Effective Date: February 1st, 2025
This Privacy Policy (“Policy”) sets forth the terms under which Modava (“Company,” “we,” “us,” or “our”) collects, uses, processes, stores, and discloses your personal information when you access and use the Modava mobile application (“App”) and any related services (collectively, the “Services”). This Policy complies with applicable data protection regulations, including but not limited to the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the California Consumer Privacy Act (“CCPA”), where applicable.
By downloading, accessing, or using the App, you agree to be bound by this Policy. If you do not agree with any part of this Policy, you must immediately cease use of the App.
1. Information We Collect
1.1 Personal Data
“Personal Data” refers to any information that can directly or indirectly identify an individual. We collect the following categories of Personal Data from you when you use the App:
– Identifiers: Name, email address, phone number, username, password, and other login credentials.
– Commercial Information: Purchase history and preferences if you make transactions within the App.
– Financial Information: Payment card details (which may be processed by third-party payment processors in compliance with applicable regulations).
– Location Data: Geolocation data if you enable location services on your device.
– Internet or Other Electronic Network Activity Information: Information related to your use of the App, such as access times, features used, and browsing history.
1.2 Automatically Collected Data
We may automatically collect the following data when you use the App:
– Device Information: Type of device, operating system, unique device identifiers, and mobile network information.
– Usage Data: Information about how you interact with the App, including pages or features accessed, time spent on the App, and navigation patterns.
– Cookies and Tracking Technologies: We use cookies and similar technologies to collect data about your device and how you use the App. This includes session cookies, persistent cookies, and third-party tracking tools for analytics and advertising purposes.
1.3 Special Categories of Data
We do not intentionally collect any sensitive data (such as health, race, religious beliefs, sexual orientation, or biometric data). If you voluntarily provide such information, you explicitly consent to our processing of that data.
2. Legal Basis for Data Processing
We process your Personal Data in accordance with applicable data protection laws, based on one or more of the following legal grounds:
2.1 Contractual Necessity
We process your Personal Data as necessary to provide the App and its Services, fulfill our contractual obligations to you, and manage your account, including registration and payment processing.
2.2 Legitimate Interests
We may process your Personal Data to pursue our legitimate interests, including but not limited to improving the functionality and performance of the App, personalizing your experience, preventing fraud, and ensuring network and information security. We will only process your data on this basis where our legitimate interests do not override your privacy rights.
2.3 Consent
In cases where you provide your consent, such as opting into marketing communications or enabling location services, we process your Personal Data based on that consent. You have the right to withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
2.4 Legal Obligation
We may process your Personal Data to comply with a legal obligation, such as tax regulations, regulatory requirements, or law enforcement requests.
3. Use of Your Information
3.1 Purposes for Processing Personal Data
We process Personal Data for the following purposes:
– Provision of Services: To operate and maintain the App and deliver Services requested by you.
– Personalization: To personalize your experience, including providing tailored content, recommendations, and advertisements based on your preferences and usage.
– Communications: To send you administrative and marketing communications, including App updates, promotional offers, and important legal notices.
– Analytics: To analyze usage patterns and improve the functionality, security, and performance of the App.
– Compliance: To comply with applicable legal obligations, including fraud prevention, anti-money laundering laws, and requests from law enforcement authorities.
3.2 Marketing and Advertising
With your consent, we may use your Personal Data for marketing purposes, including delivering targeted advertisements via third-party ad networks. You can opt out of marketing communications by following the unsubscribe instructions in such communications.
4. Sharing and Disclosure of Personal Data
4.1 Service Providers
We may share your Personal Data with third-party service providers who perform services on our behalf, such as payment processors, hosting services, analytics providers, and customer support services. These service providers are required to protect your Personal Data and use it only as instructed by us.
4.2 Business Transfers
In the event of a merger, acquisition, restructuring, or sale of assets, your Personal Data may be transferred as part of such a transaction, provided that the receiving party agrees to comply with the terms of this Policy or provide equivalent protections.
4.3 Legal Obligations
We may disclose your Personal Data if required to do so by law or in response to valid legal requests, such as subpoenas, court orders, or government investigations. We may also disclose your information when necessary to protect our rights, privacy, safety, or property, or that of our users.
4.4 Third-Party Partners
We may share aggregated, non-personally identifiable information with third-party partners for research, advertising, or analytics purposes. This data does not identify individual users.
5. International Data Transfers
We may transfer your Personal Data to countries outside your jurisdiction of residence, including to the United States or other jurisdictions that may have different data protection laws. We take appropriate measures to ensure that your Personal Data is adequately protected in accordance with this Policy and applicable data protection laws, including implementing appropriate safeguards such as Standard Contractual Clauses.
6. Data Retention
We will retain your Personal Data for as long as necessary to fulfill the purposes for which it was collected, as required by applicable law, or to comply with legal obligations, resolve disputes, and enforce our agreements. When your Personal Data is no longer needed for these purposes, we will securely delete or anonymize it in accordance with our data retention policies.
7. Your Rights
Depending on your location and applicable data protection laws, you may have the following rights regarding your Personal Data:
7.1 Right of Access
You have the right to request access to the Personal Data we hold about you, including details about how we process it.
7.2 Right to Rectification
You have the right to request the correction of inaccurate or incomplete Personal Data.
7.3 Right to Erasure (“Right to Be Forgotten”)
In certain circumstances, you may request the deletion of your Personal Data, subject to applicable legal exceptions.
7.4 Right to Restriction of Processing
You have the right to request that we restrict the processing of your Personal Data under certain conditions, such as if you contest the accuracy of the data or object to its processing.
7.5 Right to Data Portability
Where applicable, you may request a copy of your Personal Data in a structured, commonly used, and machine-readable format.
7.6 Right to Object
You have the right to object to the processing of your Personal Data for direct marketing purposes or based on our legitimate interests.
7.7 Right to Withdraw Consent
Where processing is based on your consent, you have the right to withdraw consent at any time. Withdrawal of consent does not affect the lawfulness of processing prior to the withdrawal.
8. Data Security
We implement appropriate technical and organizational measures to protect your Personal Data from unauthorized access, disclosure, alteration, or destruction. However, no method of transmission over the internet or method of electronic storage is completely secure, and we cannot guarantee absolute security.
9. Children’s Privacy
The App is not intended for use by individuals under the age of 18, and we do not knowingly collect Personal Data from minors. If we become aware that we have inadvertently collected data from a minor without parental consent, we will take steps to delete such information.
10. Changes to this Privacy Policy
We reserve the right to update this Policy at any time. If we make material changes, we will provide notice through the App or by other means as required by law. Your continued use of the App after such changes constitutes your acceptance of the updated Policy.
11. Contact Information
If you have any questions or concerns regarding this Policy or your Personal Data, please contact us at:
Email: the.modava.app@gmail.com
By using the Modava mobile application, you acknowledge that you have read, understood, and agree to this Privacy Policy.