1. Data controller
- Controller
- MITXOS MANAGEMENT, S.L. (MODU PROJECT)
- Tax ID (CIF)
- B26615278
- Registered office
- Plaza Wroclaw, 5, 2.º A, 20014 Donostia/San Sebastián, Gipuzkoa, Spain
- Contact and exercise of rights
- hello@moduproject.com
2. Personal data we process
We process only the data needed to respond to communications and manage a potential professional relationship:
- identification and contact details, such as your name, email address and telephone number;
- the company or organisation you belong to;
- information you provide about the project, locations, deadlines or requirements;
- basic technical data related to the operation and security of the website.
The website form does not currently allow file uploads and does not request special-category personal data. Please do not include sensitive information that is not necessary for us to deal with your enquiry.
3. Purposes and legal bases
Enquiries and project requests
Purpose: to receive, assess and respond to your enquiry; request clarification; assess project feasibility; prepare a proposal and follow it up.
Legal basis: taking pre-contractual steps at your request and, for general enquiries, our legitimate interest in responding to and managing the communication received.
Client and supplier relationships
Purpose: to manage quotations, orders, contracts, production, logistics, invoicing, payments and professional communications.
Legal basis: performance of the contractual relationship and compliance with legal, accounting and tax obligations.
Website security and operation
Purpose: to maintain security, prevent abusive use and resolve technical incidents.
Legal basis: our legitimate interest in protecting the website, its systems and its users.
Data submitted through the form is not used to subscribe you automatically to newsletters or to send advertising unrelated to the request you have made.
4. Retention periods
Enquiries are retained for as long as necessary to deal with them and carry out any appropriate follow-up. If no commercial relationship begins, they may be retained for a maximum of 24 months from the last communication, unless you request deletion earlier.
Where a contractual relationship exists, data will be retained while that relationship remains active and subsequently for the periods required by applicable commercial, tax, accounting or liability rules.
Data may remain blocked for the limitation periods necessary to address potential liabilities.
5. Recipients and service providers
We do not sell your data or disclose it to third parties for advertising purposes. Service providers may access it where necessary to provide and maintain our services, subject to the appropriate safeguards and agreements:
- Hostinger, as our web hosting and technical infrastructure provider;
- Microsoft 365, as our corporate email and associated storage provider;
- professional, technical or administrative service providers where necessary to manage an enquiry or project or comply with legal obligations.
Some technology providers may process data from countries outside the European Economic Area. Where applicable, recognised mechanisms under data protection law will be used, such as adequacy decisions, Standard Contractual Clauses or other valid safeguards.
6. Your rights
You may request access to your personal data, rectification or erasure, restriction of processing, object to processing and, where applicable, request data portability.
To exercise these rights, email hello@moduproject.com, stating which right you wish to exercise and providing only the information necessary to verify your identity.
You may also lodge a complaint with the Spanish Data Protection Agency (AEPD) if you believe that the processing of your personal data does not comply with applicable law.
7. Security and accuracy of information
We apply reasonable technical and organisational measures to protect personal data against loss, unauthorised access, alteration or disclosure. No system connected to the Internet is completely infallible, but we review our measures in light of the nature of the data and the risks identified.
You are responsible for ensuring that the information you provide is accurate, up to date and does not improperly affect the rights of third parties.
8. Changes to this policy
We may update this policy when our processing activities, service providers, website functionality or applicable law change. The current version and its latest update date will always be available on this page.