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Privacy Policy

1. Introduction

At Splatware UG ("Splatware", "we", "us", or "our"), your privacy and the protection of your personal data are of the utmost importance. This Privacy Policy explains how we collect, process, use, disclose, transfer, and store your personal information when you use our websites, applications, platforms, and services (collectively, the "Services").

This Privacy Policy is designed to meet the requirements of applicable data protection laws, including the General Data Protection Regulation (EU) 2016/679 ("GDPR"), the German Federal Data Protection Act (Bundesdatenschutzgesetz – "BDSG"), and the Telemedia Act (Telemediengesetz – "TMG"). It applies to all users, whether accessing the Services through a web browser, a mobile device, an API integration, or other means.

By creating an account, uploading any files (including 3D models, images, or videos), using our marketplace, or otherwise accessing or using our Services, you acknowledge that you have read, understood, and agreed to this Privacy Policy. If you do not agree to this Privacy Policy, you must not access or use our Services.

We encourage you to read this Privacy Policy carefully. Should you have any questions about our data protection practices or your rights under this Privacy Policy, you can contact us at the information provided below.

Please note that we may provide additional data and privacy information embedded in our Services for specific features that require the collection of personal data. In such cases, you will be able to review this information before enabling those features.

2. Data Controller Information

The entity responsible for the collection, processing, and use of your personal data under this Privacy Policy (the "Data Controller") is:

  • Company Name: Splatware UG
  • Address: Leydenallee 94, 12165 Berlin, Germany
  • Email: info@splatware.com
  • Website: www.splatware.com

If you have any questions regarding this Privacy Policy or wish to exercise your data protection rights (such as access, rectification, erasure, restriction, or objection), you may contact us at the email address provided above.

At this time, Splatware UG has not appointed a dedicated Data Protection Officer (DPO) under GDPR Article 37, as this is not required by law for our current processing activities. However, all data protection inquiries will be handled promptly and in accordance with applicable data protection laws.

3. What Personal Data We Collect

In order to provide and improve our Services, Splatware collects and processes different categories of personal data. The types of information we collect include, but are not limited to:

  • Account Registration Data:When you register for an account, we collect information such as your full name, email address, password (stored securely and encrypted), and country of residence. This information is necessary to create and maintain your account.
  • Uploaded Content Data:When you upload 3D models, images, videos, or other materials through our Services, we collect and store this content to provide functionality such as private project storage, public model sharing, and marketplace listing.
  • Usage Data:We automatically collect technical information about your device and use of the Services, such as your IP address, device type, operating system, browser type, referring URLs, access times, pages visited, and other diagnostic data. This data helps us maintain security and optimize the Services.
  • Payment Data:If you purchase paid Services (such as Pro or Enterprise subscriptions), we process payment information via third-party payment providers. We do not store full credit card numbers or banking information on our servers. Payment providers may collect your billing address and payment details in accordance with their own privacy policies.
  • Communication Data:When you communicate with us (for example, via email, support tickets, or feedback forms), we collect the content of your communications, including any attachments, metadata, and your contact information.

We do not collect any sensitive personal data (e.g., health information, political opinions, religious beliefs) unless expressly requested and agreed upon for a specific purpose and lawful basis.

4. How We Use Your Personal Data

We use your personal data for the following purposes, in accordance with applicable data protection laws:

  • To Provide and Maintain the Platform:We use your data to register your account, authenticate you when you log in, store and manage your uploads, and deliver core functionalities of the Services.
  • To Allow Account Management and Communication:Your personal data enables you to manage your profile settings, update your content, participate in the marketplace, and receive necessary communications related to your account.
  • To Process Uploads and Share Them Publicly or Privately:Depending on your settings, your uploaded models, images, or videos may be displayed publicly on our platform or remain private. We use your data to manage these preferences and ensure correct visibility.
  • To Operate the Marketplace (Buy/Sell Models):We use your personal data to facilitate transactions between users, display listed models, process payments through third-party services, and deliver purchased content.
  • To Send Important Service Updates and Notifications (Non-Marketing):We may send you essential communications about your account, system updates, changes to our Terms or Privacy Policy, or other critical operational matters. You cannot opt out of these communications as they are necessary for service administration.
  • To Send Optional Marketing Emails:With your explicit consent or where legally permitted, we may send you promotional communications about new features, services, special offers, or events. You can opt out at any time by following the unsubscribe link provided in such emails.

We will not use your personal data for purposes materially different from those described in this Privacy Policy without first obtaining your explicit consent.

5. Legal Bases for Processing

We process your personal data in accordance with the General Data Protection Regulation (GDPR) and applicable local data protection laws. The legal bases for our processing activities are as follows:

  • Performance of a Contract (Art. 6(1)(b) GDPR):We process your personal data to fulfill our contractual obligations towards you, including the provision of our Services, account management, upload functionality, marketplace participation, and support services.
  • Compliance with Legal Obligations (Art. 6(1)(c) GDPR):In certain cases, we are legally required to process your personal data, for example to comply with tax regulations, commercial record-keeping obligations, or lawful requests from public authorities.
  • Consent (Art. 6(1)(a) GDPR):Where legally required, we obtain your consent before processing your personal data for specific purposes, such as sending marketing communications. You may withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
  • Legitimate Interests (Art. 6(1)(f) GDPR):Where applicable, we process your personal data to pursue our legitimate interests, provided that such interests are not overridden by your fundamental rights and freedoms. Legitimate interests include platform security, fraud prevention, enhancing and personalizing the Services, and optimizing our operations.

If we rely on legitimate interests for processing, we ensure that we carefully balance our interests with your privacy rights.

6. Sharing and Disclosure of Personal Data

We treat your personal data with strict confidentiality. We only share your data with third parties in the following limited circumstances:

  • Internal Employees and Authorized Service Providers:Your personal data is accessible only by employees and contractors of Splatware UG who require access to fulfill their job duties and are bound by confidentiality agreements. Additionally, we engage trusted service providers (e.g., IT support, cloud hosting) under strict contractual data processing agreements ensuring data security and GDPR compliance.
  • Third-Party Services:We utilize third-party providers to deliver parts of our Services, including but not limited to:
    • Firebase by Google LLC for authentication, cloud storage, hosting, and database services;
    • Payment processors (e.g., Stripe, PayPal) for handling payments securely;
    • Analytics providers (e.g., Google Analytics) to analyze and optimize platform usage.
    Such providers are contractually bound to process your data solely in accordance with our instructions and applicable laws.
  • Legal Requests and Obligations:We may disclose your personal data if required to do so by law, regulation, legal process, or government request (GDPR Art. 6(1)(c)), or if necessary to enforce our rights, respond to claims, or protect the rights, property, or safety of Splatware, our users, or the public.

We do not sell, rent, or trade your personal data to third parties for their marketing purposes.

7. Third-Party Services and Integrations

To provide a seamless, secure, and efficient user experience, Splatware relies on various trusted third-party services. We carefully select our partners to ensure they adhere to high standards of data protection and comply with applicable data privacy laws. The categories of third-party services we use include:

  • Firebase (by Google LLC):We use Firebase for user authentication, cloud storage, hosting, and database management. Firebase processes user registration data, login credentials, project storage (uploaded files), and other operational data necessary for the functionality of our Services.
  • Payment Providers:We use third-party payment processors such as Stripe and PayPal to securely handle subscription payments, purchases of models, and marketplace transactions. Your payment information is processed directly by these providers according to their respective privacy policies, and we do not store full credit card details on our servers.
  • Analytics Providers:We utilize analytics services such as Google Analytics or Plausible Analytics to collect aggregated usage data about how users interact with the platform. This helps us improve our Services, optimize user experience, and monitor system performance.
  • AI Service Providers:In specific cases where external AI services are used for processing images, videos, or 3D models (e.g., for optimization, enhancement, or conversion), your data may be securely transmitted to third-party AI providers. Such transmissions only occur under strict agreements ensuring GDPR compliance and confidentiality.

Please note that your interactions with third-party services may also be governed by the privacy policies of the respective providers. We encourage you to review their policies to understand how your personal data is processed by them.

All third-party providers engaged by Splatware are contractually obligated to process personal data only on our behalf and in compliance with applicable data protection laws.

8. International Data Transfers

In some cases, your personal data may be transferred to, stored, and processed outside of the European Economic Area ("EEA"), including but not limited to the United States. For example, our use of services provided by Firebase (Google LLC) and other technology partners may involve international data transfers.

To ensure adequate protection of your personal data when transferred outside the EEA, we implement appropriate safeguards as required under GDPR. Specifically, we rely on the following mechanisms:

  • Standard Contractual Clauses (SCCs):We require third-party service providers and partners to agree to and implement the European Commission’s Standard Contractual Clauses for international data transfers where no adequacy decision exists.
  • Additional Technical and Organizational Measures:In cases where SCCs alone are not sufficient, we implement supplementary measures such as encryption, strict access controls, and minimized data transfer to further protect your personal data.

By using our Services, you acknowledge and agree that your personal data may be processed in countries outside of your country of residence, including in countries that may not provide the same level of data protection as the EEA.

If you would like further information about international data transfers and the safeguards we apply, you may contact us at info@splatware.com.

9. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

  • Account and Uploaded Content:Personal data associated with your account and your uploaded content (such as 3D models, images, videos) is retained for as long as your account remains active. Upon deletion of your account or specific content, we will delete the associated data unless retention is required for legal reasons.
  • Marketplace Transactions:Records related to sales or purchases in the Splatware marketplace, including transaction data and communication history, are retained for a minimum period required under applicable tax, accounting, and commercial laws (typically up to 10 years in Germany).
  • Support and Communication Data:Inquiries, support tickets, and communications with us may be retained for a reasonable period necessary to resolve the inquiry and for internal recordkeeping purposes.

You have the right to request deletion of your personal data at any time (subject to the conditions set out in Section 10 below). We will comply with such requests unless a longer retention period is required or permitted by law.

Upon expiration of the applicable retention periods, we will securely delete or anonymize your personal data in accordance with applicable laws and industry standards.

10. Your Rights Under GDPR

If you are located in the European Economic Area ("EEA") or otherwise subject to the General Data Protection Regulation ("GDPR"), you have the following rights regarding your personal data:

  • Right to Access:You have the right to request confirmation as to whether we process your personal data and to receive a copy of that data.
  • Right to Rectification:You have the right to request correction of inaccurate personal data or completion of incomplete data concerning you.
  • Right to Erasure ("Right to be Forgotten"):You have the right to request that we delete your personal data under certain conditions, such as when the data is no longer necessary for the purposes for which it was collected.
  • Right to Restrict Processing:You have the right to request restriction of the processing of your personal data under certain conditions, for example, if you contest the accuracy of the data.
  • Right to Data Portability:You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller, where technically feasible.
  • Right to Object to Certain Processing:You have the right to object at any time to the processing of your personal data based on legitimate interests or direct marketing purposes.
  • Right to Withdraw Consent:Where we process personal data based on your consent (e.g., for receiving marketing communications), you have the right to withdraw your consent at any time. Withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

To exercise any of these rights, you may contact us at info@splatware.com. Please note that we may need to verify your identity before processing your request in order to protect your privacy and security.

You also have the right to lodge a complaint with a data protection supervisory authority if you believe that the processing of your personal data infringes applicable laws.

11. Cookies and Tracking Technologies

Our Services use cookies and similar tracking technologies (such as web beacons and pixels) to enhance your user experience, analyze site traffic, enable essential platform functionalities, and, where applicable, deliver personalized marketing.

  • Session Management:We use essential cookies to authenticate users, manage sessions, and ensure the secure and efficient operation of our Services. These cookies are necessary for the functionality of the website and cannot be disabled.
  • Website Analytics:We use analytics cookies (e.g., Google Analytics or Plausible Analytics) to understand how users interact with our Services. This helps us measure performance, detect technical issues, and optimize the user experience. Analytical data is aggregated and does not directly identify individual users.
  • Marketing and Personalization:If applicable, we may use marketing cookies to deliver targeted advertisements or offers based on your browsing behavior and preferences. Such cookies will only be activated with your explicit prior consent, where required by law.

Upon your first visit to our website, we display a cookie banner requesting your consent to the use of non-essential cookies. You have the option to accept, reject, or configure your cookie preferences at any time through the cookie management tool available on our website.

You can also manage cookie settings directly through your browser. Most browsers allow you to control cookies through their settings preferences, including blocking or deleting cookies entirely. Please note, however, that disabling certain cookies may impact the functionality and availability of some features on our platform.

For more detailed information about the cookies we use and how to manage your preferences, please refer to our separate Cookie Policy.

12. Children's Privacy

Protecting the privacy of children is particularly important to us. Our Services are not intended for use by individuals under the age of sixteen (16) years. Depending on your jurisdiction, this minimum age may be lowered to thirteen (13) years under applicable law (e.g., COPPA in the United States).

We do not knowingly collect, solicit, or process personal information from individuals under the minimum required age. If we learn that we have inadvertently collected personal information from a child without appropriate parental consent, we will take immediate steps to delete such information.

If you are a parent or guardian and believe that your child has provided personal data to us without your consent, please contact us immediately at info@splatware.com so that we can take appropriate actions.

We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Privacy Policy by instructing children never to provide personal information through our Services without parental consent.

13. Security of Your Information

We take the security of your personal information seriously and implement appropriate administrative, technical, and physical measures to protect it against unauthorized access, alteration, disclosure, or destruction. These measures include, but are not limited to, access control systems, encryption protocols, secure server infrastructure, regular security assessments, and staff training on data protection.

Access to your personal data is limited strictly to personnel, contractors, and service providers who require access for legitimate operational or support purposes. All individuals with access are bound by strict confidentiality obligations and data protection agreements.

Despite our efforts to safeguard your information, no security system is impenetrable. Therefore, we cannot guarantee absolute security of your data transmitted to or stored within our systems. You are responsible for maintaining the confidentiality of your login credentials and for all activities that occur under your account.

If you believe your personal data has been compromised, please contact us immediately at info@splatware.com so we can investigate and take appropriate measures.

14. Changes to This Privacy Policy

We reserve the right to modify or update this Privacy Policy at any time to reflect changes in legal, regulatory, or operational requirements. When we update our Privacy Policy, we will revise the "Last Updated" date at the top of the page.

In the event of material changes, we will provide you with additional notice through appropriate means, such as via email, in-app notifications, or prominent posting on our website, before the changes become effective.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal data and your rights.

Your continued use of our Services after the effective date of the updated Privacy Policy constitutes your acceptance of the changes.

15. Contact Information

If you have any questions, concerns, requests, or complaints regarding this Privacy Policy or our data protection practices, please contact us using the following details:

  • Email: info@splatware.com
  • Address: Leydenallee 94, 12165 Berlin, Germany

We will endeavor to respond to your inquiries in a timely manner and in accordance with applicable data protection laws. You also have the right to lodge a complaint with your local data protection authority if you believe that your rights under GDPR or other applicable laws have been infringed.