Open Model ("Open Model", "we", "us", "our") is a marketing technology platform operated by Sonra Digital Pty Ltd, a company incorporated in Australia. Open Model provides self-serve Marketing Mix Modelling (MMM) software accessible at openmodel.pro.
For the purposes of applicable data protection law, Sonra Digital Pty Ltd acts as the data controller in respect of personal data processed through the Open Model platform and website. Our contact details are set out in Section 13.
We use personal data for the following purposes:
We rely on the following legal bases under the General Data Protection Regulation: Contract (Article 6(1)(b)) for delivering the platform; Legitimate interests (Article 6(1)(f)) for security, fraud prevention, and anonymised analytics; Consent (Article 6(1)(a)) for marketing emails; and Legal obligation (Article 6(1)(c)) for compliance requirements. Where we process special category data, we rely on explicit consent (Article 9(2)(a)).
The same legal bases apply under the UK GDPR as retained and amended in domestic UK law. For transfers from the UK, we rely on adequacy regulations or standard contractual clauses as appropriate. Our UK representative contact is set out in Section 13.
We comply with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth). We collect personal information only where reasonably necessary for our functions and activities, and notify individuals of our collection at or before the time of collection as required by APP 5. We do not use government-related identifiers as our own identifiers.
Under the California Consumer Privacy Act (as amended by the CPRA), California residents have additional rights described in Section 8. We do not sell personal information as defined under the CCPA, and we do not share personal information for cross-context behavioural advertising. The categories of personal information we collect and our business purposes for collection are described in Sections 2 and 3 above.
We do not sell, rent, or trade your personal information. We share data only in the following limited circumstances:
All third-party service providers are contractually bound to process personal data only on our instructions and to maintain appropriate security measures.
Open Model is operated from Australia, and our infrastructure runs on Google Cloud Platform. Your data may be processed in Australia, the United States, and other countries where our service providers operate.
Where we transfer personal data outside the European Economic Area, we ensure an adequate level of protection through: (a) transfers to countries with an EU adequacy decision; or (b) standard contractual clauses (SCCs) approved by the European Commission under Article 46(2)(c) GDPR; or (c) other appropriate safeguards permitted under GDPR Chapter V.
For transfers of UK personal data outside the UK, we rely on the UK's International Data Transfer Agreement (IDTA) or UK addendum to EU SCCs as appropriate, in accordance with Section 119A of the Data Protection Act 2018.
Before disclosing personal information to overseas recipients, we take reasonable steps to ensure that the overseas recipient does not breach the APPs in relation to that information, in accordance with APP 8.1.
We retain personal data only for as long as necessary for the purposes set out in this policy, or as required by law. Our standard retention periods are:
When data is no longer required, we securely delete or anonymise it.
Depending on your location, you have the following rights regarding your personal data. To exercise any right, contact us at the details in Section 13. We will respond within 30 days (or sooner where required by law).
Access (Art. 15) · Rectification (Art. 16) · Erasure (Art. 17) · Restriction of processing (Art. 18) · Data portability (Art. 20) · Object to processing (Art. 21) · Withdraw consent at any time · Lodge a complaint with your supervisory authority. For EU residents: your national data protection authority. For UK residents: the Information Commissioner's Office (ICO), ico.org.uk.
You have the right to access the personal information we hold about you (APP 12), to correct inaccurate information (APP 13), and to make a complaint to the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au if you believe we have interfered with your privacy.
You have the right to: Know what personal information we collect, use, disclose, or sell · Delete your personal information · Correct inaccurate personal information · Opt out of the sale or sharing of personal information (we do not sell or share) · Limit use of sensitive personal information · Non-discrimination for exercising your rights. To submit a verifiable consumer request, contact us at privacy@openmodel.pro. We will not discriminate against you for exercising your CCPA rights.
Email privacy@openmodel.pro with your name, email address, and a clear description of your request. We may ask for information to verify your identity before processing your request. There is no charge for reasonable requests.
We use cookies and similar tracking technologies on our website. You can control non-essential cookies through the cookie preference centre available on our website or via your browser settings.
Strictly necessary for the website and platform to function. These cannot be disabled. They include session authentication, security tokens, and load balancing.
Used to understand how visitors interact with our website in aggregate, anonymised form. We use privacy-respecting analytics tooling and do not share this data with third-party advertising platforms.
Only set with your prior consent. Used to track the effectiveness of our own marketing and early access campaigns. We do not operate retargeting or cross-site behavioural advertising.
Non-essential cookies are only placed with your prior, freely given, specific, and informed consent in accordance with the ePrivacy Directive (EU) and the Privacy and Electronic Communications Regulations 2003 (UK). You may withdraw cookie consent at any time through our preference centre.
We implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. These measures include:
In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours (GDPR / UK GDPR) or as soon as practicable (Australian Privacy Act), and will notify affected individuals without undue delay where required.
Open Model is a professional B2B platform not directed at individuals under the age of 18 (or 16 where applicable under GDPR). We do not knowingly collect personal information from children. If you believe we have inadvertently collected data from a minor, please contact us immediately at privacy@openmodel.pro and we will delete it promptly.
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. When we make material changes, we will notify you by email to the address associated with your account and update the "Last updated" date at the top of this page. We will provide at least 30 days' notice before material changes take effect for existing users.
Your continued use of Open Model after the effective date of an updated policy constitutes your acceptance of the changes. If you do not agree to the updated policy, you must cease using the platform and may request deletion of your data.
For all privacy enquiries, to exercise your rights, or to make a complaint, please contact our Privacy Officer:
We ask that you contact us in the first instance to attempt to resolve any privacy concern directly. We take all complaints seriously and will respond within 30 days.