This Privacy Policy applies to the Motti Mobile entities listed here (“Motti“, “we“, “us“, “our“) and explains how we collect, record, hold, store, use, disclose, or otherwise process (collectively “Process“) personal information.

You accept this policy when you use or sign up for our services, feature or functionality offered by us.

Purpose of this Policy

We take these activities seriously and do our best effort to provide fair, secure, and fully-legal systems for the appropriate handling of private and personal information. All such activities at Our Company are intended to be consistent with both generally accepted privacy ethics and standard business practices.

Private and Personal information (also referred to as “personal data” in some jurisdictions) is any information or a combination of pieces of information, that can be used to identify you or that we can link to you, including but not limited to a name, address, email address or telephone number among others.

Your information may be supplemented with additional information from other companies such as publicly available information and other information which we may append or match to your information.

The following Privacy Policy describes how we collect and use the personal information you provide to us. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.

General Summary

Our primary activity is supporting our clients in relation to their own marketing, loyalty and rewards programs, and other customer-related marketing functions (together, “Programs“). As members or registered users of, or otherwise participants of a Program (or are interested in or eligible to become a member of a Program) we may collect your personal information.

We process this personal information on behalf of our clients, and our clients are responsible for its use. In cases where European Union GDRP data protection law applies, our entities serve as processors of such personal information, and, where they are required by applicable data protection law, our clients will explain more about how personal information is used in their Programs.

Despite the above, we collect personal information for our own use therefore unless we inform you otherwise, the Motti entity that you interact with that links to this Privacy Policy is responsible for the collection and use of your personal information.

Our websites and Programs are not directed toward individuals under the age of 18 and we do not knowingly or intentionally collect or process personal information from individuals under the age of 18.

Our websites and Programs cannot guarantee to honor “do not track” settings on web browsers and may not offer you full control to request that we not track your use of its services except as otherwise stated in this Privacy Policy or our Cookies Policy.

How we collect personal information

If you register for an account or use our Programs, we may collect the following types of information:

• Contact information - your name, address, phone, email, and other similar information.

• Business information - bank and/or credit card account numbers that you link to your selected payment method.

• Transaction information – interaction with our Programs such as purchases, actions and behaviors you make.

When you register with us, we use certain information previously collected from you to set up a profile. After you register, you may provide additional member information about yourself and add profile information about you or your business in the My Profile section. Such member and company profiles could include, as needed, a description of your interests in products, purchase experience, consumer behaviors, and membership in marketing organizations.

Before allowing you to use Motti, we may require you to provide additional information we can use to verify your identity or address, or manage risk, such as your date of birth, tax id, or other information. We may also obtain supplementary information about you from third parties such as credit bureaus, KYC, AML control & transparency and identity verification services.

When you using our Programs, we collect information about your activities on our website and we may collect information about your device for fraud prevention purposes.

As is true of most web sites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users’ movements around the site and to gather demographic information about our user base as a whole. In addition, we may also offer communication tools between Motti Program members in which you can contact, or be contacted, if an interest in an opportunity arises. You understand and agree that when you send a notification to another user, that user will have access to your information because it is displayed within the invitation. We may collect additional information from or about you in other ways such as contacts with our customer support team and from other companies.

In addition, our Web site offers publicly accessible message boards. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our message board, contact us at legal@motti.com.

In some cases, and due to technical, legal or fiscal requirements, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. Where permitted by applicable law, we may also collect and Process personal information from other sources for our own use, including but not limited to information from social media platforms (for example, when you interact with us on those platforms or access our social media content); and publicly available or publicly accessible sources.

Careers: If you wish to apply for an open position on our “Careers” page, you have the option to upload your resume. We will only use and store your resume on file for the sole purpose of evaluating it in connection to any available position within our organization.

How we use personal information

Your Personal information is used to operate and improve the features, offerings and content presented; to personalize the content and advertisements provided; to fulfill requests for services; to communicate with and respond to inquiries; to conduct research about your use of our services; to display information about you and your business; to communicate with other users and business contacts; and, to help offer you other services that may be of interest to you.

The contents of your online communications, as well as other information about you and our clients, shall not be monitored, however they may be accessed and disclosed in response to lawful governmental requests or legal process, in other circumstances in which we have a good faith belief that a crime has been or is being committed by a user, that an emergency exists that poses a threat to the safety of you or another person, when necessary either to protect our property, or for us to render the service you have requested.

We may automatically Process your personal information to evaluate personal aspects and predict outcomes with automated rules and decisions about you based on your personal information to show tailored content on our websites and Programs.

European GDRP data protection law requires us to have a legal basis to Process your personal information. In most cases where we need a legal basis, it will be one of the following:

a) To fulfil our contractual obligations to you, for example to provide the services you have requested. Failure to provide this information may prevent or delay the fulfilment of these contractual obligations;

b) To comply with our legal obligations;

c) To meet our legitimate interests, for example to understand how you use our services and to enable us to derive knowledge from that information to develop new services.

When we Process personal information to meet our legitimate interests, we place safeguards in place to ensure that your privacy is protected and that our legitimate interests are not overridden by your interests or fundamental rights and freedoms.

In carrying out our business, it may be necessary to share information about you with third parties, such as:

- Motti Companies: we may share certain information, including for example, information relating to your inquiry about our services, between entities in the Motti group.

- Service providers: like most large organizations we use a range of service providers to help us maximize the quality and efficiency of our services and our business operations.

- Law enforcement agencies: Ordered by a subpoena we may share personal information with these parties where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.

- Asset purchasers: A company with which we are involved in a merger, acquisition, or sale of all or a portion of its assets. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal information uses it in a manner that is consistent with this Privacy Policy.

- Good Faith: Under the belief in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our Terms and Conditions.

Marketing Services and Marketplace

Your Personal information will not be shared with third parties for their marketing purposes unless it is necessary to fulfill a transaction you have requested, or in other circumstances in which you have given your consent to the sharing of your information to our affiliates, partners, agents or other parties whose products or services we believe may be of interest to you.

Since Motti is designed to help companies and business professionals create marketing experiences and run loyalty and rewards programs with others, Motti services are designed so that certain information about you and your business is available to others and via the internet on our Marketplace. If you wish to request removal of your information from our Marketplace, please refer to the “Contact Us” section below.

We partner with third-party networks to either display advertising on our Web site or to manage our advertising on other sites. Our network partner uses cookies and Web beacons to collect non-personally identifiable information about your activities on this and other Web sites to provide you with targeted advertising based on your interests.

If you wish to not have this information used for the purpose of serving you targeted ads, you may opt out by clicking here. If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you.

Out of respect for your privacy, you may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in those emails, accessing the email preferences in your account settings page or you can contact us at legal@motti.com. This exclusion does not apply to notices we provide you about your account.

Our Site includes links to other Web sites whose privacy practices may differ from those of Motti. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any Web site you visit.

Security

Throughout this policy, we use the term "personal information" to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that is anonymous so that it does not identify a specific user.

We make available a secure page for entering sensitive information (such as credit card number), protected by industry-standard SSL encryption technology. This technology encrypts your information prior to transmitting it over the Internet.

We maintain the confidential information you provide us in a secure database. We further require credentials such as a user identification and password to limit access to registered accounts. Please keep in mind that while we have established safeguards to help prevent unauthorized access to or misuse of your Motti information, no method of transmission over the Internet, or method of electronic storage, is 100% secure however, and we cannot guarantee that your personally identifiable information will never be disclosed in a manner inconsistent with this Privacy Policy (for example, in the event of unauthorized acts by third parties that violate the applicable law or our policies).

We store and process your personal information through a third party and they protect it by maintaining physical, electronic and procedural safeguards in compliance with the highest security standards. The use of computer safeguards such as firewalls and data encryption is also provided by our supplier.

Personal Information transfers outside the jurisdiction of collection

In the conduct of our business, we disclose to, hold or access personal information from various countries including without limitation United States of America, Mexico, Spain, Argentina, Canada, the Caribbean and Colombia.

We may disclose personal information to destinations outside the jurisdiction from which it was collected.

The privacy laws of the countries to which we transfer personal information may not provide the same level of protection as the privacy laws of the country from which the personal information was collected or be regarded as ensuring an adequate level of protection for personal information under European data protection law. However, this does not change our commitments to safeguard your privacy and we will put in place appropriate safeguards in accordance with applicable legal requirements to ensure that your personal information is adequately safeguarded.

Retention of Personal Information

We will keep your personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information for a period at least five full calendar years ending on December 31st of the corresponding year.

We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the information.

Future changes to our Privacy Policy

We operate in a dynamic business environment. Over time, aspects of our business may change as we respond to changing market conditions. This may require our policies to be reviewed and revised. We may change this Privacy Policy at any time.

The most current version of this policy will govern our use of your information and will always be available via a link from our website. Please check this link often for changes.

In the event that we make any material changes we will notify you or by means of a notice on this website prior to the change becoming effective.

We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Us

If you have further questions or concerns that have not been addressed in this statement, please send inquiries to: legal@motti.com

Please be sure to include your name, address and email so we can contact you.

This Privacy Policy is effective as of September 1st 2022