Privacy Policy

Moderavia is a product and service operated by F.M. Prime Services UG (haftungsbeschränkt). Moderavia is not a separate incorporated company or legal entity.

For privacy questions or to exercise a data-protection right, email [email protected] and identify the relevant account or workspace where possible.

This policy applies to visitors to moderavia.com, Early Access applicants, account and workspace users, support contacts, and people whose personal data is processed through an authorized Moderavia workspace.

The privacy role depends on the specific processing activity. F.M. Prime Services UG is the controller for the public website, applications, account administration, security, billing, and its own service operations. Where a business customer submits or connects personal data and determines the purposes and essential means, the customer is normally the controller and F.M. Prime Services UG acts as processor for that activity. The same party can therefore be controller for one activity and processor for another. Users should also consult their organization's privacy information.

Where Article 28 GDPR applies, processing on a customer's instructions must be governed by an appropriate data processing agreement before that processing begins. The public policy is not itself a data processing agreement; commercial customers can contact [email protected] to arrange the required contract.

• Website and device data: requested URL, timestamp, IP address, user agent, referral information, response status, and security or delivery logs.
• Early Access and communications: name, business email, company, website, business type, objective, message, language/source, submission history, and support correspondence.
• Account and authentication data: business email, password verifier, email-verification state, roles, workspace membership, session and security events. Moderavia does not store a readable account password.
• Workspace and business data: goals, plans, tasks, content, observations, recommendations, approvals, decisions, outcomes, CRM or lead data supplied by the customer, and related audit records.
• Integration data: provider and account identifiers, granted scopes, encrypted credential envelopes, connection and health state, discovered resources, provider-read results, sync history, and operational evidence.
• AI and operational data: selected inputs needed for an AI-assisted workflow, model output, routing and cost records, error codes, audit events, and security logs.

We do not require special-category personal data for ordinary use. Customers must not submit such data unless the parties have expressly agreed that processing and an appropriate legal basis exists.

We process data to provide and administer the service; authenticate users; isolate and secure workspaces; perform requested integrations and AI-assisted workflows; provide support; prevent abuse; maintain auditability; improve reliability; handle Early Access applications; and meet legal obligations.

Depending on the context, the legal basis is Article 6(1)(b) GDPR (contract or pre-contract steps), Article 6(1)(c) (legal obligation), Article 6(1)(f) (legitimate interests in operating, securing and improving a B2B service and communicating with business contacts), or Article 6(1)(a) (consent). Where consent is the basis, it may be withdrawn prospectively at any time. A customer acting as controller is responsible for the legal basis governing data it places in its workspace.

A user may explicitly authorize Moderavia through Google OAuth to access a supported Google service. Moderavia requests the scopes shown on Google's consent screen and uses the resulting authorization only for the connected workspace and the user-facing integration selected by the customer.

For the current Google Ads integration, customer-authorized access is used for reporting, analytics, account health, account discovery and classification, and evidence inside the customer's Moderavia workspace. This may include accessible customer identifiers, manager-account status, campaign information, performance metrics, connection health, and sync evidence. The current production path is read-only; this policy does not claim autonomous ad creation, budget changes, or spend.

OAuth access and refresh tokens are stored as encrypted credential envelopes and are unwrapped only within the credential-bearing execution boundary for the requested provider operation. Tokens and Google API data are not intentionally exposed to other customers. We do not sell Google API data, use it for advertising to users, or use it to train a general-purpose AI model.

Google API data is disclosed only as needed to operate the requested feature through contracted service providers, to protect the service, to comply with law, or at the customer's direction. Moderavia's use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including applicable Limited Use requirements.

Users can disconnect a Google integration in Moderavia, revoke authorization in their Google Account, or request deletion by contacting us. Revocation stops future access but does not by itself erase records that must be retained for security, audit, contractual, or legal reasons.

Moderavia uses AI-assisted workflows to analyze authorized business information and produce findings, plans, recommendations, drafts, or proposed actions. Only information selected or required for a particular workflow is sent to a configured model provider; not every customer data item is automatically sent to an AI provider.

Model output may be incomplete or wrong and is treated as analysis or a proposal, not guaranteed fact or professional advice. Sensitive external actions can remain subject to deterministic policy, recorded evidence, and human approval. AI providers may act as processors where a live model is configured for the service.

The public marketing site does not currently use advertising or behavioral analytics cookies. The authenticated application uses host-only, Secure and HttpOnly session cookies, and a short-lived workspace-choice cookie, where necessary to sign users in and keep the requested session secure. Theme and language preferences may be kept in browser local storage.

These mechanisms are used to deliver functionality requested by the user. If non-essential analytics or advertising technologies are introduced, this policy and any required consent controls will be updated before they are used.

We use carefully selected service providers only as needed to operate Moderavia. Current categories include infrastructure hosting and managed databases (Railway), DNS/content delivery and network security (Cloudflare), Google for user-authorized OAuth and API services, and an AI model provider such as Anthropic when a live model is configured. Professional advisers or authorities may receive information where required by law or necessary to establish, exercise, or defend legal claims.

Providers receive only the data required for their role and are subject to contractual, confidentiality, and data-protection obligations where required. Their services remain subject to their own availability, security, API, account, and policy constraints; Moderavia cannot guarantee a third party's uninterrupted operation or acceptance of a request. Current subprocessor information may be requested at [email protected].

Some providers may process data outside Germany or the European Economic Area. Where the recipient country is not covered by an EU adequacy decision, we use an appropriate transfer mechanism where required, such as the European Commission's Standard Contractual Clauses, together with supplementary measures where appropriate. Provider location and safeguards can vary by service configuration.

We retain data only for as long as needed for the purpose collected, the customer relationship, security and auditability, or applicable law. Early Access data is retained while the application is assessed and for a limited follow-up period unless the applicant asks for deletion or a legal need requires longer retention. Sessions expire or are revoked; integration credentials are retained until disconnected, revoked, replaced, or the relevant workspace is deleted.

Workspace records generally remain for the contract term and an orderly deletion/export period. Security, approval, execution, billing, and legal records may be retained longer where needed to demonstrate authorization, resolve disputes, prevent abuse, or meet statutory obligations. Backups and queued deletion jobs expire on their operational rotation rather than immediately. When retention ends, data is deleted or irreversibly anonymized.

Moderavia uses high-level controls including tenant-scoped access, PostgreSQL row-level security, role-based access, encrypted credential handling, separation of credential-bearing execution, bounded credential leases, audit records, and human approval controls for protected actions. Access is limited according to operational need.

No internet service is risk-free. These controls are not a claim of SOC 2, ISO 27001, GDPR certification, an external security audit, or penetration-test certification.

Subject to the GDPR's conditions and exceptions, data subjects may request access, correction, deletion, restriction, data portability, or object to processing based on legitimate interests. Where processing relies on consent, consent may be withdrawn for the future without affecting earlier lawful processing. You may also object at any time to direct marketing; Moderavia does not currently use Google API data for direct marketing.

Send a request to [email protected]. We may need to verify identity and, where the data is controlled by a customer, route the request to that customer. You may lodge a complaint with a supervisory authority, in particular the Unabhängiges Landeszentrum für Datenschutz Schleswig-Holstein (ULD), Holstenstraße 98, 24103 Kiel, Germany, or the authority for your habitual residence or workplace.

We may update this policy when the product, providers, or legal requirements change. The current version and effective date will remain available at this URL. Material changes affecting an existing processing purpose will be communicated in an appropriate manner and, where required, a new consent will be requested before the new processing begins.

Questions, withdrawal notices, objections, and deletion requests may be sent to [email protected]. See also the Terms of Service and legal information.