Privacy Policy

Your AI Revenue Stream Starts Here – Your Privacy Protected

Effective Date: 1 February 2026

Welcome to Bennovate. This Privacy Policy explains how Bennovate sp. z o.o. ("we", "us", "our") collects, uses, discloses, and protects your personal data when you participate in our partner and affiliate programmes, use our services, or engage with us through www.bennovate.com. We are committed to transparency and compliance with the GDPR, the UK applicable data protection law, Polish data protection laws, and all applicable regulations governing network marketing and referral programmes.

1. Definitions 2. Data Controller 3. Partner Categories 4. Information We Collect 5. Legal Basis 6. How We Use Information 7. Commission Data 8. MLM Compliance 9. Data Sharing 10. Data Security 11. Data Retention 12. Your Rights 13. Cookies 14. Contact Us

1. Definitions

Term	Definition
Personal Data	Any information relating to an identified or identifiable natural person.
Partner	Any individual or entity participating in Bennovate's partner, affiliate, or referral programmes.
Affiliate	A Partner who promotes Avantwerk services through referral links and earns commission.
Commission	Financial compensation paid to Partners based on referred sales or services.
Upline	A Partner who recruited or referred another Partner into the programme.
Downline	Partners recruited or referred by another Partner.

2. Data Controller Information

2.1 Company Details

Bennovate sp. z o.o. is the data controller for personal data processed through our partner programmes and website.

Company Name: Bennovate sp. z o.o.

Legal Form: Limited Liability Company (Spółka z ograniczoną odpowiedzialnością)

Registered Office: ul. Christiana Andersena 25, 94-118 Łódź, Poland

Management Board: Bartłomiej Kubas, President of the Board

KRS: 0000597272

Registration Court: District Court for Łódź-Śródmieście, XX Commercial Division

VAT ID / NIP: PL7272799328

REGON: 363700466

Share Capital: 5,000.00 PLN (fully paid)

2.2 Relationship with Avantwerk

Bennovate operates the partner programme for the Avantwerk platform (www.avantwerk.com). Both brands are operated by Bennovate sp. z o.o. and share data necessary for service delivery, commission calculation, and customer support.

3. Partner Programme Categories

Bennovate operates a multi-tier partner programme. The data we collect varies by partner type:

Affiliate Partner

Share referral links and earn commission. Basic registration data required.

Sales Partner

Active sales with potential downline network. Enhanced verification required.

S&I Partner

Sales and implementation services. Full business verification required.

Implementation Partner

Certified to deliver Avantwerk implementations. Comprehensive due diligence.

Network Marketing Transparency: Our partner programme involves multi-tier commission structures. We clearly distinguish between commissions from product sales versus partner recruitment. Commission eligibility is based primarily on actual product sales, not recruitment.

4. Information We Collect

4.1 Partner Registration Data

For All Partners

Full legal name, email address, and phone number
Country of residence and preferred language
Referral source (who referred you)
Marketing preferences

For Sales and S&I Partners

Residential or business address
Government-issued ID or business registration
Tax identification number (NIP, VAT number)
Professional qualifications and experience

4.2 Financial and Payment Data

Bank account details for commission payments
Payment service accounts (e.g., PayPal, Wise)
Invoicing information and tax documentation
Commission history and earnings records

4.3 Network and Referral Data

Upline and downline relationships
Referral tracking codes and links
Network tier and position
Referred customer information and sales attribution

Partner Responsibility: If you refer prospects to Bennovate, you must ensure you have their consent to share their information, or another lawful basis exists. You are responsible for complying with data protection laws when collecting prospect data.

5. Legal Basis for Processing

Legal Basis	Processing Activities
Contract Performance	Processing registration, calculating commissions, managing network relationships, providing partner support.
Legal Obligation	Tax reporting, AML compliance, consumer protection, MLM regulatory compliance, fraud prevention.
Legitimate Interests	Programme improvement, fraud detection, network integrity monitoring, compliance enforcement.
Consent	Marketing communications, testimonials, non-essential cookies, partner directory listings.

6. How We Use Your Information

6.1 Partner Programme Administration

Processing and verifying partner applications
Managing your partner account and access
Tracking referrals and attributing sales
Maintaining network structure and relationships
Providing partner resources and training

6.2 Commission Processing

Calculating commissions based on verified sales
Processing payments to your designated account
Generating commission statements and reports
Handling disputes and adjustments
Tax reporting and withholding

6.3 Compliance and Verification

Verifying identity and programme eligibility
Monitoring compliance with Partner Agreement
Investigating fraud, abuse, or policy violations
Meeting regulatory requirements for network marketing

7. Commission and Financial Data

7.1 Commission Transparency

Bennovate is committed to transparent commission practices. We process financial data to accurately calculate Tier 1, Tier 2, and Tier 3 commissions based on actual product sales to end customers.

Important: Our commission structure rewards product sales, not recruitment. Commissions from downline sales are derived from actual customer transactions, not from recruiting new Partners. Full details are in your Partner Agreement.

7.2 Tax Compliance

We process tax-related data to comply with laws in Poland, UK, EU member states, and other jurisdictions. This includes generating annual summaries (e.g., PIT-8C), withholding taxes where required, and reporting to authorities.

8. Network Marketing Compliance

8.1 Regulatory Framework

Our programme complies with network marketing regulations across all jurisdictions:

EU: Directive 2005/29/EC (Unfair Commercial Practices)
Poland: Act on Counteracting Unfair Market Practices
Applicable: applicable consumer protection regulations
Germany: Gesetz gegen den unlauteren Wettbewerb (UWG)
Spain: Ley de Competencia Desleal

8.2 Anti-Pyramid Scheme Measures

Commissions based on sales to end customers, not recruitment
No mandatory purchases required to earn commissions
Transparent income disclosure and realistic expectations
Focus on product value, not recruitment incentives
Regular compliance audits and monitoring

8.3 Income Disclosure

We publish income disclosure statements with realistic earnings information. Most Partners earn modest commissions; significant income requires substantial sales activity.

9. Data Sharing and Disclosure

We do not sell your personal data. We share information in these circumstances:

9.1 Within the Network

Upline Partners: Limited info for mentorship (name, contact, metrics)
Downline Visibility: Basic info about Partners you referred
Partner Directory: With consent, your profile may be listed

9.2 With Avantwerk

We share data with the Avantwerk platform for customer referral attribution, commission verification, customer support, and project management.

9.3 Service Providers

Payment processors, cloud hosting, email platforms, analytics tools. All bound by data processing agreements. See Security & Data Protection.

10. Data Security

10.1 Technical Measures

Encryption in transit (TLS 1.3) and at rest (AES-256)
Multi-factor authentication for partner portal
Regular security audits and penetration testing
Intrusion detection and monitoring
PCI-DSS compliant payment processing

10.2 Your Responsibilities

Keep your login credentials secure
Protect prospect and customer data you collect
Report suspected security incidents promptly
Follow data protection requirements for referrals

11. Data Retention

Data Category	Retention Period
Active Partner Account Data	Duration plus 3 years
Commission and Payment Records	7 years (tax compliance)
Network Structure Data	Duration plus 5 years
Compliance Investigation Records	10 years after closure
Prospect Data (no conversion)	2 years from last contact
Identity Verification Documents	5 years after partnership ends