Information provided pursuant to Article 13 of Regulation (EU) 2016/679 — General Data Protection Regulation (“GDPR”).
1. Data Controller
The Data Controller is:
Kiri Nawa Kai APS
Tax Code: 97750310159
Registered office: Via Bruno Cesana 10, 20132 Milan, Italy
Email: kirinawakai@gmail.com
Certified email address: kirinawakai@pec.poste.it
References in this notice to “Rope Tales” concern projects and activities managed or organised by Kiri Nawa Kai APS under the Rope Tales name.
2. Personal data collected
Through this form, we may collect the following categories of personal data:
- name and contact details;
- year of birth;
- city and country of residence;
- sex assigned at birth;
- information concerning gender identity, gender expression, sexual orientation or pronouns that you voluntarily choose to provide;
- links to social media profiles, websites or portfolios;
- photographs showing your face and body;
- information concerning your professional, artistic, modelling, bondage or performance experience;
- information concerning previous injuries, medical conditions, psychological conditions, surgeries or physical limitations;
- information concerning medication;
- preferences regarding nudity, explicit content, sexual content and recognisability;
- travel, accommodation and compensation requirements;
- preferences regarding possible projects and publishing licences;
- any additional information voluntarily included in the form.
Please do not provide information that is not reasonably necessary for the evaluation of your application.
3. Special categories of personal data
Some of the information requested or voluntarily provided may concern health, sex life or sexual orientation and may therefore constitute special categories of personal data under Article 9 GDPR.
Such information will be processed only with your explicit consent and exclusively for the purposes described in this notice.
Photographs and videos submitted through the form will not be used for biometric identification or facial-recognition purposes.
4. Purposes of processing
Your personal data will be processed for the following purposes:
A. Management and evaluation of your application
To receive, review and assess your application and determine whether your profile may be suitable for photographic, video, artistic, educational or promotional projects.
B. Communication concerning possible projects
To contact you by email or telephone concerning your application, possible auditions, meetings, photographic sessions, filming sessions or proposed collaborations.
C. Health and safety assessment
To evaluate, within the limits of our competence, whether any information concerning injuries, physical conditions, psychological conditions or medication should be taken into consideration when proposing or organising bondage-related activities.
The information collected through this form does not constitute medical advice or a medical fitness assessment. Additional information or medical clearance may be requested before a specific activity where appropriate.
D. Organisation and budgeting
To evaluate travel, accommodation, compensation and licensing requirements connected with a possible collaboration.
E. Protection of legal rights
Where necessary, data may be retained or used to establish, exercise or defend legal claims.
5. Legal bases
The processing of ordinary personal data is based on:
- your request to be considered for possible collaborations and the adoption of measures at your request prior to entering into a contract, pursuant to Article 6(1)(b) GDPR;
- your consent, pursuant to Article 6(1)(a) GDPR, for information that is optional or not strictly necessary for the initial evaluation;
- the legitimate interest of the Data Controller in managing applications, ensuring the security of its activities and protecting its legal rights, pursuant to Article 6(1)(f) GDPR;
- compliance with legal obligations, where applicable, pursuant to Article 6(1)(c) GDPR.
The processing of personal data concerning health, sex life or sexual orientation is based on your explicit consent pursuant to Article 9(2)(a) GDPR.
You may withdraw your consent at any time. Withdrawal will not affect the lawfulness of processing carried out before withdrawal.
6. Mandatory and optional information
Fields marked with an asterisk are required in order to submit and assess the application.
Failure to provide required identification or contact information may make it impossible to evaluate your application.
The provision of special-category data is voluntary. However, where information concerning health, physical limitations or safety is relevant to a proposed activity, failure to provide sufficient information may make it impossible to offer or proceed with that activity safely.
You are not required to disclose your sexual orientation, gender identity or psychological condition unless you consider that information relevant to the activities for which you are applying.
7. Methods of processing and security
Data will be processed electronically and, where necessary, manually by authorised persons acting under the authority of the Data Controller.
Appropriate technical and organisational measures will be adopted to protect the information against unauthorised access, disclosure, alteration, accidental loss or unlawful use.
Because the form may contain intimate photographs and information concerning health or sex life, access will be restricted to persons who need the information for model selection, production organisation, safety assessment or legal and administrative management.
8. Persons who may receive the data
Personal data may be accessed or received by:
- authorised members, employees or collaborators of Kiri Nawa Kai APS;
- persons responsible for selecting models or organising the relevant project;
- photographers, video producers, riggers or other professionals involved in evaluating a specific proposed collaboration, only where necessary;
- website, hosting, cloud-storage, email, form-management and IT service providers acting as data processors;
- accountants, legal advisers, insurers or other professional advisers where necessary;
- public authorities where disclosure is required by law.
Special-category data will not be shared with photographers, riggers, organisers or production staff unless the information is necessary for the evaluation, safety or organisation of a specific activity.
Personal data will not be sold.
9. International transfers
Some technical service providers or persons involved in international projects may be located outside the European Economic Area.
Where personal data are transferred outside the European Economic Area, the Data Controller will ensure that the transfer is based on an adequacy decision, appropriate safeguards such as the European Commission’s Standard Contractual Clauses, or another lawful transfer mechanism provided by the GDPR.
Information concerning health, sex life or sexual orientation will not be transferred to a third country merely for the purpose of presenting a candidate to foreign organisers without an additional assessment of necessity and applicable safeguards.
10. Retention period
Applications will be retained for up to five years from the date of submission.
This retention period reflects the nature of our selection process, as the number of applications may significantly exceed the number of photographic and video projects that we are able to produce each year. Applicants may therefore be contacted regarding a possible collaboration several years after submitting the form.
During this period, the application will remain part of our active model selection archive. You may withdraw your application and request the deletion of your personal data at any time.
At the end of the five-year period, the application and the related uploaded photographs will be deleted, unless you expressly confirm that you wish to keep your application active for a further period.
Where a collaboration takes place, data required for contractual, accounting, insurance or legal purposes may be retained for the longer periods required by applicable law.
Information that is no longer necessary, particularly detailed health information and uploaded application photographs, will be deleted or anonymised whenever it is no longer required for the purposes for which it was collected.
11. No authorisation to publish your image
Submitting this application does not authorise Kiri Nawa Kai APS, Rope Tales or any third party to publish, distribute, sell or otherwise use your image.
Before producing or using photographs or videos, the parties will agree on a separate written model release or publishing licence specifying, among other matters:
- the type and degree of nudity or explicit content;
- the permitted uses;
- the publication channels;
- any commercial use;
- the duration and territorial scope of the licence;
- compensation and expense reimbursement;
- any restrictions or embargo periods.
12. Automated decision-making
Applications are not accepted or rejected exclusively through automated decision-making or profiling producing legal or similarly significant effects.
13. Your rights
Under Articles 15–22 GDPR, you may request:
- confirmation as to whether your data are being processed;
- access to your personal data;
- correction of inaccurate or incomplete information;
- deletion of your data;
- restriction of processing;
- data portability, where applicable;
- objection to processing based on legitimate interests;
- withdrawal of consent at any time.
Requests may be sent to:
kirinawakai@gmail.com
Before responding, we may request information reasonably necessary to verify your identity.
You also have the right to lodge a complaint with the competent supervisory authority. In Italy, the supervisory authority is the Garante per la protezione dei dati personali.
14. Updates
This privacy notice may be updated where necessary. The version available when the application is submitted will apply to the information collected through that application.
Last updated: 13/07/2026