TMAC Privacy Policy
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TMAC Privacy Policy

The modular analytics company limited


1.            INTRODUCTION

1.1         In this Privacy Policy:

1.1.1           references to we, us or our means THE MODULAR ANALYTICS COMPANY LIMITED, a company incorporated and registered in England and Wales (No. 11258401), whose registered office is The Express Building, 9 Great Ancoats Street, Manchester M4 5AD.  We operate from the address shown in the ‘How to contact us’ section below;

1.1.2           references to you or your means any individual who uses our mobile application MyClassMate (V1.0 and all subsequent versions) (Mobile App); and

1.1.3           references to Website means the website found at  (as amended from time to time).

2.            privacy policy

2.1         This policy (together with any other documents referred to in it) sets out the basis on which we collect and use personal data about you through:

2.1.1          your use of the Mobile App; and/or

2.1.2           your use of the Website.

2.2         This Privacy Policy describes in detail who is responsible for the personal data that we collect about you, the nature of the personal data we collect and how we will use it.  We will also set out who we disclose it to and your rights and choices in relation to your personal data.

2.3         In this Privacy Policy where we use the words personal data we use these words to describe information that is about you and which identifies you.


3.1         We are the controller for the purpose of data protection law, in respect of your personal data collected and used through your use of the Mobile App and/or the Website.

3.2         This is because we dictate the purpose for which your personal data is used and how we use your personal data.

4.            what PERSONAL DATA do we hold about you?

4.1         We collect and use personal data about you in the course of your use of the Mobile App and/or Website.  You will also provide us with your personal data when you create a user account, or when you choose to interact with us. The personal data we collect is described in the table below.

4.2         Information you provide to us

The information you provide to us may include:  

Type of Personal Data


Registration on the Mobile App and Website

Identity Data

Name, title, date of birth, gender, username and password for access to our Mobile App and Website.

Includes demographic information (such as your postcode) provided from you directly when you provide information about your interests and preferences on our Website.

Contact Data

Includes billing address, email address and telephone number.

Financial Data

Includes bank account and payment card details.

Profile Data

Includes purchases or orders made by you, your interests, preferences, feedback and survey responses.

Transaction Data

Includes details about payments to and from you and other details of products/services you have purchased from us.


Sound Recording Data

The music recordings you create and upload to the Mobile App.

Music Analysis Data

The Mobile App's analysis of the Recording Data, produced and provided to you through your use of the Mobile App.

Feedback Data

Name, address, e-mail address or telephone number, details about the service you received/your experience.

Marketing Preferences

Marketing and Communications Data

Includes your marketing and communication preferences.

To improve our marketing communications, we may collect information about interaction with, and responses to, our marketing communications.


Technical Data

Includes information collected when you access our website or mobile applications, your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website or mobile applications.

Usage Data

Includes information about how you use our Website and Mobile App.

We analyse your Usage Data in order to recommend learning modules.

We collect this data through our use of cookies on our Mobile App or Website. Cookies are pieces of information stored directly on the device you are using. Cookies allow us to recognise your device and to collect information such as internet browser type, time spent using the Mobile App or Website and pages visited.

Please see our Cookies Policy which can be accessed at for further details on how we use cookies on our Mobile App or Website.


This includes information you provide:

a)    when you fill in forms on the Mobile App;

b)    in communications between us, including e-mails, letters, [and text messages].

4.3         Information we collect from you

4.3.1           technical information (including your login information for the Mobile App or Website and, to the extent that they constitute personal data, the IP address you use to connect your device to the Internet and the browser type and version you use on your device);

4.3.2           information collected from forms you complete

4.3.3           information contained in and records of communications between you and us, including emails, letters [and text messages].

4.4         Information we receive from other sources and/or publicly available sources such as:

4.4.1           [social media platforms such as Facebook;]  

4.4.2           analytics providers [such as [NAME] based [inside OR outside]  outside the European Economic Area];

4.4.3           advertising networks [such as [NAME] based [inside OR outside] the European Economic Area];

We collect identity and contact information about you from the above, and any other available sources (as updated from time to time).

5.            how do we use the personal DATA we collect about you? 

5.1         Under data protection law we can only use your personal data if we have a proper reason to do so (this is also known as a legal basis). Examples of where we have a legal basis include when:


5.1.1           we have your consent;

5.1.2           it is necessary to enter into or perform a contract with you or your employer where you are acting on behalf of a corporate entity (or to take steps at your request prior to entering into that contract);

5.1.3           it is necessary to comply with a legal obligation;

5.1.4           it is necessary in order to protect your vital interests; or

5.1.5           it is in our legitimate interests.

5.2         Where we rely on our legitimate interests we mean our:

5.2.1           pursuit of our commercial activities and objectives, or those of a third party;

5.2.2           compliance with applicable legal and regulatory obligations and any codes of conduct;

5.2.3           improvement and development of our business operations and service offering, or those of a third party; or

5.2.4           protection of our business, shareholders, employees and customers, or those of a third party.

5.3         We have set out our reasons for using your personal data in the table below under the heading Legal Basis.  Where we rely on our legitimate interests, we have set out those interests in the table below. 



Type of personal data

Lawful basis of processing

To register you as a new user

(a) Identity Data

(b) Contact Data

Performance of a contract

To process and deliver any in-app purchases (including managing payments, fees and charges, and collecting and recovering money owed to us) and other free services through the Mobile App.

(a) Identity Data

(b) Contact Data

(c) Financial Data

(d) Transaction Data

(e) Recording Data

(f) Music Analysis Data

(g) Marketing and Communications Data

(a) Performance of a contract

(b) Legitimate interests (to recover debts due to us)

To manage our relationship with you (including notifying you about changes to our terms or this notice and asking you to leave a review or take a survey)

(a) Identity Data

(b) Contact Data

(c) Profile Data

(d) Marketing and Communications Data

(a) Performance of a contract

(b) Legal or regulatory obligation

(c) Legitimate interests (to keep our records updated and understand how customers use our products/services)

To enable you to take part in a prize draw, competition, raffle or complete a survey

(a) Identity Data

(b) Contact Data

(c) Profile Data

(d) Usage Data

(e) Marketing and Communications Data

(a) Performance of a contract

(b) Legitimate interests (to understand how customers use our products/services, to develop them and grow our business)

To administer and protect our business, website and mobile applications (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity Data

(b) Contact Data

(c) Technical Data

(a) Legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Legal obligation

To deliver relevant content and advertisements to you and measure or understand the effectiveness our advertising

(a) Identity Data

(b) Contact Data

(c) Profile Data

(d) Usage Data

(e) Marketing and Communications Data

(f) Technical Data

(g) Feedback Data

(h) Webinars

Legitimate interests (to understand how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, mobile applications, products/services, marketing, customer relationships and experiences

(a) Technical Data

(b) Usage Data

(c) Feedback Data

Legitimate interests (to define types of customers for our products/services, to keep our website and mobile applications updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about products/services that may be of interest to you.

Note that we use artificial intelligence to analyse your use of the Mobile App, which then recommends learning modules which may be of interest to you.

(a) Identity Data

(b) Contact Data

(c) Technical Data

(d) Usage Data

(e) Profile Data

(f) Marketing and Communications Data

Legitimate interests (to develop our products/services and grow our business)


6.            failure to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (e.g., to provide you with products/services).  In this case, we may have to cancel a product/service but we will notify you if this is the case at the time.

7.            who may we disclose your PERSONAL DATA to? 

7.1         We may have to share your personal data with the parties set out below for the purposes that we collected the personal data.

7.1.1           Service providers who provide IT and system administration services.

7.1.2           Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

7.1.3           HMRC, regulators and other authorities.

7.1.4           Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.  Alternatively, we may seek to acquire other businesses or merge with them.  If a change happens to our business, then the new owners may process your personal data in the same way as set out in this notice.

7.2         We require all third parties to respect the security of your personal data and to treat it in accordance with the law.  We do not allow our third-party service providers to process your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

8.            Where will we transfer your personal DATA?

8.1         We will process your personal data within the UK and Europe only.

8.2         Unfortunately, the transmission of information via the internet is not completely secure.  Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to us and any transmission is at your own risk.  Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.

9.            how long will we keep your personal DATA for?

9.1         We will retain your personal data for no longer than is necessary for the purposes for which the personal data are processed, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements and for the establishment or defence of legal claims.

9.2         To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

9.3         In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

10.         Your rights and how to make a complaint

10.1       Under certain circumstances, you have rights under data protection laws in relation to your personal data.  In summary these are the rights of access, rectification (i.e., correction), erasure (also known as the "right to be forgotten"), restriction, objection, data portability and withdrawal of consentIf you wish to exercise any of these rights, then please contact us.

10.2       You will not have to pay a fee to access your personal data (or to exercise any of the other rights).  However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.  Alternatively, we could refuse to comply with your request in these circumstances.

10.3       We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights).  This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.  We may also contact you to ask you for further information in relation to your request to speed up our response.

10.4       We try to respond to all legitimate requests within one month.  Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests.  In this case, we will notify you and keep you updated.

10.5       You also have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (  We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please feel free to contact us in the first instance.

11.         Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, we will give you reasonable notice of any changes.

12.         HOW TO CONTACT Us

12.1       If you have any questions regarding this Privacy Policy or the way we use your personal data, you can contact us by:

12.1.1        email at [email protected]; or

This Privacy Policy was last updated on 01 April  2021.