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Privacy-Notice

Ten 24 Media Limited – 3D scan store - Privacy Notice


Thank you for taking the time to read our privacy notice. This explains how we (Ten24 Media Limited, trading as 3D scan store) collect and process your personal data when you purchase or use our products or services, visit our website (www.3dscanstore.com), sign up for a newsletter, or interact with us in any other way.

 

It is important that you read this privacy notice carefully as it contains information relevant to your privacy and how you can exercise the rights you have in connection with your personal data. If you have any questions you can contact us on the details given below.

 

1.  IMPORTANT INFORMATION AND WHO WE ARE  

Ten24 Media Limited is responsible for personal data you share with us, or which we generate or obtain about you. That makes us a controller in connection with that data. 

We have appointed a data privacy manager. That is the person who is in charge of making sure that your personal data is kept safe throughout the time that we are responsible for it, and that it is used in the ways described in this notice. If you have any questions about this privacy notice or our data protection practices please contact them, using the following details:

 

CONTACT DETAILS

 

Our full details are:

 

Full name of legal entity: Ten24 Media Limited

 

Name or title of data privacy manager: James Busby

 

Email address: info@3dscanstore.com

 

2.  THE DATA WE COLLECT ABOUT YOU  

 

Personal data means any information about an individual which enables that person to be identified, or any information about an identifiable individual. It does not include data which cannot be connected to an identifiable individual (which is called anonymous data).

 

There are different types of personal data about you which we might collect, use, store or transfer. We have grouped these together as follows, and provided some illustrations of the type of personal data which might fall into each grouping:

 

  • Identity Data could include your first name, maiden name, last name, username or similar identifier, marital status, title, date of birth or gender
  • Contact Data could include your billing address, delivery address, email address, telephone numbers or another unique identifier for use with electronic communications
  • Financial Data could include bank account and payment card details
  • Transaction Data could include details about payments to and from you and other details of products and services you have purchased from us.
  • Imagery/Biometric Data could include photographs or other still images of you or parts of your body, and the measurements derived from those images (please note – we never use Biometric Data for the purposes of identification) for the purposes of developing 3D models
  • Technical Data could include your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and information about other technology on the devices you use to access this website
  • Profile Data could include your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses
  • Usage Data could include information about how you came to and leave our website, and how you use our website, products and services
  • Marketing and Communications Data could include your preferences in receiving marketing from us and your communication preferences.

We can also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will only be used in accordance with this privacy notice.

 

Except as specified elsewhere in this notice, we do not knowingly collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic data). It is possible that information falling into one or more of those Special Categories could be inferred about you from the information that we do process, but we will not store or make use of that information unless it is necessary for a purpose that we have communicated to you in advance. Nor do we collect any information about criminal convictions and offences.

 

IF YOU FAIL TO PROVIDE PERSONAL DATA  

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, if you don’t allow us to capture Imagery Data about you, we will not be able to produce a 3d model/avatar to your specifications; if you don’t share financial information with us, we won’t be able to take payment for things you want to buy on our website). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

  

3. HOW WE COLLECT YOUR PERSONAL DATA

 

We use different methods to collect data from and about you including through:

 

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

    • visit our studio for a photography/body scan session; 
    • ask for information about our products or services;
    • create an account on our website;
    • make a purchase as a consumer or commercial customer;
    • request marketing to be sent to you; or
    • give us feedback or contact us.

  • Imagery Capture if you are a model who attends our studio for a body scan various items of personal data about you will be captured and processed as part of that scan. This will include not only Imagery Data, but will also include some biometric information. None of this data will be used for the purposes of identification but only for the creation of a 3D model and/or resulting products derived from the captured images. This will be explained in more detail prior to your participation in the scan.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie notice https://www.3dscanstore.com/cookie-notice for further details about this.
  • Generated Data. We may generate Transaction, Usage, Marketing and Communications Data about you, by way of records of the direct and automated interactions that you have with us or our website.
  • Third parties. We will receive personal data about you from various third parties as set out below:

(a)     Third party service providers (such as Google, Facebook and Dropbox based in and outside the UK) which may provide personal information when you link, connect or log in to your account or browser profile with the third party provider; and

 

(b)     analytics providers such as Google based outside the EU.

 

PLEASE NOTE: that although payments can be made on the site, these are handled by authorised third parties including Stripe, Paypal and Alipay, who do not share any sensitive financial information with us.

 

 

4. HOW WE USE YOUR PERSONAL DATA  

We will only use your personal data for the purpose for which we collected it which include the following:

 

Purpose/Activity

 

Type of data

 

Lawful basis for processing including basis of legitimate interest

 

To register you as a new customer

 

(a) Identity

(b) Contact

 

Performance of a contract with you

 

Scan images of you and building a 3d model using that imagery

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Technical

(f) Profile

(g) Usage

(h) Marketing and Communications

 

Performance of a contract with you

Necessary for our legitimate interests (building a commercial database of 3d models for resale)

To process and deliver your order including:

(a) Manage payments, fees and charges (such payments are handled by third party providers including Stripe, Paypal and Alipay)

(b) Collect and recover money owed to us

 

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

 

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

 

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

 

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

 

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

 

To enable you to take part in a prize draw, competition or complete a survey

 

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

 

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

 

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

 

(a) Identity

(b) Contact

(c) Technical

 

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

 

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

 

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

 

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

 

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

 

(a) Technical

(b) Usage

 

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

 

To make suggestions and recommendations to you about goods or services that may be of interest to you

 

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

 

Necessary for our legitimate interests (to develop our products/services and grow our business)

 

 

 

5. HOW WE SHARE YOUR PERSONAL DATA  

 

We may share your personal data with the parties set out below for the purposes set out in the table above.

  • Although at present we do not use Third Parties as part of our supply chain, but that may change in the future.
  • Other external Third Parties, including the following Mailchimp (mailing list administration).
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

6.  CHILDREN’S PRIVACY

 

Protecting the privacy of young children is especially important. For that reason, we do not knowingly collect or solicit personal information from anyone under the age of 18 or knowingly allow such persons to register as Members. If you are under 18, please do not send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 18 is allowed to provide any personal information to or on 3D Scan Store. In the event that we learn that we have collected personal information from a child under age 18 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 18, please contact us at info@3dscanstore.com

 

7.  INTERNATIONAL TRANSFERS  

We do not currently intend to transfer, store and process your personal data outside the United Kingdom. It may be, from time to time, that it is necessary for us to make a transfer of your personal data to a country (a “third country”) which is outside of the UK. We will only do so where we have a legitimate business purpose for doing so, and will ensure that appropriate safeguards are in place in relation to that transfer. These will include establishing whether the recipient is located within a country in relation to which the relevant UK Secretary of State has made a finding of adequacy in connection with its data protection regime. Where there has been no such adequacy determination we will ensure that appropriate contractual safeguards are in place which will be documented in a data sharing or data processing agreement using the model clauses approved by the UK Secretary of State and the Information Commissioner’s Office, from time to time.

8.  DATA SECURITY  

 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

9.  DATA RETENTION  

 

We will only keep your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

 

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

 

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for further commercial use (for example Imagery Data collected during a body scan may be modified so that it is no longer distinctive or able to identify you, so that it can be reused), in which case we may use this information indefinitely without further notice to you.

 

10.  YOUR LEGAL RIGHTS  

Under certain circumstances, you have rights under data protection laws in relation to your personal data including the right to receive a copy of the personal data we hold about you and the right to make a complaint at any time to the Information Commissioner’s Office, the UK supervisory authority for data protection issues (www.ico.org.uk). These rights include the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

 

  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

 

  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

 

  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

 

  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • If you want us to establish the data’s accuracy.
    • Where our use of the data is unlawful but you do not want us to erase it.
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

 

  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

NO FEE USUALLY REQUIRED: You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU: We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND: We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.