Moda Privacy Policy
Last Updated: October 21, 2026
This Privacy Policy (“Policy”) describes how Nullframe, Inc. d/b/a Moda (“Moda,” “Company,” “we,” “our,” or “us”) collects, uses, discloses, and otherwise processes Personal Data in connection with the Moda website (the “Website”), the Moda platform (the “Platform”), related services (collectively, the “Services”), and our other business activities. This Policy applies to Personal Data that Moda processes for its own purposes as a Controller or Business. To the extent Moda processes Personal Data solely on behalf of a customer in connection with the Services, such processing is governed by Moda’s Data Processing Addendum (“DPA”), available at https://moda.app/dpa, to the extent applicable.
Personal Data We Collect
“Personal Data” means information that identifies, relates to, describes, or can reasonably be linked to an individual, or that is otherwise defined as personal information, personal data, or a similar term under applicable privacy law. Depending on how you interact with us, we may collect the following categories of Personal Data:
| Category | Examples |
|---|---|
| Contact and Professional Information | Name, email address, telephone number, mailing address, employer, job title, department, professional role, and similar business contact information |
| Account Information | Username, account identifier, login and authentication information, account role, permissions, customer affiliation, and account preferences |
| Communications and Support Information | Emails, support requests, chat messages, feedback, survey responses, meeting information, troubleshooting information, and other communications with us |
| Internet, Device, and Usage Information | IP address, browser type, operating system, device information, device identifiers, referring URLs, pages viewed, dates and times of access, approximate location derived from IP address, and information regarding interactions with the Website or Services |
| Cookie and Analytics Information | Cookie identifiers, session information, traffic-source information, marketing attribution information, and other information collected through cookies and similar technologies |
| Content and AI Interaction Information | Prompts, inputs, outputs, files, content, and other information submitted to, generated through, or otherwise processed in connection with the Services, to the extent Moda processes such information for its own purposes. |
We may also collect other Personal Data that you voluntarily provide to us.
Sources of Personal Data
We may collect Personal Data:
- directly from you;
- automatically when you interact with our Website or Services;
- from our customers;
- from service providers, business partners, and other third parties; and
- from publicly available sources.
Cookies and Similar Technologies
We and third parties that provide services to us may use cookies, pixels, web beacons, and similar technologies to collect information about interactions with the Website or Services. These technologies may be used to:
- operate and secure the Website and Services;
- maintain user preferences and functionality;
- understand usage and Website performance;
- conduct analytics;
- measure marketing effectiveness; and
- support advertising activities, where applicable.
You may be able to control certain cookies through your browser settings or other tools we make available.
How We Use Personal Data
We may use Personal Data for the following purposes:
- to provide, operate, administer, and support the Services;
- to create and manage accounts;
- to authenticate users and maintain security;
- to communicate with you;
- to respond to inquiries, requests, and support matters;
- to understand use of and improve the Website and Services;
- to conduct analytics and measure performance;
- to develop, train, test, evaluate, and improve our artificial intelligence and machine-learning models and related features;
- to conduct marketing, advertising, and business development activities;
- to detect, investigate, prevent, and address fraud, security incidents, misuse, or unlawful activity;
- to maintain business, financial, and operational records;
- to comply with applicable legal and regulatory requirements;
- to establish, exercise, or defend legal claims;
- to enforce our agreements and policies; and
- for other purposes disclosed at the time of collection or with your consent.
We may combine Personal Data collected from different sources for the purposes described in this Policy. We do not sell Personal Data for monetary consideration.
AI and Model Development
We may use Personal Data to develop, train, test, evaluate, and improve our artificial intelligence and machine-learning models and related features, including to improve the performance, safety, reliability, and functionality of the Services, as described in our Terms of Service and subject to applicable law. To the extent Moda uses Personal Data contained in Customer Data for its own model development or improvement purposes, Moda acts as a Controller or Business with respect to that processing. Customers may opt out of the use of Customer Data for model training by emailing [email protected]. Opt-outs apply prospectively, subject to applicable law.
Google user data obtained through Google Workspace APIs is not used for the model-training purposes described in this section, as further described in the “Google User Data (Workspace APIs)” section below.
Google User Data (Workspace APIs)
Moda offers optional integrations with Google Drive, Docs, Sheets, and Slides. If you connect your Google account, Moda accesses only the Google user data necessary to provide the features you request, including:
- files you select, link, or ask Moda to access, and files Moda creates on your behalf; and
- basic profile information, such as your name and email address, used to identify your connected account.
Notwithstanding anything else in this Policy, Google user data is not used for the model-training purposes described in the “AI and Model Development” section. Moda does not use, transfer, or sell Google user data, whether raw or derived from Google user data, to develop, train, or improve general-purpose artificial intelligence or machine-learning models. Moda uses Google user data only to provide and support the functionality you request. Moda does not sell Google user data or use it for advertising. Moda’s use and transfer of information received from Google APIs complies with the Google API Services User Data Policy, including its Limited Use requirements. Certain Moda features use third-party AI providers, including Anthropic and OpenAI. Google user data may be shared with those providers only as necessary to provide the functionality you request. Content imported from Google may be retained as part of your Moda workspace until deleted by you or in accordance with Moda’s retention practices. You may disconnect your Google account through Moda’s settings or revoke Moda’s access through your Google account permissions.
How We Disclose Personal Data
We may disclose Personal Data to the following categories of recipients:
Service Providers
We may disclose Personal Data to vendors, contractors, and service providers that perform services on our behalf (“Service Providers”), including providers of hosting, infrastructure, security, authentication, communications, customer support, analytics, payment processing, and other business services.
Analytics Partners
We may disclose Personal Data to analytics, advertising, or marketing partners (“Analytics Partners”) in connection with analytics, marketing, advertising, and measurement activities.
Government Authorities
We may disclose Personal Data to applicable government authorities (“Government Authorities”) where we reasonably believe disclosure is necessary or appropriate to:
- comply with applicable law, legal process, or governmental requests;
- protect our rights, property, or safety or the rights, property, or safety of others;
- detect, investigate, or prevent fraud, security incidents, or unlawful activity;
- enforce our agreements or policies; or
- establish, exercise, or defend legal claims.
Corporate Transactions
We may disclose or transfer Personal Data in connection with an actual or proposed merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or other corporate transaction.
With Your Consent or Direction
We may disclose Personal Data with your consent, at your direction, or as otherwise disclosed to you at the time of collection.
De-Identified and Aggregated Information
We may use and disclose information that has been aggregated, de-identified, or anonymized so that it cannot reasonably be linked to an identifiable individual for any lawful purpose. Where required by applicable law, we will maintain de-identified information in de-identified form and will not attempt to re-identify it except as permitted by law.
Data Retention
We retain Personal Data for as long as reasonably necessary for the purposes described in this Policy or as otherwise permitted or required by applicable law. In determining appropriate retention periods, we may consider the nature of the Personal Data, the purposes for which it is processed, legal and regulatory requirements, contractual obligations, security considerations, and our legitimate business needs. When Personal Data is no longer required, we may delete, de-identify, or otherwise dispose of it in accordance with applicable law and our retention practices.
Your Privacy Rights
Depending on where you reside and subject to applicable law, you may have certain rights regarding your Personal Data, which may include the right to:
- confirm whether we process your Personal Data;
- access Personal Data we maintain about you;
- correct inaccurate Personal Data;
- request deletion of Personal Data;
- obtain a copy of Personal Data in a portable format;
- opt out of the sale of Personal Data;
- opt out of the sharing of Personal Data or processing for targeted advertising;
- opt out of certain profiling;
- limit certain uses or disclosures of sensitive Personal Data;
- obtain information regarding certain third parties to whom Personal Data has been disclosed;
- withdraw consent where processing is based on consent;
- appeal certain decisions relating to a privacy rights request; and
- exercise privacy rights without unlawful discrimination or retaliation.
The availability and scope of these rights depend on applicable law.
Exercising Your Rights
To submit a privacy rights request, please contact us at:
Your request should provide sufficient information for us to reasonably identify you and understand the nature of your request. We may take reasonable steps to verify your identity or authority to make a request before responding. Where permitted by applicable law, an authorized agent may submit certain requests on your behalf. We will respond to requests in accordance with applicable law.
Appeals
If we deny your privacy rights request and applicable law provides a right to appeal, you may appeal our decision by contacting [email protected] and identifying the request and decision you wish to appeal. We will process eligible appeals in accordance with applicable law.
Marketing Communications
You may opt out of marketing emails by using the unsubscribe instructions contained in those communications or by contacting us. We may continue to send non-promotional communications relating to your account, transactions, or use of the Services.
Sensitive Personal Data
We do not knowingly collect or process sensitive Personal Data through the Website or Services for our own purposes, except where necessary to comply with applicable law or where such information is voluntarily provided and processing is permitted by applicable law.
Children
The Website and Services are not directed to children, and we do not knowingly collect Personal Data from children in violation of applicable law. If we learn that we have collected Personal Data from a child in violation of applicable law, we will take reasonable steps to delete or otherwise process the information as required by law.
Security
We maintain reasonable administrative, technical, and organizational safeguards designed to protect Personal Data. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.
California Privacy Rights
California residents may have additional rights under applicable California privacy laws, including rights to know, access, correct, delete, and obtain certain information regarding our collection, use, disclosure, sale, or sharing of Personal Data, as well as rights to opt out of certain processing and to limit certain uses of sensitive Personal Data. The categories of Personal Data we collect, the purposes for which we use Personal Data, the sources from which we collect Personal Data, and the categories of parties to whom we disclose Personal Data are described above. Moda does not sell Personal Data. California residents may exercise applicable privacy rights, including any applicable right to opt out of the sharing of Personal Data, by contacting [email protected] or using any other opt-out mechanism we make available.
Other State Privacy Rights
Residents of other U.S. states with applicable consumer privacy laws may have additional rights regarding their Personal Data. Such rights may include rights to access, correct, delete, or obtain a copy of Personal Data; opt out of sale, targeted advertising, or certain profiling; obtain information regarding disclosures of Personal Data; appeal certain decisions regarding privacy requests; and exercise applicable rights without unlawful discrimination. You may exercise applicable rights by contacting [email protected].
EEA and UK
If you are located in the EEA or United Kingdom, Moda acts as a Controller with respect to the Personal Data covered by this Policy. We may Process Personal Data as necessary to perform a contract, comply with legal obligations, pursue our legitimate interests, or with your consent where required. Our legitimate interests may include operating, securing, developing, analyzing, and improving our business and Services, including our artificial intelligence and machine-learning models, where those interests are not overridden by applicable individual rights. Subject to applicable law, you may have rights to access, correct, delete, restrict or object to Processing, receive certain Personal Data in a portable format, withdraw consent, and lodge a complaint with the applicable data protection authority. Personal Data may be transferred to the United States and other countries. Where required, we use appropriate safeguards for such transfers, including applicable adequacy decisions, Standard Contractual Clauses, the UK International Data Transfer Addendum, or other recognized transfer mechanisms. To exercise an applicable privacy right, contact us at [email protected].
Changes to This Policy
We may update this Policy from time to time. The “Last Updated” date above indicates when this Policy was most recently revised. Where required by applicable law, we will provide notice of material changes.
Contact Us
If you have questions regarding this Policy or wish to exercise an applicable privacy right, please contact:
Nullframe, Inc. d/b/a Moda
[email protected]