AI Features, Data Usage & Consent Policy

Last Updated: February 18, 2025 version 1.0.0A

Our AI systems are designed with privacy, transparency, and responsible governance at their core.

This policy outlines how we ensure to comply with the Data Privacy Act of 2012 and align with global standards including the General Data Protection Regulation(GDPR), the California Consumer Privacy Act(CCPA), and other international privacy frameworks.

We are committed to responsible, transparent, and privacy-first AI.

By using ModulON AI services, integrations, or AI-powered features, you acknowledge and agree to the practices described in this AI Policy.

For information about general personal data handling outside of AI processing, please refer to our Privacy Policy.

If you do not agree, please discontinue use of our services.

Purpose and Scope of AI Features

ModulON AI, its clients, and users are involved in AI interactions as follows:

  • ModulON AI: Provides AI-powered features, processes data received from clients, ensures privacy and security compliance, and maintains safe, isolated model training environments.
  • Clients: Organizations or individuals who integrate ModulON AI into their platforms or workflows. Clients are responsible for collecting user data, obtaining any required consent, and deciding whether anonymized data may be shared for model improvement.
  • Users: Individuals interacting with AI features through client platforms. Their data (messages, feedback, or requests) is sent to ModulON AI by the client. Users may provide consent, via the client, for their anonymized interactions to be used for improving AI models. Without consent, data is used only for real-time AI responses.

ModulON AI provides intelligent automation through:

  • Natural language understanding
  • Automated conversational responses
  • Product and order lookup (when integrated)
  • Workflow assistance
  • Conversation routing
  • Analytics and performance insights

What Data May Be Processed by AI

ModulON AI provides intelligent automation through:

  • A. User-Provided Content
    • Chat messages
    • Questions and support inquiries
    • Feedback and conversational inputs
  • B. Optional Personal Identifiers (Only if enabled and collected with consent)
    • Name
    • Email address
    • Phone number
  • C. Technical Metadata
    • Browser type
    • Device type
    • IP address (IPv4/IPv6)
    • Generated Device fingerprint
    • Session timestamps
  • D. Integration Data (Optional)

    If connected to platforms such as Shopify or Messenger:

    • Product information
    • Order details
    • Checkout links (never payment data)

ModulON AI does not intentionally process or store sensitive personal data, including health information, biometric identifiers, or government-issued IDs.

For your safety and privacy, do refrain from sharing medical details, identification numbers, or any other sensitive information through our platform.

If such information is shared voluntarily, it may be processed temporarily for technical purposes, but ModulON AI does not guarantee that it will be excluded from training or other automated processes.

Users are responsible for avoiding the submission of sensitive data, and ModulON AI cannot be held liable for its handling.

Training Data & Model Improvement

ModulON AI may use anonymized and aggregated interaction data to improve:

  • Response accuracy
  • Language understanding
  • Feature performance
  • System reliability

We Do Not:

  • Use identifiable personal data for global training
  • Store or process payment information
  • Sell your data or share it with third parties for commercial purposes
  • Use chat logs for external AI training without anonymization

We use anonymized data internally for training and AI improvement. Selected messages may also be used immediately to create context for chat responses.

In rare cases, anonymized data may be sent to external AI services as a fallback to ensure timely responses.

Since external services are beyond our control, ModulON AI cannot guarantee how this data is handled once it leaves our system.

Data is used for training only when:

  • It is anonymized
  • It cannot identify a person
  • It is covered by valid consent

User Rights

Under RA 10173, GDPR, and other global laws, users may:

  • Request correction
  • Request deletion
  • Withdraw consent
  • Object to processing

Requests may be submitted through Modulon AI official support channels.

Data Retention

Anonymous Mode

  • Training data is anonymized immediately and retained only for system improvement.

Personal Info Mode

  • Identifiable data is maybe used for training
  • Personal data is retained only for service delivery
  • Deleted within 90 days after account closure or inactivity

Technical Logs

  • Retained for up to 90 days for security and troubleshooting.

Security & Safeguards

ModulON AI takes the protection of user and client data seriously. While some security measures are still being fully implemented, the platform already incorporates several safeguards to ensure responsible and secure AI operations:

  • Encryption in transit and at rest: ModulON AI is designed to encrypt data both while being transmitted and when stored, using industry-standard protocols. Implementation is ongoing to ensure robust protection across all systems.
  • Access controls and audit logs: Access to sensitive data and system functions is restricted to authorized personnel, and all access activities are monitored and logged.
  • Secure development practices:ModulON AI follows secure coding principles, with code reviews and vulnerability assessments being progressively integrated into the development lifecycle.

Third-Party AI Providers

Some AI features may, in specific situations, rely on trusted third-party AI services to support or speed up responses, such as when the primary AI system requires additional processing for context or message generation.

  • Training data: ModulON AI conducts all model training internally. Client and user data is never shared with third-party providers for training purposes.
  • Message processing: To generate timely and contextually accurate responses, we may share relevant information — such as chat context, session history, or necessary user-provided content — with the third-party service.
  • Data minimization: Only the information strictly needed to provide the AI response is shared. Personal identifiers are anonymized wherever possible.
  • Third-party operations: Third-party providers operate independently, and ModulON AI does not control their internal processes. Their use of shared data is subject to their own privacy policies.

ModulON AI carefully selects providers that meet reasonable privacy and security standards and evaluates their use continuously to ensure responsible handling of data.

Use of Client-Provided Data

Client-provided data is processed exclusively to deliver requested AI features and improve performance within the client’s designated environment. To support these functions, clients may upload or connect approved data sources, including:

  • File uploads (PDF, documents, spreadsheets, etc.)
  • Direct text inputs
  • Website or URL scraping
  • Product or catalog data

Purpose of Processing

Client data may be used solely to:

  • Deliver requested AI features
  • Improve responses within that client’s environment
  • Train private, client-scoped models (if enabled)
  • Support workflows and automation specific to the client

Data Isolation & Restrictions

ModulON AI:

  • Does not mix data across clients
  • Does not use one client’s data to train or improve another client’s system
  • Does not use identifiable client data for global model training
  • Does not sell, share, or repurpose client data for unrelated commercial purposes

Client Ownership

All client-provided data remains the exclusive property of the client.

In relation to such data:

  • Clients act as the Data Controller, determining the purpose and lawful basis for processing.
  • ModulON AI acts as the Data Processor, processing data strictly in accordance with client instructions.
  • ModulON AI acts as Data Controller only with respect to system-generated operational metadata (e.g., logs, analytics, platform diagnostics).

ModulON AI does not claim ownership, intellectual property rights, or independent usage rights over client content.

Retention & Deletion (Client Data)

ModulON AI respects client data ownership and privacy. The following outlines our policies for retaining and deleting client data related to AI processing and training.

  • Client data is retained only as long as necessary for the stated purpose.
  • Clients may request deletion at any time.
  • Training datasets are fully removed upon contract termination.
  • Identifiable data is never retained for training without explicit consent.

AI Limitations & Accuracy

AI-generated responses may, in certain cases:

  • Misinterpret user inputs or intent
  • Provide outdated or incomplete information
  • Produce hallucinations (fabricated or inaccurate content)
  • Misrepresent context or the meaning of queries

ModulON AI applies safeguards and quality checks to promote accurate AI responses; however, outputs may sometimes be incomplete, inaccurate, or deviate from intended behavior. Users should verify critical information independently.

Potential for Unintended Outputs

Despite safeguards, AI systems may occasionally generate:

  • Biased, inappropriate, or offensive content
  • Misleading or ambiguous suggestions
  • Incorrect interpretations of inputs
  • Outputs that deviate from intended behavior

ModulON AI applies quality checks and monitoring processes to promote accurate and reliable AI responses. Outputs may occasionally be incomplete, inaccurate, or behave differently than expected. Users should independently verify critical information before taking action.

Client Responsibility

Clients are responsible for:

  • Reviewing AI-generated content
  • Validating outputs
  • Implementing human oversight
  • Ensuring compliance with their own regulations

ModulON AI assists human decision-making — it does not replace it.

Limitation of Liability

To the fullest extent permitted by law:

  • ModulON AI is not liable for damages arising from AI outputs
  • We are not responsible for decisions based on AI responses
  • We do not guarantee error-free results

Clients must ensure compliance within their own operations

Continuous Improvement

We continuously apply:

  • Safety filters
  • Monitoring systems
  • Model tuning
  • Privacy safeguards
  • Secure infrastructure practices

However, no AI system can guarantee absolute accuracy or risk-free operation.

Policy Summary

ModulON AI is designed with the following principles:

  • Privacy by design and default
  • Responsible and transparent AI governance
  • Clear and informed consent mechanisms
  • Strict client data isolation and control
  • Ongoing implementation of security and operational safeguards

Our mission is to deliver safe, transparent, and enterprise-ready AI solutions, while respecting user rights and protecting client data.

AI Transparency Policy Updates

We may update this AI Transparency Policy from time to time to reflect changes in our AI practices, system architecture, legal requirements, or service offerings.

When updates are made, we will revise the “Last Updated” date at the top of this page. Material changes may be communicated through appropriate channels, such as website notices or direct notifications where required by law.

Continued use of ModulON AI Services after the effective date of an updated AI Transparency Policy constitutes acknowledgment of the revised terms.

Contact Us

If you have any questions, concerns, or data-related requests regarding ModulON AI, please reach out to us:

Our team is available to assist with inquiries related to privacy, data protection, and AI usage policies.