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:
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:
(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.
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:
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.