GLOBAL WEB PRIVACY AND COOKIE POLICY – UP ONE AI LLC

Last Updated: July 6, 2026

Please Read Carefully.

1. INTRODUCTION AND SCOPE

UP ONE AI LLC, a limited liability company organized under the laws of the State of New Mexico with its principal place of business at 407 Lincoln Rd, Miami Beach, FL, 33139, United States (together with its subsidiaries and affiliates, collectively, “UP ONE,” “we,” “us,” or “our”), recognizes the importance of protecting your privacy.

This Global Web Privacy and Cookie Policy (“Policy”) applies to your use of our global public websites, mobile applications, AI ecosystem, and eWallet services (collectively, the “Site”), as well as your interactions with UP ONE officers, employees, and contractors. This Policy is designed to assist you in understanding how we collect, use, safeguard, and disclose your personal information and your choices in making informed decisions when using the Site.

Your Acceptance Through Use:

This Policy describes how UP ONE collects, uses, and discloses certain personal information obtained through this Site. To the extent permitted by applicable law, your use of this Site signifies your understanding and acceptance of the terms of this Global Web Privacy Policy. This Policy is incorporated into, and is part of, the Terms of Use and the official Policies & Procedures (P&P), which govern your use of the Site in general.

2. THE TYPES OF INFORMATION WE COLLECT

We may collect information about you from a variety of sources. This includes information we collect from you directly; information provided to us by or on behalf of your UP ONE Independent Business Builder (“IBB”) or Social Connector; information we collect about you when you visit our sites or view UP ONE online advertisements; and information we collect about you from other sources (where permitted by law).

2.1 Information We Collect Directly From You

We collect information directly from you when you choose to participate in our offers, clubs (Travel, Luxury Shopping, Education), programs, or otherwise provide information directly to us. Examples include:

  • Name, email address, postal address;
  • Username and password;
  • Phone number or mobile number;
  • Date of birth and Age;
  • Financial & Tax Information: Bank account details, eWallet transactional data, and government-issued identification numbers (such as SSN, EIN) required for mandatory tax reporting via W-9 (US) or W-8BEN (Non-US) forms;
  • Name of your IBB/Social Connector enroller or sponsor;
  • Demographic information and future communication preferences.

2.2 Information We Collect Automatically (Cookies & Tech)

We use cookies, Artificial Intelligence algorithms, and other technologies to collect information about you when you visit our sites, use our services, or view online advertisements. Examples include:

Your browser type, operating system, and IP address;

Web pages you view and links you click;

Sites you visited before coming to our Site;

UP ONE emails you open and/or forward;

AI Analytics data regarding your product/service selections and platform engagement.

3. HOW WE USE YOUR INFORMATION

  • Service Delivery & E-Commerce: To process your transactions, manage your UP Points, provide access to the UP Clubs, and manage your eWallet balance.
  • Communications With You: To contact you about the offerings or services in which you have expressed an interest. Where we have relied on your consent, you may opt-out at any time.
  • Network & Genealogy Management (MLM Specifics): We may use your relationship data to manage our relationship with you and calculate commissions. Please note: To facilitate team management, basic performance data (such as Rank, Volume/BV, and Name) is shared with your direct sponsor and Upline. Financial details and tax data are NEVER shared with the network.
  • Legal, Security & AI Fraud Prevention: To enforce our Terms and Conditions, detect duplicate accounts or chargeback fraud using our AI algorithms, and comply with strict tax reporting obligations (IRS, FATCA).

4. THIRD PARTIES WITH WHOM WE SHARE YOUR INFORMATION

We do not sell your personal data. We may share your personal information with:

  • Service Providers: Companies acting as our authorized agents in providing our services, including cloud hosting (AWS), payment processors (Stripe), Travel/Shopping Club aggregators, Zendesk support, and cookie analytics providers.
  • Legally Affiliated Entities & Network: Your UP ONE sponsor/Upline (strictly limited to genealogy and volume metrics) to provide or offer support and calculate the Compensation Plan.
  • Legally Compelled Disclosure: We will disclose your personal information when required to do so by law, court order, subpoena, or to meet national security or law enforcement requirements.

5. INTERNATIONAL DATA TRANSFERS

UP ONE is a global business headquartered in the United States. We may transfer the personal information we collect about you to recipients, and your personal information may be stored and processed, in countries other than the country in which the information was originally collected (including the United States).

With respect to transfers originating from the European Economic Area (EEA) to the United States, UP ONE utilizes EU Standard Contractual Clauses or other legally approved safeguards to ensure that your information is protected according to European standards (GDPR).

6. DATA RETENTION & SECURITY

UP ONE endeavors to protect the security of your personal information using SSL/TLS technology and secure cloud architectures.

How Long We Keep Your Personal Information: We will only retain your personal information for as long as necessary for the purpose for which it was collected. Specifically, for tax and accounting compliance (IRS regulations), we are legally required to retain basic financial, transaction, and identity records for a minimum of seven (7) years after account termination.

7. YOUR PRIVACY RIGHTS (GDPR & CCPA)

Depending on your jurisdiction, you may have robust rights under applicable law (including GDPR in Europe and CCPA/CPRA in California) to:

  • Request to review, access, correct, or port your personal information.
  • Request deletion of your data (subject to our 7-year legal retention requirement for financial/tax records).
  • Object to or restrict our processing of your personal data.
  • Opt-out of marketing communications.

California Residents: Under the CCPA, you have specific rights to know what information we collect and to request its deletion. We do not sell the personal information of California consumers.

Nevada Residents: Nevada residents may exercise their sale opt-out rights; however, please know we do not currently sell data triggering that statute’s opt-out requirements.

To exercise your rights or file a complaint: Please contact our Data Protection Officer (DPO) and Compliance team at [email protected].

8. COOKIE POLICY

By browsing our Site, you are agreeing to our use of cookies.

  • What is a Cookie: A small text file stored on your device that facilitates browsing and remembers your preferences.
  • How we use Cookies: We use Strictly Necessary Cookies (for secure login and eWallet access), Performance Cookies (Google Analytics), and Targeting/Advertising Cookies (to present you with more relevant advertising on social media).
  • Managing Cookies: You can set your browser to refuse all or some browser cookies. However, if you disable strictly necessary cookies, some parts of the UP ONE platform (like your back-office) may become inaccessible.

9. CHANGES TO THIS POLICY & CONTACT INFO

We are a rapidly evolving, global business. We will assess this Policy against new technologies (including AI updates) and legal requirements, making changes from time to time as required. Any material changes will be posted on this page.

Contact Us:

If you have questions or concerns regarding this Policy, please contact us:

  • By Email: [email protected]
  • By Mail: UP ONE AI LLC – Compliance Dept. – 407 Lincoln Rd, Miami Beach, FL, 33139, USA

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