lv SIA, vienotais reģistrācijas Nr. 40203445013 Stabu iela 15 -140, Rīga, LV-1010
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.
II. Cookie Policy
What kind of documents are you dealing with? These cookies and similar technologies policy of the Modivo Advertising Services Site (“Policy”) is for informational purposes only, which means that it does not create any obligations for you (it is not a contract or regulations). The purpose of the Policy is to clearly present the rules of the Modivo Advertising Services Site regarding the operation and use of cookies or similar technologies. In the following part of the document, the Administrator shall be understood as MODIVO S.A. with its registered office in Zielona Góra (ul. Nowy Kisielin- Naukowa 15, 66-002 Zielona Góra) entered in the Register of Entrepreneurs of the National Court Register, maintained by the District Court in Zielona Góra, 8th Commercial Department of the National Court Register, under KRS number: 0000541722; NIP: 9291353356; REGON: 970569861; BDO: 000031285; with a share capital: PLN 2 008 001.00, paid in full (“Administrator”).The Administrator can be contacted at the above address, e-mail address: info@eobuwie.pl or phone number: (+48) 68 422 84 04 and 507 599 050 – charge as for a standard call – according to the price list of the relevant operator. To the extent that cookies contain your personal data, the Administrator will also be the controller of your personal data. The rules for handling and processing such data are contained in the Privacy Policy. You can contact the data protection officer via e-mail: iod@modivo.com.
To whom do cookies apply? The Administrator uses cookie technology or functionality similar to it on the Modivo Advertising Services Site. Each person who visits the Modivo Advertising Services Site, whether or not he or she uses the full range of functionality (“Visitor”), has the opportunity to choose the extent of the use of cookie technology and then give the appropriate consent. Depending on the selected scope of use of cookies technology, information about the Visitor, such as the use of the Modivo Advertising Services Site or interests, may be collected through it.
What technology do we use? The Modivo Advertising Services Site uses technology that stores and accesses information on your computer, or other device connected to the network (in particular, using cookies or related solutions), in order to provide you with maximum comfort while using the Modivo Advertising Services Site, including for statistical purposes, and to identify possible abuses and for customization to the interests of visitors and third parties (entities listed in item 11 of the Policy) or other so-called “third parties” with whom we cooperate. Depending on the solutions currently implemented and made available, as well as the technical possibilities, the Visitor has the opportunity to determine the scope of use of relevant cookies (e.g. for marketing purposes) and give the appropriate consent.Depending on the extent to which the Visitor has consented as regards the use of cookies technology, cookies may automatically collect various data about the Visitor's online activities, as well as information about the location of the device being used (if the chosen scope of use of cookies and consent, if any, allows for this). If it is not possible to specify the scope of cookies from the website, the settings of the browser used by the Visitor remain effective. Due to the fact that the Administrator may use solutions with functionality similar to cookies - the following provisions of the Policy should be applied accordingly also to these technologies.
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.
Do cookies collect your personal data? When a Visitor uses the Modivo Advertising Services Site, the Visitor has the option to select the scope of use of cookies technology and then give the appropriate consent corresponding to the selected scope. Depending on the extent to which the Visitor has consented as regards the use of cookies technology, cookies collect various types of information that, as a rule, do not constitute personal data (they do not allow the Visitor to be identified). However, some information, depending on its content and use, may be linked to a specific person - attributing certain behaviours to a specific Visitor, such as by linking it to the data provided when subscribing to the newsletter service - and thus be considered personal data. This applies, in particular, to cookies that the Visitor has consented to when using the Modivo Advertising Services Site (e.g., marketing cookies that help us better customize to the needs of users).In relation to information collected by cookies that can be linked to a specific person, the provisions of the Information Clause regarding, in particular, the rights of the data subject, recipients of the data and its transfer to third countries (outside the European Economic Area), shall apply.Information on the rules for the use of cookies, including the ability to choose the scope of use of cookies technology and give appropriate consent, is also made available in the content of the information clause displayed primarily during the first visit to the Modivo Advertising Services Site (the so-called “cookie banner”).
On what legal basis do we use cookies? Obtaining and storing information using cookies, except when it is necessary to ensure the proper operation of the Modivo Advertising Services Site and the performance of their basic functions (to provide you with a service rendered electronically in this regard, when we rely on a provision of law - Article 173(3)(2) of the Telecommunications Law), is possible only on the basis of the Visitor's consent. Depending on the currently implemented and made available technical solutions and possibilities, the choice of the scope of application of the cookies technology and the possible expression of the relevant consent may be possible primarily during the first visit to the Modivo Advertising Services Site from the cookie banner that appears in a visible and easily accessible place. In this case, the Visitor may change the chosen scope of use of cookies technology at any time in the Settings on our website (but some parts of the Modivo Advertising Services Site may then not function properly). By default – the use of particular types of cookies can also be blocked from the level of web browsers (we describe this in detail later in this document). Any withdrawal of consent to cookies does not affect the legality of the actions performed.To the extent that cookies will contain your personal data, the basis for their processing is the legitimate interest of the Administrator or a third party (Article 6(1)(f) of the GDPR), which is the identification of possible abuses, the need to ensure the highest quality of content presented by the Administrator by customizing it to the preferences of Visitors and the Administrator's services, and partners (third parties listed in item 11 of the Policy) or other so-called “third parties” with whom we cooperate, in which case these entities are not involved in the processing of Customer data. To the extent that these entities may also have direct access to this information, the legal basis for such processing will be the legitimate interest pursued by these entities or the voluntary consent expressed by the Visitor. To the extent that the functionalities and personal data collected by cookies are necessary for the proper provision of services to the Visitor on the Modivo Advertising Services Site – the basis for the processing of such information may also be considered in the context of the necessity for the performance of the contract you enter into by choosing to use our website (Article 6(1)(b) of the GDPR).
What do we use cookies for? Cookies are used primarily to ensure the proper operation of our Modivo Advertising Services Site, as well as to perform their key functions.Notwithstanding the foregoing, depending on the extent to which the Visitor has consented as regards the use of cookies technology, cookies may also facilitate the Visitor's use of the Modivo Advertising Services Site (for example, by “remembering” information provided once so that the Visitor does not have to provide it each time), and may be used to customize its content.Cookies may also be used to enhance the security of the Modivo Advertising Services Site by helping to combat possible abuse and damage to the usability of the content of the Modivo Advertising Services Site. Depending on the extent of the use of cookies technology chosen by the Visitor and the consent given, through the cookies technology used on the Modivo Advertising Services Site, it is possible for the Administrator to learn about the Visitor's preferences - for example, by analysing how often the Visitor visits the Modivo Advertising Services Site. Analysis of online behaviour helps to better understand the habits and expectations of Visitors and to customize to their needs and interests. Thanks to this technology, it is possible to present Visitors with offers customized to their needs and interests and to prepare better promotions and offers. Advertising content may also be adapted to the location of the device used by the Visitor if the selected scope of cookies and the consent given allows it. Based on cookies, the Administrator may also use technology to reach Visitors with an advertising message who have previously visited the Online Store while using other websites.
Can you object to the use of information gathered through cookies? A Visitor may object to the Administrator's actions based on personal data derived from cookies for the purposes described above, to the extent that the Administrator's actions are based on a legitimate interest (we specify such situations above). In addition, at any time, the Visitor may change the scope of use of the cookies technology and withdraw the previously given consent - however, this will not affect the legality of actions performed on the basis of consent before its withdrawal and the conduct of communications for which we have obtained additional consents (such as web push).If you have any doubts about the scope of the use of cookies and the use of information obtained using them, you can contact the Administrator - contact details are in item 1 of the Policy.
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.
Third party cookies The cookies used by the Administrator are primarily used to optimize the Visitor's experience when using the Modivo Advertising Services Site. In the course of its operations, the Administrator uses the services of the following entities that use cookies on the Modivo Advertising Services Site:Google Ireland: https://policies.google.com/privacy?gl=pl https://support.google.com/searchads/answer/7298761?hl=pl https://support.google.com/analytics/topic/2919631?hl=pl&ref_topic=1008008For more information about the cookies of the mentioned entities and the relationship with the Administrator, please refer to their privacy policies.
How to delete / block cookies? The Visitor may change the use of cookies by managing the scope of use of cookies technology and the consent given within the Settings on our website (depending on the current solutions implemented by the Administrator or by changing the browser settings (depending on the current solutions implemented by the Administrator).If you use browser settings, the way to delete cookies varies depending on the browser you use. Information on how to delete cookies should be located in the “Help” tab of your chosen web browser. The deletion of cookies is not the same as the deletion of personal data by the Administrator obtained through cookies.For example, in Internet Explorer, cookies can be modified from the following level: Tools -> Internet Options -> Privacy; in Mozilla Firefox browser: Tools -> Options -> Privacy; while in Google Chrome browser: Settings -> Show advanced settings -> Privacy -> Site settings -> Cookies and site data. Access paths may vary depending on the browser version used.For detailed information about managing cookies on your cell phone or another mobile device, please refer to the user manual/instruction manual of your particular phone or mobile device.It is also possible to block third-party cookies while accepting cookies used directly by the Administrator (“block cookies of third-party sites” option).
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.