Purpose of this Privacy Policy:
We are committed to respecting and protecting the privacy rights of our users.
We created this privacy policy (the "Policy") to give you notice of
how your private information will be collected, used and shared as you use our
Services, including any white-label mobile Apps operated, managed and marketed
by our Clients. Any capitalized term not defined in this Policy will have the
meaning set forth in our Terms of Service. All references to
"we", "us", "our", or "Modela" refer to Modela IoT Company Limited
In simplified form (greater detail is below), our Policy can be summarized as
follows:
· We may collect some information about you, as described in this Policy, but you have some choices about how much you share about yourself.
· We do not knowingly collect information from children under 13 years of age.
· We will not sell your personal information but may share such information with our vendors and our Clients in connection with providing the Services.
· If we use a third party to assist us, they will be bound to protect your information.
· We may collect, use and share aggregate, anonymous information about our users.
· In certain legal situations, we may be compelled to disclose your personal information.
· If you are outside the United States, you understand and agree that we may store your information in the United States.
This Policy applies to all users of the Services This Policy applies to your
use of the Services, whether you are Client or an End User of the Services,
including in connection with one or more events (each, an "Event").
Please read this Policy carefully, as it describes how we collect, use and
share your information. By accessing and interacting with the Services, you
consent to this Policy.
If you are an End User, you acknowledge that we will share your information,
including your personally identifiable information, with our Client(s) as
specified in this Policy for the purpose of providing the Services, including
in connection with one or more Event(s) that you may attend.
Information you provide as you use the Services. When you register for a
Modela account, you must provide us with
certain personal information about yourself, such as email address. You may
also voluntarily choose to provide us with personal information as you use the
Services, including, without limitation, by completing your profile and
registering for and interacting with others in connection with one or more
Events. This may include personal information about you, such as your address,
phone number and company name (if you are a Client). If you correspond with us
by email, we may retain the content of your email messages, your email address
and our responses. We may also retain any messages you send through the
Service.
Information we collect from you passively. We automatically collect
certain information about you as you use the Services, including, without
limitation, through cookies on the Modela
website and in-app tracking when you use our Apps. This may include information
about your device (such as your Unique Device Identifier), your location, your
Internet usage, and how you interact with the Services. This may include
information about the way you use the Services, the parts of our Services you
use and third party apps or websites you visit when you leave our Services.
Information we collect from third parties. If you are an End User, we
may receive information about you from a Client, and we may collect information
from your social media accounts if you choose to give us permission to access
your social media accounts. We may also work with third parties who collect
information about you when you use our app. For example, our vendors might use
scripts or other tools to track your activities on our Services. They may do
this to make sure our Services function properly.
We use information to administer and provide the core functionality of the
Services.
We use information to improve our products and services. We may use your
information to make our website, apps and products better. We might use your
information to customize your experience with us.
We may use information to respond to your requests or questions. For
example, we might use your information, such as your email address, to respond
to your customer questions or feedback.
We may use information to communicate with you about your account or our
relationship. We may contact you about your account or feedback.
We may use information for security purposes. We may use information to
protect our company, a Client, and/or our website and apps.
We may use information for promotional purposes. For example, we might
provide you with information about new features, updates, new products or
special offers from time to time. If you prefer not to receive promotional
messages from us, please read the choices section below in Section 5.
We may share information with third parties .
We will share information to provide the
functionality of the Services. These are third parties who perform services on
our behalf. For example, we may share information with external social media
services if an End User elects to cross-publish a post. We may also share
information with our vendors who provide payment processing, hosting, customer
support, email marketing and other services to us. If you are an End User, we
will also share your information (including your contact information and
information about your engagement on the Services) with the Client associated
with your account in order to provide the functionality of the Services. The
Client may contact you in relation to one or more Events for which you have
registered (including through push notification on your device), or for their
own marketing and promotional purposes.
We may share information to comply with the law. We will also share
information if we think we have to in order to comply with the law or to
protect ourselves. For example, we will share information to respond to a court
order, subpoena, or a request from a government agency or investigatory body.
We might also share information when we are investigating potential fraud.
We may share information with any successor to all or part of our business.
For example, if all or a part of our business was sold, we may share
information as part of that transaction.
We may otherwise share information with your permission.
You have certain choices about sharing and marketing practices:
1. You can opt out of receiving our promotional emails. To stop receiving our promotional emails, follow the instructions in any promotional message you get from us. Even if you opt out of getting marketing messages, we will still send you transactional messages. These include responses to your questions.
2. You can control cookies and other browser-based tracking tools. For example, your browser may give you the ability to control cookies or other browser-based tracking tools. Please note that if you block cookies, certain features on the Modela website may not work.
3. Our Do Not Track Policy: Some browsers have "do not track" features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals.
4. You can control tools on your mobile devices. For example, you can turn off the GPS locator or push notifications on your phone. Please note that turning off certain tools on your mobile device may affect the functionality of certain features of the Services.
The Services are not intended for children
Our Services are meant for use by adults only. We do not knowingly collect
personally identifiable information from children under 13 without permission
from a parent or guardian. If you are a parent or legal guardian and think your
child under 13 has given us information, you can email us at modela.iot@gmail.com
You can also write to us at the address listed at the end of this Policy.
Please mark your inquiries "COPPA Information Request." Parents can
learn more about how to protect children's privacy on-line here.
How we store your information
We keep your personal information as long as necessary to provide the
functionality of the Services, or as otherwise required by law. If you would
like to access your information or would like us to delete or modify your
information, you may contact us by email at modela.iot@gmail.com or you
may write to us at the address listed at the end of this Policy. However, we
may also keep your information as otherwise required by law.
To continue to provide an effective service, we may store non-personally
identifiable information perpetually and may anonymize your personally
identifiable information and store that anonymized information perpetually.
Additionally, we use third-party services and do not control their practices
related to storage and retention of your information.
How we protect your information
We use reasonable efforts to secure your information and to attempt to prevent
the loss, misuse, and alteration of the information that we obtain from you.
However, the Internet and mobile apps are not 100% secure. We cannot promise
that your use of our Services will be completely safe. We are not responsible
to our users or to any third party due to any such loss, misuse, or alteration
of data, except to the extent required by the Privacy Shield Principles or
applicable law. We encourage you to use caution when using apps and the
Internet. This includes not sharing your passwords. To learn more about how to
protect yourself online, visit www.ftc.gov.
We may link to other sites or have third party services on our Services we
don't control Our Services may have links to websites we do not control. Our
Services may also have plugins or host other third party services that we don't
control. This Policy does not apply to the privacy practices of those websites
or third parties. When you interact with those websites or third parties, they
may collect information from you. Read the privacy policy of other websites
carefully. We are not responsible for, and disclaim any and all liability for,
these third-party practices.
Contact us if you have questions If you have any questions about this Policy or
want to correct or update your information, please email us at modela.iot@gmail.com
We may update this Policy
This Policy may be updated from time to time, but the changes will not apply
retroactively. If you continue to use the Services after such become effective,
you will be bound by the updated Policy.
We will notify you of any material changes to our Policy as required by law. We
will also post an updated copy on our website and Modela
IoT app. Please check our website and app periodically for updates.
California users
If you reside in California, you have the right to ask us one time each
year if we have shared personal information with third parties for their direct
marketing purposes. To make a request, please send us an email at modela.iot@gmail.com,
or write to us at the address listed at the end of this Policy. Indicate in
your letter that you are a California resident making a "Shine the
Light" inquiry.
European users Data Protection Laws.
If you are a resident of the European Union ("EU") or Switzerland,
you are entitled to certain protections under the EU's General Data Protection
Regulation ("GDPR") and/or other applicable laws (collectively, the
"Data Protection Laws"), and this section applies to your use of the
Services. As used in this section, the terms "processing,"
"processor," "controller" and "personal data"
have the meaning given to them in the Data Protection Laws.
How we obtain your personal data.
Generally, we obtain your personal data from you because you want to use the
Services. In order to use the Services (for example, to create a mobile app
project), you will need to register for the Services and create a Modela account. Without providing this
information, you will not be able to use the Services.
Our role with respect to your personal data.
When we process your personal data on behalf of our Client for the purpose of
providing the Services, we act as a processor of your personal data, as defined
under the Data Protection Laws. In such situations, the controller(s) of your
personal data, as defined under the Data Protection Laws, are any Client(s) who
create mobile apps which you use. You may be able to find the contact
information of the relevant Client by looking at the Info section of the app
they created. However, when we process your personal data for our own purposes
(such as improving the Services and making the Services available to you beyond
a particular Client's Event), we may be considered the controller of your
personal data for purposes of such processing.
Purposes and legal bases for processing.
Your personal data will be processed for the purposes described in this
Policy. Refer to the section titled "We use information about you as
disclosed and described here" for how we process your personal data, and
to the section titled "We use information about you as disclosed and
described here" for how our Clients may process your personal data. The
legal grounds for our processing, and our Clients' processing, of your personal
data are:
1. first and foremost, you provided your consent by agreeing to this Policy, which you may withdraw at any time by emailing us at modela.iot@gmail.com
2. it is necessary for our contractual relationship;
3. it is necessary for us to comply with our legal or regulatory obligations; and/or
4. the processing is in our legitimate interest as a provider of the Services. Such interests include the protection of the security and integrity of our systems, our direct marketing (which you can opt out of) and providing you with customer service and the core functionality of the Service.
Categories of recipients of personal data.
Your personal data will be shared by us described in this Policy. See the
section titled "We may share information with third parties" for more
details. The categories of recipients generally include: any Client(s) whose
app you sign up for or use, our vendors who make it possible for us to provide
the Services, any successor to our business and any governmental authority in
compliance with the law.
Period for which personal data will be stored.
We will store your personal data as long as necessary to provide the
functionality of the Services. For example, we may store your personal data as
long as your personal data is posted on or connected with any Events that you
have attended, and/or as long as the Client is using such data for their own
business purposes. We may also store your personal data as long as required by
law.
International transfer of personal data.
Please also note that you are transferring your personal data outside of
those regions to the United States of America ("US") for storage and
processing. By providing any personal data on or to the Services, you consent
to such transfer, storage, and processing.
Your rights.
Finally, you may have certain rights under the Data Protection Laws with
respect to your personal data. Such rights may include, but are not limited to,
the right to request access to your personal data, that your personal data be
corrected or deleted, to restrict the processing of your personal data or to
object to processing of your personal data. To exercise such rights, you may
contact us at modela.iot@gmail.com Specifically, and without limiting
your rights under the Data Protection Laws, you may do any of the following:
1. request access to your personal data to be able to correct, amend, or delete such personal data where it is inaccurate or has been processed in violation of the Privacy Shield Principles,
2. request that your personal data not be used for a purpose that is materially different from the purposes for which it was originally collected or for purposes subsequently authorized by you; or
3. request that we do not disclose your personal data to third parties (other than those that are acting as our agent to perform tasks on our behalf, such as payment and data processors). However, as the core functionality of the Services require that we share your personal data with Clients, you will not be able to use the Services if you request that we not disclose your personal data to Clients.
Government requests.
As described in this Policy, we may share personal data with third parties and
may be required to disclose personal data in response to lawful requests by
public authorities, including to meet national security or law enforcement
requirements.