Modular.im Customer Privacy Notice

Please read this document carefully before accessing or using this service!

1. Introduction

1.1 English, Not Legalese

Most Terms of Use and Privacy Policy documents are unreadable. They are written by lawyers and for lawyers, and in our opinion are not very effective.

Data privacy is important, and we want you to understand the issues involved. For that reason we decided to use plain English instead as much as possible, to make our terms as clear as possible. Some sections still have room for improvement - we plan to tackle these over time.

Where you read 'modular.im' or 'Modular', it refers to the service made available at https://modular.im for the purchase, provisioning, configuration, monitoring and management of hosted homeservers and associated services.

Where you read 'homeserver', 'homeservers' or 'the Homeserver', it refers to the services configured within Modular which store User account and personal conversation history, provide additional functionality such as bots and bridges, and (where enabled by the Customer) communicate via the open Matrix decentralised communication protocol with the public Matrix Network.

Where you read New Vector, New Vector Ltd. or we or us, it refers to New Vector Ltd., and its French subsidiary: New Vector SARL and their agents.

New Vector Ltd. is both the Data Controller and the Data Processor for Modular. We can be contacted as per the details below:

Email: [email protected]

Postal address:
10 Queen Street Place
London
United Kingdom
EC4R 1AG

Should you have other questions or concerns about this document, please send us an email at [email protected].

1.2 Scope of This Document

This document explains Data Privacy as it relates to Modular Customers. Modular Customers use Modular to provision and manage hosted homeservers. Apart from where otherwise noted, this document does not address Data Privacy issues relating to the messaging and file data submitted by Users to the hosted homeserver instances.

1.2 The Customer and The User

This document is designed to explain Data Privacy issues relating to a Modular Customer. Put simply, you're a Customer if you're paying (or otherwise compensating) New Vector Ltd to provide a dedicated hosted messaging service. If you have an account registered on a homeserver that you use to send and receive messages, you're a User.

It is possible to be both a Customer and a User, but we encourage you to consider these roles separately when thinking about Data Privacy concerns.

1.3 Changes to This Document

Over time we may make changes to this document. If we make a material change we will provide the Customer with reasonable notice prior to the change. We will set forth the date upon which the changes will become effective; any use of Modular by the Customer, or any use of a hosted homserver by a User will constitute the Customer's acceptance of these changes.

Your access and use of Modular is always subject to the most current version of this document.

2. Access to Your Data / Privacy Policy

New Vector processes your data under Performance of Contract. This means that we process your data only as necessary to meet our contractual obligations to you, or to engage with you to do something before entering into a contract (such as providing a quote).

2.1.2 Data Ownership - Messaging and File data within hosted homeservers

The Customer can use Modular to provision and manage hosted Matrix.org homeservers. The Customer owns and controls all messages and files submitted to their homeserver by User accounts registered natively on their homeserver. This ownership does not extend to messages and files submitted over federation or bridging.

This means that, in addition to the usual data access controls defined by the Matrix protocol, all unencrypted messages and files can be accessed by the Customer, and that access is retained even if no User account within the system retains access to the data.

2.1.3 Right to Erasure

You can request that New Vector forget your personal data by closing your account. For assistance, please contact support on [email protected]

2.1.4 Data Portability

Under GDPR you have a right to request a copy of your data in a commonly-accepted format. If you would like a copy of your data, please send a request to [email protected].

2.1.5 Your Rights as Data Subject

You have rights in relation to the personal data we hold about you. Some of these only apply in certain circumstances. Some of these rights are explored in more detail elsewhere in this document. For completeness, your rights under GDPR are:

  1. The right to be informed

  2. The right of access

  3. The right to rectification

  4. The right to erasure

  5. The right to restrict processing

  6. The right to data portability

  7. The right to object

  8. Rights in relation to automated decision making and profiling.

For more details about these rights, please see the guidance provided by the ICO. If you have any questions or are unsure how to exercise your rights, please contact us at [email protected].

2.2 What Information Do You Collect About Me and Why?

The information we collect is for the purpose of supporting your management of hosted homeservers through Modular. We do not profile homeserver Users or their data, but we might profile metadata pertaining to the configuration and management of hosted homeservers so that we can improve our products and services..

2.2.1 Information you provide to us:

We collect information about you when you input it to Modular.im or otherwise provide it directly to us.

Account and Profile Information

We collect information when you register for an account. This information is kept to a minimum on purpose, and is restricted to:

Your authentication identifier is used to authenticate your access to Modular.im and to uniquely identify you.

Transaction and Billing Information

Paying for hosted homeserver service via Modular is handled entirely by our payment processor, Stripe. The processor stores your credit card information as well as your billing contact information in order to process your monthly or annual automatic renewals, or to allow you to upgrade or downgrade your subscription without re-entering a credit card number.

We never have access to, nor store your full credit card information.

The payment processor code we use also sets a cookie in your browser, to remember your info for future purchases. You can delete or block that cookie if you wish; our website will continue to work.

We require you to enter your billing information. This data, as well as the last four digits of your credit card which is sent to us by our payment processor, is stored in our transaction database in order to maintain our financial records. This information appears on your invoice, which can be accessed by anyone who as been sent the url link to your invoice. We make the invoice links purposefully long and hard to guess for added security, and we prevent search engines from indexing them.

The history of changes to the billing contact information on the invoice made by you or our team are logged and stored in our transaction database.

The data we collect in our transaction database, including Personal Data, is not shared with third parties, except for the purposes of determining the validity of a payment. In this case we may share the name and email address associated with the purchase with the credit card holder, your company's accounting department, or with our payment processor when responding to a chargeback.

2.2.2 Information we collect automatically as you use the service:

Connection Information

We log the IP addresses of everyone who accesses Modular.im. This data is used in order to mitigate abuse, debug operational issues, and monitor traffic patterns. Our logs are kept for not longer than 30 days.

Usage Information

We track fully anonymised usage data for Modular.im. This data helps us to understand how our users are using the application so that we can make improvements.

Our analytics are powered by the Free and Open Source analytics platform Matomo, hosted entirely within our network. We don't share any analytics data with third parties.

2.4 Sharing Data in Compliance with Enforcement Requests and Applicable Laws; Enforcement of Our Rights

In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to

(a) comply with any applicable law, regulation, legal process or governmental request,

(b) protect the security or integrity of our products and services (e.g. for a security audit),

(c) protect New Vector Ltd. and our users from harm or illegal activities, or

(d) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the serious bodily harm of any person.

2.5 How Do You Handle Passwords?

We never store password data in plain text; instead they are stored hashed (with at least 12 rounds of bcrypt, including both a salt and a server-side pepper secret). Passwords sent to the server are encrypted using SSL.

It is your sole responsibility to keep your user name, password and other sensitive information confidential. Actions taken using your credentials shall be deemed to be actions taken by you, with all consequences including service termination, civil and criminal penalties.

If you become aware of any unauthorized use of your account or any other breach of security, you must notify New Vector Ltd. immediately by sending an email to [email protected]. Users should manage good password hygiene (e.g. using a password manager) and change their password if they believe their account is compromised.

If you forget your password (and you have registered an email address) you can use the password reset facility to reset it.

You can manage your account by signing in to Modular at https://modular.im.

We will never change a password for you.

2.6 Our Commitment to Children's Privacy

We never knowingly collect or maintain information in Modular.im from those we know are under 16, and no part of Modular.im is structured to attract anyone under 16. If you are under 16, please do not use the Service.

2.7 How Can I Access or Correct My Information?

You can access all your personally identifiable information that we collect by using the account management interface at https://modular.im. You can download a copy of all your data as per section 2.1.4.

2.8 Who Can See My Homeserver Configuration?

Data stored in Modular.im is accessible by the Customer's account and by New Vector Ltd engineers (employees and contractors) under the conditions outlined below.

2.9 What Are the Guidelines New Vector Follows When Accessing My Data?

2.10 Who Else Has Access to My Data?

We host Modular on Amazon Web Services (AWS). Amazon employees have access to this data. Here's Amazon's privacy policy. Amazon controls physical access to their locations.

We use Cloudflare to mitigate the risk of DDoS attacks. Here's CloudFlare's privacy policy.

Physical access to our offices and locations use typical physical access restrictions.

We use secure private keys when accessing servers via SSH, and protect our AWS console passwords locally with a password management tool.

2.11 What happens if New Vector is sold?

In the event that we sell or buy any business or assets, we may disclose your personal data to the prospective seller or buyer of such business or assets.

If we or substantially all of our assets are acquired by a third party, personal data held by us about our users will be one of the transferred assets.

2.12 How Is My Data Protected from Another User's Data?

All of the Modular.im user data resides within the same dedicated cluster. We use software best practices to guarantee that only the Customer can access it. In other words, we segment User data via software. We do our best and are very confident we're doing a good job at it, but, like every other service that hosts User data on the same database, we cannot guarantee that it is immune to a sophisticated attack.

2.13 What Should I Do If I Find a Security Vulnerability in the Service?

If you have discovered a security concern, please email us at [email protected]. We'll work with you to make sure that we understand the scope of the issue, and that we fully address your concern. Data security isour highest priority, and work to address any issues that arise as quickly as possible.

Please act in good faith towards our users' privacy and data during your disclosure. White hat security researchers are always appreciated.

3. Making a Complaint

We try to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention at [email protected] if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.

If you want to make a complaint about the way we have processed your personal information to the supervisory authority, you can contact the ICO (the statutory body which oversees data protection law) at https://www.ico.org.uk/concerns.

4. Document History