Privacy Policy

Thank you for choosing to be part of our community at Modo Energy! This Privacy Policy describes how we collect, use, share or otherwise process information relating to individuals and the rights associated with that processing.

Modo Energy Ltd and/or its affiliated entities (“Modo Energy”, “we”, “us”, or the “Company”) are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at legal@modo.energy.

When you visit our application and use our services, you trust us with your personal information. We take your privacy very seriously. In this privacy policy, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our application and its associated services. Your continued use of the application and the services shall be taken as your consent to these terms relating to your personal data.

This privacy policy applies to all information collected by us when you: This Privacy Statement applies to the processing of Personal Data collected by us when you:

Visit our websites that display or link to this Privacy Policy;
Visit our branded social media pages;
Visit our offices;
Receive communications from us or otherwise communicate with us, including but not limited to emails, phone calls, texts or faxes;
Use our products and services where we act as a controller of your personal data;
Register for, attend or take part in our events, webinars, programs, trainings, certifications or contests;
Act as or work for a service provider or supplier to Modo, to the extent Modo Energy acts as a controller with respect to your personal data;
Are employed by a customer of our products and services where your information has been shared with us in our capacity as a controller (for example, during the contracting process); or
Participate in surveys, research or other similar data collection facilitated by us.

We refer to the above activities collectively in this privacy policy as the "Services").

Our websites and services may contain links to other websites, applications, platforms and services maintained by third parties. The information practices of these third parties, including the social media platforms that host our branded social media pages, are governed by their privacy statements, which you should review to better understand their privacy practices

In some circumstances, we also collect, or our partners provide us with, publicly available information which may contain personal data that you have published or that has been made available online. The way in which our partners collect this is detailed in their own privacy policies, available on their websites.

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.

What information do we collect?

The personal data we collect directly from you may include identifiers, professional or employment-related information, financial account information, commercial information, and internet activity information, among others. We may collect such information in the following situations:

Situations	Categories of Personal Data
If you express an interest in obtaining additional information about our services; request customer support; use our “Contact Us” or similar features; register to use our websites or to receive communications; sign up for an event, webinar or contest; participate in a program, training, certification or survey; use our products and services; download certain content; or are employed by a customer of our products and services where your information has been shared with us	Contact information, such as your name, job title, company name, address, phone number, email address, username and password, other information you have voluntarily chosen to share
If you attend an event	Attendee badge information which may include name, title, company name, address, country, phone number and email address, image and video
If you register with us for a variety of purposes, including joining a community that we host or participating in a program, training or certification	Username, photo, video or other biographical information, such as your occupation, location, social media profiles or usernames, company name, areas of expertise and interests
If you interact with our websites or emails	Information about your device and your usage of our websites or emails (such as Internet Protocol (IP) addresses or other identifiers), using cookies, web beacons, or similar technologies
If you use and interact with our products and services	Information about your device and your usage of our services through log files and other technologies
If you voluntarily submit certain information to us, such as filling out a survey, responding to a questionnaire or participating in other forms of research	Information you have provided as part of that request, which may include personal data and special categories of personal data, to the extent you voluntarily choose to provide it
If you are a supplier or service provider to Modo Energy (or work for a supplier or service provider)	Contact information, payment and billing information

We also collect information about you from other sources including partners from whom we collect or purchase certain data or who provide us with publicly available information which may contain personal data. We may combine this information with personal data provided by you.

Will your information be shared with anyone?

We only process or share data based on the following legal basis:

Consent: We may process your data if you have given us consent to use your personal information.
Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfil the terms of our contract.
Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

We may share your data 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. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology in the performance of the Services, which will enable them to collect data about how you interact with the Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Marketing

We would like to send you information about additional services that we may offer which may be of interest to you. Where we have your consent or it is in our legitimate interests to do so, we may do this by post, email, telephone, text message (SMS) or automated call.
We will only ask whether you would like us to send you marketing messages when you specifically consent by ticking the relevant boxes when you complete the online registration or where you give your consent by other means.
If you have previously agreed to being contacted in this way, you can unsubscribe at any time using the means provided in each marketing medium (for example, the unsubscribe link at the bottom of any marketing email).

Do we use device and usage data? What about cookies?

We use common information-gathering tools, such as tools for collecting data, cookies, web beacons, pixels, and similar technologies to collect information that may contain personal data as you navigate our websites, our services, or interact with emails we have sent to you.

Device and usage data

As is true of most websites, we gather certain device information when individual users visit our websites. This information may include (i) identifiers, such as user ID, organization ID, username, email address and user type; (ii) commercial information; and (iii) internet activity information such as IP address (or proxy server information), device and application information, identification numbers, location, browser type, Internet service provider or mobile carrier, user interactions such as the pages and files viewed, website and webpage interactions including searches and other actions you take, operating system type and version, system configuration information, date and time stamps associated with your usage and details of which of our products and product versions you are using. This information is used for the purposes set out below.

In addition, we gather certain information automatically as part of your use of our products and services (“Usage Data”). This information may include identifiers, commercial information, and internet activity information such as IP address (or proxy server), mobile device number, device and application identification numbers, location, browser type, Internet service provider or mobile carrier, the pages and files viewed, website and webpage interactions including searches and other actions you take, operating system type and version, system configuration information, date and time stamps associated with your usage and details of which of our products and product versions you are using. This information is used for the purposes set out below. In addition, we may use aggregated Usage Data for other internal business purposes, such as to identify additional customer opportunities and to ensure that we are meeting the demands of our customers and their users.

Cookies and other similar technologies

Cookies are small text files sent by us to your computer or mobile device which enable certain features and functionality. They are unique to your account or your browser.

We use technologies such as web beacons, pixels, tags, and JavaScript, alone or in conjunction with cookies, to gather information about the use of our websites and how people interact with our emails.

When you visit our websites, we, or an authorized third party, may place a cookie on your device that collects information, including personal data, about your online activities over time and across different sites. Cookies allow us to track use, infer browsing preferences, and improve and customize your browsing experience.

We use both session-based and persistent cookies on our websites. Session-based cookies exist only during a single session and disappear from your device when you close your browser or turn off the device. Persistent cookies remain on your device after you close your browser or turn your device off. You can control the use of cookies on your device, but choosing to disable cookies on your device may limit your ability to use some features on our websites and services.

We also use web beacons and pixels on our websites and in emails. For example, we may place a pixel in a marketing email that notifies us when you click on a link in the email.

The following describes how we use different categories of cookies and similar technologies and your options for managing the data collection settings of these technologies:

Type of Cookies	Description	Managing Settings
Required cookies	Required cookies are necessary for basic website functionality. Some examples include: session cookies needed to transmit the website, authentication cookies, and security cookies. If you have chosen to identify yourself to us, we may place on your browser a cookie that allows us to uniquely identify you when you are logged into the websites and to process your online transactions and requests.	Because required cookies are essential to operate the websites, there is no option to opt out of these cookies.
Functional cookies	Functional cookies enhance functions, performance, and services on the website. Some examples include cookies used to analyze site traffic. Functional cookies may also be used to improve how our websites function and to help us provide you with more relevant communications, including marketing communications. These cookies collect information about how our websites are used, including which pages are viewed most often. We may use our own technology or third-party technology to track and analyze usage information to provide enhanced interactions and more relevant communications, and to track the performance of our advertisements.	We need your prior consent to use functional cookies. To learn how to control functional cookies via your individual browser settings, click here.

Purposes for which we process personal data and the legal bases on which we rely

We collect and process your personal data for the following purposes and relying on the following legal bases:

Purpose	Description	Legal basis
Providing our websites (including our social media pages)	We process your Personal Data to operate and administer our websites and to provide you with the content you access and request	Our legitimate interest in providing online content to our customers and prospective customers regarding our service offering and related information
Improving our websites	We process your Personal Data to analyze overall trends and help us improve the user experience on our websites	Our legitimate interest in providing a relevant and well-functioning website for the benefit of our website visitors
Promoting the security of our websites	We process your Personal Data by tracking use of our websites and verifying and investigating activity	Our legitimate interest in promoting the safety and security of our websites and in protecting our rights and the rights of others
Managing event registrations and attendance	We process your Personal Data to plan and host events or webinars for which you have registered or that you attend, including sending related communications to you	Performance of a contract or where we receive your explicit consent
Sending communications	We process your Personal Data to send you marketing information, product recommendations and other non-transactional communications (e.g., marketing newsletters, telemarketing calls, information about our products, news or events) about us, our affiliates and partners	Our legitimate interest in conducting direct marketing or where you have provided your prior consent (please see below to learn how you can control the processing of your Personal Data by us for marketing purposes)
Recording phone calls	We process your Personal Data, including recording phone calls (in accordance with applicable laws) for training, quality assurance, and administration purposes If required under applicable law, we will give you the option to object to a call being recorded	Consent or our legitimate interest in maintaining the high quality of our phone calls with users
Handling contact and user support requests	We process your Personal Data, if you fill out a “Contact Me” web form or request user support, or if you contact us by other means including but not limited to via phone	Necessary for the performance of a contract or our legitimate interest in fulfilling your requests and communicating with you
Providing our services	We process your Personal Data to perform our contract with you for the provision of our services and to satisfy our obligations under the applicable terms of use	Necessary for the performance of a contract or our legitimate interest to provide and administer our services
Developing and optimizing the performance of the services	We process your Personal Data to develop, optimize, and improve the performance of the services	Legitimate interest to develop services and ensure that the services are performing in line with customer expectations
Providing personalized interactions	We process your Personal Data to customize our interactions with you	Legitimate interest to offer the best-in class services to our customers
Managing our customer and user accounts	We process your Personal Data (including Usage Data) to manage customer and user accounts generally, such as billing, customer correspondence and customer relationship management	Necessary for the performance of a contract or our legitimate interest in the management of customer and user accounts
Managing usage and licensing compliance	We process your Personal Data (including Usage Data) to assess and manage usage and licensing compliance with the applicable terms of use of our services	Necessary for the performance of a contract or our legitimate interest in managing the provision of our services to customers
Preparing internal reports and business modeling	We process your Personal Data (including Usage Data) for internal reporting and business modeling purposes (e.g., forecasting, revenue, capacity planning, product strategy)	Our legitimate interest in the management of our business operations
Maintaining our security	We process your Personal Data (including your Usage Data) for the purposes of maintaining Modo Energy’s own security, including investigating, detecting and preventing suspicious activity, fraud and cybercrime that may affect Modo or its services	Our legitimate interest in promoting the safety and security of Modo Energy generally and to protect our rights and the rights of others
Aggregating data	We process your Personal Data (including your Usage Data) for the purposes of aggregating this information to ensure that it is no longer identifying	Our legitimate interest in minimizing the amount of Personal Data processed as part of the noted processing activity
Managing payments	If you have provided financial information to us, we process your Personal Data to verify that information and to collect payments to the extent that doing so is necessary to complete a transaction and perform our contract with you	Necessary for the performance of a contract
Collecting hiring related information	We process your Personal Data (including special categories of Personal Data) to the extent you voluntarily consent to provide it as part of a job application or hiring process	Consent or explicit consent (if required under applicable law)
Collecting diversity information	We process your Personal Data (including special categories of Personal Data) to the extent you voluntarily consent to provide it to meet our broader community goals related to diversity and equality of opportunity	Consent or explicit consent (if required under applicable law)

How do we share your personal data?

We may share your Personal Data as follows:

Service providers: With our contracted service providers, who provide services such as IT and system administration and hosting, credit card processing, research and analytics, marketing, events planning, customer support and data enrichment for the purposes and pursuant to the legal bases described above.

Modo Energy affiliates: With affiliates within the Modo Energy corporate group and companies that we acquire in the future after they are made part of our corporate group, to the extent such sharing of data is necessary to fulfill a request you have submitted via our websites or for customer support, marketing, technical operations, event registration and account management purposes.

Customers with whom you are affiliated: If you use our Services as an authorized user, we may share your personal data with your affiliated customer to the extent this is necessary for verifying accounts and activity, investigating suspicious activity, or enforcing our terms and policies;

Professional advisers: In individual instances, we may share your personal data with professional advisers acting as service providers, processors, or joint controllers - including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services, and to the extent we are legally obliged to share or have a legitimate interest in sharing your personal data;

Third parties involved in a corporate transaction: If we are involved in a merger, reorganization, dissolution or other fundamental corporate change, or sell a website or business unit, or if all or a portion of our business, assets or stock are acquired by a third party. In accordance with applicable laws, we will use reasonable efforts to notify you of any transfer of personal data to an unaffiliated third party; and

Public authorities: With public and government authorities, to the extent we are compelled to disclose personal data to comply with our legal obligations.

Transfer of your information out of the UK and EEA

Your personal data may be collected, transferred to and stored by us in the UK and by our affiliates and third-parties disclosed above, that are based in other countries.
Not all countries outside the UK or the EEA have the same data protection laws as the UK and EEA. While the European Commission has not given a formal decision that countries provide an adequate level of data protection similar to those which apply in the UK and EEA, any transfer of your personal information will be subject to an arrangement designed to help safeguard your rights and give you remedies in the unlikely event of a misuse of your personal information for instance by entering into the appropriate back-to-back agreements and, if required, standard contractual clauses or an alternative mechanism for the transfer of data as approved by the European Commission (Art. 46 GDPR) or other applicable regulators or legislators.

Children

Our websites and services are not directed at children. We do not knowingly collect Personal Data from children under the age of 13. We do not knowingly collect Personal Data for children between 13-18 unless we have obtained consent from a parent or guardian or such collection is subject to a separate agreement with us or the visit by a child is unsolicited or incidental. If you believe we have mistakenly or unintentionally collected Personal Data of a minor without appropriate consent please contact us at legal@modo.energy and we will take steps to delete their Personal Data from our systems.

How long do we keep your information?

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer or shorter retention period is required or permitted by law (such as tax, accounting or other legal requirements).

After expiry of the applicable retention periods, your personal data will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will implement appropriate measures to prevent any further use of such data.

What are your privacy rights?

You may have certain rights relating to your Personal Data, subject to local data protection laws. Depending on the applicable laws these rights may include the right to:

access your personal information;
rectify your personal information, by requesting that we update, block, or delete data if it is incomplete, outdated, incorrect, unlawfully received, or no longer relevant for the purpose of processing;
restrict the use of your personal information;
request that your personal information is erased;
object to the processing of your personal information;
data portability (in certain specific circumstances);
not be subjected to an automated decision; and
to independently remove personal information on your account, make changes and corrections provided that the changes and corrections are accurate and up-to-date.

Where we process your Personal Data for direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection.

Please note that Automated Decision-Making currently does not take place on our websites or in our services.

To exercise your rights, please contact us at legal@modo.energy. If you are resident in the UK or EEA, you have the right to lodge a complaint with the competent supervisory authority. If you work or reside in a country that is a member of the European Union or that is in the EEA, you may find the contact details for your appropriate data protection authority here.

Controls for do-not-track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.

No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

How we secure your personal data

We take appropriate precautions including organizational, technical, and physical measures to help safeguard against accidental or unlawful destruction, loss, alteration, and unauthorized disclosure of, or access to, the personal data we process or use.

While we follow generally accepted standards to protect personal data, no method of storage or transmission is 100% secure. You are solely responsible for protecting your password, limiting access to your devices and signing out of websites after your sessions. If you have any questions about the security of our websites, please contact us legal@modo.energy.

Do we make updates to this policy?

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible.

If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification.

We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

How can you contact us about this policy?

If you have questions or comments about this policy, or wish to review, update or delete your personal information you may email us at legal@modo.energy, or by post to:

Modo Energy Limited

5th Floor, 24 Stephenson Way

London, UK

NW1 2HD