1. Data Controller
The data controller for your personal data is:
Lubalab
Milan, Italy
Email: privacy@motero.app
As a small company, we are not required to appoint a Data Protection Officer (DPO) under the GDPR. For any privacy-related inquiries, please contact us at the email above.
2. What Data We Collect
We collect and process the following categories of personal data:
- Account information: Email address and name, provided during registration
- Route data: Routes you create and save within the platform
- Analysis history: Records of AI road analyses you perform, including results
- Payment information: Payment details are processed directly by Stripe — we do not store your card details. We retain transaction records (amount, date, credit pack purchased)
- Technical data: IP address, browser type, and session data necessary for the Service to function
3. How We Use Your Data
We use your data for the following purposes:
- Providing the Service: Account management, route planning, AI analysis, and credit management
- Improving analysis quality: Aggregated and anonymized analysis data helps us improve AI accuracy over time
- Community heatmap: Anonymized road quality data is used to generate the community heatmap feature — no personally identifiable information is included
- Communication: Service-related emails (account confirmation, purchase receipts, important updates)
4. Legal Basis for Processing
We process your data under the following legal bases (Art. 6 GDPR):
- Contract performance (Art. 6(1)(b)): Processing necessary to provide the Service you signed up for — account management, route planning, analysis, credits
- Legitimate interest (Art. 6(1)(f)): Improving the Service, generating anonymized community data, preventing abuse
- Consent (Art. 6(1)(a)): Where applicable, such as optional communications
- Legal obligation (Art. 6(1)(c)): Retaining transaction records as required by tax and accounting law
5. Data Sharing
We share data with the following third-party processors, only to the extent necessary to provide the Service:
- Stripe (USA) — Payment processing. Stripe acts as an independent controller for payment data. See Stripe's Privacy Policy
- Google (USA) — Street View imagery used for road analysis. Route coordinates are sent to Google's API. See Google's Privacy Policy
- Anthropic (USA) — AI analysis of road imagery. Street View images are sent to Anthropic's API for analysis. See Anthropic's Privacy Policy
- OpenRouteService (Germany) — Route calculation. Route coordinates are sent for path computation. See ORS Privacy Policy
For transfers to the USA, we rely on the EU-US Data Privacy Framework and/or Standard Contractual Clauses as appropriate.
6. Data Retention
- Account data: Retained while your account is active
- Routes and analyses: Retained while your account is active
- Transaction records: Retained for 10 years as required by Italian tax law
- Upon account deletion: All personal data is deleted within 30 days, except where retention is required by law
7. Your Rights
Under the GDPR, you have the following rights regarding your personal data:
- Right of access (Art. 15): Request a copy of the personal data we hold about you
- Right to rectification (Art. 16): Request correction of inaccurate data
- Right to erasure (Art. 17): Request deletion of your data ("right to be forgotten")
- Right to data portability (Art. 20): Receive your data in a structured, machine-readable format
- Right to object (Art. 21): Object to processing based on legitimate interest
- Right to restriction (Art. 18): Request restriction of processing in certain circumstances
To exercise any of these rights, contact us at privacy@motero.app. We will respond within 30 days.
You also have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali).
8. Cookies
Motero uses session cookies only, which are strictly necessary for the Service to function (authentication, CSRF protection). We do not use tracking cookies, analytics cookies, or any third-party advertising cookies.
9. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify registered users of material changes via email. The "Last updated" date at the top of this page indicates the most recent revision.
10. Contact
For any questions or requests regarding your privacy, contact us at:
privacy@motero.app