Our Privacy Policy

At Modus privacy is a top priority. We understand the importance of safeguarding personal information stored on our servers or network. We consider this information, referred to as “Personal Data,” to be any data relating to an identified or identifiable individual. Protecting the privacy and confidentiality of Personal Data is a fundamental aspect of our business. This Privacy Policy explains how we ensure privacy and confidentiality, outlines the information we collect, how we use it, and when we share it with third parties.

Our Privacy Policy complies with regulatory requirements, such as the General Data Protection Regulation (“GDPR”), applicable to the jurisdictions where Modus provides its Services. The terms “Site” and “Services” have the same meaning as defined in our Terms of Use. If you disagree with this Privacy Policy or any part of it, please refrain from using our Services. We regularly review this Privacy Policy to incorporate new obligations and changes to our business model. Any updates will be posted on our website.

Information about Modus

Modus is the entity (referred to as the “Controller”) responsible for using your Personal Data when you use our Services. If you have any questions about our Privacy Policy or your Personal Data, please reach out to us at info@modusdapp.org.

Collection of Personal Data

When you use our Services, we collect the following information:

1. Information you provide to us: You may give us information about yourself through forms on our website or by contacting us via phone, email, or other means. This includes details you provide when registering for the Services or reporting issues with the website.
2. Information we collect about you: During your visits to our website, we automatically collect the following information:
3. Login Information: We log technical details about your use of the Services, such as your browser type and version, wallet identifier, last wallet access time, and Internet Protocol (IP) addresses associated with wallet creation and access.
4. Device Information: We gather information about the device you use to access your account, such as hardware model, operating system version, and unique device identifiers. Please note that this information is anonymized and not linked to any specific individual.
5. Information obtained from other sources: We may receive information from external sources and combine it with the data we collect through our Services. For example:
6. Third-party services co-branded as Modus may collect information based on their own privacy policies, with clear notice to you.
7. Occasionally, we utilise cookies to enhance your online experience on our site. These cookies are small text files stored on your computer, providing us with insights on your site usage to improve both the site itself and your overall experience. Personal Data collected through cookies will be handled in accordance with this Privacy Policy.
8. Advertising or analytics providers may share anonymized information about you, including how you discovered our website.

If you have any concerns or questions regarding our Privacy Policy or the handling of your Personal Data, please contact us at info@modusdapp.org.

Use of Personal Data

We will use your Personal Data for the following purposes:

1. Understand and cater to your needs and preferences when using our Services.
2. Develop and improve our existing services and products, as well as create new offerings.
3. Manage and enhance our business operations.
4. Perform actions for which we have obtained your consent.
5. Prevent and investigate fraudulent or criminal activities.
6. Address service requests and resolve user inquiries.
7. Comply with legal and regulatory requirements.

Additionally, we reserve the right to use aggregated Personal Data to analyse how our users utilise our Services. These aggregated data will not contain any information that can identify individuals.

We also utilise third-party web analytics tools to gain insights into user engagement on our website. These third parties may use first-party cookies to track user interactions and collect information about website usage. This information is used to generate reports and improve our website. The reports focus on website trends without identifying individual visitors.

We are committed to processing your Personal Data lawfully, ensuring fair treatment, and using it solely for the purposes we have informed you about. We will not sell your Personal Data, whether individually or in aggregate, for commercial purposes.

Disclosure of Personal Data 

We may disclose your information to specific recipients in order to provide certain Services to you and/or to prevent and investigate fraudulent or criminal activities. All third parties involved will be contractually obligated to protect data in accordance with our Privacy Policy. The categories of recipients include:

1. Modus companies within Canada: We may share your information with affiliated companies within the Modus corporate family located in Canada to provide you with the Services.
2. Cloud service providers: We may utilise cloud service providers to store certain personal data and for disaster recovery services, as well as for fulfilling any contractual obligations we have with you.
3. Fraud detection service providers: We may share Personal Data with fraud detection service providers who will conduct specific fraud detection checks using the information provided.
4. Business transactions: In the event of a merger, divestiture, restructuring, reorganisation, dissolution, or sale of some or all of Modus’ assets, your Personal Data may be shared with a buyer or other successor. This includes scenarios such as bankruptcy, liquidation, or similar proceedings where Personal Data held by Modus is part of the transferred assets.

Unless required by law or exempted from legal requirements, any person or entity to whom we provide your Personal Data will be required to adhere to our Privacy Policy or similar requirements. We will make reasonable efforts to ensure their compliance, but we will not be liable if they fail to do so, unless expressly prohibited by law.

We will request that any third party, including government or enforcement entities, seeking access to the data we hold provide a court order or equivalent proof of statutory authorization. Their request must be valid and within their legal or regulatory powers.

Please note that transaction information related to certain Services you use may be recorded on a public blockchain. Public blockchains are decentralised ledgers designed to record transactions across vast networks of computer systems. It is important to be aware that blockchains can undergo forensic analysis, potentially leading to the de-anonymization and unintended disclosure of private financial information, especially when blockchain data is combined with other data.

As blockchains are independent and not controlled or operated by Modus or its affiliates, we are unable to erase, modify, or alter Personal Data from such networks.

Security of your Personal Information

We prioritise the protection of Personal Data by implementing appropriate physical, technological, and organisational safeguards and security measures. As information is transmitted over the internet, which determines its own routes and means of conveyance, we continuously audit and review our procedures and security measures to ensure their proper administration and ongoing effectiveness. Every member of Modus is committed to upholding our privacy policies and procedures to safeguard Personal Data. Our website incorporates security measures to prevent loss, misuse, and unauthorised alteration of the information under our control.

Retention of Your Personal Data:

The duration for which we retain Personal Data outside of our backup system varies depending on the purpose for which it was collected and used, as outlined below:

1. Data provided when subscribing to our Services (if applicable): Retained while the user remains active, stored in the Ireland.
2. Country location data: Retained while the user remains active, stored in the United States.
3. Data regarding your preferences: Retained while the user remains active, stored in the United States.
4. IP address login: Retained until a subsequent login from a new IP occurs, stored in the United States.

Once Personal Data is no longer necessary for the purpose it was collected, we will either remove any identifying details or securely destroy the records, as permitted. However, there may be regulatory requirements that necessitate retaining records for an extended period even after the end of your relationship with us.

Unless prohibited by law, this retention period may extend beyond the termination of your relationship with us, solely for audit, regulatory, or accounting purposes. When Personal Data is no longer needed, we have established procedures to destroy, delete, erase, or anonymize it. If you have opted out of receiving marketing communications, we will maintain your details on a suppression list to ensure you do not receive such communications.

Upon termination of your use of our Services, we reserve the right to retain your Personal Data as part of our standard backup procedures in an aggregated format.

Storage of Personal Data

Modus securely stores your Personal Data in the Ireland, where we have established secure locations that meet appropriate standards for safeguarding, confidentiality, and security of data.

Please note that the information we collect from you may be transferred to and stored in destinations outside of your country. Specifically:

1. Transfer to other Modus subsidiaries, service providers, and business partners: We may transfer your Personal Data to other company subsidiaries, service providers, and business partners (referred to as Data Processors) who work on our behalf. In the event that we transfer your Personal Data outside of the United Kingdom, we will ensure that the transfer is conducted lawfully and that Data Processors in third countries are obligated to comply with relevant privacy laws.

Your Rights

Here are the available rights in relation to the Personal Data we hold about you:

1. Information Access: Upon request, we will confirm whether we process your Personal Data and provide you with a copy of that information within 30 days from the date of your request.
2. Rectification: We strive to keep your Personal Data accurate and up-to-date. If the information we hold about you is inaccurate or incomplete, you have the right to have it rectified. We will also inform any third parties with whom we have shared your data, if feasible. To update your personal details, please email us at info@modusdapp.org. In some cases, we may require supporting documents for regulatory or legal purposes.
3. Erasure: You can ask us to delete or remove your Personal Data in certain circumstances, provided there is no legal or regulatory obligation for us to retain it. We will inform relevant third parties, if applicable, and provide you with the information about them. Please note that any agreements or retention limits required by applicable laws and regulations will apply.
4. Processing Restrictions: In certain situations, you can request the blocking or suppression of the processing of your Personal Data. This does not affect the storage of your data. We will inform you if we decide not to comply with a requested restriction. We will also inform relevant third parties, if feasible, and provide you with their contact information.
5. Data Portability: Under certain circumstances, you may have the right to receive the Personal Data you have provided us in a structured, commonly used, and machine-readable format. You can also request that we transfer this data to a third party of your choice.
6. Objection: You can request that we stop processing your Personal Data in certain situations, including if we are relying on legitimate interests, processing for direct marketing purposes, or processing for research (unless it is in the public interest). We will comply with such requests, unless we can demonstrate compelling legal grounds for the processing.
7. Automated Decision-making and Profiling: If we make decisions solely based on automated processes that significantly affect you, such as profiling, you can request not to be subject to such decisions. In certain cases, even if a decision is necessary for entering into or performing a contract, you can contest it and request human intervention. Please note that by agreeing to this request, we may need to terminate our relationship and stop providing our Services.

You can exercise any of these rights by contacting us at info@modusdapp.org.

Acceptance

By using the Site and/or Services, you agree to abide by this Privacy Policy. Modus retains the right to modify or update this Privacy Policy at any time. In the event of any significant changes, the revised Policy will be posted on this page. We recommend checking this page regularly to stay informed about any updates or revisions to this Privacy Policy.