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We welcome Content Creators, IP owners and Brands and users (“you”or “your”) to www.3dsparrow.com (“3D Sparrow” or Site”). 3D Sparrow is operated by 3D Sparrow Group Limited whose registered office is at The Annex, 3 High Street, Roade, Northampton, United Kingdom, NN7 2NW (“3D Sparrow”, “we”, “us” or “our”). We are committed to protecting and respecting your privacy (“you”, “your”, or “user”).
The data controller of your Personal Data is 3D Sparrow Group Limited whose registered office is at The Annex, 3 High Street, Roade, Northampton, United Kingdom, NN7 2NW. We use data processors who are third parties who provide elements of services for us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to. They will hold it securely and retain it for the period we instruct.
Personal Data means any information about an individual from which that person can be identified, whether indirectly or directly in particular by reference to an identifier such as a name, an identification number, location data or an online identifier (“Personal Data”). It does not include data which has been anonymised so that it can no longer be linked back to an individual.
Information we collect about you
This is information about you that you give us by creating an account with us on the Site, filling in the ‘Contact Us’ form on the Site or by corresponding with us by phone, email or otherwise or Personal Data that you otherwise choose to make available through the Site.
If you represent a Brand, we will collect your name, email address, phone number, bank details.
Personal Data we process automatically
We may automatically collect the following information about all users of our Site, which may be Personal Data as it may (particularly when combined) enable you to be identified:
technical information, including the Internet protocol (IP) address used to connect your computer or other device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
information about your visit, including the dates and times you use the Site, length of visits to certain pages, page interaction data (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call the contact phone number provided on our Site; and
Information we receive from other sources
This is information we receive about you from any third-party source.
We do not choose to 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).
How we use your Personal Data
We use your Personal Data for the following lawful bases:
where we need to, to perform obligations contained within a contract we are about to enter into or have entered into with you, including the Terms; or
where it is necessary for our legitimate interests of enforcing rights; protecting our business; correspondence with you or concerning you; analytics; fraud checks, testing, troubleshooting, surveys; or
where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your Personal Data other than in relation to sending direct marketing communications. We will get your opt-in consent before we:
send you any marketing communications; or
share your Personal Data with any third party for the purposes of marketing.
You can ask us to stop sending you marketing messages (or ask us to stop providing your details to third parties for marketing) at any time by contacting us at firstname.lastname@example.org or adjusting your account settings on the Site or following one of the opt out links contained within marketing emails. If you are receiving marketing messages from a third party and want them to stop, you will need to contact them directly.
Specifically, we use Personal Data held about you in the following ways:
to set up an account for you on the Site and provide the services;
to provide you with Personal Data in respect of any enquiry you should make;
to notify you about changes to any services we provide through the Site.
It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.
Personal Data we collect about you. We will use this Personal Data:
to deliver the Site effectively and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to improve the Site to ensure that content is presented in the most effective manner for you and for your computer or other device;
as part of our efforts to keep the Site safe and secure; and
to make suggestions and recommendations to you about services we offer that may interest you.
Personal Data we receive from other sources
To provide the analytics services.
Disclosure of your Personal Data
We may share your Personal Data with:
Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries. This is necessary for our legitimate interests of running our company.
Other users on the Site. Your Personal Data will only be shared with other users of the Site to the extent necessary for the Site to function.
We will not share your information with any third parties for the purposes of direct marketing.
We will disclose your Personal Data to third parties:
If we sell or buy any business or assets, in which case we will disclose your Personal Data to the prospective seller or buyer of such business or assets.
If we or substantially all of our assets are acquired by a third party, in which case Personal Data held by us about Site users will be one of the transferred assets.
Where we store your Personal Data
The data that we collect from you will be transferred to, and stored at, a destination within a destination outside of the UK or European Economic Area (“EEA”) including Russia. All Personal Data you provide to us is stored on our secure servers.
Unfortunately, the transmission of Personal Data via the internet is not completely secure. While we do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to us over the email or through the Site; any transmission is at your own risk. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorised access.
Whenever we transfer your Personal Data, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We may use specific contracts approved by the European Commission which give Personal Data the same protection it has in Europe; or
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to Personal Data shared between the Europe and the US; or
Where countries have been deemed to provide an adequate level of protection for Personal Data by the European Commission, we may transfer your Personal Data to third parties based in those countries.
Whether you are located in the EEA, or whether we are processing your Personal Data within the EEA, or in the context of our EEA business, you have a number of rights in relation to how we process your Personal Data. These include:
the right to access the Personal Data that we may hold about you;
the right to rectify any inaccurate or incomplete Personal Data that we may hold about you;
the right to have your Personal Data erased in certain circumstances, for example, where it is no longer necessary for us to process your Personal Data to fulfil our processing purposes; whether you object to your data being processed on certain grounds (for example, for marketing purposes) or whether your Personal Data is being unlawfully processed;
the right to object to our processing of your Personal Data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms;
the right to restrict the processing of your Personal Data under limited circumstances; and
the right to have some of your Personal Data ported to a new service provider if you no longer wish to use the Site or our services. This only applies to information you have given us.
How to exercise your data subject rights
You can exercise any of these rights any time by contacting us at email@example.com.
No fee usually required. You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
The Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Personal Data to these Sites.
We will only retain your Personal Data 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 unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.
For further information on retention periods, please contact us using the details provided at the end of this Policy.
Changes to Our Policy
Any changes we make to our Policy in the future will be posted on this page and, where you continue to hold an account with us, notified to you by email. Please check back frequently to see any updates or changes to our Policy.
Questions, comments and requests regarding this Policy should be addressed at firstname.lastname@example.org.
Should you have cause to complain about how we handle your Personal Data, please contact us in the first instance. We will do our best to resolve your concern. Alternatively, you may prefer to submit a complaint directly to your local data protection supervisory authority.