Privacy Policy

1.Who we are

SmartHR MLM Management Ltd, 40 Harbour Exchange Square, London E14 9GE, United Kingdom, is the controller of the personal data described here. This policy covers the admin panel, the member back office and the emails and messages we send from them. Our Terms of Service explain the rules for using the Service.

2.Data we collect

We collect only what we need to run your account and pay you correctly.

Account data

Name, email address, phone number, password (stored only as a salted hash), sponsor, package and preferences.

KYC documents

Government ID, selfie and proof of address, and the results of our identity and sanctions checks.

Network and genealogy data

Who sponsored you, who you sponsored, your position and rank, and the sales and commissions that flow through the tree.

Payment data

Bank account or wallet details for payouts, payout history and tax forms. Card numbers are handled by our payment provider.

Usage data

Device and browser type, IP address, pages viewed, sign-in times and actions taken, so we can secure and improve the Service.

3.How we use your data

• Provide the Service: create your account, build your genealogy, calculate commissions and process payouts.
• Meet legal duties: verify identity, prevent money laundering and fraud, keep tax records and answer lawful requests.
• Keep you safe: detect unusual sign-ins, enforce two-factor authentication and investigate abuse.
• Communicate: send receipts, payout notices, security alerts and, if you opt in, news and training invitations.
• Improve: understand which features are used and fix problems, using aggregated data where we can.

We rely on your contract with us, our legal obligations and our legitimate interest in running a secure service. Where we need your consent, for example for marketing email, you can withdraw it at any time.

4.Sharing your data

We do not sell your personal data. We share it only in these situations:

• Your network: your sponsor and upline see your name, join date, rank and sales volume. They never see your contact details, documents or payment data.
• Service providers: hosting, email and SMS delivery, identity verification and payment processors, under contracts that limit them to our instructions.
• Authorities and advisers: tax and financial regulators, courts, auditors and lawyers, when the law requires or to protect rights.
• A business change: if we merge or are acquired, your data may move to the new owner, which must honour this policy.

5.How long we keep it

We keep data only as long as we need it for the purpose it was collected, or longer if the law says so.

• Account and network data: while your account is open, then up to 12 months after it closes.
• KYC documents: for five years after your account closes, as anti-money-laundering rules require.
• Financial and tax records, including payouts and invoices: seven years.
• Audit logs: for the period set by the company, one year by default and never more than three years for personal activity.
• Backups are overwritten on a 30-day cycle, so deleted data can remain there for up to 30 days.

6.International transfers

We run from the United Kingdom and the European Union, and some providers process data in the United States and India. When data leaves your country we protect it with approved safeguards, such as the UK International Data Transfer Agreement or the EU Standard Contractual Clauses, and we limit what each provider can see.

7.Security

We protect your data with encryption in transit and at rest, mandatory two-factor sign-in for staff, strict access roles and a full audit trail. Read the details in our Security overview. No system is perfectly secure, so please keep your password private and turn on two-factor authentication.

8.Your rights

Depending on where you live, you can:

• ask for a copy of your personal data and for details of how it is used;
• correct data that is wrong or incomplete;
• ask us to delete your data, unless we must keep it by law (for example tax records);
• receive your data in a portable format, or ask us to restrict or stop using it;
• object to processing based on legitimate interest and withdraw consent at any time;
• complain to your data protection authority, such as the Information Commissioner's Office in the UK.

How to ask: email privacy@smarthr-mlm.com from the address on your account, or use the Account settings page once you are signed in. We may ask you to prove your identity and we reply within 30 days. There is no charge unless a request is clearly excessive.

9.Cookies

We use a small number of cookies and similar storage: essential ones to keep you signed in and remember your theme, and analytics ones that count visits so we can improve pages. We do not use advertising cookies. You can block or delete cookies in your browser settings, but parts of the Service may stop working without the essential ones.

10.Children

The Service is for adults. We do not knowingly collect data from anyone under 18. If you believe a child has given us personal data, write to us and we will delete it.

11.Changes to this policy

We update this policy when our practices or the law change. The date at the top shows the current version. For material changes we email members and show a notice in the back office at least 30 days before they apply.

12.Contact

Privacy questions and requests: privacy@smarthr-mlm.com. Postal address: Data Protection, SmartHR MLM Management Ltd, 40 Harbour Exchange Square, London E14 9GE, United Kingdom.