Privacy Policy for Modular Content Scheduler

1. Introduction

This Privacy Policy describes how MODULAR WEB LTD ("Company", "We", "Us", "Our"), company number 14065707, registered at 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ, handles information in connection with the internal software tool, Modular Content Scheduler (the "Service").

The Service is used exclusively by authorized employees and agents ("Users") of MODULAR WEB LTD for managing the Company's official TikTok accounts. This policy applies only to the operation of this internal tool and not to external parties.

2. Information We Process

When Users interact with the Service, we may process the following types of information:

• Information from TikTok: When a User authenticates a Company TikTok account with the Service via TikTok's OAuth flow, we receive information necessary to interact with the API on behalf of that account. This typically includes an Access Token, Refresh Token, and basic user identifiers (like Open ID, Union ID) associated with the Company's TikTok account being connected. We do not request or store personal TikTok user data beyond what is necessary to identify and manage the Company's own accounts via the API.
• Information Provided by Users: This includes video files, captions, scheduling information, and other metadata that authorized Users input into the Service for the purpose of posting to the Company's TikTok accounts.
• Operational Data: We may collect internal logs regarding the Service's operation for performance monitoring, troubleshooting, and security purposes (e.g., API call success/failure rates, timestamps).

3. How We Use Information

The information processed is used solely for the following internal purposes:

• To enable the core functionality of the Service: authenticating Company accounts, uploading content, and scheduling posts to TikTok via the API.
• To manage and monitor the performance and security of the Service.
• To ensure compliance with TikTok's Developer Terms and internal Company policies.

We do not use this information for any other purpose, such as profiling, advertising, or sharing with third parties (except as required by law or mandated by TikTok's terms).

4. Data Sharing

We do not share data processed by the Service with any external third parties, except:

• With TikTok, as necessary to use their API for posting content.
• If required by law, regulation, or valid legal process.

The Service is internal; therefore, data is only accessible to authorized MODULAR WEB LTD personnel involved in operating the Service or managing the Company's TikTok presence.

5. Data Security

We implement reasonable technical and organizational measures to protect the information processed by the Service against unauthorized access, disclosure, alteration, or destruction. This includes secure storage of API credentials and access controls within our internal systems.

6. Data Retention

We retain information processed by the Service only for as long as necessary to fulfill the purposes outlined in this policy, manage the Service effectively, or comply with legal obligations or TikTok requirements (e.g., retaining logs for a certain period). Access tokens are managed according to TikTok's guidelines.

7. User Rights (Internal)

As Users are employees/agents of MODULAR WEB LTD, rights regarding their data are primarily governed by their employment agreement and applicable data protection laws (like GDPR). Internal procedures are in place for data access or correction requests related to Company systems.

8. Changes to This Policy

We may update this Privacy Policy periodically. We will notify Users of significant changes through internal communication channels.

9. Contact Information

For questions regarding this Privacy Policy or data handling within the Modular Content Scheduler, please contact hello@modular-web.com