MODUGO PRIVACY POLICY

Effective Date: January 9, 2019

ModuGo provides this Privacy Policy to let you know our policies and procedures regarding the collection, use and disclosure of information through www.modugo.com (the “Site”), and any other websites, features, applications, widgets or online services that are owned or controlled by ModuGo and that post a link to this Privacy Policy (together with the Site, the “Site Services”), as well as any information ModuGo collects offline in connection with the Service. It also describes the choices available to you regarding the use of, your access to, and how to update and correct your personal information. Note that we combine the information we collect from you from the Site, through the Site Services generally, or offline.

By accessing or using the Site and Site Services, you confirm that you have read this Privacy Policy and consent to the information collection, disclosure and use practices described in this Privacy Policy. Please note that certain features or services referenced in this Privacy Policy may not be offered on the Site at all times. Please also review our Terms of Service, which governs your use of the Site and Site Services, and which is accessible at https://www.modugo.com/termsandservice.

1. INFORMATION COLLECTION

Users of the Site and Site Services may be ss (anyone utilizing the ModuGo platform to research and/or purchase items for sale) or Sellers (anyone utilizing the ModuGo platform to offer items for sale to Buyers), Service Providers (anyone utilizing the ModuGo platform to offer services for sale to Buyers) or any combination thereof.

Information You Provide to Us
  • Personal Information: In the course of using the Site (whether as a Buyer, Seller or Service Provider), we may require or otherwise collect information that identifies you as a specific individual and can be used to contact or identify you (“Personal Information”). Examples of Personal Information include your name, email address, company address, billing address, and phone number.
  • Payment Information: If you use the Site to make or receive payments, we, and our third party payment processors (Stripe), will also collect certain payment information, such as credit card, bank account numbers or other financial account information and billing address.
  • Identity Verification: We may collect Personal Information, such as your date of birth or taxpayer identification number, to validate your identity or as may be required by law, such as to complete tax filings and to comply with KYC laws. We may request documents to verify this information, such as a copy of your government-issued identification or photo or a billing statement.
  • General Audience Service: The Service is general audience and intended for users 18 and older. We do not knowingly collect Personal Information from anyone younger than age 18. If we become aware that a child younger than 18 has provided us with Personal Information, we will use commercially reasonable efforts to delete such information from our files. If you are the parent or legal guardian of a child younger than age 18 and believe that ModuGo has collected Personal Information from your child, please contact us at: legal@modugo.com.
  • Non-Identifying Information/Usernames: We also may collect other information, such as zip codes, demographic data, information regarding your use of the Site, and general project-related data (“Non-Identifying Information”). We may aggregate information collected from registered and non-registered users (“ModuGo Users”). We consider usernames to be Non-Identifying Information. Usernames are made public through the Site Services and are viewable by other ModuGo Users.
  • Combination of Personal and Non-Identifying Information: Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers in a way that enables you to be identified (for example, combining information with your name). But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information (for example, your viewing preferences). We may combine your Personal Information with Non-Identifying Information, but ModuGo will treat the combined information as Personal Information.
Information Collected from Users Automatically

We may automatically collect certain information from you whenever you access or interact with the Site. This information may include, among other information, the browser and operating system you are using, the URL, the search terms you entered into a search engine that led you to the Site, areas within the Site that you visited, and other information commonly shared when browsers communicate with websites. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, and site functionality.

The information we collect also includes the Internet Protocol (“IP”) address or other unique device identifier (“Device Identifier”) for any device (computer, mobile phone, tablet, etc.) used to access the Site. A Device Identifier is a number that is automatically assigned or connected to the device you use to access the Site, and our servers identify your device by its Device Identifier. Some mobile service providers may also provide us or our third party service providers with information regarding the physical location of the device used to access the Site.

The technology used to collect information automatically from ModuGo Users may include the following:
  • Cookies: Like many websites, we and our affiliates, analytics, and service providers use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We use both persistent cookies that remain on your computer or similar device (such as to save your registration ID and login password for future logins to the Service and to track your compliance with the ModuGo Terms of Service) and session ID cookies, which expire at the end of your browser session (for example, to enable certain features of the Site, to better understand how ModuGo Users interact with the Site and to monitor aggregate usage by ModuGo Users and web traffic routing on the Site). You may be able to instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all functionality of the Site Services.

    For further information on cookies and how they are used for the Service, please visit our Cookie Policy at https://www.modugo.com/home/cookiepolicy.

  • Web Beacons: We and our affiliates, analytics, and service providers may also employ software technology known as “web beacons” and/or “tracking tags” to help us keep track of what content on our Site is effective and to serve relevant advertising to you. Web beacons are small graphics with a unique identifier that may be invisible to you, and which are used to track the online activity of Internet users. Web beacons are embedded in the web pages you review or email messages you receive. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to our Site, to monitor how ModuGo Users navigate the Site, to count how many emails that were sent were actually opened, or to count how many particular articles or links were actually viewed.
  • Embedded Scripts: We and our marketing partners, affiliates, analytics, and service providers may also employ software technology known as an Embedded Script. An Embedded Script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on. The code is temporarily downloaded onto your computer or other device and is deactivated or deleted when you disconnect from the Site.

In addition, we and our marketing partners, affiliates, analytics, and service providers may use a variety of other technologies (such as tags) that collect similar information for security and fraud detection purposes and we may use third parties to perform these services on our behalf.

HOW WE RESPOND TO DO NOT TRACK SIGNALS

Please note that your browser setting may allow you to automatically transmit a “Do Not Track” signal to websites and online service you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, ModuGo does not alter its practices when it receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

User Profiles

You may have the opportunity to create a profile, which consists of information about you as an individual, and your company, and may include company information, photographs, information on transactions previously performed via the Site, feedback/rating information and other information, including your username (“Profile”). The information in your Profile may be visible to all ModuGo Users and the general public subject to the privacy choices you make within your ModuGo Profile. You may edit certain information in your Profile via your account. If, in any case, you believe that an unauthorized profile has been created about you or your company, you can request for it to be removed by contacting us at legal@modugo.com.

Testimonials

We may display personal testimonials of satisfied customers on our Site, in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at support@modugo.com.

Feedback

We collect feedback from ModuGo Users about their experience with other ModuGo Users of our Site. Please note that any feedback you provide via the Site or feedback provided about you is publicly viewable via the Site. On very rare occasions, we may remove feedback pursuant to the relevant provisions of our Terms of Service, including the Terms of Use.

2. USE AND RETENTION OF INFORMATION
WE USE INFORMATION WE COLLECT:
  • To provide and improve the Site and Site Services, complete your transactions, and address your inquiries, process your registration, verify the information you provide is valid and for compliance and internal business purposes;
  • To contact you with administrative communications and ModuGo newsletters, marketing or promotional materials (on behalf of ModuGo or third parties) and other information that may be of interest to you. If you decide at any time that you no longer wish to receive such communications from us, please follow the instructions in the Your Choices and Opting Out section, below;
  • To tailor content we display to you and offers we may present to you on the Site;
  • To administer and develop our business relationship with you and, if applicable, the corporation or other legal entity you represent;
  • To enforce and comply with the law, including conducting an investigation, to protect the property and rights of ModuGo or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, fraudulent, unethical or legally actionable activity. We may also use Device Identifiers to identify ModuGo Users; and
  • For the purposes disclosed at the time you provide your information, with your consent, and as further described in this Privacy Policy.

Unless you request that we delete certain information (see Changing Your Information or Closing Your Account below), we retain the information we collect for at least 5 years and may retain the information for as long as needed for our business and legal purposes.

3. INFORMATION SHARING AND DISCLOSURE

We may share aggregated Non-Identifying Information and we may otherwise disclose Non-Identifying Information to third parties. We do not share your Personal Information with third parties for those third parties’ marketing purposes unless we first provide you with the opportunity to opt-in to or opt-out of such sharing. We may also share the information we have collected about you, including Personal Information, as disclosed at the time you provide your information, with your consent, as otherwise described in this Privacy Policy, or in the following circumstances:

  • Information about Sellers, Buyers, Service Providers: We share information regarding Sellers, Buyers and Service providers with other site users.
  • Service Providers: We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Service-related services (e.g., without limitation, maintenance services, database management, web analytics and online advertising, payment processing, fraud detection and improvement of ModuGo’s features) or to assist us in analyzing how our Service is used. These third parties may have access to your Personal Information in order to perform these tasks on our behalf.
  • What Happens If You Agree to Receive Information From Third Parties or Request That We Share Your Information: You may be presented with an opportunity to receive information and/or marketing offers from one or more third parties. If you agree at that time to have your Personal Information shared, your Personal Information will be disclosed to that third party (or parties) and will be subject to the privacy policy and practices of that third party. We are not responsible for the privacy policies and practices of third parties, and, if you later decide that you no longer want to receive communications from a third party, you will need to contact that third party directly. You also may request, sometimes through your use of an SNS or similar interactive feature or third party application, that we share information about you with a third party and we will typically do so under those circumstances.
  • Legal and Investigative Purposes: ModuGo will share information with government agencies as required by law, including without limitation, in connection with reporting earnings. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), at the request of governmental authorities or other third parties conducting an investigation, to protect the property and rights of ModuGo or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, fraudulent, unethical or legally actionable activity. We may also use Device Identifiers to identify ModuGo Users, and may do so in cooperation with third parties at our discretion.
  • Internal and Business Transfers: ModuGo may share information, including Personal Information, with its affiliates, primarily for business and operational purposes. We may sell, transfer or otherwise share some or all of our assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets (including, in each case, as part of the due-diligence process with any potential acquiring entity) or in the event of bankruptcy. You will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
  • Sweepstakes, Contests and Promotions: We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) that may require registration. By participating in a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, your Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winner’s list.
4. THIRD PARTY ANALYTICS PROVIDERS, AD SERVERS AND SIMILAR THIRD PARTIES

ModuGo works with (or may in the future work with) network advertisers, ad agencies, analytics service providers and other vendors to provide us with information regarding traffic on the Site, including pages viewed and the actions taken when visiting the Site; to serve our advertisements on other web sites, within mobile apps and elsewhere online; and to provide us with information regarding the use of the Site and the effectiveness of our advertisements. Our service providers may collect certain information about your visits to and activity on the Site as well as other websites or services, they may set and access their own tracking technologies on your device (including cookies and web beacons), and may use that information to show you targeted advertisements. Some of these parties may collect Personal Information when you visit the Site or other online websites and services. We may also share certain Non-Identifying Information with these parties in connection with the services they provide to us.

While we may use a variety of service providers to perform advertising services, some of these companies are members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. You may want to visit http://www.networkadvertising.org/managing/opt_out.asp, which provides information regarding targeted advertising and the “opt-out” procedures of NAI members. You may also want to visit or http://www.aboutads.info/choices/, which provides information regarding targeted advertising and offers an “opt-out” by participating companies in the DAA Self-Regulatory Program. Please note that opting out through these mechanisms does not opt you out of being served advertising, and you will continue to receive generic ads while online.

5. YOUR CHOICES AND OPTING OUT

Registered ModuGo Users may update their choices regarding the types of communications you receive from us through your online account. You also may opt out of receiving marketing emails from us by following the opt-out instructions provided in those emails. Please note that we reserve the right to send you certain communications relating to your account or use of the Service (for example, administrative and service announcements) via email and other means and these transactional account messages may be unaffected if you opt out from receiving marketing communications. You may opt out of receiving text messages by replying “STOP” to any text message received. Registered ModuGo Users who access the Site by using an ModuGo mobile application may, with permission, receive push notifications. Similarly, registered ModuGo Users who access the Site by using certain desktop browsers may, with permission, receive push notifications. Notification preferences can be modified in the settings menu for the mobile application or the applicable browser.

6. CHANGING YOUR INFORMATION OR CLOSING YOUR ACCOUNT

Upon request ModuGo will provide you with information about whether we hold any of your personal information. You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information. You may access, correct, or request deletion of your personal information by making updates to that information or by contacting ModuGo through your online account. If you request to access all personal information you’ve submitted, we will respond to your request to access within 30 days. If you completely delete all such information, then your account may become deactivated. If your account is deactivated or you ask to close your account, you will no longer be able to use the Site and Site Services. If you would like us to delete your account in our system, you can do so through the ModuGo Site Services (once you logged in, visit settings/ user settings, and then click on the close my account link). We will use commercially reasonable efforts to honor your request; however, certain information will actively persist on the Service even if you close your account, including information in your Work Diaries and messages you posted to the Service. In addition, your Personal Information may remain in our archives and information you update or delete, or information within a closed account, may persist internally or for our administrative purposes. It is not always possible to completely remove or delete information from our databases. In addition, we typically will not remove information you posted publicly through or on the Service. Bear in mind that neither you nor ModuGo can delete all copies of information that has been previously shared with others on the Site.

7. SECURITY

ModuGo takes commercially reasonable steps to help protect and secure the information it collects and stores about ModuGo Users. All access to the Site is encrypted using industry-standard transport layer security technology (TLS). When you enter sensitive information (such as tax identification number), we encrypt the transmission of that information using secure socket layer technology (SSL). We also use HTTP strict transport security to add an additional layer of protection for our ModuGo Users. But remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Thus, while we strive to protect your personal data, ModuGo cannot ensure and does not warrant the security of any information you transmit to us.

8. INTERNATIONAL TRANSFER OF PERSONAL INFORMATION

ModuGo is a United States company. The Site and Site Services are not to be used by persons outside of the United States.

9. LINKS TO OTHER SITES

Our Service contains links to other websites. If you choose to click on a third party link, you will be directed to that third party’s website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit Personal Information from you. We encourage you to read the privacy policies or statements of the other websites you visit.

10. PUBLIC PROFILE

The profile you create on our site will be publicly accessible unless otherwise indicated. You may change the privacy settings of your profile through your account portal.

11. PHISHING

Phishing websites imitate legitimate websites in order to obtain personal or financial information. Identity theft and the practice currently known as “phishing” are of great concern to ModuGo. In addition, if you believe you have received an email or had a similar interaction with a third party pretending to be ModuGo, please report it at legal@modugo.com.

12. CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS

Pursuant to California Civil Code Section 1798.83, California residents who provide us with personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us, one time per calendar year, information about the customer information we shared, if any, with other businesses for their own direct marketing uses. Alternatively, the law provides that a company may comply, as ModuGo does, by disclosing in its privacy policy that it provides consumers choice (opt-in or opt-out) regarding sharing Personal Information with third parties for those third parties’ direct marketing purposes, and information on how to exercise that choice. As stated above in this Privacy Policy, ModuGo provides you choice prior to sharing your personal information with third parties for their direct marketing purposes. If you do not opt-in or if you choose to opt-out at the time ModuGo offers that choice, ModuGo does not share your information with that identified third party for its direct marketing purposes.

If you are a California resident and you have questions about our practices with respect to sharing information with third parties for their direct marketing purposes and your ability to exercise choice, please send your request to the following email address: legal@modugo.com or write to us at the following mailing address:

ModuGo
Attn: Legal
206 E. Huron St.
Ann Arbor, Michigan 48104

You must put the statement “Your California Privacy Rights” in the subject field of your email or include it in your writing if you choose to write to us at the designated mailing address. You must include your name, street address, city, state, and ZIP code. We will respond to you at your mailing address or, at our option, your email address. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

13. CHANGES TO THIS POLICY

ModuGo may update this Privacy Policy at any time and any changes will be effective upon posting. In the event that there are material changes to the way we treat your Personal Information, we will display a notice through the Site prior to the change becoming effective. We may also notify you by email, in our discretion. However, we will use your Personal Information in a manner consistent with the Privacy Policy in effect at the time you submitted the information, unless you consent to the new or revised policy.

14. CONTACTING US

If you have any questions about this Privacy Policy, please contact us at legal@ModuGo.com; or by mail addressed to ModuGo, Attn: Legal, 206 E. Huron St., Ann Arbor, Michigan 48104.