Introduction

Modu.Digital (“Modu”) registered in England under company number 12041636 and with registered office at 68 Hanbury Street, London, E1 5JL. Modu is a data controller for the purposes of the UK Data Protection Act (DPA) 2018 and the EU General Data Protection Regulation (GDPR) and is registered as such with the Information Commissioner’s Office (ICO). 

Modu is committed to protecting the privacy of our clients. This privacy notice is intended to set out the basis upon which any personal data or information we collect from you, or that you provide to us, may be collected and processed by (or on behalf of) Modu. 

It applies to use of our website, our professional services or during any communications with you. 

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How we collect your personal data 

Your personal information such as name, address, email address and phone number, or any other personal data which may reasonably identify you, may be collected by: 
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• Attending meetings and/or during telephone calls to us; 

• Corresponding with us by email, in which case we may retain the content of your email messages together with your email address and our responses; 

• Supplying us with your personal information by signing up to receive a newsletter or to attend an event; 

• Supplying us with your personal information as part of the recruitment or supplier engagement process; 

• Using our website, during which other personal data may be automatically collected, such as your IP address (please see section on cookies, below). 

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Sensitive information 

We will not collect sensitive personal information from visitors to our website, clients or our employees, except where necessitated by the terms of our engagement. Sensitive personal information includes information about racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person’s sex life or sexual orientation. 

Any sensitive personal information collected as part of our lawful processing obligations will be protected using best practice information security controls. 

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How we use your personal information 

We will use your personal information solely for the purpose for which it was provided and share it with Modu partners, staff and consultants on a ‘need to know’ basis. We will not use your data for other purposes without your explicit consent. 

We use cloud based applications and providers for information storage. Data is by preference stored in the EU but may be transferred for hosting/storage to the United States. We will only send data outside of the EU where an organisation employs data protection rules that are recognised as being equivalent. We only use suppliers who implement the same level of security controls (or stronger) as we do ourselves. 

We may use your personal information for the following purposes: 
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• To communicate directly with you regarding your query or application. We may contact you by post, email, telephone or text message. You may opt out/unsubscribe from such communications at any time by emailing privacy@modu.digital; 

• To process any job application you may make to us (including any sensitive personal information you provide); 

• To provide or administer services; 

• To update client records; 

• To confirm identity, ascertain credit worthiness and trace whereabouts where necessary; 

• To manage and monitor the skills and placement of individuals on specific project deployments, resource management, enable client feedback and improve the overall quality of our service delivery, including through client satisfaction surveys and project management; 

• To comply with legal and regulatory requirements including verifying the identity of new clients/associates (and in certain circumstances existing clients/associates) to comply with anti-money laundering regulations, right to work checks and other legislative requirements applicable to Modu; 

• To comply with law enforcement. 
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Personal information will be retained by us and will not be sold, transferred or otherwise disclosed to any third party, other than for the purpose of lawful processing. Personal information may be anonymised for the purpose of research to inform our marketing and development strategies or where such disclosure is required by law or court order. 

If your personal information changes or you no longer wish to receive a particular communication from us please let us know and we will correct, update or remove your details. This can be done by emailing privacy@modu.digital. 

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Security 

In providing services to you, we may process personal data as a controller or on your behalf as a data processor. Where we act as processor on your behalf we will only process personal data for the purposes outlined above or otherwise in accordance with your instructions, and only keep it for as long as it is needed for that purpose. 

We use up-to-date data storage and security controls to protect your personal information from unauthorised access, improper use or disclosure, unauthorised modification or unlawful destruction or accidental loss. All our employees and any third parties we engage to process your personal information are obliged to respect the confidentiality of your information. 

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Disclosing personal information to third parties 

We may disclose your personal information to our agents or service providers, where there is a lawful basis, for any of the purposes set out in this policy. 

We will not sell your information to a third party. 

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Cookies 

Modu uses cookies to provide and improve our website, including by storing your preferences and recognising you when you visit our website. To accomplish these purposes, Modu also may link information from cookies with other personal information Modu holds about you. 

A cookie is a small piece of data that a website asks your browser to store on your device in order to remember information about you, such as your language preference or login information. Those cookies are set by us and called first-party cookies. We also use third-party cookies for our advertising and marketing efforts. More specifically, we use cookies and other tracking technologies for the following purposes: 

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Strictly Necessary Cookies 

These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information. 

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Performance Cookies 

These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance. 

Targeting Cookies 

These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising. 

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How can you control cookies? 

Browser and device controls. Some web browsers provide settings that allow you to control or reject cookies or to alert you when a cookie is placed on your computer. The procedure for managing cookies is slightly different for each internet browser. You can check the specific steps in your particular browser help menu. You also may be able to reset device identifiers by activating the appropriate setting on your mobile device. The procedure for managing device identifiers is slightly different for each device. You can check the specific steps in the help or settings menu of your particular device. 

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More information 

To find out more about how cookies work, how to manage and delete them and to see which ones have been set please visit www.aboutcookies.org or www.allaboutcookies.org. 

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Your rights 

Under the GDPR, you have rights as an individual which you can exercise in relation to the information we hold about you. For further information, please visit ico.org.uk. 

If at any time you wish to exercise your rights as a data subject in relation to information we hold about you as an individual please contact us by email to privacy@modu.digital or by mail to the address below. 

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Complaints or queries 

Modu tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage you to bring it to our attention if you think that our collection or use of your information is unfair, misleading or inappropriate. 

This privacy notice does not provide exhaustive detail of all aspects of Modu’s collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below. 

If you want to make a complaint about the way we have processed your personal information please do so by email to privacy@modu.digital. If you are not satisfied with the response we give you then you can contact the Information Commissioner’s Office (www.ico.org.uk), which is the statutory body which oversees data protection law in the UK. 

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Agreement to terms of Privacy Notice 

By using this website and/or providing your personal information to us, you consent to the collection and use of your personal information by us set out in this privacy notice. 

If we change our privacy policies and procedures, we will post those changes on our website or otherwise notify you to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it. 

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Further information 

To learn more about how we collect, use and maintain your personal information, please contact: 

Data Protection Officer Email: privacy@modu.digital