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Protection of Your Data: YourModule Privacy Policy

Last update: 06 January 2021

MODULE SRL (VALGRANA (CN) VIA MONTEROSSO 31 CAP 12020), registration number 03978580045 (“Module” “Us”, “We”, and “Our”) understand that your privacy is important to you and are committed to being transparent about the technologies it uses.

This Privacy Policy (“Privacy Policy”) describes how we collect and use the personal data you provide through the Website. It also describes the choices available to you regarding our use of your Personal Data and how you can access the information. We respect your privacy and we take protecting it seriously.

This Privacy Policy should be read together with our Cookie Policy and our Terms of Use.

1. GENERAL INFORMATION

1.1. This Policy applies to the following people:
  • 1.1.1. people who use the Service (for this Policy, We define the term “User”, “you”, "your", "yours" as a person which has access to the Service);
  • 1.1.2. people who make complaints to Us by email.
1.2. We do not sell your Personal Data to third parties. A “sale” of Personal Data under the CCPA is defined broadly to include the “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means” the Personal data of a Consumer to another business or third party “for monetary or other valuable consideration”. If We decide to sell the Service, We will inform you about this, so you can forbid Us to transfer your Personal Data together with our business. If so, We will delete your Data from the databases prior to a business transfer.

2. TERMS AND DEFINITIONS

2.1. The following terms shall have the following meaning:
  • 2.1.1. “Service” or “Services”— access to our website www.yourmodule.com as well as users’ subscription to and any Order of our services, products, applications, tools, offline components and features (individually the “Service” or collectively, the “Services”) provided by our company “Module”, together with its affiliates, officers, directors, employees, agents, and subsidiaries (hereinafter “Module”, “We”, “Our” or “Us”);
  • 2.1.2. “Application” — a desktop (mobile in the future) application, created by the User through Module and made available to the public for download from a third-party platform or accessible from Service;
  • 2.1.3. “User” — any person or entity having an account allowing access to our Service;
  • 2.1.4. “Website User” — any person visiting one of our websites.

3. DATA CONTROLLER

3.1. MODULE SRL (VALGRANA (CN) VIA MONTEROSSO 31 CAP 12020), registration number 03978580045 is the data controller that is responsible for the personal data collected and used within the scope of this Privacy Policy.

4. PRINCIPLES OF DATA PROCESSING

4.1. According to Art. 5 of the EU General Data Protection Regulation (GDPR), we adhere to the following principles to protect your privacy:
  • 4.1.1. principle of lawfulness, fairness, and transparency - we process personal data lawfully, fairly, and transparently concerning the data subject;
  • 4.1.2. principle of purpose limitation - we collected personal data for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
  • 4.1.3. principle of data minimization - we collect adequate personal data, relevant and limited to what is necessary concerning the purposes for which we are processed personal data;
  • 4.1.4. principle of data accuracy - we accurate personal data and, where necessary, keep up to date. We take every reasonable step to ensure that inaccurate personal data, having regard to the purposes for which they are processed, are erased or rectified without delay;
  • 4.1.5. principle of storage limitation - we keep personal data in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed;
  • 4.1.6. principle of integrity and confidentiality - we process personal data in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and accidental loss, destruction, or damage, using appropriate technical or organizational measures.

5. PERSONAL DATA THAT WE COLLECT AND PROCESS

5.1.To fulfill our obligations on provision of a license for Service “Module” for you and applicable Terms of Use, We are entitled to ask you to provide Us with your Personal Data, including (but not limited):
  • 5.1.1. Full Name (Name and Surname);
  • 5.1.2. Personal Address (country, city, state, street, zip code);
  • 5.1.3. Personal phone number;
  • 5.1.4. Email address;
  • 5.1.5. The name of the company.
5.2. We may also receive information about you from other sources, such as when you log in to Module by using your account credentials for a separate third-party Software, such as Facebook or Google Account. We will receive information from that Software as indicated in the relevant third party's authorization screen.
5.3. We may collect Personal Data from you in a variety of ways and circumstances, including, but not limited to, access to the Module, a subscription to a newsletter, filling out a form, providing Us with feedback. We shall be entitled to combine Personal Data collected in the course of your interaction with different sections of the Service with any other relevant available information.

6. PERSONAL DATA, COLLECTED IN AN AUTOMATIC WAY

6.1. We may also automatically collect data about the devices you use to interact with our Service. Personal Data automatically collected by or transmitted to Us in the course of accessing, interacting, and operating of the Service may include, without limitation, the following Personal Data:
  • 6.1.1. device information, which may include (but is not limited to) information about the personal computer or laptop you use to access the Service including the hardware model, operating system and version, the Service you use, and other device identifiers;
  • 6.1.2. server log information, which may include (but is not limited to) your login details, the date and time of visits, the pages viewed, your IP address, time spent at the Service;
  • 6.1.3. information collected by cookies and other similar technologies. We and our service providers use various technologies to collect information when you interact with Module, including cookies and other similar technologies. Cookies are small data files that are stored on your device when you visit a Website, which enables us to collect information about your device identifiers, IP address, web browsers used to visit the Website, pages or features viewed, time spent on the Website, and links clicked. Where required, you will be asked for consent to our use of cookies. To view more information on what cookies we use and how we use them, please review our separate Cookie Policy on the Website.

7. LAWFUL BASIS OF DATA PROCESSING

7.1. Under Art. 6 of the GDPR, we only process personal data, where we have a lawful basis for doing so.
7.2. The processing of Personal Data, described in p. 5.1 of this Privacy Policy is based on contract obligations (Art. 6 (1) lit. (b) GDPR) and is performed only for the purposes specified in this Privacy Policy — to meet your request concerning the service, to formalize the development of the contractual relationship.
7.3. The processing of Personal Data, described in p. 6.1.1 and 6.1.2 of this Privacy Policy is based on a legitimate interest (Art. 6 (1) lit. (f) GDPR) and is performed only for the purposes specified in this Privacy Policy — To contact you about, and conduct, surveys or polls you choose to take part in and to analyze the data collected for market research purposes.
7.4. The processing of Personal Data, described in p. 5.2 of this Privacy Policy is based on consent (Art. 6 (1) lit. (a) GDPR) and is performed only for the purposes specified in this Privacy Policy — to provide license and access to “Module”.
7.5. The processing of Personal Data, described in p. 6.1.3 of this Privacy Policy is based on consent (Art. 6 (1) lit. (a) GDPR) and is performed only for the purposes specified in this Privacy Policy —to provide a greater and better experience with Us and other related purposes, which is described in detail in Cookie Policy on this Website.
7.6. The processing of Personal Data, described in p. 5.3 of this Privacy Policy is based on consent (Art. 6 (1) lit. (a) GDPR) and is performed only for the purposes specified in this Privacy Policy — to personalize your experience with our Service and for marketing and promotion of our Services or related products, including those of a third party’s products which are related to our Services.

8. THE PURPOSE OF DATA PROCESSING (USE OF COLLECTED PERSONAL DATA)

8.1. We may use the data, collected from you for a variety of purposes, primarily, relating to providing our Services and information about our Services. We may also use the information for such other purposes as otherwise allowed by law. We may use your personal data for such purposes, including, but not limited to:
  • 8.1.1. provide license and access to “Module”;
  • 8.1.2. meet your request concerning the service, to formalize the development of the contractual relationship;
  • 8.1.3. handle your orders and requests, including requests for technical support and assistance;
  • 8.1.4. provide a greater and better experience with our Service;
  • 8.1.5. properly fulfill tax-related and accounting obligations imposed by applicable laws;
  • 8.1.6. detect, investigate, and prevent illegal activities or conduct that may violate the Terms of Use of “Module”, this Privacy Policy and Cookie Policy;
  • 8.1.7. personalize your experience with our Service;
  • 8.1.8. processing payments;
  • 8.1.9. contact you concerning, and conduct, surveys or polls you choose to take part in and to analyze the data collected for market research purposes;
  • 8.1.10. conduct internal research and development and to improve, test, and enhance the features and functions of our Service;
  • 8.1.11. for marketing and promotion of our Services or related products, including those of a third party’s products which are related to our Services (If you do not want us to use your data in this way, please let us know by contacting us at: support@yourmodule.com;
  • 8.1.12. meet our internal and external audit requirements, including our information security obligations;
  • 8.1.13. tracking purchases and usage data;
  • 8.1.14. any other purpose as we determine, in our sole discretion, to be necessary or required to ensure the safety and/or integrity of our users, employees, third parties, public, and/or our Services, or to comply with requirements of any applicable law.

9. CONSENT TO PERSONAL DATA PROCESSING

9.1. Consent to Personal Data Processing
  • 9.1.1. By accepting this Privacy Policy, you approve to have reached the age of majority or the legal age in your jurisdiction (generally 18 or older), are solely responsible for all your actions, and fully understand the statements, outlined in this Privacy Policy.
9.2. EU Persons Consent to Personal Data processing
  • 9.2.1. If you are an EU Person and to process your Personal Data We need to receive your consent, as it is prescribed by GDPR, We will process your Personal Data only in the case We have received from you a freely given, specific, informed, and unambiguous indication of your wishes by which you signify agreement to the processing of your Personal Data (“Consent”).
  • 9.2.2. You may give your consent by ticking the respective box when you register for an account with our Service. In the case you tick the respective box, you irrevocably and unconditionally consent and agree that We shall be entitled to process your Personal Data as it is indicated by your Consent.
  • 9.2.3. Your Consent covers all processing activities with your Personal Data carried out for the same purpose or purposes. When the processing has multiple purposes, your Consent should be deemed given for all of them.
9.3. Non-EU Persons Consent to Personal Data processing
  • 9.3.1. If you are not an EU Person, by transferring to Us your Personal Data via the Software or otherwise, you irrevocably and unconditionally consent and agree that We shall be entitled, in accordance with this Policy:
    • 9.3.1.1. to process in any manner, including to collect, store, use, disclose, share and transfer (including cross-border), your Personal Data so provided to Us, as well as your Personal Data collected from your use of the Service (i.e. your Personal Data which We collect automatically and/or from other sources); and
    • 9.3.1.2. to use cookies and web beacons (pixel tags) to collect your Personal Data.

10.COMPLIANCE WITH GENERAL DATA PROTECTION REGULATION (GDPR), CALIFORNIA CONSUMER PRIVACY ACT (CCPA) AND OTHER LAWS

10.1. If you are located in the European Economic Area (EEA) privacy rights are granted and all processing of Personal Data is performed by regulations and rules following the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons concerning the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation (“GDPR”).
10.2. If you are located in California, all processing of Personal Data is performed in accordance with regulations and rules following the California Consumer Privacy Act, Cal. Civ. Code § 1798.100 et seq. (“CCPA”).
10.3. If you are located in Brazilia, all processing of Personal Data is performed in accordance with regulations and rules following the Lei Geral de Proteção de Dados (“LGPD”).
10.4. If you are located in the United Kingdom, all processing of Personal Data is performed in accordance with regulations and rules following the Data Protection Act 2018 (“DPA 2018”) and UK General Data Protection Regulation (“UK GDPR”).
10.5. If you are located in Australia, all processing of Personal Data is performed in accordance with regulations and rules following the Privacy Act 1988.
10.6. If you are located in Canada, all processing of Personal Data is performed in accordance with regulations and rules following Personal Information Protection and Electronic Documents Act (S.C. 2000, c. 5) (“PIPEDA”).
10.7. If you are located in New Zealand, all processing of Personal Data is performed in accordance with regulations and rules following Privacy Act 2020.
10.8. If you are located in the Russian Federation, all processing of Personal Data is performed in accordance with regulations and rules following the Federal Law of July 27, 2006, No. 152-FZ “On Personal Data”.

11. THE RIGHTS OF USERS

11.1. Subject to possible restrictions under national law, as a data subject under the GDPR, you may have certain rights regarding the Personal Data that we collect on you.
11.2. Under Chapter 3 of the General Data Protection Regulation (GDPR), rights of the data subjects include the following:
  • 11.2.1. Right to access. You may contact us to get confirmation as to whether or not we are processing your personal data. When we process your personal data, we will inform You of what categories of personal data we process regarding You, the processing purposes, the categories of recipients to whom personal data have been or will be disclosed, and the envisaged storage period or criteria to determine that period;
  • 11.2.2. Right to withdraw consent. In case our processing is based on the consent granted, You may withdraw the consent at any time by contacting us or by using the functionalities of the Website. You can withdraw your consent at any time by replying to the email with your withdrawal and your Personal Data will be deleted immediately. Withdrawing consent may lead to fewer possibilities to use the Service;
  • 11.2.3. Right to object. In case our processing is based on a legitimate interest to run, maintain and develop our business, You have the right to object at any time to our processing. We shall then no longer process your personal data unless for the provision of our services or if we demonstrate other compelling legitimate grounds for our processing that override your interests, rights, and freedoms or for legal claims. Notwithstanding any consent granted beforehand for direct marketing purposes, You have the right to prohibit us from using personal data for direct marketing purposes, by contacting us or by using the functionalities of the Website, or unsubscribe possibilities in connection with our direct marketing messages
  • 11.2.4. Right to restriction of the processing. You have the right to obtain from us restriction of processing of your personal data, as foreseen by applicable data protection law, e.g. to allow our verification of the accuracy of personal data after you contest the accuracy or to prevent us from erasing personal data when personal data are no longer necessary for the purposes but still required for your legal claims or when our processing is unlawful. Restriction of processing may lead to fewer possibilities to use the Website;
  • 11.2.5. Right to data portability. You have the right to receive your personal data from us in a structured, commonly used, and machine-readable format and to independently transmit those data to a third party, in case our processing is based on your consent and carried out by automated means;
  • 11.2.6. Right to complain. You have the right to complain with any relevant Data Protection Authority, in particular in the Member State of your residence, place of work, or the place of processing your personal data. If You wish to exercise any of the aforementioned rights, please Contact Us via support@yourmodule.com.
  • 11.2.7. How to use these rights. To exercise any of the above-mentioned rights, You should primarily use the functions offered by the Website. If such functions are however not sufficient for exercising such rights, You shall send us a letter or email to the address set out below under Privacy Policy, including the following information: name, address, phone number, email address, and a copy of a valid proof of identity. We may request additional information necessary to confirm your identity. We may reject requests that are unreasonably repetitive, excessive, or manifestly unfounded.

12. DATA STORING AND DELETION

12.1. We store your Personal Data for as long as needed to provide you with our Service. We may store Data longer, but only in a way that it cannot be tracked back to you. When Personal Data is no longer needed, we delete it using reasonable measures to protect the Data from unauthorized access or use.
12.2. EU Territory. We store Personal Data as long as it is needed for the provision of our Service. Traffic information is erased or made anonymous when it is no longer needed for the transmission or, in the case of payable Service, up to the end of the period during which the bill may lawfully be challenged or payment pursued. Direct marketing and provision of value-added Service information (including traffic information used for these purposes) are stored as long as the same is necessary for the provision of these activities, or up to the time when a User opts out from such use under this Privacy Policy. Other information is stored for as long as we consider it to be necessary for the provision of our Service. This Section shall not prevent any technical storage or access to information for the sole purpose of carrying out the transmission of a communication or as strictly necessary for us to provide the Service you requested.
12.3. As explained in the GDPR statement, We strive to anonymize the data when possible. If you decide to exercise your right to erasure, We will also inform our providers to delete all your data.
12.4. US Territory. We will retain collected information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by applicable legislation.
12.5. Storing might be different depending on the territory of collecting the information and the applicable legislation, but We always strive to store the information only as long as it is needed to provide, improve, or personalize our Service.

13. DATA SECURITY

13.1. We care to ensure the security of Personal Data. We follow generally accepted industry standards to protect the information submitted to Us, both during transmission and once We receive it. We maintain technical, physical, and administrative security measures to provide reasonable protection for your Personal Data. When We or our contractors process your information, We also make sure that your information is protected from unauthorized access, loss, manipulation, falsification, destruction, or unauthorized disclosure. This is done through appropriate administrative, technical, and physical measures.
13.2. There is no 100% secure method of transmission over the Internet or method of electronic storage. Therefore, We cannot guarantee its absolute security.
13.3. We never process any kind of sensitive data or criminal offense data. Also, we never undertake to profile personal data.

14. CONTRACTORS

14.1. We work with third-party services providers, who provide website, application development, hosting, maintenance, and other services for us. They may be located outside of the EEA. These contractors may have access to, or process Personal Data on behalf of Us as part of providing those services for Us. We limit the information provided to these Service providers to that which is reasonably necessary for them to perform their functions.
14.2. All data transfers are performed in accordance with the highest security regulations. Transfer of Personal Data to countries outside of the European Economic Area may be possible only in the case when We have obtained your consent for it.
14.3. All data processed by Us is stored exclusively in secure hosting facilities provided by Microsoft Azure.
14.4. We use a third-party payment processor, currently Stripe (“Payment Processors”) to assist in securely processing your payment information. If you pay with a credit card the payment information that you provide through the Services is encrypted and transmitted directly to the Payment Processor. We do not store your Payment Information and do not control and are not responsible for the Payment Processors or their collection or use of your information. You may find out more about how the Payment Processors store and use your Payment Information by accessing the Payment Processors Privacy Policy.
14.5. We may share your personal data with our insurers, our professional advisors (lawyers, bankers, auditors, corporate financiers, and brokers) in connection with the services they provide to us. If we share your personal data with those processors, we will require the recipient to keep it confidential and secure. To provide you (or your organization) with our services, we may provide personal data to the courts, to lawyers advising the other parties to a matter, or other professionals (such as overseas law firms, patent agents, forensic accountants, or barristers).

15. LINKS TO THIRD-PARTY WEBSITES

15.1. This website may contain hyperlinks to third-party websites. We are not responsible for the content of such websites, or for how those websites collect, hold, use, and distribute any personal information you provide.
15.2. When visiting a third-party website from hyperlinks displayed on this website, we encourage you to review the Privacy Notices of those websites so that you can understand how the personal information you provide will be collected, held, used, and distributed.
15.3. We use Google Analytics to create detailed statistics of website users. The statistics are collected on Google's server; the User only places JS code on the pages of his or her site. The tracking code is triggered when the User opens the page in his or her web browser. For more information on the privacy practices of Google Analytics, please visit the Privacy Policy:https://policies.google.com/privacy?hl=en-US
15.4. We use Facebook pixel to measure and increase the effectiveness of our advertising campaigns. For more information on the privacy practices of the Facebook pixel, please visit the Privacy Policy:https://www.facebook.com/business/m/privacy-and-data

16. INFORMATION RELATING TO CHILDREN

16.1. We do not intentionally collect or maintain information from persons under the age of 13, however, according to each country and its laws, the processing of the personal data of a child will be lawful where the child is at another age.
16.2. If we determine upon collection that a user is under this age, we will not use or maintain his/her Personal Information without the parent/guardian’s consent. If we become aware that we have unknowingly collected personally identifiable information from a child under the age of 13, we will make reasonable efforts to delete such information from our records.
16.3. We also recommend that parents monitor their children’s Internet activities and learn and employ software or other tools that can help their children enjoy their online experience without compromising their personal safety or allowing them to use the Internet in a manner inconsistent with their parent/guardian’s preferences.

17. APPLICATION OF THIS PRIVACY POLICY

17.1. This Privacy Policy applies to the Website. Once redirected to another website or App, this Policy is no longer applicable.

18. ACCEPTANCE OF THESE CONDITIONS

18.1. By accepting the checkbox on this Website, you agree with the uploaded Privacy Policy.
18.2. We assume that all Users have carefully read this document and agree to its content. If one does not agree with this Privacy policy, they should not use this Website.

19. CHANGES AND UPDATES TO OUR PRIVACY POLICY

19.1. From time to time, we may update this Privacy Policy. We encourage You to periodically check back and review this Privacy Policy so that You always will know what data we collect, how we use it, and with whom we share it.

20. CONTACT US!

20.1. If you have any questions, suggestions, or comments, please contact us via email at support@yourmodule.com.
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