El Momentum LTD provides a platform through which content creators and enthusiasts can publish, store, share and use graphics, photos, footage, sfx or other materials. Momentum offers profile creation and communication services on the platform, the ability to upload content and give it away for a fee.
In order to provide you with our Services, we need to collect personal information for you. In each case, we are committed to ensuring that the information we collect and use is appropriate for that purpose and does not constitute an invasion of your privacy.
The personal data we need to process for you is as follows:
| Personal data type: | Source |
| Name | Data subject |
| Address | Data subject |
| Email address | Data subject |
| Bank account number (IBAN) | Data subject |
| Photo of the data subject | Data subject |
| Date of birth | Data subject |
| Telephone number | Data subject |
| Social media links | Data subject |
| Personal websites links | Data subject |
| Employment and places of study | Data subject |
| Model and property owner identification | Third parties |
| IP Address | Generated upon visiting the website |
| Website traffic information | Generated upon visiting the website |
The personal data we collect will be used for the following purposes:
- Providing an Author profile the Controller's website
- Creating Author’s resumes through the website features
- Billing and Payment
- Invoicing and accounting, tax compliance
- Negotiating and executing contracts for our services
- Obtaining necessary legal consent for offering copyrighted content
- Reaching potential customers, direct marketing
- Managing communication with consumers
- Organizational objectives related to customer service and enchasing website performance
Our legal basis for processing for the personal data:
- Processing is necessary for the performance of a contract to which the data subject is already a party or in order to take steps at the request of the data subject prior to entering into a contract
- Executing a legal obligation
- In some cases for the purposes of the legitimate interests pursued by us as a Controller
Any legitimate interests pursued by us, or third parties we use, are as follows:
- To use your e-mail address to send you our latest offers and newsletter
- To improve the content and features of our website according to the interests of our users
- To improve our customer service and ensure customer satisfaction.
- To avoid legal disputes or defend our rights in the occurrence of such
By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified.
Consent is required for Momentum LLC to process both types of personal data, but it must be explicitly given. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.
You may withdraw consent at any time by deleting the information (in case of it is part of your personal profile) or you can ask us to do so by sending us an e-mail.
EL Momentum LTD will pass on your personal data to third parties. The following third parties will receive your personal data for the following purpose(s) as part of the processing activities
Third party name | Personal data category | Purpose |
Public | Data in Author’s public profile | Providing information to the public on author’s background and bio |
Google Analytics | Website traffic information | Analysing customer’s behaviour |
Website traffic information | Reaching potential customers, direct marketing | |
Stripe | Bank account number (IBAN) | Billing and Payment |
Website traffic information | Analysing customer’s behaviour | |
Hotjar | Website traffic information | Analysing customer’s behaviour |
GoogleAds | Website traffic information | Analysing customer’s behaviour |
Mailchimp | Email address | Reaching potential customers, direct marketing |
Occasionally, EL Momentum LTD will have to transfer your personal data to third countries. In such cases appropriate data protection safeguards will be taken.
Third parties (outside EEA) / international organizations | Appropriate data protection safeguards |
Google Inc. (USA) | EU’s Standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 |
Facebook Inc. (USA) | EU’s Standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 |
Mailchimp Inc. (USA) | EU’s Standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 |
LinkedIn Inc. (USA) | EU’s Standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 |
Stripe Inc. (USA) | EU’s Standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 |
EL Momentum LTD will retain your personal data as follows
Personal data | Retention period |
Data on Author’s public profile | Until it’s been deleted |
Data necessary for execution of a contract | Until the end of the corresponding contract or negotiations, whichever event comes first |
Data from release forms | Until the corresponding content is held on the website and 5 years later |
Website traffic data (Google Ads Google Analytics, Facebook Pixel, LinkedIn tag) | Until cookies and other tracking technologies are deleted from data subject’s browser |
Payment and billing data | Until the execution of the financial operation and 10 years later |
Direct marketing data | Until objection by the subject |
Right of access
You have the right to request a copy of the information that we hold about you.
Right of rectification
You have a right to correct data that we hold about you that is inaccurate or incomplete.
Right to be forgotten
In certain circumstances you can ask for the data we hold about you to be erased from our records.
Right to restriction of processing
Where certain conditions apply to have a right to restrict the processing.
Right of portability
You have the right to have the data we hold about you transferred to another organisation.
Right to object
You have the right to object to certain types of processing such as direct marketing.
Right to object to automated processing, including profiling
You also have the right to be subject to the legal effects of automated processing or profiling.
Right to judicial review
In the event that EL Momentum LTD refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.
All of the above requests will be forwarded on should there be a third party involved (as stated in 3.4 above) in the processing of your personal data.
In the event that you wish to make a complaint about how your personal data is being processed by Momentum LLC (or third parties as described in 3.4 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Momentum LLC ’s data protection representatives
The details for each of these contacts are:
 | Supervisory authority contact details | GDPR Owner contact details |
Contact name: | Commission for personal data protection | Will be provided privately after email request. |
Address info: | 1592 Sofia, 2 Professor Tsvetan Lazarov Boulevard  | Will be provided privately after email request. |
E-mail address: | ||
Phone contact: | +359291-53-518Â | Will be provided privately after email request. |
How will El Momentum LTD Â use the personal data it collects about me?
EL Momentum LTD  will process (collect, store and use) the information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavor to keep your information accurate and up to date, and not keep it for longer than is necessary. EL Momentum LTD is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices. Personal data may be held in addition to these periods depending on individual business needs.
Under what circumstances will EL Momentum LTDÂ contact me?
Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous measures and procedures to minimize the risk of unauthorized access or disclosure.
Can I find out the personal data that the organisation holds about me?
EL Momentum LTD at your request, can confirm what information we hold about you and how it is processed. If EL Momentum LTD Â does hold personal data about you, you can request the following information:
- Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU.
- Contact details of the data protection officer, where applicable.
- The purpose of the processing as well as the legal basis for processing.
- If the processing is based on the legitimate interests of EL Momentum LTD or a third party, information about those interests.
- The categories of personal data collected, stored and processed.
- Recipient(s) or categories of recipients that the data is/will be disclosed to.
- If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.
- How long the data will be stored.
- Details of your rights to correct, erase, restrict or object to such processing.
- Information about your right to withdraw consent at any time.
- How to lodge a complaint with the supervisory authority.
- Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
- The source of personal data if it wasn’t collected directly from you.
- Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
