Privacy Policy · Modo Survival

1. Data controller

• Owner: UBBIESTUDIO OÜ
• Tax identification (TIN): 16911979
• Address: Järvevana tee 9, 11314 Tallinn, Estonia
• Email: info@modosurvival.com
• Domain: modosurvival.com

2. Purpose of processing

In compliance with the EU General Data Protection Regulation (GDPR), users are informed that data they provide will be processed for the following explicit purposes:

• Responding to enquiries sent by email or, where applicable, through contact forms enabled on the website.
• Managing registered member accounts (access, email verification, optional community preferences such as lists or loadouts).
• Recording outbound affiliate link clicks in anonymised form (no raw IP addresses; optional internal account identifier when signed in) for editorial measurement, commission attribution and service improvement.
• Managing technical cookies, language preferences and cookie banner consent records. We do not deploy third-party analytics cookies on the current version of the site.
• Managing newsletter or promotional communications subscriptions only when the user has given unambiguous consent through a positive action (for example, checking a box on a subscription form).

3. Legal basis

The legal basis is: (i) explicit consent when the user takes a positive action (forms, registration, newsletters); (ii) pre-contractual or contractual necessity when contacting us or maintaining a member account; (iii) legitimate interest in anonymised affiliate click measurement and service security, balanced against your rights; (iv) legal obligation where applicable.

4. Recipients and data transfers

Captured data will not be sold, assigned or communicated to third-party commercial entities under any circumstances, except where expressly required by law. When a user follows an affiliate link to an external merchant, we do not transfer their commercial profile to that merchant; attribution is technical on the destination site.

For proper infrastructure provision, data is managed through trusted technology providers under strict confidentiality agreements, including web hosting provided by Hetzner Online GmbH.

5. Data subject rights

Any person has the inalienable right to exercise Access, Rectification, Erasure (right to be forgotten), Restriction of processing, Objection and Data portability. To exercise these rights, the user must send written communication to info@modosurvival.com with reliable proof of identity.

For more detail on cookies, see our Cookie Policy.

6. Categories of personal data

• Contact data: name, email address, and message content when you write to us.
• Member account: name, email, password (stored hashed), email verification timestamp, and optional community data (lists, loadouts, votes or submissions when you use those features).
• Affiliate click measurement: internal product and vendor identifiers, visit locale, timestamp, anonymised visitor signal (hashed, no raw IP), and, if signed in, your internal account identifier.
• Technical data: server logs and security events, limited to what is necessary to operate the service.

7. Retention periods

• Email enquiries: until resolved and, as a rule, up to 24 months unless a longer legal retention applies.
• Member account: while the account remains active; after deletion request or closure, erasure or anonymisation within a reasonable period (typically 30 days) unless legally blocked.
• Affiliate click logs: kept for aggregated editorial measurement; account-linked identifiable data is removed with the account.
• Server technical logs: rotated after a few months unless required for a security investigation.

8. Processors and transfers

We use processors that handle data on our behalf under GDPR Article 28 agreements, including:

• Hetzner Online GmbH — web hosting, database, and transactional mail within the EU / EEA.
• SMTP mail provider — account verification and operational messages from modosurvival.com.

We do not sell personal data. External merchants (Amazon and others) are independent controllers when you visit their site after an affiliate link.

9. Supervisory authority and complaints

You may exercise your rights by emailing info@modosurvival.com. We will respond within the applicable legal timeframe (usually one month, extendable).

You have the right to lodge a complaint with the supervisory authority in your EU country of residence. As an Estonian controller, the lead authority is the Andmekaitse Inspektsioon (Estonian Data Protection Inspectorate). Consumers in Spain may also contact the Spanish Data Protection Agency (AEPD) where applicable.

For the internal record of processing activities (ROPA) and the operational GDPR request procedure, see the operator documentation in the project repository under docs/compliance/.