Privacy Policy

Last Updated: March 2026

This Privacy Policy describes how MODERA ("we", "us", or "our") collects, uses, and discloses your information when you use our service, including our website modera.fashion and mobile applications (collectively, the "Service"). By using the Service, you agree to the collection and use of information in accordance with this policy.

Information We Collect

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). This may include:

  • Email address
  • First name and last name
  • Payment information
  • Usage Data

Usage Data

We may also collect information on how the Service is accessed and used ("Usage Data"). This may include information such as your computer's Internet Protocol address (IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.

Photos and Images

Our Service includes AI-powered features such as Virtual Try-On, Model Swap, Product-to-Model, and image editing tools. When you use these features, you may upload photos and images. Here is how we handle them:

  • Uploaded photos are transmitted to our secure servers (hosted on AWS) solely for the purpose of AI processing. They are not used for training AI models.
  • Generated results (try-on images, edited images, etc.) are stored on our secure servers (AWS S3) and associated with your account so you can access them in your gallery.
  • Original uploads used for one-time processing (e.g., garment photos for try-on) are automatically deleted within 24 hours after processing is complete.
  • AI Model faces — if you create a custom AI model from your photo, the generated face data is stored for as long as you keep the model in your account. You can delete it at any time.
  • No biometric identifiers are extracted or stored. We do not generate face templates, FaceIDs, or hashes that could be used to recognize you across services. Face detection is used only for compositional purposes (e.g., aligning a model swap or face replacement) and is not retained beyond the processing window.

Face Data and Third-Party AI Processors

MODERA uses several AI features that send your uploaded images — including images that contain a face — to specialised third-party AI providers for processing. Before you use any feature that handles a face image (Model Swap, Face Swap, Product-to-Model with face reference, AI Stylist photo upload, custom Model creation), the app shows an explicit consent dialog that names the destination processor and describes how long the data is retained. You can decline; the feature will not run without consent.

What we send and to whom:

  • Google Vertex AI (Virtual Try-On, Gemini) — receives the model image and garment image for try-on synthesis. Google processes the images solely to fulfil our request and does not retain them for training under our enterprise terms (Google Cloud AI Data Processing Addendum).
  • Replicate (Model Swap, Face Swap, Product-to-Model) — receives the source and reference images. Replicate retains inputs only as long as needed to return the result.
  • AWS Bedrock (image editing — background removal, enhancement, repaint) — receives the image to edit. AWS does not store, log, or use customer content from Bedrock to train its models.
  • Cloudinary (some image transformations) — receives the image for transformation. Inputs are deleted after transformation.

None of these processors receive your name, email, payment information, or any account identifier together with the image. We do not sell or share face data, and we do not allow processors to use face data for any purpose other than fulfilling your specific generation request.

Retention: The face image and any intermediate face data sent to a third-party processor are deleted within 24 hours of processing. Generated outputs (e.g., a model-swap result) are stored in your gallery on AWS S3 until you delete them or delete your account.

Withdrawing consent: You can revoke face-data consent at any time in Profile → Privacy. After revocation, the consent prompt re-appears the next time you use a face feature.

Use of Data

MODERA uses the collected data for various purposes:

  • To provide and maintain our Service
  • To notify you about changes to our Service
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To provide customer support
  • To gather analysis or valuable information so that we can improve our Service
  • To monitor the usage of our Service
  • To detect, prevent and address technical issues
  • To fulfill any other purpose for which you provide it

Retention of Data

MODERA will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

MODERA will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Image and Photo Retention:

  • Uploaded source images (photos for try-on, editing) — automatically deleted within 24 hours after processing
  • Generated result images (try-on results, edited images) — retained in your account gallery until you delete them or close your account
  • Custom AI models (face data) — retained until you delete the model from your account
  • Account deletion — all associated images, models, and personal data are permanently deleted within 30 days of account closure

Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

MODERA will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Data

Legal Requirements

MODERA may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of MODERA
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability

Security of Data

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Your Data Protection Rights

We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

  • The right to access, update or to delete the information we have on you
  • The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete
  • The right to object. You have the right to object to our processing of your Personal Data
  • The right of restriction. You have the right to request that we restrict the processing of your personal information
  • The right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format
  • The right to withdraw consent. You also have the right to withdraw your consent at any time where MODERA relied on your consent to process your personal information

Third-Party Services

We use the following third-party services to operate and improve our Service:

  • Amazon Web Services (AWS) — cloud infrastructure, image storage (S3), and AI processing (Bedrock). US region.
  • Google Vertex AI — Virtual Try-On Pro and Gemini image generation. Receives uploaded model/garment images solely to return the generated try-on. Does not train on customer content.
  • Replicate — Model Swap, Face Swap, and Product-to-Model inference. Receives source/reference images solely to return the generated output. Inputs deleted after the request completes.
  • Cloudinary — image transformations (resize, format conversion, some edits). Inputs not retained.
  • Apple App Store / Google Play Billing — in-app purchases on iOS and Android. Receives purchase tokens / receipts only; no image or face data.
  • Supabase — authentication and database services.
  • Stripe — payment processing (PCI DSS compliant). Used on the web only.
  • YooKassa — payment processing for users in Russia. Used on the web only.
  • Vercel — web application hosting.

Each third-party service provider processes data in accordance with their own privacy policy. We ensure appropriate data processing agreements are in place with each provider.

GDPR Compliance (European Users)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights under the General Data Protection Regulation (GDPR). MODERA aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

The legal bases for processing your data include:

  • Consent — when you upload photos for AI processing
  • Contract performance — to provide the Service you have subscribed to
  • Legitimate interests — to improve our Service, prevent fraud, and ensure security

You may exercise your rights by contacting us at [email protected]. We will respond to your request within 30 days.

Contact Us

If you have any questions about this Privacy Policy, please contact us:

ERARTA, Dubai, UAE