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The policy states that unspecified third-party companies and individuals engaged by Modal Labs for service facilitation, delivery, and analytics are granted access to users' personal information, subject to an obligation not to use or disclose it beyond their assigned tasks.
This analysis describes what Modal's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
The provision does not identify the third parties receiving personal data, does not describe the contractual mechanism through which the stated obligation is enforced, and does not specify which categories of personal data are shared with which categories of third parties. This structure may be insufficient to satisfy GDPR processor agreement requirements or CCPA disclosure obligations for categories of third parties to whom personal information is disclosed.
Interpretive note: The contractual mechanism enforcing the stated third-party obligation is not described, and the identity and number of third parties receiving personal data are not disclosed.
Under this clause, personal information collected by Modal Labs is accessible to unidentified third-party companies and individuals engaged for service-related purposes, with no enumeration of those third parties or the specific data categories shared with each.
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"We may employ third-party companies and individuals due to the following reasons: To facilitate our Service; To provide the Service on our behalf; To perform Service-related services; or To assist us in analyzing how our Service is used. We want to inform our Service users that these third parties have access to your Personal Information. The reason is to perform the tasks assigned to them on our behalf. However, they are obligated not to disclose or use the information for any other purpose.Excerpt from Modal's Privacy Policy
(1) REGULATORY LANDSCAPE: GDPR requires that data controllers enter into written data processing agreements with processors, specifying processing purposes and obligations. The policy's reference to an obligation not to disclose or use data for other purposes does not confirm that such agreements exist or meet GDPR requirements. CCPA requires disclosure of categories of third parties to whom personal information is disclosed. The policy does not provide that disclosure. (2) GOVERNANCE EXPOSURE: High. The absence of named third parties, specific data categories shared, and disclosed contractual mechanisms creates material compliance exposure under GDPR and CCPA for organizations evaluating Modal Labs as a data processor or vendor. (3) JURISDICTION FLAGS: EU and EEA users have heightened exposure under GDPR's processor agreement and international transfer requirements. California residents are subject to CCPA's third-party disclosure category requirements. Any international transfer of personal data to third parties outside the EEA would require additional transfer mechanism documentation not referenced in this policy. (4) CONTRACT AND VENDOR IMPLICATIONS: Organizations using Modal Labs as a cloud computing vendor should request documentation of third-party data processor agreements, data transfer mechanisms, and the identity of subprocessors before transmitting personal data through the platform. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should request Modal Labs' data processing agreement, list of subprocessors, and confirmation of any international transfer mechanisms in place before treating this policy as sufficient for downstream regulatory compliance obligations.
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The provision does not identify the third parties receiving personal data, does not describe the contractual mechanism through which the stated obligation is enforced, and does not specify which categories of personal data are shared with which categories of third parties. This structure may be insufficient to satisfy GDPR processor agreement requirements or CCPA disclosure obligations for categories of third …
Under this clause, personal information collected by Modal Labs is accessible to unidentified third-party companies and individuals engaged for service-related purposes, with no enumeration of those third parties or the specific data categories shared with each.
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