Privacy Policy
Your privacy is important to us. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our MLM platform in Pakistan.
Introduction
[Your Company Name] ("we," "us," "our") is committed to protecting your privacy. This Privacy Policy applies to our MLM platform and governs data collection and usage. By using our platform, you consent to the data practices described in this policy.
This Privacy Policy complies with applicable data protection laws in Pakistan, including the Prevention of Electronic Crimes Act 2016 and relevant data protection guidelines.
Scope: This policy applies to all users of our platform, including distributors, customers, website visitors, and mobile app users located in Pakistan.
Information We Collect
We collect various types of information to provide and improve our services:
Personal Information
When you register as a distributor or customer, we collect:
- Full name (as per CNIC)
- Computerized National Identity Card (CNIC) number
- Date of birth
- Contact information (phone, email, address)
- Bank account details or mobile wallet information
- Tax information (NTN if available)
Business Information
To operate your MLM business, we collect:
- Sponsor/referrer information
- Team structure and downline data
- Sales and commission records
- Training progress and certifications
- Communication with team members
Technical Information
Automatically collected technical data:
- IP address and device information
- Browser type and version
- Pages visited and time spent
- Location data (if enabled)
- Cookies and similar technologies
| Data Type | Purpose of Collection | Legal Basis |
|---|---|---|
| Identity Information | Account creation, verification, KYC compliance | Contract necessity, legal requirement |
| Contact Details | Communication, support, notifications | Contract necessity, legitimate interest |
| Financial Information | Commission payments, withdrawals, tax compliance | Contract necessity, legal requirement |
| Business Data | MLM operations, commission calculations, team management | Contract necessity |
| Technical Data | Platform improvement, security, analytics | Legitimate interest |
How We Use Your Information
We use the collected information for the following purposes:
- Account Management: To create and manage your distributor account
- MLM Operations: To calculate commissions, manage team structure, and process payments
- Communication: To send important updates, training materials, and promotional information (with consent)
- Legal Compliance: To comply with Pakistani laws including tax regulations and KYC requirements
- Platform Improvement: To enhance user experience and develop new features
- Security: To protect against fraud, unauthorized access, and security breaches
- Customer Support: To provide assistance and resolve issues
Marketing Communications: We will only send you marketing communications if you have given explicit consent. You can opt-out at any time by updating your preferences in your account settings or clicking the unsubscribe link in our emails.
Data Sharing and Disclosure
We may share your information with third parties in the following circumstances:
Service Providers
- Payment Processors: JazzCash, EasyPaisa, and banking partners for financial transactions
- Courier Services: For product delivery and logistics
- Cloud Hosting: Secure data storage within Pakistan
- SMS Gateways: For sending OTPs and notifications
Legal Requirements
We may disclose your information if required by:
- Federal Board of Revenue (FBR) for tax purposes
- Law enforcement agencies with proper legal requests
- Courts or regulatory bodies in Pakistan
Business Transfers
In the event of a merger, acquisition, or sale of assets, your information may be transferred to the new entity, subject to this Privacy Policy.
Data Protection Agreements
All third-party service providers are bound by data protection agreements that require them to protect your information and use it only for the purposes we specify.
Data Security
We implement robust security measures to protect your information:
Technical Measures
- SSL encryption for data transmission
- Encrypted storage of sensitive data
- Regular security audits and penetration testing
- Firewalls and intrusion detection systems
- Secure data centers located in Pakistan
Organizational Measures
- Limited access to personal data on a need-to-know basis
- Employee training on data protection
- Data protection officer oversight
- Regular privacy impact assessments
Data Retention: We retain your personal data only as long as necessary to fulfill the purposes outlined in this policy, or as required by Pakistani law. Typically, we retain:
- Account information: 7 years after account closure (for tax compliance)
- Financial records: 10 years (as per FBR requirements)
- Communication logs: 3 years
Your Data Protection Rights
As a user of our platform in Pakistan, you have the following rights:
Right to Access
You can request a copy of the personal data we hold about you.
Right to Correction
You can request correction of inaccurate or incomplete personal data.
Right to Deletion
You can request deletion of your personal data, subject to legal limitations.
Right to Object
You can object to certain processing of your personal data.
Right to Data Portability
You can request transfer of your data to another service provider.
Right to Withdraw Consent
You can withdraw consent for marketing communications at any time.
Exercising Your Rights: To exercise any of these rights, please contact our Data Protection Officer using the contact information below. We will respond to your request within 30 days, as required by best practices.
Cookies and Tracking Technologies
We use cookies and similar technologies to enhance your experience:
| Cookie Type | Purpose | Duration |
|---|---|---|
| Essential Cookies | Platform functionality, login sessions | Session / 30 days |
| Analytics Cookies | Usage statistics, platform improvement | 1-2 years |
| Preference Cookies | Language settings, display preferences | 1 year |
| Marketing Cookies | Relevant advertising (with consent) | 1 year |
You can control cookie settings through your browser. However, disabling essential cookies may affect platform functionality.
International Data Transfers
As an MLM platform operating in Pakistan, we prioritize keeping your data within the country. However, in certain circumstances, data may be transferred internationally:
- Only when necessary for specific services
- With appropriate safeguards in place
- To countries with adequate data protection laws
- With your explicit consent when required
We ensure that international data transfers comply with Pakistani data protection principles and provide adequate protection for your information.
Children's Privacy
Our platform is not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If you believe we have inadvertently collected information from a child, please contact us immediately so we can take appropriate action.
Changes to This Privacy Policy
We may update this Privacy Policy periodically. When we make changes:
- We will update the "Last Updated" date
- We will notify you via email or platform notification for material changes
- We will seek your consent for significant changes when required by law
Your continued use of our platform after changes constitutes acceptance of the updated Privacy Policy.
Contact Our Data Protection Team
If you have questions, concerns, or requests regarding your privacy or this Privacy Policy, please contact our Data Protection Officer:
privacy@yourmlmplatform.pk
Phone
+92-XXX-XXXXXXX
Address
[Your Company Address]
Pakistan
Response Time: We aim to respond to all privacy-related inquiries within 5-7 business days.
Last Updated: March 15, 2024
Version: 2.1
This Privacy Policy is available in both English and Urdu. In case of any discrepancy, the English version shall prevail.