Last updated: 06/08/2020
Modjoul Inc. is a data innovation company whose primary purpose is to keep employees safe and employers informed of risk in their operations. At Modjoul, we combine wearable technology with AI and software in order to understand ergonomic and safety risks along with employee wellness. We are committed to being transparent about our data processing activities and to protecting all personal data (“information” or “data”) that is entrusted to us those who use our Services (“you”).
2. WHAT DATA WE COLLECT
We may collect your information both online (for example, through your use of our websites and products) and offline (for example at events or over the phone) and we may combine, and make inferences about you, based on information collected from disparate sources. Most of the information we collect or maintain about you is provided directly by you to us. Such information typically includes personal identifiers, commercial information, protected classification information, professional or educational information and any other information you choose to directly provide to us.
If you do not want to provide us with your information you may decide at any time not to visit our Sites, install our Apps, or provide information to us directly. However, if you choose not to provide us with certain information, we may not be able to provide certain Services to you.
a. Data we collect when you express interest in or start our Services
When you express an interest in obtaining additional information about the Services we provide or by registering to use our Services, we collect personal identifiers about you such as your name, company name, designation, address, phone number, and email address.
When purchasing the Services, we may require you to provide us with additional personal identifiers and commercial information such as: financial qualifications, billing information such as billing name and address, credit card number, bank account, shipping address and any other information reasonably necessary to process your request.
When you purchase our Services, we do not view or store your bank account or credit card information. This is handled by our third-party payment processor. We store your shipping address so we can process your order through our fulfillment partner.
b. Data we collect when you create a Modjoul account
To create your personalized reports, we may ask you to provide us with personal identifiers and, as applicable, protected classification information and biometric information. For example, you will be asked to provide your name, gender, age, height, weight, nature of duties performed and your Employee ID. This information will be associated with data generated by the Devices.
c. Data we collect via the Modjoul Devices
The Modjoul Devices collect a variety of metrics about you, which may include assorted personal identifiers, biometric and geolocation data. The exact data that is collected is dependent upon the Device in question and the specific Device metrics that your Organization has decided to collect. For example, the sensors in Modjoul SmartBelt may collect information such as location, motion, speed, altitude, ambient temperature-pressure, humidity and other environmental variables. For more information about the exact data that your Device collects, please log on to your Modjoul dashboard or the Modjoul App or contact your Organization.
The Device may also transmit device usage data including, but not limited to, frequency, duration and time when the device is worn, removed, or charged.
d. Data we collect when you sync your mobile device with the App
When your Device connects or syncs with our Apps or software, data recorded on your Device is transferred from your Device to our servers. When you sync or connect your mobile device using our App with our Devices, we collect sensor data and electronic network activity information including information necessary to associate your account to the Device ID of the Modjoul Device and connect the Device to the internet.
e. Data we collect when you visit our Sites
f. Data we collect when you contact us
g. Data we collect from third-party sources
We may also collect your personal identifiers, professional or employment-related information and internet or other electronic network activity information from third-party sources in connection with conferences, professional databases, meetings, and seminars, chat rooms, blog posts, newsgroups, or social networking sites. The information we access from social networking sites will be limited by the privacy settings you establish at such sites. We may also collect information about you from your friends or associates who tell us you may be interested in our Services.
h. Data we collect in connection with our promotional and marketing efforts
3. HOW WE USE DATA
a. To provide and maintain our Services:
In most cases, we will only use your information in order to provide you with, and maintain, our Services, including:
b. Marketing Purposes:
Where permitted by applicable law, and with your prior consent where required by applicable law, we may use your information for marketing purposes and to provide you with promotional communications about our products and services. Your contact information is used to send you these notifications about new features or products we think you would be interested in.
You can always unsubscribe from further marketing at any time either by selecting the "unsubscribe" link at the end of the marketing and promotional update communications to you, or by submitting your request to firstname.lastname@example.org. Please keep in mind that if you unsubscribe from our marketing communications, we may still contact you for other legitimate reasons (e.g. in relation to an order you placed, an inquiry you made, an event for which you registered, a legally required notice, etc.).
c. Other Business Purposes:
We may also use the information we collect to improve and protect our Services. In particular, data and logs are used in research to understand and improve our services, to troubleshoot our services, to detect and protect against error, fraud or other criminal activity, and to enforce our Terms of Service. In some cases, aggregated and anonymized data that does not identify you may be used to inform health, insurance, and risk management communities about trends, for marketing and promotional purposes, and for sale to interested audiences.
d. European Privacy Notifications:
4. WHAT KIND OF DATA WE SHARE
a. Data that you or your Organization directs us to share
Each Organization has its own unique practices regarding how your information is shared and your level of control over how your information may be shared. If you would like to learn more about how your data is shared, please contact your Organization’s human resources department.
b. Data we share in our course of business:
We may share your information in the furtherance of our business, including under the following circumstances:
5. HOW LONG WE SAVE YOUR DATA
It is up to your Organization to determine how long we retain your information that we collect on behalf of your Organization. As a general practice, we delete such information (including all biometric information, if applicable) from our systems within sixty (60) days from the initial collection of that information. We may retain your usage data and other analytics data collected from your use of the Modjoul App or Devices for a longer period, as requested by your Organization. Please note, however, that your Organization may choose to download and retain copies of your information on their own systems for a longer period of time.
Where we collect information about you on our own behalf (ie outside of our relationship with your Organization), we will only retain your information as long as reasonably required for the purposes for which your data was collected or provided by you, unless a longer retention period is required or permitted by law (for example, for regulatory purposes).
6. YOUR CONTROL OVER YOUR DATA
Depending on your location and home jurisdiction, you may have additional rights, including rights under the California Consumer Privacy Act of 2018 (“CCPA”) or the GDPR, regarding how we use and share your information. Such rights may include:
To obtain more information about exercising your rights, including how to designate an authorized agent to make a data request for you, please send an email to email@example.com.
Please be advised that upon the receipt of your request, we may ask you to provide additional information so that we can verify your identity and process your request. We may, in limited circumstances, refuse to comply with your request or charge you a reasonable fee if your requests are clearly unfounded or excessive. In all cases, we will notify you of any fee in advance. Finally, we may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
7. HOW WE KEEP YOUR DATA SAFE
We have implemented reasonable measures to help protect your data against loss, misuse, and unauthorized access, disclosure, alteration, or destruction. All of our employees and contractors are required to follow these security procedures, both online and offline. Access to personal data is limited to those employees or contractors who have a need to access the information to perform tasks for us. We will only disclose data to those service providers, auditors, and/or advisors who are legally or contractually obligated to protect them or as required or permitted by law. Such measures may include physical access controls, encryption, internet firewalls, intrusion detection and network monitoring depending on the nature of the information and the scope of processing.
Depending on your Organization, alternate or additional security measures may apply. If you have a security-related concern, please contact your immediate supervisor.
8. TRANSFER OF YOUR INFORMATION TO OTHER COUNTRIES
Where authorized by your Organization, we will transfer personal data pertaining to individuals located outside of the United States to our affiliates and suppliers in the United States and elsewhere in the world, pursuant to applicable data protection laws.
Cookies are text files that are sent by servers to web browsers and stored on your computer. Cookies are not used to run programs or deliver viruses to your computer. The purpose of a cookie is to tell the web server that you have returned to a specific page. For example, if you submit a form on our Site, a cookie helps us to recall your specific information on subsequent visits. When you return to the same Site, the information you previously provided can be retrieved, so you can easily use the customized features.
You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can modify your browser setting to decline cookies if you prefer.
In addition to cookies, we may collect data from web beacons. Web beacons and pixel tags are images embedded in a Site or email for the purpose of measuring and analyzing usage and activity. We, or other third-party services acting on our behalf, may use web beacons and pixel tags to help us analyze usage and improve our functionality.
10. DEACTIVATING YOUR ACCOUNT
Please contact firstname.lastname@example.org or (864) 722-9760 to start the process of deactivating your account.
11. CHILDREN’S ONLINE INFORMATION POLICY
We understand the importance of protecting children’s privacy, particularly with their online interactions. The Services are not intended for nor directed at persons under the age of 13. We do not knowingly collect any data from children under the age of 13.
12. CONTACTING US
If you have a question about how your information is collected or otherwise used on behalf of your Organization, please reach out to your Organization for more information.