Data Privacy Policy
Effective Date: 06 July 2025
This Privacy Policy (“Policy”) sets out the basis on which Mochi L.L.C-FZ (“Mochi”, “we”, “our”, or “us”), a company duly incorporated under the laws of the United Arab Emirates, processes Personal Data in connection with the access to and use of our website (https://themochi.app), platform, and affiliated applications, including integrations with Meta APIs (collectively, the “Services”).
Mochi is committed to protecting the privacy and security of Personal Data in accordance with applicable data protection laws, including but not limited to the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the California Consumer Privacy Act of 2018, as amended (“CCPA”), and other relevant legislation
1. Definitions
For the purposes of this Policy:
“Personal Data” means any information relating to an identified or identifiable natural person.
“Processing” means any operation performed on Personal Data, such as collection, storage, use, disclosure, or deletion.
“User” means any individual accessing or using the Services, including authorized representatives of our business clients.
“Meta Data” means information obtained through integrations with Meta Platforms, including Instagram account data and messaging data, as authorized by Users.
2. Data Controller
The Data Controller responsible for Processing under this Policy is:
Mochi L.L.C-FZ
Meydan Grandstand, 6th floor
Meydan Road, Nad Al Sheba
Dubai, United Arab Emirates
License No: 2531534.01
Formation No: 2531534
Issued by: Meydan Free Zone, Dubai
Contact: hey@themochi.app
3. Categories of Personal Data Collected
We may collect and process the following categories of Personal Data:
3.1 Account & Login Data – Email address, IP address, and Instagram account identifiers (via Meta API).
3.2 Usage Data – Messages and chat interactions submitted by Users.
3.3 Voice Data – Audio files and voice models uploaded or generated with explicit consent.
3.4 Analytics Data – Usage metrics such as session logs and behavioral data (via Google Analytics).
3.5 Payment Data – Billing information processed by Stripe (credit card details are not stored by Mochi).
4. Legal Basis for Processing
We process Personal Data under one or more of the following lawful bases:
Consent: for activities requiring express authorization, such as voice cloning.
Contractual Necessity: to perform obligations under our Terms of Service.
Legitimate Interests: to secure, maintain, and improve the Services.
Legal Obligation: to comply with statutory or regulatory requirements.
5. Purposes of Processing
Personal Data is processed strictly for the following purposes:
Authentication of Users via Meta APIs.
Provision of CRM and unified inbox features.
Generation of AI-powered workflows and responses.
Sending authorized voice messages on behalf of coaches.
Analytics and performance monitoring.
Subscription and billing administration.
6. Data Retention
6.1 Chat Data: Retained for the duration of account activity and deleted after 90 days of inactivity.
6.2 Voice Data: Retained for the lifetime of the account unless earlier deletion is requested.
6.3 Billing & Analytics: Retained only as necessary for audit, tax, and compliance obligations.
6.4 We reserve the right to retain certain data where required by applicable law.
7. Integration Removal & Meta Data Deletion
In accordance with Meta’s Platform Policies:
Upon revocation of consent or disconnection of Instagram/Facebook accounts, all related Meta Data is automatically deleted via Meta’s Data Deletion Callback.
No Meta Data shall remain in Mochi systems following such revocation.
8. Voice Messaging & Cloning
Authorized Users (e.g., appointment setters and closers) may send voice messages to prospects and leads on behalf of coaches. Such messages may use a voice model pre-approved by the coach with explicit consent.
Voice cloning is used solely for business communication purposes.
Audio messages are delivered only through supported messaging APIs (e.g., Instagram).
Voice Data shall not be used for advertising, profiling, or resale.
Coaches may withdraw consent at any time, triggering deletion of their Voice Data.
9. Data Subject Rights
Subject to applicable laws, Users have the right to:
Request access to their Personal Data.
Request correction or deletion of Personal Data.
Restrict or object to Processing.
Exercise data portability rights.
Withdraw consent at any time.
Lodge a complaint with a competent data protection authority.
Requests must be submitted to hey@themochi.app and will be addressed within statutory timeframes.
10. Children’s Privacy
The Services are not directed at children under 13 years of age (or under 16, where applicable). Mochi does not knowingly collect data from minors. Any such data will be promptly deleted upon discovery.
11. Security Measures
We implement appropriate technical and organizational measures, including:
Hosting on Google Cloud with encryption-at-rest.
TLS/HTTPS encryption for all transmissions.
Role-based access controls.
Logging and monitoring of access to sensitive systems.
12. Subprocessors
Mochi engages the following third-party service providers:
Meta (Facebook/Instagram) – account linking and messaging APIs
ElevenLabs – voice cloning and audio generation
Google Cloud & Firebase – infrastructure and storage
Google Analytics – usage analytics
Stripe – payment processing
We do not sell or rent Personal Data to any third parties.
13. International Data Transfers
Personal Data may be transferred to and stored in jurisdictions outside the User’s country of residence, including the United States and Europe. Transfers are conducted in accordance with applicable data protection laws.
14. Cookies and Tracking Technologies
We use cookies and similar technologies strictly for functionality and analytics. No third-party advertising cookies are deployed. Users can manage cookies through their browser settings.
15. Policy Updates
Mochi may update this Policy periodically. Material changes will be communicated, and the “Effective Date” will be updated accordingly.
16. Contact Information
For inquiries or to exercise data rights:
📧 hey@themochi.app
🌐 https://themochi.app