Last updated: 28 February, 2022
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).
1. Abouts Us
Our website, http://modemfestival.com 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
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
For more information about cookies, visit allaboutcookies.org.
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.
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: firstname.lastname@example.org 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
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
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
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.
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.
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.
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.
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
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 email@example.com 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: https://www.facebook.com/momento.demento.psytrance, 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
4 Grand Canal Square, Grand Canal Harbour, Dublin 2,Dublin, D02X525, Ireland
8. Links to other websites
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
Festival Modem d.o.o.
Donje primislje 11
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)
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.
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 modemfestival.com, accessible from: http://modemfestival.com
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.
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).