Privacy Notice

Last update: 20 April 2021

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This notice describes how Technologies S3D 3D Inc. (“S3D”, “us”) collects, processes, uses and shares personal information and personal data through the We3D mobile application (the “Application”).

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In this notice, the term personal data refers to information concerning an individual who is identifiable.

The contact details of the person responsible for ensuring compliance with this notice are as follows:

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Privacy Manager :
Technologies ShapeShift 3D Inc.
CP 300 BP Saint Dominique
Montréal QC H2S 3K9

Canada

privacy@shapeshift3d.com

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1. Summary

S3D collects user-provided three-dimensional scans of the head, face or other body parts in order to customized products that you ordered from S3D or from another person or entity (a “Third-Party Seller”).

Scan data is used to customize three-dimensional models and send such customized models to Third-Party Sellers or to a manufacturer so they can provide you with a customized product. We also use scan data on an anonymous basis to perform analyses, to validate models developed by S3D and to experiment with the customization of 3D-printed wearables. S3D does not collect your name, email or other personally identifiable data other than scan data unless you purchased a product directly from S3D. This data is sent directly to Third-Party Sellers.

For details about our processing of personal data, please read below. You can use these quick links to access information that is more relevant for you.

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1.    Summary

2.    Our Legal Basis for Processing

3.    Data We Collect

4.    How We Use your Data

5.    How we Store your Data

6.    How Personal Data is Protected

7.    Who has Access to your Personal Data

8.    What are your Rights about your Personal Data

9.    Updates to this Notice

 

2. Our Legal Basis for Processing

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We process personal data based on the following basis:

• We use your personal data as necessary to provide you services, directly or indirectly through Third-Party Sellers;

• We use your personal data based on our legitimate interests to perform research and analyzes. Such processing is always done on an anonymous basis unless we have your explicit consent.

• We may process your personal data based on your consent if we have obtained your consent.

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3. Data We Collect

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We collect and store the following information:

• A three-dimensional image or your head, face or other body part (“3D Scans”);

• A unique user ID generated by the Application;

We collect the following information on behalf of Third-Party Sellers:

• Your name and email address;

• A unique user ID generated by the Application;

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4. How We Use your Data

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We process personal data for the purposes described below:

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4.1.Model Customization

We use 3D Scans to modify three-dimensional models to fit your personal characteristics. We associate a unique user ID with the customized model to allow the Third-Party Seller to direct you order of personalized product to the right individual.

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4.2.Identification of Customer

If you ordered a product through a Third-Party Seller, we do not have access to the database associating unique user IDs with your name or email address.

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4.3.Research and analysis

We use 3D scans on an anonymous basis to:

• Perform analyses, compile statistics and refine our algorithms and processes.

• Improve our software by testing our algorithms on a large pool of test subjects.

• Compile statistics to better understand differences between different people.

• Perform validation studies on our customization methods.

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5. How we Store your Data

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Third-Party Sellers may store your personal data in accordance with their own procedures and policies.

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5.1.Record Keeping

Unless you ordered products directly from us, we do not store your name and email address.

We keep 3D Scans and unique user IDs until you ask us to delete your data (directly or through a Third-Party Seller, as the case may be) or until our activities no longer require that we associate your 3D Scan to a unique user ID. We will delete or anonymize your 3D Scan within 36 months of your submission.

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Instead of deleting 3D Scans, we may delete the associated user ID or replace your unique user ID with another anonymous identification number which is not associated with your identity in any way.

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5.2.Storage

Personal data is stored electronically on our servers located in the United States of America and Canada. These servers are operated by our hosting provider, which undertakes in writing to keep your personal data confidential and to use the same only for the purpose of providing services to us. 

Personal data collected about individuals located outside of Canada is transferred to Canada. Canada is recognized as an appropriate jurisdiction for the transfer of personal data from the European Economic Area. Any onward transfer is made in accordance with this notice to a sub-processor, we will ensure that such transfer is made with appropriate safeguards to protect the rights of the individuals involved.

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6. How Personal Data is Protected

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Your personal data is hosted by our hosting provider, which agrees to use industry-standard security measures to maintain the integrity and confidentiality of data.

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Our employees are aware that personal data collected by S3D is confidential and are informed about the appropriate security measures to prevent unauthorized access to personal data.

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7. Who has Access to your Personal Data

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We only share your personal data as described in this notice or when we have your consent. Your personal data may be disclosed to the categories of recipients described below for the purposes mentioned.

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7.1.Employees

Collected personal data is only available to our officers and employees who must access it for the purposes described in this notice.

 

7.2.Third-Party Sellers

Third-Party Sellers receive your name, email address and unique user ID when you perform a scan through the Application. After you scan is processed, we send a customized model along with the unique user ID associated with your 3D Scan to the Third-Party Seller. Third-Party Sellers do not have access to your 3D Scan. Third-Party Sellers do not process personal data on our behalf but on their own behalf. The processing of your personal data by Third-Party Seller is governed by your agreement with such Third-Party Seller and their own privacy documentation.

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7.3.Service Providers

We share personal data with the service providers listed below:

Name

Type of Data

Location of Processing

Useful Links

Amazon Web Services (AWS).

A three-dimensional image or your head, face or other body part (“3D Scans”); Name; Sex. [JB11] 

 

Canada, USA and EU.

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7.4.Legal Obligations

We may also disclose personal data to third parties if the law expressly authorizes or requires such disclosure, or if we are ordered to do so by a competent authority. We may disclose personal data in the context of court proceedings if necessary to protect our rights or those of our commercial partners.

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7.5.Sale of Business

In the event that the sale or restructuring of all or part of our business is envisioned, we may disclose collected personal data to the persons or organizations involved before and after the transaction, whether or not it takes place. In such a case, these persons or organizations undertake to keep disclosed personal data confidential and to use same exclusively in order to evaluate the feasibility or the opportunity of the proposed transaction as well as in accordance with this notice.

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8. What are your Rights about your Personal Data

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If you ordered a product through a Third-Party Seller, you must contact the Third-Party Seller to exercise your rights about your personal data, as we do not keep a record of your name and email address.

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8.1.Accessing your data

To access the personal data that we hold about you or to rectify personal data that is incorrect, you may make a request in writing to the following address: privacy@shapeshift3d.com or to our address at the beginning of this notice.

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We will respond to your request promptly (within 30 days of receipt), allowing you to access your personal date that is under our control. When required by law, we will provide your data in a portable machine-readable format.

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8.2.Withdrawing your Consent

If you wish to withdraw your consent to the processing of your personal data (if such processing is based on your consent) or request the erasure of your personal data (in all cases), please notify us in writing at privacy@shapeshift3d.com. We will respond to your request as soon as possible (within 30 days of receipt).

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8.3.Complaints

If you reside in the European Economic Area and some other jurisdictions, you have the right to lodge a complaint about the processing of your personal data with a supervisory authority responsible for the protection of privacy. The competent authorities may vary depending on your place of residence.

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Otherwise, our processing of personal data is governed by the laws applicable in Canada and the authorities of Canada shall be solely competent to receive any complaint about our processing of personal data.

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8.4.Verification

We reserve the right to verify the identity of individuals requesting access to personal data. Any information collected to perform this verification will not be used for any other purpose.

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9.Updates to this Notice

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We may update this notice from time to time to reflect changes in our personal data management practices. If this notice is modified, the updated notice will be available on our website at the following URL : www.shapeshift3d.com/we3d-privacy

If we have your email address, we will notify you of any material changes to our privacy notice by email prior to the coming into force of the updated notice.

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