Privacy Notice

1. Scope and Updates of This User Privacy Notice

This User Privacy Notice applies to your use of this website and all Majero

Operations LLC (doing business as Majero Models) services and sites

(collectively the “Services”), regardless of how you access or use these

Services, including access via mobile devices and third-party apps (e.g.,

Facebook, Twitter).

This User Privacy Notice also applies if explicit reference is made to it via a

link or in a similar manner (e.g. on websites of partners on which Services

from Majero Operations LLC are offered).

We may change this User Privacy Notice at any time by posting the revised

User Privacy Notice on this website and indicating the effective date of the

revised User Privacy Notice.

You may have rights under the California Consumer Protection Act. 

What Personal Data We Collect and Process

We collect personal data when you use our Services, provide us with

information via a web form, participate in online community discussions or

otherwise interact with us. The data we collect depends on the context of your

interactions with Majero Operations LLC and the choices you make. You have

choices when it comes to the technology you use and the data you share.

When we ask you to provide personal data, you can decline. Some Services

may require personal data to provide you with a service. If you choose not to

provide data required to provide you with a service, you cannot use that

particular service. Likewise, where we need to collect personal data by law or

to enter into or carry out a contract with you, and you do not provide the data,

we will not be able to enter into the contract or, if this relates to an existing

service you’re using, we may have to suspend or cancel that service. We will

notify you if this is the case at the time. Where providing the data is optional,

and you choose not to share personal data, features like personalization that

use such data will not work for you. We also collect personal data from other

sources (such as public sources and/or third parties).

In total, we collect the following personal data:

2.1 Personal Data You Provide When Using Our Services

 Data that identifies you, such as your name, address, telephone numbers

or email addresses, or your user name that you provide when accessing

certain Services.

 Identification data and tax identification numbers that you may provide

when engage with us as a content provider.

 You may provide us with information through a web form, by participating

in community discussions, inquiries, dispute resolution, customer service

calls recorded with your consent, or if you contact us for any other reason

regarding our Services.

 Other data that we are required or entitled by applicable law to collect and

process and that we need for your authentication or identification, or for the

verification of the data we collect.

2.2 Personal Data We May Collect When You Use Our Services

 Data regarding your interactions with our Services and your

communications with us.

 Computer and connection information, such as statistics regarding your

use of services from Majero Operations LLC, information on data traffic to

and from websites, referral URL, your IP address, your access times, your

browser history data, your language settings and your weblog information.

 Content consumption data. Information about media content (e.g., TV,

video, and apps) you access through our website.

 Social data and other information about your relationships and interactions

between you, other people, and organizations in connection with the social

media and other aspects of our website.

 Content of your files and communications you input, upload, receive,

create, and control, such as comments, suggestions, feedback, survey

data, product reviews you write, and other posts.

 Other content we collect when providing products to you include:

communications, including audio, video, text (typed, inked, dictated, or

otherwise), in a message, email, or call.

2.3 Personal Data We Collect in Connection with the Use of Cookies and

Similar Technologies

We use cookies, web beacons and similar technologies to collect data while

you use our Services. We collect this data from the devices (including mobile

devices) that you use to engage our Services. The data collected includes the

following usage- and device-related information:

 Data about the pages you visit, the access time, frequency and duration of

visits, the links on which you click and other actions you take as part of

your use of our Services and email content.

 Your user segment.

 Model or device type, operating system and version, browser type and

settings, device ID or individual device identifier, advertisement ID,

individual device token, and cookie-related data (e.g. cookie ID).

 The IP address from which your device accesses the Services.

 Location data, including the location data of your mobile device. Please

note that most mobile devices allow you to manage or disable the use of

location services for all applications in the settings menu.

2.4 Personal Data from Other Sources

We also collect personal data about you from other sources and from third

parties to the extent permitted by applicable law. We protect data obtained

from third parties according to the practices described in this statement, plus

any additional restrictions imposed by the source of the data. These third-

party sources vary over time and include:

 Services that make user-generated content from their service available to

others, such as local business reviews or public social media posts.

 Communication services, including email providers and social networks,

when you give us permission to access your data on such third-party

services or networks.

 Service providers that help us determine your device’s location.

 Publicly available sources, such as open government databases.

We combine or connect the personal data we collect from you with data from

these other sources. Where personal data is disclosed to us by third parties,

we take steps to confirm that the information has been collected with your

consent and/or that these third parties are otherwise legally permitted to

disclose your personal data to us.

2.5 Social Network Data You Share with Us

 We allow you to share personal data with social networks, to use social

networks to create a Majero Operations LLC account or to link your Majero

Operations LLC account to a social network. These social networks may

automatically provide us with access to certain personal data they have

stored about you (e.g. content you have viewed or enjoyed, information

about the advertisements you have been shown or clicked on, etc.). You

can determine the personal data that we can access through the privacy

settings of each social network.

 If you give us access to content pages, your grant of access is your

consent that we may, for at least two years, or until you withdraw your

consent or are no longer connected to the social network, share with and

collect from social networks information regarding your viewing of videos.

 We may also use plug-ins or other technologies from various social

networks. If you click on a link displayed through a social network plug-in,

you voluntarily connect to that social network.

3. Purposes and Legal Basis for Data Processing and Categories of

Recipients

We process your personal data for various purposes and pursuant to various

legal bases. We process your personal data primarily to provide and improve

our Services, to provide you with a personalized user experience on this

website, to contact you about your interactions with Majero Operations LLC

and our Services, to provide customer service, and to detect, prevent, mitigate

and investigate fraudulent or illegal activity.

Below you will find a summary of the purposes for which we process your

personal data, including the categories of recipients to whom we transmit

personal data for the purposes stated, sorted by legal basis:

3.1 Data Processing and Contractual Obligations.  We process your personal

data in order to fulfil our contract with you and to provide you with our

Services. This includes the following purposes:

 Processing of data relating to you for the purpose of entering into a

contract with you and executing it.

 Provision of our Services, including but not limited, providing and

enhancing features of the website, providing other services you may use,

and ensuring the functionality of our Services.

 Resolving disputes and providing other services within the scope of

customer service. For these purposes, we may contact you via your email,

telephone, by SMS or push notification on your mobile device, or by postal

mail.

 Processing of general location data (such as IP address or postal code) in

order to provide you with location-based services.

 Enforcement of our User Agreement, this User Privacy Notice and other

rules and policies.

 Publication and promotion of your content on our websites.

3.2 Data Processing and Legal Obligations.  We process your personal data

in order to comply with legal obligations to which we are subject. This includes

the following purposes:

 Participation in proceedings (including judicial proceedings) conducted by

public authorities or government agencies, in particular, for the purpose of

detecting, investigating and prosecuting illegal acts.

 Prevention, detection and mitigation of illegal activities.

 Ensuring the information security of our Services.

 Retention and storage of your personal data to comply with specific legal

retention requirements (for more information on Majero Operations LLC’s

storage of your data, see Storage Duration and Erasure).

Where necessary, we transmit your personal data to processors and the

following recipients for one or several of the purposes described above:

 Law enforcement agencies, courts, government agencies or public

authorities.

 Third party service providers

 Third parties who are involved in judicial proceedings, in particular, if they

submit a legal order, court order or equivalent legal order to us.

3.3 Limited Third Party Data Processing.  We process your personal data

where necessary for the purposes of the legitimate interests pursued by us or

by a third party, except where such interests are overridden by your interests

or fundamental rights and freedoms. In order to reconcile our legitimate

interests with your rights, we have introduced appropriate control

mechanisms. On this basis, we process your data for the following purposes:

 Participation in proceedings (including judicial proceedings) conducted by

courts, law enforcement agencies, government agencies or public

authorities, in particular for the purpose of detecting, investigating and

prosecuting illegal acts, unless there is a statutory obligation to this effect,

and we may legitimately assume that the disclosure of the data is

necessary to avert imminent disadvantages or to report a suspicion of an

illegal act. In such cases, we will only disclose what we believe is

necessary.

 Protection of the legitimate interests of third parties in connection with civil

law disputes, unless there is a statutory obligation to this effect, if we may

legitimately assume that it is legally necessary to disclose the data to such

third parties.

 Prevention, detection, mitigation and investigation of fraud, security

breaches and other prohibited or unlawful activities, including the

assessment of corresponding risks (e.g. through the use of captchas or the

telephone number stored in your Majero Operations LLC account for two-

factor authentication), unless there is a statutory obligation to this effect.

 Monitoring and improvement of the information security of our Services,

unless there is a statutory obligation to this effect.

 Analysis and improvement of the Services, e.g. by reviewing information

from users about blocked or crashed pages in order to identify and solve

problems and to provide you with an improved user experience, including

as part of product development.

 Analysis of telephone conversations with our customer service that we

recorded with your consent.

 Customization of page content to display the items and services you may

like based on the actions you take.

 Evaluation of the quality and success of our email marketing campaigns

(e.g. through analysis of opening and click rates).

 Assertion of or defense against legal claims

Where necessary, we transmit your personal data to processors and the

following recipients for one or several of the purposes described above:

 Law enforcement agencies, courts, government agencies or public

authorities, intergovernmental or supranational bodies

 Third parties who are involved in judicial proceedings

 Other companies in the context of a company acquisition

 In the event of an investigation for fraud, intellectual property infringement,

product piracy or other unlawful activity, if we, in our sole discretion, deem

the investigation of such incident necessary or useful. In such cases, we

will disclose the seller’s name, address, city, zip code, country, telephone

number, email address and company name and bind the party by a

worldwide non-disclosure agreement to treat the data as confidential

 Information about your right to object to processing based on our legitimate

interests can be found below under Rights as a Data Subject and, with

regard to the use of cookies and similar technologies, below under Cookies

& Similar Technologies.

We will do not sell or otherwise pass on your personal data to third parties for

their marketing or advertising purposes nor will we sell or otherwise make it

available to third parties for a fee.

3.4 How to Access and Control Your Personal Data

You can access and control your personal data by contacting Majero

Operations LLC. For instance:

 If Majero Operations LLC obtained your consent to use your personal data,

you can withdraw that consent at any time.

 You can request access to, erasure of, and updates to your personal data.

 If you’d like to port your data elsewhere, you can use tools Majero

Operations LLC provides to do so, or if none are available, you can contact

Majero Operations LLC for assistance.

You may have these rights under applicable laws, including the EU General

Data Protection Regulation (GDPR), but we offer them regardless of your

location. In some cases, your ability to access or control your personal data

will be limited, as required or permitted by applicable law.

3.5 Browser-based Controls

When you use a browser, you can control your personal data using certain

features. For example:

 Cookie controls. You can control the data stored by cookies and withdraw

consent to cookies by using the browser-based cookie controls described

in the Cookies section of this privacy statement.

 Tracking protection. You can control the data third-party sites can collect

about you using Tracking Protection in Internet Explorer (versions 9 and

up). This feature will block third-party content, including cookies, from any

site that is listed in a Tracking Protection List you add.

 Browser controls for “Do Not Track.” Some browsers have incorporated

“Do Not Track” (DNT) features that can send a signal to the websites you

visit indicating you do not wish to be tracked. Because there is not yet a

common understanding of how to interpret the DNT signal, Majero

Operations LLC services do not currently respond to browser DNT signals.

4. Storage Duration and Erasure

Your personal data will be stored by us in accordance with applicable data

protection laws to the extent necessary for the processing purposes set out in

this User Privacy Notice. Subsequently, we will delete your personal data in

accordance with our data retention and deletion policy or take steps to

properly render the data anonymous, unless we are legally obliged to keep

your personal data longer (e.g. for tax, accounting, auditing, or other legal

purposes). As far as legally permissible or required, we restrict the processing

of your data instead of deleting it (e.g. by restricting access to it). This applies

in particular to cases where we may still need the data for the execution of the

contract or for the assertion of or defense against legal claims. In these cases,

the duration of the restriction of processing depends on the respective

statutory limitation or retention periods.  The length of time we retain personal

data may vary depending on the Services we provide and our legal obligations

under applicable national law.

The following factors typically affect the retention period:

 Necessity for the provision of our Services: This includes such things as

executing the User Agreement with you, maintaining and improving the

performance of our products, keeping our systems secure, and maintaining

appropriate business and financial records. Most of our retention periods

are determined on the basis of this general rule.

 Special categories of personal data: If we store special categories of

personal data, a shorter retention period is usually appropriate.

 Consent-based processing of personal data: If we process personal data

on the basis of consent (including consent to the extended storage), we

store the data for as long as necessary in order to process it according to

your consent.

 Statutory, contractual or other similar obligations: Corresponding storage

obligations may arise, for example, from laws or official orders. It may also

be necessary to store personal data with regard to pending or future legal

disputes. Personal data contained in contracts, notifications and business

letters may be subject to statutory storage obligations depending on

national law.

5. Rights as a Data Subject

Subject to possible restrictions under national law, as a data subject, you have

the right to access, rectification, erasure, restriction of processing and data

portability with regard to your personal data. In addition, you can withdraw

your consent and object to our processing of your personal data on the basis

of legitimate interests. You can also lodge a complaint with a supervisory

authority.

Your rights in detail:

 You can withdraw your consent to the processing of your personal data by

us at any time. As a result, we may no longer process your personal data

based on this consent in the future. The withdrawal of consent has no

effect on the lawfulness of processing based on consent before its

withdrawal.

 You have the right to obtain access to your personal data that is being

processed by us. In particular, you may request information on the

purposes of the processing, the categories of personal data concerned, the

categories of recipients to whom the personal data have been or will be

disclosed, the envisaged period for which the personal data will be stored,

the existence of the right to request rectification or erasure of personal data

or restriction of processing of personal data or to object to such

processing, the right to lodge a complaint with a supervisory authority, any

available information as to the personal data’s source (where they are not

collected from you), the existence of automated decision-making, including

profiling and, where appropriate, meaningful information on its details. You

may make such a request no more than two (2) times within any twelve

month period.

 You have the right to obtain from us without undue delay the rectification of

inaccurate personal data concerning you. Taking into account the

purposes of the processing, you have the right to have incomplete

personal data completed, including by means of providing a supplementary

statement.

 You have the right to obtain from us the erasure of personal data

concerning you, unless processing is necessary to complete a transaction,

detect wrongdoing (e.g., fraud, deception, etc.), repair errors, exercise the

right of freedom of expression and information, exercise of a legal right, for

compliance with a legal obligation, for reasons of public interest or for the

establishment, exercise or defense of legal claims.

 You have the right to obtain from us restriction of processing to the extent

that

o the accuracy of the data is disputed by you,

o the processing is unlawful, but you oppose the erasure of the personal

data,

o we no longer need the data, but you need it to assert, exercise or defend

legal claims or

o you have objected to the processing.

 You have the right to receive the personal data concerning you, which you

have provided to us, in a structured, commonly used and machine-

readable format and have the right to transmit those data to another

controller (“right to data portability”).

 You have the right to lodge a complaint with a supervisory authority. As a

rule, you can contact the supervisory authority of your usual place of

residence, your place of work or the registered office of the controller.

If your personal data is processed on the basis of legitimate interests, you

have the right to object to the processing of your personal data on grounds

relating to your particular situation. This also applies to profiling. If your

personal data is processed by us for direct marketing purposes, you have the

right to object at any time to the processing of your personal data for such

marketing, which includes profiling to the extent that it is related to such direct

marketing.

The exercise of the above data subjects’ rights (e.g. right to access or

erasure) is generally free of charge. Where requests are manifestly unfounded

or excessive, in particular because of their repetitive character, we may

charge an appropriate fee (at most our actual costs) in accordance with the

applicable statutory regulations or refuse to process the application.

You can exercise your rights as a data subject by directing an inquiry to:

Majero Operations LLC

P.O. Box 13474

Scottsdale, AZ 85267

info@majeromodels.com

 

6. Cookies & Similar Technologies

Cookies are small text files placed on your device to store data that can be

recalled by a web server in the domain that placed the cookie. We use

cookies and similar technologies for storing and honoring your preferences

and settings, enabling you to sign in, combating fraud, analyzing how our

products perform, and fulfilling other legitimate purposes.

We also use “web beacons” to help deliver cookies and gather usage and

performance data. Our websites may include web beacons, cookies, or similar

technologies from third-party service providers.

You have a variety of tools to control the data collected by cookies, web

beacons, and similar technologies. For example, you can use controls in your

internet browser to limit how the websites you visit are able to use cookies

and to withdraw your consent by clearing or blocking cookies.

Our use of cookies and similar technologies

Majero Operations LLC uses cookies and similar technologies for several

purposes, depending on the context or product, including:

 Storing your preferences and settings. We use cookies to store your

preferences and settings on your device, and to enhance your

experiences. Saving your preferences with cookies prevents you from

having to set your preferences repeatedly.

 Sign-in and authentication. We use cookies to authenticate you. When you

sign in using your personal Majero Operations LLC account, we store a

unique ID number, and the time you signed in, in an encrypted cookie on

your device. This cookie allows you to move from page to page within the

site without having to sign in again on each page. You can also save your

login information so you do not have to login each time you return to the

site.

 We use cookies to process information that helps us secure our products,

as well as detect fraud and abuse.

 Storing information you provide to a website. We use cookies to remember

information you shared. When you provide information to Majero

Operations LLC we store the data in a cookie for the purpose of

remembering the information.

 Social media. We may use social media cookies, including those that

enable users who are signed in to the social media service to share

content via that service.

 Majero Operations LLC uses cookies to enable you to provide feedback on

a website.

 We use first- and third-party cookies and other identifiers to gather usage

and performance data. For example, we use cookies to count the number

of unique visitors to a web page or service and to develop other statistics

about the operations of our products.

 Majero Operations LLC uses cookies to understand and improve how our

products perform. For example, we use cookies to gather data that helps

with load balancing; this helps ensure that our websites remain up and

running.

In addition to the cookies Majero Operations LLC sets when you visit our

websites, third parties can also set cookies when you visit Majero Operations

LLC sites. For example:

 Companies we hire to provide services on our behalf, such as site

analytics, place cookies when you visit our sites. See opt-out links below.

 Companies that deliver content, such as videos or news, place cookies on

their own. These companies use the data they process in accordance with

their privacy policies, which may enable these companies to collect and

combine information about your activities across websites, apps, or online

services.

How to control cookies

Most web browsers automatically accept cookies but provide controls that

allow you to block or delete them. Certain features of Majero Operations LLC

products depend on cookies. If you choose to block cookies, you cannot sign

in or use some of those features, and preferences that are dependent on

cookies will be lost. If you choose to delete cookies, any settings and

preferences controlled by those cookies, including advertising preferences,

are deleted and will need to be recreated.

Our use of web beacons and analytics services

Some Majero Operations LLC webpages contain electronic tags known as

web beacons that we use to help deliver cookies on our websites, count users

who have visited those websites, and deliver branded products. We also

include web beacons or similar technologies in our electronic communications

to determine whether you open and act on them.

In addition to placing web beacons on our own websites, we sometimes work

with other companies to place our web beacons on their websites. This helps

us to, for example, develop statistics on how often clicking on a link on a

Majero Operations LLC website results in a particular activity. It also allows us

to understand your activity on the website of a Majero Operations LLC partner

in connection with your use of a Majero Operations LLC service.

Finally, Majero Operations LLC products often contain web beacons or similar

technologies from third-party analytics providers, which help us compile

aggregated statistics about the effectiveness of our promotional campaigns or

other operations. These technologies enable the analytics providers to set or

read their own cookies or other identifiers on your device, through which they

can collect information about your online activities across applications,

websites, or other products. However, we prohibit these analytics providers

from using web beacons on our sites to collect or access information that

directly identifies you (such as your name or email address).

7. Data Security

Majero Operations LLC is committed to protecting the security of your

personal data. We use a variety of security technologies and procedures to

help protect your personal data from unauthorized access, use, or disclosure.

For example, we store the personal data you provide on computer systems

that have limited access and are in controlled facilities. When we transmit

highly confidential data (such as a credit card number or password) over the

internet, we protect it through the use of encryption. Majero Operations LLC

complies with applicable data protection laws, including applicable security

breach notification laws.

8. Other Important Information Regarding Data Protection

This section contains important additional information about the protection of

personal data in connection with the use of our Services, including whether

you are required to provide personal data.

Personal data relating to third parties

If you provide us with personal data relating to another person, you must

obtain the consent of this person or the disclosure of the data to us must be

otherwise legally permissible. You must inform the other person of how we

process personal data in accordance with our User Privacy Notice.

Collection of data from children

We follow all applicable data protection laws when collecting personal

information online from children. For example, in the EU we do not collect

personal information from children under 16 years of age unless we get

consent from a parent. Similarly, in the U.S., we obtain verified parental

consent when collecting personal information from children younger than 13.

9. California Consumer Privacy Act

If you are a California resident, we process your personal data in accordance

with the California Consumer Privacy Act (CCPA). This CCPA section of our

Privacy Statement contains information required by the CCPA and

supplements our Privacy Statement.

 Sale. We do not sell your personal data. So, we do not offer an opt-out to

the sale of personal data.

 Your Rights. You have the right to request that we (i) disclose what

personal data we collect, use, disclose, and sell and (ii) delete your

personal data. You may make these requests yourself or through an

authorized agent. If you use an authorized agent, we may request

information from you or the agent demonstrating that the agent is acting on

your behalf.

o You may exercise your rights by contacting us by email

(info@majeromodels.com). Upon receipt of your request, we will send you

a verification form by email or postal mail. To complete your request,

please respond to the verification form when you receive it. To verify your

identity, we may require you to provide certain information, including name,

email address, postal address, or other information you may have provided

us in relation to the Services. In addition, if you ask us to provide you with

specific pieces of personal information, we will require you to sign a

declaration under penalty of perjury that you are the consumer whose

personal information is the subject of the request. Under the CCPA, you

may designate an authorized agent to make a request on your behalf but

the agent will need to complete the verification process, including the

submission of proof that it has been designated to act on your behalf. For

access and deletion requests made by an authorized agent on your behalf,

we also may require you to verify your own identity directly with us (as

described above).

o Please understand that Majero Operations LLC cannot delete personal

information in those situations where our retention is required for our own

internal business purposes or otherwise permitted by the applicable law

(such as fraud prevention or legal compliance). In these situations, we will

retain your information in accordance with our records retention program

and securely delete it at the end of the retention period.

 Non-Discrimination. You have a right not to receive discriminatory

treatment if you exercise your CCPA rights. We will not discriminate

against you if you exercise your CCPA rights.

 Personal Information Processing. In the bulleted list below, we outline

the categories of personal data we collect, the sources of the personal

data, our purposes of processing, and the categories of third-party

recipients with whom we share the personal data. For a description of the

data included in each category, please see the Section 3 of the Privacy

Notice: Purposes and Legal Basis for Data Processing and Categories of

Recipients.

10. Contact Us

Questions and requests regarding this Privacy Policy or the information we

collect from you are welcome and should be addressed to:

Majero Operations LLC

P.O. Box 13474

Scottsdale, AZ 85267

info@majeromodels.com

Last Modified: August 15, 2023