Privacy Policy — Downline Autopilot
Effective date: 2026-08-19 · Data controller: Leadspire LLC · https://app.downlineautopilot.com
Draft — to be reviewed by a lawyer before selling to third parties
This document was written from what the software actually does and aims to be complete and honest, but it is not legal advice and has not been reviewed by a lawyer. Before selling paid subscriptions to leaders other than the founder it must be reviewed by a professional — in particular the tax treatment, non-EU data transfers, the Article 28 GDPR data processing agreement and the liability limitations.
1. Two different roles — please read this first
Downline Autopilot handles two kinds of personal data, and our responsibility is different for each.
- Subscriber data — the account, billing and usage data of the leader who subscribes. For this we are the data controller: this policy describes what we do with it.
- Organization data — the members, customers, orders and cashback requests that the subscriber imports from dōTERRA myOffice. For this we are only a data processor: the subscriber is the controller, decides what happens and is the one who must inform those people and answer their requests. We process it only on the subscriber's documented instructions, that is, to run the features they use.
If you are a member or customer of a dōTERRA leader and you want to know why your data is in this system, or you want it deleted, contact your leader first — they are the controller. You can also write to us at privacy@wiseteam.app and we will forward the request and support them in answering it.
2. Data we process as controller (subscribers)
- Account: name, email address, password (stored hashed), team name, country, language, role, dōTERRA Owner ID if provided.
- Billing: plan, subscription status, invoices and payment identifiers held by our payment processor. We never see or store full card numbers.
- Service use: sign-in timestamps, sending statistics, error and audit logs (including super-admin access to a workspace, which is recorded).
- Support: what you write to us.
Legal bases: performance of the contract (providing the Service), legal obligations (accounting), and our legitimate interest in keeping the Service secure and in preventing abuse.
3. Data we process on behalf of subscribers
- Members of the subscriber's organization: ID, name, email, phone, postal address, country, language, enrolment date, sponsor/enroller, rank, member type, volumes and activity dates.
- Orders: order number, date, amount, points and, where synchronized, the products in the order.
- Email activity: what was sent, delivery, opens, bounces, complaints and unsubscribes.
- Cashback requests: order number and amount declared by the customer, an optional order confirmation upload, the payment details they enter (PayPal address or bank details) and the IP address the request was sent from.
The subscriber decides the purpose and the legal basis for this processing. Our documented instruction is simply: provide the features of the Service and nothing else. We do not use this data for our own purposes, do not sell it, do not share it between subscribers and do not use it to train anything.
4. Sub-processors
We use these providers to run the Service. They act on our instructions and are bound by contract.
| Provider | What it is used for | Where |
|---|---|---|
| Railway | Application hosting and database | USA / EU |
| Resend | Sending and delivery tracking of your email campaigns | USA |
| Stripe | Subscription payments (subscriber billing data only) | USA / EU |
| PayPal | Cashback payouts, when the customer chooses PayPal | USA / EU |
| Wise | Cashback payouts by bank transfer | EU / UK |
| Revolut Business | Cashback payouts by bank transfer | EU / UK |
| Airwallex | Cashback payouts by bank transfer | EU / APAC |
Cashback payment details are passed to the payment provider chosen by the customer only to execute that payment — that is unavoidable: a bank transfer cannot happen without the account details reaching the institution that makes it. They are not shared with anyone else. We will announce changes to this list before they take effect.
5. International transfers
Leadspire LLC and part of our infrastructure are based in the United States. Where personal data of people in the European Economic Area is transferred outside it, the transfer relies on the European Commission's Standard Contractual Clauses, together with the technical measures described below.
6. Security
- Each subscriber's data lives in a separate workspace; separation is enforced in the data layer on every query, and fails closed if the workspace is not known.
- Payment provider credentials and the payment details entered by cashback customers are encrypted at rest (AES-256-GCM).
- Passwords are stored hashed; all traffic uses HTTPS.
- Access by our staff to a subscriber's workspace is restricted and recorded in an audit log.
7. How long we keep data
- Account and billing data: for the life of the subscription and afterwards for as long as accounting and limitation rules require.
- Organization data: for as long as the subscription is active. After termination it can be exported for 30 days and is then deleted.
- Cashback requests: the payment details, the uploaded receipt, the IP address and the customer's free-text message are deleted automatically 24 months after the request is closed. Only the accounting record — amount, currency, dates, status and payment reference — is kept.
- Unsubscribe records are kept indefinitely: they are what stops someone being contacted again.
8. Your rights
You can ask for access, correction, deletion, restriction, portability, and object to processing based on legitimate interest. Write to privacy@wiseteam.app. If you are in the EEA or the UK you can also complain to your data protection authority. Every marketing email sent through the Service carries a one-click unsubscribe link that works immediately and survives later data imports.
9. Cookies
The application uses a single session cookie to keep you signed in. There is no advertising, no analytics and no third-party tracking on the application or on the public cashback portal.