The type of information we collect and store depends on your activity on our website and learning platform. Here is the information we collect at various stages of use of our website and services:
When you visit modalllearning.com, we collect and store the following information (“Visitor Data”):
Visitor Data is tied to your browser via a unique browser cookie identifier (see section on Data Collection Tools below).
If you have provided your email address to us to access or download information, your Visitor Data may be tied to your email address.
Our website may also offer a chat functionality to receive real time support. We may retain any information you provide via the chat feature.
As data controllers, Customers decide which of their personnel are given access to Modal’s platform, which may include their employees, independent contractors, or other individuals. Modal receives and processes their first and last name, professional email address, assigned user ID, and all of their activities on the Modal platform, including their communications with other Learners, coaches and Modal staff, as well as their work product created through or uploaded to the platform. We may also collect information about Learners’ jobs and professional development and career goals.
Modal’s processing of such data is detailed in and governed by a written agreement between Modal and each of its Customers. As a data processor or service provider, Modal will access, store, and use the personal data of Learners solely to provide its services to its Customers or as instructed or authorized by its Customers, except where an individual Learner has instructed Modal to retain such information upon creating a Personal Learner Account.
Learners who use our services through their employer account should contact their employer for assistance with any requests or questions relating to the processing of their personal information by Modal.
If you use Modal services through your employer account, you may wish that all information collected and stored by Modal in connection with your employer account be stored and maintained by Modal so that you can continue your learning journey with another employer, or independently. Modal enables you to create a Personal Learner Account and to have all information collected via your employer account be stored by Modal and tied to your Personal Learner Account. Modal will then become the controller (or business for the purpose of the California Consumer Privacy Act) of all your personal information previously collected.
If you purchase a learning journey or other services directly from Modal, we collect certain data about your purchase (such as your name, billing address, and ZIP code) as necessary to process your order and which may optionally be saved to process future orders. For security, Modal does not collect or store sensitive cardholder data, such as full credit card numbers or card authentication data. You must provide certain payment and billing data directly to our payment service providers, including your name, credit card information, billing address, and ZIP code. We may also receive limited information, like the fact that you have a new card and the last four digits of that card, from payment service providers to facilitate payments.
You Use Social Media Features
Modal may enable you to create an account and log in using sign-in services such as Facebook and LinkedIn. These services will authenticate your identity and provide you the option to share certain personal information from your Facebook or LinkedIn account with us. If you log in using your Facebook or LinkedIn profile, we may receive information like your name, profile picture, age range, language, email address, and friend / connections list. All such information is then added to your account information.
Social media features that we may implement on our website or within our platform (like the Facebook “Like” or “Share” button) may allow the social media providers to collect your IP address and the URL of the page you are on when you use the feature via their own tracking tools. The sharing features may also set a social media service cookie to your browser (see section on Data Collection Tools below).
By performing certain actions on our website or using some of our functionalities or features, you may be eligible or invited to participate in a contest or in a drawing for a prize. The full terms and conditions of any such challenge, contest or sweepstakes (“Promotion”) will be set forth where the opportunity to enter the Promotion is offered. To administer a Promotion and fulfill prizes to the winners, we may collect additional information about you when you enter the promotion, or once you have become eligible for receiving a prize, such as your postal address. We may also share such information with our prize fulfillment vendors.
This Notice of Financial Incentive applies to sweepstakes and other giveaways offered by Modal. We treat the value of personal information collected through Promotions as the equivalent of relevant expenses related to the collection and retention of such personal information. The prize and cash incentive we offer to participants of Promotions reasonably relate to the value of the additional personal information collected.
You may submit professional and education information about you when you submit a job application to us for working at Modal. We do not combine this information with any data we otherwise collect through our website or our learning platform, and keep it in a separate database. This is used only to respond to your job application and to retain your information to contact you in case a future job opening corresponds to your qualifications. Modal’s internal job application system is powered by Greenhouse and so your application information is hosted and stored by Greenhouse on our behalf.
The Modal learning platform may contain links to third party websites and services. These links are provided only for your convenience and you are free to use them. We do not control these third parties or their websites, and any data collected by these third parties via their websites is governed by their respective privacy policies.
When your employer creates an account for you, they provide to us your login credentials and you then complete your account information and provide additional information directly to us. If you create a Personal Learner Account, you provide to us your account data and other professional information.
Modal and service providers acting on our behalf (like Google Analytics, vendors who power our chat or text message features, and advertising companies we hire to promote our services) use data collection tools like cookies, web beacons, tags, scripts, customized links, device or browser fingerprints and similar tracking technologies (together, “Data Collection Tools“) to gather data when you use our website, platform, and services. These Data Collection Tools automatically track and collect Visitor Data when you use our website.
Cookies are small text files stored by your browser, to collect, store, and share data about your activities across websites, including on Modallearning.com. Cookies can remain on your computer or mobile device for different periods of time. Some cookies are 'session cookies', meaning that they exist only while your browser is open. These are deleted automatically once you close your browser. Other cookies are 'permanent cookies', meaning that they survive after your browser is closed. They can be used by websites and advertising services to recognize you when you open your browser and browse the Internet again. Cookies can be “first party”, meaning they are served directly by us to your browser or mobile device, or “third party”, meaning they are served by either one of our vendors to provide their services to us, or by an advertising partner when we promote our services.
Modal may use third party public sources to obtain information about your professional status, such as LinkedIn, either to market our services to you or to customize your learning experience.
We collect and process your personal information for the purposes detailed below. Where required by law, we obtain your consent to use and process your personal information. Otherwise, we rely on another authorized legal basis including but not limited to the performance of our contracts with our Customers or our legitimate interest to collect and process your personal information to operate and secure our site and platform and to market and promote our services.
Making our website and platform function: We use personal information to facilitate our website, platform, and services’ technical functioning, including recognizing you across your various mobile and desktop devices, troubleshooting and resolving issues. We use Visitor Data to identify new and returning visitors and their website access preferences.
Providing our services: We use personal information to provide and administer our learning portal and associated services to our Customers and to Learners.
Personal information enables us to personalize Customer and Learner experience (for instance, to recognize a user by name when they return to our site, to present content in the language of the user’s browser, or to promote an event in their time zone).
Personal information also enables us to communicate with Customers, Learners and coaches by onsite messaging, push notification, support chat, email, text messages or telephone, to provide updates about the status of learning journeys, respond to questions, and send administrative messages and information about our service (such as messages about your account or notifications about changes to our services and updates to our terms of services or other applicable terms). We may also send you messages on behalf of coaches and other Learners. We may also solicit your feedback via surveys and send you messages about new features, content or services, rewards programs, newsletters, or upcoming events.
Promoting our services to new customers and identifying customer opportunities: We promote our learning platform and services on third-party websites and applications. We use personal information to assess new potential customer opportunities and to conduct market research. When you visit our website and view the content offered on our website, we may use your Visitor Data to determine your interests in our products and services and instruct our advertising service providers to deliver advertisements to you based on your inferred interests in our products and services. We may assign an activity score to determine your level of interest for certain Modal products or services, which informs our direct marketing activities. Our advertising partners may use Visitor Data to target our advertisements to you when you are visiting third party sites. If we use third party cookies to perform these activities, we obtain your prior consent in countries where it is required (see section on Data Collection Tools above).
When you provide us with your email address (to access or download information on our site, to register for a promotional event or if you leave a business card with us at an event, or if we scan your badge at a professional conference), we may use the information we received from you to send you promotional messages about our products and services.
To improve our services: We use aggregated data from our visitors and Learners to analyze what content is consumed, what learning activities are performed, and other aggregated site usage data. This helps us determine trends and informs how we can improve our services, and develop new products, services, and features, and improve our site design and usability.
For safety and compliance: We use personal data to secure our website and platform, prevent fraud and abuse, ensure the safety of our visitors, Customers, Learners, employees, third parties, the public, or as otherwise required for us to comply with any applicable laws.
Managing payments: If you pay for certain services we retain your name, email and the transaction information to the extent necessary to complete a transaction and perform our contract with you. We do not collect or store any credit card information and use a secure payment processing service to process any credit card payment.
How long we retain your personal data depends on the nature of the data and the purpose for which we use the data.
We do not sell, rent, nor loan your personal information to anybody. We however share information under certain circumstances with specific third-parties as detailed below.
Modal shares Learner personal information with coaches so they can interact with Learners to provide the services.
We also share user data with third-party companies who perform services on our behalf, like payment processing, hosting, fraud and abuse prevention, data analysis, push notification, chat, email and text messaging services, as well as advertising services, including for the creation of email target lists for various promotional messages, the dispatch of promotional and informational messages, analysis of actions you take upon receiving messages, retargeting visitors who showed interest in our services, and the management of unsubscribe requests and our email sunset policy. We also use vendors to administer surveys who may receive or collect certain information about you if you participate in a survey. We also use vendors to manage our CRM and marketing databases that include prospect and customer contact information as well as details of communications with them. CRM data is hosted in databases controlled by us and hosted by our vendor. These service providers may access and use your personal data solely as we direct, to provide our requested service.
We may disclose your data to third parties if we (in our sole discretion) have a good faith belief that the disclosure is:
If Modal is part of a business transaction like a merger, acquisition, corporate divestiture, or dissolution (including bankruptcy), or a sale of all or some of its assets, we may share, disclose, or transfer all of your data to the acquiring or successor organization (including prior to the transaction for due diligence purposes).
Personal data is also processed in the United States by our service providers. We executed with our service provider Standard Contractual Clauses adopted by the European Commission and the UK data protection agency to facilitate transfers of personal data from the EEA and UK to the United States. Under these clauses, our service providers are restricted and regulated in their processing of your data. By submitting your data or using our services, you consent to this transfer, storage, and processing by Modal and its processors.
Modal takes appropriate security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal information. We have different security measures based on the type and sensitivity of the personal data we collect and store. Unfortunately, no system can be 100% secured, and we cannot guarantee that all data we store and all communications between you and others via the Modal platform will never be accessed by an unauthorized person.
The login credentials of your account, specifically your account password, is an important part of our security system, and it is your responsibility to protect it. You should not share your password with anyone, and if you believe your password or account has been compromised, you should change it immediately and contact us at email@example.com to let us know.
You have rights and choices regarding our collection and use of your personal information, as well as the collection and use of some of our third party partners. These are detailed below.
If you no longer wish to receive promotional emails from us, you may opt out by following the unsubscribe link or instructions provided at the bottom of any email we send. You may also contact us at firstname.lastname@example.org to make an email unsubscribe request. After we receive your request, please allow up to ten business days for us to complete your request, during which you may still receive some emails from us.
Please note that third party advertisers that maintain their own mailing lists may send communications that advertise our products or services; and you may need to contact those parties directly in order to stop receiving their email communications.
You may receive text messages from us or third parties as part of our services to Learners, if you agree to receive these text messages. You may however opt-out of receiving certain text messages by texting "STOP" in response to a message. If you need any assistance, text "HELP" in response to the message. You may also contact us at email@example.com to update the communication preference settings of your account.
If you are accessing our services through an employer Learner account you should request the termination of your account via your employer who has a contract with Modal.
If you are located in the European Economic Area, you may opt out of certainData Collection Tools by clicking the “Cookie settings“ link at the bottom of any page.
You can opt-out of third-party advertising targeting Data Collection Tools to prevent our advertising partners to track you to deliver targeted interest based ads to you on third party websites through these (and other) resources:
You may opt out of tracking and receiving tailored advertisements on your mobile device by some mobile advertising companies and other similar entities by downloading the App Choices app at https://youradchoices.com/appchoices. In addition, third party tools enable you to search for and opt-out of some of these devices, such as the Ghostery browser plug-in available at https://www.ghostery.com/.
Do Not Track (DNT) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. However, we do not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT.
Users who are California residents have certain rights under the California Consumer Privacy Act, (“CCPA”):
To exercise any of these rights under CCPA, contact us at firstname.lastname@example.org or write to us at 436 Bryant Street, 2nd Floor, San Francisco, CA 94107. CCPA allows you to designate an authorized agent to make these requests on your behalf. For your protection, we may require that the request be sent through the email address associated with your account, and we may need to verify your and/or your agent’s identity before fulfilling your request.
As a California resident, you also have the right to request certain details about what personal information we share with third parties for those third parties’ direct marketing purposes. To submit your request, contact us at email@example.com or write to us at 436 Bryant Street, 2nd Floor, San Francisco, CA 94107 with the phrase “California Shine the Light” and include your mailing address, state of residence (California), and email address.
Modal does not sell its users’ personal information or personal data as selling is defined by Nevada law. Nonetheless, Nevada residents have the right to submit a request that we do not sell your covered personal information, which you can do by contact us at firstname.lastname@example.org or write to us at 436 Bryant Street, 2nd Floor, San Francisco, CA 94107.
If you If you are located in the European Economic Area or the UK, you also have additional rights:
To exercise any of these rights, contact us at email@example.com or write to us at 436 Bryant Street, 2nd Floor, San Francisco, CA 94107. For your protection, we may require that the request be sent through the email address associated with your account, and we may need to verify your identity before fulfilling your request.
You also have the right to lodge a complaint about our data processing with your supervisory authority.
If you are an Australia resident and you have a complaint, you may refer it to the office of the Australian Information Commissioner (“OAIC”). You can contact OAIC by visiting www.oaic.gov.au; forwarding an email to firstname.lastname@example.org; telephoning 1300 363 992; or writing to OAIC at GPO Box 5218, Sydney NSW 2001. You may contact us at email@example.com to make a complaint about a breach of the Australian Privacy Principles which will be responded to within 30 days.