Privacy Policy
Last Updated: 13/11/2025
1. Introduction
Welcome to Modan ("we," "us," "our"). We operate a FX and price discovery platform for cross-border payments services (the "Service"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website https://modan.io and use our Service.
We are committed to protecting your privacy and complying with applicable data protection laws, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
Data Controller Information:
- Company Name: Soft Signal Ltd
- Registered Address: 20-22 Wenlock Road, London, N1 7GU, UK
- Contact Email: privacy@modan.io
2. Information We Collect
2.1 Information You Provide Directly
Contact Information:
- Name
- Email address
- Phone number (optional)
- Country of residence
Service Preferences:
- Currency pairs and corridors of interest
- Watchlists and saved views
- Rate alert configurations (corridors, thresholds, frequency)
- Company or institution and stated use case (optional, provided at signup)
Developer / API Usage:
- API key names and hashed key material (we never store raw keys)
- API request metadata (endpoint, timestamp, response status and latency)
2.2 Information Collected Automatically
Technical Information:
- IP address
- Browser type and version
- Device information (type, operating system)
- Time zone settings
- Browser plug-in types and versions
- Operating system and platform
Usage Information:
- Pages visited on our Service
- Time and date of visits
- Time spent on pages
- Click patterns and interaction with comparison tools
- Search queries within our Service
- Referring website addresses
2.3 Information from Third Parties
We may receive limited information from:
- Analytics providers (Google Analytics)
- Advertising networks
- Search information providers
- Technical service providers
3. Legal Basis for Processing
We process your personal data based on the following legal grounds:
- Consent: For marketing communications and non-essential cookies
- Legitimate Interests: For providing and improving our Service, fraud prevention, and network security
- Contract Performance: To provide requested services and support
- Legal Obligations: To comply with applicable laws and regulations
4. How We Use Your Information
4.1 Provide Core Services
- Display real-time exchange rates and pricing data from providers
- Generate market data insights based on your specified criteria
- Send requested rate alerts and market updates
- Provide customer support and respond to inquiries
4.2 Improve Our Service
- Analyze usage patterns to enhance user experience
- Develop new features and comparison tools
- Conduct market research and analysis
- Test and troubleshoot technical issues
4.3 Communications
- Send service-related notifications
- Provide requested exchange rate alerts
- Send newsletters and market insights (with consent)
- Respond to customer service requests
4.4 Legal and Security
- Prevent fraudulent use of our Service
- Comply with legal obligations
- Enforce our Terms of Service
- Protect rights, property, and safety
5. Information Sharing and Disclosure
We do not sell, trade, or rent your personal information. We may share information with:
5.1 Service Providers
Carefully selected third parties who assist us in:
- Hosting and infrastructure services
- Email delivery services
- Analytics and performance monitoring
- Customer support tools
5.2 Business Transfers
In the event of a merger, acquisition, or sale of assets, your information may be transferred.
5.3 Legal Requirements
We may disclose information when required to:
- Comply with legal obligations
- Respond to lawful requests from public authorities
- Protect our rights and safety
- Prevent fraud or illegal activities
5.4 Partner Providers
We do NOT share your personal information with the service providers whose rates we display unless you explicitly choose to be redirected to their services.
6. Data Retention
We retain personal information for as long as necessary to:
- Provide requested services
- Comply with legal obligations
- Resolve disputes and enforce agreements
Specific retention periods:
- Contact information: Until you unsubscribe or request deletion
- Usage data: 24 months
- Cookie data: See Cookie Policy below
- Support correspondence: 3 years
7. Your Rights
Under UK GDPR, you have the right to:
- Access: Request a copy of your personal data
- Rectification: Correct inaccurate or incomplete data
- Erasure: Request deletion of your data ("right to be forgotten")
- Restriction: Limit processing of your data
- Portability: Receive your data in a structured format
- Object: Object to certain types of processing
- Withdraw Consent: Where processing is based on consent
To exercise these rights, contact us at support@modan.io.
8. Data Security
We implement appropriate technical and organizational measures to protect your information, including:
- SSL/TLS encryption for data transmission
- Secure data storage with encryption at rest
- Regular security assessments and updates
- Limited access controls and authentication
- Regular staff training on data protection
However, no method of transmission over the internet is 100% secure.
9. International Transfers
Your information may be transferred to and processed in countries outside the UK/EEA. We ensure appropriate safeguards are in place through:
- Standard Contractual Clauses
- Adequacy decisions
- Your explicit consent where required
10. Children's Privacy
Our Service is not intended for individuals under 18 years of age. We do not knowingly collect personal information from children.
11. Third-Party Websites
Our Service displays information from and may link to third-party service providers. We are not responsible for their privacy practices. Please review their privacy policies before providing any information to them.
12. Changes to This Policy
We may update this Privacy Policy periodically. We will notify you of material changes via email or prominent notice on our Service.
13. Contact Us
For privacy-related questions or concerns:
Data Protection Officer
Soft Signal Ltd
Email: support@modan.io
Address: 20-22 Wenlock Road, London, N1 7GU, UK
You also have the right to lodge a complaint with the Information Commissioner's Office (ICO):
- Website: https://ico.org.uk
- Phone: 0303 123 1113
Cookie Policy
Last Updated: 13/11/2025
1. What Are Cookies?
Cookies are small text files placed on your device when you visit our website. They help us provide you with a better experience and understand how our Service is used.
2. How We Use Cookies
We use cookies for the following purposes:
2.1 Essential Cookies (Strictly Necessary)
These cookies are required for our Service to function properly.
| Cookie Name | Purpose | Duration |
|---|---|---|
| session_id | Maintains user session | Session |
| security_token | Security and fraud prevention | Session |
| cookie_consent | Stores cookie preferences | 12 months |
2.2 Functional Cookies
These enhance functionality and personalization.
| Cookie Name | Purpose | Duration |
|---|---|---|
| currency_preference | Remembers preferred currency pairs | 30 days |
| corridor_preference | Remembers corridor preferences | 30 days |
| language | Language preference | 12 months |
| timezone | User timezone for rate displays | 30 days |
2.3 Analytics Cookies
These help us understand how visitors interact with our Service.
| Cookie Name | Purpose | Duration |
|---|---|---|
| _ga | Google Analytics - distinguishes users | 2 years |
| _gid | Google Analytics - distinguishes users | 24 hours |
| _gat | Google Analytics - throttle request rate | 1 minute |
| _utm* | Google Analytics - campaign tracking | 6 months |
2.4 Marketing Cookies
Used to deliver relevant advertisements and track campaign effectiveness.
| Cookie Name | Purpose | Duration |
|---|---|---|
| _fbp | Facebook Pixel | 90 days |
| _gcl_au | Google Ads conversion tracking | 90 days |
| IDE | Google DoubleClick | 13 months |
3. Third-Party Cookies
Some cookies are placed by third-party services that appear on our pages:
- Google Analytics: For website analytics
- Google Ads: For advertising effectiveness
- Facebook Pixel: For social media advertising
- Hotjar: For user behavior analytics (if applicable)
4. Managing Cookies
4.1 Cookie Consent Tool
Upon first visit, you can accept or reject non-essential cookies through our cookie banner.
4.2 Browser Settings
You can control cookies through your browser settings:
- Chrome: Settings > Privacy and Security > Cookies
- Firefox: Settings > Privacy & Security > Cookies
- Safari: Preferences > Privacy > Cookies
- Edge: Settings > Privacy, Search, and Services > Cookies
4.3 Opt-Out Links
- Google Analytics: https://tools.google.com/dlpage/gaoptout
- Google Ads: https://adssettings.google.com
- Facebook: https://www.facebook.com/ads/preferences
5. Impact of Rejecting Cookies
- Essential Cookies: Cannot be rejected as the Service won't function properly
- Functional Cookies: Some features may not work as expected
- Analytics/Marketing Cookies: No impact on Service functionality
6. Do Not Track Signals
We currently do not respond to Do Not Track browser signals. However, you can control tracking through our cookie preferences.
7. Local Storage
In addition to cookies, we may use local storage (HTML5) to store preferences and improve performance. This can be managed through browser settings.
8. Updates to Cookie Policy
We may update this Cookie Policy to reflect changes in our practices or legal requirements. Check the "Last Updated" date for the latest version.
9. Contact Us
For questions about our use of cookies:
- Email: support@modan.io
Additional Recommended Clauses
Data Processing Agreements
For B2B services or API access, we maintain Data Processing Agreements (DPAs) compliant with Article 28 of UK GDPR. Contact support@modan.io to request a DPA.
California Privacy Rights
If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), including:
- Right to know what personal information is collected
- Right to know if personal information is sold or disclosed
- Right to opt-out of the sale of personal information
- Right to non-discrimination
Automated Decision-Making
We do not use automated decision-making or profiling that produces legal effects or similarly significantly affects you. Our price comparisons are based on publicly available rates and do not involve automated decisions about individual users.
Privacy by Design
- Data minimization - we only collect necessary information
- Purpose limitation - we only use data for stated purposes
- Privacy settings default to most protective options
- Regular privacy impact assessments
Breach Notification
In the unlikely event of a data breach that poses a risk to your rights and freedoms, we will:
- Notify the ICO within 72 hours
- Notify affected individuals without undue delay
- Provide information about the breach and mitigation steps
Accessibility
We are committed to making our privacy information accessible to all users. For alternative formats of this policy, please contact support@modan.io.
Lawful Basis for Marketing
We rely on consent for marketing communications. You can withdraw consent at any time by:
- Clicking "unsubscribe" in any marketing email
- Contacting us at support@modan.io
- Updating preferences in your account settings
Data Protection Impact Assessments
We conduct Data Protection Impact Assessments (DPIAs) when implementing new technologies or processing activities that may pose high risks to individual privacy.
Special Category Data
We do not intentionally collect special category data (racial/ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, biometric data, health data, or data concerning sex life or sexual orientation).
Accountability and Governance
We maintain comprehensive records of processing activities and implement appropriate technical and organizational measures to ensure and demonstrate GDPR compliance.