Privacy Policy
Last updated: July 4, 2026
⚠ Draft for review. This document is a starting template and is not yet legal advice or a final agreement. It is pending review and finalization by Nelo's legal counsel before launch.
This Privacy Policy explains how Nelo (“Nelo,” “we,” “us,” or “our”) collects, uses, shares, and protects your personal information when you use the Nelo website, partner program, and related services (the “Services”). It forms part of, and should be read together with, our Terms & Conditions and Policies & Procedures.
1. Information You Provide
When you register for and use the Services, we collect information you give us directly, including:
- Account details — your name, email address, chosen member ID (referral code), and password, which we store only as a secure one-way hash and never in plain text;
- Profile & shipping details — phone number, shipping address, and country, where you provide them;
- Payout details — the external USDT wallet address(es) you save for withdrawals;
- Communications — messages and support requests you send us.
2. Information Collected Automatically
When you use the Services we also collect certain technical information automatically, such as your IP address, device and browser type, and general activity within your account, using cookies and similar technologies (see Section 4).
3. Transaction & Program Information
To operate the partner program we keep records of your orders, your internal commission-wallet ledger, transfers, withdrawals, qualification and activity status, and your position in the sponsorship (unilevel) and Dual Equity (binary) structures. USDT deposits and payouts are recorded on public blockchains, which are outside our control (see Section 7).
4. Cookies & Similar Technologies
We use a strictly necessary session cookie to keep you signed in, and we store your language choice in your browser. We use Cloudflare Turnstile on our sign-up form to tell humans apart from automated bots. We do not use advertising or cross-site tracking cookies.
5. How We Use Your Information
We use your information to:
- Provide, operate, and secure the Services and your account;
- Process product orders, USDT deposits, and withdrawals, and calculate commissions and bonuses;
- Communicate with you — for example account, transaction, security, and support messages;
- Detect, prevent, and investigate fraud, abuse, and violations of our Terms;
- Comply with legal, tax, accounting, and regulatory obligations.
6. How We Share Information
We do not sell your personal information. We share it only as needed to run the Services:
- Service providers who process data on our behalf under contract — including our payment/settlement provider (NOWPayments), our email provider (Resend), and our hosting, database, and security/CDN providers (Vercel, Neon, and Cloudflare);
- Your organization — your sponsor and eligible upline may see limited network information about partners in their organization as needed to support the program; partners can never see upline or cross-line members' data;
- Legal and safety — where required by law, regulation, or legal process, or to protect the rights, property, or safety of Nelo, our partners, or others;
- Business transfers — in connection with a merger, acquisition, or sale of assets, subject to this Policy.
7. Digital Assets & Public Blockchains
USDT deposits and withdrawals occur on public blockchains. Blockchain transactions are permanent and public and cannot be changed or deleted by us, and a wallet address you use may be linked to your other on-chain activity by third parties. Do not use the Services if you are not comfortable with these characteristics of digital assets.
8. Data Retention
We keep your information for as long as your account is active and as needed to provide the Services, and afterward as required to meet legal, tax, accounting, dispute-resolution, and fraud-prevention obligations, after which it is deleted or anonymized.
9. Security
We use technical and organizational measures to protect your information, including encryption in transit, one-way hashing of passwords, and optional two-factor authentication. No method of transmission or storage is completely secure, however, and we cannot guarantee absolute security.
10. International Data Transfers
Nelo operates globally and may process and store your information in countries other than the one where you live, including where our service providers operate. Where required, we take steps to ensure your information receives an adequate level of protection when it is transferred.
11. Your Rights & Choices
Subject to applicable law, you may have the right to access, correct, update, or delete your personal information, to object to or restrict certain processing, and to receive a copy of your data. You can update much of your information in your account settings, or contact us to exercise these rights. Some information must be retained for legal and program-integrity reasons.
12. Children's Privacy
The Services are intended for adults (at least 18 years old, or the age of majority in your jurisdiction). We do not knowingly collect information from children.
13. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be posted here with a new “last updated” date and, where appropriate, communicated to you.
14. Contact
Questions about this Privacy Policy or your personal information can be directed to Nelo at [PLACEHOLDER — privacy/support contact email to be added]. Depending on where you live, you may also have the right to lodge a complaint with your local data-protection authority.