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As a general rule, each MODIVO group entity determines purposes and methods of processing Personal Data (“Personal Data”) autonomously, which in effect means, that each entity constitutes a separate administrator (“Administrator”). In most cases, your Personal Data administrator is that entity, with which you sign an agreement and conduct business.
Information contained in this document applies to each MODIVO Group entity separately, to the extent to which these entities are Administrators, and to the entire MODIVO S.A. group, as in most processes it is the Personal Data Administrator.
It is also possible for an entity to conduct some activities on another MODIVO group entity’s behalf, e.g. related to logistics or marketing, in such cases, the first entity does not become a Personal Data Administrator and only processes the Personal Data on basis of a contract of entrusting the processing of Personal Data, signed with the Administrator.
Processing of Personal Data Your Personal Data might be processed for multiple reasons: (i) if you have provided your Data in person through various communication channels (e.g. submitting your application, sending an inquiry/offer via e-mail or telephone); (ii) as part of our cooperation when signing or executing a contract or agreement; (iii) when we acquired your Data from other sources (e.g. from a company with which you cooperate and which is our contractor/customer, this might also include other MODIVO Group entities).
Processing related to business, trade relationships as well as contacts
The scope of Personal Data processing As Administrator, we process Personal Data of our customers and business partners and their employees/associates, as well as Personal Data of other people provided to us as part of the performance of contracts or making contact with us via telephone, emailor forms on our web pages.In connection with these relations, we may process the following Personal Data: identification data, contact details, position, professional qualification data and other Personal Data provided to us with reference to the cooperation or contact.We collect the above-mentioned Personal Data directly from you as well as from other people, e.g. from your employers/clients.
Purpose and basis of Personal Data processing Because of the afore-mentioned relations, we process Personal Data for the following purposes:
to establish cooperation and conclude a contract;
to perform and settle previously concluded contract;
to reply to inquiries and requests as well as to pursue further correspondence/contact in this respect;
for marketing purposes and contactsrelated to other information and services provided by the Administrator;
as a defense against potential claims, as well as to issue any claims;
to fulfill the Administrator’s legal obligations (e.g. related to taxes or accounting).
The basis for the processing of Personal Data by the Administrator is:
the necessity to perform a contract or take action before its conclusion at the request of the Data subject;
the implementation of legal obligations imposed on the Administrator;
the legitimate interest of the Administrator in the form of marketing of products and services of the Administrator or a third party, contact, including correspondence and defense against potential claims.
In general, providing Personal Data is voluntary, but it may be necessary for entering into or performing a contract, responding to a directed inquiryor to conducting correspondence.
Period of Personal Data processing The Personal Data collected for entering into and performing a contract will be processed for the duration of the contract or until you object to the processing based on our legitimate interest, unless the law (e.g. archiving, tax or accounting law) obliges us to prolong theprocessing of the Personal Data, or we store it longer to defend ourselves against potential claims, for their period of limitation prescribed by law, depending on which period is longer.Your Personal Data provided as part of your contact with us will be processed till the end of communication with you and, in the case of marketing activities, until an objection is made, unless the law obliges us to continue processing or until the expiry of the period ofexpiration of possible claims.
Recipients of Personal Data Your Personal Data may also be transferred to entities that help us to conduct communication with our associates and customers (e.g. help us with sending out e-mails or running marketing campaigns), help us maintain our webpage and the app, provide support and ensure the operation of ourICT tools and systems (e.g. data retention), handle shipments and payments (online payment operators or banks), provide ongoing legal services, conduct audits, etc., to other MODIVO Group entities within the above activities.
The transmission of Personal Data outside the European Economic Area (EEA) As an exception, we might transfer your Personal Data to our partners processing the Data outside European Economic Area (EEA), but only within the scope deemed necessary, related to services we are provided by these partners, especially IT services(e.g. cloud storage of data). To ensure the security of your Personal Data, we use safeguards, such as standard contractual clauses approved by the European Commission contracts for entrusting the processing of Personal Data, which meet the GDPR requirements. In case of transmission of Personal Data outside the EEA, we make every effort so that our partners would guarantee an appropriate level of protection by implementing additional safeguards. You have the right to obtain copies of the safeguards we use, in particular by contacting our data protection officer.
Rights In any event, you have the right to:
access Personal Data (including receiving information on which Personal Data is processed),
request correction and limitation of the Personal Data processing (e.g. if it is incorrect);
erase Personal Data (e.g. if it was processed unlawfully);
transfer of Personal Data which you have provided to the Administrator, when the processing takes place in an automated manner the data is processedbased on of consent or in connection with the contract, e.g. with another administrator;
object to the processing of Personal Data processed based on of indispensability for purposes arising from legitimate interests pursued by the Personal Data Administrator or by a third party, in particular in the case of processing for marketing purposes;
lodge a complaint to the President of the Personal Data Protection Office.
If the processing of Personal Data is based on your consent, you have the right to withdraw it at any time without affecting the legality of the processing which was carried out on the basis of consent before its withdrawal.
What are cookies? Cookies are small textual information sent by the server and stored on the Visitor's device (usually on the computer's hard drive or mobile device). It stores information that the Modivo Advertising Services Site may need in order to customize to the Visitor's use of it and to collect statistical data about the Modivo Advertising Services Site (e.g., which pages were visited, what items are downloaded) and data about the domain name of the Internet service provider, or the Visitor's country of origin.
What kind of cookies do we use and are they harmful? The cookies used on the Modivo Advertising Services Site are not harmful either to the Visitor or to the computer/device used by the Visitor. The Modivo Advertising Services Site uses two types of cookies: session cookies, which remain stored on the Visitor's computer or mobile device until the Visitor logs off from the website or shuts down the software (web browser), and persistent cookies, which remain on the Visitor's device for the time specified in the parameters of the cookies or until they are manually deleted in the web browser.
How long will the information collected by cookies be stored? Depending primarily on the purposes and legal basis for processing personal data collected by cookies, they may be stored for varying periods. In the case of web push communication – it will be carried out, as a rule, until you opt out of this form of contact with us (consent withdrawal).Personal data collected by cookies regarding a Visitor who is not a user of the Modivo Advertising Services Site, will be stored until an objection is made. The Administrator may delete personal data if it has not been used for marketing or other legitimate purposes (such as statistical analysis) for 3 years unless the law obliges the Administrator to process personal data longer.Some of the personal data may be kept longer in case the Visitor has any claims against the Administrator, or for the Administrator's claim or defence against claims (including those of third parties), for the period of limitation prescribed by law, in particular, the Civil Code.In any case, the longer term of storage of Personal Data is decisive.
Cookies used on Modivo Advertising Services Site The table is subject to ongoing updating for the tools used by the Administrator. We make every effort to ensure that the table includes all the cookies we currently use. However, they will always be cookies used for the analogous purposes you will find in the table. If you want to stay up to date with the list of cookies we use, we recommend that you regularly check the updated Policy.
What consequences will deleting or blocking cookies have? In the case of cookies whose purpose is to facilitate or improve the use of the Modivo Advertising Services Site, limiting their use on a particular device may affect the operation of the Modivo Advertising Services Site and, in some cases, may significantly impair the use of the Modivo Advertising Services Site.
Can this policy be changes and how will you find out? The Administrator may change the Policy in the future. Each time it will post a notice of the such change within the Modivo Advertising Services Page. With each change, a new version of the Policy will appear with a new date.
Since when is this version of the policy effective? This version of the Policy is effective as of 2023-12-06.