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This privacy policy (the Privacy policy) describes the processing of your personal data by Vectary, Inc. with its registered seat at Greentree Drive 160, Dover 199 04, United States of America (the Company , we or us ) for the purpose of providing you with our services located at www.vectary.com (the Site) where you can create and share 3D content, using Vectary´s collaborative platform, consisting of (a) Studio, an online editor where users can create 3D digital designs (Projects) (b) Workspaces, where users can collaborate on Projects, and (c) Share Link, where users can create a publicly accessible link to their Projects (collectively, with all other services accessible through the Site the Services).
1.1 All the capitalized terms used in this Privacy Policy shall have the meaning assigned to them in our Terms of Use.
2.1 We collect a variety of personal data (Data) from you when you provide it to us directly, when we request it from you, or when you give us permission to get it from a third party source, depending on your use of our Site and/or Services:
a) Information you provide for the use of our Site and Services.
i. Registration: Information that you provide to us when registering with our Site (including your name and email address).
ii. Profile: Information that you provide when completing your profile on our Site (including your name, profile pictures, gender, date of birth, interests and hobbies, educational details and employment details, location,
iii. Purchase: Information relating to any purchases you make in respect of the Services and information you provide to the online payment service provider (including your name, email address and payment status and details).
iv. Communication: Information contained in or relating to any communication that you send to us or send through our Site (including the email address as well as any other communication content).
v. Notifications: Information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (including your name and email address).
vi. Posting: Information that you post to our Site for publication on the internet (including your name, photo and Projects).
vii. Questionnaires: Information you decide to share when you take part in our questionnaires (including the email address, account details, position).
viii. Public Project Link: Information you decide to share to generate the publicly accessible Project Link (including account details and user name).
ix. Other: Any other Data that you choose to send to us. We do not 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 and biometric data) and we encourage you not to share this type of information with us.
b) Information we obtain from social media platforms:
i. When you visit or interact with our pages on social media platforms, such as Facebook, LinkedIn, Twitter, Instagram, YouTube, Pinterest and other third-party platforms, you are agreeing to the platform provider’s privacy policy. This may include sharing with us your name, profile, photos, reactions and comments to our posts, etc. The platform provider’s privacy policy applies to your interactions and their collection, use and processing of your Data. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.
ii. Data from other accounts. If you use a third party, like Google or Facebook, to log in to the Site (or later connect your third-party account to your Vectary account), then you authorize the third party to share your Data with us, including your name, username, photo, email address, and any other information you agree to share. The platform provider’s privacy policy applies to your interactions and their collection, use and processing of your Data.
c) Information we obtain from other third parties.
We may receive Data about you from third-party sources. For example, we may obtain your Data from other third parties, such as marketing partners, publicly available sources and data providers.
d) Information we collected by automated means from your browser and device through cookies and other tracking technologies.
With your permission where it is required by applicable laws, we, our providers, and our business partners may automatically log information about your computer and about your visits to and use of our Site and/or Services (including your IP address and geographical location, device type, device screen resolution, browser type and version, operating system, referral source, length of visit, page views, preferred language, mouse events (movements, location and clicks), keypress, referring URL and domain, pages visited, date and time Site was accessed and website navigation paths or any similar information that may be obtained by the Company directly or indirectly from third party providers.). Information that you provide to us when using our Site and/or the Services, or that is generated in the course of the use of those Services (including the timing, frequency and pattern of Service use).
On our webpages, this information is collected using cookies, browser web storage (also known as locally stored objects, or “LSOs”), Flash-based LSOs (also known as “Flash cookies”), web beacons, and similar technologies, and our emails may also contain web beacons.
See our Cookie Policy for more information.
3.1 To provide our services and operate the Site we use your Data to:
• register and/or create an Account
• provide, operate and improve the Site, and our products and services
• establish and maintain your user profile on the Site
• provide you with the results of the questionnaire
• enable security features of the Site, such as by sending you email when you forget your account password, and remembering devices from which you have previously logged in
• communicate with you about the Site, our services, including by sending you announcements, updates, security alerts, and support and administrative messages
• understand your needs and interests, and personalize your experience with the Site and our communications
• provide the features and functionality of the Site
• respond to questions or requests you have submitted to us.
Please note that any personal information or content that you voluntarily disclose for posting to the Site, its related forums, message boards, your Public Projects, or similar publicly accessible areas or content become available to the public.
3.2 For research and development
When processing your Data you provided us we may use automated evaluation of certain personal features or characteristics to improve the Site and to develop new products and services, including use of the Site.
3.3 To send you marketing and promotional communications
Subject to giving us consent, we may also use your email address to send you other messages, such as newsletters, information about how to use our Services, changes to Services, or special offers. If you decide not to receive such messages anymore, you may unsubscribe by following the link provided in the email communication. Unsubscribing may prevent you from receiving messages regarding updates, improvements, or offers. You may not unsubscribe from service-related emails. If you correspond with us by email, we may retain the content of your email messages and our responses.
3.4 To create anonymous, aggregated or de-identified data
We may use certain information about you and/or certain of your Data without identifying you as an individual to third parties. We make Data into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We do this and share it with third parties for our lawful business purposes, including to analyze and improve the Site and promote our business.
3.5 To display advertisements
We work with advertising partners to display advertisements elsewhere online. These advertisements may be targeted based on your use of the Site or your activity elsewhere online. To learn more about your choices in connection with advertisements, please see the section below titled “Object to how we use your Data for direct marketing purposes.”
3.6 For compliance, fraud prevention, and safety
We may use your Data and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the Terms of Use that govern the Site; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
3.7 To comply with law
We use your Data as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
3.8 With your consent
In some cases, we may specifically ask for your consent to collect, use or share your Data, such as when required by law.
4.1 We use your Data only as permitted by law. Our legal bases for processing the Data described in this Privacy Policy are described below.
4.2 We shall process your Data in accordance with applicable law and protect your Data against misuse and/or any unlawful disclosure.
4.3 Performance of a contract
We process your Data as is necessary to provide the services that you requested from us. For example:
• We use your information in order to create your account and set your profile on Vectary.
• We share your information with services provider to provide you with the services you requested.
4.4 Your Consent
We process certain information based on your consent, which you may revoke at any time. For example:
• we and our partners use cookies and similar technologies, as described in more detail in our Cookie Policy, based on your consent;
• we and our partners rely on your consent to provide you with tailored ads based on your actions and information, including based on your activity on the Site and other websites;
• we will send you marketing communications where you have consented to receiving such communications in accordance with applicable law.
Data that you have disclosed voluntarily
When you provide a bio, we do not 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 and biometric data) and we encourage you not to share this type of information with us.
4.5 Legitimate Interests
We may process your information where it is necessary for the purposes of our legitimate interests or our partners’ legitimate interests. In particular, we process your information in furtherance of the following legitimate interests:
• Keeping the Services safe and secure: We and our service providers use your information because it is necessary to pursue our legitimate interests in ensuring our Site is secure, such as implementing and enhancing security measures and protections, protecting against fraud, spam and abuse, and enforcing our Terms of Use.
• Providing, improving, and developing the Services: We and our services providers use your information to provide the Site as well our products and services, including any personalized services, and to understand and improve our business. We do so as it is necessary to pursue our legitimate interests of providing an innovative and tailored offering to our users and members on a sustained basis.
• Providing ads, and measurement and analytics services: We and our partners use your information to provide personalized ads, and to measure and analyze the success of those ads in order to provide accurate and reliable reporting to our advertisers. We do so as necessary to pursue our legitimate interests and our partners’ legitimate interests of marketing and monetizing our services.
4.6 Legal Obligation
We may process your information in order to comply with a legal obligation, a court order, or to exercise and defend legal claims. For example:
• we may preserve and disclose your information if it is necessary to respond, based on applicable law, to a valid legal request (e.g. a subpoena, search warrant, court order, or other binding request from government or law enforcement); and
• we may retain and process your information where it is necessary for compliance with applicable laws.
As detailed in the Privacy Policy, where we process your information based on legitimate interests, you have the right to object to such processing. Where you exercise your right to object, we will cease processing your information for that specific purpose, unless there are compelling legitimate grounds overriding your objection or where your information is processed for legal reasons.
4.7 Use for new purposes
We may use your Data for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your Data for an unrelated purpose, we will notify you and explain the applicable legal basis.
5.1 We share your Data with third parties where it is necessary to provide our products and Sites, and for purposes described in this Privacy Policy.
5.2 Affiliates
We may share your Data with member of our group of companies, especially subsidiaries, and affiliates for the purposes set out in this Privacy Policy.
5.3 Service providers
We may share your Data with third party companies and individuals that provide services on our behalf or help us operate the Site (such as customer support, hosting, analytics, email delivery, marketing, quality assurance vendors, IT services and developers, and database management services). Our service providers include notably Hotjar, Sentry, New Relic, Zendesk, Circle, Drip, and Paddle, but we may work with other services providers as well. These third parties may use your Data only as directed or authorized by us and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose.
5.4 Partners
We may sometimes share your Data with partners or enable partners to collect information directly via our Site. Our partners may include notably Google, Facebook, Instagram, LinkedIn, YouTube, Vimeo. Please read our partners’ privacy policy to understand how they use your Data.
5.5 Third-party websites, platforms and social media networks
If you have shared your publicly accessible Project Link or enabled features or functionality that connect the Site to a third-party website, platform or social media, we may disclose the Data that you authorized us to share. In particular, our Site includes certain social media features, including social media share buttons. If you choose to share a post using the social media share button, information about that Content will be shared with Facebook, etc. We do not control the third party’s use of your Data. Please consult the third-party website or platforms’ privacy policy to understand how they use your Data.
5.6 Professional advisors
We may disclose your Data to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
5.7 Authorities and others for compliance, fraud prevention and safety
We may share your Data for the compliance, fraud prevention and safety purposes described above.
5.8 Business transferees
We may sell, transfer or otherwise share some or all of our business or assets, including your Data, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.
Your Personal Data may be transferred and stored outside your place of residence, that are subject to different standards of data protection. We will take appropriate steps to ensure that transfers of personal data are in accordance with applicable law and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights.
We retain Data for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.
To determine the appropriate retention period for Data, we consider the amount, nature, and sensitivity of the Data, the potential risk of harm from unauthorized use or disclosure of your Data, the purposes for which we process your Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
8.1 You are entitled to:
a) Access to your Data: In particular to:
(i) request information about the purpose of their processing,
(ii) categories of processed Data,
(iii) identifying the recipient to whom the Data are to be provided, or
(iv) duration of processing and collecting your Data.
b) Correction of your Data:
In case you acknowledge that we are processing Data about you, which are not correct, please inform us about this matter and we shall correct such incorrect data without undue delay.
c) Erasure of your Data (Right to be forgotten):
You can also request that we erase your Data in limited circumstances where:
(i) the Data are no longer necessary in relation to the purpose for which they were collected,
(ii) you withdraw your consent to processing your Data according to this Privacy Policy,
(iii) you object to the processing of your Data,
(iv) in case your Data have been obtained by us unlawfully, or
(v) we have a legal obligation to do so
d) Restriction of Data processing:
You have the right to restriction of your Data processing if:
(i) the accuracy of your Data is contested by you for a period which shall enable us to verify the accuracy of your Data,
(ii) the processing of your Data is unlawful and you request restriction of such Data use instead of erasure,
(iii) we no longer need your Data for the purpose of processing, but are required by you for the establishment, exercise or defence of legal claims, or
(iv) you have objected to the processing of your Data pending the verification whether our legitimate grounds override yours.
We can continue to use your Data following a request for restriction, where:
• we have your consent,
• to establish, exercise or defend legal claims, or
• to protect the rights of another natural or legal person.
e) Data portability:
You are entitled to receive your Data processed by us in a structured, commonly used and machine-readable format or you can ask to have it transferred directly to another data controller, but in each case only where:
• the processing is based on your consent or on the performance of a contract with you; and
• the processing is carried out by automated means.
f) Object Data processing:
You have the right to object the processing of your Data based on the grounds of legitimate interest, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
g) Object to how we use your Data for direct marketing purposes:
You can request that we change the manner in which we contact you for marketing purposes.You can request that we not transfer your Data to unaffiliated third parties for the purposes of direct marketing or any other purposes.
h) Lodge a complaint with a supervisory authority:
If you consider that your rights relating to the processing of your Data have been infringed you have the right to lodge a complaint with your local supervisory authority.
8.2 Withdraw consent. Where we are relying on your consent for the processing of your Data, you have the right to withdraw your consent at any time by contacting contact@vectary.com.
8.3 You may submit these requests by email to contact@vectary.com. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your Data or our response to your requests regarding your Data, you may contact us or submit a complaint to the data protection regulator in your jurisdiction.
9.1 Your personal data are not a subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you, or similarly significantly affects you.
10.1 Protecting the privacy of young children is especially important. For that reason, we do not knowingly collect or solicit Data from anyone under the age of 16. If you are under 16, please do not send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 16 is allowed to provide any Data to or on the Site. In the event that we learn that we have collected Data from a child under age 16 without verification of parental consent, we will delete that information as soon as reasonably practicable. If you believe that we might have any information from or about a child under 16, please contact us at contact@vectary.com.
11.1. We reserve the right to change our Privacy Policy. If we change our privacy policies and procedures, we will post those changes on the Site to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it. We may, and if required by law, also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through the Site.
11.2 Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Site (or as otherwise indicated at the time of posting).
12.1 Vectary Inc. is the controller of your Data covered by this Privacy Policy for purposes of EU data protection legislation.
13.1 Please direct any questions or comments about this Policy or privacy practices to contact@vectary.com.
14.1 You have a right to lodge a complaint with your local data protection supervisory authority (i.e. your place of habitual residence, place or work or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before referring the matter to your local supervisory authority. You can find your data protection regulator:
For the EU here
For the UK here