Described embodiments provide systems and methods for selecting a position for a user interface element. A device may detect a mode of holding the device by a hand of a user using an input of the user. The device may identify an arrangement defining a plurality of positions to present a corresponding plurality of user interface elements on a display based at least on the mode of holding. The device may determine a number of interactions by the hand of the user with a user interface element. The device may, from the plurality of positions, a position to present the user interface element on the display based at least on the number of interactions in accordance with the arrangement.