We hereby inform you on Our current privacy policies and practices applicable to the processing of your personal data (‘Personal Data’) collected by Espiral Imparavel Lda through Modi-fy’s Website/WebApp (the ’Website’).


Modi-fy ( is a Website/WebApp operated by Espiral Imparavel Lda.

For any queries you may contact Us at, directly on Our website form or through Our live chat tool.


This Privacy Policy describes the Personal Data We may collect from you, the processing of such Personal Data and your rights in relation thereto.


The term Personal Data refers to the data you provide to Us through the Website and may vary depending on the type of relationship you have with Us. Personal Data include:


The information systems and software procedures used to operate this Website acquire personal data as part of their standard functioning. The transmission of such data is an inherent feature of Internet communication protocols. This data category includes, among other things, the IP addresses and/or the domain names of the computers and terminal equipment used by any user, the location of the devices, the URI/URL (Uniform Resource Identifier/Locator) addresses of the requested resources, the time of such requests, the method used for submitting a given request to the server, returned file size, a numerical code relating to server response status (successfully performed, error, etc.) and other parameters related to the users’ operating system and computer environment.


If you decide to create an account on the Website, you may be required to provide Us your Personal Data such as name, e-mail address and password with the submission of the registration form. You may also include additional Personal Data such as your username.


All the payments for the purchases you perform on Our Website are processed by third party payments gateway providers therefore We do not collect or store debit/credit card details or any other payment means data. The payment gateway providers we work with are world leading providers, however if you have any concerns or require any additional information, please refer to the providers’ own websites. 


When you contact Us through, or through Our live chat tool you may be required to provide Us your Personal Data such as name, email address and, at your own discretion, other information you decide to share with Us, that We may collect from you. 


We use cookies and similar technologies or tools to collect information about your activities on Our Website, including to use social media features or services on Our Website which may enable you to connect with Our social media pages or share any promotional activities with your friends and social networks. Detailed information on the cookies We use and the purpose for which We use them are set out in Our Cookie Settings.


Your Personal Data will be collected and processed for the following purposes:

Categories of data: Purposes of processing Legal basis:
Browsing data To extract statistical information on service usage (most visited pages, visitors by time/date, geographical areas of origin, etc.) and to check the functioning of the services. It is Espiral Imparavel’s legitimate interest to analyse and improve the performance of its services and to prevent crimes and frauds (Art. 6(1)(f) of the GDPR). We will analyse your Personal Data in order to improve Our services and your experience with Our Website (where your consent is not required, Art. 6(1)(a) of the GDPR).
Registration/creation of the profile To process the creation of your account and profile on the Website and to provide or allow you to access certain areas, functions and features of Our Website. Necessary for the performance of a contract to which you are party or in order to take steps at your prior to entering into a contract (Art. 6(1)(b) of the GDPR).
Biographical data, financial information and billing details To provide you with the products and/or services you purchased or subscribed to, as well as processing transactions and payments in connection therewith. Necessary for the performance of a contract to which you are party or in order to take steps at your prior to entering into a contract (Art. 6(1)(b) of the GDPR).
For administrative purposes connected with the performance of the commercial relationship with you or the fulfilment of legal requirements (e.g., accounting or tax requirements) or for complying with any requests from the competent authorities. Compliance with a legal obligation to which We are subject (Art. 6(1)(c) of the GDPR) or, in the event there is no such legal obligation, Our legitimate interest to keep adequate records in connection with the execution of the commercial relationship (Art. 6(1)(f) of the GDPR).
Account and contact details To contact you with information about current or new products, commercial opportunities, promotions and services or events sponsored by us that may be deemed to be of interest to you, as well as to verify customer satisfaction and to carry out market research, analysis and surveys, and also to allow you to participate into prize contests, rewards, trips and/or receive gifts. Your consent (Art. 6(1)(a) of the GDPR).
To respond to your queries and questions and to provide any information you require (e.g., information and suggestion about products) in the ‘Contact Us’ section. It is Espiral Imparavel’s legitimate interest to provide customer service and respond to your queries (Art. 6(1)(f) of the GDPR).

The submission of your Personal Data is not mandatory. Any refusal to provide the consent will not have any effect other than Our inability to provide you the products and/or services. In such situation, We shall not be liable for any losses, liabilities and damages whatsoever and howsoever arising thereof. At any time, you have the right to withdraw your consent. The withdrawal of consent shall not affect the lawfulness of processing based on consent before the withdrawal.


Your Personal Data are processed by Our personnel and, if necessary or functional to fulfilling the purposes indicated above, your Personal Data may be processed by third parties that may be appointed by Us as data processors.

The categories of recipients to whom your Personal Data may be disclosed to are as follows:

  1. Third parties such as (i) IT providers; (ii) financial institutions or payment gateway providers in connection with the processing of financial and payment information; (iii) marketing agencies to carry out marketing campaigns, surveys and promotions; and (iv) legal, accounting, tax, labour consultants and other professionals; and
  2. Public entities and authorities, exclusively for the purpose of fulfilling legal and regulatory obligations.

Under certain circumstances, your Personal Data may be transferred outside the European Economic Area (EEA) to third party’s data processors. In such cases, We ensure that We have adopted appropriate safeguards, including binding corporate rules or standard data protection clauses adopted by the European Commission, in order to guarantee the data subjects with an adequate level of protection. You may obtain a copy of these appropriate or suitable safeguards when contacting Us at the contact details above.


Data are retained as long as necessary for the performance of the services provided by the Website and to comply with legal obligations (including, auditing or taxation purposes), to meet regulatory requirements, resolve disputes, maintain security, and/or to prevent frauds and abuse.

In relation to Personal Data of your profile, We will retain the same as long as your account with Us is still active. If you choose to close the account or if your account is closed, We will delete your Personal Data and information within thirty (30) days. This is without prejudice to Our right to retain the information (such as username and transaction details) to comply with legal obligations, prevent frauds and protect Our legal interest.


We treat the security for all information submitted or provided by you to Us seriously and is of importance to Us. We will take reasonable steps to protect or secure this data, including your Personal Data. Accordingly, We may require Our employees or third-party service providers to assist Us in implementing or applying appropriate securities measures (such as firewalls, penetration testing and etc). You are also advised not to disclose and secure your own username and password.


You have the right to obtain from Us confirmation whether your Personal Data are being processed by Us, and, in said circumstances, you have the right to request access to and rectification or erasure of the same or restriction of processing, and to object to the processing at any time, as well as under certain circumstances the right to data portability. With respect to the data portability, you have the right to receive your Personal Data in a structured, commonly used and machine-readable format and to request the transmission of said data.

With respect to the right to object where the processing is based on Our legitimate interest, you can object to the processing at any time and We will cease processing your Personal Data unless we have a compelling legitimate reason to continue such processing or where the processing is needed for legal reasons. In addition, you can object to the processing of your Personal Data in the circumstance such as where We are processing the Personal Data for direct marketing purposes.

If you have subscribed to or opted-in to receive Our marketing communications you can opt-out at any time through the ‘Settings’ section, free of charge, requesting that your Personal Data not be used for marketing purposes.

You may exercise any of the above rights by contacting Us at


Our Website or any products/services being rendered to you may contain links to other websites that are not operated by Us and whose privacy practices may differ from Us. If you click on a third-party link, you may be directed to the third party website. Any submission of your Personal Data to any of those third-party websites will be governed by the relevant third-parties’ privacy policies. We have no control and shall not assume any responsibilities howsoever arising thereof and We strongly advise you to carefully read the privacy policies prior to the disclosure of any information.


We may, from time to time, partner with a third party to display Our or a third party’s advertisement(s) on Our Website or engage a third party to manage Our advertising on Our Website. For more detailed information, please refer to Our Cookie Setting. 

Mobile Applications or Mobile Website

We may provide Our products or services to you via our mobile applications or mobile website that is designed to be used on mobile computing devices (the ‘Applications’). You may be required to log in to Our mobile applications or mobile website with your username and password in order to allow you to associate with the user account you have created on Our Website. The processing of Personal Data information therein will also be governed in accordance with this Privacy Policy and Our Cookie Settings.

In addition to the above, you may opt-out of personalised advertising by adjusting the settings on your mobile device.

  • For iOS mobile devices:

Go to ‘Settings’ on your mobile device > scroll down to ‘Privacy’ > select ‘Advertising’ > turn on ‘Limit Ad Tracking’.

  • For Android mobile devices:

Go to ‘Settings’ on your mobile device > scroll down to ‘Google’ > select ‘Ads’ > turn on ‘Opt-out of Ads personalisation’.

Please be aware that such an opt-out will disable all personalised ads on applications which use IDFA and Google Android Advertising ID. This does not mean you will not see advertisement. You will see advertisements that are not personalised to you.


We will keep this Privacy Policy under regular review, and We may update this Privacy Policy from time to time. The updated version shall apply and supersede all previous versions. Hence, it is advisable that you check this Privacy Policy on a regular basis.