Privacy Policy

Last updated 31 August 2026. This is a template document — have it reviewed by a lawyer for your jurisdiction before launch.

1. What we collect

Account: full name, email, mobile number, password (hashed).
KYC: bank account holder name and account number, provided by you for withdrawals. Stored encrypted at rest.
Activity: your matrix position, packages, wallet and ledger entries, referral and login timestamps, and the IP address of requests.

2. Why we use it

To operate your account and the compensation plan, process recharges and withdrawals, prevent fraud and abuse, meet legal and tax obligations, and provide support.

3. Sharing

We share data with our payment/banking partners to pay withdrawals, with hosting and infrastructure providers who process data on our instructions, and with authorities where legally required. We do not sell personal data.

4. Retention

Ledger and transaction records are retained for the period required by applicable accounting and tax law. Other account data is kept while your account is active and for a reasonable period afterwards.

5. Your rights

[REVIEW WITH COUNSEL] Subject to local law you may request access to, correction of, or deletion of your personal data, and may object to certain processing. Contact us to exercise these rights.

6. Security

Passwords are hashed; KYC bank details are encrypted at rest; access is restricted to authorised staff. No system is perfectly secure — tell us immediately if you suspect unauthorised access to your account.

7. Cookies

We use a single session cookie to keep you signed in. It is HttpOnly, SameSite=Lax and, on HTTPS, Secure. No third-party tracking cookies are set.

8. Contact

[REVIEW WITH COUNSEL] Data controller name, address and privacy contact to be inserted here.