09/01/2025

​

At Mottoz, your trust is our priority. This Privacy Policy (“Policy”) explains how MOTTOZ USA LLC / UE INVESTMENT INC. and its affiliates (“Mottoz”, “we”, “our”, or “us”) collect, use, share, and protect your personal information when you use our services.

This Policy applies to our websites, apps, platforms, and communication channels (collectively, the “Services”). By using Mottoz, you agree to this Policy and our Terms of Service.

 

I. Introduction

Scope of This Privacy Policy

This Privacy Policy applies to all natural persons and legal entities (collectively, "Users") who access, interact with, or otherwise engage with any part of the Mottoz ecosystem, including but not limited to:

• End consumers
   

• Microentrepreneurs and business partners
   

• Franchisees and white-label clients (MOTTOZ BOLT)
   

• Delivery partners, drivers, and contractors
   

• Merchants and service providers (including Mottoz SeaPro, Pulse, and Neighborhood)
   

• Corporate clients, investors, and technology integrators
   

This Policy governs the collection, processing, use, retention, transfer, and disclosure of Personal Information and Sensitive Data, obtained directly or indirectly, through engagement with Mottoz’s digital infrastructure.

This includes interactions with:

• Mobile applications (e.g., Mottoz Customer, Driver, Partner, Bolt, SeaPro, and Pulse apps)
   

• Web platforms, dashboards, and portals
   

• APIs and third-party integrations
   

• Communication systems, including in-app chat, SMS, WhatsApp, email, and customer service channels
   

• Augmented reality and IoT tools, such as MOTTOZ LENS and MAIA-enabled services
   

• Back-office tools used by franchisees and corporate administrators
   

By creating an account, placing or receiving an order, operating as a delivery or service partner, using white-label infrastructure, participating in reviews or surveys, or otherwise utilizing any functionality of Mottoz services (collectively, the “Services”), Users consent to the processing of their data under this Privacy Policy, the Terms of Service and in accordance with applicable U.S. federal and state laws, EU regulations (e.g., GDPR), LATAM data protection frameworks, and other international privacy standards.

 

Purpose of This Privacy Policy

The purpose of this Privacy Policy is to provide clear, transparent, and enforceable information to all Users regarding how Mottoz manages Personal Information throughout its digital and operational ecosystem.

This Policy is designed to help Users understand:

1. What Information We Collect

The types and categories of Personal Information we collect, including:

• Data provided directly by Users (e.g., account details, preferences, payment data)
   

• Data automatically generated through platform use (e.g., geolocation, order history, device IDs)
   

• Data obtained from authorized third parties (e.g., marketing partners, public sources, analytics tools)
   

2. Why We Collect It

The legitimate purposes and legal bases for data collection and processing, including:

• Performance of services and fulfillment of orders or contractual obligations
   

• Fraud detection and platform security
   

• Personalization and user experience optimization (e.g., via MAIA AI engine)
   

• Regulatory compliance, including tax, health, or consumer protection laws
   

• Operational analytics, marketing performance, and innovation
   

3. How We Use and Manage It

How Personal Information is:

• Used within Mottoz to provide, operate, improve, and customize services
   

• Stored securely using encrypted cloud infrastructure and access controls
   

• Processed and transferred, including across borders, systems, and vendors
   

• Shared or disclosed, strictly under legitimate business needs or legal obligations
   

4. User Rights and Choices

The rights Users have under applicable data privacy laws, including:

• Right to Access and review their Personal Information
   

• Right to Correction of inaccurate or outdated data
   

• Right to Deletion (where applicable)
   

• Right to Data Portability
   

• Right to Object or Opt-Out of certain processing activities, such as direct marketing or automated decision-making
   

This Policy is intended to ensure full compliance with relevant data protection regulations, including but not limited to:
CCPA, CPRA, GDPR, LGPD, and other applicable national or state-level privacy frameworks.

Mottoz is committed to the principles of transparency, data minimization, accountability, and user empowerment. We continuously update our policies and systems to reflect evolving legal standards and emerging technologies.

By continuing to use the Mottoz platform, Users affirm that they have read, understood, and accepted this Privacy Policy, and consent to the processing of their Personal Information as described herein.

 

Updates to This Privacy Policy

Mottoz may amend, revise, or update this Privacy Policy periodically to reflect:

• Changes in our business model or service offerings (including new verticals or features such as SeaPro, Pulse, or Neighborhood)
   

• Technological advancements (e.g., integration of AI tools such as MAIA, or updates to our data infrastructure)
   

• Evolving regulatory requirements across jurisdictions, including local, federal, and international data protection laws (e.g., GDPR, CCPA, LGPD)
   

• Internal governance enhancements or best-practice privacy standards
   

 Notification of Material Changes

When material updates occur—such as the collection of new types of Personal Information, introduction of new processing purposes, or expansion of third-party data sharing practices—Mottoz will provide clear, proactive, and timely notice to Users via one or more of the following methods:

• Email sent to the User’s registered email address
   

• In-app notification or pop-up, requiring acceptance or acknowledgment before continuing use
   

• Banner or prominent notice on the Mottoz website, portal, or user dashboard, including the effective date of the revised Policy
   

 Effective Date and Continued Use

Unless otherwise specified, updates to this Policy take effect immediately upon publication. Continued access to or use of the Mottoz platform following the effective date will constitute the User’s acknowledgment and binding acceptance of the updated Privacy Policy.

 Consent for Significant Changes

Where required by applicable law, or where an update materially affects Users’ rights or changes the legal basis for processing, Mottoz will seek explicit consent from Users prior to implementation of such changes.

Mottoz encourages Users to review this Privacy Policy regularly to stay informed about how we protect their data and privacy as our platform evolves.

 

II. Personal Information We Collect

In the course of delivering our Services, Mottoz collects and processes various categories of Personal Information, as defined under applicable privacy and data protection laws. This data may originate from:

• Direct interactions with the platform by the User
   

• Automated technologies that monitor usage patterns or device behavior
   

• Verified third-party sources or business partners (e.g., payment providers, marketing affiliates, ID verification services)
   

1. Information You Provide Directly

These are the types of Personal Information you voluntarily submit when engaging with the Mottoz platform, including during registration, onboarding, transactions, or customer support interactions:

🧾 Contact & Account Information

• Full name
   

• Email address
   

• Mobile phone number
   

• Residential and/or business address (for delivery and billing)
   

• Profile photo (if applicable)
   

• Date of birth (when required for service eligibility or legal compliance)
   

• Login credentials: username, password, one-time passcodes, authentication tokens
   

 Payment & Billing Information

• Payment method details: credit/debit card number, expiration date, security code (if applicable)
   

• Billing contact details: name on card, billing address
   

• Payment confirmation metadata (e.g., transaction ID, authorization tokens)

 

• Credit/Debit Card Information: Card number (processed in tokenized or encrypted form), expiration date, and card verification code.
   

• Digital Wallets and Alternative Payment Methods: Payment data from third-party providers such as Apple Pay, Google Pay, PayPal, or other authorized payment services.
   

• Billing Details: Name on the account, billing address, and transaction-related metadata (e.g., date, time, and purchase confirmation).
   

For your protection, sensitive payment information is not stored directly by Mottoz. Instead, such data is collected, transmitted, and processed securely by our authorized third-party payment providers, in accordance with PCI-DSS (Payment Card Industry Data Security Standard) and other applicable laws. Mottoz may retain only limited non-sensitive data, such as the last four digits of your card, expiration date, and payment confirmation tokens, for recordkeeping, fraud prevention, and customer support purposes.

 

Note: Mottoz does not store full card details directly. All payment transactions are processed by PCI-DSS-compliant third-party payment processors.

 Identity Verification & Compliance Data

Where required for fraud prevention, age-restricted services (e.g., alcohol), or legal obligations, we may collect:

• Government-issued IDs (e.g., passport, national ID, driver’s license)
   

• Related metadata: ID number, issuing country, expiration date, date of birth
   

• Facial images or selfie photos submitted for identity verification (e.g., KYC processes)
   

• Results from third-party verification providers (when integrated)
   

 Communications & User-Generated Content

• Direct communications via in-app chat, emails, support requests, or surveys
   

• Public reviews, ratings, testimonials, or feedback submitted through the platform
   

• Uploaded content: photos, videos, or documents submitted voluntarily
   

• Participation in promotional campaigns, contests, or beta testing
   

 Transactional & Order Data

• Details of orders placed: product or service type, quantity, delivery instructions
   

• Pricing information: base price, tips, discounts, taxes, fees
   

• Promo codes, referral bonuses, or loyalty points earned or redeemed
   

• Time stamps, delivery status, and fulfillment history

 

Communications & Content

We collect information from your interactions with Mottoz, other Users, and Merchants, including but not limited to:

• Chats & Calls: Content of in-app messages, SMS/text communications, masked calls with drivers or merchants, and, where permitted by law and disclosed in advance, call recordings for quality assurance and dispute resolution.
   

• Surveys & Feedback: Information you provide in response to surveys, contests, promotions, or sweepstakes organized by Mottoz or its partners.
   

• Reviews & Ratings: User-generated content such as reviews, ratings, or feedback regarding merchants, drivers, or services provided on the Mottoz platform.
   

• Uploaded Media: Any photos, videos, voice recordings, or other content voluntarily shared by you in connection with your use of the platform.
   

This data may be used to address customer support issues, resolve disputes, enforce quality and safety standards, and enhance platform functionality.

 

Identity Verification (where required)

For legal compliance, fraud prevention, and access to certain services (including delivery or purchase of age-restricted products, such as alcohol or tobacco), Mottoz may request and process identity verification data, including:

• Government-Issued Identification: Driver’s license, passport, or other forms of identification, which may include details such as name, date of birth, expiration date, identification number, and issuing authority.
   

• Selfies or Biometric Verification: Real-time photos or video captured for the purpose of comparing with ID documents to confirm identity and prevent account fraud.
   

• Electronic or Digital Signatures: Captured in connection with proof of delivery, verification of receipt of age-restricted goods, or other contractual acknowledgments.
   

All identity verification data is processed in accordance with applicable privacy and consumer protection laws, retained only for as long as legally necessary, and safeguarded through administrative, technical, and physical security measures.

Information Collected Automatically

When you engage with the Mottoz platform—whether through our mobile applications, web interfaces, APIs, or integrated third-party services—we automatically collect certain categories of technical and behavioral information. This data is essential for ensuring platform functionality, user experience optimization, operational integrity, and compliance with applicable laws.

a.  Device & Usage Data

We collect information about the devices and browsers you use to access our Services, including:

• IP Address & Unique Identifiers: Such as Internet Protocol (IP) address, device ID, advertising ID (e.g., IDFA, GAID), and hardware fingerprints
   

• Device Characteristics: Device type, model, manufacturer, operating system and version, carrier, hardware settings, screen resolution, language preference, and time zone
   

• Browser Metadata: Browser type, version, configuration, and plug-in details
   

• App Interaction Logs: Screens viewed, features used, time spent on pages, scroll behavior, and navigation paths
   

• Crash & Diagnostic Reports: App performance metrics, system logs, crash dumps, and latency indicators
   

This information is used to troubleshoot errors, monitor performance, detect misuse or unauthorized access, and ensure platform stability and scalability.

 

b.  Location Data

Subject to your device settings and permissions, we may collect geolocation data to support our delivery and matching algorithms:

• Precise Location (GPS): Real-time, high-accuracy location sourced from your device’s GPS module
   

• Proximity Location: Inferred from Bluetooth, Wi-Fi networks, or nearby cellular towers
   

• IP-Based Location: Approximate geolocation inferred from your IP address (typically at the city or region level)
   

We use this data to:

• Match users with nearby merchants, drivers, and partners
   

• Calculate accurate delivery times and available services
   

• Enable route optimization, dispatch efficiency, and order prioritization
   

• Detect suspicious activity, fraud, or misuse (e.g., spoofing or account hijacking)
   

• Produce aggregated geospatial analytics to improve coverage and demand prediction
   

You may adjust your device permissions at any time to limit or disable location data collection. Note, however, that certain features may be unavailable or less accurate as a result.

c.  Cookies & Tracking Technologies

Mottoz, along with our authorized third-party partners, uses a range of tracking technologies to understand how Users interact with the platform. These include:

• Cookies & Local Storage: Small text files saved in your browser or device to remember login state, language preferences, or previous actions
   

• Web Beacons & Pixel Tags: Transparent graphics or embedded code used to monitor engagement with emails, digital ads, or platform features
   

• Mobile SDKs & App Identifiers: Integrated code libraries that measure in-app usage patterns, support crash reporting, or enable personalized messaging
   

We leverage these technologies to:

• Authenticate Users and maintain secure sessions
   

• Deliver relevant advertisements and limit ad frequency
   

• Understand behavioral trends and user journeys
   

• Optimize UI/UX and conversion performance
   

• Detect anomalous behavior and protect against fraud or abuse
   

For full details on our use of cookies, and how you can manage your preferences, please refer to Section VII: Cookies and Tracking Technologies Policy.

 

Information from Third Parties

In addition to the information you provide directly and that which is automatically collected, Mottoz may obtain Personal Information about you from third-party sources. This information is combined with other data we hold to enhance platform functionality, verify identities, maintain security, and personalize services. Such third-party data sources include, without limitation:

a. Social Media & Authentication Services

If you choose to access the Mottoz platform or create an account using third-party authentication providers (e.g., Google, Facebook, Apple ID, or other social media or identity services), these platforms may share with us certain information you have authorized, such as:

• Name, profile picture, email address, contact list, and other basic account information;
   

• Authentication tokens or identifiers necessary to enable login and account linking.
   

The information shared with Mottoz depends on your privacy settings with the third-party provider. We do not control the privacy or data handling practices of these platforms, and Users are encouraged to review their applicable privacy policies.

b. Merchants, Business Partners & Enterprise Accounts

We may receive information from merchants, vendors, and corporate partners who integrate with Mottoz or participate in enterprise arrangements. This may include:

• Loyalty and Rewards Programs: Account identifiers, points balance, and redemption history where you have linked your Mottoz account with a merchant’s program.
   

• Enterprise Accounts: Employment or organizational data (e.g., employer name, student ID, corporate billing information) to facilitate subsidized services, group accounts, or expense reporting.
   

• Co-Marketing & Promotional Campaigns: Contact details and engagement information where you have consented to joint promotional activities between Mottoz and its partners.
   

c. Fraud Prevention, Security & Verification Partners

To maintain the integrity of the platform, Mottoz may obtain additional data from fraud detection, identity verification, and cybersecurity service providers, including:

• Confirmation of whether the information provided matches known persons or fraudulent profiles;
   

• Risk scoring or fraud indicators based on device usage, transaction patterns, or prior suspicious activity;
   

• Verification of government-issued identification, phone numbers, or payment credentials to prevent unauthorized account access.
   

This data is used strictly for fraud detection, identity verification, compliance with applicable laws (such as age-restricted deliveries), and safeguarding the rights, property, and security of Mottoz, its Users, and third parties.

 

III. How We Collect Personal Information

Mottoz collects Personal Information through various channels to provide, operate, and improve our Services, and to comply with applicable legal and contractual obligations. The methods of collection include, without limitation:

1. Directly from You

We collect Personal Information that you voluntarily provide when you interact with Mottoz, including:

• Account Creation and Profile Setup: Information such as your name, email, phone number, password, and delivery address when you register for a customer, driver, or merchant account.
   

• Transactions and Orders: Payment credentials, billing details, and delivery instructions when placing an order or completing a transaction.
   

• Customer Support and Communications: Content of messages, calls, or emails when you contact Mottoz for assistance, provide feedback, or participate in surveys, promotions, or referral programs.
   

By providing this information, you consent to its collection and use for the purposes described in this Policy.

2. Automatically

When you access or use the Mottoz platform, we automatically collect certain categories of data through technological tools and tracking mechanisms, including:

• Device and Usage Data: IP address, device identifiers, operating system, browser type, app activity, crash logs, and performance data.
   

• Location Data: GPS signals, Wi-Fi networks, and IP-based geolocation, which may be used for delivery assignments, fraud detection, and service optimization.
   

• Cookies and Similar Technologies: Tracking tools that help personalize advertising, analyze user trends, and improve platform performance.
   

Such automated collection ensures the security, functionality, and continuous improvement of the Services.

3. From Third Parties

We may also obtain Personal Information from external sources, including:

• Social Media and Authentication Services: If you log in through Google, Facebook, Apple, or similar services, which may provide us with identifiers, contact details, and profile information.
   

• Merchants and Enterprise Partners: Loyalty program data, organizational details, or billing information shared by restaurants, vendors, or business partners in connection with enterprise or group accounts.
   

• Payment Processors and Financial Institutions: Limited payment-related details (e.g., verification results, card type, or account confirmations) necessary to complete transactions securely.
   

• Fraud Prevention and Security Providers: Data used to confirm identity, detect fraudulent activity, and maintain platform integrity.
   

Mottoz combines this third-party information with data collected directly and automatically to ensure accuracy, prevent abuse, and deliver a secure, seamless experience.

 

IV. How We Use Personal Information

Mottoz processes Personal Information solely for legitimate business purposes, in accordance with applicable privacy and data protection laws, and always in a manner consistent with this Privacy Policy. The purposes of processing include, without limitation:

1. To Provide, Operate, and Improve the Services

We use Personal Information to deliver a seamless and efficient user experience, including to:

• Process Transactions: Facilitate orders, deliveries, and secure payments between customers, drivers, and merchants.
   

• Enable Personalized Features: Provide customized recommendations, promotions, loyalty rewards, and marketing communications tailored to user preferences.
   

• Account Management: Maintain account functionality across multiple devices, enable login, manage preferences, and support enterprise or loyalty program integrations.
   

• Service Enhancement: Conduct analytics, performance monitoring, and user trend evaluations to improve and expand the features, reliability, and usability of the Mottoz platform.
   

2. To Ensure Safety, Security, and Compliance

Protecting the integrity of the platform and its participants is a core priority. We use Personal Information to:

• Fraud and Abuse Prevention: Detect, investigate, and mitigate fraudulent activity, unauthorized transactions, and malicious behavior.
   

• Identity Verification: Confirm driver and user identities, including through government-issued documents or other verification methods, particularly for compliance with age-restricted product delivery and applicable legal obligations.
   

• Platform Monitoring: Monitor transactions, user behavior, and communications to ensure compliance with Mottoz’s Terms of Service, internal policies, and regulatory requirements.
   

• Safety Protections: Implement technological safeguards, conduct risk assessments, and respond to safety-related incidents to protect the rights, property, and security of customers, drivers, merchants, and Mottoz.
   

3. To Communicate With You

We process Personal Information to provide essential communications and support, including to:

• Notify you of order status, account activity, or updates to our Services.
   

• Respond to inquiries, complaints, or requests for assistance submitted via email, phone, or in-app communication.
   

• Inform you of changes to this Privacy Policy, Terms of Service, or other legally required notices.
   

4. To Comply With Legal and Regulatory Obligations

We may use Personal Information where necessary to:

• Fulfill tax, accounting, and corporate reporting requirements.
   

• Cooperate with law enforcement, regulators, and courts as required by law, subpoena, or other legal process.
   

• Maintain adequate business records and comply with applicable labor, transportation, and data protection laws.

•  

          5. To Communicate With You

Mottoz processes Personal Information to enable effective, timely, and personalized communication with Users. These communications are essential to the platform’s functionality, service integrity, and user engagement strategy. Specifically, we may use your information to:

a. Operational & Transactional Communications

• Send real-time notifications regarding order status, driver location, estimated time of arrival (ETA), and delivery confirmations
   

• Deliver digital receipts, payment confirmations, or billing updates
   

• Inform you about system updates, service outages, or critical platform alerts
   

• Provide terms updates, legal notices, and security-related notifications
   

These communications are mandatory and transactional in nature, and you may not opt out of receiving them without deactivating your account.

b. Customer Support & Issue Resolution

• Respond to inquiries, support tickets, or complaints submitted via the app, website, chat, or email
   

• Investigate and resolve disputes between users, merchants, drivers, or other stakeholders
   

• Follow up on reported incidents, service feedback, or claims for refunds or compensation
   

• Provide troubleshooting instructions, technical assistance, or platform usage guidance
   

c. Promotional & Engagement Communications

• Share offers, seasonal promotions, limited-time discounts, or announcements about new features or verticals (e.g., SeaPro, Pulse, Mottoz Print)
   

• Invite participation in marketing initiatives, surveys, or product beta testing
   

• Deliver content recommendations powered by MAIA (e.g., based on dietary preferences, past orders, or browsing history)
   

Such communications are subject to your marketing preferences and applicable legal consent requirements. You may manage or opt out of these messages at any time via the Your Privacy Rights and Choices section.

d. Loyalty, Referral, and Incentive Programs

• Administer friend referral programs, track shared invites and usage, and issue associated bonuses
   

• Provide updates on your loyalty points, rewards balance, or eligibility for special tiers or perks
   

• Communicate redemption options or expiring benefits
   

• Notify you of exclusive user status (e.g., Neighborhood Ambassador, Pulse Contributor, or SeaPro Subscriber)
   

       6.For Advertising and Analytics

Mottoz uses Personal Information and behavioral data to optimize marketing performance, improve advertising relevance, and deliver a more contextual and engaging user experience across all touchpoints.

a. Campaign Measurement & Attribution

• Monitor engagement with promotional emails, push notifications, and SMS offers
   

• Analyze the success of referral programs, seasonal campaigns, coupon usage, and loyalty initiatives
   

• Assess click-through rates, conversion rates, user segmentation, and ROI of paid marketing channels
   

b. Contextual & Targeted Advertising

• Display personalized ads within the Mottoz platform based on your preferences, order history, and real-time context
   

• Deliver sponsored content or relevant product recommendations using insights derived from MAIA’s predictive algorithms
   

• Where legally permitted, serve you with tailored ads across third-party platforms (e.g., Facebook, Instagram, TikTok, Google, Nextdoor) using cookies, pixels, SDKs, or mobile identifiers
   

Targeted advertising is conducted in compliance with local privacy laws (e.g., CCPA, GDPR, LGPD). Where required, we will obtain your prior opt-in consent for these activities and provide tools to withdraw such consent at any time.

c. User Experience Personalization

• Dynamically adjust app layout, product suggestions, or homepage modules based on prior engagement
   

• Provide contextual offers (e.g., local promotions, weather-based recommendations, or nearby trending items)
   

• Enhance discovery via AI-powered modules like Pulse (e.g., "What’s popular near you" or "Recommended for your lifestyle")
   

• Enable intelligent re-engagement (e.g., reminders for abandoned carts or subscriptions)
   

These personalization activities are designed to increase relevance and value to Users without compromising privacy or transparency.

 

7. For Legal and Compliance Purposes

Mottoz may process, retain, and disclose Personal Information when reasonably necessary to comply with its legal, regulatory, and contractual obligations, including but not limited to the following:

• Compliance with Laws and Regulations: Fulfill obligations arising under federal, state, and local legislation in the United States and, where applicable, international data protection frameworks. This includes, without limitation, requirements relating to consumer protection, transportation and labor regulations, financial reporting, tax compliance, anti-money laundering (AML), and data privacy laws.
   

• Governmental and Law Enforcement Requests: Respond to valid subpoenas, court orders, warrants, regulatory inquiries, or other lawful requests from public authorities, including to meet national security or law enforcement requirements.
   

• Contract Enforcement and Dispute Resolution: Enforce the Mottoz Terms of Service, Driver Agreements, Merchant Agreements, and other binding contracts, including the investigation, arbitration, or litigation of disputes that may arise between Mottoz, its Users, and third parties.
   

• Protection of Rights and Safety: Protect the legal rights, property, and safety of Mottoz, its affiliates, employees, contractors, Users (customers, drivers, and merchants), or the general public, including in connection with claims, liability management, or insurance coverage.
   

Mottoz will limit disclosures to what is strictly necessary to achieve the compliance objective and will take steps, where appropriate, to notify affected Users unless prohibited by law.

 

V. Sharing and Disclosure of Personal Information

Mottoz may disclose or otherwise make available certain categories of Personal Information to third parties under limited circumstances, strictly in accordance with this Privacy Policy and applicable law. Such disclosures shall be effected for legitimate business, contractual, or legal purposes, and subject to appropriate safeguards. The principal categories of disclosure include:

1. Restaurants and Merchants
   We may share your Personal Information with restaurants, merchants, and their authorized agents for the purpose of preparing, fulfilling, and delivering your orders, as well as administering participation in loyalty, rewards, or promotional programs.
    

2. Drivers and Delivery Partners
   To enable the pickup, transportation, and delivery of goods and services, as well as to facilitate direct communication between customers and drivers, we disclose limited Personal Information, such as name, delivery address, order details, and masked phone numbers.
    

3. Service Providers
   We engage third-party service providers and contractors to perform functions on our behalf, including but not limited to: payment processing, cloud hosting, IT infrastructure, analytics, security monitoring, customer support, and marketing services. These service providers are contractually bound to process Personal Information solely as instructed by Mottoz and subject to confidentiality and security obligations.
    

4. Enterprise Accounts
   Where a user accesses Mottoz through an employer, educational institution, or other organization under an enterprise account arrangement, we may disclose Personal Information (such as order history, account identifiers, and usage data) to such organization in order to facilitate billing, account management, and service delivery.
    

5. Advertising and Marketing Partners
   Subject to applicable law and user preferences, Mottoz may share certain identifiers and usage data with advertising networks and partners to enable personalized campaigns, remarketing, and measurement of campaign effectiveness. Users may exercise their rights to opt-out of such disclosures as set forth in the section Your Privacy Rights and Choices.
    

6. Affiliates and Subsidiaries
   We may share Personal Information within our corporate group, including with UE INVESTMENT Inc. and its subsidiaries or affiliates, for operational, administrative, and compliance purposes, provided that such entities are bound by equivalent obligations of confidentiality and data protection.
    

7. Legal and Safety Disclosures
   We may disclose Personal Information to courts, regulators, governmental authorities, or law enforcement agencies when such disclosure is mandated by applicable law, regulation, subpoena, or legal process, or when necessary to protect the rights, safety, or property of Mottoz, its users, employees, or the general public.
    

8. Business Transactions
   In the context of a contemplated or completed merger, acquisition, reorganization, financing, or sale of all or part of Mottoz’s assets, Personal Information may be transferred as part of the transaction, subject to customary confidentiality obligations and applicable legal requirements.
    

9. With Your Consent
   Finally, we may share Personal Information with third parties for purposes beyond those described in this Policy where you have provided your express, informed consent.

 

VI. Your Privacy Rights and Choices

Mottoz is committed to respecting and protecting the rights of its users in relation to their Personal Information. The scope and enforceability of such rights depend on the jurisdiction in which you reside, and may include, without limitation, the following:

1. Right of Access
   You have the right to request confirmation as to whether we process your Personal Information and, where applicable, to obtain a copy of such data, together with supplementary information regarding the nature, purpose, and recipients of the processing.
    

2. Right to Rectification (Correction)
   You may request the correction, amendment, or update of any Personal Information held by Mottoz that is inaccurate, incomplete, or outdated.
    

3. Right to Erasure (“Deletion” or “Right to be Forgotten”)
   You may request the deletion of your Personal Information, subject to certain legal limitations (e.g., tax, accounting, contractual, or regulatory obligations that require data retention). Where no such obligations apply, Mottoz will comply with your request in accordance with applicable law.
    

4. Right to Data Portability
   You may request that we provide your Personal Information in a structured, commonly used, and machine-readable format, and, where technically feasible, transmit that data directly to another service provider of your choice.
    

5. Right to Restrict or Object to Processing
   Depending on applicable law, you may have the right to restrict the processing of your Personal Information or object to specific types of processing, including profiling, automated decision-making, or direct marketing communications.
    

6. Right to Opt-Out of Marketing Communications
   You may opt out of receiving promotional emails, SMS messages, and push notifications at any time by:
    

   • Using the “unsubscribe” link included in email communications,
      

   • Adjusting your device or app notification settings, or
      

   • Contacting us directly.
      

Please note that service-related communications (e.g., account verification, order confirmations, delivery updates, and security alerts) are transactional in nature and cannot be opted out of.

1. Right to Opt-Out of Targeted Advertising and Sale of Data
   Where applicable (including, but not limited to, California Consumer Privacy Act (CCPA/CPRA) and Nevada law), you have the right to opt out of the sale or sharing of your Personal Information for targeted advertising purposes. Mottoz does not sell Personal Information in the traditional sense of the term but may disclose limited identifiers to advertising partners for cross-context behavioral advertising. You may exercise this right through our in-app settings or by contacting us as provided below.

 

VII. Cookies and Tracking Technologies

Mottoz, together with its authorized service providers and business partners, employs the use of cookies, software development kits (“SDKs”), pixels, web beacons, device identifiers, and similar tracking technologies (collectively, “Tracking Technologies”) in connection with the operation of the Platform and Services. These technologies are used for the following lawful purposes:

1. Authentication and Security
    

   • To recognize registered Users, verify logins, and maintain session integrity.
      

   • To detect and prevent fraudulent activity, unauthorized access, or other malicious behavior.
      

2. Preferences and Functionality
    

   • To store User preferences, language selections, device settings, and other personalization features.
      

   • To enable certain functionality of the Platform, including cart retention, order tracking, and account recognition across sessions and devices.
      

3. Analytics and Performance
    

   • To collect information on how Users interact with the Platform, including pages visited, features accessed, and technical performance (such as load times or crash reports).
      

   • To conduct aggregated analytics for purposes of product development, service improvement, and operational efficiency.
      

4. Advertising, Marketing, and Offers
    

   • To deliver personalized promotions, loyalty offers, and targeted advertisements, whether on the Mottoz Platform or across third-party websites and applications.
      

   • To measure the effectiveness of marketing campaigns, referral programs, and promotional activities.
      

User Choices and Controls

• Browser Settings: You may disable or limit the use of cookies through the configuration of your browser settings. Please note that disabling cookies may impact the availability and functionality of certain features of the Platform.
   

• Mobile Application Settings: You may adjust your device or application permissions to limit or restrict the use of SDKs and mobile tracking identifiers (such as IDFA on iOS or AAID on Android).
   

• Opt-Out of Personalized Advertising: Where required by law, Mottoz provides mechanisms to opt out of cross-context behavioral advertising. Users may exercise this right through in-app settings or by contacting us directly at privacy@mottoz.com.
   

Notice to Users in Certain Jurisdictions

• In jurisdictions where explicit consent is required for the use of non-essential cookies (e.g., under the General Data Protection Regulation (GDPR) and the ePrivacy Directive in the European Economic Area), Mottoz will not activate such Tracking Technologies unless and until you have provided your affirmative consent through a cookie banner or in-app consent tool.
   

• Users in California and Nevada may additionally exercise their rights to opt out of the sale or sharing of personal data for targeted advertising, as further described in Section VI of this Privacy Policy.
   

VIII. Data Retention and Security

1. Data Retention
Mottoz retains Personal Information only for as long as is reasonably necessary to achieve the purposes described in this Privacy Policy, or as required to satisfy applicable business, legal, tax, accounting, or regulatory obligations. The length of time that we retain data may vary depending on:

• Nature of the data collected (e.g., account information, payment records, communications logs).
   

• Purpose of collection (e.g., order fulfillment, fraud prevention, marketing).
   

• Legal obligations (e.g., financial and tax laws requiring the retention of payment and transaction records for a minimum of seven (7) years).
   

• Litigation or regulatory requirements, where data may be preserved as evidence in ongoing or potential disputes.
   

Upon expiration of the applicable retention period, or upon verified request for deletion (where legally permissible), Mottoz will either securely delete, anonymize, or aggregate the Personal Information so that it can no longer be associated with an identified or identifiable User.

2. Data Security
Mottoz employs a combination of administrative, technical, and physical safeguards designed to preserve the confidentiality, integrity, and availability of the Personal Information under our custody and control. These include, but are not limited to:

• Encryption protocols to secure data in transit (TLS/SSL) and at rest.
   

• Firewalls, intrusion detection systems, and continuous monitoring of network activity.
   

• Access controls that limit Personal Information to authorized personnel only, based on the principle of least privilege.
   

• Vendor due diligence and contractual requirements for third-party service providers that process data on behalf of Mottoz.
   

• Periodic security audits and risk assessments to evaluate vulnerabilities and strengthen security measures.
   

Despite our commercially reasonable efforts, no system, transmission of data, or storage solution can be guaranteed to be 100% secure. Accordingly, Mottoz cannot warrant absolute security of your information. Users are responsible for maintaining the confidentiality of their account credentials and are strongly encouraged to:

• Use strong, unique passwords and change them regularly.
   

• Enable additional security features, where available.
   

• Notify Mottoz immediately at security@mottoz.com in the event of suspected unauthorized access to their Account.

 

IX. Cross-Border Transfers of Data

Mottoz is a U.S.-based company. Accordingly, Personal Information collected through the Platform may be transferred to, stored in, or otherwise processed in the United States and other jurisdictions where Mottoz, its affiliates, or its third-party service providers maintain operations.

We recognize that certain jurisdictions, such as the European Economic Area (EEA), the United Kingdom (UK), and Switzerland, maintain data protection laws that differ from those in the United States and may not provide the same level of protection. To ensure compliance with applicable regulations, Mottoz implements appropriate legal safeguards for cross-border data transfers, including:

1. Standard Contractual Clauses (SCCs): For Users located in the EEA, UK, or Switzerland, transfers of Personal Information to countries without an adequacy decision by the European Commission or other competent authority are made pursuant to SCCs, which contractually obligate recipients to protect Personal Information in accordance with EU/UK data protection standards.
    

2. Data Privacy Frameworks: Where applicable, Mottoz or its vendors may rely on certifications under recognized data transfer frameworks (e.g., the EU–U.S. Data Privacy Framework, the UK Extension to the EU–U.S. Data Privacy Framework, and the Swiss–U.S. Data Privacy Framework) as approved by the relevant authorities.
    

3. Other Legal Mechanisms: In certain limited cases, Mottoz may rely on User consent, the necessity of processing to perform a contract, or other derogations permitted under applicable law to lawfully transfer data.
    

By using the Mottoz Platform, you acknowledge and agree that your Personal Information may be transferred to and processed in jurisdictions outside your country of residence. We will take steps consistent with applicable legal requirements to ensure that your Personal Information receives an adequate level of protection.

Users located in the EEA, UK, or Switzerland may contact us at privacy@mottoz.com to request a copy of the SCCs or other safeguards relied upon for cross-border transfers.

 

X. Children’s Privacy

Mottoz values the protection of minors’ data and operates in strict compliance with applicable child privacy laws.

• Age Restriction: The Mottoz Platform, Services, and related offerings are not directed to or intended for individuals under the age of eighteen (18). By creating an account or using our Services, you represent and warrant that you are at least 18 years old.
   

• No Knowing Collection: Mottoz does not knowingly collect, use, or process Personal Information from minors under 18. In particular, we do not knowingly collect any information from children under 13 years of age in the United States, in compliance with the Children’s Online Privacy Protection Act (COPPA).
   

• Immediate Action in Case of Error: If Mottoz becomes aware that Personal Information has been inadvertently collected from an individual under the applicable minimum age without verified parental consent, Mottoz will promptly delete such information from its records and take reasonable steps to terminate the minor’s account.
   

• Parental or Guardian Rights: If you are a parent or legal guardian and believe that your child has provided Personal Information to Mottoz without your consent, you may request deletion by contacting us at privacy@mottoz.com. We will verify your identity before taking action.
   

• International Considerations: Where local laws impose stricter age thresholds (e.g., 14 in Quebec, Canada or under 16 in certain EU Member States), Mottoz will apply the higher standard consistent with the applicable jurisdiction.
   

 

XI. Third-Party Sites and Integrations

The Mottoz Platform and Services may contain links to, or may otherwise allow you to access, third-party websites, mobile applications, loyalty programs, payment gateways, or other services that are not owned, operated, or controlled by Mottoz (collectively, “Third-Party Services”).

• No Control or Responsibility: Mottoz does not endorse, supervise, or assume any responsibility for the privacy, security, or data processing practices of Third-Party Services. Any Personal Information you choose to provide to such third parties is governed exclusively by their respective privacy notices and terms of service, and not by this Privacy Policy.
   

• Independent Obligations: Your interactions with Third-Party Services are at your own discretion and risk. Mottoz expressly disclaims liability for any loss, misuse, or unauthorized disclosure of information arising out of your use of, or reliance on, any Third-Party Service.
   

• Due Diligence: We strongly encourage you to review carefully the applicable privacy policies, terms, and conditions of each Third-Party Service prior to providing them with any Personal Information or authorizing data-sharing through our Platform.
   

• Integrations: Certain integrations, such as loyalty programs or payment processors, may require you to affirmatively authorize Mottoz to share limited Personal Information (e.g., name, contact details, or order history) with the relevant third party. Such sharing will only occur with your consent or as necessary to fulfill the requested transaction.

 

XII. Region-Specific Disclosures

Mottoz operates in multiple jurisdictions and complies with applicable privacy and data protection laws. Depending on your place of residence, you may be entitled to additional rights beyond those described in this Privacy Policy.

1. California Residents (CCPA/CPRA)

• Under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), you have the right to:
   

  • Know the categories and specific pieces of personal information we collect, use, and disclose.
     

  • Request deletion of your personal information, subject to legal exceptions.
     

  • Request correction of inaccurate information.
     

  • Opt-out of the “sale” or “sharing” of personal information for targeted advertising purposes.
     

  • Limit the use and disclosure of sensitive personal information.
     

• You may exercise these rights by emailing us at privacy@mottoz.com or by using the privacy settings available in the Mottoz app. We will not discriminate against you for exercising your rights.
   

2. Nevada Residents

• Pursuant to Nevada Revised Statutes, Chapter 603A, Nevada consumers may direct Mottoz not to sell certain personal information to third parties. Requests may be submitted by email to privacy@mottoz.com, with “Nevada Opt-Out” in the subject line.
   

3. Canada

• If you reside in Canada, Mottoz processes your personal information in compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws (including Québec’s Law 25).
   

• You may have the right to access, correct, or withdraw consent for the processing of your personal information, subject to legal and contractual restrictions.
   

4. European Economic Area (EEA), United Kingdom (UK), and Switzerland

• If you are located in the EEA, UK, or Switzerland, Mottoz processes your personal information in accordance with the General Data Protection Regulation (GDPR) or its local equivalents. This includes the right to:
   

  • Access, rectify, or erase your personal information.
     

  • Restrict or object to processing.
     

  • Data portability.
     

  • Lodge a complaint with your local supervisory authority.
     

• Mottoz relies on various legal bases for processing, including contractual necessity, legitimate interests, consent, and compliance with legal obligations.
   

5. Latin America (LATAM)

• In certain jurisdictions such as Brazil, Mottoz complies with the Lei Geral de Proteção de Dados (LGPD), which provides rights similar to GDPR. You may exercise rights of access, rectification, deletion, portability, and information on data-sharing.

 

XIII. Changes to This Privacy Policy

Mottoz reserves the right, in its sole discretion, to amend, modify, or update this Privacy Policy from time to time in order to reflect changes in our business practices, technological advancements, or to ensure continued compliance with applicable laws and regulations.

• Notification of Changes:
  In the event of material modifications that affect your rights or our obligations under this Policy, we will provide you with clear notice. Such notice may be delivered by one or more of the following methods:
   

  • Direct communication via email to the address associated with your account.
     

  • In-app notifications within the Mottoz mobile application.
     

  • Prominent posting of the updated Policy on our website.
     

• Effective Date:
  Unless otherwise specified, all changes shall become effective on the date indicated in the “Last Updated” legend at the top of this Policy.
   

• Acceptance of Changes:
  By continuing to access or use the Mottoz Platform and Services after the effective date of an updated Privacy Policy, you are deemed to have acknowledged and consented to the revised terms. If you do not agree with the modifications, you must discontinue use of the Services and may request deletion of your account in accordance with Section VI of this Policy.
   

• Archival Copies:
  For purposes of transparency, prior versions of this Policy may be retained by Mottoz and made available upon written request, subject to applicable retention and confidentiality requirements.

 

XIV. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or Mottoz’s data protection practices, you may contact us through the following channels:

• Email (Primary Contact for Privacy Matters):
  📧 privacy@mottoz.com
   

• Telephone (Customer and Privacy Inquiries):
  📞 +1 (786) 956-3759
   

• Postal Address (Registered Office):
  MOTTOZ USA LLC / UE INVESTMENT Inc.
  Attn: Privacy Office
  401 E Las Olas Blvd, Suite 1400
  Fort Lauderdale, FL 33301, USA
   

For legal or regulatory purposes, all communications should be directed to Mottoz’s Privacy Office, which is responsible for overseeing compliance with applicable data protection laws and this Privacy Policy.

Depending on your jurisdiction, you may also have the right to lodge a complaint with your local data protection authority if you believe that Mottoz has not handled your personal information in accordance with applicable legal requirements.