Privacy Policy

1. Introduction

MLNU respects the privacy of customers, prospective customers, Independent Business Builders and other individuals whose personal information it processes.

This Privacy Policy explains how MLNU processes personal information in connection with its website, products, customer services, orders, deliveries, returns, refunds, Business Builder activities and related business administration.

MLNU processes personal information in accordance with applicable South African privacy law, including the Protection of Personal Information Act 4 of 2013 ("POPIA").

2. Who Is Responsible for Your Personal Information?

The Responsible Party for ordinary MLNU business processing is:

JA Moolman, a sole proprietor trading as MLNU

MLNU determines the purposes and means of processing personal information for its ordinary customer, operational and business activities.

Where approved third-party service providers process personal information on behalf of MLNU, appropriate confidentiality, contractual and security requirements apply.

3. Information Officer

The MLNU Information Officer is:

JA Moolman
Proprietor / Information Officer
Email: support@mlnu.business
Telephone: +27 72 340 0997
Address:
R72, Kidd's Beach
East London
5201
South Africa

Privacy-related requests, complaints and enquiries may be directed to the Information Officer using the contact details above.

4. Personal Information We Collect

MLNU collects only personal information that is reasonably necessary for an identified and lawful business purpose.

Depending on the nature of your interaction with MLNU, this may include:

• your name;
• telephone or mobile number;
• email address, where required;
• delivery or physical address;
• order and product information;
• payment and transaction information;
• delivery and fulfilment information;
• information relating to returns and refunds;
• information provided when contacting customer support;
• information necessary to administer an Independent Business Builder relationship; and
• other information reasonably required for an approved lawful purpose.

An identity number is not a routine customer-order field. It is requested only where reasonably necessary for a specific approved verification, legal or fraud-prevention purpose.

5. Information We Do Not Routinely Collect

MLNU follows a data-minimisation approach.

Personal information must not be collected merely because it is technically possible or convenient to collect it.

In particular, MLNU does not routinely collect customer identity numbers for ordinary product orders.

Special personal information, children's personal information, biometric information, passwords and financial credentials are not collected through ordinary customer ordering processes unless a specific approved process, lawful basis and appropriate safeguards apply.

6. How We Collect Personal Information

Personal information may be collected when you:

• browse or interact with the MLNU website;
• create or maintain a customer relationship;
• place an order;
• request delivery;
• contact customer support;
• request a return or refund;
• communicate with MLNU about an order or transaction;
• voluntarily provide information to MLNU; or
• apply to participate as an Independent Business Builder.

Where an Independent Business Builder assists a customer, customer information must be collected through approved processes and only for authorised purposes.

7. Why We Use Personal Information

MLNU may process personal information for the following purposes:

• identifying and communicating with customers;
• preparing, confirming and fulfilling orders;
• delivering products;
• providing customer support;
• processing returns and refunds;
• administering payments;
• maintaining accounting records;
• administering Business Builder compensation;
• preventing fraud and unauthorised transactions;
• resolving complaints and disputes;
• maintaining required audit records;
• complying with legal obligations; and
• conducting direct marketing where a separate lawful basis and applicable consent or opt-out mechanism exists.

8. Lawful Basis for Processing

MLNU processes personal information only where there is an appropriate lawful basis for doing so.

For ordinary order processing, the primary lawful basis may be that processing is necessary to take steps at your request and to conclude or perform your order.

Other lawful bases may apply depending on the nature and purpose of the processing, including legal obligations, legitimate interests or valid consent where applicable.

Consent is not presented as the only lawful basis where processing is genuinely necessary to fulfil an order or meet another lawful obligation.

9. Customer Orders and Transactions

Personal information associated with an order may be used to identify the customer, process and fulfil the order, arrange delivery, administer payment, provide support, process returns or refunds, maintain accounting records, prevent fraud and comply with applicable legal obligations.

Where an Independent Business Builder assists a customer with registration or order capture, the customer remains responsible for checking the accuracy of their information, selected products, delivery address and transaction details.

10. Sharing Information with Approved Service Providers

MLNU may use approved service providers where reasonably necessary to operate the business.

These functions may include:

• payment processing;
• product delivery;
• technology and hosting;
• CRM and customer administration;
• customer support;
• accounting;
• communications; and
• other approved business functions.

Personal information is disclosed only where reasonably necessary for the approved purpose.

MLNU applies appropriate contractual, confidentiality and security requirements to approved service-provider relationships.

11. Business Builder and Customer Information

Independent Business Builders may assist customers within the authorised MLNU operating model.

Where a Business Builder handles customer personal information, that information must be used only for the approved purpose and handled through authorised processes.

Customer information must remain confidential and may not be used for unrelated recruitment, profiling or marketing without an appropriate lawful basis and applicable consent.

Business Builders may not maintain unauthorised customer databases or use customer information for personal purposes.

12. Direct Marketing

MLNU treats direct marketing separately from ordinary order processing.

Placing an order does not automatically constitute consent to unrelated direct marketing.

Where consent is the applicable lawful basis for direct marketing, the consent mechanism will be separate from order acceptance and will provide an appropriate method for withdrawing consent.

Marketing permissions and opt-out requests are managed in accordance with applicable law and MLNU's approved processes.

13. Children's Personal Information

MLNU does not intentionally collect or process children's personal information through its ordinary customer ordering processes.

If a proposed business process requires the collection or processing of children's personal information, that process must be appropriately assessed and approved before such information is collected.

14. Information Security

MLNU maintains reasonable safeguards appropriate to the nature and sensitivity of the personal information it processes.

Security measures may include:

• access control;
• authentication and appropriate security practices;
• role-based access where available;
• approved systems and storage;
• secure transmission;
• secure storage;
• device security;
• controlled permissions;
• appropriate backup practices;
• incident logging;
• access review; and
• secure deletion.

MLNU takes reasonable steps to protect personal information against loss, unauthorised access, disclosure, alteration or destruction.

15. Security Incidents and Breaches

MLNU maintains procedures for responding to suspected personal-information security compromises and breaches.

A suspected compromise may include personal information being lost, misdirected, accessed without authorisation, stolen, accidentally disclosed or exposed through a compromised device or account.

MLNU will assess the incident, contain and investigate it appropriately, preserve relevant evidence and take reasonable remedial measures.

Where notification is required, MLNU will communicate with affected persons and the appropriate regulatory authority in accordance with applicable law.

16. Retention of Personal Information

MLNU retains personal information only for as long as reasonably necessary for the purpose for which it was collected, applicable legal obligations, accounting requirements, dispute resolution, agreement enforcement, fraud prevention, audit, compensation administration, tax administration or another approved lawful purpose.

The current operating retention schedule includes:

When personal information is no longer required for an approved purpose and no legal or other valid retention requirement applies, MLNU will take reasonable steps to delete or anonymise it.

17. Your Rights

Subject to applicable law, you may have rights in relation to your personal information, including the right to:

• request access to personal information held about you;
• request correction of inaccurate or incomplete information;
• request deletion where legally available;
• object to certain processing;
• withdraw consent where consent is the applicable lawful basis;
• object to or opt out of direct marketing; and
• lodge a privacy-related complaint through the appropriate channels.

The exercise of a right may be subject to lawful requirements, verification or limitations.

18. Requests Concerning Your Personal Information

If you would like to request access to, correction of or deletion of your personal information, or if you wish to raise a privacy-related concern, contact the MLNU Information Officer.

Information Officer: JA Moolman
Email: support@mlnu.business
Telephone: +27 72 340 0997

MLNU may request reasonable information necessary to verify your identity before responding to a personal-information request.

19. Accuracy of Personal Information

MLNU takes reasonable steps to ensure that personal information used for its business purposes is accurate, complete and current where necessary.

Customers and Business Builders should notify MLNU when relevant personal information changes or is incorrect.

20. Confidentiality

MLNU expects persons who are authorised to access personal information to keep that information confidential and to use it only for authorised purposes.

Personal information must not be disclosed, transferred, copied or reused for unrelated purposes without an appropriate lawful basis and authorisation.

21. External Websites and Services

The MLNU website may contain links to external websites, platforms or services, including the MLNU online shop and Business Builder platform.

External websites and services may have their own privacy policies and terms. MLNU's Privacy Policy does not govern personal information independently collected and processed by those external services.

You should review the privacy information applicable to any external service before providing personal information through that service.

22. Changes to This Privacy Policy

MLNU may update this Privacy Policy from time to time to reflect changes in its business, products, services, information-processing practices or applicable legal requirements.

The current version published on this website will be the applicable version from its effective date, subject to applicable law.

23. Privacy Contact

For privacy questions, requests or complaints, contact:

JA Moolman
Information Officer
MLNU
R72, Kidd's Beach
East London
5201
South Africa

Email: support@mlnu.business
Telephone: +27 72 340 0997

24. Effective Date

Effective date: 31 August 2026

This Privacy Policy should be read together with the applicable MLNU Terms and Conditions, Shipping & Delivery Policy and Returns & Refunds Policy.