Privacy Policy

Privacy Policy Website and Mobile Diagnostics Application by MODI Abrites 

Last updated 26/03/2025. Replaces all prior versions. 

1. Introduction 

1.1. MODI by Abrites is a car diagnostics solution by MODI Abrites Ltd. (“limited liability company”), UIC 207885431 - a company incorporated under the laws of Bulgaria and having its seat and registered address of management in Sofia, 147 Cherni vrah Blvd. – "MODI Abrites", "the Company", "we" or "us" (“Provider”). The marketing website and online store for purchasing the solution is https://modiobd.com (“the Website” or “our Website”).  

1.2. We understand that you are aware of and care about your own personal data and privacy, and taking that seriously, we are committed to providing you with safe and secure experience while using our services.  

1.3. This Privacy Policy ("the Policy") sets out the basis on which we process your personal data in our capacity as personal data controller, as defined in Regulation (EU) 2016/679 ('the General Data Protection Regulation" or "the GDPR") in connection with your using the Website https://modiobd.co​m. Please, read the following Privacy Policy carefully to understand our views and practices regarding your personal data and how we will treat it. 

I. Definitions 

a. "Cookie" – a small text file that is placed on your device when you visit the Website. 

b. "Controller" - 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. MODI Abrites will be Personal Data Controller when processing your Personal Data.  

c. "Data Subject" - any individual who is identified or identifiable and to whom personal data relate.  

d. "EEA" – the European Economic Area. 

e. "EU" – the European Union. 

f. "GDPR" – the General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC). 

g. "Personal Data" - any information relating to an identified or identifiable individual; an identifiable individual is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual. 

h. "The Website" - is the web application https://modiobd.com, the code on which it runs, the corresponding Graphic User Interface, and all copyrightable APIs and plug-ins/extensions, and scripts owned and operated by MODI Abrites in connection with https://modiobd.com​ ​. 

i. "The MODI (Mobile Diagnostics) Application" - is the software application, the code on which it runs, the corresponding Graphic User Interface, and all copyrightable APIs and plug-ins/extensions, and scripts owned and operated by MODI Abrites where the Service is offered, whether in its web or mobile version. 

j. "Processing" - any operation or set of operations which is performed on Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. 

k. "Profiling" means any form of automated processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to an individual, in particular to analyse or predict aspects concerning that individual's personal preferences, interests, reliability, behaviour, location or movements, etc. 

l. "The Services" is MODI Abrites’ car diagnostics services offered through its MODI Mobile Application and the MODI OBDII Device. 

m. "You" means the user of the Services having an Account with the Website or a visitor to the Website who is only browsing around. 

n. "Your Account" means all your Personal Data and any other information which is filled in by you upon your registration on the Website https://modiobd.com​ ​, as amended from time to time, including, without limitation, your name and surname, password (​ ​​ ​encrypted), address for delivery, phone number, eMail, country of residence, any payments you made. Your account in its entirety is only visible and accessible to you and, on occasion and for the purposes defined in the Terms of Use, this Policy, or the law, to MODI Abrites. 

All capitalised words which are not defined hereof shall have the meaning ascribed to them in the Terms of Use and/or in the GDPR, respectively.

2. What kind of Personal Data do we process? 

1.1. Identification Personal Data, registration, subscription and authentication.

When you purchase a subscription, it is available exclusively through the Apple or Google Store. When purchasing a subscription from these stores, you use your existing Apple or Google account, and we do not have access to any additional personal data. You purchase a MODI OBDII Device through our Website, and you provide us with your username and eMail, name and surname, address for delivery, phone number, and password (encrypted).  

1.2. We will also have access to your payment method with limited details (but not to your sensitive payment data). To shop on our website you do not need to register​ ​, but you may still wish to do so to have your orders in one place. 

1.3. When you choose your subscription plan and activate it with your subscription account, you agree with the Apple’s and Google’s privacy policies. 

3. Processing of Personal Data for marketing purposes 

We may process your e-mail address to provide you with Marketing e-mails about new releases or similar Services of MODI Abrites to the ones you already use and important system or delivery notices. You can unsubscribe from receiving marketing e-mails at any time by following the link provided in your eMail or by adjusting the settings on your device, respectively. 

4. Processing of Personal Data to perform the Services you requested 

We will also collect information on the vehicle model, brand, and vehicle identification number (VIN), which is automatically identified and sent to our servers for logging diagnostic data from your vehicle. This data is used to maintain the proper functionality of the application, provide support when needed, and help users with specific problems. 

5. How do we collect the Personal Data? 

Your Personal Data is generally collected from you directly. When creating your Account with the Website, you provide us with the data necessary for the delivery. In this way we obtain your Personal Data. 

6. Do we share your Personal Data with third parties? 

To be able to send you our products, which you purchased from us, we must provide the delivery companies your personal information, such as: your name and surname, shipping, billing address and telephone number. 

We provide these shipping methods: 

• Standard shipping. Package will be sent via Deutsche Post (MODI Abrites Ltd., company code:207885431, address: 1407, Sofia, Cherni vrah 147 blvd.) 

• Express shipping. Package will be sent via DHL express (MODI Abrites Ltd., company code:207885431, address: 1407, Sofia, Cherni vrah 147 blvd.) 

 
7. Cookies 

Cookies are widely used by website owners who aim to make those provide various functions, or to work more efficiently, as well as to provide reporting information. There are various types of Cookies which are differing in their purposes, data processed and domain where the data is stored. We classify the Cookies that we use on our Website in the following categories: 

​​A. Strictly Necessary Cookies –These Cookies are necessary for the Website to function and cannot be switched off in our systems. They are usually connected to responses to actions made by you, e. g. a request for services such as setting your privacy preferences, logging in or filling in forms.

B. Functional Cookies – These Cookies enable the Website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these Cookies, then some or all of these services may not function properly. 

C. Analytics Cookies - These Cookies allow us to count visits and traffic sources so we can measure and improve the performance of the Website. They help us to know which pages are the most and least popular and see how visitors move around the Website. All information these Cookies collect is aggregated and therefore anonymous. If you do not allow these Cookies we will not know when you have visited the Website and will not be able to monitor its performance.

E. Marketing Cookies – these Cookies are used to serve personalised ads to visitors of the Website and to make Marketing more effective. 

Except from the Strictly Necessary Cookies, all the other Cookies we use require obtaining your prior consent. Thus, we will process Personal Data via these Cookies only after you opt in to be tracked by those.

8. Purposes of Processing 

We process the Personal Data from your Account to provide you with the Services, delivery of your purchased items and enable you to use the Website. 

We pursue Marketing of our services when processing your e-mail address for marketing purposes. 

With the same purpose we use Cookies for analysing the Website traffic and enabling performance statistics, as well as improving the performance of the Website. 

9. Lawfulness of the Processing 

All processing operations with your Personal Data that we carry out have legal basis. Therefore, we observe the GDPR principle of lawfulness of the Processing.  

The Personal Data from your Account and in relation to your vehicle is processed to perform our contractual obligation under the ​Terms of Use to​ provide you with the Services and enable you to use the Website. Thus, the legal basis for the processing of this Personal Data is Art. 6 (1) (b) of the GDPR: the processing is necessary for the performance of a contract to which the Data Subject is party or to take steps at the request of the Data Subject prior to entering a contract. 

​​Processing for marketing purposes will be initiated after we obtain your consent and therefore our legal basis is Art. 6 (1) (a) of the GDPR: the Data Subject has given consent​ to the processing of his or her Personal Data for one or more specific purposes. In exceptional cases, we may conduct processing for marketing purposes without your prior consent if it is allowed by law.  

If we process any Personal Data by using Cookies, we will also do that after obtaining your prior consent through our consent panel, so we base this processing on Art. 6 (1) (a) of the GDPR. 

10. How long do we keep the Personal Data? 

We will keep your account-related Personal Data while you maintain your Account with the Website. For non-registered users, personal data which we no longer need in order to fulfil the objectives of the law will be deleted immediately after fulfilling its purpose, such as completing the delivery​ ​. Once you delete your Account or MODI Abrites terminates it as provided in the Terms of Use, we will cease to process your Personal Data we do not need and will erase it.  

The processing terms for personal data collected by cookies is specified under section V above. 

Please, be informed that we will keep some of your Personal Data within the statutorily defined terms for tax, social security or anti-money laundering purposes and we will not erase it when you delete your Account if such retention is prescribed by law.  

11. Sharing your Personal Data with our Partners 

We may use third-parties' products, solutions, or services such as hosting or payment services that may lead to processing of Personal Data. In these cases, we have Data Processing Agreements executed with said service providers. 

12. Transferring Personal Data outside the EU/EEA 

MODI Abrites does not transfer your Personal Data outside the EU/EEA or countries whose personal data protection has been proclaimed as adequate by the European Commission, like the USA under the Privacy Framework. Our servers, where the MODI Application is hosted, are located in Sofia, Bulgaria. However, our Website is hosted by SiteGround in a data center in the Netherlands, where all website-related data is processed and stored. Both locations are within the EU and comply with GDPR requirements, ensuring that your personal data is handled securely and lawfully. 

13. Security 

We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with the GDPR. There is no absolute guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. Therefore, we cannot guarantee its absolute security. While no security system is 100% penetration-proof, we implement appropriate security measures to protect against unauthorized access or disclosure of the information we may collect. Furthermore, adhering to our data security policy, we conduct monitoring for vulnerabilities and security incidents at regular intervals with respect to our systems; we try to maintain our software and ensure we have the necessary updates in place; and use appropriate tools for ensuring that your Personal Data is being processed in a safety manner. 

14. Do we observe the GDPR?

MODI Abrites is a legal entity situated in the European Union. We process Personal Data of users​ ​ and visitors to the Website while providing The Services. Therefore, MODI Abrites shall be defined as a Personal Data Controller as provided in the GDPR. However, for Subscribers, personal data is primarily managed by Apple and Google under their respective privacy policies. Nonetheless, since we have access to order details and the user’s device ID, we may be able to associate this information with it, making it identifiable as personal data. We are committed to ensuring the highest protection standards for your Personal Data. With this aim, we observe strictly the GDPR requirements for implementation of technical and organisational measures, the principles of privacy by default and by design, lawfulness, fairness and transparency, purpose and storage limitation, data minimisation, integrity, confidentiality, and accuracy. Furthermore, we strive to demonstrate accountability and transparency by providing you with detailed information for the processing of your Personal Data. You can find this information in the Policy and the other privacy notices addressed to you while browsing around the Website. GDPR provides Data Subjects with a wide array of rights. Being a Controller, we will respond and assist you when you request from us to exercise any of your GDPR rights concerning the processing related to The Services. We will do that when the respective legal grounds are in place. 

15. Your rights 

You are entitled to exercise the rights you have as a Data Subject under the GDPR. Depending on the specific circumstances concerning your Personal Data that we process when providing the Services, you will have the following rights:  

16. Right to access 

You have the right to obtain from us confirmation as to whether or not Personal Data concerning you are being processed; you are entitled to require information about the purposes of the processing, the categories of Personal Data concerned, etc.; also, you have the right to access to the Personal Data. If a Data Subject files a verifiable request with us we would disclose to him/her and deliver the Personal Data which we process about him/her. We reserve the right to charge the Data Subject for such requests if he/she requires Personal data more than twice in a 12-month period. 

17. Right to rectification

You have the right to obtain from us the rectification of inaccurate Personal Data concerning you and to have incomplete Personal Data completed. 

18. Right to erasure 

You are entitled to request from us to delete any Personal Data about you which we have collected and processed. Please note that one or more carve-outs to the foregoing may apply: 

-We are legally bound to keep the Personal Data for a certain time, or we must comply with another law or legal obligation; for example, we will not erase data that we must keep for tax or social security purposes; 

-We engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the Data Subject has provided informed consent; 

-We process your Personal Data for the establishment, exercise, or defence of legal claims  

-You may request your Personal Data deletion if any of the following circumstances is in place: 

-Your Personal Data is no longer necessary in relation to the purposes for which we collected or otherwise processed it; 

-You withdraw your consent on which the processing is based, and we have no other legal ground for the processing; 

-The Personal Data has been unlawfully processed; 

-The Personal Data must be erased to comply with a legal obligation in the EU or Member State law to which we are subject; 

19. Right to restriction of processing 

You have the right to request from us restriction of your personal data's processing where one of the following applies: 

-You contest the accuracy of your Personal Data; you may require us to restrict the processing of your Personal Data for a period enabling us to verify the accuracy of your Personal Data;

-The processing is unlawful, and you oppose the erasure of your Personal Data and request the restriction of their use instead; 

-We no longer need your Personal Data for the purposes of the processing, but you require them for the establishment, exercise, or defence of legal claims; 

-You have objected to processing pending the verification whether our legitimate grounds override yours. 

20. Withdrawing consent 

You can always withdraw your consent related to direct marketing by clicking the unsubscribe link in any non-business communication from us. The withdrawal of your consent will not affect the lawfulness of processing based on consent before such withdrawal. 

21. Filing appeal with the Data Protection Authority 

You have the right to lodge a complaint with a supervisory authority if you consider that we have infringed the GDPR in processing your Personal Data (for Bulgaria the supervisory authority is the Commission on Personal Data Protection – www.cpdp.bg). 

Any of the abovementioned rights can be exercised if you file a request at https:/modiobd.com/contact-form/create​. The request will be addressed no later than 30 days as of its receipt. Exercising of any of the above rights does not allow MODI Abrites to discriminate against the respective Data Subject. 

22. Your correspondence with us 

If you have a concern or complaint about your privacy, let us know and we will try to fix it. You may also contact us if you want to make us a proposal to improve The Services from privacy perspective. Our contacts are as follows: Since even the best-trained bots are not always helpful, our support team is available for you at:​ ​​https:/modiobd.com/contact-form/create. 

23. Updates 

The Policy will not remain the same during the Website's lifetime. As digitalisation progresses and the regulation of Personal Data processing relations develops, we will strive to constantly improve and adapt our practices to this development, which in turn will be reflected in the Policy. Anytime we make a change to the Policy, we will publish a short notification on the Website.