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.
Company Name: Spinlegacy Unipessoal LDA
NIF: PT517378108
Head Office: Aveiro, Portugal
Email: client@upmlm.com
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.
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.
We process your data based on:
Your consent
Our contractual obligations when you subscribe to paid plans
Our legitimate interest in improving our services
We do not share your personal data with third parties, except:
Service providers required for payment processing (e.g. Stripe)
When required by law
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.
All data is stored securely in encrypted databases.
Access to your content is restricted to your account only.
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.
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
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.
We may update this Privacy Policy to reflect platform or legal changes. We will notify users via email or platform notification.
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