Last Updated: October 2020

YOUR PRIVACY MATTERS

Modula Inc. (“Modula”) is committed to your privacy.  This Privacy Policy describes our practices with respect to personal and other information that we collect, including through your interactions with our US website (modula.us).  This policy does not apply to our European affiliates or their websites (e.g., modula.eu).  If you visit those websites, please refer to the privacy policies posted there.

INFORMATION WE COLLECT

“Personal Information” is information that identifies or could reasonably be used to identify an individual person or household.  We may collect and process the following Personal Information:

• Personal contact information such as name, address, telephone number and email address.

“Other Information” is any information that cannot reasonably be used to identify an individual person or household.  We may collect and process the following Other Information:

• Browser and device information.
• Information collected through cookies, pixel tags and other technologies.
• Information that has been aggregated in a manner such that it no longer reveals your specific identity.

If we are required to treat Other Information as Personal Information under applicable law, then we will collect, use and disclose it for the purposes for which we collect, use and disclose Personal Information as detailed in this Policy.

HOW WE COLLECT PERSONAL AND OTHER INFORMATION

We and our service providers may collect Personal Information online in several ways, including through:

• our website, including your providing your contact through the “Contact Us” page.
• emails and other communications you send to us.
• our social media properties (“Our Social Media”).
• extranet sites made available to our customers and third parties (“Extranet Sites”). 
• our interactions with you as part of our customer’s or potential customer’s organization.
• our registration process for newsletters and other communications and events.
• referral sources, joint marketing partners and event sponsors, when they share the information with us.

If you disclose any Personal Information relating to other people to us or to our service providers in connection with our products and services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

We and our service providers may collect Other Information in a variety of ways, including through:

• Your browser or your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the services (such as the App) you are using.  We use this information to ensure that our website functions properly for you.
• Cookies, which are pieces of information stored directly on the computer that you are using.  Cookies allow us to collect information such as browser type, time spent on the website, pages visited, language preferences and other traffic data.
• Pixel tags and other similar technologies.  Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of our website and response rates.
• Third-party services that help us recognize your device and understand how you use our site so that we can improve our communications with you.  Specifically, these partners collect information about your activity on our site to enable us to measure and analyze traffic and browsing activity on our site and show advertisements for our products and services to you on third-party sites.  We may share data, such as hashed email derived from emails or other online identifiers collected on our site with our advertising partners.  This enables our partners to recognize and deliver you ads across devices and browsers.  Among the third-party services we use is Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the services and report on activities and trends.  This service may also collect information regarding the use of other websites, apps and online resources.  You can learn about Google’s and YouTube’s practices by going to https://www.google.com/policies/privacy/partners/, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.  To view Google’s and YouTube’s privacy policy, please click [here].  Our partners may also use non-cookie technologies that you are not able to block through browser settings.  For this reason, you can use the following third-party tools to decline the collection and use of information for the purpose of serving you interest-based advertising:

                        The NAI’s opt-out platform: http://www.networkadvertising.org/choices/

                        The EDAA’s opt-out platform http://www.youronlinechoices.com/

                        The DAA’s opt-out platform: http://optout.aboutads.info/?c=2&lang=EN  

• Your computer’s IP address, which is automatically assigned by your Internet Service Provider.  An IP address may be identified and logged automatically in our server log files whenever a user accesses our systems, along with the time of the visit and the pages visited.  Collecting IP addresses is standard practice and is done automatically by many websites, applications and other systems.  We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the system. We may also derive your approximate location from your IP address.

We may use and disclose Other Information for any purpose, subject to applicable law.  If we combine Other Information with Personal Information, we will treat the combined information as Personal Information.

HOW WE USE PERSONAL INFORMATION

We and our service providers use the Personal Information we collect for legitimate business purposes, namely:

• To provide the information and communications you request, or that we believe may be of interest to you, with respect to our company and its products and services;
• To manage our relationships with our customers and potential customers, including contacting you or other individuals in connection with our products and services; and
• When applicable, to perform our contractual obligations to you or your organization.

HOW WE DISCLOSE PERSONAL INFORMATION

We may disclose Personal Information:

• To our affiliates and dealers, as applicable, for the purposes described in this Privacy Policy (you can find the names and locations of our affiliates and dealers in the Dealer Network page and in our Global Presence page).  Subject to local requirements, this information may be used such affiliates and dealers and for all the purposes outlined in this Privacy Policy.  Modula Inc. is the party responsible for the management of the jointly used Personal Information
• To our third-party service providers, to facilitate services they provide to us, such as website hosting, consulting and monitoring of our websites, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing and other services.
• On message boards, chat, profile pages, blogs and other services to which you are able to post information and content [(including, without limitation, Our Social Media)], or through which you are able to send messages through our systems.  Please note that any information you post or disclose through these systems will become public and may be available to other users and the general public. 
• To comply with applicable law and regulations, including laws outside your country of residence.
• To cooperate with public and government authorities, including authorities outside your country of residence.
• To cooperate with law enforcement.
• For other legal reason, such as to enforce our terms and conditions and to protect the rights, privacy, safety or property of our company, our affiliates, you or others.
• In connection with the sale or our company or our business assets.

HOW LONG WE RETAIN PERSONAL INFORMATION

We retain Personal Information for as long as needed or permitted for the purposes for which it was obtained, consistent with applicable law.  Specifically, we will consider whether:

• Our relationship with you or your organization is still continuing.
• We have a continuing legal obligation to keep records of your transactions or communications.
• Retention is advisable in light of our legal position (e.g., in regard to applicable statutes of limitations, litigation or regulatory investigations).

YOUR CHOICES

You have choices regarding marketing-related communications.  If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt out by following the unsubscribe instructions in any such message or by contacting us by email at [email protected]. We will try to comply with your request as soon as reasonably practicable.  Please note that if you opt out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt out.

PRIVACY RIGHTS FOR RESIDENTS OF THE EUROPEAN ECONOMIC AREA

If you are resident in the European Economic Area (“EEA”), under European law you have the following rights in respect of your Personal Information that we hold:

• Access.  You have the right to obtain confirmation of whether, and where, we are processing your Personal Information; information about the categories of Personal Information we are processing, the purposes for which we process your Personal Information and how we determine applicable retention periods; information about the categories of recipients with whom we may share your Personal Information; and a copy of the Personal Information we hold about you.
• Portability.  You have the right, in certain circumstances, to receive a copy of the Personal Information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your Personal Information to another person.
• Rectification.  You have the right to obtain rectification of any inaccurate or incomplete Personal Information we hold about you without undue delay.
• Erasure.  You have the right, in some circumstances, to require us to erase your Personal Information without undue delay if the continued processing of that Personal Information is not justified.
• Restriction.  You have the right, in some circumstances, to require us to limit the purposes for which we process your Personal Information if the continued processing of the Personal Information in this way is not justified, such as where the accuracy of the Personal Information is contested by you.
• Objection.  You have a right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation.  There may be compelling reasons for continuing to process your Personal Information, and we will assess and inform you if that is the case.  You can object to marketing activities for any reason.
• Post-Mortem (residents of France only).  If you reside in France, you have the right to set guidelines for the retention and communication of your Personal Information after your death.

If you wish to exercise one of these rights, please contact us at [email protected].

You also have the right to lodge a complaint with your local data protection authority.

Residents in other jurisdictions may also have similar rights to the above.  Please contact us at [email protected] if you would like to exercise one of these rights, and we will comply with any request to the extent required under applicable law.

PRIVACY POLICY AND RIGHTS FOR CALIFORNIA RESIDENTS

This California Privacy Policy is intended to comply with the California Consumer Privacy Act (CCPA), California Online Privacy Protection Act (CalOPPA), California Notice Data Security Act and other applicable privacy laws.  Consumers with disabilities may access this policy in an alternative format by sending an email to: [email protected].

For purposes of this California Privacy Policy, “Personal Information” means anything that identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular California consumer or household.

Modula Inc. does not sell Personal Information.

As a California resident, you have the following rights regarding the Personal Information we collect about you:

• Right to Notice.  You have the right to receive notice of the categories of Personal Information we collect prior to or at the time we collect your Personal Information.  The Personal Information we collect about California residents is described above in the section titled INFORMATION WE COLLECT.  The business or commercial purposes for the collection of your Personal Information are described above in the section titled HOW WE USE PERSONAL INFORMATION.
• Right to Know.  You have the right to know about the Personal Information we collected and disclosed about you and your household during the prior 12 months.  You can obtain the Personal Information we collected and/or disclosed about you by calling us at our toll-free telephone number: 1-877 648 9755 or emailing us at: [email protected]. To ensure that the request is coming from you and to protect the security of your Personal Information, we may require you to provide us with certain information to verify your identity such as your email address, your telephone number, a description of the product or service you purchased or inquired about, the dollar amount of your last purchase and a signed declaration under penalty of perjury from you that you are the consumer whose Personal Information is subject to the request.  You may use an authorized agent to exercise your right to know if the authorized agent has your power of attorney act to on your behalf or your written authorization permitting such agent to request access to your Personal Information.
• Right to Delete.  You have the right to request us to delete the Personal Information that we have collected or maintained about you and your household.  You can make this request by calling us at our toll-free telephone number: 1-877 648 9755 or emailing us at: [email protected]. To ensure that the request is coming from you and to protect the security of your Personal Information, we may require you to provide us with certain information to verify your identity such as your email address, your telephone number, a description of the product or service you purchased or inquired about, the dollar amount of your last purchase and/or a signed declaration under penalty of perjury from you that you are the consumer whose Personal Information is subject to the request. You may use an authorized agent to exercise your right to delete if the authorized agent has your power of attorney to act on your behalf or your written authorization permitting such agent to request deletion of your Personal Information.
• Right to Nondiscrimination.  You have the right to receive our products and services on equal terms regardless of whether or not you exercise your rights under the CCPA.
• Right to Request Information about Disclosures.  You may request information about any disclosures of categories of Personal Information we make to our affiliates or third parties for their direct marketing purposes.  We will provide a list of the categories of Personal Information disclosed to third parties or our affiliates for their direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties or affiliates.  Your request may be made no more than once per calendar year.  You may submit your request by emailing us at: [[email protected]].  We do not respond to “Do Not Track” requests.

If you have questions or concerns regarding this Privacy Policy, please email us at: [email protected]

PRIVACY RIGHTS FOR NEVADA RESIDENTS

You have the right to direct us not to sell certain personally identifiable information that we collect about you on our websites or other online services by emailing us at [email protected]. This information includes: your first name or first initial and last name in combination with your social security number; driver’s license number, driver authorization card number or identification card number; account number, credit card number or debit card number, in combination with any required security code, access code or password that would permit access to your financial account; medical identification number or a health insurance identification number; user name, unique identifier or electronic mail address in combination with a password, access code or security question and answer that would permit access to an online account.

Additionally, you may review and request that we change the personally identifiable information that we collect about you on our websites or other online services by emailing us at [email protected].

Our service providers and other third parties may collect personally identifiable information about your online activities over time and across different internet websites or online services when you use our website or other online services.

THIRD-PARTY SERVICES

Except as specifically provided herein, this Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties.  This includes any third party operating any website or service to which our website may link.  The inclusion of a link does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to such other organizations through or in connection with [Our Social Media].

USE OF OUR SERVICES BY MINORS

The goods and services we provide are not directed to individuals under the age of majority and we do not knowingly collect Personal Information from such individuals.

CROSS-BORDER TRANSFER

Your Personal Information may be stored and processed in any country where we have affiliates, outlets and facilities or in which we engage service providers.  By using our services you understand that your information may be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.  In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards.  You may obtain more information by reaching out to us at [email protected].

UPDATES TO THIS PRIVACY POLICY

The “LAST UPDATED” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised.  Any changes will become effective when we post the revised Privacy Policy.  Your use of our online services following these changes means that you accept the revised Privacy Policy.

HOW TO CONTACT US

Modula Inc. is the company responsible for collection, use and disclosure of your Personal Information under this Privacy Policy.

If you have any questions about this Privacy Policy, please contact us at [email protected]