Privacy Policy


Last updated: 28 February, 2022

About this Privacy policy.

Here at Festival Modem d.o.o. (hereinafter: “Modem”, “we”, “us”, “our”),  we understand that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone that visits our website. We only collect and use information in ways that are useful to you and in a manner consistent with your rights and our obligations under the law, including the General Data Protection Regulation (GDPR).

We have compiled this Privacy Policy to let you know when and why we collect your personal data, what we do with it, how we store it and the circumstances in which we may disclose it to others in relation to your use of our website. This would only ever be in the course of our business operations to provide you with the service(s) you have chosen such as tickets, trader applications or working with us for example or working with us for example. We never sell, rent or trade email lists or personal information to other companies for marketing purposes.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use the website. By accessing or using the website, whether or not you purchase any of our Services or create an account with us, you agree to this Privacy Policy.

1.  Abouts Us
Our website, is owned and operated by Festival Modem d.o.o. and our registered address is Donje Primišlje 11, 47240 Slunj, Croatia. Modem Festival is the “data controller” of any personal data it may collect, process and hold about you, unless we inform you otherwise.

2.  Scope and Purpose of Personal Data Processing

2.1  Collection of personal data when you visit our website

Log files
When using our website for information purposes only, so when you do not log in to use the website, register or otherwise provide information, we collect the data that your browser transmits to our server.This information includes, among other things:

  • The IP address of the device used
  • Information about the browser type, browser version and about the operating system used
  • The time and duration of the visit, information about the Internet service provider
  • Reference / exit websites

The data is technically necessary for us to display our website to you. It is also evaluated to make the website user-friendly and to ensure stability and security. The legal basis for the processing is our legitimate interests.

Cookies and similar technologies
In addition, we also use cookies on our website. Cookies are small text files that are assigned to your browser and stored on your device. Through them, certain information flows to the place that sets the cookie, such as settings or data for exchange with the system. This helps us to make our website more user-friendly and effective overall. The legal bases for this are your consent and our legitimate interests. Cookies cannot execute programs or transmit viruses to your device.

For more information about cookies, visit

You can set your browser not to accept cookies and the above website tells you how to remove cookies from your browser. However, in a few cases some of our Website features may not function as a result.

To find out more about the use of cookies and how you can manage them, please read our Cookie Policy

2.2  When you making contact   
If you contact us via a contact form, letter, email, social media or telephone, we process the data provided by you for the purpose of processing your inquiry and for marketing purposes. The legal basis for the processing is our legitimate interests. If the aim of establishing contact is to conclude a contract to which you are a party or to carry out measures prior to concluding a contract, then an additional legal basis is to perform under a contract.

You can object to this processing at any time. Please send your objection to the following email address: with the subject heading “Stop Processing”.

Your data will be erased if circumstances indicate that the relevant issue has been conclusively clarified and erasure is not prevented by any legal archiving obligations.

2.3  Online website forms
Through our website we make online forms available so that fans have the opportunity to send their proposals and participate in the making of the festival. Through these online forms, we receive information such as (but not limited to): name, email, gender, date of birth, phone, address and country.

2.6  Newsletter and Mailing lists
As part of the registration process for our e-newsletters we collect personal information. We use that information to tell you our latest news, information on ticket and event updates, videos and photos.  We also use it to update you on information that you have asked us to tell you about. We don’t rent or trade email lists with other organisations and businesses.

Processing of your data after you subscribe to our newsletter is based on the fact that we have your consent. Within the scope of the subscription process we will therefore obtain your consent to processing of your data and draw your attention to this data protection declaration. You can unsubscribe from the newsletter and withdraw the consent you have given at any time. 

2.7  When we perform other contractual services
We process the personal data of our principals, customers, clients, contractual partners and potential customers to facilitate performance of contractual services or measures prior to conclusion of contracts. The personal data processed in this regard; the type; the extent and the purpose as well as the necessity of its processing are determined by the contractual relationship on which processing is based. Processed data includes our contractual partners’ master data (e.g. names and addresses), contact data (e.g. email addresses and telephone numbers) and contract data (e.g. services which have been used; contract contents; contractual communications, names of contact persons) and payment data (e.g. bank details, payment history). Occasionally there may be instances where we will require you to provide additional personal information, some of which may be sensitive (for instance for accessibility). We will always tell you why we are collecting your information and how we will use it.

We process personal data which is required to establish and perform contractual services and, insofar as this is not obvious to the contractual partners, make them aware that this data is required.

Data is erased when it is no longer required to fulfil contractual or legal obligations or in connection with any warranty or comparable (archiving) obligations.

2.8. For Marketing and Purposes
If you have given us your contact details, we may use these (in accordance with any preferences you have expressed) to send you marketing messages by email, SMS and post, to keep you aware of what we’re up to and to help you see and find our products.

As part of running our business, Modem has a legitimate interest to promote our products using marketing messages to existing customers of Modem and those in a negotiation with us for a sale or service, unless you have asked us not to.

When we collect your personal data, we give you the opportunity to opt-in to receive those marketing messages by simply ticking the boxes. Should you change your mind, we have lots of ways you can stop receiving marketing messages, which we’ve set out below.If you are currently opted-out of our marketing, you can always choose to opt-in to receive our emails by amending your preferences.

How to stop marketing messages from Modem

You can stop receiving marketing messages from us at any time. For email marketing, the best way to do this is to click on the ‘unsubscribe’ link in any email you receive. 

It might take some time for all our systems to be updated, so you might get messages from us while we fully process your request, but we will ensure that we mark you as having opted out on our database as soon as we receive your request. Please be aware that stopping marketing messages will not stop our service communications (such as order and delivery updates).

3. Who do we share your information with

We may share Your personal information in the following situations:

  • Merger or Acquisition. We may share your information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
  • Security and Compelled Disclosure. We may share your information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also share your information to protect the rights, property, life, health, security and safety of TrueVault, the Services or any third party.
  • Consent. We may share your information for any other purpose disclosed to you and with your consent.
  • If we need to do so in order to exercise or protect our legal rights, users, systems and services; or
  • In response to requests from individuals (or their representatives) seeking to protect their legal rights or the rights of others.

In addition to the MoDem, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this website (administration, sales, marketing, legal, system administration).

We will never sell any of your personal data to a third party. However, in order for us to provide our services to you, we share your personal data with our trusted third party service providers (sometimes known as data processors) or our group companies (as detailed below). Whenever we share your personal data, we put safeguards in place which require these organisations to keep your data safe and to ensure that they do not use your personal data for their own marketing purposes.

4.  Detailed Information on the Processing of your Personal Data by third party Service Providers

The Service Providers we use may have access to your Personal Data. These third-party Service Providers collect, store, use, process and transfer information about your activity on our website in accordance with their Privacy Policies.

Analysis, Marketing and Tracking Services
We may use third-party service providers to monitor and analyse the use of our website.

  • Google Analytics
    We use Google Analytics to measure traffic on our website. Google has their own Privacy Policy which you can review here. If you’d like to opt out of tracking by Google Analytics, visit the Google Analytics opt-out page.

SPAM protection
This type of service analyzes the traffic of this Application, potentially containing Users’ Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.

  • Google reCAPTCHA
    We use reCAPTCHA to check whether entry of data on our portals (e.g. in contact forms) is carried out by humans or an automated programme. To do so, reCAPTCHA analyses the site visitor’s behaviour using a variety of characteristics (e.g. IP address, length of visits to the websites or mouse movements made by the user). Google reCAPTCHA is a SPAM protection service provided by Google Ireland Limited. The use of reCAPTCHA is subject to the Google privacy policy and terms of use.

Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of our website and interact with them.This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

  • Google Fonts
    Google Fonts is a typeface visualization service provided by Google LLC or by Google Ireland Limited, depending on the location this our website is accessed from, that allows our website to incorporate content of this kind on its pages. For more information about Google Fonts you can review their privacy policy here

Mailing Lists/Newsletters
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.

These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

  • MailJet
    We use MailJet services to process Newsletter Subscriptions, to deliver our newsletters as well as sending transactional email in case you bought an event ticket.
    We gather statistics around email opening and click throughs using industry standard technologies to help us monitor and improve our e-newsletter.  For more information about MailJet you can review their privacy policy here

    You can unsubscribe to general mailings at any time of the day or night by clicking the link at the bottom of the email.

Hosting and Backend Infrastructure
This type of service has the purpose of hosting Data and files that enable this Application to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Application.

Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

  • Amazon Web Services, Inc. (AWS)
    We use the external web hosting service providers Amazon Web Services, Inc. (AWS)
    In the event that data is also transferred to the USA, AWS has subjected themselves to the EU-US Privacy Shield.

    For more information about Amazon Web Services (AWS) visit: Privacy Policy

Social Media
On our website we have included buttons to promote web pages (e.g. “like”, “pin”) or share (e.g. “tweet”) on social networks like . These buttons work using pieces of code coming from themselves. This code places cookies. These social media buttons also can store and process certain information, so a personalised advertisement can be shown to you.

Please read the privacy statement of these social networks (which can change regularly) to read what they do with your (personal) data which they process using these cookies. The data that is retrieved is anonymised as much as possible. are located in the United States.

5.  Your rights with respect to personal data

You have the following rights with respect to your personal data:

  • You have the right to know why your personal data is needed, what will happen to it, and how long it will be retained for.

  • Right of access: You have the right to access your personal data that is known to us.

  • Right to rectification: you have the right to supplement, correct, have deleted or blocked your personal data whenever you wish.

  • If you give us your consent to process your data, you have the right to revoke that consent and to have your personal data deleted.

  • Right to transfer your data: you have the right to request all your personal data from the controller and transfer it in its entirety to another controller.

  • Right to object: you may object to the processing of your data. We comply with this, unless there are justified grounds for processing.

To exercise these rights, please contact us. Please refer to the contact details at the bottom of this Privacy Policy. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
If you have a complaint about how we handle your data, we would like to hear from you, but you also have the right to submit a complaint to the supervisory authority (the Data Protection Authority) in this case the Croatian Personal Data Protection Agency
Tel. +385 1 4609 000

6.  Security and Retention of your personal data
The Data processing is carried out using computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

6.1  Security of your personal data
We take the security of your personal data very seriously. We have implemented various strategies, controls, policies and measures to keep your data secure and keep these measures under close review. We protect your data by using encryption techniques and we use other safeguards such as firewalls and password protection. This means that your data is protected and only accessible by co-workers who need it to carry out their job responsibilities. We also ensure that there are strict physical controls in our buildings which restricts access to your personal data to keep it safe. However, no website can be completely secure and so we would urge you to notify us if you have any concerns. We will notify you promptly in the event of any breach of your personal data which might expose you to serious risk.

6.2  Retention of your personal data
In broad terms, we will only retain your personal data for as long as is necessary for the purposes described in this Privacy policy. This means that the retention periods will vary according to the type of the data and the reason that we have the data in the first place.
If you want us to remove your details from your subscriptions (providing you do not have any bookings, any other contractual agreements or there is a legal basis for not doing so) then you can email us at any time to request this. Please put ‘Personal Data’ in the subject heading.
We have procedures in place regarding our retention periods which we keep under review taking into account our reasons for processing your personal data and the legal basis for doing so.

7.  Facebook Page

Modem is the Data Controller  Personal Data collected while using our website. As operator of the Facebook Fan Page:, MoDem and the operator of the social network Facebook are Joint Controllers.

In the case of publishing unlawful or offensive content, Modem may, without prior notice, exclude the person in question from the circle of members or may delete his or her comment.

Modem is not responsible for content or comments published by Facebook users which violate rules and regulations. Modem is also not responsible for any errors in the functioning of Facebook, or any problems arising from changes to the system’s operation.

MoDem has entered into agreements with Facebook that define the terms for use of the Facebook Fan Page, among other things. These terms are mostly based on the Facebook Terms of Service 

Visit the Facebook Privacy Policy here for more information about how Facebook manages Personal data or contact Facebook online, or by mail: Facebook Ireland Limited
4 Grand Canal Square, Grand Canal Harbour, Dublin 2,Dublin, D02X525, Ireland

8.  Links to other websites

We sometimes provide you with links to other websites, but these websites are not under our control.  Therefore, we will not be liable to you for any issues arising in connection with their use of your information, the website content or the services offered to you by these websites.  We advise you to consult the privacy policy and terms and conditions on each website to see how each supplier may process your information.

9.  Changes to this policy

We reserve the right to update this privacy notice from time to time so please do check it each time you submit any personal data to us.

10 Contact details

If you have any questions or comments about this Privacy Policy or our privacy practices, please contact us by using the following contact details:

Festival Modem d.o.o.
Donje primislje 11
47240 Slunj



Definitions and legal references

Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)
The service provided by this website as described in the relative terms (if available) and on this site/application.

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookies are Trackers consisting of small sets of data stored in the User’s browser.

Tracker indicates any technology – e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – that enables the tracking of Users, for example by accessing or storing information on the User’s device.

Log files
Refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Refers to, accessible from:

The natural accessing or using the website, or the company, or other legal entity on behalf of which such individual is accessing or using the website, as applicable.

Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the website.

Legal information
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy relates solely to this Application, if not stated otherwise within this document.