Privacy Policy 2022. 05. 22
This privacy policy (the “Policy”) is established by Model Solution (24, Beotkkot-Ro 20-Gil Geumcheon 11 Seoul 08582 South Korea). Should you have any question about the collection and processing of your personal data by Model Solution, please contact our Data Protection Officer at info.sec@model-solution.com. Please read this Policy carefully to understand our policies and practices regarding your personal data and how we will process and treat it. By using a Model Solution website, by calling Model Solution or by otherwise giving us your personal data, you agree to this Policy. Overall, we respect the privacy rights of our clients and recognize the importance of protecting the information that is collected about them.
1. Acceptance of the Policy and Consent
By reaching out to Model Solution, by whatever means used, we may collect and process a certain amount of personal data that relates to the user of the system.
The Policy shall apply to any case in which a user reaches out to us, whatever the method or medium used. It details the conditions under which we may collect, keep, use and save information that relates to the user, as well as the choices that the user has in relation to the collection, utilization and disclosure of personal data. In any case, the user must acknowledge that they have read and understood this Policy and agree to be bound by it and to comply with all applicable laws and regulations. The user must also acknowledge that they have read and understood any terms of use that apply to our website and agree to be bound by them. Reaching out to Model Solution forms a valid consent to any and all processing of data as described and detailed in this Policy. The user may withdraw their consent at any time, and request that we cease to process their data and/or delete it, although this will not affect the validity of any earlier processing. Please note that Model Solution may also process the user’s personal data on another legal basis to insure the proper functioning of our website when a user accesses the website. If the user does not agree to this Policy or otherwise fails to provide some necessary personal data to us (Model Solution will inform the user when this is the case, for example, by making required information clear in our registration forms), (a) the individual must not use our websites or apps and (b) Model Solution may not be able to provide the user with our goods and/or services.
What are the sources of personal data?
This Policy applies to personal data that Model Solution collects from or about users from the following sources: Model Solution websites or mobile sites.
- E-mail, text and other electronic messages. Electronic communications between users and Model Solution. (together “E-mail”)
- The Model Solution call center. Calls to any customer service number operated by or for Model Solution.
- Other sources where applicable, including publicly available information as well as through the use of CCTV cameras.
2. Which personal data we collect?
Depending both on (i) the services provided by Model Solution and used by a user, as well as (ii) the source from which the processed personal data originates and (iii) the user’s choices and configuration of their terminal (with respect in particular to cookies and other tracers), the following personal data may be collected and processed by Model Solution.
a. Data communicated by you
When a user reaches out to us, we may ask the individual to supply personal information such as :
- Name
- E-mail address
- Telephone number
- Company Name
- Address
This information is used to set up and manage a user’s personal information with Model Solution and/or any order that the user may have placed with Model Solution. This information may also be used to contact the noted individual. The information provided is also used to better identify user preferences and wishes in relation to products we offer. Personal data that is indispensable for us to fulfil the purposes that are described in this Policy (see Clause 5) is marked with an asterisk on various pages of our websites and/or underlined as required upon any contact the user may have with Model Solution. Should the user not fill in these mandatory fields or otherwise not provide Model Solution with required information, Model Solution may not be able to process the user’s requests and/or provide the user with requested products and services. Other personal data the user may communicate to us is purely optional and allows us to know the user better and to improve our communications and services accordingly. Model Solution may also collect data from publicly available sources, which shall be considered as data having been communicated by you. E-mail address: we may use your E-mail address in order to send you emails in relation to our products and services. Data within E-mails: Should you send us an E-mail, we may keep all information contained in the E-mail, especially in order to resolve your inquiries or otherwise assist you.
b. Data collected in relation to the use of Model Solution websites or through E-mails
When an individual accesses, visits or browses the Model Solution website, or receives and/or answers E-mails from Model Solution, the web server automatically registers details of the individual’s access and actions. This includes information about activity on and interaction with Model Solution websites and/or E-mail, such as the individual’s IP address, the device or browser type being used, the webpage the individual visited before coming to Model Solution websites, and identifiers associated with individual devices, as well as any log information. This information enables Model Solution to analyze how Model Solution websites are being accessed and used, and to track performance of the websites as well as of any service offered on or through the Websites. Location Information in particular: an individual’s devices (depending on their settings) may transmit location information to us, in particular through Model Solution websites. Model Solution uses this information to customize, improve and protect company websites. For example, we may use location information to determine local language preferences, or to geotag a post. Hypertext links to third-party websites or sources: we may propose hypertext links from our websites to third-party websites or Internet sources. We do not control and cannot be held liable for third parties’ privacy practices and content. Please read third-party privacy policies carefully to find out how they collect and process personal information Cookies and similar technologies: All this information and related data is collected automatically, in particular through cookies (performance and tracking cookies, functional cookies, technical cookies, browser cookies, etc.). We also use Google analytics (see Clause 4).
c. Data collected from a social network
When individuals authorize a third party social network (Facebook, Instagram, etc.) to share information and data with us, we may receive any data that they publicly share on those social networks as well as any information that is part of their profile or that they allow the social network to share (name, electronic address, gender, profile picture, user code, list of friends or contacts, etc.). We also receive information pertaining to profiles when individuals use a social network functionality integrated to Model Solution websites or that are used to interact with us through a social network. Users should at all times, be aware of the terms of use and privacy policies that apply to third-party social networks and are of the website’s exclusive responsibility.
3. Cookies
a. What are cookies?
Cookies are small text files which are placed on a computer or mobile phone when an individual visits a website. They are widely used in order to make websites work or to work more efficiently. Cookies help websites recognize a device and remember information about an individual’s visit (e.g., your preferred language, font size and other preferences). Most web browsers are set up to accept cookies, although a browser can be set to refuse all cookies or to indicate when a cookie is being sent, as mentioned under paragraph c hereunder. Note, however, that some portions of websites may not work properly if cookies are refused. Model Solution also uses web beacons (also known as an "action tag" or "clear GIF technology"), or similar technology, which helps analyze the effectiveness of websites by measuring, for example, the number of visitors to a site, how many visitors clicked on key elements of a site or what web pages were visited.
b. How we use cookies?
Cookies allow Model Solution to operate services as users have requested, facilitate user navigation on our websites and related use of their features, so as to provide users with a seamless experience and relevant ads. We may collaborate with other companies, including social or advertisement networks, which place cookies, web beacons or other tracking technology on company websites to collect or receive information from our websites and elsewhere on the internet and use that information to provide measurement services and target ads.
c. How to manage your cookies preferences?
Most browsers allow management of cookies preferences by changing browser settings. If you consent to Model Solution use of cookies but later wish to opt out, you may delete the cookies which have been set and change your browser settings to block any further cookies. The “Help” function of your browser should tell you how. Alternatively, the following links provide instructions for managing cookie settings of commonly used browsers:
In addition, you may wish to visit www.aboutcookies.org, which contains comprehensive information on how to do this on a wide variety of browsers. Please note that if you block cookies, your experience on our Website may be impacted.
4. Google Analytics
It is possible that some or all Model Solution websites use Google Analytics, an internet site analysis service supplied by Google Inc. (“Google”). Google Analytics uses cookies which are text files placed on a computer to help to analyze the use made of websites by its users. The data generated by cookies concerning use of Model Solution websites (including your IP address) will be forwarded to, and stored by, Google on servers located in the United States. Google will use this information to evaluate use of websites, compile reports on site activity for its publisher and provide other services relating to the activity of websites and use of the internet. Google may release related data to third parties if there is a legal obligation to do so or when third parties process data for the account of Google including, in particular, the publisher of the websites. Google will not cross-reference your IP address with any other data held by Google. As mentioned under clause 3 above, you may deactivate the use of cookies by selecting appropriate parameters on your navigator. However, deactivation of this kind might prevent the use of certain functions of Model Solution websites. By using Model Solution websites, a user specifically consents to the processing of their personal data by Google under the conditions and for the purposes described above. If an individual using the website does not want Google Analytics to be used in their browser, they can install the Google Analytics browser add-on at https://tools.google.com/dlpage/gaoptout.
5. How we use your personal data?
We use data and information collected to :
- Offer all functions of Model Solution websites;
- Allow for correct execution of all functions of Model Solution websites;
- Personalize use of Model Solution websites as well as enhance noted websites and all related functions;
- Interact with users and answer questions or remarks, including notification of users of any changes in relation to services and/or products;
- Fulfill any contract, especially in relation to products that a customer may have purchased or otherwise received, in particular through Model Solution customer service for repairs;
- Manage membership and/or client accounts, including our online shop to pass and/or manage any order, for the purpose of offering superior customer service and to provide any information that customers may request;
- Proceed to antifraud and blacklist management for any case in which a person has been implicated in fraud regarding our products, services or trademarks. This allows Model Solution to, modify or refuse the offender’s access to services or products as well any entry into a contact with Model Solution. This also allows the company communicate with and defend Model Solution’s rights before state authorities;
- With proper consent or within the applicable rules and regulations, provide customers with any information that could be useful or of interest, especially regarding Model Solution products and promotional opportunities, especially through newsletters, invitations and other publications;
- Take all required measures in relation to online transactions, especially to prevent fraud and payment defaults.
6. Data retention
Model Solution, as a matter of business practice, does not retain personal data longer than necessary for purposes stated and to comply with legal requirements, unless otherwise agreed to by Model Solution and the user of Model Solution websites. User data may be stored and/or archived for a limited period, which shall not exceed 10 years of time (unless legal obligations or regulations require or allow a longer retention period). At the end of the applied retention period, Model Solution shall delete user data contained in the system.
7. How do we share and/or transfer your personal data?
Personal data shall be processed by Model Solution. It may also be transferred in case of a reorganization of Model Solution, including merger, takeover, de-merger, and in general any reorganization operation. Your personal data may also be transferred to the following third-parties :
- Third-party providers in relation to the services offered on Model Solution websites, especially any IT service suppliers, consultants, providers of hosting and maintenance services of the websites and any other third party processing personal data on our behalf, as well as any postal and payment service providers, in order to fulfill and execute orders that have been placed on or through Model Solution websites. Third-party subcontractors, in order to provide product, service or information, as well as any customer service that was asked for., or for interest-based advertising based on data collected from the customer and/or through use of Model Solution websites. Such third-parties include carriers as well as payment and fraud management service providers.
- Any person or entity required by law or judicial order: Model Solution may disclose data to third parties if we determine that such disclosure is reasonably necessary to comply with existing laws, to protect our rights or prevent fraud or abuse. When Model Solution receives law enforcement or national security requests for information, we scrutinize such requests carefully, especially if they are vague, overbroad or otherwise unlawful. When legally permitted and reasonably possible, we may provide a customer with notice that their information is being requested by a government agency. In any case, both the assessment of the request as well as the possibility of informing the customer of that request are at the sole discretion of Model Solution, and that the company may not be held liable from a civil, criminal or administrative point of view.
Model Solution may transfer personal data to third parties only when it is necessary to provide a product or service to the customer. In such cases, related third parties are prohibited from using this data beyond what is necessary to provide the relevant product or service to the customer. In some specific cases when this level of protection is not guaranteed, Model Solution will obtain prior consent or establish with the recipient of personal data a contractual framework or sufficient safeguards that ensure an adequate level of protection abroad. Customers or users may request access to a copy of these safeguards by contacting us.
8. Security measures
We strictly apply the principles of data protection and implement appropriate technical and organizational measures to limit the processing of user data as well as ensure its security. Only personal data which is necessary for completing a request or order is processed by Model Solution, and all access to personal data is limited to what is required as detailed under clause 5 of this Policy.
9. Your choices
We strive to provide users with choices regarding personal data that is provided or that is otherwise collected, in particular through our websites. The following mechanisms provide users the following control over their personal data. Regarding Cookies and similar technologies: users can select browser settings to refuse all or some browser cookies, or provide alerts when cookies are being used, as mentioned under clauses 3 and 4 above.
10. Your rights
Users have the right to request access to information about personal data related to that individual which has been processed by us. Alternatively, system users can contact Model Solution at info.sec@model-solution.com. Users may also have the right to request that we :
- Correct or erase related personal data or restrict processing of their data.
- Transfer personal data to a third party.
- Stop processing related personal data in cases where we rely on a user’s consent and do not have another legal basis to continue processing noted data.
- Stop using personal data to build a client profile. In this case, the user will no longer benefit from customized offers or services.
- Stop sending information about our offers and news
All access, correction and deletion requests can also be sent by regular mail along with your contact details (phone number and email) to the address referred to at the beginning of the Policy. Model Solution may ask for proof of identity (copy of an official Identification Document with a photo mentioning your date and place of birth). The request is free of charge unless the request is unfounded or excessive (e.g. if an individual has already requested such personal data multiple times in the last twelve months or if the request generates an extremely high workload). In such case, we may charge a reasonable request fee according to applicable data protection legislation. Model Solution encourages users to contact us if they feel that their personal data has been mishandled or if we have failed to meet their expectations.
11. Updates to the Policy
Model Solution may revise or update this Policy from time to time. Any changes to this Policy will become effective upon posting of the revised Policy on Model Solution websites.
12. Jurisdiction and applicable law
This Policy and all matters arising out of or related to this Policy shall be governed by the substantive laws of South Korea, without regards to conflicts of laws and principles thereof. Any controversy, claim or dispute between you and us arising out of or relating to this Policy shall be subject to the exclusive jurisdiction of the Supreme Courts of South Korea, and each party hereby irrevocably consents to the jurisdiction and venue of such Court.
13. Contact
For any question or request regarding your personal data, please contact our Data Protection Officer at info.sec@model-solution.com.
Please note that the representative of Model Solution in Asia is at : 24, Beotkkot-Ro 20-Gil Geumcheon 11 Seoul 08582 (South Korea)