Privacy Notice

Last updated: May 19, 2026

1. Who we are

This Privacy Notice describes how Allan Kelly, an individual sole trader operating under the trading name "Modulr" ("we", "us", "our"), collects and uses your personal data. Allan Kelly is the data controller for the personal data described in this notice.

2. Personal data we collect

  • Contact details — name and email address you provide at checkout or when you contact us.
  • Order information — products purchased, order date, and download history.
  • Support communications — the contents of any messages you send us.
  • Usage and device data — IP address, browser type, device identifiers, pages visited, and basic telemetry collected through our website.

Payment card details are collected directly by Paddle, our Merchant of Record. We never see or store your full card number.

3. How we use your data

  • To deliver the product you purchased and provide access to downloads (legal basis: performance of a contract).
  • To respond to customer support requests (legal basis: performance of a contract).
  • To prevent fraud and secure our Service (legal basis: legitimate interests).
  • To improve our products and website (legal basis: legitimate interests).
  • To comply with legal, tax, and accounting obligations (legal basis: legal obligation).
  • To send occasional updates about new products, only where you have opted in (legal basis: consent).

4. Who we share your data with

  • Paddle — our Merchant of Record, who handles all payment processing, subscription management, tax compliance, invoicing, and refunds.
  • Service providers and subprocessors — hosting, analytics, email delivery, and customer support tooling, acting on our instructions.
  • Professional advisers — accountants and legal advisers, where reasonably necessary.
  • Authorities — where required by law, court order, or to protect our rights.

5. Data retention

We retain personal data only for as long as is necessary for the purposes described above, or as required to comply with our legal obligations (for example, tax records). When data is no longer needed, it is deleted or anonymised.

6. Your rights

Depending on where you live, you may have the right to access, correct, delete, or restrict the use of your personal data; to object to processing; to data portability; and to withdraw consent at any time. You may also have the right to lodge a complaint with your local data protection authority. To exercise these rights, please contact us using the details below. We aim to respond within one month.

7. International transfers

Your data may be processed by service providers located outside your country. Where this happens, we rely on appropriate safeguards (such as Standard Contractual Clauses or adequacy decisions) to protect your data.

8. Security

We use appropriate technical and organisational measures — including encryption in transit and access controls — to protect your personal data against loss, misuse, and unauthorised access.

9. Cookies

We use essential cookies to operate the website and may use analytics cookies to understand how visitors use our pages. You can manage cookie preferences through your browser settings.

10. Contact

For privacy-related questions or to exercise your rights, please contact Allan Kelly via the contact details on our homepage.