Privacy Policy

Last updated: 05-09-2025

This Privacy Policy explains how Spinlegacy Unipessoal LDA (“we”, “us”, or “our”) collects, uses, and protects your personal data when you use the UpMLM platform (“Platform”).

By using UpMLM, you agree to this policy.

1. Data Controller

• Company Name: Spinlegacy Unipessoal LDA

• NIF: PT517378108

• Head Office: Aveiro, Portugal

• Email: client@upmlm.com

2. Data We Collect

We collect the following data when you create an account:

• Name

• Email address

Additionally, when using the platform, the following optional or functional data may be stored:

• Contacts/leads you input

• Courses you create

• Messages you send via email/WhatsApp/SMS

• Network structures (upload or created manually)

• Planner tasks and notes

We do not collect sensitive personal data unless explicitly provided by you in the platform.

3. How We Use Your Data

We use your data to:

• Provide and improve the UpMLM platform

• Communicate with you about your account and updates

• Send onboarding materials or newsletters (with your consent)

• Respond to support requests

• Ensure platform functionality (e.g. lead capture, messaging, automations)

We do not sell or share your data with third parties for marketing purposes.

4. Legal Basis for Processing

We process your data based on:

• Your consent

• Our contractual obligations when you subscribe to paid plans

• Our legitimate interest in improving our services

5. Data Sharing

We do not share your personal data with third parties, except:

• Service providers required for payment processing (e.g. Stripe)

• When required by law

6. Data Retention

• Your data is kept as long as your account remains active.

• Upon deletion of your account, data is securely removed unless required for legal reasons.

7. Data Security

• All data is stored securely in encrypted databases.

• Access to your content is restricted to your account only.

8. Use of Data for AI Training and Service Improvement

UpMLM may collect and process information and content entered or generated by users within the platform — including data related to leads, members, notes, internal communications (such as WhatsApp, SMS, or email integrations), and the activity of users connected to the same organization — for the exclusive purpose of training and improving artificial intelligence systems that support and enhance the platform’s features.

This processing aims to optimize automation, personalization, and performance of the UpMLM service for both the individual user and the overall user base. All data used for these purposes is treated in accordance with the General Data Protection Regulation (GDPR), applying strict anonymization and security measures to ensure that no personal or confidential information is disclosed or made identifiable outside the platform.

9. Your Rights

You have the right to:

• Access, correct, or delete your personal data

• Withdraw your consent at any time

• File a complaint with a data protection authority

To exercise your rights, contact us at: client@upmlm.com

10. International Users

Our platform is based in EU and complies with the GDPR. If you access the platform from outside the EU, you agree to the transfer and processing of your data in Portugal.

11. Updates to this Policy

We may update this Privacy Policy to reflect platform or legal changes. We will notify users via email or platform notification.