PRIVACY POLICY ADDENDUM FOR CALIFORNIA RESIDENTS
This PRIVACY POLICY ADDENDUM FOR CALIFORNIA RESIDENTS (“Addendum”) supplements and amends the information contained in the above Privacy Policy of Spatial and applies solely to individuals who reside in the State of California (“You”). Spatial adopts this Addendum to comply with the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this Addendum. In the event of a conflict between the Spatial Privacy Policy and this Addendum, this Addendum shall prevail but only with respect to personal information California residents. Where the Privacy Policy refers to “Personal Data” it shall be interpreted to mean “Personal Information” as defined in this Addendum but only for California residents.
- Information Spatial Collects
Spatial collects information both online and offline that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). In particular, Spatial has collected the types of Personal Information set forth above in Section 2 of the Privacy Policy from You within the last twelve (12) months and possibly prior to that. The type of information specified in Section 2 of the Privacy Policy falls under category of “Identifiers” ,”Internet or other similar activity” both as defined under the CCPA or Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Personal Information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA's scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
The categories of Personal Information set forth above are obtained from the following categories of sources:
- Directly or indirectly from our customers or their agents. For example, from documents that our customers provide to Spatial related to the access and use of Spatial products and/or services.
- Directly and indirectly from activity on our Sites. For example, from submissions through our Sites or website usage details collected automatically.
- From third parties that interact with Spatial in connection with products Spatial provides or the services Spatial perform.
- Use of Personal Information
The purposes for which Spatial uses Your Personal Information are set forth above in Section 4 of the Privacy Policy. Spatial will not collect additional categories of Personal Information or use the Personal Information Spatial collected for materially different, unrelated, or incompatible purposes without providing You notice.
- Sharing Personal Information
In the preceding twelve (12) months, Spatial may have disclosed Your Personal Information for a business purpose as further specified in Sections 4, 6 and 7 of the Privacy Policy. Spatial discloses Your Identifiers for a business purpose to the following categories of third parties:
- 3DS Group Companies.
- Spatial Service providers.
- Third parties to whom You or Your agents authorize Spatial to disclose Your Personal Information in connection with products or services Spatial provides to You or Your agents. Spatial does not sell Personal Information.
- Your Rights and Choices
The CCPA provides You with specific rights regarding Your Personal Information. This section describes Your CCPA rights and explains how to exercise those rights.
- Access to Specific Information and Data Portability Rights
- You have the right to request that Spatial disclose to You certain information about Spatial’s collection and use of Your Personal Information over the past 12 months. Once Spatial receives and confirms Your verifiable consumer request, as defined by the CCPA, Spatial will disclose to You:
- The categories of Personal Information Spatial collected about You;
- The categories of sources for Your collected Personal Information;
- Our business or commercial purpose for collecting, or sharing Your Personal Information;
- The categories of third parties with whom Spatial shares Your Personal information, if any;
- The specific pieces of Personal Information Spatial collected about You.
- If Spatial disclosed Your Personal Information for a business purpose, a separate list disclosing: Disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
- Deletion Request Rights
You have the right to request that Spatial deletes any of Your Personal Information that Spatial collected from You and retained, subject to certain exceptions. Once Spatial receives and confirms Your verifiable consumer request, Spatial will delete (and direct Spatial service providers to delete) Your Personal Information from Spatial records, unless an exception applies.
Spatial may deny Your deletion request if retaining Your Personal Information is necessary for it or its service providers to:
- Complete the transaction for which Spatial collected Your Personal Information, provide a product or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform a contract with You.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Provide You with support services related to Spatial products.
- Exercise free speech, ensure the right of another consumer to exercise his/her free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if You previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Spatial.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which You provided it.
- Exercising Access, Data Portability, and Deletion Rights.
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to Spatial by sending an email to: info_spatial@3ds.com.
You may also exercise those rights by submitting such a request to the privacy office at 3DS by either:
Only You or a person or a business entity registered with the California Secretary of State to conduct business in California that You authorize to act on Your behalf, may make a verifiable consumer request related to Your Personal Information.
You may also make a verifiable consumer request on behalf of Your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows Spatial or 3DS (collectively referred to hereinafter as “Us” or “We”) as applicable to reasonably verify You are the person about whom Spatial collected Personal Information or an authorized representative.
- Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it.
We cannot respond to Your request if We cannot verify Your identity or authority to make the request and confirm the Personal Information relates to You. Making a verifiable consumer request does not require You to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
- Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If We require more time (up to 90 days), We will inform You of the reason and extension period in writing. We will deliver a written response by mail or electronically, at Your option. Any disclosures We provide will only cover the 12-month period preceding the verifiable consumer request's receipt and/or explain the reasons We cannot comply with a request, if applicable. For data portability requests, We will select a format to provide Your personal information that is readily useable and should allow You to transmit Your Personal Information from Spatial to another entity without hindrance.
We do not charge a fee to process or respond to Your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If We determine that the request warrants a fee, We will tell You why We made that decision and provides You with a cost estimate before completing Your request.
- Non-Discrimination
Spatial will not discriminate against You for exercising any of Your CCPA rights. Unless permitted by the CCPA, Spatial will not:
- Deny You products or services;
- Charge You or suggest You may receive different prices or rates for products or services, including through granting discounts or other benefits, or imposing penalties;
- Provide You or suggest You may receive a different level or quality of products or services (or suggest so).
- Contact Information
If You have any questions or comments about this Addendum, our Privacy Policy, the ways in which Spatial collects and processes Your personal information, Your choices and rights regarding Your use, or wish to exercise Your rights under California law, please do not hesitate to contact Spatial by sending an email to: info_spatial@3ds.com.
You may also contact the 3DS Data Privacy Office at:
Phone: (888) 337-0030 (toll free within the US only)
Postal Address: Dassault Systèmes Americas Corp.
Attn: Americas Data Protection Officer
175 Wyman Street Waltham
MA 02451
Or by contacting the 3DS Data Protection Officer via the following form: https://www.3ds.com/privacy-policy/contact.
PRIVACY POLICY ADDENDUM FOR PERSONAL INFORMATION GOVERNED BY JAPANESE LAW
This PRIVACY POLICY ADDENDUM FOR PERSONAL INFORMATION GOVERNED BY JAPANESE LAW (“Addendum”) supplements and amends the information contained in the above Privacy Policy of Spatial and applies solely to individuals whose personal information is subject to the Act on Protection of Personal Information of Japan (“APPI”) (“You”). Spatial adopts this Addendum to comply with the APPI. Any terms defined in the APPI have the same meaning when used in this Addendum. In the event of a conflict between Spatial Privacy Policy and this Addendum, this Addendum shall prevail but only with respect to personal information subject to APPI. Where the Privacy Policy refers to “Personal Data” it shall be interpreted to mean “Personal Information” as defined in this Addendum but only for personal information subject to APPI.
- Purpose of using Personal Information
- The purposes for which Spatial uses Your Personal Information are set forth above in Section 4 of the Privacy Policy and more specifically:
- Provision of information on 3DS’ products and services via telephone, email, postal mail, etc.
- Provision of information on events and seminars organized by Spatial or in which Spatial is participating and mailing invitations as well as distribution of related documentation.
- Analysis of Your needs for products, services, wishes etc.
- Sharing Your Personal Information with 3DS Group Companies (as defined in the Privacy Policy).
- Provision of Your Personal Information to third parties such as Spatial seminar sponsors, distributors and other business partners.
- Any and other purposes of use included in the above range.
- Additional Information related to Your Personal Information Processed by Spatial
(A) Names of the Companies processing Your Personal Information
The following companies will process Your Personal Information for the purposes listed below:
Dassault Systèmes S.E.
Dassault Systèmes K.K.
Spatial Corp.
The Personal Information You provide (such as Your name, address, phone number, e-mail and other asked Personal Information) will be used for the purposes set forth in Section 4 of the Privacy Policy and Section 1 of this Addendum. In addition, those Personal Information may be shared with 3DS Group Companies and third parties that are contributing to the performance of one or several purposes listed Section 4 of the Privacy Policy and Section 1 of this Addendum and, in particular for the organization of events as mentioned in the Registration Page. Your Personal Information will be shared according to a secured process such as 3DDrive or any other file transfer.
(B) Your rights
With regard to Your rights to request disclosure of purpose of use, correction, addition, deletion, suspension of use / erasure, stop of third party provision regarding Personal Information held, You may either contact Spatial by sending an email to info_spatial@3ds.com, or you may contact the 3DS Privacy Office by filling in this form https://www.3ds.com/privacy-policy/contact or you can contact:
Dassault Systèmes K.K. Personal Information Inquiries
Tokyo 2-1-1 Osaki, Shinagawa-ku ThinkPark Tower Phone number 03-4321-3500 (main number)