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Privacy Policy

Last updated: June 7, 2021

 

 

  1. Introduction

 

This privacy policy has been compiled to better serve those who are concerned with how their 'Personal Information' is being used online.

 

Personal Information is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context.

 

Safeguarding your Personal Information is important to Modelo Inc. and its affiliates (collectively “we”, “us” or “Modelo Group”) and we recognise the responsibility you entrust us with when providing your Personal Information. This Privacy Policy details how your Personal Information is used by us both actively and passively, when you use our services. With this Privacy Policy (together with Modelo Terms & Conditions of Use and any other documents referred to on it) we wish to outline the basis on which any Personal Information we collect from you, or that you provide to us, will be processed including, what information we may collect from you via the services, how we will use it, how we may disclose information provided by you to third parties and the use of "cookies".

Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personal Information in accordance with features and services of Modelo Platform (“Modelo Platform”).

 

 

  1. Personal Information We Process & How We Use Your Information

 

  1. Registration

In order to use certain services of Modelo Platform, you may be required to create an account ("Account"), which will require you (or in some cases, may just give you the option) to provide Personal Information, such as your name and email address.

 

For users who live in the European Economic Area (“EEA”), the legal basis for processing the registration data is the intention of fulfilling or initiating a contractual relationship with us pursuant to Article 6 (1) b) of the GDPR is additionally the legal basis for processing the data. The mandatory information requested as part of the registration process is required to fulfill or initiate a contract with us for specific services of Modelo Platform.

 

A user account will be created for you when you register. We will retain the data in the user account for as long as an active user relationship exists.

 

  1. Account settings

 

You can set your avatar, name, address and decide whether to receive email notifications in account settings.

 

We use your Personal Information to help you to complete account settings. For users who live in the EEA, the legal basis for processing your data is your consent pursuant to Article 6 (1) a) of the GDPR.

 

If you do not agree to this processing, please don’t set your account of Modelo Platform.

 

This data is only saved for as long as an active user relationship exists, after which it will be deleted or anonymized.

 

  1. Payment service

 

Every time you pay for paid services of Modelo Platform, payment service providers will collect your name(s), bank account, your name on card, credit card number, card expiry, CVC, price of the service you purchase, whether the payment has been completed. The payment service provider is Stripe Inc.

 

Payment service providers use your Personal Information to enable you to pay online for your convenience. Also, by collecting your payment data, you can easily get your refund. For users who live in the EEA, the legal basis for this is the intention of fulfilling or initiating a contractual relationship between you and payment service providers pursuant to Article 6 (1) b) of the GDPR.

 

Further information on the processing of data by Stripe, as well as on your rights and options for privacy, can be found at: https://stripe.com/en-nl/privacy.

 

  1. Project management

 

Every time you manage projects, projects’ name, establishment date, expiry date, name of your client, your country/region, description of projects, the size of projects, the number of models, the number of feedbacks, the number of files, the number of walkthrough, information of team members, your comment data and your mark data will be collected.

 

We use these data to help you to manage design online, and with this function, you can easily manage your designs, keep the team connected on the latest version of the document in an organized way and increase your productivity. For users who live in the EEA, the legal basis for processing your data is the intention of fulfilling or initiating a contractual relationship with us pursuant to Article 6 (1) b) of the GDPR.

 

This data is only saved for as long as an active user relationship exists, after which it will be deleted or anonymized.

 

  1. Invitation of team members

Every time you invite your team members into your projects, your team members’ name(s), emails, their roles in the design project (such as owner of the design or team members) (“team members data”) will be collected.

 

We use your team members data to help you and your team members to communicate with each other conveniently and timely and work together on the design to increase your efficiency of designing. For users who live in the EEA, the legal basis for processing your data is the intention of fulfilling or initiating a contractual relationship between you and payment service providers, pursuant to Article 6 (1) b) of the GDPR. Before you invite your team members to collaborate with you, please obtain your team members’ consent to be invited and to provide team members data to us.

 

This data is only saved for as long as an active user relationship exists, after which it will be deleted or anonymized.

 

  1. Display tools

 

Every time you use the display tools of Modelo Platform (such as Walkthrough, 360 Tour and VR Embed 3D), the model uploaded by you, the number of your clicks of display tools and the time of your clicks of display tools will be collected.

 

We use this data to help you use display tools of Modelo Platform. For users who live in the EEA, the legal basis for processing your data is the intention of fulfilling or initiating a contractual relationship between you and us, pursuant to Article 6 (1) b) of the GDPR.

 

This data is only saved for as long as an active user relationship exists, after which it will be deleted or anonymized.

 

  1. PDF markup

 

Every time you make PDF markup on the designs, your marks, the place of marks, the appendixes of marks(“mark data”) will be collected.

 

We use your mark data to help you to make comments on your design with pinpoint accuracy, call out your team members, assign tasks and track replies to your comments. For users who live in the EEA, the legal basis for processing your data is the intention of fulfilling or initiating a contractual relationship between you and us, pursuant to Article 6 (1) b) of the GDPR..

 

This data is only saved for as long as an active user relationship exists, after which it will be deleted or anonymized.

 

  1. Commentary

 

Every time you make commentary on the designs, your user name(s), date and time of the comments, the content of your comments (“comment data”) will be collected.

 

We use your comment data to help you to provide design feedback conveniently, and to communicate with your team members effectively and seamlessly. For users who live in the EEA, the legal basis for processing your data is the intention of fulfilling or initiating a contractual relationship between you and us, pursuant to Article 6 (1) b) of the GDPR..

 

This data is only saved for as long as an active user relationship exists, after which it will be deleted or anonymized.

 

  1. Model sharing

 

Every time you share models on Modelo Platform, the recipients’ email address, model description and model setting will be collected.

 

We use this data to help you communicate with others conveniently and timely and work together on the design to increase your efficiency of designing. For users who live in the EEA, the legal basis for processing your data is the intention of fulfilling or initiating a contractual relationship between you and payment service providers, pursuant to Article 6 (1) b) of the GDPR. Before you fill the recipients’ email address, please obtain the recipients’ consent.

 

This data is only saved for as long as an active user relationship exists, after which it will be deleted or anonymized.

 

  1. Demo request & consultation schedule

 

When you request demo or schedule consultation about business accounts on Modelo Platform, your name(s), phone number, interested products, company name, country/region, information you are looking for and available time will be collected.

 

We use this data to contact you and provide you with demo and information about business accounts. For users who live in the EEA, the legal basis for processing your data is your consent pursuant to Article 6 (1) a) of the GDPR.

 

If you do not agree to this processing, please don’t request demo or schedule consultation about business accounts on Modelo Platform.

 

This data is only saved for as long as an active user relationship exists, after which it will be deleted or anonymized.

 

  1. Customer services

 

When you use the Frequently Asked Questions service of Modelo Platform, we will use Zendesk to collect your email address, the subject, description and attachments of your request.

 

We use this data to communicate with you about your question or requests on how to use Modelo for 3D presentations and collaboration. The legal basis for processing this data is your consent pursuant to Article 6 (1) a) of the GDPR.

 

If you do not agree to this processing, please don’t use Frequently Asked Questions service through Modelo Platform. Instead, you can send your questions or requests to us at hi@modelo.io.

 

This data is only saved for as long as an active user relationship exists, after which it will be deleted or anonymized.

 

  1. Newsletter

 

When you register for our e-newsletter, your email address will be used for our promotional purposes until you unsubscribe. You will regularly receive information via email in this regard on current topics as well as emails for specific events and special promotions. The emails may be personalized and individualized based on the information saved about you.

 

In addition, we process the following data in relation to the use of the newsletter: the email program you are using, your browser’s operating system, the time of access, and your abbreviated IP address. For users who live in the EEA, the legal basis for processing your data is your consent pursuant to Article 6 (1) a) of the GDPR.

 

If you do not wish to receive this information, we will also provide you with the method to cancel such an information subscription with an unsubscribe link contained in every newsletter. But you will not be able to cancel the subscription of the information that is related to the system service and is not a promotion advertisement. For example, a notification sent to you by Modelo Group due to the service suspension caused by system maintenance.

 

  1. Stability of Modelo Platform

 

Every time you use Modelo Platform, we collect your IP address, version information about browsers used, your operating system and general non-identifiable demographic data (“operating data”).

 

We use this operating data to identify and resolve errors, to determine the stability of the website in different browsers and operating systems, and to make adjustments or improvements. For users who live in the EEA, the legal basis for processing the operation data is that we have a legitimate interest in processing data pursuant to Article 6 (1) f) of the GDPR.

 

Your operating data will only be saved for the time as long as your account exists, after which they will be deleted or anonymized.

 

  1. Data analysis

It's also important to note that we allow third party to conduct behavioral tracking. Every time you visit Modelo Platform, we will use Mixpanel to collect your IP address, the request from your browser as well as the time this request was made, product and version information about the browser used, the operating system of your devices.

 

Mixpanel uses your Personal Information to analyse your behaviors and help us to improve our website in order to better serve you. For users who live in the EEA, the legal basis for data analysis is that we have a legitimate interest in processing data pursuant to Article 6 (1) f) of the GDPR.

 

Further information on the processing of data by Mixpanel, as well as on your rights and options for privacy, can be found at: https://mixpanel.com/legal/privacy-policy/.

 

 

  1. Use of Cookies

Cookies are small files that a site or its service provider transfers to your computer's hard drive through your Web browser (if you allow) that enables the site's or service provider's systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us remember and process the items in your shopping cart. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (like Internet Explorer) settings. Each browser is a little different, so look at your browser's Help menu to learn the correct way to modify your cookies.

You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you select this setting you may be unable to access certain parts of the Site.

 

  1. Your Rights and Contact

 

We take great care to ensure that the processing of your personal information is explained as transparently as possible and that you are also informed about your rights. Should you require more detailed information or want to exercise the rights to which you are entitled, you can contact us at any time so that we can take care of your request.

 

  1. Rights of data subjects

Subject to possible restrictions under national laws, as a data subject, you have the right to access, rectification, erasure, restriction of processing, objection to a decision based solely on automated processing, data portability and not to be discriminated with regard to your personal information. In addition, you can withdraw your consent and object to our processing of your personal information on the basis of our legitimate interests. You can also lodge a complaint with a supervisory authority. Details are as follows:

 

(1)      You can withdraw your consent to the processing of your Personal Information by us at any time. As a result, we may no longer process your personal information based on this consent in the future. The withdrawal of consent has no effect on the lawfulness of processing based on consent before its withdrawal.

 

(2)      You have the right to obtain access to your personal information that is being processed by us. In particular, you may request information on the purposes of the processing, the categories of Personal Information concerned, the categories of recipients to whom the Personal Information have been or will be disclosed, the envisaged period for which the Personal Information will be stored, the existence of the right to request rectification or erasure of Personal Information or restriction of processing of Personal Information or to object to such processing, the right to lodge a complaint with a supervisory authority, any available information as to the personal information’s source (where they are not collected from you), the existence of automated decision-making, including profiling and, where appropriate, meaningful information on its details. Your right to access may be limited by national laws.

 

(3)      You have the right to obtain from us without undue delay the rectification of inaccurate personal information concerning you. Taking into account the purposes of the processing, you have the right to have incomplete Personal Information completed, including by means of providing a supplementary statement.

 

(4)      You have the right to obtain from us the erasure of Personal Information concerning you, unless the processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the establishment, exercise or defence of legal claims. The right to erasure may be limited by applicable national laws.

 

(5)      You have the right to obtain from us restriction of processing to the extent that the accuracy of the data is disputed by you, the processing is unlawful, but you oppose the erasure of the personal information, and we no longer need the information, but you need it to assert, exercise or defend legal claims or you have objected to the processing.

 

(6)      If your personal information is processed on the basis of our legitimate interests, you have the right to object to the processing of your personal information on grounds relating to your particular situation. This also applies to profiling. If your personal information is processed by us for direct marketing purposes, you have the right to object at any time to the processing of your personal information for such marketing, which includes profiling to the extent that it is related to such direct marketing.

 

(7)      You have the right to receive the personal information concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller (“right to data portability”).

 

(8)      You have the right to object to a decision based solely on automated processing, including profiling, except that the decision is necessary for entering into, or performance of, a contract between you and us, except that the decision is authorised by applicable laws which lay down suitable measures to safeguard your rights and freedoms and legitimate interests, or except that the decision is based on your explicit consent.

 

(9)      We will not discriminate against any user for exercising their rights under applicable laws and this Privacy Policy.

 

  1. Exercise of rights

We would like to maintain accurate Personal Information, and we endeavour to comply with all rights you might have under data protection laws. If you would like to delete, access or correct any of your Personal Information that we may be storing, there may be tools that we make available via the services. Otherwise, please contact us at hi@modelo.io to make your request, containing adequate details of the request. We will treat your request in accordance with applicable laws.

 

  1. Data protection officer and contact

We have appointed a data protection officer to support us in relation to data privacy issues and with whom you can also make contact directly. Our data protection officer is available to you to deal with queries relating to our processing of Personal Information or to provide other information on data privacy issues. We will respond to your requests within one month or two months (if the request is complex or you have made a number of requests).

 

Data Privacy Contact

E-mail: hi@modelo.io

Address: Modelo Inc, 1 Davis Square, Somerville MA 02144.

 

  1. Complaints

 

If you are of the opinion that the processing of your Personal Information by us is not in compliance with this Privacy Policy or the applicable data protection regulations, you have the right to make a complaint to a regulatory authority. You can also make a complaint to hi@modelo.io. We will then check the matter and inform you about the outcome of the investigation.

 

 

  1. Data Deletion and Storage Period

 

We will retain your Personal Information only for as long as necessary to fulfil the purpose(s) for which it was collected and to comply with applicable laws. Your consent to such purpose remains valid after termination of our relationship with you.

In principle, we store your data as long as it is required to deliver the services and as long as we have the rightful interest towards saving it for an extended period of time (for instance, after fully executing a contract, we may still have a rightful interest towards the use of your data for marketing purposes). Excluded from deletion is only the data we need for the execution of pending tasks and the data we need to realize our rights and our claims, as well as certain data that we must store for a legally mandatory longer period of time. When certain data is only saved due to a legally mandatory preservation term, the processing of it by us is limited, even without your request.

 

  1. Third Party Disclosure

 

We do not sell, trade, or otherwise transfer to outside parties your Personal Information unless we provide you with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others' rights, property, or safety.

 

For the free users of Modelo Platform, we will disclose your design in the 3D Community on the Modelo Platform and other users could visit your designs through the 3D Community on the Modelo Platform.

 

 

  1. How We May Share or Disclose Your Personal Information

 

We only use your Personal Information to provide the services you request. If we cooperated with external service providers in the provision of services through Modelo Platform, they shall also only access the data for the purpose of providing certain types of services. We use technical and organizational measures to ensure compliance with the data protection regulations and also ask for compliance on the part of our external service providers in this respect.

We will not transfer the data to other third parties without your explicit consent, in particular not for marketing purposes. Your Personal Information shall only be transferred if you have given your consent to do so, or if we are entitled or obliged to do so due to legal regulations and/or official or judicial orders. This may especially involve the provision of information for law enforcement purposes, for averting danger, or for enforcing intellectual property rights.

We may send or otherwise share Personal Information to/with our local or foreign subsidiaries or affiliates for the purpose of storing such information on our behalf, or carrying out other processing on our behalf. These entities may be located in other countries where Modelo Platform has no presence, and their servers may be located anywhere in the world. We require these entities to agree to process such Personal Information in accordance with this Privacy Policy.

 

 

  1. How We May Transfer Your Personal Information Across the Border

We will not transfer your Personal Information to our affiliates and service providers in third countries without your consent.

Insofar as we transfer your Personal Information ourselves or through service providers to countries outside the EEA, we shall comply with the special provisions of Article 44 of the GDPR in this respect and shall similarly ask for our service providers to comply with these regulations. We shall therefore only transfer your data to countries outside the EEA subject to the level of protection assured by the GDPR. This level of protection is assured especially through the use of standard privacy clauses in accordance with Article 46 (2) c) of the GDPR.

 

 

  1. Third Party Links

Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

 

 

  1. Children’s Privacy Policy

The services are not structured to attract minors. Accordingly, we do not intend to collect Personal Information from anyone we know to be minors. If we learn that we have collected Personal Information from minors, we will use commercially reasonable efforts to delete that data as quickly as possible. If you believe that we might have any such data, please contact us at hi@modelo.io.

 

  1. Fair Information Practices

 

The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.

 

For users who live in the United States, in order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:

(1)      We will notify the users via email within 7 business days;

(2)      We will notify the users via in site notification within 7 business days.

 

We also agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.

 

 

  1. CAN SPAM Act

 

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

 

For users who live in the United States, we collect your email address in order to market to our mailing list or continue to send emails to our clients after the original transaction has occurred.

 

To be in accordance with CANSPAM we agree to the following:

(1)      NOT use false, or misleading subjects or email addresses;

(2)      Identify the message as an advertisement in some reasonable way;

(3)      Include the physical address of our business or site headquarters;

(4)      Monitor third party email marketing services for compliance, if one is used;

(5)      Honor opt-out/unsubscribe requests quickly; and

(6)      Allow users to unsubscribe by using the link at the bottom of each email.

 

If at any time you would like to unsubscribe from receiving future emails, you can email us at hi@modelo.io or follow the instructions at the bottom of each email and we will promptly remove you from ALL correspondence.

 

 

  1. Changes to this Privacy Policy

The effective date of this Privacy Policy is indicated in the top of this Privacy Policy. We reserve the right to change this Privacy Policy at any time with effect for the future. Changes may arise especially in the case of technical modifications to our website or revisions to data protection regulations. The up-to-date version of the Privacy Policy can be accessed directly via our website at all times. We recommend that you familiarize yourself regularly with any changes to this Privacy Policy.