Privacy Notice

1. Who is responsible for your information

SUNSARA GROUP (PTY) LTD, a private company registered in South Africa under registration number 2026/579917/07, is responsible for the processing described in this Privacy Notice.

Registered address: 89 George Street, Suite 2168, Cape Town, Western Cape, 7140, South Africa.

Website: https://newlegenda.art

Privacy enquiries: sunsarasuvorova@gmail.com

This Notice covers the NEW LEGENDA international services operated by SUNSARA GROUP, including participant accounts, invited expert accounts, judge applications, judging, audience voting and related purchases.

The Russian commercial segment has a separate operator and privacy notice. Changing the interface language does not by itself change the responsible organisation or authorise the transfer of an existing account between operators.

This Notice explains our handling of personal information. It does not constitute your consent to advertising, public image use or every activity described below.

2. Information we collect

The information required depends on the feature you use.

Do not send passwords, complete card details or card security codes in messages, submissions or support requests.

3. Where information comes from

We receive information directly from you when you register, complete a form, submit a work, make a purchase, vote or contact us.

We also receive relevant information from payment providers, authorised managers, judges, invited experts and service providers involved in the activity you request. For example, a payment provider confirms a payment, a judge submits an assessment and a manager’s code identifies the source of a registration. If an authorised manager contacts a prospective participant on our behalf, we may also receive limited professional contact or profile information and the person’s response or communication preferences for referral administration, subject to applicable law.

A submitted photograph or video may contain information about a client or model. In that case, we receive that information from the person submitting the material.

Anyone submitting another person’s information must have the necessary authority, provide that person with this Notice and obtain the permissions required for the intended use. A participant’s agreement does not automatically constitute consent on behalf of a model.

4. Why we use information

We use personal information for the following purposes and on the applicable lawful grounds:

Information necessary to create an account, verify a vote, assess a submission or complete a purchase is identified in the relevant form. If you do not provide it, we may be unable to complete that particular action.

Declining optional marketing does not prevent registration, purchase, judging or voting.

5. Who can see information within the Platform

Access is limited according to each person’s role and assigned task.

Participants can access their own submissions, payment status, results and recommendations released to them.

Invited experts can access works assigned for recommendations. Recommendations are reviewed before publication. The author remains identifiable to authorised administrators but is hidden from the participant and judge in the recommendation panel. This is not complete anonymity: we retain authorship records for moderation and accountability.

A participant sees a published recommendation after the assessment of their work is completed. A judge sees it after submitting their own assessment of that work.

Judges receive the information needed to assess assigned works. Administrative, referral and payment records are not automatically included in a work’s assessment view.

Managers act under a separate services arrangement and can access only the assigned registrations, applications, attributed purchases, programme progress, service reports and commission information needed for their work. Referral tracking does not give a manager unrestricted access to another user’s account or payment details.

Judge candidates can see their referral progress and related fee calculation. A referral relationship does not provide unrestricted access to another person’s contact or payment information.

Public visitors can see information released through public galleries, results or judge profiles in accordance with the relevant publication permissions and event rules. Voters’ email addresses are not displayed publicly.

6. Works, photographs and public profiles

Private assessment, public gallery display and advertising are different uses.

Submitting a work for assessment does not by itself authorise every form of public or promotional use. Where a separate permission is required, the relevant form identifies what will be published and where.

For an active judge profile, the information may include the judge’s first and last name, photograph, city, approved nominations, social-media profile link and championship role. The Judge Programme Terms disclose the public profile card and one co-authored promotional social-media post as programme features. The profile card remains on the Platform for one year after the relevant stage. The retention period for the social-media post must be disclosed when the candidate accepts the specific image and profile licence. Qualification works are used for internal review only; they are not published without separate permission.

Information published openly can be viewed, copied or shared by others. If you withdraw consent for an optional use, we will stop that use and address removal from channels we control, subject to applicable law. We cannot guarantee removal of independent third-party copies, but this does not remove our own legal obligations.

Please avoid submitting medical records, identity documents or unrelated sensitive information unless we specifically request it through an appropriate process. If a submission contains information requiring additional legal protection, we may restrict access while establishing whether it can lawfully be processed.

7. Service providers and other recipients

Where necessary for the stated purposes, information may be disclosed to:

hosting, storage and technical support providers;

email delivery, authentication and security providers;

payment providers and financial institutions;

authorised judges, experts, managers and administrative personnel;

delivery providers sending physical awards;

professional advisers, auditors, regulators or authorities where disclosure is required or lawfully justified.

Providers processing information on our instructions must be subject to appropriate confidentiality, security and processing obligations.

Payment providers may also process information under their own privacy notices and legal obligations. A link or notice identifying the relevant payment provider must be available in the payment flow.

Sponsors do not receive access to participant contact lists merely because they sponsor a championship. Any separate disclosure must have an identified purpose and lawful basis.

8. International processing

The international service is operated by a South African company. Access by authorised personnel, service providers or assigned reviewers in other countries may involve an international transfer.

Before introducing a transfer requiring additional safeguards, we will identify the relevant destination, purpose and protection arrangements in the information provided for that activity or in an updated notice.

Transfers subject to South Africa’s Protection of Personal Information Act must meet its applicable transfer conditions. Where the EU or UK data protection rules also apply, the relevant transfer requirements must be met separately.

Accepting general website terms is not blanket consent to unrestricted international transfers. You may contact us for information about the recipients, destinations and safeguards relevant to your data, including a copy of applicable safeguards where the law provides that right.

9. Automated processing

The Platform uses automated rules to validate required fields, verify email, detect repeated votes, confirm payment events, attribute referrals and calculate programme progress or remaining fees.

Application deadlines and programme rules may also affect a candidate’s status or access automatically. An automated check that files are present does not itself establish their professional quality.

You may contact us to question an automated outcome, explain relevant circumstances and request human review. We will provide the information and review rights required by applicable law for decisions that produce legal or similarly significant effects.

10. How long we keep information

Retention depends on the purpose and applicable requirements:

Account information: while needed to provide the account, followed by any limited retention necessary to handle closure, disputes or legal obligations.

Submissions, assessments and recommendations: while needed to run the championship, deliver results, handle published review procedures and resolve related claims.

Public materials: judge cards for one year after the relevant stage; co-authored judge posts for the period disclosed in the specific image and profile licence; other public materials for the period and purpose covered by the applicable publication permission or other lawful basis.

Payment and accounting records: for the period required by applicable accounting, tax and transaction laws.

Voting and security records: while needed to verify results, investigate misuse and resolve relevant complaints.

Marketing information: until consent is withdrawn or the relevant purpose ends; a limited suppression record may be retained to honour an opt-out.

Acceptance and consent records: while needed to demonstrate the applicable permissions or defend related claims.

When information is no longer needed and no lawful retention ground remains, it must be deleted or irreversibly de-identified. Restricted backup copies must follow the applicable deletion cycle and must not be reused for unrelated purposes.

11. Marketing and cookies

Verification codes, payment confirmations, application decisions, results and certificate notifications are service messages.

Voting, using an invitation code or receiving a service message does not automatically subscribe you to promotional communications. We and authorised managers may send promotional electronic communications only where permitted by the law applicable to the recipient and in line with that person’s preferences. Each marketing communication must identify the sender and provide a simple way to ask that further messages stop. Managers must not treat a registration code, public profile or response to a service message as marketing consent. You can withdraw marketing consent or object to direct marketing through the unsubscribe mechanism or by contacting us.

Essential website technologies support functions such as authentication, security and payment sessions. Optional analytics or advertising technologies are subject to the choices and information provided in Cookie Settings, where applicable. Refusing optional technologies must not be treated as acceptance of them.

12. Security

We are responsible for implementing reasonable organisational and technical safeguards appropriate to the information processed. These include controlled access, confidentiality requirements and procedures for handling security incidents.

No online service can guarantee absolute security. Where an incident requires notification, we will notify the relevant authority and affected people as required by applicable law.

13. Your rights

Depending on the law that applies, you may request:

confirmation of whether we process your information and access to it;

correction of inaccurate information;

deletion of information where continued processing is not justified;

restriction of processing or consideration of an objection;

withdrawal of consent for processing based on consent;

data portability where that right applies;

review of a qualifying automated decision.

To make a request, email sunsarasuvorova@gmail.com with the subject Privacy Request. Describe the request and provide enough information for us to locate the relevant records. We may request proportionate verification before disclosing or changing information.

Withdrawal of consent does not invalidate processing already carried out lawfully. Some records may still need to be retained on another lawful basis. We will explain any applicable limitation and respond within the period required by law.

You may complain directly to the Information Regulator of South Africa through inforegulator.org.za. Where EU or UK data protection law applies, you may also complain to the competent supervisory authority.

14. Children

Professional accounts and paid championship services are intended for adults. If a particular event permits a minor’s participation or submission of a minor’s image, the required information and permission from a parent, guardian or other competent person must be obtained before processing.

If you believe a child’s information has been submitted without appropriate authority, contact us so that we can investigate and take the necessary action.

15. Updates and contact

We may update this Notice to reflect changes in the Platform or applicable requirements. The current version and update date will be displayed on this page. Where a new purpose requires fresh permission, publishing an updated notice alone will not provide that permission.

Privacy contact: sunsarasuvorova@gmail.com

SUNSARA GROUP (PTY) LTD

89 George Street, Suite 2168, Cape Town, Western Cape, 7140, South Africa.