Privacy Policy

Conectiv respects its members and recognizes the importance of protecting personal information. This Privacy Policy explains what information we collect, how it is used, with whom it may be shared, the choices available to you regarding your information, and how you may access or update certain data.

You have accessed a website operated by or on behalf of a Conectiv Distributor, or Conectiv’s corporate website (collectively, the “Site”). These Sites are operated by Conectiv LLC (the “Company,” “Conectiv,” “we,” “our,” or “us”) and hosted on servers maintained by Conectiv and its third-party service providers. Information submitted through the Site is transmitted to and accessible by Conectiv and, where applicable, the independent Distributor to whom the Site is assigned, except as otherwise described in this Privacy Policy. By accessing the Site and providing information, you consent to the collection, use, and disclosure of information as outlined below.

Conectiv maintains a strong commitment to data protection and complies with the General Data Protection Regulation (“GDPR”) and applicable U.S. privacy laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA/CPRA”). These standards are applied regardless of geographic location.

Information Collected

Conectiv is the sole owner and controller of information collected through its corporate website and Distributor-replicated websites (collectively, the “Websites”). Information is collected at various points, including account registration, enrollment, purchases, and interactions with member services.

Personal Information

Members may be required or requested to provide personally identifiable information, including any data capable of identifying an individual, such as:

• Name and surname
• Mailing or billing address
• Email address
• Telephone number
• Identification numbers
• Internet Protocol (IP) address
• Cookie identifiers
• Advertising identifiers
• Payment-related information

Conectiv does not collect precise geolocation data or mobile device unique identifiers.

Member Information

Members must provide contact and payment information to enroll, maintain an account, and access Conectiv services. This information is used to:

• Establish and manage member accounts
• Process transactions and recurring payments
• Provide customer support and service communications
• Comply with legal and regulatory obligations

All payment data is processed and stored by PCI-compliant third-party payment processors. Conectiv does not store full payment card numbers or banking credentials and cannot access or modify payment details on behalf of members.

Technical and Usage Information

Conectiv may collect limited technical information through cookies, log files, and similar technologies to support website functionality, analytics, fraud prevention, and system security. Such information is aggregated and is not used to create individualized marketing profiles tied to personal identifiers.

Payment Processing Data

Conectiv may share limited transaction response data (such as payment decline codes) with third-party processors to optimize payment systems. This data does not include full payment card numbers, security codes, or expiration dates.

Legal Basis for Processing (GDPR)

Conectiv processes personal data under one or more of the following lawful bases:

• Performance of a contract
• Compliance with legal obligations
• Legitimate business interests, including fraud prevention and platform security
• Consent, where required by law

Information Sharing

Personally Identifiable Information

Conectiv does not sell personal information. Personal data may be shared only with:

• Contracted service providers necessary to operate the platform
• Independent Distributors associated with a replicated website
• Upline Distributors for genealogy and reporting purposes
• Regulatory or law enforcement authorities when legally required

Distributor and Genealogy Information

Certain member data, including name, contact information, sales volume, and order history, may be visible within Conectiv’s genealogy and reporting systems. Distributors are independent contractors and are not data controllers on behalf of Conectiv. Access to genealogy information is governed by contractual confidentiality and non-solicitation obligations. Conectiv is not responsible for unauthorized use of information by Distributors acting outside the scope of their agreements.

Sales and Enrollment Information

When a member enrolls or makes a purchase through a Distributor-assigned Site, Conectiv provides that Distributor with limited transactional information necessary to support enrollment and compensation reporting. No sensitive personal or payment data is shared.

Aggregated and De-Identified Information

Conectiv may share anonymized and aggregated data with partners and service providers for analytics, auditing, and operational improvement. This information cannot reasonably be used to identify an individual.

Automated Processing

Certain platform functions, including commission calculations, access permissions, and compliance monitoring, may involve automated processing. Members have the right to request human review of decisions that significantly affect them, where required by applicable law.

Data Retention

Conectiv retains personal information only for as long as necessary to fulfill contractual obligations, comply with legal requirements, resolve disputes, and enforce agreements. Retention periods vary based on data type and applicable law. Information no longer required is securely deleted or anonymized.

International Data Transfers

Conectiv may transfer personal data to service providers located outside the member’s country of residence. Where required, such transfers are protected by appropriate safeguards, including Standard Contractual Clauses or equivalent legal mechanisms.

Communications

Service Communications

Conectiv may send account-related and service communications necessary for platform operation, billing, compliance, and security. These communications are non-promotional and may not be opted out of while an account remains active.

Marketing Communications

Members may receive informational communications regarding Conectiv services. Where required by law, members may manage marketing preferences through account settings or unsubscribe mechanisms.

California Privacy Rights (CCPA/CPRA)

California residents have the right to:

• Know what personal information is collected and how it is used
• Access, correct, or delete personal information
• Limit the use of sensitive personal information
• Opt out of the sale or sharing of personal information (Conectiv does not sell data)
• Exercise rights without discrimination

Requests may be submitted using the contact information below.

Legal Disclosure

Conectiv may disclose personal information when required by law or when it believes in good faith that such disclosure is necessary to comply with legal processes, protect rights, or ensure platform security.

Changes to This Privacy Policy

Conectiv reserves the right to amend this Privacy Policy at its sole discretion. Material changes will be posted on the Websites and become effective upon publication unless otherwise stated.

Children’s Privacy

Conectiv does not knowingly collect personal information from individuals under the age of 18. The Websites, products, and services are intended solely for individuals who are at least 18 years of age.

Member Rights

Members retain control over their personal data and may request access, correction, deletion, restriction, portability, or objection to processing, subject to applicable law.

Mobile App Stores

This Privacy Policy applies to the ConeqtX mobile applications available on the Apple App Store and Google Play. Together with any in-app disclosures, it comprehensively describes how the apps access, collect, use, and share user data. A link to this Privacy Policy is provided in the app store listings and within the apps themselves. Disclosures in this policy are not limited to the categories shown in Google Play’s Data safety section or Apple’s App Privacy details.