Privacy Policy

This Privacy Policy explains how Paweł Lipiński NIP PL5792071477, a sole proprietor registered in Poland, Rolnicza 8B/7, 82-200 Malbork, the owner and operator of the Systemly platform ("Systemly", "we", "us", "our"), collects, uses, and protects personal information when you visit gosystemly.com, create or use a Systemly account at app.gosystemly.com, contact us, or otherwise use our services (together, the "Service").

Systemly provides an all-in-one marketing and customer-management platform to independent Arbonne consultants. By using the Service you agree to this Privacy Policy. If you do not agree, please do not use the Service.

1. Who this policy covers, and our two roles

This policy applies to customers and prospective customers of Systemly (the consultants who buy or evaluate our platform) and to visitors of our website. We handle personal information in two different roles:

• As a controller. For information about you as our customer (your account, billing, and how you use the platform), we decide how and why it is processed. This policy governs that information.
• As a processor. When you use the platform to run your own business, you load in information about your own contacts, leads, and customers ("Customer Content"). For that data you are the controller and we act only as your processor, on your instructions, and how you handle it is governed by your own privacy policy. If you are subject to the GDPR, UK GDPR, or similar laws, you may enter into a Data Processing Addendum (DPA) with us; contact us through the contact form to request one.

2. Information we collect

Account and profile: your name, email address, business or brand name, phone number if you provide it, login credentials, your domain and social account connections, and the content of any messages or support requests you send us.

Billing and payment: our payments are handled by our payment processor, Stripe, under its own privacy policy. We do not store your full card number. We keep limited billing records such as your name, billing address, the last four digits and type of card, and your subscription and invoice history.

Collected automatically: IP address, browser and device information, pages and features used, log data, approximate location based on IP, and dates and times of access, through cookies and similar technologies (see Section 8).

Customer Content: the contacts, messages, forms, and other data you create or import while using the platform, which we process only as your processor to provide the Service.

Website visitors: the details you submit if you use a form or the contact form on gosystemly.com.

3. How we use information

We use personal information to create and administer your account and provide the Service; process payments and send invoices; provide onboarding and support; operate, secure, and improve the Service; send you service and transactional messages; send you marketing about Systemly where permitted (which you can opt out of at any time); prevent fraud and abuse; and comply with our legal and tax obligations.

We do this on the following legal bases: performance of our contract with you; our legitimate interests in operating, securing, and improving the Service and in business-to-business marketing; your consent where required (for example, certain cookies and optional communications, which you can withdraw at any time); and compliance with legal obligations.

4. Who we share information with

We do not sell your personal information. We share it only as follows:

• Service providers (sub-processors) who help us run the Service, under contracts requiring confidentiality and appropriate security, including the third-party infrastructure providers that powers and hosts the platform, our payment processor Stripe, our email-delivery provider, and providers of support and security tooling.
• Professional advisers such as our accountants and legal advisers, where needed.
• Legal and safety, where required by law or to protect the rights, property, or safety of Systemly, our users, or others.
• Business transfers, in connection with a merger, acquisition, or sale of assets, subject to this policy.
• With your consent, for any other purpose we describe to you.

A current list of our sub-processors is available on request through the contact form.

5. International data transfers

We are based in Poland (in the EEA), and some of our sub-processors, including our infrastructure provider and Stripe, process data in the United States and other countries. Where we transfer personal information across borders, we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses, the UK International Data Transfer Agreement or Addendum, and equivalent mechanisms.

6. Data retention

We keep personal information for as long as your account is active and as long as needed to provide the Service, and after that where necessary to comply with legal, tax, and accounting obligations and to resolve disputes. Customer Content is retained and deleted according to your instructions and our agreement with you. When information is no longer needed, we delete or anonymize it.

7. Security

We use reasonable administrative, technical, and organizational measures to protect your information, including encryption in transit and access controls. No system is completely secure, so we cannot guarantee absolute security.

8. Cookies and similar technologies

We use cookies and similar technologies to keep you signed in, remember your preferences, operate the platform, and keep it secure. Our marketing website (gosystemly.com) does not run third-party advertising or analytics trackers. You can control or block cookies in your browser settings, though blocking essential cookies may stop parts of the Service from working.

9. Your rights

Depending on where you live, you may have the right to access, correct, or delete your information, receive a portable copy, restrict or object to processing, withdraw consent, opt out of marketing, and not be discriminated against for exercising these rights. To exercise any right, contact us through the contact form. We may need to verify your identity, and we aim to respond within 30 days, or sooner where the law requires.

• California (CCPA / CPRA). You have the right to know, access, delete, and correct your personal information, and to opt out of any "sale" or "sharing." We do not sell or share your personal information. You may use an authorized agent, and we will not discriminate against you for exercising these rights.
• Other U.S. states. Residents of states with comprehensive privacy laws (such as Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Florida, and Montana) have comparable rights, including the right to appeal a refused request.
• United Kingdom and EEA. You have the rights above under the UK GDPR and GDPR and may lodge a complaint with a supervisory authority, in Poland the President of the Personal Data Protection Office (UODO), uodo.gov.pl, or in the UK the Information Commissioner's Office (ICO), ico.org.uk.
• Canada. Under PIPEDA you may access and correct your information and complain to the Office of the Privacy Commissioner of Canada, priv.gc.ca.
• Australia. Under the Privacy Act 1988 and the Australian Privacy Principles you may access and correct your information and complain to the OAIC, oaic.gov.au.
• New Zealand. Under the Privacy Act 2020 you may access and correct your information and complain to the Office of the Privacy Commissioner, privacy.org.nz.

10. Children

The Service is intended for businesses and adults aged 18 and over. It is not directed to children, and we do not knowingly collect personal information from anyone under 18.

11. Third-party links

The Service may link to third-party websites we do not control. This policy does not apply to them; please review their own privacy policies.

12. Changes to this policy

We may update this Privacy Policy from time to time. The "Last updated" date above reflects the latest version, and continued use of the Service after a change means you accept it.

13. Contact us

Contact form: gosystemly.com/contact

Paweł Lipiński NIP PL5792071477,
Rolnicza 8B/7, 82-200 Malbork,
Poland

We aim to respond within 30 days, or sooner where required by law.