Privacy Policy

Last Updated

MODULE PRIVACY POLICY

The Module Design, Inc. (“Module”) Privacy Policy (the “Privacy Policy”) is designed to inform you (“You”) about Module’s collection and use of information in the conduct of Module’s business.  The Privacy Policy applies to all users of the Module platform (the “Service”). The “Service” includes (a) the Module website (the “Site”), (b) Module Data, and (c) the other services provided to You through the Site, including, without limitation, email newsletters and real-time text message alerts. Module’s Terms of Service (the “Terms of Service”) is incorporated herein by reference and is available at http://staging.modulehousing.com/termsofservice. All defined terms in the Privacy Policy shall have the same meaning as defined in the Terms of Service.

By using the Service, You are consenting to Module’s collection, use, processing, and disclosure of Your information as set forth in this Privacy Policy, which may be modified from time to time.  You should review this Privacy Policy from time to time so that You are updated on any changes. If You do not wish to consent to Module’s collection, use, processing and disclosure of Your information, then do not use the Service or any portion thereof.

Module adheres to the following policies with regard to Your privacy.

  1. DEFINITIONS
  2. “NPI” is information that is not personally identifiable and that is obtained through Your use of the Service.
  3. “PII” is non-public information that is personally identifiable and obtained in connection with providing a product or service to You, including personally identifiable information You provide during the registration process or during Your use of the Service. It may include information such as name and address that You provide to Module. PII does not include information that has been made anonymous or aggregated so that it can no longer be used, whether in combination with other information or otherwise, to contact or identify You.
  4. HOW MODULE SENDS INFORMATION TO YOU
  5. As part of the Service, Module may send You this information through SMS text messages, email, or other channels.
  6. To receive information from Module through SMS text messages, You must provide us with Your mobile phone number and respond to the SMS text message that Module sends to that number as part of the verification process. Your mobile phone carrier’s standard messaging rates will apply. If You opt-in to receive SMS text messages from Module, You will receive one (1) to twenty (20) text messages per week. You may opt-out of and opt-in to receiving these text messages at any time by texting “STOP.”
  7. Module may also send You information through email, or other channels. You may opt-out of receiving emails from us through email by clicking on the “Unsubscribe” link contained in each email.
  8. INFORMATION COLLECTION
  9. When You use the Service, Module collects NPI, for example, Your device’s browser type. Likewise, in order to offer You meaningful products and services and for other reasons, Module may collect PII about You from the following sources:
  • Information transmitted from Your mobile device, including information described in Section 3(d) below; or
  • Information You create or Information You give Module on applications or other forms while using the Service; or
  • Information You send Module via any medium, including, but not limited to email, telephone, and social media interaction.
  1. Registration

In order to use certain portions of the Service, You must provide Module the following information: email address, and first and last name, and create a password. In addition, You may choose to add additional information to Your account, for example an estimated budget. Module may request other information from You during or after the registration process that Module uses to provide better and more customized services to its customers.

  1. Use of Cookies and Related Technology

The Service may send a “cookie” to Your device. A cookie is a small piece of data that is sent to Your browser from a web server and stored on Your device. A cookie cannot read data off Your device or read cookie files created by other sites. Cookies do not damage Your system. Cookies allow Module to recognize You as a user when You access the Service using the same device and web browser. Module uses cookies to identify which areas of the Service You have used, so the next time You use the Service, those pages may be readily accessible. Module also may use this information to better personalize the content that You see while using the Service. Most browser software can be set to reject cookies. However, if You reject Module’s cookies, certain functionality on the Service may not work correctly or at all.

Module may also use web beacons, pixels, anonymous ad network tags, cookies and similar technologies to collect NPI about Your use of the Service and the websites of selected sponsors and advertisers, to collect anonymized, aggregated auditing, research and reporting for advertisers, and to collect data related to Your use of special promotions or newsletters. The information collected by web beacons also allows Module to statistically monitor how many people open Module’s emails and for what purposes these actions are being taken. Module’s web beacons are not used to track Your activity outside of the Service or the websites of Module’s sponsors. In addition, Your web browser requests advertisements and web beacons directly from ad network servers, these networks can view, edit or set their own cookies, just as if You had requested a web page from their site. Module may link NPI from web beacons, cookies, and related technologies collected during Your use of the Service to Your PII.

  1. Log Files, IP Addresses and Information About Your Device

When You use the Service, Module may automatically receive the URL of the site from which You came and the site to which You are going when You leave Module’s Service. Module also receives the IP address (and approximate city based on same) of Your computer (or the proxy server You use to access the internet), Your computer operating system and type of web browser You are using, email patterns (e.g., email open statistics), Your mobile device, including Your Unique Device Identifier (“UDID”) and mobile operating system, as well as the name of Your ISP or Your mobile carrier. The link between Your IP address and Your PII is not shared with third parties without Your permission, except as described in Section 8 (“When Module May Disclose Your Information”), below.

Do Not Track:  Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked.  If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform.  For this reason, many website operators, including Module, do not respond to DNT signals.

  1. Usage Data

Module also collects information about how You use the Service, including Service performance, clicks, and access data and times. Module utilizes Google Analytics in providing the Services. For more information regarding Google’s use of cookies, and collection and use of information, see the Google Privacy Policy (available at https://policies.google.com/privacy?hl=en). If you would like to opt out of Google Analytics tracking, please visit the Google Analytics Opt-out Browser Add-on (available at https://tools.google.com/dlpage/gaoptout).

  1. SMS and Call Data

If You communicate with us by phone or through SMS texts, as part of providing You the Service, Module may receive SMS and/or call data, such as the date and time of the call or SMS, the sending and receiving phone numbers, and the content of the SMS message.

  1. EXEMPTIONS FROM PRIVACY POLICY

Module’s Privacy Policy does not apply to (a) any information You may send to Module by email or instant messaging programs (i.e. AOL, Yahoo, etc.), as email and instant messages are not recognized as secure communication forms or (b) information You provide to or that is collected by any third party. As such, Module requests that You do not send any information, which You consider private, to Module by email or instant message.

  1. USE OF PII
  2. From time to time, Module may disclose the information collected from You, including PII, in accordance with Section 8 (“When Module May Disclose Your Information”), below.
  3. Module uses and/or intends to use PII to:
  • Operate and improve the Service;
  • Create Your account;
  • Provide You with the Service and other products and services that You may request or that You have expressed interest in;
  • Evaluate Your interest and needs in order to improve the Service and make available other offers, products or services;
  • Evaluate the types of offers, products or services Module makes available to You and potential customers;
  • Track use of the Service;
  • Provide customer support;
  • Communicate and provide additional information that may be of interest to You through email or other means, such as special offers, announcements, and marketing materials;
  • Send You reminders, technical notices, updates, security alerts and support and administrative messages, service bulletins, or marketing;
  • Provide advertisements to You through email messages;
  • Create reports based on anonymized and aggregated PII to be made available to industry members, provided that such reports will not themselves contain PII; and
  • Manage Module’s everyday business needs such as Service administration, forum management, fulfillment, analytics, fraud prevention, enforcement of Module’s corporate reporting obligations, Terms of Service or to comply with the law.
  1. This Privacy Policy does not limit Module’s use of any NPI, and Module reserves the right to use and disclose such information to third parties at Module’s discretion.
  2. LINKS/POSTINGS TO OTHER SITES

You may access the Service on a third-party website and/or the Service may contain links to other websites. Module is not responsible for the actions, practices, or content of such websites linked to or from any of the Service. You understand that such websites may have their own legal documents to which You must agree prior to using and that Module has no control over these legal documents. As always, You understand that it is Your responsibility to verify Your legal use of a website as well as use of information from the website with the corresponding website owner. Module does not guarantee, approve, or endorse any information, material, services, or products contained on these third-party websites.  Module is not responsible for any content on sites linked from or to the Service or for obtaining any necessary consent for such third-party websites to collect, transmit, or otherwise use Your information.

  1. USE OF AGGREGATE DATA

Module may combine NPI, including anonymized data, You provide through the Service with information from other users to create aggregate data that may be disclosed to third parties. Aggregate information disclosed to third parties does not contain any information that could be used to identify You and does not include Your PII.

  1. WHEN MODULE MAY DISCLOSE YOUR INFORMATION
  2. Except as set forth in this Privacy Policy or as specifically agreed to by You, Module will not disclose any PII as gathered from You through the Service.
  3. Module may share PII in limited fashion to Module’s contractors and service providers that perform services on Module’s behalf, including, but not limited to, operation of the Service technology, data analytics, marketing services, and other related services. Unless You have opted-out (see Section 8.F. below) of such sharing, these contractors also may have access to Your email address or mobile phone number to send newsletters or special promotions to You on Module’s behalf or to send emails to You for purposes such as conducting market research on Module’s behalf. Access to Your PII by such contractors and service providers is limited to the information reasonably necessary for the contractor to perform its limited function for Module. Module also contractually requires that such contractors and service providers: 1) protect the privacy of Your PII consistent with this Privacy Policy, and 2) not use or disclose Your PII for any purpose other than providing Module with products and services as required by law.
  4. Module may share PII Module collects, as permitted by law, to companies such as credit reporting agencies, or servicing and processing companies, or when required or advised to do so in response to a valid legal requirement to release this information such as a state or federal law, regulation, search warrant, subpoena, or court order; or in special cases, such as in response to a physical threat to You or others, to protect property, or if Module determines such disclosure is legally advisable or necessary to defend or assert legal rights or prevent harm, to defend ourselves in litigation. In the event that Module is legally compelled to disclose Your PII to a third party, Module will attempt to notify You unless doing so would violate the law or court order.
  5. Module may share PII in accordance with Section 11 (“Transfer of Ownership”), below.
  6. Module may share and/or sell aggregated data in accordance with Section 7 (“Use of Aggregate Data”).
  7. If You prefer that Module does not share certain PII with third parties, as described above, You can direct Module not to share that PII by contacting Module (support@modulehousing.com). Please note that an opt-out with respect to information sharing will not apply to information sharing arrangements described in Sections 8.B. or 8.C.

 

  1. Finally, Module may provide content and services to You through websites and platforms other than those contained in the Service. Module will not disclose Your PII to these third-party websites and platforms without Your consent, but You should be aware that any information You disclose on such sites or platforms is NOT subject to this Privacy Policy.
  2. SECURITY POLICY & USER ID/PASSWORD
  3. Module policies limit access to un-aggregated user PII that is collected from the Service to Module employees and agents and the employees and/or agents of Module’s affiliates and business partners who need the information to fulfill their business responsibilities, and who are under obligations of confidentiality.
  4. Module shall maintain appropriate administrative, physical and technical safeguards to protect the security, confidentiality and integrity of Your data.  These safeguards include encryption of Your data in transmission (using SSL or similar technologies), except for external third party integrations that You may link to the Service at Your choice, if available, that do not support encryption, and encryption of backups of databases. If Module provides the capability for You to create a user ID and password, You should protect Your user ID and password and NOT share it with anyone. If You believe Your user ID and password have been compromised and You have trouble changing Your user ID/password on the Service, please contact Module’s technical support department (support@modulehousing.com).
  5. CAN-SPAM COMPLIANCE NOTICE

You can opt out of receipt of further email correspondence from Module by contacting Module at support@modulehousing.com.

  1. TRANSFER OF OWNERSHIP

If the entire or substantial ownership of the Service were to change, or in the event of another sale or transfer of some or all of Module’s assets, Your user information, including PII, may be transferred to the new owner so the Service can continue operations. In any such transfer of information, Your user information, including PII, would remain subject to the promises of Module’s then current Privacy Policy. If You prefer that Module does not share Your PII in accordance with this Section 11 (“Transfer of Ownership”), You can direct Module not to share that PII by contacting Module (support@modulehousing.com).

  1. NOTICE TO RESIDENTS OF COUNTRIES OUTSIDE OF THE UNITED STATES OF AMERICA

Module is headquartered in the United States of America, and the Service is not marketed to, or intended or designed for use outside of, the United States of America. PII may be accessed by Module or transferred to Module or affiliates, business partners, merchants, or service providers (in accordance with this Privacy Policy) in the United States of America or to Module’s affiliates, business partners, merchants, or service providers outside of the United States of America (e.g., one of Module’s service providers may have servers located outside the United States of America) in accordance with this Privacy Policy. Processing Your PII is necessary for Module to perform its obligations under the Terms of Service for the Service. Module may also process Your PII for the purpose of a legitimate business interest such as maintaining, improving, and tracking the use of the Service. Module will protect the privacy and security of PII according to Module’s Privacy Policy, regardless of where it is processed or stored.

  1. CALIFORNIA PRIVACY RIGHTS

Pursuant to Section 1798.83 of the California Civil Code, residents of California can obtain certain information about the types of PII that companies with whom they have an established business relationship have shared with third parties for direct marketing purposes during the preceding calendar year. In particular, the law provides that companies must inform consumers about the categories of PII that have been shared with third parties, the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. To request a copy of the information disclosure provided by Module pursuant to Section 1798.83 of the California Civil Code, please contact Module via email to support@modulehousing.com.

  1. YOUR ACCEPTANCE OF THIS PRIVACY POLICY
  2. This is Module’s entire Privacy Policy and it supersedes any earlier version. You agree to it every time You use the Service.
  3. If Module makes any material changes to this Privacy Policy, Module will notify You by email or by posting a prominent notice on the Service prior to the change becoming effective. Module encourages You to periodically review this page for the latest information on Module’s privacy practices. Your continued use of the Service constitutes Your agreement to be bound by such changes to this Policy. Your only remedy, if You do not accept the terms of this Policy, is to discontinue use of the Service.
  4. PROTECTING CHILDREN’S PRIVACY
  5. Use of the Service is limited to users who are eighteen (18) years of age or older.
  6. Module strongly believes in protecting the privacy of children. In line with this belief, Module does not knowingly collect or maintain PII from the Service from persons under eighteen (18) years of age, and no part of the Service is directed to persons under eighteen (18) years of age. If You are under eighteen (18) years of age, then please do not use or access the Service at any time in any manner. Module will take appropriate steps to delete any PII of persons less than eighteen (18) years of age that has been collected on the Service without verified parental consent upon learning of the existence of such PII.
  7. GENERAL DATA PROTECTION REGULATION (GDPR)
  8. Module’s policy is to protect and safeguard any PII obtained by Module in accordance with applicable United States state and federal laws governing the protection of PII and data.   Those who choose to access the Service from locations outside the United States do so on their own initiative, and are responsible for compliance with local laws if and to the extent local laws are applicable.   
  9. Module does not target or knowingly collect data from users in the EU.  If You are an EU or United Kingdom resident and believe Module may have collected PII from You, subject, as the case may be, to additional elements that may be required to establish Your identity, You may send Module an e-mail at support@modulehousing.com to request, at no charge, to delete any information Module may have collected from You.
  10. HOW LONG WE RETAIN YOUR INFORMATION

Module keeps Your PII only as long as necessary for the purposes for which the PII are processed and as permitted by applicable law.

In practice, Module deletes or anonymizes Your PII upon deletion of Your account, unless:

  • Module must keep it to comply with applicable law;
  • Module must keep it to evidence our compliance with applicable law;
  • there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
  • the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users’ safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account.

Keep in mind that even though Module’s systems are designed to carry out data deletion processes according to the above guidelines, Module cannot promise that all data will be deleted within a specific timeframe due to technical constraints.

  1. QUESTIONS ABOUT THIS PRIVACY POLICY

Should You have a privacy question about the Service or this Privacy Policy, You may contact Module at support@modulehousing.com or the following address:

Module Design, Inc.

Chief Product Officer

6401 Penn Ave.

Pittsburgh, PA 15206