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Legal

The information provided by The Modiano Group on our websites is for general informational purposes only

Legal

1. Introduction

The Modiano Group operates the following websites as part of a connected group of companies:

This Privacy Policy explains how we collect, use, share and protect your personal data when you visit any of these websites or otherwise interact with us. It applies to all entities within the Modiano Group listed above.

We are committed to handling your personal data responsibly and in compliance with applicable data protection law, including the UK General Data Protection Regulation (UK GDPR), the EU General Data Protection Regulation (EU GDPR 2016/679), and the Czech Act on Personal Data Processing.


2. Who We Are – Data Controllers

The data controller responsible for your personal data depends on which website you are visiting and how you interact with us.

  • G. Modiano Ltd
    11 Grosvenor Place, London SW1X 7HH, United Kingdom. Registered in England and Wales
    ICO registration number: 00019655604
    Contact: privacy@gmodiano.com

 

 

  • Nejdecká Česarna Vlny a.s.
    Nádražní 1267, 362 21 Nejdek, Czechia
    Contact: privacy@ncv.cz

 

 

  • Mediterranean Wool Industries Company SAE
    Sadat City, 7th Industrial Zone, Plot #7058 & 7060, Menofia Governerate, Egypt
    Contact: privacy@mwi.com.eg

Where Group companies act jointly in determining the purposes and means of processing, they may be regarded as joint controllers. Each entity remains responsible for handling data subject requests relating to their respective operations.

 

3. What Personal Data We Collect

3.1 Data you provide to us

  • Name, job title and company name
  • Email address, telephone number and postal address
  • Messages and enquiries submitted via contact forms or email
  • Login credentials for members-only or market information portals
  • Any other information you voluntarily provide

3.2 Data collected automatically

  • IP address and approximate geographic location
  • Browser type, device type and operating system
  • Pages visited, time spent on site, and referring URLs
  • Cookie identifiers and similar tracking technologies (see Section 9)

3.3 Data from third parties

  • Publicly available business contact information (e.g. from LinkedIn or company websites) used for business development
  • Data provided by wool auction platforms or trade registries relevant to commercial

 

4. How We Use Your Personal Data

Responding to enquiries and providing information Legal basis: Legitimate interests (responding to genuine business enquiries) or, where required, consent.

Managing business relationships and contracts Legal basis: Performance of a contract, or steps taken at your request prior to entering a contract.

Operating members-only or market information portals Legal basis: Performance of a contract; legitimate interests.

Marketing and communications Legal basis: Legitimate interests (for existing business contacts) or consent (where required by applicable law). You may opt out at any time.

Improving our websites and services Legal basis: Legitimate interests. We analyse website usage to improve performance, content and user experience.

Compliance with legal obligations Legal basis: Legal obligation. This includes record-keeping, anti-money-laundering checks and regulatory requirements applicable to wool trading.

Security and fraud prevention Legal basis: Legitimate interests; legal obligation.

 

5. Who We Share Your Data With

We do not sell your personal data. We may share it with:

  • Other Modiano Group companies, where necessary for the legitimate operation of the business
  • IT service providers, website hosting providers and CRM systems acting as data processors on our behalf
  • Professional advisers (solicitors, accountants, auditors) bound by confidentiality obligations
  • Regulatory bodies and law enforcement, where required by law

All third-party processors are required to process your data only on our instructions and to implement appropriate technical and organisational security measures.

 

6. International Transfers of Personal Data

The Modiano Group operates globally, with offices in Australia, Czechia, Egypt, Italy, New Zealand, South Africa, Turkey, United Kingdom and a representative Office in China. Your personal data may be transferred to and processed in countries outside the UK and European Economic Area (EEA).

Where we transfer personal data internationally, we ensure an appropriate level of protection is in place by relying on one or more of the following safeguards:

  • Adequacy decisions issued by the UK Government or the European Commission
  • Standard Contractual Clauses (SCCs) approved by the relevant supervisory authority
  • Other legally recognised transfer mechanisms under applicable data protection law

You may request further information about the specific safeguards in place for any transfer by contacting us using the details in Section 11.

7. How Long We Keep Your Data

We retain personal data only for as long as necessary for the purposes set out in this policy, or as required by law. Our general retention principles are:

  • Website analytics data: up to 26 months, or as configured in your cookie consent preferences

When personal data is no longer required, we securely delete or anonymise it.

8. Your Rights

Depending on your location and the applicable law, you may have the following rights in relation to your personal data:

  • Right of access – to obtain a copy of the personal data we hold about you
  • Right to rectification – to have inaccurate data corrected
  • Right to erasure (“right to be forgotten”) – to request deletion of your data in certain circumstances
  • Right to restriction of processing – to ask us to pause processing in certain circumstances
  • Right to data portability – to receive your data in a structured, machine-readable format
  • Right to object – to processing based on legitimate interests, or for direct marketing purposes
  • Right to withdraw consent – where processing is based on consent, you may withdraw it at any time
  • Rights relating to automated decision-making – we do not make solely automated decisions that have a legal or significant effect on you

To exercise any of these rights, please contact the relevant data controller using the details in Section 2, or write to us at the details in Section 11. We will respond within one month. We may ask you to verify your identity before processing your request.

You also have the right to lodge a complaint with a supervisory authority:

  • UK: Information Commissioner’s Office (ICO) – ico.org.uk
  • Czechia: Úřad pro ochranu osobních údajů (ÚOOU) – uoou.cz
  • Italy: Garante per la protezione dei dati personali – garanteprivacy.it


9. Cookies and Similar Technologies

Our websites use cookies and similar tracking technologies to ensure they function correctly, analyse usage and, where you have consented, to support marketing activities.

We use CookieYes as our Consent Management Platform (CMP). When you first visit one of our sites, a cookie consent banner will be displayed. You can choose which categories of cookies to accept or decline, and you can update your preferences at any time by clicking the “Cookie Settings” link in the footer of any page.

We use the following categories of cookies:

  • Strictly necessary – essential for the website to function. These cannot be declined.
  • Functional – enable enhanced functionality and personalisation, such as language preferences and member login sessions.
  • Analytics – help us understand how visitors interact with our sites (e.g. Google Analytics). Activated only with your consent.
  • Marketing – used to deliver relevant advertising. Activated only with your consent.

A full list of the cookies used on each site — including their name, provider, purpose and duration — is available in the CookieYes cookie declaration embedded in the footer of each website. This list is automatically updated when our cookie scan detects changes.

 

10. Security

We implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. These include:

  • TLS/SSL encryption for all data transmitted to and from our websites
  • Access controls and authentication for internal systems
  • Regular security assessments and software updates
  • Staff training on data protection obligations

No method of transmission over the internet is completely secure. While we take all reasonable steps to protect your data, we cannot guarantee absolute security. In the event of a data breach likely to result in a risk to your rights and freedoms, we will notify you and the relevant supervisory authority as required by law.

 

11. Contact Us

If you have any questions about this Privacy Policy, wish to exercise your rights, or have a concern about how we handle your data, please complete our contact form:

Contact us

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements or technology. When we make material changes, we will update the “Last reviewed” date at the bottom of this document and, where appropriate, notify you by email or by a notice on the relevant website.

We encourage you to review this policy periodically. Your continued use of our websites after any changes constitutes your acknowledgement of the updated policy.

 

Effective date: June 2026
Last reviewed: June 2026