Legal Statement

Last updated: [[LAST_UPDATED_DATE]].

This Legal Statement identifies the operator of MAM, explains the general nature of the digital service, and makes available contact and corporate information required under applicable Italian and European Union law. It applies to the website, mobile applications and related features to the extent actually offered. It does not replace the Terms and Conditions, Privacy Policy, Cookie Policy or transaction-specific disclosures shown before an operation.

1. Operator identity and legal details

The provider of the MAM service and the entity responsible for the official information on this page is:

These details are provided pursuant to, where applicable, Article 7 of Italian Legislative Decree No. 70 of 9 April 2003 and Italian corporate-disclosure rules. Details displayed here must match the relevant official public registers.

2. Support, complaints and official communications

For assistance with accounts, registration, subscriptions, MAM transactions, payments and technical issues, use the Help Center where available to your role, or email [[MONITORED_SUPPORT_EMAIL]]. For contractual communications and formal complaints contact [[MONITORED_CONTRACTS_AND_COMPLAINTS_EMAIL]]. For personal-data matters contact [[MONITORED_PRIVACY_EMAIL]].

The published channels must allow direct and effective communication. Response procedures and time frames are governed by applicable law, the relevant contractual terms and the nature of the issue. These contacts do not displace reporting or dispute mechanisms specified for an individual transaction.

3. Description and scope of MAM

MAM is a multi-role digital platform for company recognition and benefits programs. Its features may include MAM units and wallets, company distributions, purchase requests, trading and conversions, subscriptions, transactions with participating businesses, support services and administrative controls.

Access to individual features depends on the user's role, affiliated business, subscription plan, applicable permissions and eligibility requirements. Relevant roles include Employer, Employee, Private user, Partner, Partner Operator and Merchant Cashier, together with authorized administrators.

Experimental, demonstration or testing features are not a promise of general commercial availability. Any Demo Mode simulations must remain clearly distinguishable from real economic transactions.

4. Platform operator, participating companies and transaction parties

The Operator supplies the software infrastructure, oversight functionality and services expressly identified as its own. Participating companies are separate legal entities. Depending on the program, they may invite users, distribute benefits, maintain company balances, participate in transactions, and sell goods or provide services at their premises.

Within MAM Merchant, where MAM units are applied toward a discount on a purchase from a participating business, the seller or provider of the underlying goods or services is, unless otherwise clearly disclosed before purchase, that participating business. A Merchant Cashier acts within the permissions granted by the participating business. Responsibility for the underlying goods or services, their quality, conformity, delivery and applicable warranties follows the actual sales contract and mandatory law.

For trades between users, between users and businesses, or through the platform, the actual counterparty, seller status, amount, fees and material conditions must be disclosed by the relevant transaction flow and Terms. This Legal Statement does not automatically make the Operator the seller, issuer, regulated intermediary or counterparty in every transaction.

5. MAM units, wallets, Treasury, Reserve and Reference Price

MAM may record MAM quantities attributed to users or businesses, movements between wallets and company Treasury, a reference Reserve, Backing Value and a Reference Price calculated according to the applicable operational rules.

These descriptions explain how the platform functions. They do not, by themselves, guarantee a redemption amount, investment return, continuous market liquidity or the absence of risk. The quotation used for a specific operation, euro and MAM amounts, rounding, limits and availability are established by the relevant operation flow and applicable conditions.

Names such as “MAM”, “wallet”, “Reserve” or “Reference Price” do not by themselves determine the legal classification of the underlying activities. Payment-services, financial-instruments, crypto-assets, e-money and other regulatory frameworks must be assessed against the actual economic and technical features. This Statement does not assert or presume any regulatory exemption.

6. Regulated activities, licences and supervisory authorities

If any service provided by the Operator requires a registration, licence, authorization, regulatory approval or sector-specific supervision, the actual regulated provider, authorization details, supervisory authority and territorial scope must be disclosed:

[[IF_APPLICABLE_ADD_AUTHORIZED_ENTITY_LICENCE_TYPE_NUMBER_AND_DATE_SUPERVISOR_AND_COVERED_COUNTRIES; OTHERWISE_REMOVE_THIS_PARAGRAPH]].

The use of an authorized payment or technology provider does not automatically confer its authorization on the Operator. Services subject to regulation must not be offered without the legally required permissions.

7. Prices, taxes, subscriptions and fees

Economic conditions applicable to plans, subscriptions and transactions are displayed before any binding commitment where required, and in relevant summaries. Users must be able to identify prices or reference values, currencies, duration, included or additional taxes, platform and payment-provider fees, other additional costs, renewal conditions and cancellation methods.

Fees and prices may vary by transaction type, role, participating business, payment method and the rules applicable at the time. For statutory withdrawal rights, refunds, disputes and warranties, see the Terms and Conditions, the transaction-specific pre-contractual disclosures and mandatory consumer-protection rules.

8. Payments, Stripe and external providers

MAM may use Stripe, including Checkout and Connect, for relevant payment processing, collections, connected-account verification, transfers, fees, refunds, chargebacks and disputes. Stripe services are subject to their respective contractual and privacy arrangements. The use of Stripe does not automatically change the legal relationships between the Operator, users and participating businesses.

Authentication may use Google, and application infrastructure may use Base44 and related technology providers. Personal-data processing roles and relevant international-transfer arrangements are described in the Privacy Policy. Third-party names and marks remain the property of their respective owners.

9. Account eligibility, minimum age and lawful use

Users must provide accurate information, observe their role permissions, protect credentials and temporary codes, avoid using other users' accounts, and not bypass authorization, balances, identity verification, anti-fraud or availability safeguards. Applicable age and legal-capacity requirements, and any lawful verification obligations, must be met.

MAM's approved minimum age and any role-specific distinctions are [[APPROVED_MINIMUM_AGE_AND_ROLE_SPECIFIC_RULES]]. Certain services may only be available to adults or authorized businesses; technical access to the app does not amount to an entitlement to use a restricted feature.

10. User content, reporting and moderation

Listings, descriptions, attachments, messages and other user-provided material must be lawful, truthful, relevant and respectful of third-party rights. Fraudulent, misleading, defamatory, threatening, discriminatory or intellectual-property-infringing content, and content prohibited by law or the Terms, is not permitted.

Where permitted by law and the Terms, the Operator may review, restrict, suspend or remove content or access through proportionate measures. To report potentially illegal material or infringements, contact [[ILLEGAL_CONTENT_REPORTING_CHANNEL_AND_MONITORED_EMAIL]] or use any applicable in-app reporting mechanism.

Where the service falls within the scope of Regulation (EU) 2022/2065 (Digital Services Act), notice, explanation, complaint and redress procedures must meet the obligations applicable to the actual type and size of intermediary provider. This Statement does not replace those procedures.

11. Digital Services Act points of contact, where applicable

Where Articles 11 and 12 of Regulation (EU) 2022/2065 require dedicated contact points, the relevant channels are:

• Competent authorities and the European Commission: [[DSA_AUTHORITIES_POINT_OF_CONTACT_EMAIL]].
• Service recipients: [[DSA_USER_POINT_OF_CONTACT_EMAIL]].
• Communication languages: Italian and [[OTHER_ACTUALLY_SUPPORTED_LANGUAGES]].
• Notices about specific illegal content: [[ILLEGAL_CONTENT_NOTICE_URL_OR_CHANNEL]].

Such channels must be monitored, easy to find and not exclusively automated where the law requires effective direct communication.

12. Intellectual property, trade marks and licences

Unless otherwise identified, MAM branding, logos, names, original text, visual elements, application code and other Operator materials are protected by applicable intellectual-property laws. This Statement does not transfer those rights. Users receive only the limited usage rights set out in the applicable terms and licences.

Trade marks and materials belonging to participating businesses, Stripe, Google, Apple, Base44 and other parties remain with their respective rights holders. Copyright or trade-mark complaints may be submitted to [[INTELLECTUAL_PROPERTY_REPORTING_EMAIL]] with sufficient information to review the claim.

13. Accuracy, service availability and liability

The Operator aims, subject to the nature of the service and applicable obligations, to provide understandable information and auditable workflows. Platform displays may include data that change following transaction processing, reference-value recalculation or event reconciliation. Confirmed transaction details, rather than an earlier indicative display, govern the relevant operation where validly agreed.

Maintenance, technical incidents and disruptions affecting third-party services may temporarily reduce availability. Nothing in this Statement excludes or limits liability where exclusion or limitation is prohibited by law, or overrides non-waivable consumer rights.

14. Data protection, cookies and device storage

The Privacy Policy describes personal-data purposes, legal bases, recipients, retention, account deletion and individuals' rights. The Cookie Policy explains cookies and similar local storage technologies. For privacy-rights requests contact [[MONITORED_PRIVACY_EMAIL]].

Acknowledging receipt of a Privacy Policy is separate from accepting contractual Terms. Any optional consent, where required, must be informed, separate and withdrawable.

15. Consumer complaints, warranties and dispute resolution

Complaints about MAM may be submitted to [[MONITORED_CONTRACTS_AND_COMPLAINTS_EMAIL]], identifying the relevant transaction and facts without providing passwords or full card numbers. For disputes over goods or services sold by a participating business, the actual seller's complaints process may also apply, without prejudicing any obligations of the Operator.

Where applicable, consumers may seek alternative dispute resolution (ADR) or assistance from competent authorities. Information on ADR bodies is published by the European Commission. Any participation commitment or obligation involving a particular ADR body should be completed with verified details: [[APPLICABLE_ADR_BODY_AND_PARTICIPATION_ARRANGEMENTS_OR_REMOVE]].

The former European online dispute resolution (ODR) platform was discontinued on 20 July 2025 and is not available as a complaint-submission channel.

16. Applicable law and cross-border consumer rights

The Operator is established in Italy and acts subject to applicable Italian and European Union law. Contractual governing law is addressed in the Terms and Conditions and relevant conflict-of-laws rules. A choice of Italian law does not deprive a consumer of non-waivable protections provided by the law of their country of habitual residence where applicable EU rules so require.

Any jurisdiction provision must be interpreted consistently with mandatory consumer-protection, jurisdiction and EU rules. Separate conditions for participating companies or Partners apply only where validly agreed.

17. Distribution through Apple App Store and Google Play

MAM may be distributed through third-party app stores. Apple and Google do not become the operator of MAM, the counterparties to transactions between users or the sellers of participating businesses' goods merely by distributing the app. Relevant store terms, digital-payment policies and the Operator's obligations as developer or service provider continue to apply.

Developer details, support contacts, privacy disclosures and feature descriptions published in app stores must be accurate and match the actual app and the Operator's legal identity. Store-specific financial declarations, licences and supporting documentation are handled separately from this Legal Statement where required.

18. Updates, languages and related documents

The Operator may update this Statement after changes to its corporate details, features, contact channels or applicable law. Material changes are made accessible and notified where required. The current version must be publicly accessible without login at [[OFFICIAL_MAM_HTTPS_URL]]/legal-statement.

The Italian and English texts are intended to convey equivalent information. Material discrepancies must be resolved consistently with mandatory law and any validly agreed contractual language rule, without depriving consumers of required disclosures in an understandable language. See also the Terms and Conditions, Privacy Policy, Cookie Policy and Help Center (where accessible).

Operator: [[OPERATOR_REGISTERED_LEGAL_NAME]] — Registered office: [[FULL_REGISTERED_ADDRESS_POSTCODE_CITY_PROVINCE_ITALY]] — Contact: [[MONITORED_GENERAL_CONTACT_EMAIL]].