GDPR and Privacy
In May 2018 the EU General Data Protection Regulation (GDPR) replaces the existing patchwork of EU National Data Protection legislation and brings a level of consistency to data and privacy protection in the EU. Even prior to the implementation of GDPR, ModemGuides recognized the worldwide importance of privacy, security, and data protection to our customers, partners, and employees.
We have a cross-functional approach to privacy governance, which covers all areas of the company and includes customer, partner, and employee data. The legal, customer care, IT, HR and Engineering teams meet on a regular basis to help guide, design, and develop products and systems from the ground up to protect data and privacy. ModemGuides has a Board of Directors’ Cybersecurity Committee that is tasked with the oversight and monitoring of ModemGuides’ privacy and data security and regularly engages with outside experts regarding various privacy issues including privacy by design and encryption. ModemGuides has an active cybersecurity program and to make sure information is secure, we strictly enforce privacy safeguards within the company. This means we use access management and access controls commensurate with the risk to data to ensure access to data is associated with a business need, such as providing customers with support.
Specifically, as part of our EU General Data Protection Regulation (GDPR) work, we have assessed, and continue to assess, our major processes, products, and services. In particular, we have:
In addition, all ModemGuides employees are required to take training on Privacy and Security.
Finally, ModemGuides complies with all applicable laws that require notification about data security incidents. That means we conduct prompt investigations and analysis, so that we can provide notification in a timely manner if necessary. We are also committed to providing customers that have been impacted by an incident with appropriate assistance, which may include information about support from ModemGuides or advice on steps customers can take to reduce the risk of harm.
Ad and Cookie Privacy
We use common tracking technologies.
We collect personal information about users over time and across different websites when you use this website, app or service. We also have third parties that collect personal information this way. To do this, we use several common tracking tools. Our vendors may also use these tools. These may include browser cookies. We may also use web beacons and similar technologies.
We use tracking technologies for a variety of reasons.
We use tracking tools, including cookies, on our websites. A cookie is a piece of text that is placed on your computer’s hard drive. Depending on the settings you have selected, your browser adds the text to your device as a small file. Many browsers are set to accept cookies by default. You have the ability to accept or decline cookies as you prefer. The Help portion of your web browser, most likely found on the toolbar, typically tells you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. We use tracking tools:
- To provide information that will allow or improve the functionality of the various services we offer.
- To recognize new or past customers.
- To store your password if you are registered on our sites – for your convenience.
- To better understand the interests of our customers and our website visitors. To help our business partners or other websites engage in these activities.
- To gather statistics on how our websites are used.
- To improve the ModemGuides websites by measuring any errors that occur.
- To allow us to test different designs of our websites.
We collect information about you during the checkout process on our store.
What we collect and store
While you visit our site, we’ll track:
- Products you’ve viewed: we’ll use this to, for example, show you products you’ve recently viewed
- Location, IP address and browser type: we’ll use this for purposes like estimating taxes and shipping
- Shipping address: we’ll ask you to enter this so we can, for instance, estimate shipping before you place an order, and send you the order!
When you purchase from us, we’ll ask you to provide information including your name, billing address, shipping address, email address, phone number, credit card/payment details and optional account information like username and password. We’ll use this information for purposes, such as, to:
- Send you information about your account and order
- Respond to your requests, including refunds and complaints
- Process payments and prevent fraud
- Set up your account for our store
- Comply with any legal obligations we have, such as calculating taxes
- Improve our store offerings
- Send you marketing messages, if you choose to receive them
If you create an account, we will store your name, address, email and phone number, which will be used to populate the checkout for future orders.
We generally store information about you for as long as we need the information for the purposes for which we collect and use it, and we are not legally required to continue to keep it. For example, we will store order information for up to 10 years for tax and accounting purposes. This includes your name, email address and billing and shipping addresses.
We will also store comments or reviews, if you choose to leave them.
Who on our team has access
Members of our team have access to the information you provide us. For example, both Administrators and Shop Managers can access:
- Order information like what was purchased, when it was purchased and where it should be sent, and
- Customer information like your name, email address, and billing and shipping information.
Our team members have access to this information to help fulfill orders, process refunds and support you.
What we share with others
We share information with third parties who help us provide our orders and store services to you; for example —
We accept payments through PayPal. When processing payments, some of your data will be passed to PayPal, including information required to process or support the payment, such as the purchase total and billing information.
We use specific tracking technologies.
Cookies are not the only way to recognize or track visitors to ModemGuides websites. We may also use other, similar technologies from time to time, like web beacons (sometimes called “tracking pixels” or “clear gifs”). These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our websites or opened an e-mail that we have sent them. This allows us, for example, to monitor the traffic patterns of users from one page within our websites to another, to deliver or communicate with cookies, to understand whether you have come to our websites from an online advertisement displayed on a third-party website, to improve site performance, and to measure the success of e-mail marketing campaigns. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their functioning.
We engage in interest-based advertising.
We and our partners display interest-based advertising using information gathered about you over time across multiple websites or other platforms. This might include apps.
Interest-based advertising or “online behavioral advertising” includes ads served to you after you leave our website, encouraging you to return. They also include ads we think are relevant based on your shopping habits or online activities. These ads might be served on websites or on apps. They might also be served in emails. We might serve these ads, or third parties may serve ads. They might be about our products or other companies’ products.
How do we gather relevant information about you for interest-based advertising?
To decide what is relevant to you, we use information you make available to us when you interact with us, our affiliates, and other third parties. We gather this information using the tracking tools described above. For example, we or our partners might look at your purchases or browsing behaviors. We might look at these activities on our platforms or the platforms of others.
We work with third parties who help gather this information. These third parties might link your name or email address to other information they collect. That might include past purchases made offline or online. Or, it might include online usage information.
You can control tracking tools.
Your browser may give you the ability to control cookies. How you do so depends on the type of cookie. Certain browsers can be set to reject browser cookies. To find out more about how to enable, disable, or delete cookies from your web browser, check out the settings panel of your browser.
Our Do Not Track Policy: Some websites have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals. If you block cookies, certain features on our sites may not work. If you block or reject cookies, not all of the tracking described here will stop.
Options you select are browser and device specific.
You can opt-out of online behavioral advertising.
The Self-Regulatory Program for Online Behavioral Advertising program provides consumers with the ability to opt-out of having their online behavior recorded and used for advertising purposes.