Privacy Policy

Introduction

Aylo Freesites Ltd (hereinafter “we”, “us” or “our”) operates the website https://www.modelhub.com/ (hereinafter “Modelhub” or the “Website”) and is the controller of the information collected or provided via this Website.

Please read this privacy policy carefully, as your access to and use of our Website signifies that you have read, understand and agree to all terms within this privacy policy. If you do not agree with any part of this privacy policy or our terms, please do not access or continue to use our Website or otherwise submit your personal data. We respect your privacy and are committed to protecting your personal data.

If you have any questions about our privacy practices, please see “Contact” information below for information on how to contact us.

We collect, process, and retain personal data to the extent it is necessary to provide users with our service. This privacy policy applies to information we collect:

• on this Website,
• in e-mail, text and other communications between you and this Website,
• through mobile applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website, or
• when you interact with our advertisements and applications on third-party websites and services if those applications or advertisements include links to this privacy policy.

It does not apply to information collected by:

• us offline or through any other means, including on any other website operated by us or any third party (including our affiliates and subsidiaries) except specified in our terms or this privacy policy; or
• any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.

The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified (“Personal Information”). It does not include data that has been anonymized or pseudonymized.

We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:

Persons who visit the Website without logging in or registering (“Unregistered Users”)

• Technical Data includes internet protocol (IP) address, which we pseudonymize (a technique that replaces or removes information in the dataset that identifies an individual), browser type and version, time zone setting and location, operating system and platform and other technology on the devices you use to access this Website.
• User Submitted Data includes data collected at your direction for a specific function, for example a contest or survey.
• Usage Data includes aggregated information about how you use our Website, products and services.

Persons who choose to create an account (“Registered Users”)

• Identity Data includes username or similar identifier, date of birth and gender.
• Contact Data includes email address.
• Financial Data in case of purchases includes payment card details.
• Transaction Data in case of purchases, it may include details about payments to and from you and other details of products and services you have purchased or received from us.
• Technical Data includes pseudonymized internet protocol (IP) address, your login data, browser type and version, time zone setting and location, operating system and platform and other technology on the devices you use to access this Website.
• User Submitted Data includes data collected at your direction for a specific function, for example your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Dataincludes information about how you use our Website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may also collect, use, and share your data to produce and share aggregated insights that do not identify you. Aggregated data may be derived from your personal data but is not considered personal data as this data does 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, to generate statistics about our users, to calculate the percentage of users accessing a specific Website feature, to calculate ad impressions served or clicked on, or to publish visitor demographics.

We do not collect special categories of Personal Information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, political opinions, trade union membership, information about your health and genetic and biometric data). However, particular preferences and sexual orientation depend on how you use our Website and services. The processing of such Sensitive Personal Information may be necessary to provide some of our service to you.

Our Websites are not directed to persons under the age of 18 or the applicable age of majority in the jurisdiction from which the Websites are accessed (“minors”), and we prohibit minors from using the Websites. As indicated throughout this privacy policy, some users may be asked to provide some information to us and our service providers in order for us to make sure that they are over the age of majority required to have access to the Websites and to view their contents. We do not knowingly process personal information from minors. If you are the parent or legal guardian of a minor who has provided us with personal information, then please contact us at support@modelhub.com to have that minor’s personal information deleted.

The Sources from Which We Process Your Personal Information

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

• Directly from you: Information that you provide when carrying out search queries on our Website or by filling in forms on our Website, in particular at the time of registering to use our Website, subscribing to our service, posting material, taking part in surveys, entering a contest or promotion sponsored by us, when reporting a problem with our Website, or requesting further services.
• Automated technologies or interactions: See “Third-party Use of Cookies and Other Tracking Technologies” for details of how we may automatically collect your personal data.

User Contributions

We may provide areas on our Website where you can post information about yourself and others and communicate with others, upload content (e.g., pictures, videos, audio files, etc.), and post comments or reviews of content found on the Website. Such postings are governed by our terms of use found at https://www.modelhub.com/information/terms. You should be aware that any Personal Information you submit, display, or publish in public areas of our website is considered publicly available and can be read, collected, used, and disclosed by others. We cannot control who reads your posting or what other users may do with the information you voluntarily post, so we encourage you to exercise discretion and caution with respect to your Personal Information. To request removal of your personal information from our website, please refer to the section “your rights related to your personal information” in this policy.

Our Legal Bases under Canadian and European Union (EU) Privacy Law

We have the following legal bases under Canadian and EU privacy law for processing your personal data for the purposes described under Section Purposes for Which We Process Your Personal Information section:

• We process personal data for the purposes of providing the services, customer management, certain customization of content (e.g., based on your selected preferences, favorites and ratings), and functionality and security because the processing is necessary for the performance of a contract, specifically it is necessary to provide the services or products you have requested, or to provide our Websites and services in a manner consistent with our terms and conditions and any other contract that you have with us.
• We process personal data, including identifiers, for the purpose of verifying your identity because such processing is necessary for us to comply with a legal or regulatory obligation.
• We process personal data for the purposes of customization of advertising, marketing, and analytics for our legitimate interests.
• We process personal data for functionality and security because it is necessary for our legitimate interests, and in certain cases because the processing is necessary for us to comply with a legal or regulatory obligation.
• We process personal information in specific circumstances where you have provided your consent to such processing.

Purposes for Which We Use Your Personal Information

In general, we use information that we collect about you or that you provide to us, including Personal Information and Sensitive Personal Information, for following purposes:

• Provision of services (Registered Users only): to present our Website and its contents to you, including any interactive features on our Website, and to provide you with information, products or services that you request from us; we also collect and use Personal Information to verify your eligibility and deliver prizes in connection with contests and sweepstakes;
• Customer management (Registered Users only): to manage a registered users’ account, to provide customer support and notices to the registered user about his account or subscription, including expiration and renewal notices, and notices about changes to our Website or any products or services we offer or provide through it;
• Customization of content (Registered Users only): to perform research and analysis about your use of, or interest in, our Website content, products, or services, in order to develop and display content and advertising tailored to your interests on our Website and other sites;
• Analytics: to determine whether users of the Website are unique, or whether the same user is using the Website on multiple occasions, and to monitor aggregate metrics such as total number of visitors, pages viewed, demographic patterns;
• Functionality and security: to diagnose or fix technology problems, and to detect, prevent, and respond to actual or potential fraud, illegal activities, or intellectual property infringement;
• Compliance: to enforce our terms and conditions and to comply with our legal obligations;
• in any other way we may describe when you provide the information; or for any other purpose with your consent provided separately from this privacy policy.

Disclosure of Your Personal Information

We do not disclose your Personal Information except in the limited circumstances described here.

• We may disclose your Personal Information to members of our corporate group (that is, entities that control, are controlled by, or are under common control with us) to the extent this is necessary for the purposes of provision of services, customer management, customization of content, advertising, analytics, verifications, functionality and security, and compliance.
• Service providers. To our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, processing credit card payments, risk and fraud detection and mitigation, providing customer service, performing business and sales analysis, customization of content, analytics, security, supporting our Website functionality, surveys and other features offered through our Website. These service providers may have access to Personal Information needed to perform their functions but are not permitted to share or use such information for any other purposes.
• Legal successors. To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about our Website users is among the assets transferred. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal information uses it in a manner that is consistent with this privacy policy.
• To comply with the law or protect our rights or the rights of third parties: We access, preserve and share all of the categories of personal information with regulators, law enforcement or others where we reasonably believe such disclosure is needed to (a) satisfy any applicable law, regulation, legal process, or governmental request, (b) enforce applicable terms of use, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address illegal or suspected illegal activities, security or technical issues, (d) protect against harm to the rights, property or safety of our company, our users, our employees, or others; or (e) to maintain and protect the security and integrity of our Websites or infrastructure. In such cases, we may raise or waive any legal objection or right available to us, in our sole discretion.

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We also may share aggregated information with third parties for conducting general business analysis. This information does not contain any Personal Information and may be used to develop content and services that we hope you and other users will find of interest.

Financial Information

Financial information (including Personal Information) that you have provided to us will only be shared with our third-party processors to initiate and complete any orders placed on your account. All credit card transactions and such are processed with industry standard encryption through third party processors who only use your financial information and Personal Information for that purpose. All financial data and related Personal Information will not be shared by us with third parties except with your authorization or when necessary to carry out all and any transactions requested by you with the understanding that such transactions may be subject to rules, terms, conditions, and policies of a third party. All such information provided to a third party is subject to their terms and conditions.

How We Protect the Security of Your Personal Information

We take appropriate security measures (including physical, electronic, and procedural measures) to safeguard your Personal Information from unauthorized access and disclosure. For example, only authorized employees are permitted to access Personal Information, and they may do so only for permitted business functions. In addition, we use encryption in the transmission of your Personal Information between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your Personal Information. Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of Personal Data.

You are responsible for always maintaining the secrecy of your unique password and account information. We are not responsible for circumventions of any privacy settings or security measures contained on the Website.

Cookies and Automatic Data Collection Technologies

As you navigate through and interact with our Website, we use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including information such as your internet protocol (IP) address, browser type, operating system, the referring web page, pages visited, location, your mobile carrier, device information, search terms, and cookie information.

We use cookies, which are small text files that are stored in your web browser or downloaded to your device when you visit a website. We currently use the following types of cookies, which are set by the Websites’ domains, or by other domains we own or control:

• Strictly necessary cookies: These are cookies that are required for the operation of our Website. These include, for example, cookies that enable a user to log in to our Website and to check if a user is allowed access to a particular service or content.
• Functionality cookies: These cookies are not essential, but help us to personalize and enhance your online experience on our Website. This type of cookies allows us to recognize you when you return to our Website and to remember, for example, your choice of language.
• Analytical cookies: These cookies allow us to recognize and count the number of users and to see how users use and explore our Website. These cookies help us to improve our Website, for example by ensuring that all users are able to find what they are looking for easily.
• Targeting cookies: These cookies record the visit of a user on our Website, the pages a user has visited and the links a user has followed in order to enable us to make our Website more relevant to the users' interests.

Analytics, Functionality and Targeting cookies can be switched off at any time by accessing the ‘Manage cookies’ option that is located at the footer of our website. However, if you decline to accept these cookies, some functionality on our Websites may be disabled and can interrupt your access to certain parts of our Website.

Cookies can be either session cookies or persistent cookies. A session cookie expires automatically when you close your browser. A persistent cookie will remain until it expires, or you delete your cookies. Expiration dates are set in the cookies themselves; some may expire after a few minutes while others may expire after multiple years.

• Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also known as clear gifs, pixel tags, single-pixel gifs and web bugs) that are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users or to access cookies.
• Do Not Track: Our systems do not recognize browser “Do Not Track” signals.
• Use of Google Analytics. We use Google as a service provider to collect and analyze information about how users use the Websites, including, by collecting website activity data through first-party cookies set by our domains, and third-party cookies set by Google. Because we activated IP anonymization for Google Analytics, Google will anonymize the last octet of a particular IP address and will not store your full IP address. Google will use the information only for the purpose of providing Google Analytics services to us and will not use this information for any other purposes. The information collected by Google Analytics may be transmitted to and stored by Google on servers in the United States pursuant to standard contractual clauses approved by the EU. You can learn more on how Google uses data here, and you can opt-out of Google Analytics by visiting the Google Analytics opt-out page or by accepting only necessary cookies.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third parties, including advertisers, ad networks and servers, content providers and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. Unless expressly stated otherwise, our website does not provide any Personal Information to these third parties, however they may collect information, including Personal Information, such as IP address, browser type and version, time zone setting and location, operating system and platform and other technology on the devices you use to access this Website. They may use this information to provide you with interest-based advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Choices About How We Collect, Use, and Disclose Your Personal Information

We strive to provide you with choices regarding the Personal Information you provide to us.

• You can choose not to provide us with certain Personal Information, but that may result in you being unable to use certain features of our Website because such information may be required in order for you to register as a user/member; purchase products or services; participate in a contest, promotion, survey, or sweepstakes; ask a question; or initiate other transactions on our Website.
• The cookie banner can be utilized to customize your cookie preferences. The cookie banner will record when you have consented to our cookies. For Registered Users, we will ask for consent once a year or when we have major changes to our cookies, to ensure you stay up to date with changes to our cookie and privacy policies. For Unregistered Users, your cookie banner selection will be kept only for the specific session. The cookie banner specifically controls the Functionality, Analytics, and Targeting cookies set by using our website. Strictly necessary cookies cannot be disabled, nor can the tool be used to block cookies on third party websites linked from our website.

You can access the cookie banner anytime by clicking on the ‘Manage cookies’ option that is located at the footer of our website.

• You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Website may then be inaccessible or not function properly.
• You can opt out of receiving marketing emails from us using the opt-out link provided in our emails or by changing your preferences in your account settings. If you are a Registered User, we may continue to send you other types of important emails e.g., e-mails about your transactions, account, or orders.
• You may use your account settings to delete your user contributions and audio/video information.
• You may also delete and deactivate your account with us at any time unless required not to do so by law or by a court order. If you do so, your profile will no longer be accessible by you. If you later choose to have an account with us, you will have to sign up for a new account as none of the information you previously provided or saved within your account will have been saved.

Your Rights Related to Your Personal Information

Subject to local law, you have certain rights regarding the Personal Information we collect, use, or disclose and that is related to you, including the right:

• to receive information on the Personal Information concerning we hold about you and how such Personal Information is used (right to access);
• to rectify inaccurate Personal Information concerning you (right to data rectification);
• to delete/erase your Personal Information (right to erasure/deletion, “right to be forgotten”);
• to receive the Personal Information provided by you in a structured, commonly used and machine-readable format and to transmit those Personal Information to another data controller (right to data portability);
• to object to the use of your Personal Information where such use is based on our legitimate interests or on public interests (right to object);
• in some cases, to restrict our use of your Personal Information (right to restriction of processing); and
• to withdraw your consent at any time where our processing is based on consent (right to withdrawal of consent).

You may exercise your right to access and deletion using the buttons at the bottom of this page. Additionally, you may, at any time, send us an e-mail at support@modelhub.com to exercise your above rights in accordance with the applicable legal requirements and limitations. If you are located in the European Economic Area, you have a right to lodge a complaint with your local data protection authority.

Please note that unless you have created an account with us, we may not have sufficient information to identify you and therefore may not be in a position to respond to your request. Additionally, in some cases to adequately verify your identity or your authorization to make the request, we may require you to provide additional information.

Note that some requests to delete certain personal information will require the deletion of your user account as the provision of user accounts are inextricably linked to the processing of certain personal information (e.g., your e-mail address).

California Rights and Choices

The California Consumer Privacy Act (“CCPA”) provides you certain rights in relation to your personal information:

• Right to Know: You have the right to request that we disclose certain information about our processing of your personal information over the past 12 months, including the specific pieces of information we processed.
• Right to Request Deletion: You have the right to request that we delete any of your personal information we processed from you and retained, subject to certain exceptions set forth in the CCPA.
• Right to Non-Discrimination for the Exercise of Your Rights: We will not discriminate against you because you have exercised any of your rights under the CCPA.

To exercise the rights described above, please use the buttons at the bottom of this page or email us at support@modelhub.com with the email subject line “CCPA Request.” In either case you will need to provide the following information to verify your identity and enable us to locate your information in our systems: your username and email address that you used to create an account with us, as well as any other information which we may reasonably request in order for us to verify your identity. We may require you verify that you have access to your account and/or email account that you used to register with us.

You can designate an agent to make a request by executing a notarized power of attorney to have that person act on your behalf and providing that person with the information listed above that allows us to verify your identity and locate your information. Alternatively, you will need to directly confirm your identity with us using the methods described above, sign an authorization for the agent to act on your behalf and provide us with confirmation that you have done so.

We disclose certain categories of California residents’ personal information for our business purposes, as described in the section above titled Disclosure of Your Personal Information.

Notice to Law Enforcement

The following information serves as a guideline for law enforcement officials seeking disclosure of records. You may serve us a valid court order, subpoena, search warrantor equivalent legal or official administrative document by respecting the following conditions:

• The document(s) is uploaded, and all required fields have been filed out adequately on our platform for legal service process located at: https://legalservice.aylo.com/legal/datarequest
• The document(s) you are serving is correctly issued by a valid court of law or equivalent legal or administrative authority to our operating entity. (See footer to find our operating entity);
• The document(s) is also sent by mail at the following address: 195-197 Old Nicosia-Limassol Road, Block 1 Dali Industrial Zone, Cyprus 2540.

We reserve the right to refuse online service through our Website, namely in cases where the above requirements are not met and require formal legal service at the above address. In such event, you will be notified. We may raise or waive any legal objection or right available, in our sole discretion.

TRANSFERS OF YOUR PERSONAL INFORMATION TO OTHER COUNTRIES

Where the laws of your country allow you to do so, by using the Websites you consent to the transfer of information that we process about you, including personal information, to other countries in which we, members of our corporate group (including affiliates and related entities) or our service providers are located. When we transfer personal information to countries outside of the European Economic Area (“EEA”) or other regions with comprehensive data protection laws, we will ensure that the information is transferred in accordance with the applicable laws. Where relevant, our transfers outside the EEA are made pursuant to standard contractual clauses approved for use by the European Union.

Retention of Personal Information

We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 unauthorized 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 requirements.

Where we no longer need to process your Personal Information for the purposes set out in this Privacy Policy, we will delete your Personal Information from our systems.

Where permissible, we will also delete your Personal Information upon your request. Information on how to make a deletion request can be found under “Your Rights Related to Your Personal Information”.

If you have questions about our data retention practices, please send us an e-mail at support@modelhub.com.

The period for which we keep your Personal Information that is necessary for compliance and legal enforcement purposes varies and depend on the nature of our legal obligations and claims in the individual case.

Third-Party Links and Sites

If you click on a link to a third-party site, you will be taken to websites we do not control. This Privacy Policy does not apply to the privacy practices of these websites. Read the privacy policy of other websites carefully. We are not responsible for these third-party practices.

Changes To Our Privacy Policy

We may modify or revise our privacy policy from time to time. Although we may attempt to notify you when major changes are made to this privacy policy, you are expected to periodically review the most up-to-date version found at http://www.modelhub.com/information/privacy so you are aware of any changes, as they are binding on you.

If we change anything in our privacy policy, the date of change will be reflected in the “last modified date”. You agree that you will periodically review this privacy policy and refresh the page when doing so. You agree to note the date of the last revision to our privacy policy. If the “last modified” date is unchanged from the last time you reviewed our privacy policy, then it is unchanged.

No Error Free Performance

We do not guarantee error-free performance under this privacy policy. We will use reasonable efforts to comply with this privacy policy and will take prompt corrective action when we learn of any failure to comply with our privacy policy. We shall not be liable for any incidental, consequential, or punitive damages relating to this privacy policy.

Contact Information

If you have any questions about this privacy policy or our information-handling practices, please contact us at support@modelhub.com

You may also contact us at 195-197 Old Nicosia-Limassol Road, Block 1 Dali Industrial Zone, Cyprus 2540, Phone: +357 22662 320, Fax: +357 22343 282.