On This Page
1. Introduction
Modulo ("Company," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website at https://modulo.click (the "Site"), engage our services, or otherwise interact with us.
This Privacy Policy should be read together with our Terms of Service.
By accessing or using our Site or Services, you acknowledge that you have read and understood this Privacy Policy.
2. Information We Collect
2.1 Information You Provide to Us
We collect information that you voluntarily provide when you:
- Submit a contact form: Name, email address, company name, and message content.
- Book a consultation: Name, email address, company information, and details about your project or requirements.
- Subscribe to our newsletter: Email address.
- Enter into a Service Agreement: Business contact details, billing information, company registration details, and information necessary to perform the Services.
- Communicate with us: Any information you include in emails, messages via WhatsApp, or other communications.
2.2 Information Collected Automatically
When you visit our Site, we automatically collect certain information about your device and usage, including:
- Device Information: Browser type and version, operating system, device type, and screen resolution.
- Usage Information: Pages visited, time spent on pages, referring URLs, click patterns, and navigation paths.
- Network Information: IP address, approximate geographic location (city/country level), and internet service provider.
This information is collected through cookies and similar tracking technologies as described in Section 4, and only after you have provided consent for non-essential cookies.
2.3 Information from Third Parties
We may receive information about you from third-party services you use to interact with us, such as LinkedIn or scheduling platforms (such as Cal.com when you book a consultation).
3. How We Use Your Information
We use the information we collect for the following purposes:
| Processing Activity | Purpose | Lawful Basis (UU PDP) |
|---|---|---|
| Providing and delivering Services | Responding to inquiries, processing engagements, delivering contracted services | Performance of a contract (Art. 20(2)(b)) |
| Responding to inquiries | Replying to contact form submissions and messages | Legitimate interest (Art. 20(2)(f)) |
| Marketing communications | Newsletter, AI infrastructure insights | Consent (Art. 20(2)(a)) |
| Website analytics | Understanding usage, improving user experience | Consent (Art. 20(2)(a)) |
| Security and fraud prevention | Detecting abuse, unauthorized access, bot protection | Legitimate interest (Art. 20(2)(f)) |
| Legal compliance | Meeting regulatory requirements, responding to legal process | Legal obligation (Art. 20(2)(d)) |
We do not sell your personal information to third parties.
4. Cookies & Tracking Technologies
4.1 Cookies We Use
Essential Cookies: These cookies are necessary for the Site to function properly. They enable basic features like page navigation and secure access. These cookies do not collect personally identifiable information and cannot be disabled.
Analytics Cookies: We use analytics tools to understand how visitors interact with our Site. These cookies are only activated after you provide consent via our cookie consent banner:
- Google Analytics (GA4): Collects data about page views, user journeys, session duration, and traffic sources. GA4 processes your IP address to determine approximate geographic location but does not store full IP addresses. Data is processed by Google LLC.
- Microsoft Clarity: Records anonymized user interaction data including click patterns, scroll behavior, and session recordings to help us identify usability improvements. Data is processed by Microsoft Corporation.
4.2 Cookie Consent
When you first visit our Site, you will be presented with a cookie consent banner allowing you to accept or decline non-essential cookies. Analytics cookies (Google Analytics and Microsoft Clarity) are only activated after you provide consent. You can withdraw your consent at any time through the cookie settings link available in the footer of our Site. You can also control cookies through your browser settings.
4.3 Do Not Track
Our Site does not currently respond to "Do Not Track" browser signals. However, you can manage tracking through your cookie consent preferences as described above.
5. Third-Party Services
We use the following third-party services that may collect or process your data:
| Service | Purpose | Data Processed |
|---|---|---|
| Google Analytics (GA4) | Website analytics | Anonymized usage data, device info, approximate location |
| Microsoft Clarity | User experience analytics | Anonymized interaction data, session recordings |
| Cloudflare Turnstile | Bot protection / CAPTCHA | IP address, browser characteristics, interaction data |
| Cal.com | Consultation scheduling | Name, email, scheduling preferences |
| Netlify | Website hosting | Server logs, IP addresses |
| WhatsApp (Meta) | Client communication | Messages, contact information, message metadata, device information |
Each third-party service operates under its own privacy policy. We encourage you to review their policies for details on how they handle your data.
6. Data Sharing & Disclosure
We do not sell, rent, or trade your personal information. We may share your information in the following limited circumstances:
- Service Providers: We share data with third-party service providers who assist us in operating our Site and delivering our Services (as listed in Section 5). These providers are contractually obligated to protect your data.
- Legal Requirements: We may disclose your information if required to do so by law, legal process, or government request.
- Business Transfers: If Modulo is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change.
- With Your Consent: We may share your information with third parties when you have given us explicit consent.
7. Data Retention
We retain your personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy:
- Contact form submissions: Retained for 2 years from submission, or for the duration of the business relationship, whichever is longer.
- Service Agreement data: Retained for 7 years following the completion of the Engagement.
- Newsletter subscription data: Retained until you unsubscribe.
- Analytics data: Retained according to the default settings of each platform (typically 14 months for Google Analytics).
- Server logs: Retained for 90 days.
8. Data Security
We implement appropriate technical and organizational measures to protect your personal information, including:
- Encryption of data in transit (TLS/SSL).
- Secure hosting infrastructure.
- Access controls limiting data access to authorized personnel.
- Regular security assessments of our systems.
While we strive to protect your personal information, no method of transmission over the internet or method of electronic storage is 100% secure. We cannot guarantee absolute security.
9. Data Breach Notification
In the event of a personal data breach, we will notify affected data subjects in writing within 3 × 24 hours (72 hours) of becoming aware of the breach, as required by the Indonesian Personal Data Protection Law (Law No. 27 of 2022). The notification will include a description of the breach, the personal data disclosed, and recommended steps to mitigate potential adverse effects. Where required by law, we will also notify the relevant authorities.
10. Your Rights
Under the Indonesian Personal Data Protection Law (Law No. 27 of 2022), you have the following rights regarding your personal information:
- Access: Request information about and a copy of the personal data we hold about you.
- Correction: Request that we correct inaccurate or incomplete personal data.
- Deletion: Request that we delete your personal data, subject to certain legal exceptions and retention obligations.
- Withdraw Consent: Where processing is based on consent, withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.
- Object to Processing: Object to the processing of your personal data in certain circumstances, including processing for direct marketing purposes.
- Restrict Processing: Request that we restrict or suspend the processing of your personal data.
- Data Portability: Request your personal data in a commonly used, machine-readable format for transfer to another controller.
- Complaint: You have the right to file a complaint if you believe our processing of your personal data violates applicable data protection law.
To exercise any of these rights, please contact us at dam@modulo.click. We will respond to your request within 3 × 24 hours of receipt and fulfill the request within 14 days, or within the timeframe required by applicable law.
11. International Data Transfers
Modulo operates globally and uses service providers based in various countries, including the United States. When we transfer personal data outside of Indonesia, we ensure that the receiving country or organization provides an equivalent level of personal data protection as required by the Indonesian Personal Data Protection Law (Law No. 27 of 2022).
Cross-border data transfers are conducted in accordance with the following safeguards:
- Equivalent protection: We verify that the destination country or international organization has an adequate level of personal data protection.
- Contractual safeguards: We use binding contractual agreements with our service providers to ensure appropriate data protection standards are maintained.
- Coordination with authorities: Where required by Indonesian law, we coordinate cross-border transfers with the relevant supervisory authority.
You may request information about the safeguards we use for international data transfers by contacting us at dam@modulo.click.
12. Children's Privacy
Our Site and Services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child, we will take steps to delete such information promptly. If you believe we have inadvertently collected information from a child, please contact us at dam@modulo.click.
13. Changes to This Policy
We may update this Privacy Policy from time to time. When we make material changes, we will:
- Update the "Last Updated" date at the top of this page.
- Post the updated Privacy Policy on our Site.
- Notify registered clients via email if the changes materially affect how we handle their data.
We encourage you to review this Privacy Policy periodically.
14. Contact Information
If you have questions about this Privacy Policy, want to exercise your data rights, or have concerns about how we handle your information, please contact us:
Data Protection Contact
Modulo
Email: dam@modulo.click
Website: modulo.click/contact
You also have the right to lodge a complaint with your local data protection supervisory authority.