Privacy Policy — Avatar Creator

This Privacy Policy explains how personal data is collected and processed through the Avatar Creator website, landing page, waitlist, newsletter forms, contact forms, advertising campaigns, analytics tools and related online services. This Privacy Policy is provided in accordance with Regulation (EU) 2016/679 (“GDPR”), the Italian Personal Data Protection Code as amended, applicable Italian and European e-privacy and cookie rules and other data protection laws, where applicable. This Privacy Policy applies only to the Avatar Creator website and related online services controlled by the Data Controller identified below. Third-party platforms, marketplaces, payment providers, social media platforms and external websites process personal data according to their own privacy policies and terms.

1. Data Controller

The Data Controller is:

[Your Full Legal Name]
Established in Italy
Email: support.avc@protonmail.com
Website: avcsuite.com

For any privacy-related request, you can contact the Data Controller at the email address above. No Data Protection Officer has been appointed because, based on the current processing activities, such appointment is not mandatory under Article 37 GDPR. If this changes, this Privacy Policy will be updated.

2. Personal Data We Collect

Depending on how you interact with the website, we may collect the following categories of personal data.

2.1 Data you provide voluntarily

We may collect personal data that you choose to provide, including:

email address;
name, if requested;
company name or professional role, if requested;
country or language preference, if requested;
message content, if you contact us;
newsletter, waitlist or launch update preferences;
information submitted through forms on the website.

Providing this data is optional. However, if you do not provide the requested information, we may not be able to send you updates, respond to your request or provide the service you asked for.

2.2 Technical and browsing data

When you visit the website, some technical data may be automatically processed, including:

IP address;
browser type and version;
device information;
operating system;
approximate location inferred from IP address;
pages visited;
date and time of access;
referral URL;
server logs;
technical cookies or similar technologies required for the website to work;
consent preferences recorded through the cookie banner or consent management system.

This data is processed to operate the website, ensure security, maintain the service, prevent abuse and manage user privacy preferences.

2.3 Analytics, advertising and retargeting data

Subject to your consent where required, the website may use analytics and advertising technologies such as:

Google Analytics 4;
Google Ads / Google tags;
Meta Pixel;
similar analytics, conversion tracking, advertising or retargeting technologies.

These tools may process data such as:

IP address;
cookie identifiers and online identifiers;
device and browser information;
operating system;
pages viewed;
actions performed on the website;
campaign parameters;
referral URL;
conversion events, such as form submission, waitlist signup or purchase-related events;
date and time of interaction;
consent status and cookie preferences.

These tools may be used to measure website traffic, underst and campaign performance, record conversions, create advertising audiences, show retargeting ads and measure the effectiveness of ads shown on platforms such as Google, YouTube, Facebook and Instagram. Where advanced matching, enhanced conversions or similar advertising features are enabled, contact identifiers such as email address may be hashed before being transmitted to the relevant advertising provider, subject to your consent and applicable law.

2.4 Newsletter, waitlist and email marketing data

If you subscribe to the Avatar Creator waitlist, newsletter, launch updates or product communications, we may process:

email address;
subscription date and time;
IP address used for subscription, where available;
consent status;
email preferences;
email delivery data;
email interaction data, such as opens or clicks, where technically available;
unsubscribe status.

Email communications may be managed through MailUp or another email marketing provider.

2.5 Purchase and marketplace-related data

If you purchase Avatar Creator through a third-party marketplace, such as SuperHive or another platform, the purchase process may be handled directly by that marketplace. In that case, the marketplace may act as an independent data controller for account management, payment processing, tax handling, invoices, refunds, fraud prevention, transaction records and marketplace communications. Depending on the marketplace and purchase flow, we may receive limited information necessary to:

verify your purchase;
manage your product license;
provide customer support;
handle refund or support requests;
prevent fraud, unauthorized access or abuse;
comply with legal obligations;
protect our rights and enforce our terms.

Please also read the privacy policy and terms of the marketplace where you purchase Avatar Creator.

3. Why We Process Personal Data and Legal Bases

We process personal data only when we have a valid legal basis under GDPR.

3.1 Website operation, maintenance and security

We process technical data, server logs and essential cookies to operate the website, maintain security, prevent abuse, diagnose technical issues, protect the service from malicious activity and manage basic website functionality. Legal basis: legitimate interest in operating and securing the website.

3.2 Waitlist, newsletter and product updates

If you subscribe to receive launch updates, newsletters, product news, waitlist communications or marketing emails, we process your email address and subscription data to send those communications. Legal basis: your consent. You can withdraw your consent at any time by using the unsubscribe link included in each email or by contacting us.

3.3 Contact requests and pre-contractual communication

If you contact us, we process your data to reply to your request, provide information, manage pre-sale questions, support requests or business communications. Legal basis: pre-contractual measures, contract performance where applicable and legitimate interest in responding to user requests.

3.4 Purchase, license and support management

If you purchase Avatar Creator or request support, we may process data necessary to verify your purchase, manage your license, provide support, handle refunds, prevent fraud, manage customer communications and comply with marketplace or legal requirements. Legal basis: contract performance, legal obligations and legitimate interest in protecting the product, preventing abuse and managing customer relationships.

3.5 Analytics, advertising, retargeting and non-essential tracking

If we use Google Analytics, Google Ads, Meta Pixel or similar analytics and advertising technologies, these tools will be activated only where required after you have given consent through the cookie banner or consent management system. These tools may be used for:

analytics and traffic measurement;
campaign measurement;
conversion tracking;
advertising audience creation;
retargeting;
personalized advertising;
performance measurement of ads and landing pages.

Legal basis: your consent. You can withdraw or change your consent at any time through the cookie settings available on the website.

3.6 Advertising profiling

Subject to your consent, advertising tools such as Google Ads and Meta Pixel may process browsing and interaction data to create or include you in advertising audiences, measure conversions and show you ads related to Avatar Creator on third-party platforms. This may involve profiling for advertising purposes. We do not use this data to make decisions based solely on automated processing that produce legal effects or similarly significant effects on you. Legal basis: your consent.

3.7 Legal compliance and protection of rights

We may process personal data where necessary to comply with legal obligations, respond to lawful requests, enforce our terms, protect intellectual property rights, prevent unauthorized redistribution or defend legal claims. Legal basis: legal obligation and legitimate interest.

4. Email Marketing Provider

We may use MailUp to manage newsletters, waitlists, launch updates and product communications. When MailUp processes personal data on our behalf for the sending of our email campaigns, it acts as a data processor under GDPR. MailUp may process data such as:

email address;
IP address;
subscription date and time;
consent status;
delivery status;
email opens;
link clicks;
preferences;
unsubscribe status.

This data is processed to send communications, manage subscriptions, document consent, measure email performance and allow users to unsubscribe. You can unsubscribe from marketing emails at any time by using the unsubscribe link included in each email or by contacting us. For more information about MailUp’s own privacy practices, please refer to MailUp’s official privacy policy.

5. Cookies and Similar Technologies

The website uses cookies, pixels, tags and similar technologies

5.1 Technical cookies

Technical cookies are used to make the website work, ensure security, remember privacy preferences and provide essential functionality. These cookies do not require consent where they are strictly necessary.

5.2 Analytics and advertising technologies

Subject to your consent where required, the website may use tools such as:

Google Analytics for analytics and traffic measurement
Google Ads / Google tags for conversion tracking, advertising measurement and remarketing;
Meta Pixel for conversion tracking, advertising measurement, audience creation and retargeting;
MailUp or embedded form technologies for newsletter and waitlist management;
other similar analytics, advertising or tracking technologies

These tools may use cookies, pixels, local storage, tags or other identifiers to recognize browsers or devices, measure interactions, attribute conversions and support advertising campaigns.

5.3 Consent management

You can accept or reject non-essential cookies through the cookie banner. Non-essential cookies and similar tracking technologies are not activated before your consent where consent is required by applicable law. You can change or withdraw your consent at any time through the cookie settings available on the website. The website may use consent management mechanisms, including Google Consent Mode or similar technologies, to adjust analytics and advertising tags according to your consent choices.

5.4 Cookie Policy

A dedicated Cookie Policy or cookie table should be made available on the website and should provide detailed information about each cookie or tracking technology, including:

cookie or technology name;
provider;
purpose;
category;
duration;
whether it is first-party or third-party;
links to third-party privacy policies where applicable.

6. Provision of Personal Data

Providing your email address for the waitlist, newsletter or launch updates is optional. If you do not provide it, you will not receive those communications. Providing data through contact forms is optional. However, without the requested information, we may not be able to respond to your request. Technical data necessary for website operation is processed automatically when you access the website. Consent to analytics, advertising and retargeting tools is optional. Refusing or withdrawing consent does not prevent you from accessing the website, but may limit our ability to measure campaigns, personalize ads or underst and website performance. Purchase-related data may be necessary to manage licenses, support, purchase verification, refunds or legal obligations.

7. Who We Share Personal Data With

We may share personal data with trusted third parties only where necessary for the purposes described in this Privacy Policy. These may include:

website hosting providers;
domain, DNS, CDN or website security providers;
email marketing providers, including MailUp;
marketplace platforms, such as SuperHive or other sales platforms;
payment processors, where applicable;
analytics providers, including Google Analytics, if enabled;
advertising providers, including Google Ads and Meta, if enabled and subject to consent where required;
consent management providers;
IT service providers;
legal, tax or accounting advisors, where necessary;
public authorities, courts or law enforcement bodies, where required by law.

These recipients process personal data either as independent controllers or as processors acting on our instructions, depending on the service provided. We do not sell your personal data for money. Where advertising technologies involve data sharing for personalized advertising, such processing will take place only where required after your consent and in accordance with applicable law.

8. International Data Transfers

Some service providers may process personal data outside the European Economic Area, including in countries that may not provide the same level of data protection as the European Union. Where personal data is transferred outside the EEA, we rely on appropriate safeguards where required, such as:

adequacy decisions adopted by the European Commission;
the EU-U.S. Data Privacy Framework, where applicable;
Standard Contractual Clauses approved by the European Commission;
additional technical and organizational safeguards;
other transfer mechanisms permitted by applicable law.

Third-party providers such as Google, Meta, MailUp, marketplace platforms or hosting providers may use global infrastructure. For more information, please refer to their respective privacy policies and data transfer documentation.

9. How Long We Keep Personal Data

We keep personal data only for as long as necessary for the purposes described in this Privacy Policy. Indicative retention periods are:

Newsletter and waitlist data: until you unsubscribe, withdraw consent, or until the relevant contact list is no longer active.
Email marketing interaction data: for as long as necessary to manage communications, document consent, measure campaign performance and maintain suppression or unsubscribe records.
Technical logs: for a limited period necessary for security and maintenance, usually up to 12 months unless a longer period is needed for security investigations.
Analytics data: according to the retention settings configured in the relevant analytics provider.
Advertising and retargeting data: according to the retention settings configured in the relevant advertising platform and your consent choices.
Purchase, license and support data: for the time necessary to manage the contractual relationship, provide support, verify licenses, prevent fraud, comply with legal obligations and protect legal rights.
Legal/accounting data, where applicable: for the period required by applicable law.
Cookie consent records: for the period necessary to document consent and manage user preferences.

When personal data is no longer needed, it will be deleted, anonymized or securely archived where legally required.

10. Your Rights

Under GDPR, you have the right to:

access your personal data;
request correction of inaccurate or incomplete data;
request deletion of your personal data;
request restriction of processing;
object to processing based on legitimate interest;
object at any time to processing for direct marketing purposes, including profiling related to direct marketing;
request data portability where applicable;
withdraw consent at any time where processing is based on consent;
lodge a complaint with a supervisory authority.

In Italy, the competent supervisory authority is the Garante per la Protezione dei Dati Personali. To exercise your rights, contact us at: support.avc@protonmail.com We may need to verify your identity before responding to your request. Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal.

11. Newsletter Unsubscribe

If you receive marketing emails from us, you can unsubscribe at any time by clicking the unsubscribe link included in each email. After unsubscribing, you will no longer receive marketing emails from the relevant mailing list. We may retain limited information necessary to record your unsubscribe request and ensure that you are not contacted again for the same marketing purpose. Even if you unsubscribe from marketing emails, we may still send strictly necessary non-marketing communications, such as license, purchase, support, legal or security-related messages where applicable.

12. Automated Decision-Making and Profiling

We do not use personal data collected through the Avatar Creator website for decisions based solely on automated processing that produce legal effects or similarly significant effects on users. However, if you consent to advertising and retargeting technologies, your browsing and interaction data may be used by advertising platforms to create audience segments, measure conversions and show personalized or retargeted ads. You can withdraw your consent or object to direct marketing at any time.

13. Children’s Privacy

Avatar Creator is intended for professional users, artists, freelancers, studios and adult or professional 3D creators. The website, newsletter and waitlist are not directed to children. We do not knowingly collect personal data from children under the age required by applicable law to provide valid consent. If we become aware that we have collected personal data from a child without proper authorization, we will delete it or take appropriate steps as required by law.

14. Security

We apply reasonable technical and organizational measures to protect personal data against unauthorized access, loss, misuse, alteration or disclosure. These measures may include, where appropriate:

secure hosting infrastructure;
access controls;
encrypted connections;
account and credential protection;
limitation of access to personal data;
regular review of service providers;
backup, logging and security monitoring measures.

However, no website, email system or online service can guarantee absolute security. You are responsible for using secure devices, keeping your accounts safe and avoiding unauthorized sharing of personal data.

15. Third-Party Links and Services

The website may contain links to third-party websites, marketplaces, social media pages, payment processors or external platforms. This Privacy Policy applies only to Avatar Creator’s website and related online services controlled by the Data Controller. Third-party websites and platforms process personal data according to their own privacy policies and terms. We are not responsible for the privacy practices of third-party websites or services.

16. Users Outside the European Economic Area

The website may be accessible worldwide. If you access the website from outside the European Economic Area, your personal data will be processed primarily in accordance with GDPR and applicable Italian and European data protection rules. Where local data protection laws grant you additional rights, we will respect those rights where they apply to our processing activities.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in the website, services, legal requirements, providers or data processing activities. The updated version will be published on this page with a revised “Last updated” date. Where required by law, we may also notify users or request renewed consent.

4. Contact

For any questions contact us at support.avc@protonmail.com.