Scope of This Policy
This Privacy Policy applies to individuals who interact with ModulON AI, including:
- Visitors to our website
- Users of our services, APIs, plug‑ins, or integrations
- Individuals who contact us through email, forms, chat, or events
- Clients, partners, and prospective business customers
For purposes of this Policy, these interactions are collectively referred to as the “Services”.
This Policy does not apply to data processing activities performed independently by our clients on their own platforms using ModulON AI. Such processing may be governed by separate agreements or the client’s own privacy policies.
Our Role in Data Processing
Depending on the context, ModulON AI may act as either a Data Controller or a Data Processor:
Data Controller
When we determine the purpose and means of processing personal data (e.g., website analytics, account management, support communications).
Data Processor
When we process personal data strictly on behalf of a client under contractual instructions (e.g., AI chat interactions embedded on a client’s platform).
When acting as a Data Processor, responsibility for lawful data collection and consent rests with the client as Data Controller.
Legal Bases for Processing
Where required by law, we process personal data based on one or more of the following:
- Performance of a contract
- Compliance with legal obligations
- Legitimate business interests (e.g., service improvement, security, fraud prevention)
- Your consent, where applicable
We apply data minimization and proportionality principles across all processing activities.
Types of Data We Collect
The categories of data we collect depend on how you interact with ModulON AI whether as a website visitor, platform user, client, or end user interacting with a client’s AI deployment.
We collect only the information reasonably necessary to operate, secure, and improve our services, and to fulfill our contractual and legal obligations.
The types of data may include:
- A. Identifiers
- Name
- Email address
- Phone number
- Account credentials
- IP address
- B. Commercial Information
- Transaction records
- Subscription details
- Service usage logs
Payment information is handled by third‑party payment processors. ModulON AI does not store any payment details.
- C. Device & Technical Data
- Browser type
- Device and operating system information
- Log file
- Session metadata
- D. User‑Generated Content
- Messages submitted through forms or chat
- Support inquiries
- Feedback, surveys, and uploaded content
- E. Client-Provided Data (for AI Configuration & Training)
Clients may upload or connect data sources to configure and improve AI performance within their own environment, including:
- Documents (PDFs, spreadsheets, docs, text files)
- Direct text inputs
- Website or URL content
- Product catalogs or knowledge base data
- Structured datasets
Such data is processed solely to deliver client-requested AI features.
ModulON AI acts as a Data Processor for this information.
- F. Inferences
- Usage patterns
- Interaction behavior
- System performance analytics
- Preferences inferred from engagement
Sensitive Personal Data
ModulON AI does not intentionally request, collect, or require sensitive personal data for the normal operation of its services.
Sensitive personal data may include, but is not limited to:
- Health or medical information
- Biometric or genetic data
- Government-issued identification numbers
- Financial account or payment card details
- Information relating to race, ethnicity, religion, political opinions, or similar protected categories
Users and clients are strongly advised not to submit sensitive personal data through chat interfaces, training uploads, support channels, or any AI-powered feature.
If sensitive personal data is voluntarily provided:
- It may be processed as part of normal system operations (including temporary storage, AI processing, logging, or model interaction).
- ModulON AI does not actively monitor, filter, classify, or segregate sensitive categories in real time.
- We do not guarantee that such data will be excluded from automated processing or AI-related workflows.
- Submission of such data is at the user’s or client’s discretion and risk.
Clients are responsible for implementing appropriate safeguards and obtaining any legally required consent before submitting sensitive personal data into the system.
How We Use Personal Data
We use personal data only where necessary and proportionate to:
- Provide, operate, and maintain our Services
- Deliver AI-powered features and related functionality
- Respond to inquiries, support requests, and communications
- Manage accounts, subscriptions, authentication, and billing
- Improve platform performance, reliability, security, and user experience
- Monitor usage, troubleshoot issues, and maintain system integrity
- Detect, prevent, and investigate abuse, fraud, or unauthorized access
- Comply with applicable legal, regulatory, and contractual obligations
We do not sell personal data.
Where we process personal data on behalf of clients, we do so strictly in accordance with applicable agreements and documented instructions.
Data Sharing & Disclosure
We may share personal data with trusted third parties strictly as necessary to operate and provide our Services, including:
- Infrastructure and cloud hosting providers
- Payment processors
- Analytics, monitoring, and security services
- Professional advisors (legal, accounting, compliance)
- Third-party AI service providers that support response generation or processing
- Government authorities, regulators, or law enforcement where required by law
When third-party AI providers are used:
- Only the minimum necessary information is shared
- Data is transmitted using secure communication channels
- Personal identifiers are minimized or anonymized where technically feasible
- Third-party providers operate independently and are subject to their own privacy policies and terms.
ModulON AI does not control the internal processing practices of third-party providers once data is transmitted to them.
We carefully evaluate external providers prior to integration; however, their handling of data is governed by their own policies.
Data Retention
We retain personal data only for as long as reasonably necessary to:
- Provide and maintain our Services
- Fulfill contractual obligations
- Comply with applicable legal and regulatory requirements
- Resolve disputes and enforce our agreements
- Protect legitimate business and security interests
Retention periods vary depending on the nature of the data, the purpose for which it was collected, and applicable legal requirements.
Where data is no longer required, we take reasonable steps to delete, anonymize, or securely dispose of it.
Data Security
We implement reasonable administrative, technical, and organizational measures designed to protect personal data against unauthorized access, alteration, disclosure, or destruction.
These safeguards are intended to maintain the confidentiality, integrity, and availability of information processed through our Services.
However, no method of transmission over the internet or electronic storage system is completely secure. While we strive to protect personal data, we cannot guarantee absolute security.
Your Rights
Subject to applicable data protection laws (including RA 10173, GDPR, and other regional regulations), you may have the right to:
- Access your personal data
- Request correction or updates
- Request deletion, subject to legal and contractual limitations
- Withdraw consent where processing is based on consent
- Object to or restrict certain processing activities
- File a complaint with a relevant supervisory authority
Requests may be submitted through our official contact channels. We may require reasonable verification of identity before processing such requests.
Where Modulon AI acts as a Data Processor on behalf of a client, data subject requests should be directed to the relevant client organization, which acts as the Data Controller.
Policy Updates
We may update this Privacy Policy from time to time to reflect changes in our practices, 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 our Services after the effective date of an updated Privacy Policy constitutes acknowledgment of the revised terms.
Contact Us
If you have any questions, concerns, or privacy-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.