Legal
Privacy Policy
Implementation draft for client review — not a substitute for legal advice. Operated by: [Legal entity / operator name — to be provided by the client]. Contact for privacy questions: use the contact page.
1. Information we collect
- Account information: name, username, email address, and password (stored hashed). Usernames double as public referral identifiers.
- Referral relationship data: who referred whom (a single sponsor per member), registration source, and the resulting uni-level referral tree.
- Activity data: account status (pending, active, inactive, rejected), approval and status-change history with reasons, and daily engagement counts (Active ID eligibility records). Activity counts are engagement records only and never represent payments or earnings.
- Support messages: anything you send through the contact form (name, email, subject, message).
- We do not intentionally collect any other sensitive information. Please do not send passwords or one-time codes to us.
2. Purposes and appropriate use
- Creating and administering accounts, including reviewing registrations and recording approval decisions.
- Maintaining the referral tree (teams, downlines, and counts) and applying administrator-configured activity and eligibility rules equally to all members.
- Responding to support and privacy requests sent through the contact channel.
- Operating, securing, and auditing the platform (for example, recording who approved an account and when).
- We do not sell personal information. We do not use referral or activity data to calculate commissions, payouts, or investment returns, because the platform has no payment, commission, or investment features.
3. Referral relationship and activity data
- Each member has at most one sponsor. The referral relationship is a permanent record of who invited whom and cannot be transferred between members.
- Team listings and counts show names, usernames, referral codes, statuses, and dates only.
- Status decisions (pending approval, activation, deactivation, rejection) are recorded with the deciding administrator, date, and reason. Past activity records are never rewritten when rules change.
4. Access controls and sharing
- Members see only their own private data; team listings, public pages, and search results show community information only.
- We do not share personal information with third parties except as necessary to operate the site (for example, hosting), or when required by applicable law. Any such disclosure would be limited to what is necessary.
5. Retention and account status
- Account records, referral relationships, status history, and activity records are retained while the account exists so the community structure and audit trail stay intact.
- Rejected, deactivated, or inactive accounts are retained with their referral history rather than deleted automatically; this is stated at the time of rejection/deactivation.
- Specific retention periods and deletion routines: [to be confirmed by the client].
6. Your requests: access, correction, deletion
- For requests — access to, correction of, or deletion of your personal information where applicable — contact us through the contact page, including your username and registration email so we can locate your application. We will respond as appropriate to the request and applicable requirements.
- Some information (for example, referral ancestry and audit history affecting other members) may need to be retained even after an account is closed; we will explain this in response to any such request.
7. Security practices
- Passwords are stored hashed; access to member data is gated by authentication and least-privilege authorization (members see only their own private data; administrators see only what their role requires).
- Administrative actions are recorded with actor, date, and reason. The audit log never stores passwords or session tokens.
- We apply standard precautions (authenticated sessions, rate limits on login, registration, and contact forms, and validated inputs). No method of transmission or storage is completely secure, and we make no certification or compliance claims beyond what is stated here.
8. Changes and questions
If this policy changes, the updated version will be published on this page. Questions or requests about privacy: please use the contact page.
Draft version published for client review. Effective date, governing law, and operator details: [to be provided and approved by the client before publication].