1Definitions

• Platform: Refers to the UpMLM software and website.
• User: Anyone registered on the Platform.
• Content: Any data, information, text, files, courses, or materials uploaded or created by Users.
• Company: Refers to Spinlegacy Unipessoal LDA.

2Service Description

UpMLM is a CRM platform designed for entrepreneurs in network marketing, social selling, or multilevel marketing (MLM). It offers tools such as:

• Lead management
• E-learning and training platform
• Automation features (email, WhatsApp, SMS)
• Landing page creation
• Online planner
• Event/calendar management

Users may access a Free Plan (Freemium) or upgrade to a Paid Plan (monthly or annually via Stripe).

3Free Plan Limitations

The Platform offers a Freemium Plan that provides free access to the UpMLM system with limited functionalities. Users may upgrade to paid plans at any time to unlock additional features and expanded capabilities.

4User Eligibility and Conduct

• Users must be at least 18 years old.
• Account sharing is not allowed.
• Users are responsible for the content they upload.
• Inappropriate or illegal content may result in account suspension, although no active moderation is applied by default.

5Payments, Cancellation and Withdrawal

• Payments are processed via Stripe.
• Paid plans renew automatically at the end of each monthly or annual period, at the price in force, until you cancel.
• You can cancel at any time in your account settings. The cancellation takes effect at the end of the period already paid, and you can keep using the free plan.
• A 30-day money-back guarantee is available, no questions asked.
• If you are a consumer, you also have the legal right to withdraw from the contract within 14 days of subscribing, without giving any reason (Decree-Law 24/2014). To withdraw, email client@upmlm.com; we refund the payment within 14 days, using the same payment method.

6Privacy and Data

• Privacy Policy available at: https://upmlm.com/en/privacy/
• Required data: name and email address for registration.
• Data is not sold or shared with third parties for marketing. It is only shared with the service providers needed to run the Platform, as listed in the Privacy Policy.
• Sensitive information (messages, stats, contacts) is stored privately and is only accessible by the user who created it.

7Intellectual Property and Content

• All user-generated content (e.g., courses, automations) remains the property of the user.
• Public courses may be used as templates or examples by the Platform.

8Availability and Liability

• The Company aims to maintain 95% monthly uptime.
• We do not guarantee business success or network growth.
• The Platform is provided “as is”. To the extent permitted by law, the Company is not liable for indirect losses, such as loss of profit or business interruption. Nothing in these Terms limits liability for intent or gross negligence, for death or personal injury, or the rights that consumers have under the law.

9AI Features

9.1. Use of Your Content

The Company processes the information and content entered, generated, or transmitted through the Platform — including data about leads, members, notes, and organizational activity — only to provide, maintain, and secure the Platform and its artificial intelligence features for you, such as automated suggestions, personalization, and productivity tools. The Company does not use this content to train general artificial intelligence models, and improves the Platform only with aggregated statistics that do not identify anyone.

9.2. User-Requested AI Insights

The User acknowledges that specific AI-driven insights (e.g., lead scoring or communication templates) require the processing of User Content to generate the requested output. This content is sent only to the AI sub-processors listed in the Privacy Policy, only to the extent needed for each request, encrypted in transit and at rest, and is not used to train their models.

9.3. Third-Party API Restrictions (Google, Meta, LinkedIn)

Strict Exception: Notwithstanding any other provision in these Terms, Spinlegacy Unipessoal LDA explicitly agrees that any data obtained through third-party APIs (including, but not limited to, Google OAuth/Gmail API, Meta Graph API, and LinkedIn API) will be subject to the following restrictions:

• Limited Use: Such data will be used exclusively to provide user-facing features explicitly requested by the User.
• No Generalized Training: Data sourced from these third-party APIs will not be used to train, retrain, or improve generalized artificial intelligence or machine learning models for the Platform or any third-party service.
• Transient Processing: Any interaction between third-party API data and AI sub-processors is strictly transient and governed by confidentiality agreements that prohibit the storage or use of such data for the sub-processor’s own model training.

10Data Processing on Your Behalf

When you enter personal data of other people in the Platform (for example leads, team members or contacts), you are the controller of that data and the Company processes it on your behalf as a processor, under article 28 of the GDPR. In that role, the Company:

• processes the data only to provide the Platform, following your documented instructions, which are these Terms and your use of the Platform’s features;
• ensures that the people who process it are bound by confidentiality;
• applies appropriate technical and organizational security measures;
• uses only the sub-processors listed in the Privacy Policy, under contracts with equivalent obligations, and informs you of changes by updating that list;
• helps you answer requests from the people concerned and meet your security and data-breach obligations;
• deletes the data when you delete it or close your account, unless the law requires it to be kept;
• provides the information needed to demonstrate compliance and allows audits on reasonable request.

You are responsible for having a legal basis to collect and use that data, including the consent of the people you contact where the law requires it.

11Support

• Support is provided via email (client@upmlm.com), Monday to Friday, from 9h to 17h Lisbon time, except on Portuguese public holidays.
• Priority support is available for paying customers.

12Complaints and Dispute Resolution

• You can file a complaint in the electronic Complaints Book (Livro de Reclamações) at www.livroreclamacoes.pt — search for “Spinlegacy Unip LDA”.
• If you are a consumer, you can also turn to an alternative dispute resolution entity: the Centro Nacional de Informação e Arbitragem de Conflitos de Consumo (CNIACC, www.cniacc.pt). The full list of entities is available at www.consumidor.gov.pt.

13Governing Law and Jurisdiction

• These Terms are governed by the laws of Portugal.
• Any legal disputes will be resolved in the courts of Oliveira do Bairro, Portugal, without prejudice to the mandatory rules that allow consumers to go to the courts of their place of residence.

These Terms are available in several languages. In case of any discrepancy, the Portuguese version prevails.

By using the UpMLM platform, you acknowledge that you have read, understood, and agreed to these Terms and Conditions.

For questions or concerns, please contact: client@upmlm.com