Legal

Motuva Enterprise Data Processing Agreement

Last updated: 2 November 2026

Version 1.0

In plain English

This summary helps you read the agreement. Parts 1 to 3 are what bind.

When your company sends us photos, you decide what happens to them and we act only on your instructions. In data protection law, you are the controller and we are your processor.
The promises we make are the European Commission's own standard clauses for this (Implementing Decision (EU) 2021/915), copied word for word in Part 2. We have only chosen the options the clauses offer, and filled in the four annexes in Part 3.
One paragraph (1.11) makes the same clauses work under UK law.
Your photos and pictures are processed in Romania and stored in London, and every copy is deleted 30 days after the job.
We email your owners at least 30 days before we add or replace a company that handles your data.
If an owner switches on "Help improve Motuva with our pictures", the copies kept for that are ours to look after. Our privacy notice covers them, not this agreement.

Part 1: How this agreement works

1.1 Who it is between. MotorCut Ltd, trading as Motuva ("Motuva", "we"), and the company named on your Motuva Enterprise account ("you"). Annex I gives the details.

1.2 How it binds. This agreement forms part of the Motuva Enterprise Terms. The person who ticks the agreement box when signing up, or when accepting an invitation, confirms they can bind your company. We record the person, the company, the time and the version accepted, and that record is the signature and accession date in Annex I. If your procurement team needs paper, we will send you a copy signed by us.

1.3 What it covers. The personal data in the photos, logos, references and metadata you send us, and in the finished pictures we make, which we process for you to provide Motuva Enterprise. Annex II describes it.

1.4 What it does not cover. We are the controller, not your processor, for:

the details of the people who use your account: their names, work email addresses, roles, sign-in records and internet addresses;
your company's billing and verification details;
your support conversations with us;
training copies, once made (paragraph 1.5).

We need these to run, secure and bill the service. Our privacy notice covers them.

1.5 Training copies. "Help improve Motuva with our pictures" is off unless an owner of your account switches it on. When an owner does, you instruct us to copy each photo you then send, and its finished picture, with camera and location data removed, into a separate archive for your company. From the moment a copy is made, we hold it as a controller, only to improve Motuva's own picture engine. We never sell or license these copies, publish them or use them in marketing. You confirm you are entitled to let us have them for this purpose. When an owner switches it off, or the account closes, we delete your company's archive within 30 days.

1.6 Your instructions. Your documented instructions are: the Enterprise Terms, this agreement, the Looks and settings you save in the hub, and each request you send through the API or the "Try it" page. You can give further instructions by email to hello@motuva.com from an owner's address.

1.7 Sub-processors. You give us general written authorisation to use the sub-processors listed in Annex IV, also published at motuva.com/enterprise/data-handlers. Under Clause 7.7(a) we email your owners at least 30 days before we add or replace one. To object, reply to that email within the 30 days and tell us why. We will discuss with you whether we can avoid using that sub-processor for your data. If we can't, you may close your account before the change takes effect. If you do, we refund the price of the credits you have paid for and not used.

1.8 Information and audits. Under Clause 7.6 we will answer your questions and give you the information you need first. If you still need an audit or an inspection, you or an independent auditor you appoint may carry it out:

at reasonable intervals, normally no more than once a year, unless there are indications of non-compliance or a supervisory authority requires one;
with at least 30 days' notice, during UK working hours, and in a way that does not expose other customers' data;
at your own cost;
with the auditor bound by a duty of confidentiality.

1.9 Personal data breaches. We give the notice in Clause 9.2 by email to every owner of your account, without undue delay. We aim to do so within 48 hours of becoming aware of the breach.

1.10 When the agreement ends. Under Clause 10(d) you choose between return and deletion:

Return. You collect your pictures through the API or the hub before you close your account. Once the account is closed, nobody can sign in to it.
Deletion. Every photo and picture is deleted 30 days after its job, and on closing within 30 days at the latest. On request, we confirm the deletion in writing.
What we keep. We keep our ledger of credits, your purchases and your invoices for 6 years, because UK tax law requires it. A job's reference and its picture details are deleted with its pictures, 30 days after the job.

1.11 Processing under UK law. Where the processing is subject to the UK GDPR, the Clauses in Part 2 apply as the contract required by Article 28 of the UK GDPR, and are read as follows:

(a) references to Regulation (EU) 2016/679, and to its Articles, mean the UK GDPR (as defined in section 3(10) of the Data Protection Act 2018) and the equivalent Articles of it, read with that Act;
(b) references to Union or Member State law mean the law of the United Kingdom or of a part of it;
(c) references to the competent supervisory authority mean the Information Commissioner;
(d) references to Chapter V of Regulation (EU) 2016/679, and to standard contractual clauses adopted by the Commission under its Article 46(2), mean Chapter V of the UK GDPR and the safeguards it allows, including the International Data Transfer Agreement and the International Data Transfer Addendum to the European Commission's standard contractual clauses, issued by the Information Commissioner under section 119A of the Data Protection Act 2018;
(e) references to Regulation (EU) 2018/1725 do not apply.

This paragraph adds to the Clauses, as Clause 2(b) allows. It does not change them.

1.12 Every customer. We apply this agreement to every Motuva Enterprise customer, wherever it is based.

1.13 Liability. The limits of liability in the Enterprise Terms apply to claims between you and us under this agreement, except where the law does not allow a limit. Nothing in this agreement limits the rights of the people whose data is processed.

1.14 Which document wins. If this agreement conflicts with the Enterprise Terms on personal data, the Clauses win first (Clause 4), then the rest of this agreement, then the Enterprise Terms.

1.15 Law. This agreement is governed by the laws of England and Wales, as the Enterprise Terms are.

Part 2: The standard contractual clauses

The European Commission's standard contractual clauses between controllers and processors, from the Annex to Commission Implementing Decision (EU) 2021/915 of 4 June 2021 (Official Journal L 199, 7 June 2021, p. 18).

SECTION I

Clause 1: Purpose and scope

(a) The purpose of these Standard Contractual Clauses (the Clauses) is to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

(b) The controllers and processors listed in Annex I have agreed to these Clauses in order to ensure compliance with Article 28(3) and (4) of Regulation (EU) 2016/679 and/or Article 29(3) and (4) of Regulation (EU) 2018/1725.

(d) Annexes I to IV are an integral part of the Clauses.

(e) These Clauses are without prejudice to obligations to which the controller is subject by virtue of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

(f) These Clauses do not by themselves ensure compliance with obligations related to international transfers in accordance with Chapter V of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

Clause 2: Invariability of the Clauses

(a) The Parties undertake not to modify the Clauses, except for adding information to the Annexes or updating information in them.

(b) This does not prevent the Parties from including the standard contractual clauses laid down in these Clauses in a broader contract, or from adding other clauses or additional safeguards provided that they do not directly or indirectly contradict the Clauses or detract from the fundamental rights or freedoms of data subjects.

Clause 3: Interpretation

(a) Where these Clauses use the terms defined in Regulation (EU) 2016/679 or Regulation (EU) 2018/1725 respectively, those terms shall have the same meaning as in that Regulation.

(b) These Clauses shall be read and interpreted in the light of the provisions of Regulation (EU) 2016/679 or Regulation (EU) 2018/1725 respectively.

(c) These Clauses shall not be interpreted in a way that runs counter to the rights and obligations provided for in Regulation (EU) 2016/679 / Regulation (EU) 2018/1725 or in a way that prejudices the fundamental rights or freedoms of the data subjects.

Clause 4: Hierarchy

In the event of a contradiction between these Clauses and the provisions of related agreements between the Parties existing at the time when these Clauses are agreed or entered into thereafter, these Clauses shall prevail.

Clause 5 - Optional: Docking clause

*Not used in this agreement.*

SECTION II — OBLIGATIONS OF THE PARTIES

Clause 6: Description of processing(s)

The details of the processing operations, in particular the categories of personal data and the purposes of processing for which the personal data is processed on behalf of the controller, are specified in Annex II.

Clause 7: Obligations of the Parties

7.1. Instructions

(a) The processor shall process personal data only on documented instructions from the controller, unless required to do so by Union or Member State law to which the processor is subject. In this case, the processor shall inform the controller of that legal requirement before processing, unless the law prohibits this on important grounds of public interest. Subsequent instructions may also be given by the controller throughout the duration of the processing of personal data. These instructions shall always be documented.

(b) The processor shall immediately inform the controller if, in the processor’s opinion, instructions given by the controller infringe Regulation (EU) 2016/679 / Regulation (EU) 2018/1725 or the applicable Union or Member State data protection provisions.

7.2. Purpose limitation

The processor shall process the personal data only for the specific purpose(s) of the processing, as set out in Annex II, unless it receives further instructions from the controller.

7.3. Duration of the processing of personal data

Processing by the processor shall only take place for the duration specified in Annex II.

7.4. Security of processing

(a) The processor shall at least implement the technical and organisational measures specified in Annex III to ensure the security of the personal data. This includes protecting the data against a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access to the data (personal data breach). In assessing the appropriate level of security, the Parties shall take due account of the state of the art, the costs of implementation, the nature, scope, context and purposes of processing and the risks involved for the data subjects.

(b) The processor shall grant access to the personal data undergoing processing to members of its personnel only to the extent strictly necessary for implementing, managing and monitoring of the contract. The processor shall ensure that persons authorised to process the personal data received have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality.

7.5. Sensitive data

If the processing involves personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data or biometric data for the purpose of uniquely identifying a natural person, data concerning health or a person’s sex life or sexual orientation, or data relating to criminal convictions and offences (“sensitive data”), the processor shall apply specific restrictions and/or additional safeguards.

7.6. Documentation and compliance

(a) The Parties shall be able to demonstrate compliance with these Clauses.

(b) The processor shall deal promptly and adequately with inquiries from the controller about the processing of data in accordance with these Clauses.

(c) The processor shall make available to the controller all information necessary to demonstrate compliance with the obligations that are set out in these Clauses and stem directly from Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725. At the controller’s request, the processor shall also permit and contribute to audits of the processing activities covered by these Clauses, at reasonable intervals or if there are indications of non-compliance. In deciding on a review or an audit, the controller may take into account relevant certifications held by the processor.

(d) The controller may choose to conduct the audit by itself or mandate an independent auditor. Audits may also include inspections at the premises or physical facilities of the processor and shall, where appropriate, be carried out with reasonable notice.

(e) The Parties shall make the information referred to in this Clause, including the results of any audits, available to the competent supervisory authority/ies on request.

7.7. Use of sub-processors

(a) OPTION 2: GENERAL WRITTEN AUTHORISATION: The processor has the controller’s general authorisation for the engagement of sub-processors from an agreed list. The processor shall specifically inform in writing the controller of any intended changes of that list through the addition or replacement of sub-processors at least 30 days in advance, thereby giving the controller sufficient time to be able to object to such changes prior to the engagement of the concerned sub-processor(s). The processor shall provide the controller with the information necessary to enable the controller to exercise the right to object.

(b) Where the processor engages a sub-processor for carrying out specific processing activities (on behalf of the controller), it shall do so by way of a contract which imposes on the sub-processor, in substance, the same data protection obligations as the ones imposed on the data processor in accordance with these Clauses. The processor shall ensure that the sub-processor complies with the obligations to which the processor is subject pursuant to these Clauses and to Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

(c) At the controller’s request, the processor shall provide a copy of such a sub-processor agreement and any subsequent amendments to the controller. To the extent necessary to protect business secret or other confidential information, including personal data, the processor may redact the text of the agreement prior to sharing the copy.

(d) The processor shall remain fully responsible to the controller for the performance of the sub-processor’s obligations in accordance with its contract with the processor. The processor shall notify the controller of any failure by the sub-processor to fulfil its contractual obligations.

(e) The processor shall agree a third party beneficiary clause with the sub-processor whereby - in the event the processor has factually disappeared, ceased to exist in law or has become insolvent - the controller shall have the right to terminate the sub-processor contract and to instruct the sub-processor to erase or return the personal data.

7.8. International transfers

(a) Any transfer of data to a third country or an international organisation by the processor shall be done only on the basis of documented instructions from the controller or in order to fulfil a specific requirement under Union or Member State law to which the processor is subject and shall take place in compliance with Chapter V of Regulation (EU) 2016/679 or Regulation (EU) 2018/1725.

(b) The controller agrees that where the processor engages a sub-processor in accordance with Clause 7.7. for carrying out specific processing activities (on behalf of the controller) and those processing activities involve a transfer of personal data within the meaning of Chapter V of Regulation (EU) 2016/679, the processor and the sub-processor can ensure compliance with Chapter V of Regulation (EU) 2016/679 by using standard contractual clauses adopted by the Commission in accordance with of Article 46(2) of Regulation (EU) 2016/679, provided the conditions for the use of those standard contractual clauses are met.

Clause 8: Assistance to the controller

(a) The processor shall promptly notify the controller of any request it has received from the data subject. It shall not respond to the request itself, unless authorised to do so by the controller.

(b) The processor shall assist the controller in fulfilling its obligations to respond to data subjects’ requests to exercise their rights, taking into account the nature of the processing. In fulfilling its obligations in accordance with (a) and (b), the processor shall comply with the controller’s instructions

(c) In addition to the processor’s obligation to assist the controller pursuant to Clause 8(b), the processor shall furthermore assist the controller in ensuring compliance with the following obligations, taking into account the nature of the data processing and the information available to the processor:

(1) the obligation to carry out an assessment of the impact of the envisaged processing operations on the protection of personal data (a ‘data protection impact assessment’) where a type of processing is likely to result in a high risk to the rights and freedoms of natural persons;

(2) the obligation to consult the competent supervisory authority/ies prior to processing where a data protection impact assessment indicates that the processing would result in a high risk in the absence of measures taken by the controller to mitigate the risk;

(3) the obligation to ensure that personal data is accurate and up to date, by informing the controller without delay if the processor becomes aware that the personal data it is processing is inaccurate or has become outdated;

(4) the obligations in Article 32 of Regulation (EU) 2016/679.

(d) The Parties shall set out in Annex III the appropriate technical and organisational measures by which the processor is required to assist the controller in the application of this Clause as well as the scope and the extent of the assistance required.

Clause 9: Notification of personal data breach

In the event of a personal data breach, the processor shall cooperate with and assist the controller for the controller to comply with its obligations under Articles 33 and 34 of Regulation (EU) 2016/679 or under Articles 34 and 35 of Regulation (EU) 2018/1725, where applicable, taking into account the nature of processing and the information available to the processor.

9.1 Data breach concerning data processed by the controller

In the event of a personal data breach concerning data processed by the controller, the processor shall assist the controller:

(a) in notifying the personal data breach to the competent supervisory authority/ies, without undue delay after the controller has become aware of it, where relevant/(unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons);

(b) in obtaining the following information which, pursuant to Article 33(3) of Regulation (EU) 2016/679, shall be stated in the controller’s notification, and must at least include:

(1) the nature of the personal data including where possible, the categories and approximate number of data subjects concerned and the categories and approximate number of personal data records concerned;

(2) the likely consequences of the personal data breach;

(3) the measures taken or proposed to be taken by the controller to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects.

Where, and insofar as, it is not possible to provide all this information at the same time, the initial notification shall contain the information then available and further information shall, as it becomes available, subsequently be provided without undue delay.

(c) in complying, pursuant to Article 34 of Regulation (EU) 2016/679, with the obligation to communicate without undue delay the personal data breach to the data subject, when the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons.

9.2 Data breach concerning data processed by the processor

In the event of a personal data breach concerning data processed by the processor, the processor shall notify the controller without undue delay after the processor having become aware of the breach. Such notification shall contain, at least:

(a) a description of the nature of the breach (including, where possible, the categories and approximate number of data subjects and data records concerned);

(b) the details of a contact point where more information concerning the personal data breach can be obtained;

(c) its likely consequences and the measures taken or proposed to be taken to address the breach, including to mitigate its possible adverse effects.

The Parties shall set out in Annex III all other elements to be provided by the processor when assisting the controller in the compliance with the controller’s obligations under Articles 33 and 34 of Regulation (EU) 2016/679.

SECTION III — FINAL PROVISIONS

Clause 10: Non-compliance with the Clauses and termination

(a) Without prejudice to any provisions of Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725, in the event that the processor is in breach of its obligations under these Clauses, the controller may instruct the processor to suspend the processing of personal data until the latter complies with these Clauses or the contract is terminated. The processor shall promptly inform the controller in case it is unable to comply with these Clauses, for whatever reason.

(b) The controller shall be entitled to terminate the contract insofar as it concerns processing of personal data in accordance with these Clauses if:

(1) the processing of personal data by the processor has been suspended by the controller pursuant to point (a) and if compliance with these Clauses is not restored within a reasonable time and in any event within one month following suspension;

(2) the processor is in substantial or persistent breach of these Clauses or its obligations under Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725;

(3) the processor fails to comply with a binding decision of a competent court or the competent supervisory authority/ies regarding its obligations pursuant to these Clauses or to Regulation (EU) 2016/679 and/or Regulation (EU) 2018/1725.

(c) The processor shall be entitled to terminate the contract insofar as it concerns processing of personal data under these Clauses where, after having informed the controller that its instructions infringe applicable legal requirements in accordance with Clause 7.1 (b), the controller insists on compliance with the instructions.

(d) Following termination of the contract, the processor shall, at the choice of the controller, delete all personal data processed on behalf of the controller and certify to the controller that it has done so, or, return all the personal data to the controller and delete existing copies unless Union or Member State law requires storage of the personal data. Until the data is deleted or returned, the processor shall continue to ensure compliance with these Clauses.

Part 3: The annexes

ANNEX I: List of parties

Controller

1. Name: the company named on the Motuva Enterprise account. Address: the company's address as recorded when it was verified in the hub. Contact person's name, position and contact details: the account's owners, at the email addresses recorded in the hub. If the company has a data protection officer, their details as the company records them. Signature and accession date: the agreement tick given at sign-up or when accepting an invitation, with the person, time and version recorded (paragraph 1.2), or the date of a signed copy.

Processor

1. Name: MotorCut Ltd, trading as Motuva. Company number 12362580, registered in England and Wales. Registered with the Information Commissioner's Office under number ZC271428. Address: Ava Office, Fir Tree Close, Stretton, Warrington, Cheshire, WA4 4NA, United Kingdom. Contact person's name, position and contact details: Chris Percival, Director, hello@motuva.com. Motuva has not appointed a data protection officer. Signature and accession date: Motuva accepts this agreement with every customer by publishing it and recording the customer's acceptance. A copy signed by Motuva is available on request.

ANNEX II: Description of the processing

Categories of data subjects whose personal data is processed

People who appear in the photos you send, such as customers, staff or passers-by near a vehicle.
People who can be linked to a vehicle through its number plate or through the reference you send, such as its keeper, seller or buyer.
Anyone named in the references, metadata or logos you send.

Categories of personal data processed

Photos you send and the finished pictures we make, which may show faces and number plates.
Camera and location data saved inside the original photo files.
The reference you send with each job (such as a stock number, registration number or VIN) and any metadata you add.
Logos you upload, where they contain personal data.

Sensitive data processed (if applicable) and applied restrictions or safeguards

None is intended, and the Enterprise Terms ask you not to send it. Photos may show people by chance. We do not process them to identify anyone and the service does not analyse faces. Any photo that happens to reveal sensitive data is protected by the measures in Annex III, in particular: deletion after 30 days, staff access only with a recorded reason that is shown to you, and no copy kept for any other purpose unless you have switched on training copies (paragraph 1.5).

Nature of the processing

Receiving your photos through one-time upload links, and storing them.
Sending each photo to the picture engine, which runs on our sub-processor's servers in Romania, by a short-lived link to our own storage.
Finding the car, cutting it out, covering the number plate, and placing the car in a studio or scene, as your Look says.
Re-saving every picture we hand out without hidden data (camera, location, software and comments).
Holding finished pictures so you can collect them through links that expire after 24 hours.
Sending "picture done" messages to the address you choose. They contain no picture and no download link.
Opening a picture, by our staff, only with a reason that is recorded and shown in your activity log.
Deleting everything on the schedule below.

Purpose(s) for which the personal data is processed on behalf of the controller

To provide Motuva Enterprise to you: making the edited vehicle pictures you ask for, delivering them, answering your support requests and investigating problems, keeping the service secure, and counting the credits each picture uses.

Duration of the processing

For as long as you use Motuva Enterprise, and for each item:

photos and finished pictures: deleted 30 days after the job was created, every copy, including old versions in our storage;
an uploaded photo not used in a job within 24 hours: deleted then;
copies on the picture engine's servers: deleted within 24 hours, and their logs within 7 days;
download links: expire after 24 hours, and the delivery network keeps no copy;
logos: kept while your account is open and deleted when it closes;
job references and picture details: deleted with the pictures, 30 days after the job;
the ledger of credits, purchases and invoices: 6 years, for UK tax law;
after the agreement ends: as paragraph 1.10 says.

For processing by (sub-) processors, also specify subject matter, nature and duration of the processing

As set out for each sub-processor in Annex IV.

ANNEX III: Technical and organisational measures including technical and organisational measures to ensure the security of the data

These are the measures in place for Motuva Enterprise. They are described in more detail, in plain English, in our security overview.

Measures of pseudonymisation and encryption of personal data

Every connection is encrypted with TLS: to our API, to our storage, to the database and to the picture engine. Our storage refuses any request that is not encrypted.
Stored data is encrypted at rest: storage with AES-256 server-side encryption, and the server disks, the database and its backups with keys managed by Amazon Web Services.
Jobs sent to the picture engine carry a random job id and short-lived links only. They carry no company name and no customer reference.

Measures for ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services

Motuva Enterprise runs on its own server and its own database, separate from Motuva's other services.
Each customer's data is kept apart in two independent ways: every query is limited to the caller's company in our code, and the database itself refuses rows belonging to another company (row-level security).
Speed limits and queue limits stop any one caller from crowding out others. If the limit counter is unavailable, requests are refused rather than let through.
The API accepts traffic only through our network security provider, and the database accepts connections only from the Motuva Enterprise server.

Measures for ensuring the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident

The database is backed up automatically, with point-in-time recovery for 7 days, and the backups are copied to a second Amazon Web Services region (Ireland).
A restore from backup was rehearsed before launch, and the restored records were checked to balance.
Jobs are saved before they are sent for processing. A job that gets no answer is re-sent a limited number of times, then fails free and you are told.

Processes for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures in order to ensure the security of the processing

A written threat model lists each risk and the control for it.
Before launch, and before changes to sign-in, payments, the database or security controls reach production, those controls are tested by trying to break them, including attempts to read another company's data from every route.
Automated tests run on every change, including a test that a planted file's hidden data does not survive into a picture we hand out.

Measures for user identification and authorisation

Every person signs in with a password and a 6-digit code sent to their work email. There is no way in with a password alone. Each code is stored hashed, works once and expires after 10 minutes.
Five roles (owner, admin, developer, billing, read-only) limit what each person may do. Sensitive actions ask for a new emailed code.
Sign-in attempts are limited, and an email address is locked for 15 minutes after 10 failures.
Passwords are stored with Argon2id. API keys are shown once and stored only as a keyed hash. Revoking a key takes effect at once. Each key can be limited to certain steps, a daily cap and a list of internet addresses, and key requests from a web browser are refused.
Our staff reach customer data only through a separate staff route that is not on the internet, after signing in to our admin portal with a second step. Each action needs a reason, is recorded, and is shown to you as "Motuva support". Staff never see keys, passwords or sign-in codes, cannot sign in as you, and cannot download pictures in bulk.

Measures for the protection of data during transmission

TLS on every connection, as above.
Finished pictures are collected through signed links that expire after 24 hours, served from a delivery network that keeps no copy.
"Picture done" messages are signed (HMAC-SHA256), sent only over HTTPS, never to private or internal addresses, and contain no picture and no download link.

Measures for the protection of data during storage

Storage buckets block all public access, and files are reached only through short-lived signed links.
The secrets that sign your messages are encrypted in the database under their own key.
Our application secrets are kept encrypted in Amazon Web Services' parameter store, never in code. The service refuses to start if one is missing.

Measures for ensuring physical security of locations at which personal data are processed

Data is stored in Amazon Web Services data centres in London, with database backup copies in Ireland, and processed in a RunPod data centre in Romania. We rely on those providers' physical security. Motuva keeps no customer data on its own premises or laptops.

Measures for ensuring events logging

Your activity log records every action by your team, your keys and our staff. It is kept for 6 years and cannot be edited or deleted by anyone.
Our own record of staff actions is written in the same step as the action, cannot be edited or deleted, and is kept for 6 years.
One request id follows each request from end to end. Application logs never contain passwords, keys, secrets or signed links, and are kept for 30 days.

Measures for ensuring system configuration, including default configuration

Anything a role is not allowed to do is refused by default.
Training copies are off by default.
The live service publishes no internal technical documentation.

Measures for internal IT and IT security governance and management

Access to the live systems is limited to named accounts, and each environment has its own credentials.
Changes to sign-in, payments, the live database and security controls are reviewed against the threat model before they reach production.

Measures for certification/assurance of processes and products

Motuva holds no security certification. We answer security questionnaires on request.

Measures for ensuring data minimisation

Only uploaded photos are accepted. We never fetch photos from links.
Every picture we hand out is re-saved without camera, location or other hidden data.
Customer references and company names are kept out of logs and out of requests to the picture engine.

Measures for ensuring data quality

Your references and metadata are stored and returned exactly as you sent them.

Measures for ensuring limited data retention

Automatic storage rules delete photos and pictures 30 days after the job, including old versions. The schedule is in Annex II and in our retention statement.

Measures for ensuring accountability

We record which version of the Enterprise Terms and this agreement each person accepted, and when.
Our activity log and staff record, above.

Measures for allowing data portability and ensuring erasure

You can download every finished picture, in JPEG, WebP or PNG, through the API or the hub while we keep it, and export your jobs and usage as CSV files.
Erasure happens automatically 30 days after each job, and when you close your account.

Description of the specific technical and organisational measures to be taken by the processor to be able to provide assistance to the controller

Requests from individuals (Clause 8). If someone asks us about their data in your pictures, we pass the request to your owners promptly and do not answer it ourselves unless you ask us to. You can find every job by its reference in the hub and through the API, and download its pictures, for as long as we keep them. Every picture is deleted within 30 days of its job without any action from you, and on request we delete one job's pictures sooner.
Impact assessments and prior consultation (Clause 8(c)). This annex, our security overview, our retention statement and our data handlers page give you the information you need. We answer further questions by email.
Personal data breaches (Clause 9). We notify every owner by email as paragraph 1.9 says, with the information Clause 9.2 lists, and send further information as we have it.

ANNEX IV: List of sub-processors

You have authorised the use of the following sub-processors (Clause 7.7(a), Option 2). The list is also published at motuva.com/enterprise/data-handlers, and we email your owners at least 30 days before any change.

1. Name: Amazon Web Services EMEA SARL. Address: 38 Avenue John F. Kennedy, L-1855 Luxembourg. Contact person's name, position and contact details: through the AWS account. Description of the processing: hosts the Motuva Enterprise server, database and storage in London (eu-west-2), with database backup copies in Ireland (eu-west-1), and delivers finished pictures through its delivery network, which keeps no copy. It stores photos, finished pictures, logos, references and metadata for the durations in Annex II. Its data processing addendum is part of the AWS Service Terms.

2. Name: Runpod Inc. Address: 1351 Fairview Blvd Ste A 1134, Delran, NJ 08075, United States (RunPod's notice address). Contact person's name, position and contact details: through RunPod's support. Description of the processing: runs the servers in its data centre in Romania on which the picture engine makes your pictures. It receives photos and logos through short-lived links to our storage, keeps working copies for no more than 24 hours and logs for no more than 7 days, and never receives your company name or your references. RunPod's data processing agreement with us includes the European Commission's standard contractual clauses and the UK Addendum.

3. Name: Cloudflare, Inc. Address: 101 Townsend Street, San Francisco, CA 94107, United States. Contact person's name, position and contact details: through the Cloudflare account. Description of the processing: network security and delivery in front of our API and in front of RunPod's servers. Photos and finished pictures pass through it, encrypted, on their way to and from the picture engine. Its data processing agreement is part of its terms.

4. Name: Functional Software, Inc. (Sentry). Address: 45 Fremont Street, 8th Floor, San Francisco, CA 94105, United States. Contact person's name, position and contact details: through the Sentry account. Description of the processing: error reports from our systems, stored in Sentry's EU data region in Germany. Error reports are scrubbed so that they do not carry pictures, keys, links or customer references. Data processing agreement accepted on 11 October 2026 (version 5.1.0).