Privacy Policy
Last updated: August 2026
Creayo LLC ("we", "our", "us") operates Moda. This Privacy Policy explains how we collect, use, and protect your information.
1. Information We Collect
We collect the following types of information:
Personal Information:
- Name (optional, for log exports)
- State or territory of residence (for rule configuration)
- Learner permit date
Session Data:
- Driving session start and end times
- Session duration
- Supervisor name and relationship
- Start and end location coordinates, city names, and the route of the drive (stored on your device only, never sent to us)
- Road type classification
- Day/night classification
Weather Data:
- Weather condition at session start (e.g., clear, rain, snow)
- Temperature
- Precipitation probability
Device Information:
- Device identifier (for sync purposes only)
- App version
2. How We Collect Information
- Directly from you: Name, state, permit date, supervisor details
- Automatically: Location (with permission), weather (via Apple WeatherKit), time of day
- We do NOT collect information from third-party sources
3. How We Use Your Information
We use your information to:
- Track and display your driving progress
- Calculate compliance with state requirements
- Generate DMV-ready export documents
- Sync data across your devices (unless in local-only mode)
- Send progress reminders (with your permission)
We do NOT use your information for:
- Advertising or marketing
- Selling to third parties
- User profiling or tracking
- Data mining
4. Location Data
During an active driving session the app records the route you take, as a series of points, so it can show you a map of the drive afterwards. This happens entirely on your phone.
Route points, start and end coordinates, and city names are never sent to Moda. They are stored only on your device. What we receive from a drive is its duration, its total distance, and details you enter yourself such as the supervisor and road type. We cannot see where you drove.
We do NOT:
- Track your location outside an active driving session
- Send your route or coordinates to our servers
- Share location data with third parties
- Use location data for advertising or profiling
Location collection requires your explicit permission and can be denied. If denied, sessions will be logged without location data.
Transfer Mode
Because route data lives only on your phone, it is lost when you move to a new one. Settings includes an optional Transfer Mode that includes the app's data file in your iPhone's own encrypted backup, so your drives move with you.
Transfer Mode is off unless you turn it on. When it is on, that data file is copied to Apple as part of your own device backup, under your own Apple Account. The file includes your route points and start and end locations, your name and date of birth, your family code, and your supervisors' details, which can include a phone number, email address, and driver's licence number. None of it is sent to Moda, and we still cannot see any of it. You can turn Transfer Mode off at any time, which removes the data from future backups.
5. Data Storage and Security
- All data is stored locally on your device first
- If cloud sync is enabled, data is stored on Supabase servers with encryption
- iCloud backup provides additional redundancy
- You may choose local-only mode to keep all data exclusively on your device
- We use industry-standard security measures to protect your data
6. Data Shared with Third Parties
We share data only with:
- Apple (iCloud backup, WeatherKit, StoreKit for purchases)
- Supabase (cloud data storage, if sync is enabled)
These services are bound by their own privacy policies and provide data protection.
We do NOT share data with:
- Advertising networks
- Data brokers
- Analytics companies that track users
- Any other third parties
7. Children and Minors
Moda is designed for teen drivers (typically ages 15-18). We are committed to protecting the privacy of minors:
- We collect only information necessary for the App's core functionality
- We do not use data from minors for advertising, marketing, or profiling
- We do not include third-party advertising or analytics that track users
- Parents/guardians can view their teen's driving data through the family linking feature
- Parents/guardians can request deletion of their teen's data by contacting support@modadriving.com
- The App does not knowingly collect personal information from children under 13 without verifiable parental consent
- If we learn we have collected information from a child under 13 without proper consent, we will delete it promptly
8. Data Retention
We retain your data for as long as your account is active or as needed to provide services. You may delete your data at any time through the App's settings. Upon account deletion, all cloud-stored data is permanently removed within 30 days.
9. Your Rights
You have the right to:
- Access your data (available through the App and export features)
- Correct inaccurate data (edit sessions and profile in the App)
- Delete your data (Settings > Delete Account & Data)
- Withdraw consent for data collection
- Export your data in PDF or CSV format
- Switch to local-only mode at any time
10. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of material changes through the App. Continued use after changes constitutes acceptance.
11. Contact Us
For privacy questions or requests, contact us at support@modadriving.com.
12. International Users
Moda is available in the United States and Australia. If you are located outside the United States, your data may be transferred to and processed in the United States where our servers are hosted.
Australian Users:
If you are in Australia, we comply with the Australian Privacy Act 1988 and the Australian Privacy Principles (APPs). In particular:
- We collect only personal information reasonably necessary for the App's functionality (APP 3)
- Your data may be stored on servers in the United States via Supabase. We take reasonable steps to ensure these services comply with the APPs (APP 8)
- You can access, correct, or delete your personal information at any time through the App (APPs 12 and 13)
- We will notify the Office of the Australian Information Commissioner (OAIC) and affected individuals in the event of an eligible data breach under the Notifiable Data Breaches scheme
- Your location coordinates are never sent to Moda. Only aggregate distance data is synced, consistent with data minimisation principles. Coordinates stay on your device unless you turn on Transfer Mode in Settings, which includes them in your own encrypted Apple device backup; even then they are not sent to us
- We do not use your data for direct marketing, behavioural advertising, or profiling
For Australian privacy complaints or requests, contact us at support@modadriving.com. If you are not satisfied with our response, you may lodge a complaint with the OAIC.
13. Weather Data Attribution
Weather data is provided by Apple Weather. Apple Weather — Data Sources