Privacy Policy

Version 1.0 · 19 October 2026

 

1. Who We Are

Millionaires United is operated by Athada (Pvt) Ltd, a company registered in Sri Lanka, trading as Millionaires United (“we,” “us,” or “our”).

We are responsible for deciding how personal information is used for our website, membership applications, verification, community administration, and support.

Privacy contact

Athada (Pvt) Ltd
Level 13, MAGA ONE
No. 200 Narahenpita Road
Colombo 00500, Sri Lanka

Email: contact@millionairesunited.com
Email subject: Privacy Request

This Policy explains our handling of personal information concerning:

  • Website visitors

  • Membership applicants

  • Current and former members

  • People who contact us or subscribe to updates

  • Referrers, professional references, and people identified in relevant correspondence or reports

It applies to millionairesunited.com and our administration of the official Millionaires United Discord server, Telegram group, and WhatsApp group.

2. Our Role and the Role of Other Platforms

We decide how to use application records, verification information, membership decisions, administrator records, and information submitted directly to our team.

Discord, Telegram, and WhatsApp also process information for their own services. Their activities are governed by their respective privacy policies and applicable law.

Depending on the activity, a provider may act on its own behalf or process information for another organisation. This Policy describes our responsibilities; it does not replace a platform’s privacy policy or give us control over its systems.

Other members may independently process information when communicating or conducting business with you. Our Terms restrict their use of community information, but those restrictions do not make all member activity processing on our behalf.

3. Information You Provide

Membership applications

We collect information supplied through the application, including:

  • Full name

  • Email address and mobile number

  • City and country of residence

  • Current role, company, industry, and professional background

  • Professional profile links or other references

  • Self-declared net worth range

  • Main source of wealth

  • Typical investment or transaction size

  • Business, investment, and geographic interests

  • Reasons for joining and intended contribution

  • Referral details

  • Eligibility and conduct declarations

  • Acceptance of the Terms and related application records

We request ranges rather than a detailed inventory of your assets in the standard application.

Verification

Where necessary, we may collect:

  • Identity confirmation information

  • Notes from a verification conversation

  • Relevant company or professional records

  • Information supplied by a reference

  • Redacted evidence supporting financial eligibility

  • Confirmation from an appropriately qualified accountant or lawyer

  • An identity document where other checks are insufficient

Before requesting identity documents or financial evidence, we will explain what is needed, why it is needed, how to provide it, who may access it, and the applicable retention period.

Verification calls are not recorded unless we explain a specific reason and obtain separate permission beforehand. Declining a recording does not, by itself, prevent verification through another reasonable method.

We do not ask for passwords, authentication codes, financial account access, or cryptocurrency recovery phrases.

Participation and administration

We may process:

  • Platform usernames, user IDs, and membership status

  • Joining, access, suspension, and departure records

  • Introductions, messages, files, and other contributions available to administrators in official spaces

  • Requests to share opportunities

  • Relevant commercial-interest disclosures

  • Moderation reports, evidence, decisions, and reconsideration requests

  • Correspondence with the community team

We do not automatically have access to private conversations between members. We may receive relevant extracts when a participant submits them for support, moderation, or a legal matter.

Contact and subscriptions

When you contact us, we collect your contact details, message, and relevant follow-up correspondence.

If you subscribe to optional updates, we collect your subscription preferences and a record of the choice you made.

4. Information Collected Through the Website

When you visit the website, our systems and service providers may process technical information such as:

  • IP address

  • Browser and device type

  • Operating system

  • Requested pages and access times

  • Referring page or website

  • Error records

  • Security events and suspected automated abuse

  • Cookie identifiers and consent preferences, where applicable

We use necessary technical information to deliver the website, troubleshoot errors, prevent abuse, and maintain security.

Cookies, embedded content, or similar tools that are not necessary for the requested service will be subject to the choices and legal requirements explained in our Cookie Policy.

Accepting membership Terms does not authorise optional tracking.

5. Information From Other Sources

We may obtain relevant information from:

  • Public company registers

  • Business websites and professional profiles

  • References identified by an applicant

  • A person who introduces or refers an applicant

  • Members reporting a conduct or security concern

  • Platform providers or professional advisers helping address an incident

  • Competent authorities where a lawful request or notification is involved

We limit checks to information reasonably relevant to identity, eligibility, professional background, security, or community conduct.

We do not treat an allegation, an online statement, or a referral as automatically accurate. Where adverse information materially affects a decision, we will ordinarily allow clarification, subject to confidentiality, safety, and legal restrictions.

Where required, we will provide notice to people whose information we receive indirectly within the applicable legal period.

6. Why We Use Personal Information

We use information for the following purposes.

Purpose Information involved
Responding to enquiries Contact details, messages, and correspondence
Assessing applications Application answers, background references, and eligibility information
Confirming identity and eligibility Verification records and supporting evidence where required
Providing membership access Contact details, platform identifiers, and access records
Operating the community Introductions, contributions, preferences, and administrative records
Reviewing proposed commercial posts Proposed content, conflicts, and approval correspondence
Handling complaints and enforcing rules Reports, relevant evidence, decisions, and responses
Maintaining security Technical logs, account identifiers, and incident information
Sending service notices Registered contact details and membership status
Sending optional updates Subscription details and communication preferences
Meeting legal obligations and handling claims Information necessary for the particular obligation or dispute
Understanding community composition Limited membership information used to prepare appropriately aggregated statistics

We do not use application net worth information to target members with investment promotions or sell access to them.

7. Legal Grounds for Processing

Where applicable law requires a legal ground, we use one appropriate to the particular activity.

Steps requested by you and membership administration

We process information necessary to consider your application and provide the membership you request, where the relevant law permits reliance on contractual necessity or pre-contractual steps.

Legitimate interests

Where recognised by applicable law, we may rely on legitimate interests in:

  • Maintaining a credible and relevant community

  • Preventing impersonation, fraud, and misuse

  • Protecting members and confidential discussions

  • Responding to enquiries and complaints

  • Maintaining website and account security

  • Establishing, exercising, or defending legal claims

We consider whether the processing is necessary, proportionate, and reasonably expected, and whether your rights override those interests.

Consent

We obtain consent where required, including for optional marketing, non-essential tracking, recording a verification call, or a proposed publicity use involving your identity.

You may withdraw consent by contacting us or using the relevant unsubscribe or preference control.

Withdrawal does not affect processing lawfully completed before withdrawal.

Legal obligations

We may process or disclose information where necessary to comply with an applicable legal obligation or binding legal demand.

We do not rely on acceptance of this Policy as blanket consent to all processing.

8. Required and Optional Information

Application fields marked as required are needed to assess eligibility or administer membership.

If you do not provide necessary information, we may be unable to assess the application, establish identity, or provide the requested access.

Optional profile references, additional background details, marketing subscriptions, and publicity permissions are not conditions of membership unless a particular item is reasonably necessary for an alternative verification process explained to you.

Where possible, we will consider a less intrusive way to establish the same fact.

9. Sensitive and Excessive Information

Financial information and identity documents require particular care, even where they are not legally classified as special-category information.

Do not submit:

  • Full account credentials or payment card security details

  • Cryptocurrency recovery phrases or private keys

  • Unredacted financial statements unless specifically requested

  • Health information, political opinions, religious beliefs, or other sensitive information unrelated to the application

  • Confidential information about another person without authority

Redact unrelated transactions, account numbers, and third-party information from requested evidence unless those details are necessary for the stated check.

We do not conduct biometric matching or create biometric identification templates as part of our standard admission process.

If information subject to special legal protections is genuinely necessary for a complaint, legal claim, or other exceptional matter, we will identify the applicable additional processing condition before using it.

10. What Other Members Can See

Other members may see your real name, the professional background you share, your contributions, and platform profile information.

Discord

Participants may see your display name, username, server profile, messages, files, and other information you make available through the server.

Telegram

Participants may see your name, username, photograph, contributions, and other profile information. Phone-number visibility depends on Telegram’s settings and the relationship between users.

WhatsApp

In ordinary WhatsApp groups, your phone number is generally visible to other participants. Profile information visibility also depends on the platform’s settings and features.

Do not assume that joining a private group hides your phone number from its members.

Application information

We do not distribute your application, net worth range, source-of-wealth answers, identity documents, or verification evidence to the general membership.

Administrators may use a simple access designation, such as approved membership or restricted-channel eligibility, without disclosing the underlying financial evidence.

We will not publish a member directory or share an application biography with the community without explaining the proposed use and obtaining any permission required.

11. How We Share Information

We share information only where relevant to an identified purpose.

Authorised administrators

Administrators receive access according to their responsibilities. Financial evidence and identity documents are restricted to those conducting verification or handling a relevant legal or security matter.

Service providers

Providers may process information to support:

  • Website hosting and maintenance

  • Application and contact forms

  • Email delivery

  • Secure storage and backups

  • Security and anti-abuse measures

  • Technical support

  • Verification, where a provider is specifically engaged

Providers acting on our behalf must receive appropriate instructions and contractual protections. Before introducing an external verification provider, we will explain its role and the information it will receive.

Community platforms

Discord, Telegram, and WhatsApp receive information necessary to provide their services when you create an account, join, or participate.

We do not supply your complete membership application to those platforms merely to admit you.

Professional advisers

Lawyers, accountants, insurers, and other advisers may receive information reasonably necessary for confidential advice, legal claims, or compliance.

Authorities and legal disclosures

We may disclose information in response to a lawful obligation, valid legal process, or a justified report to a competent authority.

We assess the request and limit disclosure to what is necessary. A person identifying themselves as an authority does not automatically receive access.

Business transfers

Information may be disclosed where necessary for a genuine transfer or reorganisation of the business, subject to appropriate confidentiality, lawful processing, and notice requirements.

A prospective buyer does not receive unrestricted access to financial evidence or private conversations simply because discussions are taking place.

Your instructions

We may share information at your express request, including a requested introduction. Permission for one introduction does not authorise unrelated disclosure.

We do not sell personal information or provide member lists to advertisers, brokers, fundraisers, or other members.

12. International Processing

Millionaires United is administered from Sri Lanka. Our members and platform providers operate internationally.

Information may be accessed or processed in Sri Lanka and in other countries where relevant providers, authorised administrators, or recipients operate.

Participation in an international group also makes information you share available to members in their respective countries.

Where applicable law requires safeguards for an international transfer, we must establish an appropriate mechanism before making that transfer. Depending on the circumstances, this may include an applicable adequacy decision, recognised contractual safeguards, and supplementary protections.

We do not treat acceptance of membership Terms or this Policy as blanket consent to international transfers.

You may contact us for information about the recipients, destinations, and transfer safeguards relevant to your information, and request a copy or explanation of applicable safeguards subject to necessary redactions.

If a required lawful arrangement cannot be established, we may restrict the relevant processing or be unable to provide a particular service.

13. Retention Periods

We retain identifiable information only for the stated purpose and period, subject to lawful exceptions below.

Record category Standard retention period
Incomplete applications Up to 90 days after the last activity
Declined, withdrawn, or closed applications Up to 12 months after the final decision or closure
Waitlisted applications Up to 12 months after waitlisting; a longer waitlist requires your agreement to remain under consideration
Approved application and core membership record During membership and up to 24 months after closure
Copies of identity documents and raw financial evidence Deleted within 30 days after the verification decision or completion of a related reconsideration
Minimal verification record During membership and up to 24 months after closure
Routine support and contact correspondence Up to 24 months after the enquiry is resolved
Ordinary website security and access logs under our control Up to 90 days
Significant incident, moderation, and legal complaint records Up to three years after the matter is closed, unless a longer legal hold is necessary
Optional marketing subscription information Until unsubscribe, or after 24 months without meaningful subscriber activity
Records of consent, withdrawal, and policy acceptance During the relevant relationship and up to three years afterwards
Privacy-request records Up to three years after completion
Routine backup copies under our control Expire through rotation within 90 days after deletion from active systems

Minimal verification records

These record the date, method, reviewer, result, and any necessary follow-up. They should not reproduce a complete identity document, financial statement, or unrelated personal information.

Private community content

Conversation histories on Discord, Telegram, and WhatsApp are not governed by a single retention period controlled by us.

We do not routinely create complete external archives of group conversations. Material copied for a specific moderation, legal, or support purpose follows the relevant period above.

Messages may remain in platform systems, conversation histories, backups, and recipients’ accounts after you leave. We assess requests concerning content we can control, but cannot promise deletion from every recipient’s device or independent platform system.

Legal holds and exceptions

Where information is needed for an existing dispute, investigation, legal obligation, or reasonably anticipated claim, we may retain the relevant portion beyond the standard period.

We record the reason, restrict use, and review the need at least every six months. Unrelated records are not retained merely because a legal hold exists.

Deletion requests and applicable law may require earlier deletion. Legally required retention may require longer storage.

Where backup copies cannot immediately be selectively removed, they remain protected, are not used for ordinary processing, and are removed through the stated rotation. If restored for recovery, relevant deletions must be reapplied.

14. Preventing Re-Entry After Serious Misconduct

Where necessary to prevent a person removed for serious misconduct from rejoining, we may retain a limited restriction record for up to three years after removal.

This may contain a name, relevant account identifier or email address, removal date, and a brief reason.

It does not justify retaining the person’s complete application, identity documents, or financial evidence.

We review restriction records annually. Longer retention requires a documented continuing risk or legal reason.

15. Security

We restrict access according to role and use safeguards appropriate to the information and risk.

Our requirements include:

  • Individual administrator accounts

  • Multi-factor authentication where available

  • Restricted access to verification material

  • Secure methods for transmitting sensitive evidence

  • Confidentiality obligations for people handling records

  • Removal of access when an administrator’s role ends

  • Review of provider access and security incidents

  • Deletion schedules for records under our control

No service can guarantee absolute security.

If a personal information breach occurs, we will investigate, take reasonable containment measures, and make notifications to authorities and affected individuals where required by applicable law.

You can help by protecting your accounts, reviewing platform settings, and reporting suspicious requests promptly.

16. Marketing and Service Messages

Service messages include application updates, verification requests, access instructions, security alerts, and material changes affecting membership.

These are separate from optional newsletters or promotional updates.

Where required, optional marketing uses a separate opt-in. You may unsubscribe through the message or by contacting us.

We retain a minimal suppression record, normally the email address and opt-out status, to avoid sending further unwanted marketing. It is used for suppression rather than promotion and retained while needed for that purpose.

Unsubscribing from marketing does not prevent essential membership communications. Closing membership ends routine member communications, except messages needed to complete closure, handle outstanding matters, or meet legal obligations.

17. Statistics, Publicity, and AI

We may prepare aggregate statistics about membership size, countries, industries, and community participation.

We will avoid publishing small-group breakdowns or combinations that could reasonably identify a member or reveal their financial circumstances.

We do not publish identifiable wealth information, member names, photographs, testimonials, or case studies without separate permission.

We do not use private applications, identity documents, financial evidence, or community conversations to train AI models.

We do not upload those materials to external generative AI services for routine review or summarisation.

These commitments govern our own activities. Independent platform providers operate under their own policies.

18. Automated Decisions

Admission, refusal, suspension, and termination decisions are reviewed by a person.

We do not make these decisions solely through automated profiling.

Technical systems may help detect spam, suspicious access, or form abuse. If an automated restriction prevents you from applying or accessing a service, contact us for human review.

19. Your Rights and Choices

Depending on the law applicable to you and the circumstances, you may have rights to:

  • Receive information about our processing

  • Access your personal information

  • Correct inaccurate or incomplete information

  • Request deletion

  • Restrict certain processing

  • Object to processing based on legitimate interests

  • Object to direct marketing

  • Receive certain information in a portable format

  • Withdraw consent

  • Challenge a solely automated decision where such rights apply

  • Complain to a competent data protection authority

These rights are not absolute. For example, access may require redaction of another person’s information, and deletion may be limited by a legal obligation or an active claim.

Where we refuse or limit a request, we will explain the reason to the extent legally permitted and identify available complaint routes.

We do not require you to waive privacy rights as a condition of membership.

20. Making a Privacy Request

Email contact@millionairesunited.com with the subject Privacy Request.

Where possible, use the email address associated with your application or membership and explain the request.

We will verify identity proportionately. We will not routinely require a full identity document where control of the registered account or another less intrusive check is sufficient.

We aim to acknowledge requests within five working days and respond within one calendar month.

Where applicable law requires a shorter period, we will follow it. Where an extension is legally permitted and necessary because of complexity or request volume, we will explain the reason and revised deadline within the original response period.

Requests are ordinarily free. A charge or refusal for a manifestly unfounded or excessive request will be considered only where permitted by law and explained in advance.

An authorised representative may contact us, but we may request evidence of authority and verify the identity of the person represented.

Requests concerning a platform provider’s own records may also need to be directed to that provider. We will still address information within our responsibility.

21. Children

Membership is restricted to individuals aged 18 or older.

We do not knowingly accept membership applications from children or intentionally collect their information for membership.

If you believe a child has submitted personal information, contact us. We will investigate and delete information that has no lawful reason to be retained.

Do not include children’s identities, documents, photographs, or financial information in an application or community discussion unless genuinely necessary, lawful, and authorised.

22. Information About Other People

If you identify a referrer, provide a reference, submit a report, or share information about another person:

  • Include only what is relevant

  • Do not falsely claim their endorsement

  • Inform them where appropriate

  • Do not submit confidential or sensitive material without authority or another lawful justification

Providing another person’s details does not automatically give us permission to market to them.

We may contact a named reference to confirm relevant background, but will not send your full application or financial information merely to request a reference.

23. Complaints

If you believe information has been mishandled, contact us with the subject Privacy Complaint.

Explain the concern and the outcome sought. We aim to acknowledge the complaint within five working days and provide a response or progress update within 30 calendar days.

You do not have to complete our internal complaint process before approaching a competent authority.

Depending on your location and applicable law, you may contact:

  • The Data Protection Authority of Sri Lanka

  • The relevant supervisory authority in your European Economic Area country

  • The UK Information Commissioner’s Office

  • Another data protection or privacy regulator with jurisdiction

Applicable legal remedies remain available.

24. Changes to This Policy

We will update the version and date when this Policy changes.

For a material change to how we use or disclose applicant or member information, we will ordinarily provide at least 30 calendar days’ notice by email or an official community channel.

Urgent legal or security changes may require shorter notice.

If a new purpose requires consent, we will request it before beginning that processing. Publication of a revised Policy does not retrospectively authorise an incompatible use or replace legally required consent.

25. Third-Party Privacy Information

For information about the platforms’ own processing, consult:

External links, embeds, and services may involve independent processing. Review the relevant provider’s information before using them.

26. Contact Us

For privacy questions, requests, or complaints:

Athada (Pvt) Ltd, trading as Millionaires United

Level 13, MAGA ONE
No. 200 Narahenpita Road
Colombo 00500, Sri Lanka

Email: contact@millionairesunited.com
Subject: Privacy Request or Privacy Complaint