Module adheres to the following policies with regard to Your privacy.
- “NPI” is information that is not personally identifiable and that is obtained through Your use of the Service.
- “PII” is non-public information that is personally identifiable and obtained in connection with providing a product or service to You, including personally identifiable information You provide during the registration process or during Your use of the Service. It may include information such as name and address that You provide to Module. PII does not include information that has been made anonymous or aggregated so that it can no longer be used, whether in combination with other information or otherwise, to contact or identify You.
- HOW MODULE SENDS INFORMATION TO YOU
- As part of the Service, Module may send You this information through SMS text messages, email, or other channels.
- To receive information from Module through SMS text messages, You must provide us with Your mobile phone number and respond to the SMS text message that Module sends to that number as part of the verification process. Your mobile phone carrier’s standard messaging rates will apply. If You opt-in to receive SMS text messages from Module, You will receive one (1) to twenty (20) text messages per week. You may opt-out of and opt-in to receiving these text messages at any time by texting “STOP.”
- Module may also send You information through email, or other channels. You may opt-out of receiving emails from us through email by clicking on the “Unsubscribe” link contained in each email.
- INFORMATION COLLECTION
- When You use the Service, Module collects NPI, for example, Your device’s browser type. Likewise, in order to offer You meaningful products and services and for other reasons, Module may collect PII about You from the following sources:
- Information transmitted from Your mobile device, including information described in Section 3(d) below; or
- Information You create or Information You give Module on applications or other forms while using the Service; or
- Information You send Module via any medium, including, but not limited to email, telephone, and social media interaction.
In order to use certain portions of the Service, You must provide Module the following information: email address, and first and last name, and create a password. In addition, You may choose to add additional information to Your account, for example an estimated budget. Module may request other information from You during or after the registration process that Module uses to provide better and more customized services to its customers.
Module may also use web beacons, pixels, anonymous ad network tags, cookies and similar technologies to collect NPI about Your use of the Service and the websites of selected sponsors and advertisers, to collect anonymized, aggregated auditing, research and reporting for advertisers, and to collect data related to Your use of special promotions or newsletters. The information collected by web beacons also allows Module to statistically monitor how many people open Module’s emails and for what purposes these actions are being taken. Module’s web beacons are not used to track Your activity outside of the Service or the websites of Module’s sponsors. In addition, Your web browser requests advertisements and web beacons directly from ad network servers, these networks can view, edit or set their own cookies, just as if You had requested a web page from their site. Module may link NPI from web beacons, cookies, and related technologies collected during Your use of the Service to Your PII.
- Log Files, IP Addresses and Information About Your Device
When You use the Service, Module may automatically receive the URL of the site from which You came and the site to which You are going when You leave Module’s Service. Module also receives the IP address (and approximate city based on same) of Your computer (or the proxy server You use to access the internet), Your computer operating system and type of web browser You are using, email patterns (e.g., email open statistics), Your mobile device, including Your Unique Device Identifier (“UDID”) and mobile operating system, as well as the name of Your ISP or Your mobile carrier. The link between Your IP address and Your PII is not shared with third parties without Your permission, except as described in Section 8 (“When Module May Disclose Your Information”), below.
Do Not Track: Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including Module, do not respond to DNT signals.
- Usage Data
- SMS and Call Data
If You communicate with us by phone or through SMS texts, as part of providing You the Service, Module may receive SMS and/or call data, such as the date and time of the call or SMS, the sending and receiving phone numbers, and the content of the SMS message.
- USE OF PII
- From time to time, Module may disclose the information collected from You, including PII, in accordance with Section 8 (“When Module May Disclose Your Information”), below.
- Module uses and/or intends to use PII to:
- Operate and improve the Service;
- Create Your account;
- Provide You with the Service and other products and services that You may request or that You have expressed interest in;
- Evaluate Your interest and needs in order to improve the Service and make available other offers, products or services;
- Evaluate the types of offers, products or services Module makes available to You and potential customers;
- Track use of the Service;
- Provide customer support;
- Communicate and provide additional information that may be of interest to You through email or other means, such as special offers, announcements, and marketing materials;
- Send You reminders, technical notices, updates, security alerts and support and administrative messages, service bulletins, or marketing;
- Provide advertisements to You through email messages;
- Create reports based on anonymized and aggregated PII to be made available to industry members, provided that such reports will not themselves contain PII; and
- Manage Module’s everyday business needs such as Service administration, forum management, fulfillment, analytics, fraud prevention, enforcement of Module’s corporate reporting obligations, Terms of Service or to comply with the law.
- LINKS/POSTINGS TO OTHER SITES
You may access the Service on a third-party website and/or the Service may contain links to other websites. Module is not responsible for the actions, practices, or content of such websites linked to or from any of the Service. You understand that such websites may have their own legal documents to which You must agree prior to using and that Module has no control over these legal documents. As always, You understand that it is Your responsibility to verify Your legal use of a website as well as use of information from the website with the corresponding website owner. Module does not guarantee, approve, or endorse any information, material, services, or products contained on these third-party websites. Module is not responsible for any content on sites linked from or to the Service or for obtaining any necessary consent for such third-party websites to collect, transmit, or otherwise use Your information.
- USE OF AGGREGATE DATA
Module may combine NPI, including anonymized data, You provide through the Service with information from other users to create aggregate data that may be disclosed to third parties. Aggregate information disclosed to third parties does not contain any information that could be used to identify You and does not include Your PII.
- WHEN MODULE MAY DISCLOSE YOUR INFORMATION
- Module may share PII Module collects, as permitted by law, to companies such as credit reporting agencies, or servicing and processing companies, or when required or advised to do so in response to a valid legal requirement to release this information such as a state or federal law, regulation, search warrant, subpoena, or court order; or in special cases, such as in response to a physical threat to You or others, to protect property, or if Module determines such disclosure is legally advisable or necessary to defend or assert legal rights or prevent harm, to defend ourselves in litigation. In the event that Module is legally compelled to disclose Your PII to a third party, Module will attempt to notify You unless doing so would violate the law or court order.
- Module may share PII in accordance with Section 11 (“Transfer of Ownership”), below.
- Module may share and/or sell aggregated data in accordance with Section 7 (“Use of Aggregate Data”).
- If You prefer that Module does not share certain PII with third parties, as described above, You can direct Module not to share that PII by contacting Module (email@example.com). Please note that an opt-out with respect to information sharing will not apply to information sharing arrangements described in Sections 8.B. or 8.C.
- SECURITY POLICY & USER ID/PASSWORD
- Module policies limit access to un-aggregated user PII that is collected from the Service to Module employees and agents and the employees and/or agents of Module’s affiliates and business partners who need the information to fulfill their business responsibilities, and who are under obligations of confidentiality.
- Module shall maintain appropriate administrative, physical and technical safeguards to protect the security, confidentiality and integrity of Your data. These safeguards include encryption of Your data in transmission (using SSL or similar technologies), except for external third party integrations that You may link to the Service at Your choice, if available, that do not support encryption, and encryption of backups of databases. If Module provides the capability for You to create a user ID and password, You should protect Your user ID and password and NOT share it with anyone. If You believe Your user ID and password have been compromised and You have trouble changing Your user ID/password on the Service, please contact Module’s technical support department (firstname.lastname@example.org).
- CAN-SPAM COMPLIANCE NOTICE
You can opt out of receipt of further email correspondence from Module by contacting Module at email@example.com.
- TRANSFER OF OWNERSHIP
- NOTICE TO RESIDENTS OF COUNTRIES OUTSIDE OF THE UNITED STATES OF AMERICA
- CALIFORNIA PRIVACY RIGHTS
Pursuant to Section 1798.83 of the California Civil Code, residents of California can obtain certain information about the types of PII that companies with whom they have an established business relationship have shared with third parties for direct marketing purposes during the preceding calendar year. In particular, the law provides that companies must inform consumers about the categories of PII that have been shared with third parties, the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. To request a copy of the information disclosure provided by Module pursuant to Section 1798.83 of the California Civil Code, please contact Module via email to firstname.lastname@example.org.
- PROTECTING CHILDREN’S PRIVACY
- Use of the Service is limited to users who are eighteen (18) years of age or older.
- Module strongly believes in protecting the privacy of children. In line with this belief, Module does not knowingly collect or maintain PII from the Service from persons under eighteen (18) years of age, and no part of the Service is directed to persons under eighteen (18) years of age. If You are under eighteen (18) years of age, then please do not use or access the Service at any time in any manner. Module will take appropriate steps to delete any PII of persons less than eighteen (18) years of age that has been collected on the Service without verified parental consent upon learning of the existence of such PII.
- GENERAL DATA PROTECTION REGULATION (GDPR)
- Module’s policy is to protect and safeguard any PII obtained by Module in accordance with applicable United States state and federal laws governing the protection of PII and data. Those who choose to access the Service from locations outside the United States do so on their own initiative, and are responsible for compliance with local laws if and to the extent local laws are applicable.
- Module does not target or knowingly collect data from users in the EU. If You are an EU or United Kingdom resident and believe Module may have collected PII from You, subject, as the case may be, to additional elements that may be required to establish Your identity, You may send Module an e-mail at email@example.com to request, at no charge, to delete any information Module may have collected from You.
- HOW LONG WE RETAIN YOUR INFORMATION
Module keeps Your PII only as long as necessary for the purposes for which the PII are processed and as permitted by applicable law.
In practice, Module deletes or anonymizes Your PII upon deletion of Your account, unless:
- Module must keep it to comply with applicable law;
- Module must keep it to evidence our compliance with applicable law;
- there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
- the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users’ safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account.
Keep in mind that even though Module’s systems are designed to carry out data deletion processes according to the above guidelines, Module cannot promise that all data will be deleted within a specific timeframe due to technical constraints.
Module Design, Inc.
Chief Product Officer
6401 Penn Ave.
Pittsburgh, PA 15206