MODIVO - Advertising Services

Processing of Personal Data

  1. Processing of Personal Data
    1. Personal Data Administrator This information is for the following entities, belonging to the MODIVO Capital Group (“MODIVO group”), i.e.:
      • MODIVO A.  (ul.  Nowy  Kisielin -Nowa  9,  66-002 Zielona Góra; e-mail:,  telefon:  (+48)  22  123  0  123.  Kontakt  do inspektora ochrony danych:;
      • pl Logistics Sp. z o.o. (ul. Nowy Kisielin -Nowa 9, 66-002 Zielona Góra; e-mail:, telefon: (+48) 68 422 84 04);
      • de GmbH (Nuhnenstr. 7d, 15234 Frankfurt (Oder); e-mail:, telefon: 0335 233 86 886);
      • ch GmbH (c/o KAVO-Immobilien AG, Baarerstrasse 11, 6300 Zug; e-mail:, telefon: (+41) 44 5087357);
      • cz s.r.o. (Českomoravská 2420/15, Libeň, 190 00 Praha 9; e-mail:, telefon: 228 881 562);
      • epantofi MODIVO s.r.l. (Splaiul Unirii, Nr. 4, Sitraco Center II, bl. B3, etaj 5, Ap. 5.3, sector 4, Bucharest 040031; e-mail:, telefon: +4 0371783601);
      • MODIVO S.R.L., Alme’ (BG) via A. Locatelli 49 CAP 24011 C/O Studio Associato
      • sk s.r.o., Ivanská cesta 16, Bratislava -district Ružinov 821 04.
      • Branded Shoes & Bags Sp. z o.o. (ul. Nowy Kisielin -Nowa 9, 66-002 Zielona Góra; e-mail:, telefon: (+48) 68 422 84 04)
      • 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.

    2. 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).

    3. Processing related to business, trade relationships as well as contacts

      1. 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.

      2. 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.

      3. 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.

    4. 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.

    5. 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.

    6. 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.

  2. The use of required cookies on the website

    In order to provide services at the highest level, we use required cookies, that ensure the proper functioning of our website and the implementation of its basic functions.

    Required cookies category includes cookies that are essential to keep our website working properly, to make it safer by helping to combat fraud, and to perform basic website functions. Thanks to these cookies the basic content of our website is displayed correctly and you can use it safely. This category is always active. You can block cookies in your browser settings, but this will cause the website to function incorrectly.

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