1. Introduction.

(a) Website Owner. TopModeal, Inc., a/k/a Selekt ("Selekt," the "Company," "we," and "us") is committed to maintaining a safe and trustworthy private community and we understand that privacy and confidentiality are of the utmost importance to our Clients, Talent, and other users ("you"). Your privacy is a top priority in everything that we do and every feature that we develop. To that end, the policy set forth below (the "Privacy Policy") reflects our commitment to protecting your privacy and describes the information we collect, how that information may be used, and with whom it may be shared. We have attempted to describe the policy in plain language, limiting legal and technical jargon where possible. By using our application or website (collectively, the "App"), certain features of the App, or related services, including, but not limited to, those related to RSVPing and/or attending events which are advertised, featured, hosted or otherwise disseminated through the App (collectively, the "Service"), you are agreeing to be bound by the terms described in this Privacy Policy. This Privacy Policy applies to all use by both Clients and Talent of the Service. We encourage you to read this Privacy Policy and our Terms of Service carefully and contact us at members@theselekt.com with any questions you may have. We will occasionally update this Privacy Policy to reflect changes in the law, our data collection and use practices, the features of our Service, or advances in technology. When we make changes, we will revise the “updated” date at the top of this Privacy Policy, which will be posted prominently on our website and the App. We encourage you to regularly check for the most recent version, as your continued use of the Service following the posting of changes to this Privacy Policy will mean you consent to and accept them. If you do not consent to such changes you can terminate your account at any time as described in our Terms of Service.

(b) Anonymous Website Visits. In general, you can visit the Selekt Website or app without disclosing or revealing any personal information. Selekt does not keep track of the domains from which people visit us, however Selekt analyzes the data gathered from Website visits for trends and statistics, and then discards the gathered data.

(c) Website Transactions. At times, Selekt will need personal information regarding a customer or a prospect. For example, to process an event order or provide a membership subscription, Selekt may need to know a customer`s name, mailing address, e-mail address and credit card details. It is Selekt`s intent to inform you now before Selekt collects personal information, such as a user`s name and/or address on the Internet. If you tell us that you do not wish to have this information used as a basis for further contact with you, Selekt will respect your wishes

(d) Third Party Certification. Selekt abides by the Safe Harbor framework as set forth by the United States Department of Commerce regarding the collection, use and retention of information collected from the European Union.

2. Personal Information That May Be Collected.

(a) Identifying Information. In order to access the App, you will be asked to begin an application using certain credentials such as your social media handle(s), contact information, and phone contacts, among other things. Upon doing so, you authorize us to access information from your social media account(s), such as your username, profile picture, biography, website, and number of pictures. This information is used to verify your identity and to evaluate your connection to our existing members, among other things. You will also be asked to allow us to collect your geographical location information, particularly while on a booking as Talent, and you may respond to such request by allowing us to collect location information at all times, only while you are using the App or not at all. Further, you may be asked if you would like to display your specific location to other users. The disclosure of your location to other users is not required for you to use the Service and may be enabled or disabled by you at any time through the App settings. In addition, we may collect and store any personal information you provide in connection with your application, while using our Service, which may include, identifying information such as your name, social media handle(s), email address, date of birth, gender, city of residence, telephone number. In connection with your use of the Service, you may also provide us images, video, a biographical description, information about your gender and preferences for recommendations and connections. Some of the information that you provide may be considered “special” or "sensitive" in certain jurisdictions. By choosing to provide this information, you consent to our processing of it. Any information you provide may be viewable by other users of the Service. If you communicate with other users within the Service, you provide us the content of your conversation. Should you contact us with an inquiry, we may collect the content of that correspondence or interaction. You may change your personal information (other than your date of birth) at any time within the App settings.

(b) Information Collected Automatically. In addition to the information you provide, certain information will be automatically collected as you use the Service, including, but not limited to, the operation system used by your device, your device type and ID, your IP address, how and how often you interact with other users and your access times. If you grant us permission to use location services, we will automatically collect data regarding your geographical location at all times or while the App is actively running, depending on the permission that you grant us. Note that even if you do not grant us permission to use location services, we may collect data regarding your city, state and general location (not your exact location) through your IP address, and for the purposes of ensuring booking attendance and completion if you are Talent.

(c) Service Quality Monitoring. Some Website or app transactions and services may require a customer to telephone Selekt, or Selekt to call the customer. Selekt will not contact you by telephone without your prior consent, except to confirm an order placed online and/or to inform a customer of the status of such order. Customer should be aware that it is Selekt's practice to monitor, and in some cases record such calls, for staff training or quality assurance purposes.

(d) Information from Children. Selekt does not sell products or services for purchase by children, and will not collect or post information from a child under the age of 18 without the involvement of a parent or guardian. Selekt will notify the child`s parent or guardian at the e-mail address provided by the prospective customer, alerting the parent or guardian to the child`s use of the Website and providing instructions as to how the parent or guardian can delete the child`s registration from the Website. Selekt does not use personally identifying information collected from, by, or about children for any purpose and will immediately delete all such information once discovered.

(e) Lost or Stolen Information. If a customer`s credit card and/or password is lost or stolen, the customer should promptly notify Selekt in order to enable Selekt to cancel the lost or stolen information and to update its records with the updated information

(f) Chat Rooms, Forums and Bulletin Boards. If a customer participates in a Selekt chat with another user, public discussion forum, or posts messages to a Selekt bulletin board, if any exist, customer should be aware that the information disclosed and shared may be broadly available to other persons, both inside of and/or outside Selekt, who have access to that chat, forum or bulletin board. Some individual Selekt chat rooms, forums or bulletin boards have additional rules and conditions regarding participation. Also, participant`s expressed opinion is his or her own and should not be considered as reflecting the opinion of Selekt.

(g) Links to Other Websites. The Selekt Website may contain links to other websites. Selekt is not responsible for the privacy practices, any other policies, or the content of those other Websites.

(h) Financial information. As we exclusively accept payment through third party services such as Stripe, we will never ask for your credit card information and your financial details are, and will remain, secured by and subject to the applicable third party’s security and privacy policies.

3. Uses Made of the Information.

(a) Limited Uses Identified. Without customer`s prior consent, Selekt will not use your personal identifiable information for any purpose other than that for which it is submitted. Selekt uses personal identifiable information to reply to inquiries, handle complaints, provide operational notices and in program record-keeping. Selekt also processes billing and business requests related to Selekt Website participation.

(b) Marketing Uses. Unless customer marks an "x" on the opt-out option box herein provided, Selekt reserves the right to provide customer with information about Selekt`s Website, Selekt products and services, and related information in which customer has indicated an interest.

(c) Stored Information Uses. Selekt stores the information provided by customer and the information entered on the Selekt Website. We may use information that we collect about you to, among other things, (i) create and manage your account, (ii) manage events, RSVP lists and otherwise operate and improve the events feature, (iii) deliver and improve the Service, including developing new features, (iv) facilitate and monitor use, content and interactions among users, (v) perform research, analysis and analytics internally or by using a third party service such as Google Analytics, (vi) manage our business, (vii) communicate with you and (viii) enforce or exercise rights under our Terms of Use. Information that we disclose to Google Analytics is subject to Google's privacy terms.

(d) Applicants. Only other users whose applications have been accepted will be able to see your App profile. Applicants who have not yet been approved will have no way to know or see that you are a member of the Selekt community just as users cannot see which applicants have been approved.

(e) Service providers; Promotional Partners. We may share non-personal, nonidentifiable information with third parties that perform services on our behalf or that provide promotional benefits to you as a Selekt member. These service providers and promotional partners may have access to such non-personal, non-identifiable information needed to perform their functions but are not permitted to share or use such information for any other purposes.

(f) Other Situations. We may disclose your information in connection with (i) certain legal matters and to ensure legal compliance, (ii) a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency, (iii) a significant corporate transaction, such as the sale of our business or its assets, or (iv) your consent or request that we do so.

(g) Aggregated and Non-Personal Information. In addition to the uses of your personal information referenced above, we may use and share non-personal, non-identifiable information we collect through your use of the Service. We may also use and share aggregated, non-personal information with third parties including advisors, investors and professionals for purposes related to our business.

(h) Legal Bases for Processing your Information. We rely on the following legal bases in processing your information: (i) most of the time, the reason we process your information is to perform the contract that you have with us. For instance, as you go about using our service to build meaningful connections, we use your information to maintain your account and your profile, to make it viewable to other users and recommend other users to you; (ii) we may also use your information where we have 4 legitimate interests to do so (for instance, we analyze users’ behavior to improve the Service and develop new features, and we process information for administrative, fraud detection and other legal purposes); and (iii) finally, from time to time we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us at members@theselekt.com.

4. Disclosure of the Information.

(a) Within Corporate Organization. Selekt is a multinational organization, with legal entities, business processes, management structures, and technical systems that cross borders. Selekt may share your personal information within the Selekt corporate organization, and may transfer the information to countries in the world where Selekt conducts business. Some countries may provide less legal protection for customer personal information. In such countries Selekt will still handle customer personal information in the manner describe herein.

(b) Mergers and Acquisitions. Circumstances may arise where for business reasons, Selekt decides to sell, buy, merge or otherwise reorganize its businesses in the United States or some other country. Such a transaction may involve the disclosure of personal identifying information to prospective or actual purchasers, and/or receiving such information from sellers. It is Selekt`s practice to seek appropriate protection for information in these types of transactions.

(c) Agents. Selekt employs or engages other companies and individuals to perform business functions on behalf of Selekt. These persons are provided with personal identifying information required to perform their functions, but are prohibited by contract from using the information for other purposes. These persons engage in a variety of functions which include, but are not limited to, fulfilling orders, delivering packages, removing repetitive information from customer lists, analyzing data, providing marketing assistance, processing credit card payments, providing legal support, and providing customer services.

(d) Marketing Analysis by Third Parties. Selekt reserves the right to disclose to third parties personal information about customers for marketing analysis; however, any information disclosed will be in the form of aggregate data that does not describe or identify an individual customer

(e) Disclosure to Governmental Authorities. Under certain circumstances, personal information may be subject to disclosure pursuant to judicial or other government subpoenas, warrants or orders.

5. Use of Computer Tracking Technologies.

(a) No Tracking of Personal Information. Selekt`s Website and app are not set up to track, collect or distribute personal information not entered by visitors. Through website access logs Selekt does collect clickstream data and HTTP protocol elements, which generate certain kinds of non-identifying site usage data, such as the number of hits and visits to our sites. This information is used for internal purposes by technical support staff for research and development, user analysis and business decision making, all of which provides better services to the public. The statistics garnered, which contain no personal information and cannot be used to gather such information, may also be provided to third parties.

(b) Use of Cookies. Selekt, or its third-party vendors, collects non-identifiable and personal information through the use of various technologies, including "cookies". A cookie is an alphanumeric identifier that a website can transfer to customer`s hard drive through a customer`s browser. The cookie is then stored on customer`s computer as an anonymous tag that identifies the customer`s computer, but not the customer. Cookies may be sent by Selekt or its third-party vendors. Customer can set its browser to notify customer before a cookie is received, giving an opportunity to decide whether to accept the cookie. Customer may also set its browser to turn off cookies; however, some Websites may not then work properly

(c) Use of Web Beacon Technologies. Selekt may also use Web beacon or other technologies to better tailor its Website and app to provide better customer service. If these technologies are in use, when a visitor accesses these pages of the Website or app, a non-identifiable notice of that visit is generated which may be processed by Selekt or by its suppliers. Web beacons usually work in conjunction with cookies. If customer does not want cookie information to be associated with customer`s visits to these pages, customer can set its browser to turn off cookies; however, Web beacon and other technologies will still detect visits to these pages, but the notices they generate cannot be associated with other non-identifiable cookie information and are disregarded

(d) Collection of Non-Identifiable Information. Selekt may collect non-identifiable information from user visits to the Selekt Website and app in order to provide better customer service. Examples of such collecting include: traffic analysis, such as tracking of the domains from which users visit, or tracking numbers of visitors; measuring visitor activity on the Selekt Website and app; Website and system administration; user analysis; and business decision making. Such information is sometimes known as "clickstream data." Selekt or its contractors may use this data to analyze trends and statistics.

(e) Collection of Personal Information. Selekt collects personal identifying information from customer during a transaction. Selekt may extract some personally identifying information about that transaction in a non-identifiable format and combine it with other non-identifiable information, such as clickstream data. This information is used and analyzed only at an aggregate level (not at an individual level) to help Selekt understand trends and patterns. This information is not reviewed at an individual level.

6. Information Security.

(a) Cross-Border Data Transfers. Sharing of information referenced above sometimes involves cross-border data transfers, for instance to the United States and other jurisdictions. As an example, the personal information of users located in the European Economic Area (“EEA”) is transferred to countries outside of the EEA. In doing so, we take all reasonable steps to ensure that personal information remains protected. For instance, we use standard contract clauses approved by the European Commission or other suitable safeguards to permit data transfers from the EEA to other countries. Standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of your data. If you would like to receive additional information on the safeguards that we implement, please contact us at members@theselekt.com.

(b) Security Measures; No Liability. We take the security of your information very seriously and have implemented a number of measures to safeguard it. Despite our efforts, no system is guaranteed to be completely secure. While we have taken, and will continue to take, reasonable actions to regularly update and improve our security, including regularly monitoring our systems for possible vulnerabilities and attacks and regularly reviewing our information collection practices, we do not promise, nor you should expect, that your information, chats, or other communications will always remain secure. We have no liability to you or to any third party arising out of any loss, misuse or alteration of your personal information. Users outside of the United States should note that your information may be transferred to our servers which are hosted within or outside the United States. By using the Service you consent to the transfer of your information to countries which may not provide the same level of protection available in your country of residence. If you believe that your account or information is no longer secure, or otherwise have information that may be relevant to us regarding information security, please notify us immediately at members@theselekt.com.

(c) Retaining Your Information. We keep your personal information only as long as we need it for legitimate business purposes and as permitted by applicable law. To protect the safety and security of our users on and off the Service, we implement a safety retention window of three months following account deletion. During this period, account information will be retained although the account will not be visible on the App. In practice, we delete or anonymize your information upon deletion of your account (following the safety retention window) or after two years of continuous inactivity, unless (i) we must keep it to comply with applicable law; (ii) there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or (iii) the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users safety and security. Keep in mind that 7 even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific timeframe due to technical constraints.

7. Text Messages and Other Communications

By using the Service in any capacity, including RSVPing to an event or otherwise engaging with our Events feature, you agree to receive text messages and other correspondence from us regarding event update as well as upcoming events, features, and other promotional matters, which messages and other correspondence may be based on information that you have provided and other data that we have collected based on your use of the Service.

8. Your Rights

(a) Tools to Control Your Information. You are in control of your information, so we have provided you with the following tools: (i) account settings that help you to access, rectify or delete information that you provided to us and that is associated with your account directly within the Service; (ii) mobile device permission systems for specific types of device data and notifications, such as phone book and location services as well as push notifications, which you can use to change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications; and (iii) you can delete your account at any time by using the corresponding functionality directly on the Service. You can also, at any time in your sole discretion, withdraw any consent that you give us with respect to your personal information. To withdraw your consent, or if you have any question regarding the above, please contact us at members@theselekt.com.

(b) TKey Points to Remember. We want you to be aware of your privacy rights. You should remember that you have the following rights with respect to your information: (i) you may review the personal information we keep about you (depending on the jurisdiction, this may be called right of access, right of portability or variations of those terms) and you can request a copy of your personal information by putting in such a request through memebrs@theselekt.com; (ii) if you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion or object to its processing, please contact us at members@theselekt.com; (iii) you may direct us to restrict or “block” the processing of personal information in certain circumstances, such as where you contest its accuracy or object to our processing of the information; (iv) you have the right to obtain your personal information that you provided to us and you may use such information elsewhere. For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests. Keep in mind, we may reject requests for certain reasons, including if the request is 8 unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user. If you wish to receive information relating to another user, such as a copy of any messages you received from him or her through our service, the other user will have to contact us to provide their written consent before the information is released. Also, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our Service to you anymore. For instance, we cannot provide our service if we do not have your date of birth.

(c) Uninstall and Accountability. Remember that you can stop all information collection at any time by uninstalling the App using the standard uninstall process for your device. If you uninstall the App from your mobile device, the unique identifier associated with your device will continue to be stored. If you re-install the application on the same mobile device, we will be able to re-associate this identifier to your previous transactions and activities. In certain countries, including those in the European Union, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work or where we are established.

9. Privacy Policy Changes and Opt-Out Rights.

(a) Changes to Privacy Policy. This privacy notice was last updated on April 11, 2024. Selekt reserves the right to change or update its privacy policy statement at any time. A notice of any material change will be made available to all customers through Selekt`s app and Website. There are two boxes at the end of Selekt`s notice of change: (1) an "I accept" box, and (2) an "I do not accept" box, or words of similar import. If customer does not mark the "I do not accept" box, customer will have accepted Selekt`s privacy policy updates.

(b) Opt-Out Right. All Website and app users have the right at any time to cease permitting personal information to be collected, used or disclosed by Selekt and/or by any third parties with whom Selekt has shared and/or transferred such personal information. Right of cancellation may be exercised by contacting Selekt via e-mail members@theselekt.com, telephone or certified postal mail. After processing the cancellation, Selekt will delete such user`s personal information from its data base.

10. Access Rights to Data.

(a) Information Maintained by Selekt. Upon customer`s request, Selekt will provide a reasonable description of customer`s personally identifiable information that Selekt maintains in its data bank. Selekt can be contacted by e-mail at members@theselekt.com.

(b) Corrections and Changes to Personal Information. Help Selekt to keep customer personal information accurate. If customer`s personal information changes, or if customer notes an error upon review of customer information that Selekt has on file, please promptly e-mail Selekt and provide the new or correct information.

(c) Your California Privacy Rights. Beginning on January 1, 2005, California Civil Code Section 1798.83 permits customers of Selekt who are California residents to request certain information regarding Selekt`s disclosure of personal information for their direct marketing purposes. To make such a request, please write to: members@theselekt.com Within 30 days of receiving such a request, Selekt will provide a list of the categories of personal information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. Selekt reserves its right not to respond to requests submitted other than to the address specified in this paragraph.
California`s privacy laws require a company to provide notice to California users of their rights to receive information on to which entities their information was shared for marketing purposes.

(d) GDPR
We may be collecting and using information from you if you are from the European Economic Area (EEA), and in this section of our Privacy Policy we are going to explain exactly how and why this data is collected, and how we maintain this data under protection from being replicated or used in the wrong way.

What is GDPR?
GDPR is an EU-wide privacy and data protection law that regulates how EU residents data is protected by companies and enhances the control the EU residents have over their Personal Data. The GDPR is relevant to any globally operating company and not just the EU-based businesses and EU residents. Our customers’ data is important irrespective of where they are located, which is why we have implemented GDPR controls as our baseline standard for all our operations worldwide.

What is Personal Data?
Any data that relates to an identifiable or identified individual. GDPR covers a broad spectrum of information that could be used on its own, or in combination with other pieces of information, to identify a person. Personal data extends beyond a person’s name or email address. Some examples include financial information, political opinions, genetic data, biometric data, IP addresses, physical address, sexual orientation, and ethnicity.
The Data Protection Principles include requirements such as:
● Personal data collected must be processed in a fair, legal, and transparent way and should only be used in a way that a person would reasonably expect.
● Personal data should only be collected to fulfill a specific purpose and it should only be used for that purpose.
Organizations must specify why they need the Personal Data when they collect it.
● Personal Data should be held no longer than necessary to fulfill its purpose.
● People covered by the GDPR have the right to access their own Personal Data. They can also request a copy of their data, and that their data be updated, deleted, restricted, or moved to another organization.

Why is GDPR Important?
GDPR adds some new requirements regarding how companies should protect individuals Personal Data that they collect and process. It also raises the stakes for compliance by increasing enforcement and imposing greater fines for breach. Beyond these facts it's simply the right thing to do. At Selekt we strongly believe that your data privacy is very important and we already have solid security and privacy practices in place that go beyond the requirements of this new regulation.

Individual Data Subject’s Rights - Data Access, Portability and Deletion. We are committed to helping our customers meet the data subject rights requirements of GDPR. Selekt processes or stores all Personal Data in fully vetted, DPA compliant vendors. We do store all conversation and Personal Data for up to 6 years unless your account is deleted. In which case, we dispose of all data in accordance with our Terms of Service and Privacy Policy, but we will not hold it longer than 60 days. We are aware that if you are working with EU customers, you need to be able to provide them with the ability to access, update, retrieve and remove Personal Data. We got you! We've been set up as self service from the start and have always given you access to your data.

11. Accountability.

(a) Questions, Problems and Complaints. If you have a question about this policy statement, or a complaint about Selekt compliance with this privacy policy, you may contact Selekt by e-mail members@theselekt.com.

(b) Terms of Services. If customer chooses to enter into an event order or to subscribe to Selekt`s services, customer`s action is hereby deemed acceptance of Selekt practices described in this policy statement. Any dispute over privacy between customer and Selekt is subject to the provisions of this notice and to Selekt`s Terms of Use Agreement which is hereby incorporated herein and which can be read on Selekt`s Website or app at the customer`s convenience