Privacy Policy

Privacy Policy for Moder Oy

Effective date: 4 February 2026

Last updated: 9 March 2026

Moder Oy (“Moder”, “we”, “us”, or “our”) values your privacy and is committed to protecting personal data in accordance with the EU General Data Protection Regulation (GDPR) and applicable Finnish data protection legislation. This Privacy Policy explains how we collect, use, store, and protect personal data when you interact with our services, websites, and communications.

Company and Controller Information

Moder Oy is the data controller for personal data processed under this Privacy Policy.

Company name: Moder Oy
Business ID: 3141855-7
Registered address: Veturitallinkuja 5 E, 00520 Helsinki
Country: Finland

For all privacy-related matters, you may contact us at hello@moder.app.

Scope of This Privacy Policy

This Privacy Policy applies to the processing of personal data by Moder Oy in connection with the Moder Platform, an enterprise resource management software for travel companies, Moder’s marketing and corporate websites, sales and customer communications, business partner relationships, recruitment and job applications, events and webinars, and individuals who contact Moder via our website or email. This policy applies where Moder Oy acts as a data controller or a data processor.

Roles and Responsibilities

Moder Oy acts as a data controller for personal data processed in connection with website visits, marketing activities, sales and customer relationship management, business communications, and recruitment. As a data controller, Moder Oy determines the purposes and means of processing personal data.

When customers use the Moder platform, Moder Oy acts as a data processor on behalf of its customers, who are the data controllers. In these cases, personal data is processed only in accordance with the customer’s instructions and applicable data processing agreements.

Legal Basis for Processing Personal Data

Moder Oy processes personal data only when there is a lawful basis under GDPR. These include consent (for example newsletters, marketing communications, and non-essential cookies), contractual necessity (for example providing access to the Moder platform), legitimate interests (such as B2B marketing, service improvement, security, and analytics), and legal obligations (such as accounting and regulatory requirements). Where processing is based on consent, you may withdraw your consent at any time.

Personal Data We Collect

Website, marketing, sales, recruitment (controller): name, email, company, job title, communications, website usage data, cookie/analytics data, and recruitment information (CV, application materials).
Moder platform (processor): data our customers or their end-users input or generate in the platform, which may include guest/customer details, booking and stay information, communication content, transaction and invoicing references, and technical usage logs necessary to provide and secure the service.

Cookies and Tracking Technologies

Cookies are small text files stored on your device when you visit a website. Moder Oy uses cookies and similar technologies to ensure website functionality, improve user experience, analyse website usage, and measure the effectiveness of marketing campaigns. Where required by law, we request your consent before placing non-essential cookies. You can manage or withdraw your cookie preferences at any time via your browser settings or our cookie banner. You may use our website without accepting non-essential cookies. You can view our full Cookie Policy here.

Purpose of Processing Personal Data

Moder Oy processes personal data to provide, operate, and maintain the Moder platform, communicate with customers, partners, and prospects, deliver newsletters, insights, and event invitations, improve services, products, and website performance, conduct analytics and performance measurement, ensure security and prevent misuse, and comply with legal and regulatory obligations.

Data Storage and Retention

Personal data is stored in Moder Oy’s systems, by trusted third-party service providers acting on our behalf, and as cookies on your device where applicable. We retain personal data only for as long as necessary to fulfil the purpose for which it was collected or as required by applicable law. When personal data is no longer needed, it is securely deleted or anonymised.

Service Providers and Data Transfers

Moder Oy uses carefully selected third-party service providers to support its business operations, including CRM and marketing tool Pipedrive. Pipedrive Web Visitors tracker collects data through Leadfeeder’s AWS infrastructure, where it is encrypted both in transit and at rest.

We collect the behavioral data of all website visitors, which includes pages viewed, visitor sources and time spent on the site. The visitor’s IP address is collected to detect the company and geographic location. We only show company visits and automatically filter out all users visiting from residential IP addresses.

We use Google Analytics as our analytics tool, and advertising platforms such as LinkedIn and Meta/Facebook and Google Ads. These service providers process personal data on our behalf under data processing agreements and appropriate safeguards. Where personal data is transferred outside the EU or EEA, Moder Oy ensures adequate protection in accordance with GDPR.

Data Security

Moder Oy takes the protection of personal data seriously and implements appropriate technical and organisational measures, including encryption, access controls, firewalls, malware protection, internal security policies, and restricting access to personal data on a need-to-know basis. We also require our partners and service providers to apply equivalent security standards.

Your Rights

Under GDPR, you have the right to access your personal data, request correction of inaccurate or incomplete data, request deletion of your personal data, restrict or object to processing, request data portability, withdraw consent at any time where applicable, and lodge a complaint with a supervisory authority. Moder Oy responds to all legitimate requests without undue delay.

Supervisory authority in Finland: Tietosuojavaltuutetun toimisto (Office of the Data Protection Ombudsman).

Contact Information

If you have questions about this Privacy Policy or wish to exercise your rights, you may contact Moder Oy at hello@moder.app. You may request access to your data, correction or deletion of data, data portability, or withdrawal of consent by contacting us.

Changes to This Privacy Policy

Moder Oy updates this Privacy Policy when required due to changes in our services, legal obligations, or personal data processing practices. The latest version is always published on our website and identified by its effective date.