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Privacy Policy

Introduction

Fibermode Limited (“we”, “us”, “our”) are committed to protecting and respecting your privacy. This Policy sets out the basis on which any personal data we hold about you will be processed.

Please ensure you read the below carefully to understand how we will process your data. If you do not agree with our policies, you can choose not to use our services.

By accessing or using our services, you agree to this Policy. This Policy may change from time-to-time. Your continued use of our Services after we make changes is deemed to be acceptance of those changes, so please check periodically for updates. 

Fibermode Limited will be responsible for the processing of your information, unless otherwise stated, and for the purposes of the Data Protection Legislation, will be the Data Controller.

This Policy (together with our Terms of Service and Modulr Terms of Service, and any additional terms of use incorporated by reference into the aforementioned terms, together are our “Terms of Use”) applies to your use of:

  • Modeapp [version] mobile application software (App) OR hosted on https://www.modeapp.com/ (App Site), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device (Device).
  • Any of the services accessible through the App (‘Services’) that are available on the App Site.
  • Any of the services accessible through other sites of ours (‘Mode Services’) 
  • Mode Services incorporates product and services offered by Mode Group ( Mode Global Holdings PLC is a public limited company incorporated and registered under the laws of England and Wales with company number 12794676. Mode’s subsidiaries are Mode Global Limited, JGOO Limited, Fibere Limited, Greyfoxx Limited and Fibermode Limited.) 
  • This Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. 
  • This App is not intended for individuals under 18 and we do not knowingly collect data relating to children.

Important information and who we are

Fibermode Limited is the controller and is responsible for your personal data (collectively referred to as "Company", "we", "us" or "our" in this Policy).

We have appointed a data protection officer (DPO). If you have any questions about this Policy, please contact them using the details set out below.

Contact details

Our full details are:

  • Full name of legal entity: Fibermode Limited
  • Email address: privacy@modeapp.com 
  • Postal address: Finsgate, 5-7 Cranwood Street, London, EC1V 9EE
Complaint Handling 

Our complaints handling policy can be viewed here. Should you have concerns or a complaint about your data handling, you have the right to make a complaint at any time to the Information Commissioner's Office, which is the UK regulator for data protection issues.

Changes to the privacy Policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated in October 2022. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by email or when you next start the App. The new Policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Mode Services.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you. You can update some of your details in the App or contact us directly on support@modeapp.com 

Third Party Links

Our Sites may, from time to time, contain links to and from the websites of our partners, advertisers and affiliates. Please note that these websites and any services that may be accessible through them, may use cookies, web beacons, and other storage technologies to collect or receive information from our website or elsewhere on the internet to provide measurement services and target ads; they have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. We recommend you check these policies before you submit any personal data to these websites or use these services.

The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows:

  • Identity Data.
  • Contact Data.
  • Financial Data.
  • Transaction Data.
  • Device Data.
  • Content Data.
  • Profile Data.
  • Usage Data.
  • Marketing and Communications Data.
  • Location Data

We explain these categories of data below.

Description of categories of personal data

  • Identity Data: first name, last name, maiden name, username or similar identifier, date of birth, other registration information (including identification documents, such as passport and driving licence), your image in photo or video form (where required as part of Know-Your-Customer (KYC) checks or where you upload a photo to your Mode account).
  • Contact Data: billing address, delivery address, email address and telephone numbers.
  • Financial Data: bank account (including the account number, sort code and IBAN), Blockchain or similiar address, payment card details, monthly transaction spend, primary source of funds.
  • Transaction Data: includes details about payments to and from you, details of in-App and open banking purchases (in-App purchases’).
  • Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, push notification token ID, Device IP addresses, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting.
  • Content Data: includes information stored on your Device, including friends' lists, login information.
  • Profile Data: includes your username, other registration information (including identification documents, such as passport and driving licence), your image in photo or video form (where required as part of Know-Your-Customer (KYC) checks or where you upload a photo to your Mode account), in-App purchase history, your interests, preferences, feedback and survey responses.
  • Usage Data: includes records of our discussions, if you contact us or we contact you; details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
  • Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Location Data: includes your approximate location. We do not collect GPS data.

We do not collect any Special Categories of Personal Data about you, this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).

How is your personal data collected?

We will collect and process the following data about you:

  • Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App and the Mode Services sites (together “Our Sites”), or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App, download or register an App, subscribe to any of our Mode Services, search for an App or Service, make an in-App purchase, share data via an App's social media functions, enter a competition, promotion or survey, buy and sell crypto, send and receive crypto , or earn rewards and when you report a problem with an App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.
  • Information we collect about you and your device. Each time you visit one of Our Sites we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy for further details.
  • Location Data. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.
  • Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
    • Device Data from the following parties analytics providers;advertising networks; and search information providers;
    • Contact, Financial and Transaction Data from providers of technical, payment and delivery services;
    • Identity and Contact Data from data brokers or aggregators, identify verification services;
    • Identity and Contact Data from fraud prevention databases and agencies, criminal convictions and offences may also be shared indirectly by these providers
    • Credit-reference agencies, financial or credit institutions, official registers and databases.
  • Unique application numbers. When you want to install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.

Cookies

We use cookies to distinguish you from other users of the App, App Site, the distribution platform (Appstore) or Mode Services and to remember your preferences. This helps us to provide you with a good experience when you use the App or browse any of Our Sites and also allows us to improve the App and Our Sites. 

For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.

How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

  • Where you have consented before the processing.
  • Where we need to perform a contract we are about to enter or have entered with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

You will find out more here in our as set out in the Glossary section, about the types of lawful basis that we will rely on to process your personal data.

Direct marketing consent 

We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by updating the Notifications sections in the App or by contacting us on privacy@modeapp.com

Purposes for which we will use your personal data

Purpose/activity Type of data Lawful basis for processing
To install the App and register you as a new App user

Identity

Contact

Financial

Device

Your consent
To process in-App transactions, purchases and to deliver Services including managing payments and collecting money owed to us

Identity

Contact

Financial

Transaction

Device

Marketing and Communications

Location

Your consent

Performance of a contract with you

Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you including notifying you of changes to the App or any Services

Identity

Contact

Financial

Profile

Marketing and Communications

Your consent

Performance of a contract with you

Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services)

Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)

To enable you to participate in a prize draw, competition or complete a survey

Identity

Contact

Device

Profile

Marketing and Communications

Your consent

Performance of a contract with you

Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)

To administer and protect our business and this App including troubleshooting, data analysis and system testing

Identity

Contact

Device

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)

To deliver content and advertisements to you

To make recommendations to you about goods or services which may interest you

To measure and analyse the effectiveness of the advertising we serve you

To monitor trends so we can improve the App

Identity

Contact

Device

Content

Profile

Usage

Marketing and Communications

Location

Your Consent

Necessary for our legitimate interests (to develop our products/Services and grow our business)

Disclosures of your personal data

When you consent to providing us with your personal data, you are providing consent to share your personal data with the third parties. We will only share data with third parties in order to provide you with products and services. 

  • Internal Third Parties. Other companies in the Mode Group and who are based in the United Kingdom.
  • External Third Parties. The below provides an example of key external third parties we transfer your personal data with in order to provide you with products and services. Additionally, we will share with other organisations with which you have asked us to share your personal data with.
    • Service providers who provide IT, payment, delivery and system administration service, such as Amazon Web Services (“AWS”) based in the UK, Ireland and the USA.
    • Application and device management and monitoring companies we use to help with troubleshooting and data analysis, for example Datadog, Inc in the USA.
    • Our banking and financial-services partners and payments networks, including Modulr Finance Limited based in the UK.
    • Our customer-service providers, survey and communications service providers that allow us to contact you and vice versa, such as ZenDesk, Inc based in the USA who we utilise for customer support.
    • Fraud-prevention agencies to check your identity, protect against fraud, keep to anti-money laundering laws and confirm you are eligible to use our products and services. There are several used to keep Mode and you safe, such as Onfido Limited, based in the UK.
    • Social media and advertising companies for marketing purposes, for example, Facebook Custom Audiences, USA.
    • Other organisations with which we are required to share information for legal reasons, including, for example:
      • If we have to do so under relevant laws or regulations;
      • In the event of the sale of our business;
      • In connection with criminal or fraud investigations;
      • To enforce our rights (and those of customers or others); or
      • In connection with legal claims.
    • Additionally, we will share with other organisations with which you have asked us to share your personal data with.
  • Specific third parties would be stated specifically where applicable.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

International transfers

We do transfer your personal data outside the UK in order to provide our products and services to you. 

Data security

All information you provide to us is stored on our secure servers. Any payment transactions are encrypted using Secured Sockets Layer technology. 

Where we have given you (or where you have chosen) a passcode that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. 

We will collect and store personal data on your Device on the Device’s secure enclave (such as passcode).

You should never share login details, passcode, password or provide anyone with access to our biometric information. Mode would never ask you for this type of information. It should be known only to you. 

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. Any client-related data is contained within Mode’s VPN (virtual private network). 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

Data retention

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

In the event that you do not use the App for a period of three years then we will treat the account as expired and your personal data may be deleted.

In some events we are required to maintain data for five years but no more than ten years from the end of the business relationship or transaction. 

Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to your personal data.

You have the right to:

  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    1. if you want us to establish the data's accuracy;
    2. where our use of the data is unlawful but you do not want us to erase it;
    3. where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
    4. you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. You can withdraw your consent at any time by emailing privacy@modeapp.com.
  • You also have the right to ask us not to continue to process your personal data for marketing purposes.
  • You can exercise any of these rights at any time by contacting us at privacy@modeapp.com.

Glossary

Lawful basis

Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative)and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

This notice was last reviewed October 2022.