Privacy Policy

1. How the Platform Works, in One Paragraph

Individuals (“Talent”) create an account, upload photographs of themselves, verify their identity with Stripe and choose which campaign categories they are open to, at which point they are listed. Brands, agencies and production companies (“Licensees”) create campaigns. When a Licensee adds a Talent to a campaign that falls within the Talent’s settings and completes checkout, the Platform concludes a campaign licence on the Talent’s behalf under the standing authority the Talent gave in the Talent Agreement, compiles the Talent’s unmodified photographs into a file or set of files, together with the Talent’s listing reference, full name and a footer stating the licence details described in Section 7.1 (the “Character Sheet”) and delivers it to the Licensee, who generates the advertising imagery. The Talent is notified by email and the licence is recorded in their account. We do not generate any imagery ourselves, we create no models or embeddings from anyone’s photographs, and our involvement with the images ends at delivery, apart from administering and enforcing the licence. Everything from account creation to delivery is done in performance of the Talent Agreement, which is the contract the Talent accepts at sign-up.

2. Data We Collect

2.1 We collect the following categories of personal data.

2.2 What we do not collect. We do not ask about or check criminal convictions, charges or offences, and no field in any profile or account is designed to hold them. Talent give a contractual warranty in the Talent Agreement that they have no unspent conviction for (i) an offence of violence against the person; (ii) a sexual offence; (iii) an offence of dishonesty, including fraud; (iv) an offence that was racially or religiously aggravated or otherwise motivated by hostility towards a protected characteristic; or (v) a terrorism offence, but we do not ask them to describe any conviction and we do not run criminal record checks (see Section 5). We never ask for information about your ethnicity, health, religion, politics, sexual orientation or any other special category of personal data, and no profile field is designed to hold it. Your photographs may show things from which someone could guess at some of these; we do not label, sort or filter listings, or make any decision about you, by reference to them. Your bio is written by you, what you put in it is up to you, and it is public while your listing is on. If you choose to include information of that kind about yourself, you have made it public yourself, and that is the basis on which we hold and display it (Article 9(2)(e) UK GDPR), together with the contract basis in Section 4. You can edit or delete your bio at any time. If a bio contains that kind of information about someone else, we will remove it. We do not receive the images or biometric data used in identity verification (see Section 3.3).

2.3 What is public while your listing is on. While a Talent’s listing is switched on, anyone visiting the Platform’s browse pages can see that Talent’s public preview without logging in. The public preview shows one photograph, reduced in size and watermarked (any other photograph appears only as a blurred image), and the Talent’s initials, age range, gender, nationality, country of residence and bio. Visitors can search listings by country of residence, gender, age range and campaign category, so the campaign categories a Talent is open to, including any sensitive category they have switched on, can be seen by anyone. While an exclusive licence is running, the Talent does not appear in searches for the categories it covers. A Talent’s full name, exact age, date of birth, licence details and full-size photographs are never shown publicly; full-size photographs reach a Licensee only as a Character Sheet under a campaign licence (Section 7). We instruct search engines not to index the browse pages or preview images, but that is a request, not a lock. People who view the browse pages without an account have not accepted the Licence Agreement; our Terms of Service prohibit everyone from copying or scraping what is shown, and we apply the technical measures in Section 14, but we cannot prevent a visitor from viewing or saving a preview. Someone who only visits may not be bound by those Terms as a contract, so we also rely on copyright where the Talent owns it and on data protection law. If you believe a preview has been copied or misused, tell us at support@likeness-app.com or through the complaint form on the Platform and we will act on it. Switching your listing off removes your public preview from the browse pages immediately.

3. Our Position on Photographs and Biometric Data

3.1 Photographs are personal data, and we treat them with strict safeguards. The photographs Talent upload, and the Character Sheet, are personal data and are protected with the technical and organisational measures described in Section 14, including encryption at rest and in transit and restricted access.

3.2 We do not process photographs to identify anyone. We do not create biometric templates, embeddings, measurements or models from photographs. We do not use facial recognition, facial matching or any comparable technology. No processing on the Platform is carried out for the purpose of uniquely identifying a natural person, and every licence we administer contractually prohibits Licensees from any such use and from training or fine-tuning any model on the photographs. On that basis, our own processing of photographs is not processing of special category biometric data within Article 9 UK GDPR. Visitors who view the public preview without an account (Section 2.3) are not parties to a licence; the Terms of Service prohibit them from the same uses, but a prohibition is not a technical barrier, which is why previews are reduced, watermarked or blurred.

3.3 The one exception: identity verification, which is ringfenced and carried out by Stripe. Before a Talent can be listed, their identity is verified by Stripe through Stripe Identity. Talent are redirected to Stripe, capture the required images themselves, and Stripe carries out the verification checks, which involve biometric processing performed by Stripe on the basis of the explicit consent Talent give to Stripe (Article 9(2)(a) UK GDPR). We never receive, hold or process the verification images or the biometric data involved. We receive only the outcome of the check and minimal associated metadata. Stripe’s processing is described in Stripe’s privacy notice, presented before verification begins.

4. Lawful Bases

4.1 The table below sets out the lawful basis for each kind of processing we carry out.

4.2 The marketplace runs on contract. When a Talent accepts the Talent Agreement, they enter into a contract with us under which we host their photographs, list their profile, including the public preview described in Section 2.3, when they choose to switch it on, conclude campaign licences on their behalf within the settings they have chosen, deliver their Character Sheet under each licence, and account to them for their share of the fee. All of that processing is necessary to perform that contract, and Article 6(1)(b) is our lawful basis for it. The same basis covers our processing of Licensee personal data to operate their accounts and transactions.

4.3 Why we do not ask for consent to list you. Being listed is the service you sign up for, not an optional extra. If we asked for a separate consent to list you, that consent could not be freely given, because refusing it would defeat the purpose of the account. Your control sits in the contract instead: your listing switch decides whether you can be licensed at all, your category settings decide which campaigns you can be licensed for, and both are checked at every checkout and take effect immediately. Relying on contract is more honest about what is happening and gives you clearer rights: you can switch your listing off, or leave the Platform entirely, at any time and for free, and the Talent Agreement spells out exactly what happens to any campaign licence in each of the two states described in Section 10.

4.4 Where we do rely on consent, it is real consent. We rely on consent for three things only: the identity check (which you consent to with Stripe, on Stripe’s own screen), marketing messages from us, and advertising with our advertising partners (Section 9). Each is requested separately, is never pre-ticked, is not a condition of using the Platform, and can be withdrawn at any time without affecting your account. We do not rely on legitimate interests for advertising. We do not treat acceptance of the Talent Agreement, the Licence Agreement or the Terms of Service as consent to anything.

4.5 Other bases. We rely on legitimate interests (Article 6(1)(f)) for the purposes listed in the legitimate interests row of Section 4.1, having concluded in a written assessment, which we review at least once a year, that these interests are not overridden by your rights; and on legal obligation (Article 6(1)(c)) for tax, accounting and regulatory compliance.

4.6 What consent is not used for.A Talent’s campaign category preferences (for example staying closed to alcohol or gambling campaigns) and their listing on/off setting are contractual settings, not data protection consents. Changing them is a contract variation and does not affect the lawfulness of processing.

5. Criminal Offence Data

5.1 What we do not collect. The Talent Agreement asks each Talent to warrant that they have no unspent conviction in the five categories listed in Section 2.2. That is a contractual promise, not a data collection exercise. We do not ask anyone to disclose a conviction, we do not run criminal record checks, we do not store any answer to a question about convictions, and no field in any profile or account is designed to hold information about convictions. The only record we keep is that the Talent accepted the Talent Agreement, which version, and when, except as Section 5.3 describes. If we record a Conduct Event, a short note of the reason is kept for three months and then deleted (Section 5.3).

5.2 If you choose to tell us something. A Talent may contact support to ask whether they can give the warranty, or to tell us that it is no longer accurate. Anything you volunteer in that way is personal data relating to criminal convictions and offences under Article 10 UK GDPR. We process it on the basis of Article 6(1)(b) (it is necessary to decide whether the Talent Agreement can be performed) and the condition in paragraph 29 of Schedule 1 to the Data Protection Act 2018 (your consent, expressed by your choosing to tell us). We handle it as follows: it is dealt with in the support system, never copied into your profile or account record; it is seen only by the people who need to answer you; a person, not an automated system, makes any decision that follows from it; and it is deleted within three months of the query being resolved, or within six months of our receiving it if the query is never resolved, unless we need to keep it to establish, exercise or defend a legal claim. You do not have to tell us anything beyond the fact that the warranty is or is not accurate. If what you tell us means a Conduct Event has occurred, Section 5.3 also applies.

5.3 Conduct Events.If we learn, from you or from public reports, that a Talent’s conviction warranty is no longer true or that they have been charged with an offence in one of the five categories, a person decides whether a Conduct Event has occurred under the Talent Agreement. If it has, we tell each Licensee holding a live campaign licence for that Talent only that a Conduct Event has occurred, without saying what it was or whether it concerns an offence, so that the Licensee can decide whether to end the licence. We process this information under Article 6(1)(b) and the condition in paragraph 33 of Schedule 1 to the Data Protection Act 2018 (establishing, exercising or defending legal rights). When we record a Conduct Event we make a short note of the reason, which we email to the Talent and never send to a Licensee, and we delete that note three months after the Conduct Event is recorded. After that we keep only that a Conduct Event occurred, who recorded it, when, and which of the Talent’s licences were live at the time, with no details of the event, with the licensing records (Section 13). We delete everything else within three months. The Licensee must keep our notice confidential to those deciding whether to end the licence and delete it within three months.

6. Marketing Communications

6.1 We will send you marketing messages by email only if you have opted in. The opt-in is a separate, unticked box and is not a condition of holding an account or being listed. You can withdraw at any time using the unsubscribe link in any message, and we will stop within a reasonable time. Service messages that are necessary to operate your account, such as notifications that your likeness has been licensed, payout confirmations and notices of changes to our agreements, are not marketing and do not depend on the opt-in.

7. The Character Sheet and Who Receives It

7.1The Character Sheet is a file, or set of files, containing only the Talent’s unmodified uploaded photographs, their listing reference and full name, and a footer stating the licence details: the licence reference, the brand or end client and campaign name, the campaign category, the licence tier and its scope of use, the scheduled end date, a statement that the photographs are used with the Talent’s permission for that campaign only, and our name or mark. The photographs may be presented together on one canvas with those details beneath them; their image content is not altered, and we remove embedded file metadata before delivery. Every licence detail is information the Licensee already holds from its own campaign and licence records; it is printed on the Character Sheet so that every holder in the delivery chain can see which licence governs the file and when it must be deleted. A Licensee sees a Talent’s full name only once it has licensed that Talent: it appears in the Licensee’s record of the licence on the Platform, and it is printed on the Character Sheet and used in its file name, so every holder in the delivery chain sees it. The Character Sheet is delivered to a Licensee only under a campaign licence concluded within the Talent’s settings on the Talent’s standing authority, and delivery is gated on payment for a campaign order that passes those checks.

7.2 From delivery, the Licensee is an independent controller of the personal data in the Character Sheet. The Licensee is contractually bound to use it solely for the licensed campaign, by reference-conditioned generation only (supplying the Character Sheet as an input to each generation, with no training, fine-tuning or persistent model of any kind), to keep it secure, to share it only within a recorded delivery chain (production companies and the named end client, each bound to the same obligations, and the providers of the generation tools, hosting and storage the Licensee uses as its processors, whose terms must not let them keep the Character Sheet, train on it or derive anything from it), never to use it for identification purposes, and to delete it, and confirm deletion in writing, at the end of the licence term.

8. Data Use

We use personal data to: operate and maintain the Platform; verify eligibility; match campaigns to Talent settings at checkout and conclude and record campaign licences; compile and deliver Character Sheets under those licences; notify Talent of each licence; process licensing transactions and payouts; manage accounts and provide support; send marketing messages where you have opted in; measure, where you have consented, whether our advertising on our advertising partners’ platforms led to sign-ups and listings, and show you our ads on those platforms; enforce our agreements, including auditing Licensee compliance; act against people who copy Talent photographs from the Platform under Talent Agreement Section 4.6, including removal requests and court proceedings; check Licensees against the UK Sanctions List when we approve them; detect and prevent fraud, abuse and security incidents; and comply with legal obligations.

9. Cookies and Tracking Technologies

9.1 Cookies. The Platform sets strictly necessary cookies and similar storage, which do not require consent under the Privacy and Electronic Communications Regulations 2003 (PECR), including the error-monitoring entry described in Section 14, and, only if you accept them, the two advertising cookies set by the Meta pixel (_fbp and _fbc). Our Cookie Policy lists every cookie, its purpose and duration, and explains how to change your choice at any time. We do not set analytics cookies.

9.2 What we send to our advertising partners and why. Our advertising partners are named in Cookie settings; at present the only one is Meta. If you accept advertising cookies, the Meta pixel runs on the pages of the Platform you can see without signing in, including the sign-up pages. It does not run on, or report, pages you can see only when signed in. It sends Meta Platforms, Inc. the pages you visit where it runs, the time, your IP address and browser information, the cookie identifiers above and, when you create an account, an event recording that. We also send Meta events from our own systems (the “Conversions API”): when you create an account, an event with your email address and our user identifier for you, both in hashed form, together with your IP address, browser information and the cookie identifiers; and, when a Talent profile first appears in our browse pages, an event with the Talent’s email address, user identifier, first name, last name, date of birth and country of residence, each in hashed form, and the ad-click identifier if the Talent came to us from an ad. Hashing turns each value into a code. Meta compares the codes with codes made from details it already holds, to match the event to an ad you may have seen, and uses them for nothing else. The purpose is to measure whether our advertising on Facebook and Instagram works, to improve how those ads are delivered, and to show you our ads on Facebook and Instagram. We keep a copy of the ad-click identifier from when you create an account only until it has been sent with that event, and for no more than 90 days (Section 13); we do not store the browser identifier. We do not send Meta your photographs, Character Sheets, anything derived from them, your identity documents or the outcome of your identity check, your campaign settings, your earnings or any organisation information, and we have switched off Meta’s automatic advanced matching so the pixel does not collect what you type into forms. We send nothing if you have not consented or have withdrawn consent.

9.3 Meta’s role.For users in the UK the recipient is Meta Platforms, Inc., 1 Meta Way, Menlo Park, CA 94025, USA; for users in the EEA it is Meta Platforms Ireland Limited, Block J, Serpentine Avenue, Dublin 4, Ireland. Meta acts as our processor when it matches the hashed details to a Meta account and when it provides us with measurement reports, and deletes the hashed details once matching is done. Meta and we are joint controllers under Article 26 UK GDPR for the collection and transmission of the event data; Meta is then the sole controller of what it holds and uses it for its own advertising, security and product purposes under its privacy policy at facebook.com/privacy/policy. Under our arrangement with Meta we are responsible for telling you about this processing and for obtaining your consent, and Meta is responsible for responding to requests about the data it holds. You may exercise your rights against either of us. You can also see and disconnect what businesses share with Meta in your Meta account settings under “Your activity off Meta technologies”.

9.4 Your control. You can withdraw consent at any time through Cookie settings in the footer of the Platform; we then delete the Meta cookies, stop loading the pixel, delete any copy of the ad-click identifier we hold and send no further events. Your most recent choice, made in any browser, also applies to your account: straight away if you are signed in, otherwise the next time you sign in. Your consent lasts 12 months. We ask again when it runs out, when we add an advertising partner and when we change what we ask you to agree to. Withdrawal does not affect the lawfulness of anything sent before it; Section 17 explains how to ask Meta to erase what it already holds. You also have an absolute right to object to processing for direct marketing (Article 21(2)).

10. Withdrawal, Removal and What Happens to Licences

10.1 Talent may switch their listing off at any time in account settings, and may withdraw from the Platform entirely at any time through account settings or by contacting support@likeness-app.com. Both are free and require no reason. Withdrawal ends the Talent Agreement in respect of the listing; it is a termination of contract, and the effect depends on which of two states each licence is in:

• (a) Listed only. The listing is removed immediately. No further campaign licence is concluded and nothing further happens.
• (b) Delivered. The campaign licence continues to the end of its stated term. This is explained to Talent at sign-up, and the standing authority they give in the Talent Agreement, within the settings they chose, is what commits the Talent to that term. At term end the Licensee and every party in its delivery chain must delete the Character Sheet, confirm deletion in writing, and cease all use of the generated content. The Licensee and end client may keep finished content only as an internal archive, not for use, for up to six years, in case of legal claims.

10.2Following withdrawal we erase the Talent’s photographs and Character Sheet from the Platform within 30 days, or, where a delivered licence is still running, within 30 days after the last such licence ends, because we need them to administer that licence until then. This is subject to any longer retention required or permitted by law (for example fraud prevention, tax, or the establishment, exercise or defence of legal claims), in which case we retain them only for as long as and to the extent required. If a complaint about a Talent’s listing is under review when the Talent withdraws or closes their account, we keep the photographs until the review ends, so that the complaint can be decided properly, and then erase them. Withdrawal does not affect the lawfulness of processing before it took effect.

10.3 Where a licence continues to term under Section 10.1(b), the lawful basis for the continued use of already-generated content is the performance of the campaign licence (Article 6(1)(b)) and, where applicable, the establishment, exercise or defence of legal claims (Article 17(3)(e)).

11. Data Sharing

We share personal data with: payment processors (to facilitate transactions and payouts); Stripe (for the ringfenced identity verification described in Section 3.3); cloud infrastructure providers (hosting and storage); email providers (to deliver service messages and, where you have opted in, marketing); Meta Platforms, Inc. (UK) and Meta Platforms Ireland Limited (EEA) (advertising, only with your consent, Section 9); technical service providers (operation and security); Licensees (the Character Sheet, only under a campaign licence as described in Section 7, and, for a Licensee holding a live licence, a notice that a Conduct Event has occurred, Section 5.3); Talent (the name of a Licensee that licenses them, and the brand or end client); websites, hosts, search engines and platforms we ask to remove copied photographs, and courts, other parties and their advisers in proceedings under Talent Agreement Section 4.6 (court documents may show the Talent’s full name, as that Section explains); members of the public who visit the Platform’s browse pages (the public preview only, as described in Section 2.3); legal authorities (where required by law, court order or regulatory requirement); and professional advisors (legal, accounting and audit, under confidentiality obligations). We do not sell personal data. Our service providers process personal data only on our instructions and in accordance with applicable data protection law. Meta is a joint controller with us for the collection and transmission of advertising event data and a processor for matching and measurement, as explained in Section 9.

12. International Data Transfers

Personal data may be transferred to and processed in countries outside the UK and the EEA, including where our cloud infrastructure, payment or technical providers are based. Advertising data (Section 9) is transferred to Meta Platforms, Inc. in the United States under Meta’s UK Data Transfer Addendum, which incorporates the ICO’s International Data Transfer Addendum to the EU Standard Contractual Clauses. Where we transfer personal data outside the UK or EEA we ensure appropriate safeguards, including: transfers to countries recognised as adequate by the UK Secretary of State or the European Commission; Standard Contractual Clauses supplemented by the UK International Data Transfer Addendum where required; or other lawful transfer mechanisms. In assessing protection in third countries we apply the “not materially lower” standard introduced by the Data (Use and Access) Act 2025. Transfers of photographs and Character Sheets additionally carry encryption in transit and contractual restrictions on sub-processing. Licensees are currently approved only in the United Kingdom and countries covered by UK adequacy regulations. You may request a copy of the safeguards by contacting support@likeness-app.com.

13. Data Retention

14. Security

We implement appropriate technical and organisational measures, including: encryption of personal data at rest and in transit; access controls and authentication; segregated storage of photographs and Character Sheets with access restricted to authorised personnel and systems; regular internal security reviews; staff training; and incident response procedures. Photographs shown on the browse pages are reduced in size and watermarked or blurred, requests to those pages are rate limited, and we instruct search engines not to index them.

Error monitoring.To find and fix faults we use an error-monitoring service, Sentry, which stores the data in the EU. When something goes wrong on the Platform it receives a report, which may include our user identifier for you, the email address a failed email was being sent to, the page address and browser information. On the website it also keeps a recording of what happened on screen from shortly before an error until the end of that visit, with all text masked and all images blocked, so it does not capture what you type or anyone’s photographs. To link that recording across the pages of one visit it keeps an entry in your browser’s session storage, which is deleted when you close the tab and is listed in our Cookie Policy. We do this under legitimate interests (Section 4.1, fault monitoring).

15. Data Breach Notification

In the event of a personal data breach we will: notify the Information Commissioner’s Office within 72 hours of becoming aware, where the breach is likely to result in a risk to individuals’ rights and freedoms; notify affected individuals without undue delay where the breach is likely to result in a high risk to their rights and freedoms; and document all breaches in our internal breach register. Given the personal significance of facial photographs, any breach involving photographs or Character Sheets will be treated as likely to meet the high-risk threshold requiring individual notification unless a documented risk assessment concludes otherwise.

16. Automated Decision-Making

16.1 Concluding campaign licences is automated. When a Licensee completes checkout for a campaign, the Platform automatically checks whether the Talent’s listing is on and their account is listable, whether the campaign category is one the Talent is open to, whether, for alcohol, gambling or tobacco and vaping campaigns, the Talent is 25 or over, whether any exclusive licence in force would conflict, whether the Licensee is approved and not suspended and has passed our sanctions checks, and whether the Licensee has accepted the Licence Agreement and paid, and if so concludes the campaign licence on the Talent’s behalf and delivers the Character Sheet, without human review. This is a decision with legal effect for the Talent. It is necessary for the performance of the Talent Agreement, and we apply the safeguards in Articles 22A to 22D UK GDPR: concluding licences within the Talent’s chosen settings, without referring each one to them, is the service the Talent has signed up for. The safeguards are that every licence is recorded in the Talent’s account with the campaign name, category, tier, term and fee; the Talent may contest any licence they believe falls outside their settings by contacting support@likeness-app.com, and a person will review it; and the Talent can stop the automation at any time by switching their listing off.

16.2 Other automated processing. Identity verification is automated by Stripe as described in Section 3.3. We do not use automated comparison of faces or any facial recognition technology, and we make no automated decisions about anyone on the basis of criminal offence data. Where automated processing produces decisions with legal or similarly significant effects, we ensure the safeguards required by the UK GDPR and the Data (Use and Access) Act 2025, including the right to obtain human intervention, to express your point of view and to contest the decision. To request human review of an automated decision, contact support@likeness-app.com.

17. Your Rights

Under the UK GDPR and EU GDPR you have the following rights: access (Article 15); rectification (Article 16); erasure (Article 17), subject to the licence provisions in Section 10; restriction of processing (Article 18); data portability (Article 20); objection (Article 21), including to processing based on legitimate interests and to direct marketing; withdrawal of consent at any time (Article 7(3)), which applies to marketing messages, to advertising with our advertising partners (through Cookie settings) and to identity verification through Stripe, without affecting prior processing; and the right to lodge a complaint with the Information Commissioner’s Office at ico.org.uk or another relevant supervisory authority. For data Meta holds after it has been transmitted (Section 9.3), you may also exercise your rights directly with Meta; if you ask us, we will tell you which recipients have received your data and forward your request to Meta within seven days. If you close your account, or ask us to erase your data, and we have sent Meta an event about you, we will pass on your erasure request to Meta within seven days without your having to ask. To exercise any of these rights contact support@likeness-app.com. We will respond within one month. If a request is complex, or you have made several, we may extend that by up to two further months, and we will tell you within the first month if we need to.

18. Data Privacy Complaints Procedure

In accordance with the Data (Use and Access) Act 2025 we maintain a formal complaints procedure. You may submit a complaint to support@likeness-app.com or by post to the address in Section 20. We will acknowledge receipt within 30 days, investigate without undue delay and provide a substantive response including any actions taken or proposed. If you are not satisfied, you may complain to the ICO or seek a judicial remedy.

19. Impact Assessment and Records

We have conducted a Data Protection Impact Assessment covering the Platform’s processing of photographs, the delivery of Character Sheets, the public preview on the browse pages and the licensing model, and we review it regularly as our processing, technology and the regulatory environment change. A summary is available on request from support@likeness-app.com. We maintain Records of Processing Activities under Article 30 UK GDPR, reviewed regularly and available to the ICO on request. The assessment and our records of processing also cover advertising with our advertising partners.

20. Data Protection Contact and Supervisory Authority

Data protection enquiries should be addressed to our data protection lead at support@likeness-app.com, or by post to Likeness Ltd, Flat 3, 50 Dunlace Road, London, England, E5 0NE. Our lead supervisory authority is the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, United Kingdom (ico.org.uk).

21. Changes to This Policy

We may update this Privacy Policy from time to time and will notify you of material changes by email at least 30 days before they take effect. Where changes are required to comply with new or amended legislation or regulatory guidance, we may implement them on shorter notice or with immediate effect where legally mandated.