Privacy Policy
Last Updated: Aug 15, 2026
At Modular, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Platform (as defined in the Terms) or our website, (collectively the “Services”) in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy. Remember that your use of Modular's Services is at all times subject to our Terms of Use (https://www.modular.com/terms) (collectively the “Terms”). The Terms incorporate this Privacy Policy by reference. Any terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms. We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on the Modular website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.
What this Privacy Policy Covers
You may print a copy of this Privacy Policy by clicking print.
We do not sell Personal Data for monetary compensation. However, the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (the “CCPA”) defines the terms “sale” and “sharing” broadly to include the sharing of Personal Information with third parties for something of value, even if no money is exchanged. We may share certain Personal Data with third parties that provide data enrichment, cross-context behavioral advertising, or other types of advertising, which may qualify as a “sale” or “sharing” under the CCPA’s broad definitions.
The chart below further details the categories of Personal Data under the CCPA, that we (i) collect and have collected over the past 12 months, (ii) disclosed for business purposes in connection with the provision of Services, and (iii) “sold” or “shared” as defined under the CCPA. For details regarding the categories of third parties to whom we disclose, sell, or share Personal Data, and the purposes for such processing, please refer to the above chart and the sections below on “Our Commercial or Business Purposes for Collecting or Disclosing Personal Data” and “How We Share or Disclose Your Personal Data”.
Categories of Sources of Personal Data
We collect Personal Data about you from the following categories of sources:
1. You
▪ When you provide such information directly to us. When you create an account or use our interactive tools and Services. When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires. When you send us an email or otherwise contact us.
▪ When you use the Services and such information is collected automatically. Through Cookies (defined in the “Tracking Tools and Cookie choices” section below). If you use a location-enabled browser, we may receive information about your location. If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.
2. Third Parties
▪ Vendors - We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support. We may use vendors to obtain information to generate leads and create user profiles.
▪ Social Networks - If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into your account with us.
Our Commercial or Business Purposes for Collecting or Disclosing Personal Data
1. Providing, Customizing and Improving the Services
▪ Creating and managing your account or other user profiles.
▪ Processing orders or other transactions; billing.
▪ Providing you with the products, services or information you request.
▪ Meeting or fulfilling the reason you provided the information to us.
▪ Providing support and assistance for the Services.
▪ Improving the Services, including testing, research, internal analytics and product development.
▪ Personalizing the Services, website content and communications based on your preferences.
▪ Doing fraud protection, security and debugging.
▪ Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the CCPA.
2. Marketing the Services
Marketing and selling the Services.
3. Corresponding with You
Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Modular or the Services. Sending emails and other communications according to your preferences or that display content that we think will interest you.
4. Meeting Legal Requirements and Enforcing Legal Terms
Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities. Protecting the rights, property or safety of you, Modular or another party. Enforcing any agreements with you. Responding to claims that any posting or other content violates third-party rights. Resolving disputes.
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.
How We Share or Disclose Your Personal Data
We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections of this Privacy Policy.
▪ Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include: Hosting, technology and communication providers. Security and fraud prevention consultants. Payment processors.
▪ Analytics Vendors. These parties provide analytics on web traffic or usage of the Services. They include companies that track how users found or were referred to the Services. Companies that track how users interact with the Services.
▪ Advertising Vendors.
▪ Parties You Authorize, Access or Authenticate Third parties you access through the services. Social media services. Other users.
▪ Our affiliates, including Qualcomm Incorporated and its subsidiaries.
Legal Obligations
We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.
Business Transfers
All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
Data that is Not Personal Data
We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.
Tracking Tools and Cookie Choices
The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.
We use the following types of Cookies:
▪ Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
▪ Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
▪ Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google LLC (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Service and the Google Privacy Policy.
▪ Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you.
Non-essential Cookies (Performance/Analytical and Retargeting/Advertising) are used only where you have given any consent required by applicable law. You can give, manage or withdraw that consent at any time through the cookie preference tool on our website, or block or delete Cookies via your browser or device settings, although some features may not work as a result.
We use third-party services that may associate your website activity with your email address and online profile information for marketing purposes. Where required by applicable law, we will only use these services with your prior consent. You may manage your choices through the cookie preference tool made available on our website and, where applicable, may also opt out of this tracking at app.retention.com/optout. To explore what Cookie settings are available to you or to modify your Cookies preferences, use the cookie preference tool made available on our website or review the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the UK, or https://youronlinechoices.eu/ if you are located in the European Union.
Data Security
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.
Data Retention
We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
Personal Data of Children
As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data about children under 18 years of age; if you are a child under the age of 18, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 18 years of age, we will delete that information as quickly as possible. If you believe that a child under 18 years of age may have provided Personal Data to us, please contact us at privacy@modular.com.
U.S. State Resident Rights
If you are a U.S. resident, we additionally process your Personal Data in accordance with applicable U.S. state data privacy laws. Depending on the laws applicable to our processing of Personal Data, you may have the ability to exercise the rights listed below. We provide further information regarding certain rights for California residents in this section.
California
If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end-users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.
If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at privacy@modular.com.
Knowledge/Access
You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:
▪ The categories of Personal Data that we have collected, disclosed, sold and/or shared about you.
▪ The categories of sources from which that Personal Data was collected.
▪ The business or commercial purpose for collecting, sharing and/or selling your Personal Data.
▪ The categories of third parties with whom we have disclosed, shared and/or sold your Personal Data.
▪ The specific pieces of Personal Data that we have collected about you.
If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third party recipient.
You have the right to request a copy of your Personal Data in a machine-readable format that allows you to transmit the data without hindrance, to the extent technically feasible.
Deletion
You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested, or deletion may require disproportional effort. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
Correction
You have the right to request that we correct any inaccurate Personal Data we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, if we decide, based on the totality of circumstances related to your Personal Data, that such data is correct. If your correction request is subject to one of these exceptions, we may deny your request.
Opt-Out of Sale or Sharing
You will be opted in by default to the sale or sharing of Personal Data. You have the right to opt out of the sale and sharing (as such terms are defined under the CCPA or relevant U.S. privacy laws) of your Personal Data. California residents may opt out of the sale or sharing of their Personal Data by clicking the “Do Not Sell or Share My Personal Information” link in the footer of the Modular website if you are located in California, by visiting app.retention.com/optout, or by emailing privacy@modular.com.
Limit Use and Disclosure of Sensitive Personal Data
We do not process sensitive Personal Data as contemplated by CCPA or U.S. privacy laws for purposes other than those permitted (including to provide you with the Services), and therefore do not offer a separate right to limit the use of sensitive Personal Data.
Exercising Your Rights
To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.
We will work to respond to your Valid Request within 45 days of receipt or within the timeline as required by applicable privacy law. We will not charge you a fee for making a Valid Request unless your Valid Request is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may submit a Valid Request using the following methods:
▪ Email us at: privacy@modular.com
▪ Submit a form at this address: https://www.modular.com/contact/us
You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.
No Discrimination for Exercising Your Rights
You have the right not to receive discriminatory treatment by us for the exercise of your privacy rights under the CCPA. We will not deny you our services, charge you different prices or rates, or provide you a lower level or quality of goods and services because you exercised your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.
Shine the Light
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at privacy@modular.com.
Appeal
If we deny your right to exercise any of the rights described above, you have the right to appeal that decision. To appeal that decision, please contact us at privacy@modular.com with the subject line “Privacy Rights Appeal.” If your appeal is denied and you are not satisfied with the decision, you may contact the State office of the Attorney General.
U.S. Resident Rights
If you are a U.S. resident, you may have the rights set forth under the privacy laws enacted by the state or territory in which you reside. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Additionally, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request.
If there are any conflicts between this section and any other provision of this Privacy Policy, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at privacy@modular.com
Access/Confirmation
You may have the right to request confirmation of whether or not we are processing your Personal Data and to access your Personal Data.
Correction
You may have the right to correct inaccuracies in your Personal Data, to the extent such correction is appropriate in consideration of the nature of such data and our purposes of processing your Personal Data.
Portability
You may have the right to request a copy of your Personal Data in a machine-readable format that allows you to transmit the data without hindrance, to the extent technically feasible.
Opt Out of Sale
You may have the right to opt out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data.
You may submit a request to exercise your rights using the following methods:
▪ Email us at: privacy@modular.com
▪ Submit a form at this address: https://www.modular.com/contact/us
You may also have an Authorized Agent exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.
European Union and United Kingdom Data Subject Rights
EU and UK Residents
If you are a resident of the European Union (“EU”), United Kingdom (“UK”), Lichtenstein, Norway or Iceland, you may have additional rights under the EU or UK General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.
For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Modular will be the controller of your Personal Data where covered by this Privacy Policy. Where we process Personal Data on behalf of a customer in connection with that customer’s use of the Platform, including Personal Data relating to the customer’s end users, we will act as a processor to that customer and that customer’s own privacy notice or policy will cover our processing of Personal Data in those circumstances (not this Privacy Policy).
If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at either:
- Privacy@modular.com; or
- European Economic Area and UK data subjects may also contact us by post at: Bayes Centre, 47 Potterrow Edinburgh, EH8 9BT
Personal Data We Collect
The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.
Personal Data Use and Processing Grounds
The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we use your Personal Data.
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.
▪ Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Use with you, which enables us to provide you with the Services.
o Profile or contact data
o Payment Data
▪ Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties Device data, Web analytics data, Geolocation Data, Professional Data, We may also de-identify or anonymize Personal Data to further our legitimate interests.
Examples of these legitimate interests include (as described in more detail above):
▪ Providing, customizing and improving the Services.
▪ Marketing the Services.
▪ Corresponding with you.
▪ Meeting legal requirements and enforcing legal terms.
▪ Completing corporate transactions.
▪ Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
▪ Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.
We do not process Personal Data for automated decision-making or profiling purposes.
Failure to provide Personal Data could result in your inability to use some or all portions of the Services that require such data or we may not be able to provide the relevant Services or functionality, create or administer your account, process payments, correspond with you including e.g., to respond to your questions where you have requested responses, send you marketing materials or otherwise fulfil the purpose for which the Personal Data was requested.
Sharing Personal Data
The “How We Share Your Personal Data” section above details how we share your Personal Data with third parties.
EU Data Subject Rights
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at privacy @modular.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
▪ Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by logging into your account.
▪ Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging on to your account.
▪ Erasure: You can request that we erase some or all of your Personal Data from our systems.
▪ Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
▪ Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
▪ Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
▪ Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
▪ Right to File Complaint: If you have a concern about how we handle your Personal Data, we encourage you to contact us first at privacy@modular.com so that we can try to resolve it directly. You have the right to lodge a complaint about Modular's practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. If you are in the UK, this is the Information Commissioner’s Office (ICO), which can be contacted at https://ico.org.uk/make-a-complaint/ - the ICO now requires data subject to first submit a complaint to the controller to seek to resolve and we will acknowledge that complaint and respond in the periods required by applicable law. If you are in the EU, a list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.
Transfers of Personal Data
The Services are hosted and operated in the United States (“U.S.”) through Modular and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. Where we transfer Personal Data from the EU, UK or Switzerland to the US or another country that has not been recognized as providing an adequate level of protection, we will rely on an appropriate transfer mechanism, such as the EU standard contractual clauses and for transfers subject to the UK GDPR, the UK Addendum, or other lawful transfer mechanism available under applicable data protection laws. Where relevant, we implement supplementary measures designed to protect Personal Data transferred internationally.
In certain situations, we may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Changes to this Privacy Policy
We keep this Privacy Policy under regular review and may make changes to it from time to time. This Privacy Policy was last updated on August 14, 2026.
Contact Information
If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:
