Modora (AI Home) Privacy Policy

1. Objective

CDT America LLC. ("CDT America" or "Company") aims to process the personal data of users in accordance with general principles of privacy and the provisions of the applicable data protection legislation. Your personal data, which you provide to our Company and/or is obtained by our Company by any external means, may be processed by our Company as the "Data Controller";

This Privacy Policy is adopted for the continuance and improvement of the activities carried out by CDT America. It describes which data we collect, how we intend to use, store, protect and share the data we collect, how you can withdraw your consent for the processing of these data and how you can correct and revise them. Capitalised terms in this Policy shall have the meanings specified in the Terms and Conditions unless defined separately in this Policy.

2. Collection of Personal Data and Method

CDT America may process your personal data for the purposes specified in this Privacy Policy. The personal data of users collected and used by CDT America, in particular, are as follows:

Data Categories and Data Types

Identity InformationName and surname
Contact InformationE‑mail address
Process SecurityInternet traffic data (network movements, IP address, visit data, time and date information), device name, in‑app purchase history, push‑token ID (when you allow notifications), IDFA (if permission granted), IDVF
Visual and Audio RecordsImages you upload to Modora (e.g., photos of rooms, furniture, décor)
Customer TransactionOrder and subscription information
Marketing DataIDFA, IDVF
Location DataApproximate location (city, state, latitude/longitude within a few kilometres)

We may collect your data directly from you through electronic or physical means, from your mobile device, third‑party applications, or third‑party sources such as the Apple App Store or Google Play Store (together, "App Stores") to comply with legal obligations, enhance our services, administer your use of our services, and enable you to enjoy and easily navigate our services.

With your permission, we collect location data via your mobile device's operating‑system APIs (e.g., iOS Core Location or Android Location Services). You can withdraw this permission at any time in your device settings.

We may also collect log data generated while you are using our services/applications. This log data may include information such as your device's IP address, device name, operating system version, the configuration of the app when utilising our service/application, the time/date of your use of the service/application, and other statistics.

3. Principles for Processing Personal Data

In accordance with this Privacy Policy, personal data is processed by CDT America as a data controller in line with the following basic principles:

  1. Being in accordance with the law and good faith
  2. Being accurate and, where necessary, up‑to‑date
  3. Being processed for specific, explicit, and legitimate purposes
  4. Being limited to what is necessary for the purpose for which they are processed (data minimisation)
  5. Being stored for the period stipulated in the relevant legislation or required for the purpose for which they are processed

4. Legal Grounds for Processing

Your personal data will be processed via automatic or non‑automatic means for the following purposes, in accordance with the applicable legislation:

a) Purposes of Processing Personal Data

Your personal data is processed for the following purposes in accordance with the above legal grounds:

Identity &
Contact Information
• Executing activities in compliance with legislation
• Fulfilling company–product–service commitments
• Conducting communication activities
• Executing/auditing business activities
• Providing after‑sales support
• Executing sales and subscription processes
• Conducting storage and archiving activities
• Executing agreement processes
Process Security• Executing information‑security processes
• Conducting audit/ethical activities
• Ensuring business continuity
• Providing information to authorised persons, institutions and organisations
Customer Transaction• Executing/auditing business activities
• Providing after‑sales support
• Executing goods/services sales processes
• Conducting activities for customer satisfaction
• Executing agreement processes
Visual and Audio Records• Executing activities in compliance with legislation
• Executing agreement processes
• Conducting storage and archiving activities
• Executing/auditing business activities
• Ensuring business continuity
• Enhancing customer satisfaction
Marketing Data• Conducting marketing‑analysis studies
• Executing advertising, campaign and promotion processes
Location Data• Recommending nearby stores that carry products matching your ShopLook selections
• Personalising content and services based on regional availability
• Preventing fraud and ensuring security (e.g., detecting anomalous logins)

CDT America may update the above purposes in line with obligations arising from company policies and legislation. In particular, we may process your personal data for the following operational purposes:

  • Creating and managing user accounts for Modora users
  • Customising our services, understanding user preferences, and enhancing overall experience
  • Informing you about new products, services and promotions
  • Handling digital subscriptions and in‑app purchases
  • Managing auto‑renewable subscriptions that grant access to premium features
  • Ensuring information security and fraud prevention
  • Complying with legal requests from competent authorities
  • Handling finance and accounting transactions
  • Managing contracts and strategic planning
  • Following up on user requests and complaints
  • Providing location‑based store recommendations for the ShopLook feature

b) Legal Reasons

Identity, Contact &
Customer Transaction
• Processing is necessary for the performance of a contract with you or to take steps at your request prior to entering a contract

• Processing is necessary for the establishment, exercise or defence of legal claims
Visual and Audio Records• Same contractual grounds as above
• Processing is necessary for our legitimate interests (service improvement, security, support), provided your fundamental rights are not overridden
Process Security• Processing is required to comply with a legal obligation
• Processing is necessary for our legitimate interests in ensuring network and information security
Marketing & Location• Your explicit consent obtained via your device or in‑app settings (you may withdraw this consent at any time)

5. Third‑Party Websites and Applications

Modora may contain links to other websites or services that are not controlled by CDT America. These sites may apply their own terms and conditions. CDT America cannot be held responsible for the use or disclosure of information that these websites may process. Likewise, CDT America has no responsibility for any inbound links to the Modora app.

6. Cookies

Cookies are small text files that are stored on the browser or hard drive of your device when you visit a webpage or application. Cookies allow a website to run more efficiently and present personalised content. Cookies do not collect information stored on your device.

We may use cookies necessary for operating our services, to enhance performance and functionality, and to deliver content (including ads) relevant to your interests, on our sites or third‑party sites.

You can delete cookies already present on your device and prevent new cookies being recorded via your browser or device settings. Refer to your browser's help section for details.

7. Push Notifications

CDT America may occasionally send push notifications via Modora regarding feature updates or promotions. You can manage or disable these notifications in your device settings at any time.

8. Data Retention

Your data will be stored for the duration specified in applicable legislation or for a reasonable period until the processing purpose ceases to exist, or during legal limitation periods. CDT America may continue to store your data after the expiry of its original purpose where required by other laws or with your consent.

9. Security Measures

CDT America implements appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including but not limited to anti‑virus protection, firewalls, VPN access controls, encryption, logging, penetration testing, an Information Security Management System (ISMS) and regular staff training.

10. Transferring Personal Data to Third Parties

Your data may be transferred to service providers and partners (e.g., Firebase, Adjust, Map/Places APIs, Apple and Google payment processors) located in other countries for the purposes outlined above, including storage, analytics, payment processing, user support and location‑based store recommendations.

11. Your Rights

You may exercise the following rights (subject to local laws): access, rectification, erasure, restriction, objection, portability and the right to withdraw consent. Please contact us at contact@cdtamerica.com. We will respond within 30 days. If you are not satisfied, you may lodge a complaint with your data‑protection authority.

12. Changes to This Policy

This Privacy Policy may be revised when deemed necessary. Continued use of Modora after changes take effect shall be deemed acceptance of the updated Policy.

13. Contact

Company Title: CDT America LLC
Address: Washington, USA
E‑mail: contact@cdtamerica.com