Privacy Policy — Miximodel

1. Data Controller

The data controller for your personal data is MakerLabs SARL, a French limited liability company registered under SIREN 942 958 216, with its registered office in Paris, France.

For any questions or requests related to your personal data, you can reach our privacy team at [email protected].

2. What Data We Collect

We collect the following categories of personal data:

Account data: name, email address, username, password (hashed), date of birth, and account preferences.
Profile data: biography, profile photo, location, social media links, professional details (height, measurements, experience), and portfolio content.
Photos and media: images and videos you upload to your portfolio or share in posts.
Billing data: subscription plan, billing history, and payment status. Full payment card details are processed and stored exclusively by our payment processor and are never stored on our servers.
Usage data: pages visited, features used, search queries, IP address, browser type, device information, and approximate geolocation.
Communications: messages sent through the platform's chat system and support correspondence.
Error reports: when something breaks in the app or on our servers, a technical report is sent to our error-monitoring provider, whether or not you are signed in. See Error monitoring in Section 4 for exactly what it contains.

3. Why We Collect It (Legal Basis)

We process your personal data under the following legal bases as defined by the GDPR:

Performance of contract (Art. 6(1)(b)): Account data, profile data, billing data, and communications are necessary to provide the Miximodel service as agreed in our Terms of Service.
Legitimate interest (Art. 6(1)(f)): Usage data and analytics are processed to improve the platform, ensure security, prevent fraud, and provide relevant search results. Error reports are processed on the same basis, to detect and fix faults.
Consent (Art. 6(1)(a)): Optional features such as geolocation sharing and marketing communications are only activated with your explicit consent. You can withdraw consent at any time.
Legal obligation (Art. 6(1)(c)): Certain data may be retained to comply with tax, accounting, or regulatory requirements under French and EU law.

Age verification

Miximodel hosts age-restricted content. Your date of birth is used to confirm that you are 18 or over before you are given access to any of it — the platform derives your age from the date you give; it does not ask you to assert an age directly. We record that the confirmation was given, when, and on which screen.

The legal bases are performance of contract (Art. 6(1)(b) — being 18 or over is an eligibility condition of our Terms of Service) and compliance with a legal obligation (Art. 6(1)(c) — protection of minors, and the age-verification requirements our payment processor applies to age-restricted services).

This is a declaration, not identity verification: we do not ask for or hold an identity document for this purpose. Your date of birth is not used for anything else — no birthday features, no age-based targeting, no analytics. It appears in your data export and is erased with the rest of your account data if you delete your account.

Synthetic Character Builder — data processing

When you use the Synthetic Character Builder (restricted to platform administrators — it is no longer offered to members), the data-processing basis differs from Creator Studio:

No biometric or genetic data is processed. Because the generated subject is entirely synthetic — built from attribute choices you select (casting region, body type, hair colour, etc.) and optional free-text descriptors — no photograph of a real person is submitted to any AI model. Accordingly, processing does not engage GDPR Art. 9 (special category biometric or genetic data), and no explicit consent under Art. 9(2)(a) is required for the generation step.
Your attribute choices and free-text input are ordinary personal data. They are processed on the legal basis of Art. 6(1)(b) (performance of the contract you enter into when using the feature) and are retained only for as long as necessary to fulfil the generation request and to provide you with access to your generated outputs in your account.
Outputs are AI-generated. Every image produced by the Synthetic Character Builder is AI-generated and does not depict a real person. The platform displays an AI-generated label on every such output.

Safety Check-in — buddy data processing

When you designate a safety buddy for a booking that has a physical meeting location (the Safety Check-in feature), you provide us with that person's contact details so we can keep them informed and alert them if you do not confirm you are safe by your chosen deadline.

What we collect about your buddy: their name, email address, and — only if you choose to add it — a phone number. Your buddy never needs a Miximodel account.
Why we collect it: solely to email your buddy the meeting's location and time when you set up the check-in, and — if you miss your check-in deadline — to send them an alert (alongside an internal awareness alert to Miximodel's operator). Your buddy's details are never used for marketing and are shown to no one but you, the person who designated them.
Legal basis: our legitimate interest (Art. 6(1)(f)) in the physical safety of people meeting through the platform, acted on only upon your explicit designation of that specific contact for that specific meeting.
Retention: your buddy's details (name, email, phone, and the private token for their read-only status page) are automatically erased approximately 30 days after the booking reaches a completed or cancelled state. Your buddy may also ask us to erase their details sooner, or object to this processing, by contacting [email protected].

Reporting content through the public form — complaints and removal requests

Anyone can report content to us, or ask for content they are depicted in to be removed, using the Report content form — no Miximodel account is needed, and most people who use it are not users. If that is you, this section is about you.

What we collect: your email address, your name if you choose to give it, the location of the content you are reporting, and your own description of what is wrong. We also record your IP address and browser user-agent, and the date and time your report reached us.
Why we collect it: to investigate and act on your report, to write to you with the outcome, and to be able to demonstrate to a regulator that we handled it within the time we publish. Your IP address and user-agent are used to protect the form from automated abuse and as evidence of when your report arrived. None of it is used for marketing, and none of it is sold.
Legal basis: our legal obligation (Art. 6(1)(c)) to operate a reporting channel and act on notices (Digital Services Act Arts. 16 and 20; LCEN Art. 6), and our legitimate interest (Art. 6(1)(f)) in preventing abuse of the form and in being able to prove we met our published commitment. Where your report necessarily concerns someone's health, sexual life, or alleged offences, we process it because it is necessary for the establishment, exercise or defence of legal claims (Art. 9(2)(f)) and for reasons of substantial public interest in moderating illegal content (Art. 9(2)(g)).
Who sees it: our moderation team, and nobody else. The description you write is never shown to the person whose content you reported, and never published.
Retention: we keep the record for five years after your report is closed — the French general limitation period — because that is how long a claim about our handling of it could be brought. We then erase your email address, your name, your IP address, your user-agent, and the free text you wrote, keeping only the anonymous facts of the case (what kind of report it was, when it arrived, when it was closed and how). You can ask us to erase your details sooner, or object to this processing, at [email protected] — though we may need to keep a minimal record where the law requires us to.

Reports you make inside Miximodel

When you report a post, photo, comment or conversation from inside Miximodel, we keep the report — who made it, what it is about, the reason you chose, any text you added, and what our moderators decided — for 5 years from the moderator’s decision, or from the day you sent it if it was never decided. The report is then deleted. Only Miximodel’s moderators read it.

We process it on the basis of our legitimate interest in moderating the platform and in defending claims about our moderation decisions (Art. 6(1)(f) GDPR). The period is the French general limitation period (Art. 2224 Code civil): the report is part of the record a moderation decision rests on, and once a claim about that decision is time-barred we no longer need it.

If you delete your account, your reports stay with that record (GDPR Art. 17(3)(e), the defence of legal claims), no longer linked to your name, and the text you wrote in them is erased within about a day of the moderator’s decision on each one (or of your account’s deletion, if the decision came first). A report still awaiting a decision keeps your text for the moderator, for at most 6 months from the day you sent it.

Advertising and sponsored content

On the free plan we show sponsored cards — advertisements for products sold on Amazon — inside the feed, explore, notices and availability lists. Paid plans show none.

What we use to choose them: three fields from your own profile — your role, your gender and your city. That is the whole list. We do not use cookies, device identifiers, your browsing history, your messages, or anything gathered on other websites, and we do not keep a record of which ads you personally were shown.
Legal basis: our legitimate interest (Art. 6(1)(f)) in funding the free plan with advertising that is relevant on a professional network organised by role — the direct-marketing purpose contemplated by Recital 47. This is not consent and we do not ask you for it: it is a balance we have struck, and one you can object to.
Your right to object (Art. 21(2)): you can tell us to stop using your role, gender and city to choose ads with a single switch in Privacy settings, at any time, without giving a reason, and we stop straight away. You will still see sponsored cards — they simply stop being chosen from who you are. You can also object by writing to [email protected].
Amazon Associates: Miximodel takes part in the Amazon Associates affiliate programme. The link on a sponsored card carries an affiliate tag and we may earn a commission if you buy something after following it — every sponsored card says so on its face. Following the link takes you to Amazon, which is an independent controller of whatever it collects about your visit there; its own privacy notice applies from that point. We send Amazon no personal data about you, and the card images are served from our own domain, so no advertising network is involved in showing you the card.

4. Third-Party Processors

We share your data with the following categories of third-party service providers, each acting as a data processor under our instructions:

Payment processor: Stripe (Stripe Payments Europe, Ltd., Ireland, with Stripe, Inc., USA as its sub-processor) processes subscription payments. It receives only the data necessary to process your payment and is PCI DSS compliant. Your full card details are entered on Stripe’s own hosted fields and never reach our servers.
Cloud hosting: Google Cloud Platform (Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland) hosts our application and stores your data.
Content delivery and security: Cloudflare Inc. (USA) provides CDN and DDoS protection services.
Identity document pre-screen: when you send the two photographs we ask for to verify your identity, they may first be checked automatically by Google Cloud Vertex AI (Google Ireland Limited), running in the European Union, before an administrator reviews them. The check looks only at whether each photograph shows what we ask for — a whole, readable identity document, and a person holding one. It never compares faces, never reads out or stores anything printed on the document, and never verifies anybody: it can only send back photographs that do not show what is asked, and you can then send new ones. The yes-or-no results of that check are kept with your verification record, and every automated look at your photographs is recorded like an administrator’s. What happens to the photographs afterwards depends on the decision, and the next entry says which.
Card payment provider (CCBill): CCBill, our card payment provider, requires us to hold a copy of every verified creator’s identity document and to produce it on request, including to its acquiring bank. So if we verify you, we keep both photographs for as long as your account exists — only a Miximodel administrator can open them, every opening is recorded, and they are destroyed when your account is deleted, which you can ask for at any time. If we refuse your request, or if nobody reviews it in time, both photographs are destroyed straight away and we keep only the decision and who made it. We send CCBill or its bank nothing unless they ask for a named creator’s documents; they are recipients of that production, not processors acting on our instructions.
Identity sign-in (Google): if you sign in or sign up with Google — from the web or from the app — Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) verifies your Google account and gives us your Google account id, your email address and whether Google has verified it. From the web it also gives us your name, on the email and profile scopes you grant on Google's own consent screen; from the app, an ID token your device already holds carries the same fields. Either way we check the credential's signature against Google's own published keys, read the fields above, and discard the credential itself — we never store it, and Google never receives your Miximodel password or any content from your account.
Identity sign-in (Apple): if you sign in or sign up with Apple from the app, Apple Inc. (USA) issues your device a signed identity token proving your Apple account without your password ever reaching us. We check that token's signature against Apple's own published keys — a step that sends Apple no personal data about you — and read your Apple account id and the email address Apple vouches for. Apple never includes your name in this token: if you type one when Apple asks you to on your first sign-in, we treat it as unverified and use it only to prefill your profile, never to identify you. If you use Apple's "Hide My Email," the address we receive and store is Apple's private relay address rather than your own. We discard the identity token itself once we have read it; we never store it.
Identity sign-in (X): if you sign in or sign up with X from the web, X verifies your X account and gives us your X account id, your display name, and your email address when you grant the email permission on X's own authorisation screen. That screen lists the permissions we request — tweet.read, users.read and users.email — and we read only the three fields above from them: we never read, store or publish your posts. If X does not give us an address, we ask you for one before your account is created. We store your X account id, that email address and your display name, and we never store the access token X issues — X never receives your Miximodel password or any content from your account.
Error monitoring (Sentry): Sentry (Functional Software, Inc., USA) receives a technical report when the app fails in your browser or on our servers, so we can detect and fix the fault. This applies to every visitor, signed in or not. The legal basis is our legitimate interest in keeping the platform working and secure (Art. 6(1)(f)). A report contains the browser and operating system named in your browser’s user-agent, the address of the page without its query string, fragment or any private link token, the error message with email addresses and long identifiers removed, and the version of the app. It does not contain your IP address, your name, your email or account identifier, cookies, what you typed or submitted, a recording of your session, or anything from your console. Sentry sets no cookie and stores nothing on your device. Like any server you connect to, Sentry’s servers see the network address a report arrives from. Reports are stored in Sentry’s European Union region (Frankfurt, Germany) and kept for up to 90 days, then deleted. Because a report is not linked to your account, to object (Art. 21) or to ask for a report to be deleted, write to [email protected] with roughly when it happened and on which page, so we can find it.
Messaging: Telegram Bot API is used for optional notification delivery to users who connect their Telegram account.
Push notifications — the mobile app only: if you install the Miximodel app and allow it to notify you, three providers carry that notification to your handset. Expo (Expo, Inc., USA) is the service we hand the notification to; it passes it to Firebase Cloud Messaging (Google Ireland Limited) on Android or to the Apple Push Notification service (Apple Inc., USA) on iOS, which delivers it to your device. Each of them receives the push token that addresses your handset, together with the short title and sentence shown on your screen — which can name another member, for example that someone confirmed a booking with you. They receive nothing else: no photograph, no message content, and no link that would let them open anything in your account.
This concerns the mobile app and nothing else. Using Miximodel in a browser sends no data to Expo, Firebase or Apple for this purpose, whether or not you also use the app. Turning notifications off, in the app’s settings or in your device’s, ends it: we delete the token that addresses your handset, and signing out deletes it too.
Creator Studio AI image generation (Google): Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) operates the Google Gemini image model used by Creator Studio. It processes the reference photos you provide, only on the basis of your explicit consent, to generate new images of your likeness.
Creator Studio AI image generation (OpenAI): OpenAI, LLC (USA) operates the gpt-image-2 model used by Creator Studio. It processes the reference photos you provide, only on the basis of your explicit consent. As OpenAI is based in the United States, this transfer is governed by the 2021 Standard Contractual Clauses (Module 2, Controller → Processor).
Creator Studio AI image generation (Recraft): Recraft, Inc. (USA) operates the Recraft V4.1 and V4.1 PRO image models available in Creator Studio. It processes the reference photos and text prompts you submit, only on the basis of your explicit consent, to generate new images. As Recraft is based in the United States, this transfer is governed by the 2021 Standard Contractual Clauses (Module 2, Controller → Processor) incorporated in Recraft’s Data Processing Agreement. Recraft does not use your API inputs to train its models.
Creator Studio AI image generation (fal.ai): fal.ai Inc. (USA) operates the hosted inference infrastructure that routes requests to two admin-only image models available in Creator Studio: ByteDance’s Seedream 4.5 and Alibaba’s Qwen-Image-Edit. It processes the reference photos and text prompts submitted by our admin operators, only on the basis of explicit consent, to generate or edit new images. These two engines are restricted to internal operator use only — they are not yet available to regular users. As fal.ai is based in the United States, this transfer is governed by the 2021 Standard Contractual Clauses (Module 2, Controller → Processor) incorporated in fal.ai’s Data Processing Agreement.

5. International Transfers

Some of our processors are based in the United States. When your data is transferred outside the European Economic Area, we ensure adequate protection through:

2021 Standard Contractual Clauses (SCCs), Module 2 (Controller → Processor) approved by the European Commission (Commission Implementing Decision (EU) 2021/914), incorporated in our Data Processing Agreements with US-based processors including OpenAI, Recraft, fal.ai, Stripe, Expo, Apple (for push notifications only), and Cloudflare.
Error monitoring (Sentry). Sentry stores error reports in the European Union, but Sentry is a US company and may process them from the United States, so we treat it as a transfer. Sentry has self-certified to the EU-U.S. Data Privacy Framework, and its Data Processing Addendum provides the 2021 Standard Contractual Clauses, Module 2, if that framework ceases to apply.
Processors that maintain equivalent security standards and privacy certifications.
Signing in with Apple or X is not a data export. Verifying a Sign in with Apple token only requires fetching Apple's own published signing keys, which carries no personal data about you — nothing we hold on you leaves our servers toward Apple in that step. The account id, email address and relay status Apple gives us arrive because you authenticated with Apple directly on your own device; the transfer runs the other way, from Apple to us, not from us to Apple. Push notifications are the one place this is reversed: sending one to an iPhone does hand Apple your device’s push token and the sentence shown on your screen, which is why it is listed as a transfer above. Signing in with X runs the same direction: we send X only the authorisation code and the token X itself issued, never anything we hold about you, and what comes back is the account data X hands us because you authorised it on X's own screen.

6. Data Retention

We retain your personal data for as long as necessary to:

Provide the Miximodel service while your account is active.
Comply with legal obligations (e.g., tax records are retained for the legally required period under French law, typically 6 years).
Resolve disputes and enforce our agreements.
Content moderation decisions (the audit ledger that records why an uploaded image was classified, blocked, or removed) are retained for 24 months from the scan timestamp, in line with ARCOM expectations for online content moderation. After 24 months, the audit records are deleted by an automated retention job. The retained records do not contain the image bytes — only the per-stage decision lineage (verdict, confidence, timestamp, moderator action if any).
Evidence of content removed for trust & safety reasons. When a moderator removes content for a trust-and-safety violation (for example, content suspected to be unlawful), we preserve a tamper-evident copy of that content — the file, a snapshot of its metadata, the uploader’s username and email as they stood at removal time, and the moderation decision — in a separate, access-restricted evidence store. This evidence is retained for at least 7 years (and permanently for content suspected to be child sexual abuse material), even after the uploader deletes their account. The legal basis is GDPR Art. 17(3)(b) and (e) — compliance with a legal obligation and the establishment, exercise, or defence of legal claims. This evidence is held solely to answer law-enforcement requests, internal audits, and payment-processor inquiries; it is not included in your data-portability export (see Section 7).
Creator Studio consent records. When you consent to Creator Studio, we record a minimal proof of that consent (the consent version, the date, and your IP and browser at the time). When you close your account, the directly identifying parts of this record — your name, email, IP address, and browser — are erased, while a pseudonymous proof (the consent version, the date, and a non-reversible identifier) is retained for 5 years. The legal basis is GDPR Art. 7(1) (our obligation to demonstrate that consent was given) and Art. 17(3)(e) (establishment, exercise, or defence of legal claims, aligned with the 5-year French civil limitation period). After 5 years the record is permanently deleted.
Reports and removal requests sent through the public form. A report you send us through the Report content form is retained for 5 years from the day it is closed (the French general limitation period, Art. 2224 Code civil), then automatically pseudonymised: your email address, name, IP address, browser user-agent and the text you wrote are erased, and only the anonymous facts of the case remain. See Section 3 for what we collect and why.
Reports you make inside Miximodel. Kept for 5 years from the moderator’s decision, then deleted. If you delete your account, the text you wrote is erased within about a day of each report’s decision, or after 6 months if it is still awaiting one. See Section 3.
Error reports. Reports held by our error-monitoring provider (see Error monitoring) are kept for up to 90 days, then deleted automatically by the provider.

When you delete your account, we will delete or anonymize your personal data within 30 days, except where retention is required by law. Your moderation audit records are soft-deleted in the same cascade so they cannot be linked back to you. The exceptions are evidence of content removed for trust-and-safety reasons (described above), and the reports you made inside Miximodel, kept as described in Section 3. The evidence records are retained beyond account deletion under GDPR Art. 17(3)(b)/(e). When your account is deleted, the live link between that evidence and your account is severed, but the username and email captured at removal time are kept as part of the preserved record.

7. Your Rights

Under the GDPR, you have the following rights regarding your personal data:

Right of access (Art. 15): You can request a copy of the personal data we hold about you.
Right to rectification (Art. 16): You can request correction of inaccurate or incomplete data.
Right to erasure (Art. 17): You can request deletion of your personal data ("right to be forgotten").
Right to data portability (Art. 20): You can request your data in a structured, machine-readable format.
Right to object (Art. 21): You can object to processing based on legitimate interest. Where that processing is direct marketing — the sponsored cards shown on the free plan — the objection is absolute, needs no reason, and has its own switch in Privacy settings.
Right to restriction (Art. 18): You can request that we limit the processing of your data in certain circumstances.

To exercise any of these rights, contact us at [email protected]. We will respond to your request within 30 days as required by law.

8. Right to Lodge a Complaint

If you believe that our processing of your personal data violates the GDPR, you have the right to lodge a complaint with the French data protection authority:

Commission Nationale de l'Informatique et des Libertes (CNIL)
3 Place de Fontenoy, TSA 80715
75334 Paris Cedex 07, France
Website: www.cnil.fr

9. Cookies

Miximodel uses essential cookies for authentication, session management, and age verification. We may also use analytics cookies to understand how users interact with the platform. You can manage your cookie preferences through your browser settings.

Error monitoring sets no cookie and stores nothing on your device — see Error monitoring in Section 4.

Sponsored advertising uses none. No ad network script runs on the platform, no advertising or retargeting cookie is set, nothing is read from your device to choose an ad, and the card images are served from our own domain — see Advertising and sponsored content above.

10. Changes to This Policy

We may update this Privacy Policy from time to time. When we make significant changes, we will notify you by email or by displaying a notice on the platform. Your continued use of Miximodel after the changes take effect constitutes acceptance of the updated policy.

11. Contact

For any questions about this Privacy Policy or your personal data:

Privacy email: [email protected]
General support: [email protected]
Data controller: MakerLabs SARL, SIREN 942 958 216, Paris, France