Privacy
policy
What we hold, where it came from, why we are allowed to hold it, how long we keep it, and how to make us stop.
This notice explains what Atelier AMOD does with personal data. It is written to be read rather than survived, so it is in plain language and it describes what actually happens rather than everything that might conceivably happen.
There are two quite different situations, and it matters which one you are in.
- You came to us. You wrote to the atelier, asked for a quotation, ordered a Slice, or commissioned a model. Section 4 covers you.
- We came to you. You received an email from the atelier about a specific development, and you never gave us your details. Section 3 covers you, and it is the section that email pointed you at.
1. Who we are
Atelier AMOD is a scale model workshop. It has built architectural presentation models since 2006. Atelier AMOD is the trading name of Building Movement Ltd., a company registered in Hong Kong, which is the data controller for everything described here and the invoicing entity for all of the atelier's work.
Building Movement Ltd.
Unit 2201, 22/F, Chung Kiu Commercial Building
47-51 Shan Tung Street, Mongkok
Kowloon, Hong Kong
Production is carried out by the atelier's own workshop team in Shanghai, China.
How to reach us about your data
- For anything to do with privacy, your rights, or being removed: privacy@atelieramod.com
- If we emailed you and you want it to stop: reply STOP to that email, or write to privacy@atelieramod.com. Either stops it.
- For anything else: info@atelieramod.com
Every one of these is read by a person. You do not need a particular form of words, you do not need to quote a law, and you do not need to explain why.
2. One standard, wherever you are
We are a Hong Kong company, our workshop is in mainland China, and the people we deal with are mostly in Europe, the United Kingdom and Australia. Several different privacy laws therefore touch what we do. Rather than write a different promise for each and leave you to work out which one you get, we apply one standard to everybody.
That standard is the European and United Kingdom General Data Protection Regulation, because it is the strictest of the laws that reach us and because most of the people in our records are covered by it. If you are in Australia, Hong Kong, mainland China, the United States or anywhere else at all, you get the same treatment: the same access, the same correction, the same deletion, the same right to object, answered on the same timetable, whether or not your own law would require any of it from us.
Where your local law gives you more than that, you get the more. Nothing written here reduces a right you have where you live. The laws we recognise as applying to some part of what we do are the EU GDPR and the UK GDPR, the Hong Kong Personal Data (Privacy) Ordinance as our home law, the Personal Information Protection Law of the People's Republic of China where our workshop handles project material, and the Australian Privacy Principles for our Australian clients and representative. Where any of them demands something specific, we do that thing as well.
3. If we contacted you first
Atelier AMOD approaches a small number of property developers and housebuilders each week about specific schemes they are bringing to market. If you received one of those emails, we obtained your details from a source other than you. Article 14 of the UK GDPR and of the EU GDPR requires us to tell you the following, and to do so within a month of collecting anything. This section is that notice, and the email that brought you here is how it reaches you. If you are outside Europe, you get this notice anyway, on the same terms.
What we hold about you
- Your name and job title
- The company you work for
- Your work email address, and your work telephone number where it is published
- Your LinkedIn profile address, where there is one
- The name of the development that prompted the approach, and the stage it had reached
- A record of what we sent you and when, and of any reply
That is the whole of it. We hold no home address, no personal email address, no personal social media, no financial data and nothing in a special category. We do not build a profile of you, we do not score you as an individual, and no decision about you is made automatically.
Where it came from
All of it is publicly available, or published professionally. The source of each record is noted against it, and we will tell you exactly which one applies to you if you ask. In practice it is one of these:
- Your employer's own website, including its team, press and contact pages
- Public planning, permit and land registers, and the official gazettes that publish them
- Property portals and marketing sites where the development itself is advertised
- Trade and regional press coverage of the development
- Business directories and professional business data services
Where a company publishes no named contact, we may infer a work address from that company's own published address pattern, and we copy the company's general inbox so the message reaches the right desk. We have never bought or rented a marketing list, and we never will.
We use automated tools, among them the Apify platform, to read those public sources. They are how we collect, not a source of anything about you and not a party we disclose you to: nothing about you is sent to them, and no personal data of yours flows outward at this step.
Why we are allowed to hold it
Our lawful basis is legitimate interests, under Article 6(1)(f) of the UK GDPR and of the EU GDPR. The legitimate interest is business to business commercial prospecting: telling a named professional at a development company, in their professional capacity, that a supplier of something their industry routinely commissions is available, at the point in their project when they would be specifying it.
We assessed that interest against your interests and rights before collecting anything, and we keep that assessment on file. The points that carried it are these. The data is business capacity only. Each approach names a real scheme at your own company, so it is relevant rather than untargeted. The volume is small and capped, at a handful of approaches a week across all countries. You receive one email, at most one reminder, and then permanent silence. And you can stop it at any moment.
We do not rely on consent for these emails, so nothing here should be read as a claim that you gave any. Where the law of your own country requires consent for an approach of this kind rather than permitting it on a legitimate-interests basis, we do not make the approach at all.
Your right to object
You have an absolute right to object to direct marketing, under Article 21(2). There are no grounds on which we may refuse it, and we will not ask you to justify it. We extend the same absolute right to everyone, wherever they are.
Reply STOP to the email, or write to privacy@atelieramod.com. That address is monitored. We stop immediately and permanently. Your address goes onto a suppression list that is checked before any message is drafted, and that list is never pruned, so you will not resurface in a later round. If you would rather be erased entirely than suppressed, say so and we will erase instead, though then nothing prevents the same public sources producing your details again in future.
How long we keep it
- Contacts collected but never written to: deleted within one month of collection.
- Contacts we did write to: kept for two years from the last contact, then deleted.
- Objections and opt-outs: kept indefinitely, as the email address alone. This is deliberate. It is the only way to guarantee we never write to you again, and it is a smaller intrusion than the alternative.
4. If you came to us
The contact form and email
When you write to the atelier we hold your name, your email address, whatever you chose to tell us about your project, and the correspondence itself. We use it to answer you and to quote for the work. The basis is your own request, and then the contract if one follows.
The contact form is protected by Cloudflare Turnstile, which checks that a submission comes from a person rather than a script. Turnstile sees your IP address and basic browser signals in order to make that check.
Commissioned models and Slice orders
If you order, we hold what an order needs: your name, your email address, your company, your delivery address, the specification, and the drawings you upload. Payment is taken by Stripe, which handles the card details directly. Atelier AMOD never sees or stores your card number.
Drawings you upload are stored outside the public part of the website, reachable only by the atelier and by the workshop team building your model. They are used to build your model and for nothing else, and we do not show them to anyone outside the atelier.
The client review portal
Projects in production get a private link, in the form of a project address carrying a long random token, where you can see progress photographs and mark them up. That link is the key: anyone holding it can see that project, so treat it as you would a password. We hold the comments and markings you make, your name against them, and the date. The workshop team in Shanghai sees them, because acting on them is the point.
How long we keep it
- Enquiries that did not become projects: two years from the last message.
- Project records, correspondence and review comments: for the life of the working relationship, and then seven years, because a model is a long lived object and questions about it arrive years later.
- Orders, invoices and accounting records: as long as Hong Kong tax and company law requires of Building Movement Ltd., currently seven years from the end of the financial year.
- Uploaded drawings: deleted two years after delivery, unless you ask us to keep them for a following phase.
5. The website itself
This site uses Google Analytics to count visits and to see which pages are read. It sets cookies and records a shortened form of your IP address. It tells us that a page was read; it does not tell us who you are, and we do not try to connect it to anything else. There is no advertising network on this site, no retargeting pixel, no session recording, no chat widget and no popup.
If you would rather not be counted, your browser's cookie settings or any standard content blocker will stop it. Nothing on the site stops working if you block it.
6. Who else sees your data
This list is short on purpose. Each provider processes data on our instructions, under a contract, and for one stated job:
- Google Workspace — the email we send and receive
- Google Analytics — visitor statistics on this site
- Bluehost — hosting for this website and its files
- Stripe — payment for Slice orders
- Brevo — order confirmation and notification emails
- Cloudflare — the anti spam check on the contact form
- Notion — our record of projects, companies and contacts
- Our accountant, our Australian representative where an Australian project requires it, and shipping and customs agents when a model is delivered
We do not sell personal data, we do not rent it, and we do not share it with anyone for their own marketing.
7. Where your data goes
Atelier AMOD is a Hong Kong company that builds in China and sells across Europe, the United Kingdom and Australia, so data crosses borders by necessity rather than by choice. We would rather say plainly where it goes than bury it.
- Hong Kong. Building Movement Ltd. is registered there, so company records, orders and invoices are administered from Hong Kong.
- China. Project material, including drawings and review comments, reaches the workshop team in Shanghai, because that is where models are made. Nothing reaches the workshop beyond what building and delivering your model requires.
- United States. Several of the providers listed in section 6 are established there.
- Australia. Our representative there sees only what an Australian enquiry or delivery requires.
Hong Kong and mainland China are not covered by a European Commission or United Kingdom adequacy decision. Where personal data leaves the European Economic Area or the United Kingdom we rely on the European Commission's standard contractual clauses, or the United Kingdom addendum to them, or an adequacy decision where one applies, and we keep the data set as small as the job allows. If you want to know which safeguard covers your particular data, ask and we will tell you.
8. Your rights
Whichever section above applies to you, and wherever in the world you are, you can ask us to:
- Tell you what we hold about you, and give you a copy
- Correct anything that is wrong
- Delete it
- Stop or restrict what we do with it
- Hand it to you, or to someone else, in a portable form
- Object. Against direct marketing this is absolute and immediate, as set out in section 3
- Tell you where we got it, and who we have passed it to
Write to privacy@atelieramod.com. We answer within one month, and it costs nothing. We do not require you to be in any particular country, or to cite any particular law, before we act on one of these.
If we get it wrong, you can complain to a supervisory authority. In the United Kingdom that is the Information Commissioner's Office; in the Netherlands the Autoriteit Persoonsgegevens; in Belgium the Gegevensbeschermingsautoriteit; in Hong Kong the Privacy Commissioner for Personal Data; in Australia the Office of the Australian Information Commissioner. If you are elsewhere in the European Economic Area, or anywhere else with a data protection regulator, you may go to the authority where you live or work. We would rather you came to us first, but that is your choice and not a condition.
9. Keeping it safe
The site is served over HTTPS. Order files and client project material sit outside the publicly readable part of the server. Access to the atelier's systems is limited to the people who need it. No system is perfect and we do not claim otherwise; if something goes wrong in a way that puts your data at risk, we will tell you and the relevant authority within the time the law allows.
10. Changes to this notice
If this notice changes, the new version appears on this page and the date at the top changes with it. If a change materially affects people we have already written to, we will say so in the notice rather than leave it to be discovered.