Privacy Policy

Modus Infinitum d.o.o.

Effective Date: July 24, 2018

Modus Infinitum d.o.o. (“Modus Infinitum,” “we” or “us”) offers services, such as the Penkala app (the “App”) that enable people to make photos with their favorite celebrities, public persons and private persons that will be digitally autographed and sent for a range of activities, like photo and video sharing. You consent to Penkala’s practices as set out in this privacy policy when you choose to use the App, the Penkala, our features to create photos with persons and digitally autograph them in the App, our website ( or the “Site”), or our other product and services (collectively the “Services”).


Information we collect or receive

Information you provide. We collect the content and other information you provide when you use our Services, including information about yourself or others, such as information you provide when you create an account and content that you create or provide through the App, including photos, videos, and signatures. When we do this, we may also collect information that is part of the things you share, such as the location of a photo or the date a file was created. We also collect information about how you use our Services, including your interactions with our Services in connection with third-party services or website integrations, and the people you are connected to or communicate with through our Services. In the event Penkala’s future products or features include purchases, we will collect information about your purchases or transactions, such as payment information that includes your credit or debit card information, account and authentication information, or billing and shipping information.

Information others provide. We collect content and other information that other people provide when they use our Services, including information about you, such as when they upload or share a photo of you or communicate with you through our Services.

Information from websites or apps that use our Services. We collect information when you visit or use third-party websites and apps that use or integrate with our Services (like when they integrate with our App to allow you to share photos or videos on their platform). This includes information about the websites and apps you visit, your use of our Services on those websites and apps, as well as information that you or the developer or publisher of the app or website provides to us.

Device information. We collect information from or about the devices you use to access our Services, such as the operating system, device identifier and settings, and other information that you permit our Services to access on your device, including through the permissions that you grant our Services on your device. This may also include location information, which can be derived from information such as your device’s IP address or, depending on the device you use to access or use our Services (and any applicable settings) information about your device’s precise location.

Other companies. We may receive information about you from other companies that App is connected to (like Google, Facebook, Instagram,…), in accordance with their terms and policies.

Third-party partners. We may receive information about you from third-party partners, which we may combine with the other information we collect about you.


How we use information we have

We use all of the information we have to help us provide and support our Services. Here’s how:

Provide, improve and develop Services. We use the information we have to provide, improve, develop, and understand our Services and to deliver personalized experiences, content and information for you and others, which may include online ads or other forms of marketing on and off our Services. For example, so that our Services work well for you, we made tools that apply filters that fit the contours of your face, that modify backgrounds of your face and fits with you pair person (celebrity, public person, private person). In order to enable these Services, we use the information we have to distinguish patterns of shape and form that compose a digital image with digital autograph.

We also may use the information we have to analyze how people share images or videos, such as from the App to third-party services, or to conduct surveys and research, test features in development, and analyze the information we have to evaluate and improve products and services, develop new products or features, and conduct audits and troubleshooting activities.

Communicate with you. We use the information we have, including your contact information, to communicate with you about our Services, to send you App necessary communication, marketing communications that we think you may be interested in, and to otherwise let you know about our products, services, policies and terms. We also use the information we have to respond to you when you contact us.

Promote safety and security. Importantly, we use information we have to promote safety and security on our Services and investigate use of our Services, including any suspicious activity or possible violations of our terms and policies.

Cookies and other technologies. We use cookies and other technologies to operate, provide, support and customize our Services, including to provide our web-based Services, improve your experiences, understand how our Services are used, and to protect our Services. We also use software development kits (SDKs) to read, store and access information from your mobile device to help provide our Services as described above when mobile apps use or integrate with our Services. If your device or browser offer them, you can modify your cookie settings by following the instructions provided by your device or mobile browser. Please note that if you set your browser or device to delete, disable, or block cookies or other technologies, you may not be able to access certain parts of the Services and other parts of our Services may not work properly.


How information is shared

We may share the information we have in the following circumstances, or in other circumstances with your permission.

Things you share. You may choose to share content and other information, or otherwise communicate with others, through our Services. When you do, remember that the people you share with may choose to share the information you shared with others.

Things others share. Other people may use our Services to share content and other information about you, such as photos or videos.

Third-party apps, websites or other services. When you use third-party apps, websites or other services that use, or are integrated with, our Services, they may collect or receive information about your interactions with them on our Services as well as what you post or share. Note that these services are not governed by this Privacy Policy, and we recommend that you review the terms, policies and practices of these third parties as they will apply to your access and use of those services.

Vendors, service providers and other partners. We may share the information that we collect with vendors, service providers, and others that work at our direction to help us support and provide our Services globally. For example, we may use third-party analytics tools to help us measure use of our Services, or we may use vendors that provide infrastructure services to help us provide and maintain the Services.

Sharing information on Facebook, Google, Instagram, 3rd party. You may choose to use our Services to share photos, videos or other content through your Facebook, Google, Instagram account using integrations and features that are integrated with our App and other Services. If you choose to share your information on Facebook, Google, Instagram or 3rd party then theirs Statement of Rights and Responsibility and Data Policy will apply to your information once it is shared on their platforms.

New owner. In the event that the ownership of Penkala (or any portion of our assets) changes as a result of a merger, acquisition, or in the event of bankruptcy, information we have, including information from or about you, may be transferred to another company.

We may also share de-identified or aggregate data with our partners and others. De-identified data means information where we have removed information that personally identifies you, such as your name or contact information. Aggregate data is data that has been combined with other data so that it does not identify a specific person.


Access and deletion

We store information for as long as it is necessary to provide Services to you and others, including those described above. If you have an account associated with our Services, information associated with your account will be kept until your account is deleted, unless we no longer need the data to provide products and services.

You can delete your account any time. Some of the information about you, or information you have shared with others, is not part of your account and therefore will not be deleted with your account. It may take a reasonable amount of time to delete your information, such as information stored in backup systems. Copies of some material (for example, log records) may remain in our database, as we need or use them for technical and other business-related reasons. When you delete your account, this material is disassociated from information that personally identifies you. If you would like information about how to access or delete your account, you can contact us at


Responding to legal requests and preventing harm

We may access, preserve and share information in response to a legal request (like a search warrant, court order or subpoena) if we have a good faith belief that the law requires us to do so. This may include responding to legal requests from jurisdictions outside of the Croatia where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards. We may also access, preserve and share information when we have a good faith belief it is necessary to: detect, prevent and address fraud or other illegal activity; to protect our Services, you and others, including as part of investigations; or to prevent death or imminent bodily harm. Information we receive about you, including financial transaction data related to purchases made on or through our Services, may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm. We also may retain information from accounts disabled for violations of our terms for at least a year to prevent repeat abuse or other violations of our terms.


International data transfers

We are based in the Croatia, and, regardless of where you use our Services or otherwise provide information to us, the information may be transferred to and maintained on servers located in the Europe or any other country globally. Note that the laws, regulations and standards of the country in which this information is stored may be different from your own country. By using our Services, you consent to this collection, transfer, storage, and processing of information to and in the Croatia and other countries.


Changes to this Privacy Policy

If we make changes to this Privacy Policy, we will provide reasonable notice of such changes as appropriate, such as providing notice through the Services or otherwise communicating with you, and/or updating the “Effective Date” at the top of this policy.


Contacting us

If you have any questions about this Privacy Policy or our related practices, please contact us online at, or by mail at:

Modus Infinitum, d.o.o.

Avenija Dubrovnik 15/12

10 000 Zagreb, Croatia