This Privacy Statement will inform you of:
What personal information we gather about you when you are browsing our Site or using our Services.
How we use and with whom we share the personal information we gather.
Your ability to opt out of future notifications.
What security procedures we have in place to protect your personal information from loss, misuse, or alteration.
How you can correct or update your personal information.
Use of Modolabs.com constitutes your consent to the terms of our Privacy Statement. Whenever you submit information via our Sites, you consent to the collection, use, and disclosure of that information in accordance with this Privacy Statement.
Please note that our Site and Services contain various links to other unaffiliated third-party websites. Modo Labs is not responsible for the privacy practices, privacy statements, or content contained in or regarding these other unaffiliated third-party websites that do not include this Privacy Statement.
II. PERSONAL INFORMATION
There are a few ways in which you may explicitly and intentionally provide us with and consent to our collection of certain personal information:
When you interact with us through the Site, in-person or the Services, we may collect Personal Data and other information from you, as further described below:
Personal Data That Modo Processes Through the Service (Modo is the Data Processor)
We collect the following kinds of personal information from our Clients:
Contact information such as name, email address
Application registration information such as phone number
Unique identifiers such as user name, account number or name, password
We use this information to:
Send you an order confirmation
Respond to customer service requests
Administer your account
Modo Labs collects information under the direction of its Clients, and has no direct relationship with the individuals whose Personal Data it processes. Modo Labs works with its Clients to help them provide notice to their customers concerning the purpose for which Personal Data is collected.
Modo Labs has no direct relationship with the individuals whose Personal Data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his/her query to the Client’s Administrator (the data controller). If the Client requests Modo Labs to remove the data, we will respond to their request within 15 business days.
Personal Data That You Provide Through the Site or in-person (Modo as Data Controller):
We collect the following kinds of personal information from our Clients:
Business Card Contact information such as name, professional email address, business phone number, title, name of your organization
We do also capture the IP Address associated with your device as discussed below
We use this information:
To confirm/fulfill your request
To respond to customer service requests, your comments or suggestions
For direct marketing
Overall Use of this Site. When you use our Site, we reserve the right to collect information about how the Site is being used in order to improve the performance of our Site and make our Site more useful to individuals. The information we collect during this activity is used to improve the performance of our Site, unless otherwise identified in this Privacy Statement.
Request for Information or Registrations for Webinars or other in-person events. We may include links throughout our Site to provide you with the opportunity to contact us via email to ask questions, request information and materials, register or sign up for webinars or events, or provide comments and suggestions. We collect the contact information you provide in order to respond to your requests. You may also be offered the opportunity to have one of our representatives contact you personally to provide additional information about our products or services. To do so, we may request additional personal information from you, such as your name and telephone number, to help us satisfy your request. We also use this information for direct marketing.
Non-Identifiable or Aggregated Data:
When you interact with Modo Labs through the Site or Services, in addition to other information, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. Modo Labs may store such information itself or such information may be included in databases owned and maintained by Modo Labs affiliates, agents or service providers. We may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, the domain names of our visitors’ Internet service providers, and how our users use and interact with the Services. Also, in an ongoing effort to better understand and serve the users of the Services, Modo Labs often conducts research on its customer demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis. Modo Labs may share this non-identifiable and aggregate data with the business you work for and our affiliates, agents and business partners, but this type of non- identifiable and aggregate information does not identify you personally. Modo Labs may also disclose aggregated user statistics in order to describe our Services to current and prospective business partners, and to other third parties for other lawful purposes.
In addition to the personal information identified above, we use “cookies” and other statistical and tracking technologies as described in this Section in connection with the operation of our Site. A cookie is a piece of information that our Site sends to your browser, which then stores this information on your system. We may use both temporary and persistent cookies based on the cookie’s purpose. Some cookies are deleted when you close down your browser. These are known as session cookies. Others remain on your device until they expire or you delete them from your cache. These are known as persistent cookies and enable us to remember things about you as a returning visitor to our Covered Sites.
We use these technologies in four ways:
To provide a product or service: A cookie may be used to provide you with a specific product or service. For instance, if you request a Site to remember your login password or remember your profile in a response to a blog post, the site will deposit a cookie on your computer to facilitate that product or service. The information contained in these cookies consists of random data that is used by our server to authenticate the browser requests to the server for that particular session. These cookies do not include any type of personal information. This bit of information is erased when you close your current browser window. If you choose not to accept a temporary cookie, you will not be able to navigate in these online applications. We also use a cookie when you visit our Site and request documentation or a response from us. When you are filling out a form, you may be given the option of having our Site deliver a cookie to your local hard drive. You might choose to receive this type of cookie in order to save time in filling out forms and/or revisiting our Site.
To understand our visitors: When you visit our Site, our systems may automatically collect statistics in aggregate about visitor behavior. We may monitor statistics and other data such as how many people visit our site, the user’s IP address, which pages people visit, how users interact with page content and functionality, from which domains our visitors come, which browsers people use and how they move about our Site. We use this data about your visit for aggregation purposes only. These statistics are used to help us to understand our visitors’ interests and improve the content and performance of our Site. We use this information for statistical and marketing purposes.
We also use a cookie when we track traffic patterns on our Site. Analysis of the collected information by our tracking technologies allows us to improve our Site and the user experience. If you choose not to accept a persistent cookie, you will still be able to use our Site. Even if you choose to receive this type of cookie, you can always set your browser to notify you when you receive any cookie, giving you the chance to decide whether to accept it in each situation in which one is sent. We may supplement this unidentified user data with other data to better understand our users. For instance, we may relate a user’s IP address to the company to which it relates to better understand our visitors’ interests.
To advertise: We may tailor our advertisements to certain users based on the user data and related information. You can opt out of this tracking by accessing the link below. You will need to invoke these opt-out procedures on each computer you use.
All major Internet browsers allow you to control cookies. You can learn more about adjusting browser controls at the following website: http://www.aboutcookies.org. Note that Modo does not control this website and is not responsible for its content. The link to this website is provided here as information only.
IV. HOW WE USE AND WITH WHOM WE SHARE THE PERSONAL INFORMATION WE GATHER
Our Disclosure of Your Personal Data and Other Information:
As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets. If Modo Labs is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your Personal Data, as well as any choices you may have regarding your personal information.
Agents, Consultants and Related Third Parties:
Modo Labs, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include an email service provider that sends out mailing information on our behalf and a hosting provider for maintaining our databases. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function. In all cases, we review privacy and security documentation to provide reasonable assurance that entities have appropriate privacy programs. Modo Labs will always have a contract in place with any service provider to further provide assurance of privacy controls, including non-disclosure.
Upon notice, Modo Labs will take reasonable and appropriate steps to stop and/or remediate unauthorized or unlawful processing.
Lawful Requests / Legal Requirements:
Modo Labs may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Modo Labs, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.
You can use the Site without providing any Personal Data. This will require you to turn off cookies in your browser. In addition, if you choose not to provide any Personal Data, you may not be able to use certain Services, access certain resources, or register for webinars and other events.
Our Site may offer publicly accessible blogs or community forums (“Public Areas”). You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at email@example.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
V. Information for customers in Designated Countries
Section 5 only applies to individuals located in the European Union (EU) or Switzerland and applies to Modo Labs’ role as both Data Processor for our customers and Data Controller for direct marketing.
Modo Labs participates in and has certified its compliance with the EU-U.S. & Swiss-US Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information transferred from the European Union (EU) & Switzerland, to the United States, respectively. Modo Labs is committed to subjecting all Personal Information received from the EU member countries & Switzerland in reliance on the Privacy Shield Frameworks, to the Framework’s applicable Principles. If there is any conflict between the terms in this Privacy Statement and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit U.S. Department of Commerce’s Privacy Shield List. https://www.privacyshield.gov/welcome
Modo Labs is responsible for the processing of Personal Information it receives, under the Privacy Shield Framework, or subsequently transfers to a third party acting as an agent on its behalf. Modo Labs complies with the Privacy Shield Principles for all onward transfers of Personal Information from the EU & Switzerland including the onward transfer liability provisions.
With respect to Personal Information received or transferred pursuant to the Privacy Shield Frameworks, Modo Labs is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.
With new global, regional and local privacy laws coming into effect, it is important for Modo Labs to make sure our Clients understand that they have the power to limit whom Modo Labs send their personal information to if the purpose for sending that data is outside of the service requested by that customer.
If you would like further information in relation to your legal rights under applicable law or would like to exercise any of them, please contact us using the information below at any time. Your local laws may permit you to request that we:
provide a copy of certain information we hold about you
prevent the processing of your information for direct-marketing purposes (including any direct marketing processing based on profiling)
update information which is out of date or incorrect
delete certain information which we are holding about you
restrict the way that we process and disclose certain of your information to 3rd parties.
Limit whom we share your data with if that is outside the of the services we provide, though Modo Labs does not share personal data from our Clients outside of sharing for the purpose of providing services.
Each marketing communication we send you will contain conspicuous instructions permitting you to “opt-out” of receiving future marketing communications. Note however that as user of the Service you cannot opt-out of some administrative communications that are reasonably necessary to the Service, such as billing or service notifications.
In addition to notices on our marketing communications, if at any time you wish not to receive any future marketing communications, keep your Personal Data accurate, current, & complete or you wish to have your name deleted from our mailing lists, please contact us as outlined immediately below, Section 8 or contact our Article 27 European
Modo Labs Attn:
VP of Operations
100 Cambridgepark Dr, Ste 200
Cambridge, MA 02140
By Phone: 1-888-663-6522 (MODO LAB)
We will respond to any request 45 business days.
We will retain your Personal Data for as long as your account is active or as needed to provide you services. We will retain and use your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via this Site or Services.
If you believe that we have infringed your rights, we encourage you to contact us so that we can try to address your concerns or dispute informally. Our contact information is above.
Modo Labs’ commitment to the EU-U.S. Framework entitles you to lodge a complaint via our Privacy Shield independent dispute resolution mechanism. VeraSafe has been appointed Modo Labs’ representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. VeraSafe can be contacted in addition to Modo Labs’ VP of Operations, only on matters related to the processing of personal data. To make such an inquiry, please contact VeraSafe using this contact form: https://www.verasafe.com/privacy-services/contact-article- 27-representative
Alternatively, VeraSafe can be contacted at:
VeraSafe Ireland Ltd
Unit 3D North Point House
North Point Business Park
New Mallow Road
VeraSafe Netherlands BV
Keizersgracht 391 A 1016 EJ
If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit the website above for more information and/or to file a complaint.
As a last resort and under limited circumstances, EU or Swiss individuals with residual privacy complaints may, at no cost to them, invoke a binding arbitration option before the Privacy Shield Panel.
You also have a right to lodge a complaint with a competent supervisory authority situated in a Member State of your habitual residence, place of work, or place of alleged infringement. You can find the relevant supervisory authority name and contact details under http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm .
By certifying with Privacy Shield, Modo commits to cooperate with DPAs and The Department of Commerce. If an individual submits a complaint to a data protection authority (DPA) in the EU, the Department of Commerce has committed to receive, review and undertake best efforts to facilitate resolution of the complaint and to respond to the DPA within 90 days.
VI. OUR SECURITY PROCEDURES
Modo Labs takes reasonable steps to protect the Personal Data provided via the Site and Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. The security of your Personal Data and our Clients’ information is important to us. When you enter sensitive information (such as login credentials) we encrypt the transmission of that information using secure socket layer technology (SSL). However, no Internet, email or other electronic transmission is ever fully secure or error free, so you should take special care in deciding what information you send to us in this way. If you have any questions about security on our Site, you can contact us at firstname.lastname@example.org.
VII. CHANGES TO THIS PRIVACY STATEMENT
VIII. CONTACT MODO LABS
You may contact us as follows:
Modo Labs Attn:
VP of Operations
100 Cambridgepark Dr, Ste 200
Cambridge, MA 02140
By Phone: 1-888-663-6522 (MODO LAB)
Fill out a form to request a demo.