GDPR Compliance

Last Updated: September 2026

Overview

The General Data Protection Regulation (GDPR) is a European Union regulation that strengthens and unifies data protection for individuals within the EU and EEA. Even though Model Communicator is operated from the United States, we respect the rights of all our users and apply GDPR principles to our handling of personal data for everyone.

This page outlines how Model Communicator complies with GDPR requirements, your rights as a data subject, and how to exercise those rights.

Data Controller

The data controller for Model Communicator is:

Model Communicator
Jim Tyler
Michigan, United States of America
jim@modelcommunicator.com

As data controller, Jim Tyler is responsible for determining the purposes and means of processing personal data collected through Model Communicator.

Legal Basis for Processing

Under Article 6 of the GDPR, we process personal data based on the following legal grounds:

Consent (Article 6(1)(a)) -- When you create an account and sign in with Google SSO, you consent to the collection and processing of your email address and the storage of your custom grid data.
Legitimate Interest (Article 6(1)(f)) -- We have a legitimate interest in processing minimal anonymized usage data to maintain service quality. This processing is balanced against your rights and does not override your fundamental freedoms.
Consent (Article 6(1)(a)) -- Google Analytics runs on this marketing website only after you choose "Accept All" on our cookie banner. Until then no analytics request is made and no analytics cookie is set.

You may withdraw your consent at any time by deleting your account. Withdrawal of consent does not affect the lawfulness of processing that occurred before the withdrawal.

Data We Process

Model Communicator processes a minimal amount of personal data. Here is a complete list:

Data Category	Specific Data	Purpose	Legal Basis
Identity	Email address	Account authentication	Consent
User Content	Custom communication grids	Cloud storage and sync	Consent
Preferences	Grid size, voice, language	Personalize experience	Consent
Technical	Anonymized page views	Service improvement	Legitimate interest

Data We Do NOT Process

Communication content (words, sentences, utterances)
Health data or special category data (Article 9)
Biometric data
Genetic data
Political opinions, religious beliefs, or trade union membership
Location or geolocation data
Behavioral profiling data
Data for automated decision-making or profiling

Data We Do NOT Process

Model Communicator does not process the following categories of data:

Communication content (words, sentences, utterances)
Health data or special category data (Article 9)
Biometric data
Genetic data
Political opinions, religious beliefs, or trade union membership
Location or geolocation data
Behavioral profiling data
Data for automated decision-making or profiling

Model Communicator is an AAC communication tool, and while it may be used by individuals with disabilities, it does not collect or process health-related data. Communication content is processed entirely on the user's device and never reaches our servers.

Your Rights Under GDPR (Articles 15-21)

As a data subject, you have the following rights under the GDPR. We honor these rights for all users, regardless of location:

Right of Access (Article 15)

You have the right to obtain confirmation of whether we process your personal data, and to receive a copy of that data. Contact us and we will provide your data within 30 days.

Right to Rectification (Article 16)

You have the right to request correction of inaccurate personal data. Since your email is provided by Google SSO, email changes should be made through Google. Custom grid data can be edited directly in the app.

Right to Erasure (Article 17)

You have the right to request deletion of your personal data. You can delete individual grids in the app, or request full account deletion by contacting us. We will complete deletion within 30 days.

Right to Restriction (Article 18)

You have the right to request that we restrict processing of your personal data in certain circumstances, such as while we verify the accuracy of your data or evaluate an objection you have raised.

Right to Data Portability (Article 20)

You have the right to receive your personal data in a structured, commonly used, machine-readable format. We can export your custom grids as JSON files upon request.

Right to Object (Article 21)

You have the right to object to processing of your personal data based on legitimate interests. If you object, we will cease processing unless we can demonstrate compelling legitimate grounds.

To exercise any of these rights, email us at jim@modelcommunicator.com. We will respond to your request within 30 days. There is no charge for exercising your rights.

International Data Transfers

Model Communicator is hosted in the United States. If you are located in the EU, EEA, or UK, your personal data will be transferred to and stored in the United States.

We rely on the following mechanisms to ensure adequate protection for international transfers:

Standard Contractual Clauses (SCCs) -- our infrastructure provider, Microsoft Azure, incorporates EU-approved standard contractual clauses in its data protection terms
Google Analytics -- where you have consented to analytics cookies, Google processes that data under its own standard contractual clauses
Your explicit consent -- by creating an account, you consent to the transfer of your data to the US for processing

Our infrastructure providers, Microsoft Azure and Clerk, maintain certifications and compliance frameworks that meet EU adequacy requirements, including SOC 2 Type II and ISO 27001.

Data Retention

We retain personal data according to the following schedule:

Active accounts: Data is retained for as long as your account remains active and you continue to use Model Communicator
Account deletion: Upon request, all personal data (email, custom grids, preferences) is permanently deleted within 30 days
Inactive accounts: We may reach out to inactive accounts before taking any action on them. We do not automatically delete accounts due to inactivity.
Anonymized data: Aggregate, anonymized analytics data that cannot identify any individual may be retained indefinitely for service improvement

Data Protection Officer

Model Communicator is a free, independently maintained project. Given the scale of the project and the minimal amount of personal data we process, we have not appointed a formal Data Protection Officer (DPO) as described in Articles 37-39 of the GDPR.

For all data protection inquiries, please contact Jim Tyler directly at jim@modelcommunicator.com. All data protection requests are handled personally and promptly.

Supervisory Authority

If you are located in the EU or EEA, you have the right to lodge a complaint with your local data protection supervisory authority if you believe that our processing of your personal data infringes on the GDPR.

We encourage you to contact us first at jim@modelcommunicator.com so we can try to resolve your concern directly. However, this does not affect your right to contact your supervisory authority at any time.

Cookie Consent

Model Communicator uses a small number of essential cookies required for the application to function. We do not use advertising cookies. This website also uses Google Analytics, which is loaded only after you give consent. A cookie consent banner is displayed on your first visit to allow you to make an informed choice.

For a complete list of cookies we use and how to manage them, please visit our Cookie Policy.

Changes to This Policy

We may update this GDPR compliance page from time to time to reflect changes in our practices or legal requirements. When we make changes, we will update the "Last Updated" date at the top of this page.

For significant changes that affect your rights, we will provide notice through the application or via email.

Contact Us

For any questions about GDPR compliance, to exercise your data rights, or for any data protection concern, please contact us:

Email: jim@modelcommunicator.com
Data Controller: Jim Tyler
Project: Model Communicator
Location: Michigan, USA