Privacy Notice

1. Introduction

This Privacy Notice explains how Ten24 Media Ltd, ("Ten24", “we”, “our”, “us”) outline our practices regarding the collection, use, and disclosure of Personal Data when you participate in a photography shoot and the choices you have regarding your Personal Data relating to the photography. We have developed this Privacy Notice to inform You of the data we collect, what we do with Your Personal Data, what we do to keep it secure as well as the rights and choices You have over Your Personal Data. It is important that You read this notice so that You are aware of how and why we are using such information. Without any definition of what the project is or what it aims to achieve it could be seen as confusing. Removed reference as the rest of the document should explain what is collected and why.

We have developed this Privacy Notice to inform You of the data we collect, what we do with Your Personal Data, what we do to keep it secure as well as the rights and choices You have over Your Personal Data. It is important that You read this notice so that You are aware of how and why we are using such information. Without any definition of what the project is or what it aims to achieve it could be seen as confusing. Removed reference as the rest of the document should explain what is collected and why.

2. Definitions

For the purposes of this Privacy Notice:

Company, referred to as either Ten24 Media Ltd, ("Ten24", “we”, “our”, “us”) in this Agreement

Data Controller, for the purposes of UK GDPR, refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data. For UK GDPR, the Company is the Data Controller.

Data Processor, for the purposes of UK GDPR, refers to the Company’s Service Providers.

Data Protection Legislation, as defined in the Data Protection Legislation section below.

Digital Image, means virtual 3-dimensional polygonal models, or otherwise digital captures of a face, head and neck including part of the upper bust/torso area to create a 3-dimensional digital likeness.

Model Release, means a form that we will ask you to read, agree and sign if you participate in a photography shoot.

Personal Data is any information that relates to an identified or identifiable individual.For the purposes of UK GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity.

Privacy Notice, means this document that outlines our practices regarding the collection, use, and disclosure of Personal Data when you participate in a photography shoot.

You/Your means the individual who has their Personal Data processed as part of the model photography.

3. Data Protection Legislation

Throughout this document we refer to Data Protection Legislation.

Where data is processed by a controller or processor established in the United Kingdom (UK) or comprises the data of people in the UK, it is subject to the UK General Data Protection Regulation (‘UK GDPR’) and the Data Protection Act 2018, as well as any local data protection implementation laws. This includes any replacement legislation coming into effect from time to time.

If you wish to contact us about this document our contact details are:

Lydgate House, Lydgate Lane, Sheffield, England, S10 5FH

Email: sapiens@ten24.info

Ten24 is responsible for Personal Data you share with us, or which we generate or obtain about you. That makes TEN24 a data controller in connection with that data.

We have appointed a data privacy officer who is in charge of making sure that your Personal Data is kept safe throughout the time that we are responsible for it, and that it is used in the ways described in this Privacy Notice. If you have any questions about this Privacy Notice or our data protection practices please contact the privacy manager, using the details above.

4. The Personal Data we collect about you

We collect the following types of Personal Data during your participation in the photography session:

1. Identity data: Your name and age bracket, your email address, necessary for identifying you as a participant.
2. Biometric data: Photographs and virtual 3-dimensional polygonal models (“3D scans”) of your face, head and neck including the upper bust/torso area, capturing unique physical features.
3. Special category data: Sensitive data such as race or ethnicity, collected only with your explicit consent.
4. Descriptive text, keywords, or metadata: Information provided by you or recorded to uniquely identify the digital images created during your participation.
5. Digital Image content: Photographic images and the resulting 3D models from the scans/images.
6. Voluntary data: Additional Personal Data you may choose to provide, including more detailed information on race/ethnicity, collected only with your explicit consent.

5. How we collect your Personal Data

We use different methods to collect data from you including:

Direct interactions. You may give us your Identity and contact data by filling in the Model Release form. This happens when you visit our studio or other similar locations for a photography/body scan session.

Imagery Capture. If you are a model who attends our studio for a body scan various items of Personal Data about you will be captured and processed as part of that scan. This will include not only imagery data but will also include some biometric information. None of this data will be used for the purposes of identification by Ten24, only for the creation of a 3D model and/or resulting products derived from the captured images. This will be explained in more detail prior to your participation in the scan.

6. Use of Data

We use the Personal Data we collect for the following purposes:

1. Creation and Display: Developing and displaying your image and representations of you in the form of digital 3D models and photographs in various media, such as video games, television, and films.
2. Development: Enhancing machine learning algorithms and artificial intelligence technologies.
3. Training: Generating datasets for the training and improvement of generative AI and machine learning models.
4. Sales and Distribution: Selling the 3D models/photographs on our store (3D Scan Store) and third-party stores such as but not limited to the Unreal Marketplace.

7. Legal basis

As a data controller, Ten24 is responsible for identifying the legal basis for processing your Personal Data. Ten24 relies on the following:

You have the right at any time to withdraw your consent and in such circumstances Ten24 will stop the processing of that specific information, where technically possible. Please note though that any images that have been sold on to a third party may not be able to be retrieved by Ten24. However, Ten24 may still need to retain records of that information and undertake processing relating to that information as part of performing/complying with any regulatory and legal obligations.

8. Sharing and Disclosure of Data

Your Personal Data may be shared with third parties, including:

1. Technology Partners: For developing and enhancing machine learning models.
2. Academic and Research Institutions: For analysis and research related to artificial intelligence.
3. Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this privacy policy.
4. government bodies and regulatory authorities, including the Police and other crime prevention and detection agencies and the applicable supervisory authority responsible for privacy/data protection;
5. the courts and other dispute resolution arbitrators and mediators, other parties to legal proceedings; or
6. If we need to share Personal Data in order to establish, exercise or defend our legal rights – this includes providing Personal Data to others for the purposes of detecting and preventing fraud.

We use Service Providers (“Data Processors”) who are third parties who provide elements of services for us.

We have Data Processor Agreements in place with our data processors. This means that they cannot do anything with Your Personal Data unless we have instructed them to do it. They will not share Your Personal Data with any organisation apart from us or further sub-processors who must comply with our Data Processor Agreement. They will hold Your Personal Data securely and retain it for the period we instruct.

We ensure that all third parties respect the security of your Personal Data and comply with applicable data protection laws.

9. Data Security and Retention

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. We will only keep your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

If you fail to provide Personal Data
Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you - for example, if you don’t allow us to capture Digital Image content about you, we will not be able to enter into that contract with you.

10. Your Rights

Under data protection laws, you have rights including:

1. Access: You can request access to your Personal Data.
2. Correction: You may ask to rectify any incomplete or inaccurate information we hold about you.
3. Erasure: You may request the deletion of your Personal Data under certain conditions.
4. Restrict: You can (subject to limitations) request for us to restrict the processing of your Personal Data.
5. Objection: You have the right to object to the processing of your Personal Data.
6. Data portability: You have the right to ask us to transfer your Personal Data to another data controller (subject to limitations and not including paper files).
7. Withdrawal of consent: At any time, you can withdraw consent where we rely on consent to process your Personal Data.
8. Automated decision making: You have rights in relation to automated decision making and profiling.

11. International Transfers

In some instances, your Personal Data may be processed outside the UK and the European Economic Area (EEA). For example, we may work with suppliers and partners who may make use of cloud and/or hosted technologies across multiple geographies and jurisdictions.

If and when this is the case, we take steps to ensure there is an appropriate level of security, so your Personal Data is protected in the same way as if it was being used within the UK or the EEA.

Where we need to transfer your Personal Data outside the UK or EEA, we will use one of the following safeguards.

1. Standard contractual clauses in contracts for the transfer of personal information to third countries; or
2. Transfer your information to a non-EEA country with privacy laws that give the same protection as the EEA.

11. Contact Us

For any questions related to this Privacy Notice or your Personal Data under our control, contact us at:

Email: sapiens@ten24.info
Address: Lydgate House, Lydgate Lane, Sheffield, England, S10 5FH

If you have questions regarding your rights or wish to exercise a right, please contact us as above.

The most up to date version of this Privacy Notice can be found on this page.