Privacy Policy

1. Introduction

One Model Inc. ("One Model," "we," "us," or "our") is committed to protecting the privacy of individuals who interact with our website and marketing activities. This Privacy Policy describes how we collect, use, disclose, and protect personal information in connection with our website at onemodel.co (the "Website") and our associated marketing and recruiting activities (collectively, the "Services").

Important Scope Limitation. This Privacy Policy governs personal information collected through our Website and marketing activities. It does not apply to personal information that we process on behalf of our enterprise customers ("Subscribers") when providing the One Model People Analytics platform or One AI products. Processing of Subscriber data is governed exclusively by the applicable Data Processing Agreement ("DPA") between One Model and each Subscriber. If you have questions about how a Subscriber processes your personal information through the One Model platform, please contact that Subscriber directly.

Our Website and Services are designed for business professionals and enterprises. We do not knowingly direct our Services to individuals acting in a personal, family, or household capacity, and we treat all personal information we collect as relating to individuals in their professional capacity.

2. Definitions

For the purposes of this Privacy Policy, the following terms have the meanings set out below. Capitalized terms used but not defined here have the meanings given to them in our DPA.

"Personal Data" means any information relating to an identified or identifiable natural person.
"Process" / "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, and deletion.
"Data Controller" means the entity that determines the purposes and means of Processing Personal Data. For Website visitors, One Model acts as the Data Controller.
"Data Processor" means an entity that Processes Personal Data on behalf of a Data Controller.
"Sub-processor" means a third party engaged by One Model to Process Personal Data in connection with the Services. See our Sub-processor List.
"Subscriber" means an enterprise customer that accesses the One Model platform under a subscription agreement.

3. Personal Information We Collect

3.1 Information You Provide Directly

Category	Examples
Contact Data	First and last name, professional title, company name, business email address, mailing address, phone number
Account & Profile Data	Username, password, linked social network profiles, account preferences
Professional & Employment Information	Job title, department, employer, employment history (e.g., when provided in a job application)
Communications	Inquiries, support requests, feedback, and other messages submitted through the Website or via email
Marketing Preferences	Opt-in/opt-out status for marketing communications and records of engagement
Transactional Data	Order numbers, billing information, and transaction history
Payment Information	Payment card details or bank account information, collected and processed via our PCI-compliant payment processors
User-Generated Content	Comments, messages, or other content you post or transmit through the Website
Other Data	Any additional information you voluntarily provide

Information We Collect Automatically

When you visit our Website, we and our service providers may automatically collect:

Device & Technical Data: IP address, browser type and version, operating system, device identifiers, and general geographic location derived from IP address (city/country).
Usage Data: Pages visited, navigation paths, time spent on pages, referring URLs, links clicked, and search queries.
Communication Interaction Data: Email open rates, click-through rates, and other engagement metrics related to our marketing communications.

This data is collected using cookies, web beacons, pixel tags, and similar technologies. Please see Section 9 (Cookie Notice) for further details.

Information We Receive from Third Parties

We may receive Personal Data about you from:

Public Sources: Publicly available professional profiles (e.g., LinkedIn), company websites, government registries, and similar sources.
Data Enrichment Providers: Third-party data providers (including ZoomInfo) that supplement contact and firmographic information to support our sales and marketing activities. See Section 8 for details on ZoomInfo's BuyerID feature.
Marketing & Referral Partners: Co-marketing partners and event organizers from whom we receive referral leads with your consent.
Social Media Platforms: If you interact with our social media pages or use social login features.

4. How We Use Personal Information

We use Personal Data only where we have a valid legal basis to do so. The purposes for which we Process Personal Data, and our legal bases for each, are set out below.

Purpose	Legal Basis (GDPR Art. 6)	Notes
Operating and improving the Website and Services	Legitimate interests (Art. 6(1)(f))
Responding to inquiries and providing customer support	Legitimate interests / Contract performance (Art. 6(1)(b), (f))
Sending product updates, newsletters, and promotional content	Consent (Art. 6(1)(a)) or Legitimate interests (Art. 6(1)(f))	Opt-out available at any time
Conducting interest-based advertising	Consent (Art. 6(1)(a))	See Cookie Notice
Evaluating employment applications	Pre-contractual steps (Art. 6(1)(b))
Analytics, benchmarking, and product development	Legitimate interests (Art. 6(1)(f))
Complying with legal obligations	Legal obligation (Art. 6(1)(c))
Preventing fraud and enforcing our agreements	Legitimate interests (Art. 6(1)(f))
Processing payments	Contract performance (Art. 6(1)(b))
Any other purpose disclosed at collection	Consent (Art. 6(1)(a))

We may also use Personal Data in an anonymized or aggregated form that cannot reasonably be used to identify an individual. Such data is not subject to this Privacy Policy.

5. How We Share Personal Information

We do not sell, rent, or trade your Personal Data. We may share Personal Data in the following limited circumstances:

Service Providers & Sub-processors: We share Personal Data with vetted third-party service providers and Sub-processors who assist us in operating the Website and delivering our Services (e.g., cloud hosting, CRM, analytics, email delivery). All Sub-processors are subject to data processing agreements that impose obligations consistent with this Privacy Policy and applicable law. A current list of our Sub-processors is available at onemodel.co/privacy-policy/subprocessors.
Professional Advisors: We may share Personal Data with lawyers, accountants, auditors, and insurers where necessary for professional services.
Business Transfers: In connection with a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, Personal Data may be transferred as part of that transaction, subject to confidentiality obligations.
Legal Requirements: We may disclose Personal Data to comply with applicable law, regulation, legal process, or enforceable governmental request; to protect the rights, property, or safety of One Model, our users, or the public; or to detect, prevent, or respond to fraud, security incidents, or technical issues.
With Your Consent: We may share Personal Data for any other purpose with your explicit consent.

6. International Data Transfers

One Model is headquartered in the United States. If you are located in the European Economic Area ("EEA"), United Kingdom ("UK"), Canada, or another jurisdiction with data transfer restrictions, please be aware that your Personal Data may be transferred to and processed in the United States or other countries that may not provide the same level of data protection as your home jurisdiction.

Where required by applicable law, we implement appropriate safeguards for such transfers, including:

Standard Contractual Clauses (SCCs) approved by the European Commission for transfers from the EEA;
UK International Data Transfer Agreements (IDTAs) or UK Addenda to SCCs for transfers from the UK;
Adequacy decisions where applicable; and
Other lawful transfer mechanisms as required.

You may request a copy of the applicable transfer mechanism by contacting us at privacy@onemodel.co.

7. Data Retention

We retain Personal Data for as long as necessary to fulfil the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. The criteria we use to determine retention periods include:

Whether the data is necessary to maintain an ongoing relationship with you or to perform a contract;
Whether we have a legal obligation to retain the data (e.g., tax, financial, or employment records);
Whether retention is advisable in light of our legal position (e.g., applicable statutes of limitations); and
Whether you have exercised a right to erasure, subject to overriding legal bases.

When Personal Data is no longer required, we will securely delete or anonymize it in accordance with our data retention schedule.

9. ZoomInfo BuyerID and Third-Party Data Enrichment

We use ZoomInfo's BuyerID feature on our Website to improve our understanding of website visitors and enhance the effectiveness of our marketing activities. ZoomInfo may set third-party cookies on your browser for the purpose of cross-domain visitor identification and firmographic data enrichment.

Purpose: To associate website visit activity with a known company or contact record in order to improve sales and marketing outreach.
Data Collected: Firmographic and contact information (company name, job title, business contact details) derived from ZoomInfo's proprietary database.
Restrictions on Use: Data collected via ZoomInfo BuyerID is not sold to third parties and is used solely for the purposes described in this Privacy Policy.
Legal Basis (GDPR): This processing constitutes cross-context behavioral advertising and requires opt-in consent from visitors in the EEA and UK. Consent is collected via our cookie consent banner.
CCPA/CPRA: This processing may constitute "sharing" of Personal Information for cross-context behavioral advertising purposes. California residents have the right to opt out. See Section 11 for details.
Opt-Out: You may opt out by declining advertising cookies via our cookie consent banner, adjusting your browser settings, or using the industry opt-out tools listed in Section 10.

10. Cookie Notice

10.1 What Are Cookies?

Cookies are small text files placed on your device by websites you visit. They are widely used to make websites function properly, to store user preferences, and to provide information to site owners. We also use related technologies such as web beacons, pixel tags, and local storage (collectively referred to as "cookies" in this Notice).

10.2 Categories of Cookies We Use

Category	Purpose	Consent Required?
Strictly Necessary	Essential for the Website to function (e.g., authentication, session management). These cookies cannot be disabled.	No
Functionality	Remember your preferences and settings (e.g., language, region).	Yes
Analytics & Performance	Collect aggregated information about how visitors use our Website to help us improve performance and user experience.	Yes
Advertising & Targeting	Deliver interest-based advertising and measure campaign effectiveness. Includes ZoomInfo BuyerID cookies.	Yes

10.3 Managing Your Cookie Preferences

You can manage your cookie preferences at any time by:

Using our Cookie Preference Center (accessible via the cookie banner on our Website);
Adjusting your browser settings to block or delete cookies (note: blocking strictly necessary cookies may impair Website functionality);
Using the following industry opt-out tools:

Please note that opt-out choices may be stored as cookies. If you clear your browser cookies, you may need to renew your opt-out preference.

11. Your Privacy Rights

Depending on your location, you may have the following rights with respect to your Personal Data. To exercise any of these rights, please contact us at privacy@onemodel.co.

11.1 Rights Under GDPR (EEA & UK Residents)

If you are located in the EEA or UK, you have the right to:

Access a copy of the Personal Data we hold about you (Art. 15 GDPR);
Rectification of inaccurate or incomplete Personal Data (Art. 16 GDPR);
Erasure ("right to be forgotten") of Personal Data where there is no overriding legal basis for continued processing (Art. 17 GDPR);
Restriction of processing in certain circumstances (Art. 18 GDPR);
Data Portability – receive your Personal Data in a structured, commonly used, machine-readable format (Art. 20 GDPR);
Object to processing based on legitimate interests or for direct marketing purposes (Art. 21 GDPR);
Withdraw Consent at any time where processing is based on consent, without affecting the lawfulness of prior processing;
Lodge a Complaint with your local supervisory authority (e.g., the UK ICO at ico.org.uk or the relevant EU supervisory authority at edpb.europa.eu).

We will respond to your request within 30 days (or as otherwise required by applicable law). We may need to verify your identity before processing your request.

11.2 Rights Under CCPA/CPRA (California Residents)

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA/CPRA"), grants you the following rights:

Right to Know: Request disclosure of the categories and specific pieces of Personal Information we have collected about you, the categories of sources, the business or commercial purposes for collection, and the categories of third parties with whom we share it.
Right to Delete: Request deletion of your Personal Information, subject to certain exceptions.
Right to Correct: Request correction of inaccurate Personal Information.
Right to Opt Out of Sale or Sharing: We do not sell Personal Information for monetary consideration. However, we may "share" Personal Information (as defined by CCPA/CPRA) for cross-context behavioral advertising. You have the right to opt out by clicking "Do Not Sell or Share My Personal Information" in the footer of our Website or by contacting us at privacy@onemodel.co.
Right to Limit Use of Sensitive Personal Information: To the extent we collect Sensitive Personal Information (as defined by CCPA/CPRA), you have the right to limit its use to purposes authorized by law.
Non-Discrimination: You will not receive discriminatory treatment for exercising your privacy rights.

To submit a verifiable consumer request, contact us at privacy@onemodel.co. We will verify your identity and respond within 45 calendar days (extendable by an additional 45 days with notice).

Authorized Agents: California residents may designate an authorized agent to submit requests on their behalf by providing written authorization.

CCPA Metrics: We will make annual CCPA disclosure metrics available upon request.

11.3 Rights Under PIPEDA (Canadian Residents)

If you are a Canadian resident, you have the right to:

Access the Personal Information we hold about you;
Challenge the accuracy of that information and request correction;
Withdraw consent to our use of your Personal Information, subject to legal and contractual constraints;
Lodge a complaint with the Office of the Privacy Commissioner of Canada at priv.gc.ca.

12. Children's Privacy

Our Website and Services are not directed to individuals under the age of 16 (or the applicable minimum age in your jurisdiction). We do not knowingly collect Personal Data from children. If you believe we have inadvertently collected Personal Data from a child without appropriate consent, please contact us at privacy@onemodel.co and we will promptly delete such data.

13. Third-Party Websites and Services

Our Website may contain links to third-party websites, integrations, or services that are not operated by One Model. This Privacy Policy does not apply to those third parties. We encourage you to review the privacy policies of any third-party websites or services you visit, as we have no control over and assume no responsibility for their content, privacy practices, or terms.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. We will indicate the "Last Updated" date at the top of this page. For material changes, we will provide prominent notice through the Website or by email (where we have your email address) at least 30 days prior to the changes taking effect, to the extent required by applicable law. Your continued use of the Website after the effective date of any update constitutes acceptance of the revised Privacy Policy.

15. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or our privacy practices, please contact our Privacy team:

One Model Inc. Email: privacy@onemodel.co Mail: 12-C Ledgebrook Drive, Suite 4, Mansfield Center, CT 06250

For inquiries related to data processing under a DPA, please contact your account representative or email privacy@onemodel.co referencing your Subscriber agreement.

16. Supervisory Authorities

If you are not satisfied with our response to your privacy inquiry, you may have the right to lodge a complaint with the relevant data protection authority:

Jurisdiction	Authority	Website
United States	U.S. State Department Privacy Office	state.gov
United Kingdom	Information Commissioner's Office (ICO)	ico.org.uk
European Union	European Data Protection Board (EDPB)	edpb.europa.eu
Canada	Office of the Privacy Commissioner	priv.gc.ca
Australia	Australian Communications and Media Authority (ACMA)	acma.gov.au

This Privacy Policy should be reviewed by qualified legal counsel prior to publication. It does not constitute legal advice.