Privacy Policy.

1. Who we are and what this covers

This Privacy Policy explains how Modrn Holdings, a California corporation (“Modrn,” “we,” “us,” or “our”), operating as Modrn Agency, collects, uses, shares, and protects personal information. It applies to our website at modrnagency.com and its subdomains, our forms, booking flows, emails, calls and text messages, and the services we provide to our clients (together, the “Services”).

We play two different roles, and this policy treats them differently:

• For our own business. When you visit our website, book a call with us, become a client, or otherwise interact with Modrn directly, we decide how your information is used. This policy governs that information.
• For our clients. When we build and run funnels, ads, and follow-up for a client, we process the personal information of that client’s prospects and leads on the client’s behalf and under the client’s instructions. In that role we act as a “service provider” or “processor,” and the client’s own privacy policy governs that information. See Section 10.

Our Services are offered to businesses and are not directed to consumers acting in a personal capacity. By using the Services, you acknowledge this Privacy Policy. Please also read our Terms and Conditions.

2. Information we collect

Information you give us

• Contact and business details: name, business email, phone number, company name, job title, website, industry, company size, and similar details you enter in a form, booking flow, or email.
• Qualification and call information: answers to our qualification questions, details about your offer, revenue, goals and marketing, and notes or recordings from sales, onboarding and strategy calls (we will tell you when a call is recorded).
• Client account information: billing contacts, signed agreements, project communications, brand assets, and the access you grant us to your advertising, CRM, website and other accounts.
• Payment information: payments are processed by Stripe. We receive confirmation of payment and limited details such as the last four digits of a card, but we do not store full card numbers.
• Communications: the content of emails, text messages, Slack messages and other communications you send us.

Information collected automatically

• Device and usage data: IP address, browser and device type, operating system, pages viewed, links clicked, referring page, and the date and time of your visit.
• Approximate location: general location (such as city or region) inferred from your IP address. We do not collect precise geolocation.
• Cookies, pixels and similar technologies: see Section 6.
• Video viewing data: when you watch videos hosted by Wistia on our pages, we receive information about how much of a video was watched.

Information from other sources

• Advertising platforms: when you submit a lead form on Meta (Facebook or Instagram) or LinkedIn, or interact with our ads, we receive the information you submit and campaign data.
• Referrals and partners: people who refer you to us may share your name and business contact details.
• Publicly available business information: information about your company from its website and public professional profiles.

We do not intentionally collect sensitive personal information such as Social Security numbers, health information, or precise geolocation through our website, and we ask that you not send it to us.

3. How we use information

• To respond to inquiries, schedule and hold calls, and evaluate whether we are a fit for your business.
• To provide, manage and improve the Services, including onboarding, building funnels and campaigns, reporting, and support.
• To process payments, manage subscriptions, and keep business and tax records.
• To send you information about our Services, offers and events, which you can opt out of at any time.
• To measure and improve our website and advertising, including showing our ads to people who visited our site (see Section 6).
• To protect the security of the Services, prevent fraud and abuse, and enforce our agreements.
• To comply with law and respond to lawful requests.
• For any other purpose we describe to you when we collect the information, or with your consent.

4. Calls and text messages

If you give us your phone number, you agree that Modrn may contact you at that number by call or text message about your inquiry, a scheduled call, or your engagement with us. Where we send marketing text messages, we do so only with your consent, and consent is not a condition of purchasing anything from us. Message frequency varies, and message and data rates may apply.

You can opt out of text messages at any time by replying STOP, or ask for help by replying HELP or emailing ops@modrnagency.com. We honor opt-outs made in any reasonable way.

We do not sell, rent or share your mobile phone number or text-messaging opt-in information with third parties for their own marketing purposes. We share it only with service providers that help us deliver messages, as described in Section 5.

5. How we share information

We do not sell personal information for money. We share personal information only as follows:

• Service providers that help us run our business, under contracts that limit their use of the information to providing services to us. Our main providers are listed below.
• Advertising and analytics partners such as Meta, Google and LinkedIn, through the cookies and pixels described in Section 6. Under California law some of this may be considered “sharing” for cross-context behavioral advertising, and you can opt out as described in Section 7.
• Our clients, when we deliver leads and reporting we collected on their behalf (see Section 10).
• Professional advisors such as lawyers and accountants, under duties of confidentiality.
• Business transfers: in connection with a merger, acquisition, financing, or sale of all or part of our business, subject to this Privacy Policy.
• Legal and safety: when required by law, legal process or government request, or to protect the rights, property or safety of Modrn, our clients or others.
• With your consent or at your direction.

Our main service providers

We may update these providers as our business changes. You can ask us for the current list at any time.

6. Cookies, pixels and advertising

Our website uses cookies, pixels and similar technologies, some placed by us and some by third parties, to make the site work, understand how it is used, and measure and target our advertising.

Retargeting. We use these tools to show Modrn ads to people who visited our website on other sites and apps. The ad platforms may combine this information with information they already have about you under their own privacy policies.

Your choices. You can block or delete cookies in your browser settings, though some parts of the site may not work properly. You can also manage ad preferences directly with Meta, Google and LinkedIn, opt out of Google Analytics with the Google Analytics opt-out add-on, and opt out of interest-based ads from many companies at optout.aboutads.info. California residents can also opt out of sharing as described in Section 7.

Global Privacy Control. We treat a Global Privacy Control (GPC) signal from your browser as a request to opt out of the sale or sharing of your personal information for that browser.

7. Your California privacy rights

This section applies to California residents and supplements the rest of this policy under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”).

Personal information we collected in the last 12 months

We collect these categories from the sources and for the purposes described in Sections 2 and 3. We do not collect or use sensitive personal information to infer characteristics about you.

Sale and sharing. We do not sell personal information for money. In the last 12 months we may have “shared” identifiers, internet activity and approximate geolocation with advertising partners for cross-context behavioral advertising. We do not knowingly sell or share the personal information of anyone under 16.

Your rights

• Right to know what personal information we have collected about you and how we use and disclose it, and to receive a copy.
• Right to delete personal information we collected from you, subject to legal exceptions.
• Right to correct inaccurate personal information.
• Right to opt out of sale or sharing of your personal information.
• Right to non-discrimination for exercising any of these rights.

How to make a request. Email ops@modrnagency.com with the subject “Privacy Request” and tell us which right you want to exercise. We will confirm receipt within 10 business days and respond within 45 days, or tell you if we need more time as the law allows. To protect your information, we will verify your request by matching the information you provide with the information we hold. You may use an authorized agent, and we may ask for proof of the agent’s authority and verify your identity directly.

8. Residents of other U.S. states

Depending on where you live, you may have rights to access, correct, delete or obtain a copy of your personal information, and to opt out of targeted advertising, sales and certain profiling. To exercise any of these rights, email ops@modrnagency.com. If we deny your request, you may appeal by replying to our decision with the subject “Privacy Appeal,” and we will respond as required by your state’s law.

9. Our use of AI tools

Our team uses AI tools, including Claude by Anthropic and ChatGPT by OpenAI, to help draft copy, scripts, offers and reports, and to analyze campaign performance. A person on our team reviews AI-assisted work before it is delivered or used.

We use these tools under business accounts or settings that do not allow the provider to use our inputs to train its models. We limit the personal information we enter into AI tools to what is needed for the work, and we do not use AI tools to make decisions that produce legal or similarly significant effects about you.

10. Data we process for our clients

When we run funnels, ads, CRM and follow-up for a client, the prospects and leads who interact with those campaigns are the client’s contacts. For that information:

• The client decides why and how the information is used, and the client’s privacy policy applies. Client landing pages and forms we build display or link to the client’s own privacy notice.
• We process the information only to provide our services to that client, as their service provider, under our agreement with them. We do not sell it, use it to market Modrn’s own services, or combine it with other clients’ data.
• We keep each client’s information separate in its own account within our systems.
• If you are a client’s prospect and want to exercise privacy rights, please contact that client directly. If you contact us, we will forward your request to the client and help the client respond.

11. How long we keep information

We keep personal information only as long as we need it for the purposes in this policy, unless the law requires or allows us to keep it longer.

Copies in backups are deleted on the providers’ normal backup cycles. We may keep information that no longer identifies you.

12. How we protect information

We use reasonable administrative, technical and physical safeguards designed to protect personal information, including:

• Two-factor authentication on our core business systems.
• Access limited to team members who need it for their work, and removed when their role ends.
• Written confidentiality obligations for our team members and contractors.
• Encrypted connections (HTTPS) for our website and the cloud platforms we use.
• Separate accounts for each client’s data.

No method of transmission or storage is completely secure, so we cannot guarantee absolute security. If we learn of a security incident affecting your personal information, we will notify you and others as required by law.

13. Children

Our Services are intended for businesses and for people 18 and older. We do not knowingly collect personal information from anyone under 18. If you believe a child has given us personal information, contact us and we will delete it.

14. Where information is processed

Modrn is based in the United States. Our service providers may process information in the United States and in other countries where they operate. If you contact us from outside the United States, your information will be transferred to and processed in the United States, where privacy laws may differ from those in your country.

15. Other websites

Our website and campaigns may link to websites and services we do not control, including our clients’ sites and the ad platforms. Their own privacy policies apply, and we are not responsible for their practices.

16. Changes to this policy

We may update this Privacy Policy from time to time. We will post the updated version on this page with a new “Last updated” date. If we make material changes, we will provide additional notice, such as an email to active clients, before the changes take effect.

17. Contact us