Privacy Policy

May 03, 2024

1. Introduction

Welcome to Modej Group ("Modej Group," "we," "us," or "our"). We specialize in providing services for legacy software systems, including database access, software analysis, reordering, and documentation for our clients ("Clients").

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website www.modejgroup.eu, engage with our services, or otherwise interact with us. Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access our services or website.

2. Information We Collect

We may collect information about you in a variety of ways. The information we may collect includes:

Client Data (Processed on Behalf of Clients)

In the course of providing our services, we may be granted access to our Clients' legacy software systems and databases. This access is solely for the purpose of performing the agreed-upon services, such as analysis, reordering, and documentation. The data within these systems ("Client Data") may include personal information pertaining to our Clients' customers, employees, or other individuals.

• Our Role: When processing Client Data, Modej Group acts as a "data processor" (or equivalent term under applicable data protection laws) on behalf of our Clients, who are the "data controllers."
• Client Responsibility: Our Clients are responsible for ensuring they have the lawful basis to collect, use, and share Client Data with us for the purposes of our services, and for complying with all applicable data protection laws regarding their Client Data.
• Scope of Access: Our access to Client Data is strictly limited to what is necessary to perform the contracted services. We do not use Client Data for our own purposes.

Business Contact Information

We may collect business contact information from our Clients, potential Clients, and business partners, such as:

• Name
• Job title
• Company name
• Email address
• Phone number
• Business address

Website Usage Information

If you visit our website (www.modejgroup.eu), we may collect information automatically, such as:

• IP address
• Browser type
• Operating system
• Access times
• Pages viewed
• Referring Domain

This information is collected through cookies and similar tracking technologies. Please refer to our Cookie Policy (if applicable, a link should be provided here) for more details.

Communication Information

If you contact us via email or other communication channels, we will collect your contact details and the content of your communication.

3. How We Use Your Information

We use the information we collect in the following ways:

To Provide and Manage Our Services

• To perform our contractual obligations to our Clients, including accessing, analyzing, reordering, and documenting their legacy software and databases.
• To provide technical support and respond to Client inquiries.
• To manage our Client relationships.

For Business Operations

• To communicate with Clients and potential Clients about our services.
• For invoicing and payment processing.
• To improve our services and develop new offerings.
• For internal record keeping.

For Marketing (with consent where required)

To send you information about our services, new offerings, or industry insights that we believe may be of interest to you, via our marketing email (marketing@modejgroup.eu). You can opt-out of these communications at any time.

To Comply with Legal Obligations

To comply with applicable laws, regulations, court orders, or other legal processes.

To Protect Our Rights

To protect the rights, property, or safety of Modej Group, our Clients, or others.

4. Disclosure of Your Information

We do not sell your personal information. We may share information we have collected about you in certain situations:

With Our Clients (Regarding Client Data)

As a data processor, we process Client Data according to the instructions of our Clients. Any disclosures of Client Data are made in accordance with our agreements with our Clients.

Service Providers

We may share your information with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work (e.g., IT support, hosting providers, payment processors). These service providers are contractually obligated to protect the confidentiality and security of the information.

Business Transfers

If Modej Group is involved in a merger, acquisition, asset sale, or other business transition, your information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Legal Requirements

We may disclose your information if required to do so by law or in the good faith belief that such action is necessary to: (a) comply with a legal obligation; (b) protect and defend the rights or property of Modej Group; (c) act in urgent circumstances to protect the personal safety of users of our services or the public; or (d) protect against legal liability.

With Your Consent

We may disclose your information for other purposes with your explicit consent.

5. Data Security

We implement appropriate technical and organizational security measures designed to protect the security of any personal information we process, including Client Data. These measures include, but are not limited to:

• Encryption of data where appropriate
• Strict access controls
• Secure software development and review practices
• Regular staff training on data protection and security
• Confidentiality agreements with personnel who have access to sensitive data
• Limiting access to Client Data and other personal information to authorized personnel who need such access to perform their job duties.
• Regularly reviewing our security policies and procedures.

However, please also remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your personal information and Client Data, we cannot guarantee its absolute security.

6. Data Retention

Client Data

We will retain Client Data for as long as instructed by our Client and in accordance with our contractual agreements with them. Upon termination of our services, we will return or securely delete Client Data as per the Client's instructions, unless retention is required by law.

Other Personal Information

We will retain other personal information (such as business contact information) for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law (such as for tax, accounting, or other legal requirements).

7. Your Data Protection Rights

Depending on your location and applicable data protection laws (e.g., GDPR), you may have certain rights regarding your personal information. These rights may include:

• The right to access: You have the right to request copies of your personal information.
• The right to rectification: You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.
• The right to erasure (right to be forgotten): You have the right to request that we erase your personal information, under certain conditions.
• The right to restrict processing: You have the right to request that we restrict the processing of your personal information, under certain conditions.
• The right to object to processing: You have the right to object to our processing of your personal information, under certain conditions.
• The right to data portability: You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
• The right to withdraw consent: If we are processing your personal information based on your consent, you have the right to withdraw your consent at any time.

If you wish to exercise any of these rights, please contact us at info@modejgroup.eu or support@modejgroup.eu.

For Client Data: If your request pertains to Client Data that we process on behalf of one of our Clients, we will direct your request to the relevant Client (the data controller), as they are responsible for handling such requests.

8. International Data Transfers

Your information, including personal data, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction.

If we transfer personal data from the European Economic Area (EEA), UK, or Switzerland to countries outside of these regions, we will ensure that appropriate safeguards are in place to protect your personal data, such as by using Standard Contractual Clauses approved by the European Commission or other legally recognized transfer mechanisms.

9. Children's Privacy

Our services are not directed to individuals under the age of 16 (or a higher age threshold as required by applicable law). We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected personal information from a child, we will take steps to delete such information as soon as possible.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Effective Date" at the top. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

11. Contact Us

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