Last updated: 18th September 2024
- •Modoyo safeguards your personal integrity
- •Controller
- •Which personal data does Modoyo process?
- •What is the purpose and legal basis for Modoyo's processing of your personal data?
- •How long does Modoyo store your personal data?
- •With whom does Modoyo share your personal data?
- •Transfer of personal data to third countries
- •Social Media
- •Your rights
- •Security of your personal data
- •Cookies
- •Advertising partner's and other parties' privacy policies
- •Children's information
- •If you do not share your personal data with the company
- •Changes
- •Contact information
Modoyo AB, corp. reg. no. 559252-7625, Tjärhovsgatan 34, 116 21 Stockholm, Sweden, (”Modoyo”) respects your privacy and is committed to maintaining a high level of security and integrity regarding your personal data. Modoyo is also committed to ensuring that processing is carried out in accordance with applicable data protection legislation. This Privacy Policy describes how Modoyo processes personal data about you in your capacity as a customer or user accessing and/or using Modoyo's games, products and services, or a potential customer or user, a representative of a company that is a supplier or a partner, or a potential supplier or partner to Modoyo, a visitor of Modoyo's website https://www.modoyo.com/, an applicant when you apply for employment with Modoyo, and a shareholder or as a representative of a shareholder or as a holder or a representative of a holder of other financial instruments that can be converted to or that entitle to subscribe for shares in Modoyo (“Shareholder”). Do not hesitate to contact us should you have any questions regarding our privacy protection. Modoyo's contact information is set out under the section “Contact Information”.
Modoyo is the controller of your personal data and is therefore responsible for ensuring that your personal data is processed correctly and securely in accordance with applicable legislation.
Modoyo collects and stores the following information about you that Modoyo needs to contact you and to fulfil its undertakings toward you as a customer and user of Modoyo's games, products and services.
The provision of certain personal data to us described in this privacy policy may be a statutory or contractual requirement under a contract to which you are party. If you do not share such personal data with Modoyo, Modoyo may not be able to fulfil its legal or contractual obligations towards you.
Personal information and contact information that can be used to identify you, such as name, personal identity number, address, telephone number and email address.
Account information meaning information that is associated with your customer profile at Modoyo, such as usernames, passwords, security questions and what games, products and services you use and/or have access to.
Payment information such as your payment and transaction history with Modoyo, your payment information e.g., credit or debit card information, bank information, account number and, where applicable, IBAN, SWIFT etc.
Information in communications with Modoyo, information that you provide to Modoyo by email, via Modoyo's social media or by other channels of communication and, where applicable, information regarding phone calls with Modoyo's switchboard or customer service.
Customer satisfaction information, such as information from customer surveys and evaluations, customer complaints, support or warranty matters.
Usage and behavioural information, such as information about how you use or intend to use our games, products and services including information about time spent playing and how and when you have accessed and interacted with our games or services as well as technical information such as errors, bugs or technical performance.
This information is collected to allow Modoyo to better understand which features and services are most engaging, relevant and useful to our customers and users and to communicate with you about relevant and up-to-date information and marketing.
Device information, such as which device and other technology has been used to access our games, products and services, including your internet protocol (IP) address, MAC Address, URL, unique device ID as well as your login data, network ID, network and device performance, browser type and version, hardware information, time zone settings, language settings, geographical location, browser plug-in types and versions, operating system and other technology on the device you use as well as other data from cookies or similar mechanisms. In cases of a malfunction, error or interruption on your device, technical data may also include specific device information, such as the location of the file on your device.
Events and meetings, where applicable, information regarding dietary preferences, potential allergies and/or disabilities (e.g. in connection with corporate events or meetings).
With respect to our customers and users, your personal data is usually provided directly from you, but also, in certain cases, through other sources such as our suppliers and partners.
Modoyo collects and stores the following information about you that Modoyo needs to contact you in your capacity as a representative for a company or organisation.
- Personal information and contact information, such as name, address, telephone number, email address, title, position and employer.
- Information in communications with Modoyo, information that you provide to Modoyo by email, via Modoyo's social media or by other channels of communication and, where applicable, information regarding phone calls with Modoyo's switchboard or customer service.
- Supplier or partner agreements, certain personal data included in agreement with our suppliers and partners, for example contact information to designated contact persons or names of the individuals signing the agreements.
- Events and meetings, where applicable, information regarding dietary preferences, potential allergies and/or disabilities (e.g. in connection with corporate events or meetings).
Modoyo collects and stores the following information about you in your role as a potential customer, supplier or partner to Modoyo or in your role as a representative for a company that is a potential supplier or partner to Modoyo. Modoyo needs such information to contact you and to fulfil its undertakings toward you as a potential customer, supplier or partner or in your capacity as a representative for a potential supplier or partner.
Personal information and contact information, such as name, address, telephone number, email address, title, position and employer.
With respect to suppliers and partners and company representatives for suppliers and partners and potential suppliers and partners and company representatives for potential suppliers and partners, your personal data is usually collected from the company or organisation that you represent, but also, in certain cases, directly from you, e.g. by email, our social media or other channels of communication or in connection with events or meetings. Modoyo may also receive personal data about you from other partners of Modoyo. Modoyo may also use external information services to supplement existing data, e.g. with your position and contact information.
In connection with visits to Modoyo's website, Modoyo collects the following information about you that Modoyo needs to be able to improve, streamline, simplify and develop our website.
Technical data and device information, such as IP address, MAC address, URL, unique device ID, network and device performance, browser, language and identification settings, geographic location, operating system, other information from cookies or similar mechanisms (device information).
Modoyo collects and stores the following information about you that Modoyo needs to be able to recruit the right persons for positions with Modoyo.
- Personal information and contact information, such as name, address, telephone number, email address, title, position and employer.
- Information in cover letter and CV.
- Where applicable, your picture.
- Other information that you provide Modoyo in connection with recruitment.
With respect to job applicants, your personal data may be provided to Modoyo directly from you or from the staffing agency, recruitment company or hiring company through which you apply for work.
Modoyo collects and stores the following information about you in your role as a Shareholder.
- Personal information and contact information, such as personal identification number, name, address, telephone number, email address, and position.
- Holdings of shares or other financial instruments.
- Information on financial instruments, e.g. information regarding voting rights at general meetings of shareholders, shareholding and rights relating to the ownership.
- Information regarding proxies representing Shareholders, where applicable.
- Information regarding trustees, pledges and pledgees, where applicable, and other notes in the share register.
- Other information that has been provided by you or the organisation that you represent.
The purposes for which we intend to process your personal data and the legal basis for the respective processing activities are stated below.
Purpose
Legal basis
To register and administrate a customer profile and to be able to offer a safe, secure and legal service.
The processing is necessary for the performance of the agreement with the customer.The processing is necessary for compliance with Modoyo's legal obligations.
To be able to keep in touch with the customer, either through Modoyo’s games, products and services or the customer support.
The processing is necessary for the performance of the agreement with the customer.
To enable marketing and communication about Modoyo's brand and Modoyo’s games, products and services (e.g. mailing of newsletters and other marketing materials, invitations to Modoyo's events, meetings and other gatherings etc.).
The processing is necessary for Modoyo’s legitimate interest to market its brand, games, products and services and other similar products and services to you as a customer (legitimate interest).
To carry out surveys regarding Modoyo’s games, products and services as well as customers’ experiences and satisfaction.
The processing is necessary for Modoyo’s legitimate interest to evaluate, develop and improve its brand, its products and its marketing (legitimate interest).
To ensure payment and analyse purchase history in order to offer customers the right products and marketing.
The processing is necessary for the performance of the agreement with the customer. The processing is necessary for Modoyo’s legitimate interest to offer its customers relevant marketing with regard to the customers previous purchases (legitimate interest).
To receive payments from customers in connection with purchases of Modoyo’s games, products and services.
The processing is necessary for the performance of the agreement with the customer.
To be able to respond to and compensate customers in connection with complaints and warranty matters.
The processing is necessary for the performance of the agreement with the customer.
Purpose
Legal basis
To enable marketing and communication about Modoyo's brand and Modoyo's games, products and services (e.g. mailing of newsletters and other marketing materials, invitations to Modoyo's events, meetings and other gatherings etc.).
The processing is necessary for Modoyo’s legitimate interest to market its brand, games, products and services and other similar products and services to you as a customer (legitimate interest).
Purpose
Legal basis
To ensure the operation of Modoyo's website and application. To ensure the operation of Modoyo's website and application.
The processing is necessary for Modoyo’s legitimate interest to improve, streamline, simplify and develop its website and to attract more customers/partners and to increase the number of recurring customers/partners (legitimate interest).
Purpose
Legal basis
To, in connection with recruitment, be able to decide who is best suited for a position with Modoyo and to ensure that the relevant person has the necessary skills.
The processing is necessary for Modoyo’s legitimate interest to recruit the right employees and ensure that skilled people work for Modoyo (legitimate interest).
Purpose
Legal basis
To fulfil Modoyo’s obligations to you as a Shareholder according to Modoyo’s articles of association.
The processing is necessary for Modoyo’s legitimate interest to recruit the right employeThe processing is necessary to fulfil Modoyo's contractual obligations to you in accordance with the articles of association (performance of agreement). Regarding representatives of Shareholders, the processing is necessary for Modoyo's legitimate interest in fulfilling its contractual obligations towards its Shareholders (legitimate interest).es and ensure that skilled people work for Modoyo (legitimate interest).
To fulfil Modoyo's obligations to you and other Shareholders in accordance with the Swedish Companies Act or other applicable legislation.
The processing is necessary to fulfil Modoyo's legal obligations under the Swedish Companies Act or other applicable legislation (legal obligations). Regarding representatives of Shareholders, the processing is necessary for Modoyo's legitimate interest in fulfilling its contractual obligations towards its Shareholders (legitimate interest).
Distribution of shareholder-related information
The processing is necessary in order for Modoyo to be able to inform Shareholders and other stakeholders in a timely and correct manner about information relevant to Modoyo (legitimate interest).
Your personal data is stored as long as there is a need to preserve them in order to fulfil the purposes for which the data was collected in accordance with this Privacy Policy. Thereafter, your personal data will be deleted.
Some personal data will, for the purpose of complying with applicable accounting legislation, be stored for seven years, counting from the end of the calendar year during which the financial year, to which the information pertained, was terminated.
Contact information regarding company representatives is stored during such time Modoyo considers that the information is necessary to maintain the relationship with the company/organisation. Deletion shall take place when Modoyo becomes aware that the information is no longer adequate or relevant for the purpose, or at the request of the contact person.
For more information about how long Modoyo stores specific personal data, please contact Modoyo. Contact information is provided under section "Contact" below.
The company does not disclose personal data to third parties, except when necessary to fulfil a legal obligation or to fulfil Modoyo's obligations to you, customers and/or partners. Your personal data will not be sold to third parties for marketing purposes. Situations when your personal data may be disclosed to third parties are listed in the table below.
Third party
Reason for third-party disclosure
Suppliers of cloud solutions
Personal data may be transferred to suppliers of cloud solutions since Modoyo stores certain information in cloud solutions.
Suppliers and partners
Modoyo may disclose your personal data to suppliers and/or partners, if the suppliers and/or partners need your personal data to fulfil their undertakings toward Modoyo.
Authorities
Personal data may be disclosed to authorities when necessary for compliance with Modoyo’s legal obligations.
Sale
If Modoyo intends to transfer all or part of its business, personal data may be disclosed to a potential buyer.
The public
Modoyo's share register is public and held available at Modoyo for anyone who wishes to take part of it. The information contained in the share register is therefore disclosed upon request. Minutes and voting list from the general meetings of shareholders may be disclosed to the Shareholders present at the meeting as well as to the Swedish Companies Registration Office, auditors and others to whom Modoyo has a legal obligation to disclose the minutes or otherwise considers it appropriate to disclose the minutes.
Modoyo may transfer your personal data to countries outside the EU/EEA. If your personal data is transferred to a country outside the EU/EEA, Modoyo will take the necessary measures to ensure that the transfer of the personal data is legal and that your personal data is processed securely and with an adequate level of protection that is comparable to the protection offered within the EU/EEA, for example by entering into the European Commission's standard contract clauses with the recipient. If you wish to obtain a copy of the standard contractual clauses, please contact us. Modoyo's contact information is set out under the section “Contact Information” below).
The table below shows to which countries Modoyo may transfer your personal data and the relevant statutory safeguard relied on.
Country outside the EU
Statuatory safeguard
USA (For example, our suppliers and partners AWS, Qualtrics and G Suite or Google Workspace)
The standard data protection clauses adopted by the EU Commission, GDPR Article 46.2 (c).
Regarding personal data that occurs and is processed on social media, such as Discord, Facebook, Twitter, LinkedIn, Reddit, TikTok, Instagram, and Youtube, we refer users to the policy provided by the respective service providers for information on how each service provider processes personal data. In Modoyo's view, the purpose of the processing is that representatives of existing and potential customers and partners to Modoyo shall be able to interact and maintain contact with Modoyo via social media, in order to contribute to good relationships with customers and partners and to make Modoyo's customer service and product widely accessible through several different channels. The processing is necessary for the purposes of Modoyo's legitimate interest to market its brand and its products to existing and potential customers and to partners (legitimate interest).
Right of access
You have the right to access your personal data and to obtain a copy of the personal data concerning you that is processed by Modoyo.
Right to rectification
If the personal data concerning you that is processed by Modoyo is inaccurate, incomplete or outdated, you have the right to obtain rectification of such personal data.
Right to erasure
You have the right to request the erasure of personal data concerning you. Unless Modoyo has a legal basis to continue the processing of the personal data concerning you, such personal data shall be erased.
Right to object
Under certain circumstances you have the right to object against Modoyo’s processing of your personal data.
Right to restriction of processing
Under certain circumstances you have the right to obtain restriction of the processing of your personal data. Where processing has been restricted, Modoyo may only under certain circumstances carry out other processing activities concerning the personal data than storage.
Right to data portability
Where your personal data is processed based on your consent or on a contract with you, you have the right to receive the personal data concerning you in a machine-readable format and request that those data are transmitted to another controller.
Right to lodge complaints with a supervisory authority
You have the right to lodge complaints concerning Modoyo’s processing of the personal data concerning you to the Swedish Authority for Privacy Protection, Box 8114, SE-104 20 Stockholm.
You should always be able to feel safe when you provide us with your personal data. Therefore, Modoyo has implemented the security measures that are necessary to protect your personal data against unauthorised access, alteration and destruction. Modoyo will not disclose your personal data, other than as expressly provided by this Privacy Policy.
Modoyo does not use cookies on our website or in our services.
Third-party ad servers or ad networks uses technologies like cookies, JavaScript, or Web Beacons that are used in their respective advertisements and links that appear on Modoyo, which are sent directly to users' browser. They automatically receive your IP address when this occurs. These technologies are used to measure the effectiveness of their advertising campaigns and/or to personalize the advertising content that you see on websites that you visit.
Note that Modoyo has no access to or control over these cookies that are used by third-party advertisers.
Modoyo's Privacy Policy does not apply to other advertisers or websites. Thus, we are advising you to consult the respective privacy policies of these third-party ad servers for more detailed information. It may include their practices and instructions about how to opt-out of certain options.
You can choose to disable cookies through your individual browser options. To know more detailed information about cookie management with specific web browsers, it can be found at the browsers' respective websites.
Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.
Modoyo does not knowingly collect any personal data from children under the age of 13. If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.
If you do not share your personal data with Modoyo, Modoyo will not be able to fulfil its legal or contractual obligations towards you. For Shareholders, this means that you will not be able to exercise your rights as a Shareholder, including attending and voting at general meetings.
Modoyo reserves the right to change this Privacy Policy at any time. In the event of changes to this Privacy Policy, Modoyo will publish the amended Privacy Policy on https://www.modoyo.com/ with information on when the changes will come into effect and may also notify customers and partners in an appropriate manner.
Do not hesitate to contact Modoyo if you have any questions about this Privacy Policy, the processing of your personal data or if you wish to exercise your rights under this Privacy Policy or applicable legislation.
Modoyo AB
Corporate registration number: 559252-7625
Postal address: Tjärhovsgatan 34, 116 21 Stockholm, Sweden
Email address: privacy@modoyo.com