Celebrio Privacy Policy
Effective Date: May 5, 2025

Mootivation Technologies Inc. (“Mootivation,” “we,” “us,” or “our”) operates Celebrio, an employee engagement application distributed through the Slack App Marketplace and powered by the Incentli platform. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you or your organization install or use Celebrio (the “Service”), and describes your choices and rights.

Slack requires every Marketplace app to publish a clear, publicly‑accessible privacy policy that covers (i) what data is collected, (ii) how it is used, (iii) how long it is kept, and (iv) how individuals can access, transfer, or delete their data, along with contact information for such requests.(Slack API).

The sections below address each of those points.

1. Who We Are

Legal Entity: Mootivation Technologies Inc.
Registered In: Abbotsford, BC, Canada
Email: privacy@celebrio.team

Mootivation is the “data controller” (or “business” under the CCPA) for data described in this Policy unless otherwise noted. Where we process personal data solely on behalf of a customer workspace, we are a “processor” (or “service provider”).

2. Scope

This Policy applies to information collected via:

• The Celebrio Slack application and any related web dashboards or APIs; 
• Our public websites at celebrio.team and any sub‑domains; 
• Support interactions, surveys, or other communications relating to Celebrio. 

If you interact with Incentli outside Slack (for example, redeeming rewards via Incentli’s web store), the Incentli Privacy Policy applies to that downstream activity.

3. Information We Collect

Celebrio never requests or stores Slack passwords or private‑key material.

4. How We Use Information

1. Provide & operate the Service – award points, post recognitions, display leaderboards, fulfill rewards.
   B. Maintain security & reliability – monitor logs, detect abuse, debug, and prevent fraud.
   C. Improve the product – analyze aggregate usage to prioritize features and fix usability issues.
   D. Customer support – respond to inquiries and troubleshoot issues.
   E. Marketing (web only) – understand site traffic and campaign performance.

We rely on one or more of the following legal bases (GDPR art. 6): contract performance, legitimate interests, consent (where required), and compliance with legal obligations.

5. Sharing & Disclosure

We do not sell or rent personal data. We share it only:

• Within Mootivation – employees and contractors are bound by confidentiality. 
• Service Providers/Sub‑processors – Microsoft Azure (hosting), MailGun (email), Stripe (payment processing for subscriptions).  
• Workspace Administrators – usage summaries may be visible in the admin dashboard. 
• Legal/Compliance – if required by law, court order, or to protect rights, safety, or property. 
• Business Transfers – in connection with a merger, acquisition, or asset sale (with notice). 

Sub‑processors receive only the data needed to perform their function and are contractually obligated to protect it.

6. Data Retention

Aggregated, non‑identifiable analytics may be retained indefinitely.

7. International Transfers

Celebrio is hosted in Microsoft Azure data centers in Canada and the Netherlands. We do not transfer personal data between servers or regions.

8. Security

We implement technical and organizational measures aligned with industry best practices, including:

• TLS 1.2+ encryption in transit; AES‑256 encryption at rest 
• Network firewalls and least‑privilege access controls 
• Logical segregation between customer workspaces 
• Continuous monitoring, logging, and incident‑response procedures 

No method of transmission or storage is 100 % secure; however, we continuously enhance our safeguards.

9. Your Rights & Choices

Depending on your jurisdiction, you may have the right to:

• Access – ask for a copy of your personal data; 
• Correct – request corrections to inaccurate data; 
• Delete – request deletion of personal data we hold; 
• Portability – receive data in a structured, machine‑readable format; 
• Restrict or Object – limit or object to specific processing; 
• Withdraw Consent – where processing relies on consent. 

How to exercise your rights:
Email privacy@celebrio.team from the address associated with your Slack profile and specify your request. We will respond within 30 days. If your request concerns data controlled by your employer’s workspace, we may redirect you to their administrator.

Slack users may also remove Celebrio from a workspace at any time; this revokes OAuth tokens and prevents further data collection.

10. Data Deletion Process

When a workspace uninstalls Celebrio or upon a verified deletion request:

1. OAuth tokens are revoked immediately. 
2. Within 24 hours, user‑identifiable records are queued for deletion. 
3. All workspace‑scoped data (points, rewards, logs) is purged from production databases and backups within 180 days.

11. Children’s Privacy

Celebrio is intended for business use. We do not knowingly collect personal data from anyone under 16 . If you believe such data has been collected, contact us, and we will delete it promptly.

12. Changes to This Policy

We may update this Policy from time to time. Material changes will be announced via in‑app notice or email to workspace owners at least 15 days before the new terms take effect. Continued use of Celebrio after the effective date constitutes acceptance of the revised Policy.

13. Contact Us

Questions or concerns?
Privacy Team – Mootivation Technologies Inc.
Email: privacy@celebrio.team

If you are in the EEA/UK and believe we have not adequately resolved your concern, you can complain to your local data protection authority.