Privacy Policy
Last updated: 01-04-2026
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 provides AI-powered features designed to assist Users in optimizing their network management, lead engagement, and content creation.
8.1. User-Initiated AI Assistance: When a User explicitly requests suggestions or analysis from the platform’s AI (e.g., for lead categorization, communication templates, or organizational insights), the Platform may process relevant content provided by the User—such as lead profiles, notes, and organizational activity. This processing is performed solely to generate the specific output requested by the User and to personalize the AI’s responses within that User’s organization.
8.2. Anonymization and Security: All data processed for AI-enhanced features is treated in strict accordance with the General Data Protection Regulation (GDPR). We apply industry grade anonymization and encryption measures to ensure that no personal or confidential information is disclosed, made identifiable, or used outside the secure environment of the Platform.
8.3. Third-Party API Data Protection (Limited Use & Compliance)
UpMLM integrates with third-party services, including but not limited to Google, Meta (Facebook/Instagram), and LinkedIn, to provide automated messaging, lead synchronization, and social selling features.
a) Strict Data Separation: Our Platform strictly adheres to the specific developer data policies and “Limited Use” requirements of each provider. Any data obtained through these external APIs (such as email content, private messages, or contact lists) is processed exclusively to provide the specific user-facing features requested by the User (e.g., sending an email or syncing a lead).
b) No Generalized AI Training: We do not use personal or private data obtained from these third-party APIs (Google, Meta, or LinkedIn) to train, retrain, or improve generalized artificial intelligence or machine learning models.
c) Policy Adherence:
For Google: We comply with the Google API Services User Data Policy.
For Meta: We comply with the Meta Platform Terms and Developer Policies regarding data processing.
For LinkedIn: We comply with the LinkedIn Data Processing Agreement and API Terms.
Any data transfer to third-party AI sub-processors (such as OpenAI or Anthropic) is strictly limited to the transient processing required to generate the User’s requested output and is governed by strict confidentiality agreements that prohibit the use of such data for the sub-processor’s own model training.
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.
