Privacy Policy – ModelLand

Privacy Policy

MODELLAND

PRIVACY POLICY

 

Revised February 21, 2020

 

I. INTRODUCTION 

 

This Privacy Policy (“Privacy Policy”) describes the information that Modelland Holdings LLC and its affiliates and subsidiaries (“Modelland,” “we,” “us,” “our”) collect, process, and share your Personal Information (defined below).  This Privacy Policy describes your rights and choices with respect to your Personal Information and other important information.  Please read this Privacy Policy carefully.

 

II. SCOPE OF THIS POLICY

 

This Privacy Policy applies to your use of our “Services,” which include the following:

 

  • Our “Offline Services”
    • o Offline services you use when you visit our experiential attraction in Santa Monica, California now known as “Modelland” (“Attraction”).
    • Our “Digital Services”
    • o Our products, services, and technology in the Attraction; and
    • o Our website (at www.model-land.com), mobile application, and other online services, including data collected when you interact with or reference our products/services or advertisements online, as well as via social media (e.g., when we correspond with you via social media, when we access information provided by social media platforms in relation to our pages on those platforms, or if you reference or interact with us on social media).

 

Note that certain third parties may be able to identify you across sites and services using the information they process, however, any such processing not done at our direction is outside the scope of this Privacy Policy.

 

III. CATEGORIES/SOURCES OF PERSONAL INFORMATION    

 

The following describes how we process data relating to identified or identifiable individuals and households (“Personal Information”), including the categories of Personal Information, its sources, and the purposes for which we process that Personal Information.

 

A. The Categories Of Personal Information We Process

The categories of Personal Information we collect and use include (specific data are examples, and may change):

 

    • Identity Data:
    • o Information, such as your name, physical address, e-mail address, phone/mobile number(s), gender, date of birth, age and/or age range, account login details, e.g. username and password, or other account-related information; information you provide in connection with your application to be a vendor, volunteer, or employee; your identity, public profile and simile information from social networks such as Facebook; and information such as unique IDs and similar data collected or derived from the use of tickets or RFID enabled products such as wristbands.
    • Contact Data:
    • o Identity Data that relates to information about how we can communicate with you, such as email and physical addresses, social media handles, and information you provide to us when you contact us by email or when you communicate with us via social media.
    • Financial Data:
    • o Information such as bank account details, payment card information, and information from credit reference agencies, including similar data defined in Cal Civ Code § 1798.80(e), if you make a purchase from us.
    • Location Data:
    • o Information about your location, including precise location data from GPS, wi-fi-triangulation and similar, and general location data from social media tags/posts, dates and times of your visit and which parts of the Attraction you visit, e.g. entrance location, entrance time, dwell time within the Attraction at the various exhibits, exit time, exit location, etc. relating to the use of an RFID enabled wristband at the Attraction.
    • Device/Network Data:
    • o Browsing history, search history, and information regarding your interaction with a website, application, or advertisement (e.g. IP Address, MAC Address, SSIDs or other device identifiers or persistent identifiers), online user ID, device characteristics (such as browser/OS version), web server logs, application logs, browsing data, first party cookies, third party cookies, web beacons, clear gifs and pixel tags.
    • Commercial Data:
    • o Information about the Services we provide to you and about transactions you make with us including at the Attraction (including for example, information about purchases, what has been provided to you, when and where and, if applicable, how much you paid) and similar information.
    • Inference Data:
    • o Personal Information used to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes, market segments, likes, favorites and other data or analytics provided about you or your account by social media companies or data aggregators, including household data such as income, number of children, occupation, social grade, home ownership status, the products and services you use or intend to use or purchase, and your interests.
    • Audio/Visual Data
    • o Recordings and images collected from our surveillance and other cameras when you visit the Attraction and areas adjacent to them, as well as audio files and records, such as voice mails, call recordings, and the like.
    • Biometric Data
    • o Images from facial recognition systems operated at the Attraction (if any).
    • Health Data:
    • o Information about your health (for example when you request accommodations or when we are responding to an accident which may have happened at the Attraction).
    • Biographical Data:
    • o Data relating to professional and employment history, qualifications, and similar biographic information.
    • Government ID Data:
    • o Data relating to official government identification, such as driver’s license or passport numbers, social security numbers, etc., including similar Identity Data included in Cal Civ Code §1798.80(e).
    • User Content:
    • o Unstructured/free-form data that may include any category of Personal Information, e.g. data that you give us in free text fields such as comment boxes, answers you provide when you participate in sweepstakes, contests, votes and surveys, including any other Personal Information which you may provide through or in connection with our Services.
    • Protected Category Data:
    • o Characteristics of protected classifications under California or federal law, e.g. race, national origin, religion, gender, or sexual orientation.
    • Special Category Data:
    • o Personal Information subject to GDPR and similar laws revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

 

B. Sources of Personal Information

We collect Personal Information from various sources, which vary depending on the context in which we process that Personal Information:

    • Data you provide us: We will receive your Personal Information when you provide it to us, purchase our products or services, or complete a transaction via our Services, or when you otherwise use our Services.
    • Data we collect automatically: We collect Personal Information about or generated by any device you have used to access our Services, the website, or mobile application, the website of any ticketing service provider used to purchase a ticket to the Attraction, or when you use WiFi at our Attraction (if available). 
    • Data we receive from third parties:  We receive Personal Information from third parties, for example, our ticket agent, business partners, service providers, aggregators, advertisers, social media companies or similar companies.
    • Data we create or infer:  We, certain partners, social media companies, and third parties operating on our behalf, create and infer Personal Information such as Inference Data or Aggregate Data based on our observations or analysis of other Personal Information processed under this Privacy Policy, and we may correlate this data with other data we process about you. We may combine any Personal Information about you that we receive from you, and from third parties.

 

IV. HOW WE PROCESS PERSONAL INFORMATION

 

When we use our Services, we process your Personal Information in specific contexts and for certain specified purposes, as well as for our general business purposes and, in some cases, for commercial purposes.

 

A. How We Collect Your Personal Information

We collect and process Personal Information in several contexts when you use our Services, including:

    • When you make a purchase or other transaction through our Services
    • When you visit our Attraction
    • Closed Circuit Television (CCTV)
    • When you access or use our Digital Services
    • Cookies and other tracking technologies
    • When you enter a contest or other promotion
    • When you contact us or submit information to us
    • Feedback and Surveys
    • Applications for employment or to provide services

 

See below for more information regarding the context in which we process Personal Information.

 

1. When You Make A Purchase Or Other Transaction Through Our Service

We generally process Identity Data, Contact Data, Financial Data, and Commercial Data when you engage in a purchase and sale transaction. We process this Personal Information as necessary to perform or initiate a contract with you, process your order and payment, and carry out fulfillment and delivery. In addition, we may also collect or create Device/Network Data and Inference Data. This data, together with other data we collect in this context is used as necessary in connection with certain legitimate business interests, such as:

 

    • ensuring the security of our Services and to prevent fraud;
    • providing you with information about our Services, to contact you about administrative matters, to manage and respond to any queries or complaints you make or any correspondence you send us.

 

2. When You Visit Our Attraction

We generally process Identity Data and Contact Data when you interact with us Offline at our Attraction. Additionally, when you use electronic or RFID ticketing technologies, or use in-venue Digital Services, we will collect Identity Data, Contact Data, Device/Network Data, Commercial Data, Financial Data, Audio/Visual Data, Location Data, and create Inference Data from the foregoing (see below for additional information regarding our Digital Services). If you use biometric identification technologies, we collect and use Biometric Data as necessary to allow you to participate in interactive features of the Attraction.

We may process this data as necessary in connection with certain legitimate business interests in:

● verifying your identity for authentication and security purposes;

● helping us to ensure our customers are genuine and to prevent fraud;

● performing a contract with you, and carrying out fulfillment and delivery;

● allowing you to participate in interactive features of the Attraction;

● allowing you to make a purchase or other transaction at the Attraction;

● providing you with a copy of your “look-book” photographs taken at the Attraction;

● managing access to specific areas of the Attraction;

● creating aggregate data; and

● other legitimate business interests.

 

Note, in certain cases, we may collect Health Data. Health Data is generally used so that we can provide you with tailored services (for example, regarding specific accommodations needed) or to help us investigate an incident which may have taken place at our Attraction. In each case, where consent is required by law, we will process this information only with appropriate consent.

 

3. CCTV

We may operate CCTV or security cameras on and adjacent to our Attraction. In connection with these systems, we collect and/or create Audio/Visual Data in connection with certain legitimate business interests, such as:

● preventing and detecting crime and to keep people who visit and work at our Attraction safe and secure;

● recording and investigating health and safety and other incidents which have happened or may have happened at our Attraction;

● counting the numbers of people who visit our Attraction and to analyze flows of people around the Attraction for safety and commercial purposes using software which analyzes CCTV camera images;

● creating aggregate data; and

● other legitimate business interests.

 

4. When You Access or Use our Digital Services

When you use our online or in-venue Digital Services, we automatically collect and process Device/Network Data. We use this data as necessary to initiate or fulfill your requests for certain features or functions through our Services, such as keeping you logged in, delivering pages, etc.

 

In addition to Device/Network Data, we will also collect and process Identity Data, Contact Data, and Inference Data that we collect, create, and/or receive (including through the use of cookies and similar technologies). We typically use this data as necessary in connection with certain legitimate business interests, such as:

● ensuring the security of our website, mobile application and other technology systems; and

● analyzing the use of our Services, including navigation patterns, clicks, etc. to help understand and make improvements to the Services.

 

Some Digital Services may, with your consent, process Location Data. We use this data, together with Inference Data, and Device/Network Data in order to determine your proximity to portions of our Attraction, provide directions and contextual information to you, and other features that require the use of location. We may also use this information in connection with our legitimate business interests, such as, creating aggregate information about users’ location and patterns, which we use to help improve our Attraction and other Services. Note, Location Data may be required in order for you to use certain Features of our Digital Services.

 

We may also process Identity Data, Contact Data, and User Content if you interact with or identify us, or relevant promoters, sponsors or other partners on social media platforms. Additionally, Personal Information processed when you submit information to us or complete a purchase or transaction (among others) will involve processing through Digital Services.

 

5. Cookies and Other Tracking Technologies

We use cookies and similar technologies on our Digital Services. You can find more information about cookies at www.allaboutcookies.org and www.youronlinechoices.eu. These technologies can be used to collect or create Identity Data, Device/Network Data, Contact Data, or Inference Data. Third parties may be allowed to view, edit, or set their own cookies or place web beacons on our websites. Cookies and web beacons allow us and third parties to distinguish you from other users of our website, and some of these technologies can be used by us and/or our third party partners to identify you across platforms, devices, sites, and services. Third parties may engage in targeted advertising using this data.

 

We and authorized third parties may use cookies and similar technologies for the following purposes:

    • for “essential” or “functional” purposes, such as to enable certain features of our Digital Services (for example, to allow a customer to maintain a basket when they are shopping at an online store);
    • for “analytics” purposes, such as to analyze the traffic to and on our Digital Services (for example, we can count how many people have looked at a specific page, or see how visitors move around the website when they use it, what website they visited prior to visiting our website, and use this information to understand user behaviors and improve the design and functionality of the website); and
    • for “retargeting” or similar advertising or commercial purposes, such as:
    • o for social media integration e.g. via third-party social media cookies, or when you share information using a social media sharing button or “like” button on our Services or you link your account or engage with our content on or through a social networking website such as Facebook or Twitter; and
    • o to collect information about your preferences and demographics to help target advertisements which are more likely to be of interest to you using behavioral advertising;
    • o to allow us to carry out retargeting (this includes, for example, when advertisements are presented to you for products or services which you have previously looked at on a website but have not purchased).

 

6. When You Enter A Contest Or Other Promotion

We collect and process Identity Data, Contact Data, and User Content as necessary to process your request to enter the contest, or take part in a promotion, notify you if you have won or to process delivery of a prize or for other related purposes.

 

In addition, we may process this information in connection with our legitimate business interests, such as:

● verifying your identity for authentication and security purposes (in which case we may process Government ID Data to complete verification); and

● helping us to ensure our customers are genuine and to prevent fraud.

 

Note, if you win a contest/sweepstakes, we may publicly post some of your data on our website or mobile application (for example acceptance of a prize may also require you to allow us to post publicly some of your Personal Information such as on a winners’ page). Where required by law, your information will not be posted without your consent.

 

7. When You Contact Us Or Submit Information To Us

We collect and process Identity Data, Contact Data, and User Content as necessary to address your request, fulfill the business purpose for which that information was provided, or for other related purposes. This information is primarily used to respond to your request, and to otherwise fulfill our contract or communicate with you, as appropriate.

 

Additionally where you consent or if otherwise permitted by law, we may send you marketing communications as described further below, and use this information for Commercial Purposes.

 

8. Feedback and Surveys

We generally process Identity Data, Contact Data, Inference Data, and User Content collected in connection with guest surveys or questionnaires. We generally process this Personal Information as necessary to respond to guest requests/concerns, create aggregate analytics regarding guest satisfaction, or to allow our third-party partners to communicate with guests.  Feedback/Survey data may be made available to certain third-party partners, who may use it for their own purposes. We may also store and analyze feedback for our purposes, for example, to personalize the Services, and help recommend relevant offers or services.

 

9. Employment and Service Provider Application

We may process Identity Data, Contact Data, Government ID Data, Protected Category Data, Biographical Data, Inference Data, User Content, Financial Data, and Health Data (which may include Special Category Data) in connection with your application to be a vendor, volunteer, employee, or otherwise join or support our team. We process this Personal Information primarily in connection with the assessment and creation of the personnel relationship, and to the extent permitted by applicable law, or with your consent or where authorized by law, and subject to your rights and choices, we may process Personal Information in accordance with our legitimate business interests, as follows:

● We may use your Contact Data as necessary to process your application, contact you regarding this or other future application/vendor/work opportunities, or similar matters.

● The assessment of your application may involve the creation and processing of Inference Data based on your Identity Data, Contact Data, Biographical Data, and User Content in order to evaluate your prospective engagement, assess skills alignment, qualifications, and similar matters. Inference Data does not include Special Category Data, Health Data, or Special Category Data.

● To the extent permitted under applicable law, the processing of your Personal Information in connection with application evaluation may involve the use of automated decision-making that may extract relevant information and rate applications based on their conformity with requirements. In some cases, automated processing may reject or place a low rating on applications that are found to not meet requirements of a given engagement.

 

B. How We Process Personal Information For Business Purposes

We and our Service Providers process Personal Information we hold for numerous business purposes, depending on the context of collection, your rights and choices, and our legitimate business interests. For example, we generally process Personal Information:

● In connection with providing and personalizing our Services, supporting and personalizing your visit to the Attraction, and fulfilling our contractual obligations to you

● To maintain the quality and stability of, and generally improve, our Services and Attraction

● To secure our Attraction and Services, and prevent fraud

● To personalize the Services and Attraction, and in connection with marketing and advertising, including behavioral advertising

● To compile aggregate statistics regarding the use of the Services, and the visits to our Attraction, and for research and market analysis

● To comply with the law, and for other purposes in the public interest

 

1. Service Provision and Contractual Obligations

We process any Personal Information as is necessary to provide our Services, to provide you with the products and services you purchase or request, authenticate users and their rights to access the Services, as otherwise necessary to fulfill our contractual obligations to you, and provide you with the information, features, and services you request. Additionally, we use information to authenticate your right to access the Attraction, deliver products and services, and for other related matters. Similarly, we may use Personal Information as necessary to audit compliance, and log or measure aspects of service delivery (e.g. to document ad impressions).

 

2. Internal Processing and Service Improvement

We may use any Personal Information we process through our Services as necessary in connection with our legitimate business interests in improving the design of our Services and Attraction, understanding how are Services and the Attraction are used or function, for customer service purposes, in connection with logs and metadata relating to service use, and for debugging and similar purposes relating our identification of errors and improving the stability of the Service. Additionally, we may use Personal Information to understand what parts of our Services and Attraction are most relevant to users, how users interact with various aspects of our Services and Attraction, and how our Services and Attraction perform.

 

3. Security and Incident Detection

Whether online or off, we work to ensure that our Services are secure. We may process any Personal Information we collect in connection with our legitimate business interest in ensuring that the Attraction is secure, identify and prevent crime, prevent fraud, and ensure the safety of our guests. Similarly, we process Personal Information on our Digital Services as necessary to detect security incidents, protect against, and respond to malicious, deceptive, fraudulent, or illegal activity. We may analyze network traffic, device patterns and characteristics, maintain and analyze logs and process similar Personal Information in connection with our information security activities.

 

4. Compliance, Health, Safety, Public Interest

We may also process any Personal Information as necessary to comply with our legal obligations, such as where you exercise your rights under data protection law and make requests, for the establishment and defense of legal claims, or where we must comply with our legal obligations, lawful requests from government or law enforcement officials, and as may be required to meet national security or law enforcement requirements or prevent illegal activity. We may also process data to protect the vital interests of individuals, or on certain public interest grounds, each to the extent allowed under applicable law. Please see the data sharing section for more information about how we disclose Personal Information in extraordinary circumstances.

 

5. Aggregated Data

We process Personal Information about our customers and users in order to identify trends (to create aggregated and anonymized data about our customers/users, buying and spending habits, use of our Services and Attraction, and other similar information (“Aggregated Data”). We may pass Aggregated Data to the third parties referred to in the section below to give them a better understanding of our business and to bring you a better service. Aggregated Data will not contain information from which you may be personally identified.

 

6. Personalization

We process certain Personal Information as necessary in connection with our legitimate business interest in personalizing our Digital Services. For example, aspects of the Digital Services may be customized to you so that it displays your name and other appearance or display preferences, to display content that you have interacted with in the past, or to display content that we think may be of interest to you based on your interactions with our Digital Services and other content. This processing may involve the creation and use of Inference Data relating to your preferences.

 

7. Other Business Purposes

If we process Personal Information in connection with our Services in a way not described in this Privacy Policy, this Privacy Policy will still apply generally (e.g. with respect to your rights and choices) unless otherwise stated at collection. We will process such information in accordance with the notice provided at the time of collection or in a manner that is necessary and proportionate to achieve the operational purpose for which the personal information was collected or processed or for another operational purpose that is compatible with the context in which the personal information was collected.

 

C. How We Process Personal Data For Commercial Purposes

We and certain third parties process Personal Information we hold for certain purposes, depending on the context of collection and your rights and choices:

● Marketing communications

● In connection with online advertising, including interest-based advertising, and analytics

● Data sales

 

1. Marketing Communications

Consistent with our legitimate business interests, we (or if appropriate, certain third-parties) may send you marketing and promotional communications if you sign up for such communications or purchase products or services from us. For example, we may process Contact Data and Identity Data when you opt-in to receive marketing communications via email or SMS. Where allowed, we may also send you these communications without opt-in, for example, you may receive email marketing communications if you register for our Services or for a promotion, or in connection with your communications with or submission of User Content to us. Similarly, we may also collect Device/Network Data and Contact Data so that we can determine whether you have opened an email or otherwise interacted with our communications, and we may generate Inference Data based on these interactions.

 

2. Digital Advertising & Analytics

We may partner with third-party ad networks and other ad serving providers (“Advertising Providers”) that serve ads on our behalf and others’ on non-affiliated platforms.  Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information Advertising Providers collect about your use of the Digital Services and other sites or apps over time, including information about relationships among different browsers and devices.  This type of advertising is known as interest-based advertising.

 

Modelland adheres to the Digital Advertising Alliance (“DAA”) Self-Regulatory Principles in connection with this interest-based advertising activity.  You can visit www.aboutads.info or www.youradchoices.com/AppChoices to learn more about interest-based advertising and how to opt out of this advertising by companies participating in the DAA self-regulatory program.  If you delete your cookies, reset your device advertising identifier, or use a different browser or mobile device, you will need to renew your opt-out choice.  You may also be able to limit data collection for advertising purposes using tools available on your device. Note that electing to opt out will not stop advertising from appearing in your browser.  It may make the ads you see less relevant to your interests.  Even if you opt out, Advertising Providers may continue to collect data for other purposes, including analytics and other operational purposes.

 

We may also work with third parties that collect data about your use of the Digital Services and other sites or apps over time for non-advertising purposes.  Modelland uses Google Analytics and other third-party services to improve the performance of the Digital Services and the services provided at the Attraction and for analytics and marketing purposes.  For more information about how Google Analytics collects and uses data when you use our Digital Services, visit www.google.com/policies/privacy/partners/, and to opt out of Google Analytics, visit tools.google.com/dlpage/gaoptout/.

 

3. Data Sales

We may “sell” certain Personal Information when we engage in marketing campaigns with or on behalf of sponsors, conduct interest-based advertising, or sell or grant access to Personal Information to other advertisers.

 

V. HOW WE SHARE PERSONAL INFORMATION    

 

We may share your Personal Information with selected third parties including:

    • business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you in order to provide you with a product or service;
    • with business partners, suppliers and sub-contractors to provide you with direct marketing information about promotions and offers, where permitted;
    • non-personal, aggregated, anonymized or other data to advertisers, advertising networks and social networks that require the data to select and serve relevant adverts to you and others. We also use aggregated information to help advertisers reach the kind of audience they want to target;
    • analytics and search engine providers that assist us in the improvement and optimization of the Digital Services;
    • in the event that we sell or buy any business or assets, we will disclose your personal information to the prospective seller or buyer of such business or assets or transfer personal information held where it is one of the transferred assets;
    • we will share your Personal Information if we are under a duty to disclose or share your data in order to comply with any legal obligation;
    • in the event of an emergency;
    • in order to enforce or apply our Terms of Use and other agreements, or to protect our rights, property, or safety, our customers, clients or individuals; or
    • if you consent to allow us to share your information.

 

We will share information that has been de-identified or aggregated without limitation.

 

VI. HOW WE RETAIN YOUR PERSONAL INFORMATION

 

We will retain your Personal Information for as long as it, in our discretion, remains relevant to its purpose, and in any event, for so long as is required by law.  This period may be different if required by law, or if we need to retain data in order to respond to claims, to protect our rights or the rights of a third party.  We will review retention periods periodically and may sometimes pseudonymize or anonymize data held for longer periods, if appropriate.

 

VII. HOW WE PROTECT YOUR PERSONAL INFORMATION

 

We use industry standard technical and organizational security measures to protect your Personal Information. We cannot guarantee the security of your Personal Information when you transmit it to us, and any such transmission is at your own risk.

 

Where we have given you (or where you have chosen) a password which enables you to access one of our Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

 

VIII.  MINORS

 

Our Services are neither directed at nor intended for use by children under the age of 13 in the US depending on the local jurisdiction. We generally collect information relating to minors only from parents or with parental consent and do not knowingly collect Personal Information from such minors directly. If we learn that we have inadvertently done so, we will promptly delete such Personal Information if required by law. Do not access or use the Services if you are not of the age of majority in your jurisdiction unless you have the consent of your parent or guardian.

 

IX.  CHANGES TO OUR PRIVACY POLICY

 

We reserve the right to change our Privacy Policy from time to time. Any such changes will be posted on this page so that we can keep you informed about how we process your Personal Information. We recommend that you consult this page frequently. Your continued use of our Services shall constitute your acceptance of any revised Privacy Policy.

 

X. Your EU and Other Privacy Rights

 

This section applies to those that visit or use our Services from the European Economic Area, Switzerland, or the UK.

 

Modelland processes Personal Information with your consent (e.g., when Modelland processes Personal Information to provide goods and services and fulfill requests).

 

On other occasions, Modelland may process Personal Information when it needs to do this to fulfill a contract (e.g., to process your registration for our Services) or where required to do this by law.

 

If necessary, Modelland may also process Personal Information when it is in Modelland’s legitimate interests to do this (e.g., for customer service, product development, network security, and appropriate types of marketing) and when these interests are not overridden by your data protection rights.

 

Please be aware that the Personal Information we collect may be transferred to and maintained on servers or databases located in the United States or elsewhere outside your state, province, country, or other jurisdiction, where the privacy laws may not be as protective as those in your location. 

 

You have a right to the following:

    • To request access to the Personal Information we hold about you;
    • To request that we rectify or erase your Personal Information;
    • To request that we restrict or block the processing of your Personal Information;
    • Under certain circumstances, to receive Personal Information about you that we store and transmit to another without hindrance from us, including requesting that we provide your personal information directly to another, i.e., a right to data portability; and
    • Where we previously obtained your consent, to withdraw consent to processing your Personal Information.

 

To exercise these rights, contact us using the “Contact” section below.  Please be aware that Modelland may be unable to afford these rights to you under certain circumstances, such as if we are legally prevented from doing so.

 

Additionally, you have the right to lodge a complaint against us.  If you are not satisfied with our response to your inquiry or complaint, you can contact the supervisory authority in your country of residence.

 

XI. Your California Privacy Rights

 

This section contains disclosures required by the California Consumer Privacy Act (“CCPA”) and applies only to “personal information” that is subject to the CCPA.

 

A. Personal Information We Collect, Disclose for a Business Purpose, and Sell

 

We collect the categories of Personal Information about California consumers identified in the chart below.  As further set forth in the chart below, in the past 12 months, we have disclosed (but not sold) California consumers’ Personal Information to third parties for business or commercial purposes.   

 

Category of Personal Information

Collected in last 12 months

Category of Sources

Business or commercial purposes for collection, use, and sharing

Disclosed for business purposes to the following categories of third parties:

Audio/Visual Data

No

 

 

 

Biometric Data

No

 

 

 

Commercial Data

No

 

 

 

Contact Data

Yes

All categories listed below.

All purposes listed below.

All categories listed below.

Device/Network Data

Yes

All categories listed below.

All purposes listed below.

All categories listed below.

Biographical Data

No

 

 

 

Financial Data

No

 

 

 

Government ID Data

No

 

 

 

Health Data

No

 

 

 

Identity Data

Yes

All categories listed below.

All purposes listed below.

All categories listed below.

Inference Data

Yes

All categories listed below.

All purposes listed below.

All categories listed below.

Location Data

Yes

All categories listed below.

All purposes listed below.

All categories listed below.

 

Protected Category Data

No

 

 

 

Special Category Data

No

 

 

 

User Content

Yes

All categories listed below.

All purposes listed below.

All categories listed below.

 

 

B. Categories of Sources.

 

We collect this Personal Information from the following categories of sources:

 

    • Consumers;
    • Service providers and other third parties;
    • Social media companies;
    • Data we create/infer;
    • Automatic collection;
    • Aggregators and advertisers; and
    • Affiliates not under the ModelLand brand.

 

C. Why We Collect, Use, and Share California Information.

We use and disclose the Personal Information we collect for our commercial and business purposes, as further described in this Privacy Policy.  These commercial and business purposes include, without limitation:

    • Our commercial purposes, including marketing, advertising, and enabling commercial transactions.
    • Our business purposes as identified in the CCPA, which include:
    • o Auditing related to our interactions with you;
    • o Legal compliance;
    • o Detecting and protecting against security incidents, fraud, and illegal activity;
    • o Debugging;
    • o Performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics;
    • o Internal research for technological improvement;
    • o Internal operations;
    • o Activities to maintain and improve our services; and
    • o Other one-time uses.

 

D. Recipients of California Personal Information.

 

For purposes of the CCPA, we have not “sold” in the past 12 months any category of Personal Information.

 

We will disclose the categories of Personal Information designated above to the categories of third parties listed below for business purposes:

    • Service providers;
    • Government entities;
    • Advertising networks;
    • Internet service providers;
    • Data analytics providers;
    • Operating systems and platforms;
    • Social networks; and
    • Consumer data resellers.

 

E. Your Rights Regarding Personal Information.

California residents have certain rights with respect to the Personal Information collected by businesses.  If you are a California resident, you may exercise the following rights regarding your personal information, subject to certain exceptions and limitations:

    • The right to know the categories and specific pieces of personal information we collect, use, disclose, and sell about you, the categories of sources from which we collected your personal information, our purposes for collecting or selling your personal information, the categories of your personal information that we have either sold or disclosed for a business purpose, and the categories of third parties with which we have shared personal information;
    • The right to request that we delete the personal information we have collected from you or maintain about you.
    • The right to opt out of our sale(s) of your personal information. Please note that if you opt out of certain types of sales, we will be unable to provide you with the services that rely on such sales.
    • The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.

 

To exercise any of the above rights, please contact us using the following information and submit the required verifying information, as further described below:

Modelland Holdings LLC

12400 Wilshire Blvd., Suite 1060

Los Angeles, CA 90025

Attn: Data Privacy – Modelland

Email: dataprivacy@model-land.com

Fax: (310) 576-6160

 

1. Verification Process and Required Information. Note that we may need to request additional information from you to verify your identity or understand the scope of your request, although you will not be required to create an account with us to submit a request or have it fulfilled. We will require that you provide the email address we have on file for you (and verify that you can access that email account) as well as an address, phone number, or other data we have on file, in order to verify your identity.

2. Authorized Agent. You may designate an authorized agent to make a CCPA request on your behalf. If an agent is submitting the request on your behalf, we reserve the right to validate the agent’s authority to act on your behalf.

3. Minors’ Right to Opt In. We have not in the past 12 months sold the personal information of minors under 16 years of age.  If we do sell the personal information of minors under 16 years of age, such sales will occur with affirmative authorization. 

XII. CONTACT

For questions or concerns about Modelland’s privacy policy or practices, please contact us by using the information below.

Modelland Holdings LLC

12400 Wilshire Blvd., Suite 1060

Los Angeles, CA 90025

Attn: Data Privacy – Modelland

Email: dataprivacy@model-land.com

Fax: (310) 576-6160