Privacy Policy

1. Our Role and Data Processing

Modassembly builds custom AI Agents for businesses and acts in two capacities depending on the type of data involved:

• As a controller: For data we collect directly from website visitors, prospective clients, account administrators, and billing contacts (e.g., contact details, website analytics, payment information), Modassembly is the data controller responsible for processing as described in this Privacy Policy.
• As a processor / service provider: For data processed by the client's AI Agents (including message content, end-user interactions, conversation logs, and platform-specific data such as WhatsApp Business Solution Data), Modassembly acts as a processor on the client's behalf. We process this data only on the client's documented instructions and not for our own independent purposes.

As between Modassembly and the client, data processed by the client's AI Agents remains the client's data, subject to applicable law and the terms of third-party platforms and providers (including the WhatsApp Business Solution Terms where applicable).

2. Information We Collect

We collect information you provide directly to us during the build process and throughout your service, such as:

• Contact information (name, email address, phone number)
• Requirements for the AI Agents you want built (AI Admin and AI Employees) and your business needs
• Integration specifications and requests for tools and systems you want your AI Agents to use
• Access credentials to your tools, databases, or third-party services (with your explicit consent)
• API keys and configuration details for integrations (CRMs, calendars, databases, payment systems, email services, messaging platforms, etc.)
• Communications between you and Modassembly inside the build group (a WhatsApp, SMS, Telegram, Slack or Teams group with one of Modassembly's human engineers) and any ongoing support channels
• Payment information (processed through secure third-party payment processors)
• Operating data from your deployed AI Agents (conversation logs, performance metrics)

We also automatically collect certain information about your device and how you interact with our website, including:

• Usage data (pages visited, time spent, referring/exit pages)
• Device information (IP address, browser type, operating system)
• Cookies and similar tracking technologies
• Google Analytics data to improve our website performance

3. How We Use Your Information

We use the information we collect to:

• Design and build custom AI Agents (AI Admin and AI Employees) tailored to your business workflows
• Conduct the build process with you in your build group, including requirements gathering, architecture and configuration
• Connect your AI Agents to your existing tools and systems (CRMs, calendars, databases, payment systems, email services, messaging platforms, APIs, etc.)
• Implement requested integrations that are not yet available in our standard offerings
• Host and operate your AI Agents on secure infrastructure on your behalf
• Enable deployment to WhatsApp, SMS, email, Slack, Teams, Telegram and your website
• Communicate with you about build progress, testing, and support
• Process payments and manage subscriptions
• Monitor AI credit usage and agent performance
• Provide ongoing technical support and troubleshooting
• Understand how visitors interact with our website (using aggregated website analytics only, not data processed by your AI Agents)
• Improve our platform and develop new integration options (using aggregated, de-identified website and account data only; we do not use data processed by your AI Agents for this purpose)
• Protect against fraudulent or unauthorized activities
• Comply with legal obligations

We do not train AI Models on your data. Modassembly does not use Business Solution Data, or any other data processed by your AI Agents (including any anonymous, aggregate, or derived forms of that data), to create, develop, train, or improve any machine learning or artificial intelligence systems, models, or technologies, including large language models. Any fine-tuning, if performed, is for your exclusive use and is not used to train or improve any other AI Model.

4. Information Sharing and Sub-processors

We do not sell, rent, or trade your personal information to third parties. We do not use data processed by your AI Agents for our own independent purposes. We may share your information in the following circumstances:

• With sub-processors necessary to operate your AI Agents and integrations (only the minimum required data)
• To comply with legal obligations or court orders
• To protect the rights and safety of Modassembly and our users
• With your explicit consent or at your direction
• In connection with a business transfer or acquisition (with appropriate notice)

Sub-processors: To operate your AI Agents, Modassembly engages a limited set of sub-processors, including:

• Anthropic, PBC: provider of the Claude large language models that power your AI Agents
• Cloud hosting and infrastructure providers used to host the agents and supporting services
• Payment processors used to process subscription payments
• Communication-channel providers required for deployment (e.g., WhatsApp Business Solution Providers, SMS aggregators) as configured for your account

Each sub-processor is engaged solely to provide services to Modassembly that support your AI Agents, and is bound by contractual confidentiality and data-protection obligations. A current list of sub-processors is available on request.

5. Data Security

We implement industry-standard technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. This includes:

• Secure access controls and authentication protocols
• Regular security audits and updates
• Limited access to sensitive information on a need-to-know basis
• Secure development and operations practices for all AI Agent work

However, no method of transmission over the Internet or electronic storage is 100% secure, so we cannot guarantee absolute security.

6. Tool and Service Access

When you provide us access to your tools, APIs, databases, or third-party service accounts during the onboarding and custom integration process:

• We access only what is necessary to complete the agreed-upon automation development and integration work
• We maintain strict confidentiality of your data, custom integrations, and business logic
• We use secure, time-limited access tokens and credentials whenever possible
• We implement requested integrations securely, even if they are not part of our standard offerings
• It is your responsibility to revoke our access if you terminate your subscription
• We never use your proprietary data, custom integrations, or configurations in other clients' projects
• All team members (staff+ software engineers with 10+ years experience) sign confidentiality agreements
• We deploy and host your automation solution on secure infrastructure with appropriate access controls

7. Deployment Channel Accounts and Data

For clients deploying automation solutions on any channel (WhatsApp, website, email, Slack, etc.):

• Each client provides their own platform accounts and credentials (e.g., WhatsApp Business Account and phone number, Slack workspace, email accounts); Modassembly does not provide or share platform accounts across clients
• As between Modassembly and the client, all data associated with your deployment channels (including message history, contact lists, and business profile information) remains your data, subject to applicable law and the respective platform's terms
• We process deployment channel data solely on your behalf and under your instructions
• If you request to transfer your accounts to another provider, we will assist with the transfer of control and related data within 30 days
• We do not aggregate or use your deployment data across clients or for our own purposes

8. Data Retention

We retain your information only as long as necessary to provide our services and fulfill the purposes outlined in this policy:

• Custom integrations and configurations: Owned by you; Modassembly retains a copy for maintenance and operational purposes
• Deployed solution data: Hosted on our infrastructure during active subscription
• Conversation logs and usage data: Retained for performance monitoring and support purposes during active subscription
• Your proprietary business data: Your data remains yours; we only access it as needed to operate your automation solution on your behalf
• Message credit usage records: Retained for billing purposes
• Contact information: Retained for ongoing client relationship management
• Payment records: Retained as required by law and accounting practices
• Access credentials: It is your responsibility to revoke or change access credentials if you terminate your subscription
• Communication records: Retained for customer support and legal compliance

9. Your Rights

Depending on your location, you may have certain rights regarding your personal information, including:

• Correcting inaccurate information
• Requesting deletion of your information
• Restricting or objecting to certain processing activities
• Withdrawing consent
• Requesting information about data breaches
• Requesting transfer of your deployment channel accounts and related data to another provider

To exercise these rights, please contact us using the information provided below. We will respond to your request within the timeframe required by applicable law.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will notify you of any material changes by posting the new Privacy Policy on this page, updating the “Last updated” date, and sending an email notification if you have provided us with your email address.

11. Contact Us

If you have any questions about this Privacy Policy, our data practices, or would like to exercise your privacy rights, please contact us at:

• Email: luis@modassembly.com