Privacy Policy

We will only collect and process your personal data when the law allows us to. Most commonly, we will collect and process your personal data in the following circumstances:

• Where we need to perform the contract, we are about to enter into or have entered into with you.
• Where we need to comply with a legal or regulatory obligation.
• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.
• When you consented to data collection and processing for the particular purpose.

The personal data we process (collect, use, store and share) about you depends on who you are and how we interact with you: whether you are just a regular visitor to our Website or Guest Buyer, or whether you are a registered Member (Registered User, Designer or Business Customer), or whether you apply for job position. When we refer in this Privacy Policy to 'personal data' we are referring to data about you (or other living people) from which you could be identified directly or that makes you identifiable indirectly by one or more factors related and specific to you such as your name, your contact details and even your IP address.

When you register or use the Website you will be asked to "opt in" to our Privacy Policy, General Terms and Conditions, i.e. to confirm that you have read those documents and understand and acknowledge to our use of any personal data that we may collect from you as a user of the Website as set out in this Privacy Policy. Our services are not intended for persons under 18 years of age – no one under age 18 may register as a Member of our services by creating an account and providing any information to or on the Website as specified in our General Terms and Conditions. By registering an account, you confirm you are at least 18 years old.

If you are a visitor of our Website

As you visit or interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, session logs and other similar technologies.We use cookies to improve our Website, make your browsing experience and our business decisions better. The data we may collect is:

• IP address
• Session logs (IP address, login date (month/year), last login country)
• Your location (country)
• Your devise you are browsing from and the browser you use
• Referrer website (the website that linked you to our website, if any).

The purpose of processing – to improve our Website and users experience.

Legal basis for processing – the legitimate interest (IT security, marketing) and your consent for processing data for particular purpose (e.g. the use of cookies).

The period of data storage – Please see our Cookie Policy for further details.

If you are a Guest Buyer

You can use our services by visiting our Website and exploring the opportunities (downloading free models or buying without registration). For such reason we are collecting and processing personal data as if you are a regular visitor to our Website and data you provide for us:

• Email address
• IP address
• Payment details (credit/debit card number or Paypal address). Please note that we do not store financial data. This data is processed and stored by Adyen B.V., a company trusted to process payments for some of the biggest companies in the world, according to its terms, conditions and policies, which all could be found on its website.

The purpose of processing – provision of services, including the fulfilment of orders and transactions (purchase) and delivery of goods online (3D Models)

Legal basis for processing – the performance of the contract between us and the Guest Buyer or necessity to take steps at your request before entering into a contract.

The period of data storage – 10 years after the purchase.

If you are a Registered User

When you register to use our services by creating an account on our Website or connecting your Facebook or Google account to the Website, we will collect personal data as necessary to register such account

• User name
• Email address
• IP address
• Session logs (IP address, login date (month/year), last login country)

The purpose of processing – registration of a Member account.

Legal basis for processing – the performance of the contract between us and you as a Registered User or necessity to take steps at your request before entering into a contract.

The period of data storage – 2 years after last login (if no purchases are made), 10 years after the purchase.

Additionally, if you want to purchase 3D Models in addition we would collect and process your personal data related to the payment

• Payment details (credit/debit card number or Paypal address). Please note that we do not store financial data. This data is processed and stored by Adyen B.V., a company trusted to process payments for some of the biggest companies in the world, according to its terms, conditions and policies, which all could be found on its website.

The purpose of processing – provision of services, including the fulfilment of orders and transactions (purchase) and delivery of goods online (3D Models)

Legal basis for processing – the performance of the contract between us and you as a Registered User or necessity to take steps at your request before entering into a contract.

The period of data storage – 10 years after the purchase.

If you are a Designer

If you are a registered Member who creates 3D Models and uses the Website as a platform for selling your 3D Models you are considered a Designer. We will collect and process personal data as necessary to register your account

• User name
• Email address
• Session logs (IP address, login date (month/year), last login country)

The purpose of processing – registration of a Member account

Legal basis for processing – the performance of the contract between us and the you as a Designer or necessity to take steps at your request before entering into a contract.

The period of data storage – 2 years after last login (if no purchases or sales are made), 10 years after the purchase or sale.

Additionally, in order to be eligible for royalty payments for your 3D Models sold on our Website in addition we would collect and process your personal data that you are obliged to provide when signing the Payment Agreement Form:

• First name
• Last name
• Birth date
• ID number (a number of any government-issued document such as passport, ID, driver's license, etc. or your national identification number)
• A copy of your ID document (a photo or a scan of your ID, passport, driver's license or social security)
• Full address (street address/ZIP code, city, country)
• Location (city, country)
• Bank account number (or other payment details, such as Paypal address, Webmoney or Payoneer ID)
• IP address

The purpose of processing – execution of financial transactions (transfer of royalty payments for services sold 3D Models).

Legal basis for processing – the performance of the contract between us and you the Designer or necessity to take steps at your request before entering into a contract, legal obligation.

The period of data storage – 10 years after the purchase or royalty payment.

If you are a Partnered (Wildcat) Designer

If you are a registered Member who agreed with Wildcat Terms & Conditions and works within Wildcat platform as a freelancer, you are considered a Partnered Designer. We will collect and process personal data as necessary to register your account:

• User name
• Email address
• Session logs (IP address, login date (month/year), last login country)
• Data about usage of plugin (such as Kodama) functionality, e.g. verification of 3D models

The purpose of processing – registration of a Member account, management of a Member account, and provision of Wildcat functionality and services.

Legal basis for processing – the performance of the contract between us and you as a Partnered Designer or necessity to take steps at your request before entering into a contract.

The period of data storage – 2 years after last login.

Additionally, in order to be eligible for royalty payments for your work on Wildcat platform in addition we would collect and process your personal data that you are obliged to provide when signing the Payment Agreement Form:

• First name
• Last name
• Birth date
• ID number (a number of any government-issued document such as passport, ID, driver's license, etc. or your national identification number)
• A copy of your ID document (a photo or a scan of your ID, passport, driver's license or social security)
• Full address (street address/ZIP code, city, country)
• Location (city, country)
• Bank account number (or other payment details, such as Paypal address, Webmoney or Payoneer ID)
• IP address

The purpose of processing – execution of financial transactions (transfer of royalty payments for your services).

Legal basis for processing – the performance of the contract between us and you as the Partnered Designer or necessity to take steps at your request before entering into a contract, legal obligation.

The period of data storage – 10 years after the royalty payment.

If you are a Business Customer

We offer our services to Business Customers and therefore we are processing personal data of the representative of Business Customer as necessary to register an account and for provision of our services:

• User name
• First name
• Last name
• Company info (title, company name)
• Location (city, country)
• Phone number
• Email address
• Session logs (IP address, login date (month/year), last login location)

The purpose of processing – provision of services, including the fulfilment of orders and transactions (purchase) and delivery of goods online (3D Models)

Legal basis for processing – the performance of the contract between the parties or necessity to take steps before entering into a contract.

The period of data storage – 2 years after last login.

If you are applying for an open position in the Company (Recruitment process)

The Company is constantly growing and having open positions in the Company. In connection with a job application or inquiry, whether advertised on a Company’s website or LinkedIn account, we process and store personal data of job applicant and potential candidates for employment. During the recruitment process we may process the data that you provide us with your resume or application.

• First name
• Last name
• Contact details (phone No., email address)
• Education
• Work experience
• Professional experience (certificates)
• Other information that you provide on your resume

The purpose of processing – identifying and evaluating candidates for potential employment and contacting candidates

Legal basis for processing – the legitimate interest (to select committed and experienced individuals most suitable for a particular position)).

The period of data storage – if you are not selected, we will retain the selection data until the position is closed, but not longer than 1 year, and if you are selected and employment contract is concluded, we will retain the selection data in the manner and for the period applicable to the processing of our staff staff data that will be presented to you at the time of conclusion of the contract.

If you were not selected and offered employment, we may want to remain in contact with you if we think we could consider you for future employment opportunities. If you would not object to including you in one of our recruiting programs or potential employees data base to keep your data (resume) and contact you in the future, we retain a minimal amount of your personal data.

The purpose of processing – contacting potential candidate and offering him/her to participate in the recruitment process for the particular job opening.

Legal basis for processing – the legitimate interest (to select committed and experienced individuals most suitable for a particular position).

The period of data storage – 1 year after the date of receipt of the data.

Direct Marketing

We engage in various marketing activities and try to improve our Website and user experience. We need to know what information on the Website is most interesting for visitors and Members, from which countries they come to our Website, how often they return, which browsers they use, on which devices the Website is browsed, what is their IP address. We may collect that data by using third party tools such as cookies and other technologies (e.g. Google Analytics or similar ones), which allows to record and analyze statistical data about use of the Website. Please see our Cookie Policy for further details.

Subscribing for the news

Any Website’s visitor or Member can subscribe for Company’s newsletter and receive our news, promotions, sales proposals, etc. by providing his/her email. For this we will process your data:

• Email address

The purpose of processing sending the newsletter.

Legal basis for processing – your consent.

The period of data storage – 5 years after receiving consent or until you withdraw your consent.

You may withdraw your consent at any time by simply clicking ‘unsubscribe’ link at any email or by sending your withdrawal notice to us by email at support@cgtrader.com

Sending email notifications

If you are a Member (Registered User or Designer) we may send you notifications about our proposals or your activities within your account:notifying you aboutproduct and feature announcements, community news, special offers, information about sales; sending you notifications when you get a new personal message; notifying you when your model is sold, when the purchaser rates your model or provides other feedback; informing you about received price offers (when the offer is received, gets accepted, declined or negotiated); providing you tips & tricks to help you improve your experience. For this we will process your data:

• Email address

The purpose of processing – sending notifications and provision of services.

Legal basis for processing – the legitimate interest of our Company to improve user experience and the performance of the contract between the parties .

The period of data storage – 2 years after last login.

You may object to processing of your data for this particular reason or withdraw your consent at any time by simply clicking ‘unsubscribe’ link at any email or by sending your withdrawal notice to us by email: support@cgtrader.com. Also, you may change notification settings by logging to your account and making changes in the settings.

Profiling

We may use the data of your activities as well as transactions to provide you with the most relevant information. On your registration we assign each Member to an individual profile depending on your interests (e.g., if you are looking to purchase models, to sell them or both). Depending on the profile that you are assigned to, the Company will amend the experience you receive while visiting our Website which might include slight alterations of the Website as well as most interesting pieces of the Website will reach you first or you might access additional functionalities. You may freely choose your main interests in your profile settings to guarantee the best experience.

The purpose of processing – improving Members experience and providing services adjusted to each Member interests.

Legal basis for processing – the legitimate interest of our Company to improve user experience.

The period of data storage – 2 years after last login (if no purchases or sales are made), 10 years after the last purchase or sale.

You may object to processing of your data for this particular reason (profiling) by informing us by email dpo@cgtrader.com, however please note that profiling is linked to the website functionality and you might not be able to use some of our services if profiling is disabled.

If you are a Designer – we may use your activity data (models sold, uploaded, ratings, likes, comments, etc.) to add the reputation points and assign the profile level, which is related to a Royalty rate and allows users to increase their earnings.

If you are a Partnered Designer – we may use your activity data (previous Wildcat deliveries) to assign higher complexity tasks on Wildcat platform.

The purpose of processing – execution of financial transactions, execution of contract.

Legal basis for processing – the performance of the contract between us and you as the Designer.

The period of data storage – 2 years after last login (if no royalty fee payments are made), 10 years after the last royalty fee payment.

Links to other sites

The Website may contain links to other sites, i.e. links leading to websites of our partners or to social media websites. This Policy is applicable only with respect to the Website, but not any other sites, therefore we strongly recommend to review the privacy policies of any websites that you may reach by following hyperlinks presented in this Website. We have no control and no responsibility with regard to any content presented in sites other than the Website.

We put our best efforts to keep your data safe and always require the high level of security and confidentiality from our employees and partners.

We may share your personal data with our trusted services providers. We use third party service providers to undertake processing operations on our behalf, and this may require us to share your personal data with them when they provide services to us, to you on behalf of us and under our instructions.

Transaction information data may be accessible to our partners, who provide us with tools for payments.

We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this information and do not use it for any other purpose. We take these relationships seriously and oblige all of our data processors to sign contracts with us that clearly set out their commitment to respecting your rights as individuals, and their commitments to assisting us to help you exercise your rights as a data subject.

We engage with these payment providers: Adyen, Paypal, Webmoney, Payoneer, also we may provide your data to banks or other financial institutions.

We may also provide your data (or allow access to your data) for our IT support service providers on case by case basis in case of specific incident resolution, e.g. customer service issue, security incident investigation, for accounting service providers, etc.

We may also disclose your data if required to do so by law or if we believe that such action is necessary to protect and defend the rights, property or personal safety of the Company, the Website or its visitors.

Some of our service providers and partners are established outside the European Economic Area (EEA) thus in certain situations we may transfer your personal data outside the EEA.

Whenever we transfer your data to the third countries outside the EEA, we ensure that that an adequate degree of protection is afforded to your data by ensuring at least one of the following safeguards is implemented:

• We will only transfer your data to countries that have privacy laws that have been recognized by the country from which the data are transferred that have been deemed to provide an adequate level of protection for personal by the European Commission.
• We will enter into agreements, such as standard contractual clauses (SCC) and other data transfer agreements, with recipients that require them to provide the same level of protection for the data.
• We may seek your consent for transfers of your personal data for specific purposes.
• We may rely on other transfer mechanisms approved by authorities in the country from which the data are transferred.

Service providers we engage outside the EEA are companies providing cloud storage, customer support, data analysis and reporting tools, these companies might be based in the United States of America.

For non-EEA countries customers and registered users: by using 3D marketplace or any other service provided by Company (CGTrader) you explicitly agree that your personal data will be stored and processed under GDPR and SSC (Standard Contractual Clauses in cases where personal data is transferred outside EEA) as legal basis.

As a data subject you have a number of rights in relation to your personal data. You can exercise the rights that are mentioned further by contacting us at dpo@cgtrader.com.

• The right of access – you may request access to the personal data that we hold which relates to you and receive a copy of data that we hold about you.
• The right to rectification – you may request us to correct personal data that we hold about you which you believe is incorrect or inaccurate and to complete incomplete personal data. We may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is right.
• The right to erasure – you may also ask us to erase personal data if:

1. your personal information has been processed unlawfully by us; or
2. your personal information is no longer necessary for the purposes for which it was collected by us; or
3. you withdraw your consent and where there is no other legal ground for the processing;
4. where you object to processing (see below) and there is no overriding legitimate

• interest for continuing to process your personal data.
• The right to restrict processing – you may ask us to restrict processing of your personal data in these situations:

1. If you object to processing pending the verification whether the legitimate grounds of the Company override those of you;
2. if you dispute the accuracy of personal data we are processing and want us to verify that data's accuracy;
3. where it has been established that our use of the data is unlawful but you do not want us to erase it;
4. where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims.

• The right to data portability – you can ask us to provide you or transmit those data directly to another controller of your choice, where technically feasible, certain personal data that we hold about you in a structured, commonly used machine-readable format. However, you must keep in mind that you may exercise the right of data portability only on data that is processed based on your consent or on a performance of a contract between you and us and that is being processed by automated means. We can guarantee only transferring data to you in such occasions and can not be responsible with technical compatibility of other party systems where data transfer is requested.
• The right to withdraw consent regarding processing of personal data – you may withdraw your given consent for processing of personal data for particular purposes at any time by informing us at email dpo@cgtrader.com or following the procedure that was specified before obtaining your consent.
• The right to object - you can object to our processing your personal data under certain circumstances including where processing takes place in line with the Company’s legitimate business interests as set out above. Where you object to processing, we must stop processing your personal data unless we can show that our legitimate ground for processing of your personal data overrides your interests or where we need to process the data to establish, exercise or defend legal claims.
• The right to object to automated decision making and profiling – you have the right to be informed about the existence of any automated decision making and profiling of your personal data and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.
• The right to lodge a complaint with a supervisory authority – if you think that your rights have been violated, you may file a complaint to a State Data protection Inspectorate (L. Sapiegos str. 17, LT-10312 Vilnius , phones: +370 5 271 2804 / 279 1445, fax +370 261 9494, email ada@ada.lt)

We may change this Privacy Policy from time to time based on changes to applicable laws and regulations or other requirements applicable to us, changes in technology, or changes to our business. Any changes we make to the Privacy Policy in the future will be posted on our Website at https://modelry/privacy-policy. We may also notify you directly via email about the changes and the effective date of the updated Privacy Policy if changes affect how we process personal data. If you will continue to use our services after the effective date will mean that you have accepted the changes.

This Privacy Policy was last updated in July 2021.