Effective Date: September 10, 2025

1. Introduction

Modula ("Modula", "we", "us", or "our") is committed to protecting your privacy and providing a safe online experience. This Privacy Policy explains what personal information we collect, how we use and share it, the choices you can make about that information, and how you can contact us. By accessing or using our website, products, or services (collectively, the “Services”), you agree to the terms of this Privacy Policy.

2. Scope

This Policy applies to modula.com, its subdomains, any mobile applications we operate, and to other online or offline interactions where this Policy is linked or referenced (collectively, the “Site”). It also applies to personal information we collect in our stores, via phone, email, social media, or through our authorized representatives. For vendor, contractor, employee, or applicant privacy notices, separate policies may apply.

3. Information We Collect

We limit the personal information we collect to what is adequate, relevant, and reasonably necessary for the purposes described below.

3A. Information You Provide

• Contact data: name, email address, billing and shipping address, telephone number.
• Account credentials: username and password when you create an account.
• Payment data: credit/debit card numbers and other payment instrument details (processed by our payment processors).
• Order and transaction details, including purchase history and returns.
• Communications: content of emails, chat transcripts, text messages, or other communications you send to us.
• Marketing preferences and opt-ins.
• Optional profile data: birthdate (for offers/birthday programs), shipping preferences, product reviews, and other information you choose to provide.

3B. Information Collected Automatically

When you visit or use the Site we and our service providers may automatically collect:

• Device and browser data: IP address, device identifiers, operating system, browser type and version, language, time zone.
• Usage data: pages viewed, links clicked, referring and exit pages, search terms, interaction with Site features.
• Technical and connection data: cookies, pixels, web beacons, and other similar technologies.
• Analytics and advertising identifiers: advertising IDs and similar identifiers on mobile devices.
• Location data: approximate location derived from IP address; precise geolocation only if you enable that feature.

3C. Information from Third Parties

We may receive information about you from third parties and processors (for example, Shopify, Plaid, Stripe, analytics providers, advertising partners, social networks, and other partners). We may combine this with information we collect directly.

3D. Inferences and Profiles

We may infer information about your preferences, interests, and likely purchase behavior based on your activity and use those inferences to personalize content, offers, and advertising.

4. How We Use Your Information

We use personal information for legitimate business purposes, to perform contracts, with your consent where required, and to comply with legal obligations. Typical uses include:

• To provide and operate our Services, process orders, deliver purchases, and manage your account.
• To process payments and prevent fraud (for example, via Stripe and other payment processors).
• To respond to requests, provide customer support, and communicate about orders, products, and promotions.
• To verify bank accounts or connect financial accounts where applicable (for example, via Plaid).
• To send marketing communications (you can opt out at any time).
• To personalize and improve the Site, analyze trends and usage, and perform internal research.
•  To detect, prevent, and investigate fraud, security breaches, or illegal activity.
• To comply with legal obligations and to enforce our Terms and other policies.

5. Cookies and Other Tracking Technologies

We and our partners use cookies, pixels, local storage, web beacons, and similar technologies to collect information about your interactions with the Site. Categories of cookies include:

• Essential/strictly necessary cookies: required for Site operation.
• Functional cookies: remember your settings and preferences.
• Performance/analytics cookies: measure Site usage and improve performance.
• Advertising/targeting cookies: deliver and measure ads and personalize advertising.

You may control cookie settings through your browser and device settings and by using our cookie preference tool (where available). Opt-out resources from third parties include:

• Google Analytics opt-out: https://tools.google.com/dlpage/gaoptout/
• Digital Advertising Alliance / AboutAds opt-out: http://optout.aboutads.info
• Network Advertising Initiative opt-out: http://optout.networkadvertising.org
• Note: some opt-out tools rely on cookies; if you clear cookies you may need to opt out again.

6. Advertising and Third-Party Advertising Partners

We work with advertising networks and analytics providers that may collect information about your activity across sites and apps to serve personalized ads. You can manage or opt out of targeted advertising using the opt-out resources listed above and by adjusting your device and browser settings. We also support opt-out preference signals such as the Global Privacy Control (GPC) where required by applicable law.

7. How We Share Information

We disclose personal information only in limited circumstances, including:

• Service providers and subprocessors who perform services on our behalf (for example, Shopify (e-commerce platform and hosting), Stripe (payment processing), Plaid (bank account verification and financial data connectivity), and other payment, analytics, email/marketing, fulfillment, logistics, and customer support providers).
• Affiliates and business partners, as necessary to provide services or as described at the time of collection.
• When we believe disclosure is necessary to comply with law, legal process, or to respond to lawful requests from public authorities.
• To protect the rights, property, or safety of Modula, our users, or the public.
• In connection with a corporate transaction, such as a merger, sale, reorganization, or asset transfer (with notice and contractual protections where required).
• Where you have provided consent.
  

We require service providers to use personal information only for authorized purposes and to protect it with appropriate safeguards.

8. Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Policy, to comply with legal obligations, resolve disputes, and enforce our agreements. Typical retention practices:

•  Account and order information: retained for the duration of the customer relationship and thereafter as necessary for legal, tax, or business purposes (for many records this is typically up to several years).
• Marketing preferences: retained until you unsubscribe or request deletion.
• Log and analytics data: retained in aggregated or anonymized form where feasible; otherwise retained in accordance with our data retention schedules.

If you request deletion of your data we will honor that request to the extent required by law and subject to our need to retain certain information for legitimate business or legal purposes.

9. Your Privacy Rights

Depending on where you live, you may have the following rights (subject to applicable verification and legal exceptions):

For residents of the European Economic Area (EEA) and the UK (GDPR/UK GDPR):

- Right of access, correction, deletion, restriction, portability, and to object to processing, including profiling. Where processing is based on consent, you may withdraw consent at any time.

For California residents (CCPA/CPRA) and other US state privacy laws:

• Right to know categories of personal information collected, disclosed, or sold and to whom.
• Right to access and request a copy of your personal information.
• Right to deletion of personal information (subject to exceptions).
• Right to opt out of the sale or sharing of personal information and targeted advertising.
• Right not to be discriminated against for exercising these rights.

You may exercise these rights by contacting us (see Section 15). We may require verification of your identity and may limit requests to the extent permitted by law.

Authorized Agents: you may designate an authorized agent to make requests on your behalf; we may require proof of authorization.

Appeals: if we refuse a request we will provide the reasons and, where applicable, information about how to appeal or contact a supervisory authority.

10. Automated Decision-Making and Profiling

We may use automated processing and analytics (including machine learning) to improve Site functionality, personalize content, and detect fraud. Where such processing produces legal or similarly significant effects, you have rights under relevant law (for example the right to obtain human review) and may contact us to discuss.

11. Children’s Privacy

Our Site is not directed at children under 16. We do not knowingly collect personal information from children under 16. If we learn that we have collected personal information from a child under 16 without parental consent we will take steps to delete that information. If you believe a child under 16 has provided us personal information, please contact us.

12. International Data Transfers

We operate globally. Personal information collected in one jurisdiction may be stored and processed in other jurisdictions, including the United States. When transferring data from the EEA, UK, or other jurisdictions with data transfer restrictions, we use appropriate safeguards such as standard contractual clauses or other lawful transfer mechanisms.

13. Data Security

We implement commercially reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, or destruction. However, no system is completely secure and we cannot guarantee absolute security. Please take care when sharing personal information online.

14. Third-Party Links and Services

Our Site may contain links to third-party sites, plug-ins, and applications (e.g., social media, payment providers). Those third parties may collect information about you and have their own privacy policies. We are not responsible for third-party practices; review their privacy policies before providing information.

15. Your Choices and How to Contact Us

Marketing communications: you may opt out of marketing emails by following the unsubscribe instructions in any marketing email we send you or by contacting legal@bemodula.com.

Cookies and tracking: you can manage cookie preferences via your browser settings and our cookie preference tool (where available). See Section 5 for third-party opt-out resources.

Privacy requests: to exercise your rights (access, correction, deletion, portability, opt-out of sale/sharing, etc.), please:

• Use our online privacy request form at: https://modula.com/privacy-request 
• Or email: legal@bemodula.com
• Or call: 646.767.6675

We will acknowledge your request within the timeframe required by applicable law and may request additional information to verify your identity. If you use an authorized agent, we may require proof of authorization.

If you are a resident of the EEA or UK you may also lodge a complaint with your local supervisory authority.

16. Do Not Track

Because there is no uniform standard for responding to Do Not Track signals, we do not currently respond to or alter our practices in response to Do Not Track browser signals. You can control tracking via your browser settings and the opt-out mechanisms described above.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will post the updated Policy on the Site with a revised Effective Date. Where required by law, we will provide additional notice of material changes.

18. Miscellaneous

 Notice to Residents Outside Your Jurisdiction: If you live outside the country in which our servers are located, please be aware that transferring information to the country where we operate may involve a different level of data protection.

Financial Incentives/Rewards Programs: If we offer loyalty programs or promotions that entail collecting personal information in exchange for offers, the terms, the categories of information collected, and how that information may be used will be disclosed at enrollment.

19. Contact Information

If you have questions or concerns about this Privacy Policy or our practices, please contact us:

Phone: 646.767.6675

Email: legal@bemodula.com

Hours of operation: 9am–6pm EST