Modak Program Privacy Policy

This policy describes how Modak Communities Operating Holdings Inc. (“Modak,” “we,” or “us”) collects, aggregates, stores, safeguards and uses the data and information (including non-public personal information, or “NPI”) about you and your family. It applies to everyone who: visits our websites that link to this Privacy Statement through our website, www.modakmakers.com (the “Site”); uses our mobile applications, financial accounts and cards (collectively, the “App”); uses our platforms - including touch technologies, electronic services, social networking sites, interactive features, online services or any of our described online activities we own or control that link to this Privacy Statement (collectively, our “Platforms”) - or otherwise uses the services we provide (collectively, the “Services”).
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We take your privacy and the security of your information seriously. This policy explains:

• What information we collect, and how we use it
• Choices you can make about the way your information is collected and used
• How we protect personal information electronically and physically.

This policy is incorporated into and a material term of your registration and/or use of Modak’s products and services, including our website, www.modakmakers.com.  By using the Site or Services, you consent to the practices set forth in this Privacy Policy. When the Privacy Policy mentions “Company,” “we,” “us,” or “our,” it refers to Modak, a Delaware C-corp corporation with whom you are contracting in this policy. Modak Communities Operating Holdings Inc. is referred to herein as “Modak” unless the context requires otherwise.
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REGISTRATION
Participants aged below 13
The commencement of the registration procedure on behalf of individuals aged under 13 necessitates action from parents or legal guardians. During the registration process, digital agreement is sought, mandating your assertion as the parent or legal guardian of any individual under 13 whose account you register. This assertion also signifies your agreement with our compilation and utilization of the minor's personal details in alignment with this Privacy Statement. In cases where a registrant under 13 begins the registration procedure without parental or guardian involvement, the session will terminate, and the minor will be informed about the requirement for parental or guardian input to establish an account. During such instances, we abstain from retaining the mobile number, date of birth, or any other personal information of individuals under 13 until a parent or guardian initiates a fresh registration.
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PERSONAL INFORMATION USAGE
Our utilization of personal information serves the subsequent objective for the promotion of our offerings and services, and includes tailored advertising based on interests, involving collaboration with external advertising and social media firms to exhibit promotions for our services and others' across the online realm. Our App refrains from employing third-party advertising technologies that target interest-based advertisements towards children under 13 who are logged into our platform.
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INFORMATION WE COLLECT
‍Information You Provide to Us
Modak collects information from you when you choose to provide it to us through the Site or through any other means. This may include when you create an account on the Site, register or request products or services, request information from us, sign up for newsletters or our email lists, use our Site, or otherwise contact us.The information we collect may include your name, address, email address, telephone or mobile phone number, information relating to your employment or professional activities and financial account information. You may be required to provide certain personal and/or business information to apply for and receive Modak products services.

Information We Automatically Collect
We may use cookies or other technologies to automatically collect certain information when you visit our Site or interact with our emails. For example, if you are responding to an offer, promotional email or other email from us, we may automatically populate your personal information into our system once you enter your offer code or similar identifying device or otherwise accept your offer or promotion. Additionally, we may automatically collect certain non-personal information from you such as your browser type, operating system, software version, and Internet Protocol ("IP") address. We also may collect information about your use of the Site, including the date and time of access, the areas or pages that you visit, the amount of time you spend using the Site, the number of times you return, whether you open, forward, or click-through emails, and other Site usage data.You may adjust your browser or operating system settings to limit this tracking or to decline cookies, but by doing so, you may not be able to use certain features on the Site or take full advantage of all of our offerings. Check the "Help" menu of your browser or operating system to learn how to adjust your tracking settings or cookie preferences. Please note that our system may not respond to Do Not Track requests or headers from some or all browsers.
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HOW WE USE INFORMATION WE COLLECT
Modak uses the data and information you provide in a manner that is consistent with this Privacy Policy and applicable law. If you provide personal data for a certain reason, we may use the personal data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the personal data you provide to answer your question or resolve your problem. Also, if you provide personal data in order to obtain access to the Site or Services, we will use your personal data to provide you with access to such services and to monitor your use of such services.Modak may also use your personal data and other personally non-identifiable information collected through the Site or the provision of the Services to help us improve the content and functionality of the Site or the Services, to better understand our users and to improve the Site and the Services. Modak and its affiliates may use this information to contact you in the future to tell you about services we believe will be of interest to you. If at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below.
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RECORDKEEPING
According to BSA regulations Modak is required to retain either the original, microfilm, copy or other reproduction of the relevant documents. BSA records are required to be retained for at least five years in most cases.All information gathered to support the Customer Onboarding process must be retained for five years after the account is closed.
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‍SHARING OF INFORMATION WE COLLECT
Modak is not in the business of selling your information.  There are, however, certain circumstances in which we may share your personal data with certain third parties without further notice to you, as set forth below:Agents, Consultants, and Third-Party.
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Service Providers:
Modak, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases, and processing payments. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
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Business Transfers:
As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, personal data may be part of the transferred assets.
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Related Companies:
We may also share your personal data with our corporate affiliates and subsidiaries, if any, for purposes consistent with this Privacy Policy.
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Legal Requirements:
Modak may disclose your personal data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Modak, (iii) act in urgent circumstances to protect the personal safety of users of the Site, the Services or the public, or (iv) protect against legal liability.
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WEBSITE AND PROMOTIONS:
Even though we furnish a Service for families, our Website functions solely for promotional intentions and is not targeted at individuals under 13 years old. We consciously abstain from procuring any information from individuals below 13 years old on our Website. If it comes to our attention that we've inadvertently gathered personal information from a child under 13 without the necessary legal consent from a parent or guardian, we will expunge said information.
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LINKS TO OTHER WEBSITES
The Site may have links to third-party websites, which may have privacy policies that differ from our own. We are not responsible for the practices of such sites, nor does any such link imply that Modak endorses or has reviewed the third party site subject to such link. We suggest contacting those sites directly for information on their privacy policies.
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CHILDREN AND MINORS
Modak prioritizes the safety of your children. During the registration process, we ask for your mobile phone number and date of birth, which we use to determine your age and eligibility for the Service. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide personal data without their permission. If you are under the age of 13, please do not submit any personal data through the Services. For children 13 years or older but younger than 18, we request that the child provide a first and last name, an email address and password, and a parent’s mobile phone number so that we can provide the parent with information about the program and to register for an account. If you request that we delete your child’s personal information, we will delete as much information as we are legally permitted. Due to regulatory recordkeeping obligations, we may be required by law to retain some information associated with a closed account.
We are committed to ensuring that Personal Information, as defined by COPPA, is not knowingly collected directly from children under the age of 13. In cases where an individual under the age of 13 is added to an account by the primary account holder (i.e. parent or legal guardian) as an authorized user, the necessary information for this addition will be provided to Modak by the primary account holder. Once the individual is added as an authorized user to the primary account, Modak will exclusively gather and utilize Personal Information pertaining to the authorized user, solely for the purpose of delivering Modak services. Any such information will not be disclosed to third parties for any purposes that are not mandated or allowed by law. If at any time you become aware that your child has shared Personal Information with us without your consent, please promptly notify us by reaching out to us at data_privacy@modakmakers.com
You can also request to discontinue the further collection of personal information of a child by contacting us at the same email address.
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DATA SECURITY
We have taken certain physical, administrative, and technical steps to safeguard the information we collect from and about our customers and Site visitors. While we make reasonable efforts to help ensure the integrity and security of our network and systems, we cannot guarantee our security measures. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any personal data to Modak via the Internet.
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HOW WE KEEP YOUR INFORMATION
We will only retain your information and card data for as long as necessary to fulfill the purpose(s) for which it was collected, provide our products and services, resolve disputes, establish legal defenses, conduct audits, enforce our agreements, and comply with applicable laws. Once your information and card data is no longer necessary for these purposes, we will securely delete it or render it irretrievable.

DELETION OF YOUR INFORMATION
We will securely delete or render irretrievable all your information and card data that is no longer necessary for the purposes for which it was collected.
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BACKUP DATA RETENTION
All backup data will be subject to the same retention and deletion policies as outlined above. Backup data containing card data will only be retained for as long as necessary to fulfill the purpose(s) for which it was collected and comply with applicable laws.

ACCESS TO YOUR PERSONAL INFORMATION
To keep your personal data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct personal information in our possession that you have previously submitted via the Services.

Who Can I Contact at Modak Regarding Data Protection Issues?
Modak has designated a Data Protection Officer to assist with data privacy and data protection issues. You may contact him or her by emailing data_privacy@modakmakers.com and addressing your questions or concerns to the Data Protection Officer. Modak aims to respond to privacy rights requests and inquiries within 7 business days of receipt.

IF YOU HAVE QUESTIONS
If you have any questions about this Privacy Statement or the practices described herein, you may contact us at: hi@modakmakers.com
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CHANGES TO THIS STATEMENT
Modak reserves the right to revise this Privacy Policy at any time. When we do, we will post the change(s) on the Site. This Privacy Policy was last updated on the date indicated above. Your continued use of the Site and the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.
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ANNUAL REVIEW
This policy shall be reviewed and updated at least annually to ensure its continued applicability and effectiveness in addressing current risks, regulatory requirements, and business practices. The review process will be led by [Responsible Department/Officer], who will collaborate with relevant stakeholders to incorporate necessary changes. Any updates or revisions will be documented in the Version Control History section of this policy.