Privacy Policy

1. Introduction

This Privacy Policy describes how Project Forty Two, Inc. (“Motom,” “Anchor by Motom,” “Anchor,” “us,” “we,” or “our”) collects, uses, shares, and protects personal information in connection with our platform and services.

This policy applies to your use of any related services, products, creator storefronts, mobile applications, communications, or features we operate (collectively, the “Site”). This includes both content that we provide directly and experiences we power on behalf of clients.

This Privacy Policy governs the data practices of Project Forty Two, Inc as it relates to your use of the Site, whether you’re a creator, a client, or someone interacting with our services.

Except otherwise expressly indicated in this Privacy Policy, this Privacy Policy applies only to information collected through the Site and does not apply to: (i) information that we receive or collect off-line, or (ii) the information use and collection policies of third-party websites or applications, including information that you provide directly to third parties outside of the Site.

We are committed to respecting your privacy in compliance with all applicable laws and regulations. By using the Site, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. Further, you acknowledge that this Privacy Policy is part of our Terms of Service ("TOS"), which can be found here: [Terms of Service]. By accessing or using the Site, you agree to be bound by all of its terms and conditions. If you do not agree to these terms and the terms and conditions in our TOS, please do not use the Site.

Opting Out of Sale or Sharing of Personal Information

If you would like to opt out of the sale or sharing of your personal information under applicable law (such as California's CPRA), please contact us at: admin@motom.me [Subject=Do Not Sell or Share My Information]

Upon receipt of this email, we will process your request as quickly as possible. Please note that if you are a creator and have requested the deletion of your personal data, clients will be unable to find your profile through our platform. This means that you will be much less likely to be contacted for brand campaigns. Any existing partnerships may be abruptly terminated by processing your request.

Data Portability and Restrictions

At this time, we do not offer data portability or processing restrictions. If required by applicable law, please contact us at admin.motom.me to request consideration.

2. Information that we collect

When you choose to register as a user to the Site, we receive and store information you enter or provide to us directly or in any other way.  The data we collect directly or indirectly from you is used to provide, personalize and improve our products and services.  Additionally, we may use the information we have to help clients and other partners measure the effectiveness of their programs, ads and services and better understand their existing and potential customers. The types of Personal Information collected may include your name, email address, password, phone number, TikTok handle, Instagram handle, YouTube channel, Twitch, website, and/or Facebook usernames, location, IP address, browser information, recorded usage of and activity within the Site, and any other data that is tied to such information (collectively, "Personal Information").  As a registered user, you will be asked to create an "Account" where you may or may not be able to share "Public Content" which refers to information that you submit or post to the Site for public display, such as photos, comments, reviews, and your public profile information.

We retain user Account data until deletion is requested. Financial and tax-related data may be retained for up to seven years to comply with legal obligations. Session and analytic data may be stored for up to 12 months for performance and fraud monitoring purposes. 

While using the Site, you may link out to a third-party Merchant ("Merchant") to make a potential purchase of a product or experience. We may collect information you shared with Merchants and that Merchants shared with you in completing, or abandoning, your purchases and information relevant to such purchase, including product SKUs, dates of purchase, prices, colors, sizes, availability, coupons or discounts applied to your purchase, method of payment, and shipping (collectively, "Purchase History").

If you choose to link your Account with any social media accounts or sign up for an Account using a social media account, such as a Facebook, Pinterest, Instagram, Twitter, or YouTube, we will request your authentication of your social media account information, including potentially log-in credentials such as username and password or directly via a third party social . We may also collect other information from such social media accounts, including your location, media and profile pictures as well as performance data if applicable. What information from social media accounts is available to us depends on your security and privacy settings on the social media platforms, and may include lists of your friends, followers, following, and connections on those platforms.

The Site may include features that allow users to send and receive direct messages (e.g., between creators and brands, support, or other parties). We collect and store these messages, including content and metadata such as sender, recipient, and timestamps. These messages are not publicly visible unless expressly shared. We may review or access messages to investigate complaints, prevent abuse, support moderation, or comply with legal obligations. Messaging data may be retained in accordance with our data retention practices.

Some of our clients may use the Site to create custom forms that allow them to collect additional information from you, such as answers to brand-specific questions or program eligibility criteria. These forms are designed and controlled by the client, and may request any type of information the client deems relevant. While we facilitate the collection of this data on their behalf, we do not control the content of these forms and are not responsible for how clients choose to use the information they collect. 

If you are a creator who earns revenue through the Site, we work with a third-party payment platform, Tipalti, to collect and process the financial information necessary to pay you. This may include your tax identification information, bank account details, or payment method. All personal financial data is collected and stored directly by Tipalti on our behalf, and we do not store this information on our own systems. The use of your personal financial data is governed by Tipalti’s own privacy practices, which we encourage you to review. 

https://tipalti.com/privacy/

We use commercially reasonable safeguards to protect personal information, including HTTPS encryption, limited-access controls, and data minimization practices. No method of transmission is 100% secure, and users are encouraged to protect their own credentials.

3. How we use the information

We use the personal information we collect to operate, improve, and personalize our services across the Site.

This includes:

Account and Platform Services: To create and manage your Account, enable access to creator portals, brand dashboards, and storefronts, and support the functionality of features such as campaign participation, storefront creation, and brand collaboration.

Communication: To respond to inquiries, notify you of platform updates, or share messages relevant to your activity, settings, or preferences. This may include messages from brands if you are participating in their campaigns.

Analytics and Performance: We use browsing and interaction data (such as page views, clicks, and session activity) to analyze how users engage with our platforms. This helps us understand usage trends, optimize user experience, and inform platform improvements.

Marketing and Recruitment: We use cookies and pixels (e.g., from Meta, TikTok, Google) on certain pages to help us identify and recruit creators with similar profiles (“lookalikes”) and to measure the effectiveness of promotional efforts. These tools help us understand which content is engaging or effective.

Customization: Cookies may also be used to remember your preferences, retain session information, and streamline navigation across the site. Declining non-essential cookies may reduce certain user experience features, but essential platform functions will remain available.

Session Replay and Behavior Tracking: We use session tracking tools like Microsoft Clarity to understand user behavior at a high level (e.g., what parts of a page are interacted with most). These tools store pseudonymized user behavior for the purpose of improving platform usability, not to identify specific individuals.

Client-Requested Data: In some cases, clients may ask you to submit specific information through custom forms we facilitate on their behalf. The information you provide through these forms is used to evaluate eligibility, personalize your experience, or fulfill the needs of a campaign or storefront program.

Security and Compliance: We process user data to prevent fraud, monitor for abuse, and ensure our platform remains secure for all parties.

Marketing Communications:  We may send you marketing communications about Motom/Anchor features, programs, and opportunities. If you participate in a Client campaign, you may also receive campaign-related messages (e.g., briefs, updates) from us on the Client’s behalf.

Our channels of communication include:

Email: You may choose to opt in or not during the registration process on the Sites. You may use the unsubscribe link in any marketing email or adjust your account settings.

Push notifications: We may ask your consent for push notifications during the registration process.  You may turn off notifications in the iOS settings for the Motom app.

Please allow a short period for your preferences to take effect across our systems.

You will continue to receive transactional or service messages (e.g., security alerts, payout notices, campaign operations) even if you opt out of marketing.

We do not sell or lease your contact information to third parties for their own independent marketing. If you use our Services in connection with a Client program or storefront, you acknowledge that the Client may contact you as necessary to operate that program (for example, briefs, updates, eligibility, fulfillment, or support). Any direct communications a Client sends to you, and any additional uses of your information by that Client, are governed by the Client’s own terms and privacy policy. Opting out of Motom/Anchor marketing does not affect communications sent by a Client; use the Client’s unsubscribe or preference controls for those messages. We do not authorize Clients to use your information for unrelated marketing unless they have a separate lawful basis (e.g., your consent) under applicable law.

Automated Decision-Making: Some brand programs may use automated tools to assess creator eligibility, such as follower count thresholds. These decisions are based on program-specific criteria and are not used for broader profiling.

We do not use browsing data collected from unregistered users to identify them personally. However, registered users’ activity may be linked to their account for functional or performance purposes.

4. Why We Collect and Process Personal Information

 

Important Clarifications

·       Platform Scope: This applies across all relevant Sites, including:

o   Motom.me (creator shopping platform)

o   Anchor Creator Portal and Anchor Admin Portal

o   Brand-specific storefronts on our domain or on client subdomains (white-labeled)

·       Authenticated Data: Where you link your social accounts (e.g., TikTok, YouTube), we use this data only as permitted by you and the platform. We do not post or manage content on your behalf. You can unlink accounts at any time.

·       Client-Entered Data: If a client uploads Personal Information into our systems (e.g., custom notes or third-party forms), we act solely as a service provider or data processor. That data is governed by the client’s own privacy policy.

·       Custom Forms: Clients may use our tools to build application or onboarding forms that request additional data from creators. We facilitate this data collection but are not responsible for the content or use of those forms. Please review any applicable notices provided by the brand.

5. Our Use of Cookies and Other Online Identification Tools

We use cookies and similar tracking technologies to operate and enhance the functionality of our platforms, secure user accounts, measure performance, and support advertising and affiliate tracking. These technologies help us recognize returning users, remember preferences, and analyze how our sites are used.

Some cookies are essential to the core functionality of the site (e.g., for login authentication or fraud prevention), while others support personalization, performance measurement, or marketing (e.g., Meta Pixel, TikTok Pixel, Microsoft Clarity).

We partner with providers such as Google, Microsoft, and affiliate platforms to help us understand user behavior, optimize experiences, and evaluate campaign performance.

We do not control third-party cookies placed by others, and their use is subject to their own privacy policies.

By using this Site, you consent to the use of such cookies and the sharing of data captured by such cookies with us, Google, Microsoft, and our other third-party partners. You can view, delete or add interest categories associated with your browser by visiting: https://adssettings.google.com. You can also opt out of the network cookie using those settings or using the Network Advertising Initiative's multi-cookie opt-out mechanism at: http://optout.networkadvertising.org. However, these opt-out mechanisms themselves use cookies, and if you clear the cookies from your browser, your opt-out may not be maintained.

Most web browsers allow you to manage your cookie preferences or delete cookies entirely. To learn more about cookies and how to control them, visit: https://allaboutcookies.org

Please note that blocking or deleting cookies may affect your experience or limit certain features on our site, including campaign attribution and personalized content.

When you use the Site, we automatically receive and record information on our server logs from your browser or mobile platform, including your location, IP address, cookie information, and the page you requested. This data is treated as non-Personal Information, except as required under applicable law. We also collect data in a form that does not on its own permit direct association with any specific individual, such as zip code, area code, unique device identifier, location, and the time zone where the Site are used to better understand user behavior and improve our products and services. We may collect, use, transfer, and disclose such non-personally identifiable information for any purpose.

We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement

For European Economic Area Residents If you reside in a country in the European Economic Area (EEA), then under the GDPR and applicable data protection laws you have the rights, among other things, to access your personal data, have us erase it, and/or restrict its further processing.

6. Deleting your Personal Data

If you wish to access or delete your personal data (if any) maintained by us, you can delete your account by accessing the Password & Security section of your Settings.  When you delete your account, we delete everything associated with your account and you won't be able to recover that information later.  If you are not using a Site that provides this option, and additionally, you should click the following email address and contact us at admin@motom.me. You may be asked to submit a copy of your government-issued ID for account verification purposes.  

If we deny your data access, deletion, or modification request, you may appeal the decision by emailing us at [admin@motom.me with the subject line “Data Request Appeal.”]

In the event that the Site or substantially all of its assets is sold or disposed of as a going concern, whether by merger, sale of assets or otherwise, or in the event of an insolvency, bankruptcy or receivership, the information we have collected about you may be one of the assets sold or merged in connection with that transaction.

7. Changes to the Privacy Policy

The most recent version of the Privacy Policy will always be posted on the Site, with the "Effective Date" posted at the top of the Policy. 

We may revise and update this Privacy Policy if our practices change, as technology changes, or as we add new services or change existing ones. If we make any material changes to our Privacy Policy or how we handle your personal information, or we are going to use any personal information in a manner that is materially different from that stated in our Privacy Policy at the time we collected such information, we will give you a reasonable opportunity to consent to the change. If you do not consent, your personal information will be used as agreed to under the terms of the privacy policy in effect at the time we obtained that information. By using our Site or services after the Effective Date, you are deemed to consent to our then-current privacy policy. We will use information previously obtained in accordance with the Privacy Policy in effect when the information was obtained from you.

Contacting Us

If you have any questions about this Privacy Policy, or the practices of this Site, please contact us at admin@motom.me.

Or write to us at:

Motom
135 Madison Ave., 5th Floor
NY, NY 10016