Who is responsible
Zorvale is currently a pre-incorporation project being developed in the United Arab Emirates. Until a Zorvale company is incorporated, the controller for processing carried out directly by Zorvale is Tillmann Kloss, operating Zorvale.
Privacy enquiries and data-rights requests can be sent to privacy@getzorvale.com.
When a UAE Zorvale company becomes the relevant controller, this notice will be updated and affected users will be informed where required.
What this notice covers
This notice covers the Zorvale website, founding-access requests and authorised pre-launch product use.
Information we process
Zorvale may process names, email addresses, account and workspace information, agency or roster information, reference images, monitoring instructions, discoveries, source information, review decisions, evidence records, communications and support requests.
We also process limited technical and security information such as authentication records, connection information, timestamps, device or browser information where available, and security or abuse-prevention signals.
The public founding-access form uses a one-way server-generated fingerprint derived from connection information for abuse prevention.
Where information comes from
Information may come directly from you, from an agency or other person authorised to act for you, from publicly accessible websites and online pages, from authorised search or discovery providers, or from technical records generated by Zorvale while verifying and reviewing a discovery.
Why we process information
We process information to review founding-access requests, provide authorised accounts and workspaces, perform authorised image discovery and verification, present potential matches for review, maintain evidence and decision records, secure the service, prevent abuse, support users and comply with legal obligations.
Where GDPR or UK GDPR applies, the legal basis will depend on the activity and may include steps requested before entering a contract, performance of a contract, legitimate interests in operating and securing Zorvale, compliance with legal obligations, or consent where required.
Where UAE data-protection law applies, Zorvale processes personal information on the basis of consent or another basis permitted by applicable UAE law, depending on the relevant activity.
Reference images and monitoring
Reference images are processed only for monitoring and verification that has been authorised for the relevant talent or workspace.
Zorvale may compare reference images with image assets or online appearances and create technical records describing potential matches.
No monitoring system sees the entire internet, and Zorvale does not represent that monitoring coverage is complete.
Agencies and rosters
Where an agency determines why and how talent information is processed and Zorvale processes it only on the agency's instructions, the agency may act as controller and Zorvale may act as processor for that activity.
Agency or roster-wide processing may therefore require separate data-processing terms before activation.
Zorvale may remain a separate controller for activities such as account administration, security, fraud prevention and compliance.
Technical matching
Zorvale uses technical systems to identify and verify potential image matches. Those systems produce signals and records for review.
A technical match does not automatically determine whether an image use is authorised, infringing or unlawful.
Zorvale does not use a technical image match as a solely automated legal decision producing legal or similarly significant effects for the person concerned.
International transfers
Zorvale is being developed in the United Arab Emirates and may use providers or infrastructure located in other countries.
Where applicable data-protection law restricts an international transfer, Zorvale will use an available lawful transfer mechanism and appropriate contractual, organisational or technical safeguards as required.
Retention
Information is retained only for as long as reasonably necessary for the purpose for which it was collected, provision of authorised services, security, audit requirements, dispute-resolution and applicable legal obligations.
The period varies according to the category of information, the status of the account or workspace, whether a discovery or case remains active, and whether records must be preserved for security or legal reasons.
Your rights
Depending on the law that applies to you, you may have rights to request access, correction, deletion, restriction, objection or portability of personal information and to withdraw consent where processing is based on consent.
You may also have the right to complain to the competent data-protection or supervisory authority in your jurisdiction.
Requests can be sent to privacy@getzorvale.com.
Security
Zorvale uses technical and organisational measures designed to protect personal information, including access controls, separation between public and privileged operations, and measures intended to reduce unauthorised access or disclosure.
No internet service can guarantee absolute security.
Security concerns can be reported to security@getzorvale.com.
Children
The current Zorvale pre-launch service is not intended for individual users under 18 and is not currently designed for monitoring talent under 18.
A separate guardian, agency-authority and privacy process will be required before Zorvale supports that use case.
EU and UK representatives
Zorvale is not currently established in the European Union or United Kingdom.
If Zorvale becomes subject to a legal requirement to appoint an EU or UK representative for relevant processing, the required representative will be appointed and its contact details will be published here.
Contact
Privacy and data-rights enquiries: privacy@getzorvale.com
General enquiries: hello@getzorvale.com
Changes to this notice
Zorvale may update this notice as the service, legal structure, providers or processing activities change.
The date at the top of this page shows when the notice was last revised. Material changes will be communicated where applicable law requires additional notice.
Zorvale
Every image, accounted for.
Read how Zorvale approaches the other side of using the service.