;
website operation, analytics, security and improvement;
compliance, sanctions, anti-bribery, KYC and onboarding checks;
internal reporting, group administration and business operations;
protecting our business, systems, staff, clients and partners;
corporate transactions, integrations, mergers, acquisitions, reorganisations or asset sales; and
complying with legal and regulatory obligations.
5. Disclosure of personal information
We may disclose personal information to the following categories of recipients:
Category of recipient
1. Agency Group companies and The Independents Group companies
2. Service providers and contractors
3. Professional advisers
4. Clients, suppliers, event partners and business partners
5. Regulators, authorities, courts and law enforcement
6. Corporate transaction parties
Category of personal information
1. Identifiers, such as IP address, cookie IDs or online identifiers
2. Internet or electronic network activity information
3. Inferences, such as business interests or marketing preferences
Categories of third parties
1. Analytics, advertising or marketing technology providers
2. Analytics, advertising or marketing technology providers
3. Analytics, advertising or marketing technology providers
legal basis
1. Legitimate interests
2. Legitimate interests
3. Performance of a contract; legitimate interests
4. Legitimate interests; performance of a contract
5. Performance of contract; legitimate interests; legal obligation; parental/guardian consent where required
6. Performance of a contract; legal obligation; legitimate interests
7. Legitimate interests
8. Legal obligation
CTZAR does not use sensitive characteristics, inferred sensitive traits, children’s data or protected characteristics for discriminatory targeting, exclusion or profiling.
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.
We will comply with your request where required by applicable law. In some circumstances, we may be permitted or required to continue processing certain personal data, for example for legal, regulatory, security, accounting, dispute or suppression-list purposes.
Potential disclosures of your personal data
Where relevant to a defined campaign, collaboration, event, production, booking, gifting, payment, reporting activity or other Service, we may share limited personal data with clients, brands, event partners, production partners, casting partners, logistics providers, travel providers, venues, payment providers or other suppliers where necessary for that purpose.
We may also share your personal data with other companies in The Independents Group, including Lefty where relevant, and with third-party service providers and platforms providing us with IT, hosting, CRM, database, analytics, payment, communications, production, event administration and related services. These providers may process personal data in countries outside your country of residence, subject to appropriate safeguards where required by law.
Lastly, we may disclose your personal data to our professional advisers, regulators, public authorities or any other persons to whom we are under a legal, professional or contractual duty to disclose.
Where we disclose personal data to third parties, we take appropriate steps designed to ensure that such persons respect the security of your personal data and process it in accordance with applicable Data Protection Laws.
Where a third party processes personal data on our behalf, we require appropriate data protection terms to be in place.
International transfer of personal data
Because we operate as part of an international group, your personal data may be accessed by or transferred to CTZAR, The Independents Group, Lefty, clients, brands, service providers, production partners, event partners, payment providers and other relevant third parties in jurisdictions outside your country of residence, including the UK, EEA, United States, Hong Kong, Singapore, Korea, PRC / Mainland China and other countries in which we, our clients or our service providers operate.
Where we transfer personal data internationally, we take steps designed to ensure appropriate protection in accordance with applicable law. These may include adequacy decisions, EU Standard Contractual Clauses, UK-approved transfer mechanisms, transfer impact assessments, contractual safeguards, consent where required, local filings or assessments where required, or other lawful transfer mechanisms.
More information about international transfers is set out in our General Privacy Notice and Local Law Addendum.
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 retain your personal data only for as long as reasonably necessary for the purposes for which it was obtained, including to manage Influencer and Talent relationships, administer campaigns, collaborations, events, productions, bookings, gifting, payments, reporting, the Database, legal and regulatory obligations, disputes and our legitimate business records.
In general:
Influencer and Talent profile and relationship data is retained for as long as you remain relevant to our Services, campaigns, productions, events, industry relationships or client work, unless you object or request deletion and we are required or able to comply.
Campaign, collaboration, production, event, gifting, booking and reporting records are retained for the duration of the relevant activity and for a reasonable period afterwards for business administration, legal, audit and dispute purposes.
Passport, travel, accommodation, dietary, accessibility, identification or similar logistics information is retained only for as long as necessary for the relevant booking, event, production, travel, security, health and safety or legal purpose, unless a longer period is required by law.
Payment, billing, contract, tax and accounting records are retained for as long as required for tax, accounting, legal, audit and payment administration purposes.
Suppression records may be retained where necessary to ensure that we respect opt-out, objection or deletion requests.
When determining the appropriate retention period, we consider the nature and sensitivity of the personal data, the purposes for which it is processed, applicable legal limitation periods, regulatory requirements and our legitimate business needs. Further details are set out in our Data Retention Policy, available on request.
When personal data is no longer required, we will delete it, anonymise it or securely archive it in accordance with our policies and applicable law.
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. We will comply with your request where required by applicable law. In some circumstances, we may be permitted or required to continue processing certain personal data, for example for legal, regulatory, security, accounting, dispute or suppression-list purposes.
Further details of your rights, including any additional rights available under applicable local law, are set out in our General Privacy Notice, Local Law Addendum and any applicable local privacy schedule.
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 or within such other timeframe as required by applicable law.
Privacy practices of third parties
This Privacy Notice applies to CTZAR’s processing of personal data. Clients, brands, social media platforms, production partners and other third parties may process your personal data in accordance with their own privacy notices and terms. We encourage you to review the privacy notices of any social media platform, client, brand or third-party service you use or interact with.
Our Services may use YouTube API Services and other social media APIs to access publicly available or authorised data. The use of YouTube API Services is subject to the Google Privacy Policy, available at: https://policies.google.com/privacy, and the YouTube Terms of Service, available at: https://www.youtube.com/t/terms.
Where you have authorised access to Google or YouTube data, you may revoke access through your Google Security Settings Page: https://myaccount.google.com/permissions.
Where applicable, our use and transfer of information received from Google APIs will comply with the Google API Services User Data Policy, including the Limited Use requirements.
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 if you have any questions regarding this Privacy Notice or wish to exercise your privacy rights.
If you are located in the European Economic Area, the United Kingdom or Switzerland, you have the right to make a complaint at any time to your local data protection supervisory authority.
As CTZAR is established in France, you may also contact the French data protection authority, the Commission Nationale de l’Informatique et des Libertés (CNIL): https://www.cnil.fr.
A list of EU/EEA Data Protection Authorities can be found here: https://edpb.europa.eu/about-edpb/board/members_en.
We would, however, appreciate the chance to address your concerns before you approach a supervisory authority, so please contact us in the first instance at DPO@the-independents.com.
Updated: 6 February 2026
Privacy Notice – California Privacy Schedule
This California Privacy Schedule supplements our General Privacy Notice and applies to California residents where the California Consumer Privacy Act, as amended by the California Privacy Rights Act – together, the CCPA – applies to our processing of personal information.
This Privacy Schedule is intended to provide additional California-specific disclosures, including a notice at collection, and should be read together with our General Privacy Notice.
For the purposes of this Privacy Schedule, “personal information”, “sensitive personal information”, “sell”, “share”, “service provider” and “contractor” have the meanings given under the CCPA.
Otherwise, unless defined herein, capitalised terms in this Privacy Schedule shall be as defined in our General Privacy Notice. In particular, “Agency” and “Agency Group” refer to the specific agency, legal entity or group of entities responsible for the relevant processing, as described in the General Privacy Notice.
1. Who this Privacy Schedule applies to
This Privacy Schedule applies to California residents whose personal information we process, including:
visitors to our website;
clients, prospective clients, suppliers, prospective suppliers, business partners and their representatives;
event attendees and prospective event attendees;
business contacts and prospective business contacts; and
individuals who communicate with us or interact with us in a business context.
This Privacy Schedule does not apply to personnel, employee or candidate data unless expressly stated or required by applicable law.
2. Categories of personal information we collect
We may collect the following categories of personal information:
COLLECTED?
1. Yes
2. Yes
3. Yes
4. Yes
5. Limited
6. Yes
7. Yes
8. Not usually / limited where required
Purpose of disclosure
1. Group administration, reporting, business operations, relationship management and service delivery
2. IT, hosting, CRM, communications, marketing, event administration, analytics, compliance screening and business support
3. Legal, audit, accounting, insurance, banking and consultancy services
4. Business relationship management, service delivery, project administration and event administration
5. Compliance with legal obligations, regulatory requirements and protection of rights
6. Mergers, acquisitions, reorganisations, investments, integrations, financing transactions or asset sales
6. Categories of personal information disclosed for business purposes
In the preceding 12 months, we may have disclosed the following categories of personal information for business purposes:
identifiers;
personal information described in Cal. Civ. Code §1798.80;
commercial information;
internet or electronic network activity information;
approximate geolocation data;
professional or employment-related information;
inferences; and
sensitive personal information, only where relevant and necessary.
7. Sale, sharing and targeted advertising
We do not sell personal information for monetary consideration.
However, under California law, “sale” and “sharing” can include certain disclosures of personal information to third parties through cookies, pixels, analytics, advertising or similar technologies, even where no money is exchanged. Where applicable, certain cookie, pixel, analytics, advertising or similar technologies may be considered a “sale” or “sharing” of personal information under California law, even where no money is exchanged.
Where applicable, we may “share” or “sell” the following categories of personal information for cross-context behavioural advertising, analytics or similar purposes:
Purpose
1. Analytics, marketing measurement, advertising and website optimisation
2. Website analytics, marketing measurement and advertising
3. Marketing, audience insights and business development
You may opt out of sale or sharing by:
using our cookie consent tool; or
contacting us at DPO@the-independents.com.
8. Sensitive personal information
We do not use or disclose sensitive personal information for purposes that require a right to limit under the CCPA, unless we provide you with a right to limit such use or disclosure.
Where we collect sensitive personal information, we do so only as reasonably necessary for permitted business purposes, such as security, compliance, account administration, legal obligations or provision of requested services.
9. Retention
We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including for legal, regulatory, tax, accounting, audit, reporting, security, compliance, corporate recordkeeping or dispute purposes.
In general:
Indicative retention approach
1. Retained for the duration of our relationship with you or your organisation and for a reasonable period afterwards for business administration, relationship management and legal purposes
2. Retained for the duration of the relevant relationship, contract or project and typically for 6–7 years afterwards, unless a longer period is required by law
3. Retained until you unsubscribe, opt out or object, after which we may retain limited suppression details to ensure that we respect your preferences
4. Retained for as long as necessary for event administration, relationship management and marketing purposes, unless you opt out earlier
5. Retained for the periods described in our Cookies Policy or cookie consent tool
6. Retained for as long as necessary to satisfy legal, regulatory, audit, compliance and risk management requirements
7. Retained for the duration of the matter and for such period afterwards as necessary to protect our legal rights and comply with applicable limitation periods
Further details are set out in our Data Retention Policy, available on request.
10. Your California privacy rights
Subject to applicable law, California residents may have the right to:
know/access the personal information we collect, use, disclose, sell or share;
request a copy of specific pieces of personal information;
request correction of inaccurate personal information;
request deletion of personal information;
obtain a portable copy of personal information;
opt out of sale or sharing of personal information;
limit certain uses and disclosures of sensitive personal information, where applicable; and
not be discriminated against for exercising CCPA rights.
11. How to exercise your rights
To exercise your California privacy rights, please contact us at: DPO@the-independents.com
Where available, you may also use any privacy request form, cookie consent tool or opt-out link made available on the relevant Agency website.
We may need to verify your identity before responding to your request. The information required for verification may depend on the nature of your request and your relationship with us.
12. Authorised agents
You may use an authorised agent to submit a privacy rights request on your behalf.
We may require the authorised agent to provide proof that you authorised them to act on your behalf. We may also require you to verify your identity directly with us or confirm that you provided the authorised agent with permission to submit the request.
13. Non-discrimination
We will not discriminate against you for exercising your rights under the CCPA.
14. Financial incentives
We do not offer financial incentives or price or service differences in exchange for the collection, retention, sale or sharing of personal information, unless we provide you with separate notice as required by applicable law.
15. California “Shine the Light”
California residents may request information about certain disclosures of personal information to third parties for their own direct marketing purposes, where applicable.
To make such a request, please contact: DPO@the-independents.com
16. Contact
If you have questions about this Privacy Schedule or our privacy practices, please contact: DPO@the-independents.com
17. Updates
We may update this Privacy Schedule from time to time. The latest version will be made available on the relevant Agency website or otherwise provided as required by applicable law.
Updated: April 2026