Privacy Policy

This Privacy Policy (“Policy”) describes the different ways FreySoft Poland LLC (“we”, “us”, “our”, “Company”, “Makedeal“) may collect, use, and share information obtained when you interact with the website https://app.makedeal.io (the “Site”), email address support@makedeal.io, the Company’s social media accounts such as Facebook, LinkedIn, Twitter, Instagram, Youtube (“social media accounts”), mobile application Makedeal (the “App”), or provide us with information about yourself in other ways. Such treatment may include, but is not limited to, the following:

• collection;
• recording;
• organization;
• storage;
• structuring;
• adaptation;
• alteration;
• retrieval;
• consultation;
• use;
• disclosure by transmission;
• dissemination or otherwise making available;
• alignment or combination;
• restriction; and
• erasure or destruction.

You can be visitor, client or candidate (collectively“users”):

• You are a visitor when you merely browse this Site and/or submit your personal data via cookies;
• You are a client when you accessing our Site and/or App and submit your personal data via registration form to receive our services;
• You are a candidate when your personal data is submitted to us by our clients for the purpose of receiving our recruitment services.

When you submit your personal data via our Site or App, you may be asked to consent to our processing of the personal data you provide as explained in this Policy to enable us to provide you with the information or service requested, if no other legal ground can be used.

We use the following definitions in this Policy:

“data controller” means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data is processed.

“data processor” means the natural or legal person who processes personal data on behalf of the data controller.

“data subject” is any living individual who is using our Site and/or Services.

“personal data” means any information relating to you and helping identify you (directly or indirectly) such as your name, last name, email, location data, etc.

“processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“joint controllers” means two or more controllers jointly determining the purposes and means of processing.

We collect information about you in connection with our Site and Services in two main ways:visitor data (obtained via the Site),client data (obtained through the Site and the App), andcandidate data(obtained through the Site and the App). In particular, we collect:

Visitor data:

• (a)Cookies Information. On our Site, we may use cookies and other tracking technologies for a variety of purposes: for analytics, marketing activities, remembering your preferences, and other purposes. Such use may involve the transmission of information from us to you and from you to a third party website or us. To learn more regarding our use of cookies please see the ‘Use of Cookies’ section of this Policy.

  Please note that we use third-party payment processors to collect this information from you and process your payment. Such a third-party payment processor is responsible for all collection, processing, and storage of your financial information and we do not have direct access to or possession of your payment card information or banking information.

Client data:

• (b)Contact Information. We can collect some personal data when you submit your personal data via the Site or the App. Such data may include full name, job position, nationality, employer company, email address.
• (c)Accounting Information. We collect certain information to comply with our accounting obligations, in particular we may collect a list of users and information on their subscriptions.

Candidate data:

• (d)Recruitment Information.We collect candidate’s CVs clients provide us with. During this process we may collect different personal data, including without limitation any personal data concerning clients’ customers that may appear in CVs, e.g., contact information, education information, job information, etc.
• We use the personal data we collected and the personal data you provided us with or requested us to collect only for the purposes listed in this Policy. We may share your personal data with third parties solely for the purposes listed herein.

We DO NOT sell your data. We DO NOT use automated decision-making and profiling.

We DO NOT intentionally collect and process any sensitive personal data. Please, refrain from sharing your or third-party sensitive personal data with us.

We collect and process your personal data in accordance with the provisions of the GDPR.

GDPR provides an exclusive list of lawful bases allowing us to process your personal data. During personal data processing we rely only on four of them, namely:

Article 6.1(a): consent

We collect the information you choose to give us, and we process it under your consent. You may withdraw your consent to the processing of your personal data at any time.

Please remember that the withdrawal of consent does NOT automatically mean that the processing before the withdrawal is considered unlawful. You may withdraw the consent to the processing of your personal data by sending us an email at support@makedeal.io, or by contacting us in any other way convenient for you

Article 6.1(f): legitimate interests

We process your personal data to prevent any fraudulent actions and to provide you with the desired services. Also, we need some data to enable our Site to run smoothly and give you a pleasant user experience. We use only strictly necessary data under this legal ground.

Article 6.1(b): performance of a contract

When you provide a third-party payment processor with the personal data with requested banking information to purchase services; this can be deemed as your request to form a contract or to perform a contract between you and us. However, we may ask you to give us clear consent in case of doubt.

Article 6.1(c): legal obligation

We process your personal data to fulfil the applicable legal obligations arising mainly from the GDPR. In the event of you sending us the request to fulfil the rights granted by the GDPR, we may ask you for some personal data we already have to identify you and achieve compliance with the applicable law.

Use of Your Personal Data

As a data controller and/or data processor, we use your personal data for the purposes listed in the table below where we also detail the type of personal data processed, legal bases we rely on to do so, third parties with whom we may share your personal data and information as to source of such data:

Please, note that upon processing of payments using services of a payment processor, such payment provider may collect certain personal data it considers as necessary for provision of services. Such collection of personal data is regulated under the rules and policies of payment processors. We advise you to access the payment processors’ websites carefully and always check their policies and rules regarding the collection of your personal data.

Use of Cookies

We use cookies and other tracking technologies on our Site for a number of purposes, including enabling the functionality of the Site, enhancing user experience, understanding the online behaviour of people who interact with our Site, and delivering relevant interest-based advertising to you on third-party websites.

We do not use cookies to directly identify you. We only use cookies for the following purposes:

Necessary: these cookies and other tracking technologies are essential for your use of the Site and our compliance with applicable data protection laws. We use them for certain purposes, such as checking if the user’s browser supports cookies and determining whether the user has accepted the cookie consent box or not.

Statistics: these cookies help us to understand how users interact with our website (e.g., page visits and page load speed) by collecting information anonymously to avoid your identification. Their sole purpose is to improve website functions.

Marketing: these cookies and other tracking technologies are used to deliver relevant online advertising to you on other websites. These cookies are placed by us and selected third parties and enable adverts to be presented to you on third party websites.

Data Security, Integrity and Retention

We store and process your personal data until we do not need it for any of the purposes defined in this Policy unless longer storage is required or expressly permitted by law.

We may not delete or anonymize your data if we are compelled to keep it to comply with the law or legal process.

Notwithstanding any of the aforementioned periods of data storage, you may request to delete your personal data by sending us an email at support@makedeal.io or contacting us via another way convenient for you.

We have implemented appropriate organizational, technical, administrative, and physical security measures that are designed to protect your personal data from unauthorized access, disclosure, use, and modification. We regularly review our security procedures and policies to consider appropriate new technology and methods.

Data Sharing and Disclosure

We may share your personal data to other data processors and data controllers in accordance with provisions specified hereafter.

Sharing data with data processors

There are many features necessary to provide you with our services that we cannot complete ourselves, thus we seek help from third parties. We may grant some service providers access to your personal data, in whole or in part, to provide the necessary services.

Therefore, we may share and disclose your personal data to other data processors:

• Canny (Canny Inc, USA): to receive feedback from our users. You may read its Privacy Policy here;
• Hubspot (Hubspot Inc, USA): to manage our relationships with users. You may read its Privacy Policy here;
• Greenhouse (Greenhouse Software Inc, USA): to optimize the process of candidates’ tracking and to provide our services. You may read its Privacy Policy here;
• Google Analytics (Google LLC, USA): to analyze statistical data on how the visitor uses the Site in order to improve our Site’s functionality. You may read its Privacy Policy here.

During our business activities we may engage different specialists which may receive your personal data, including technical, sales and marketing specialists, to provide you with better client service. Also, we may disclose some of your personal data to our outsource legal professionals to make our business accurate and transparent. The abovementioned specialists are collectively referred to as Contractors.

We may transfer your personal data to countries outside the EU and EEA (the USA, Ukraine, etc.) that are not determined to offer an adequate level of data protection on the basis of article 45 of GDPR (adequacy decision) with appropriate safeguards as determined under the GDPR.

We only transfer your personal data to third parties within requirements under the GDPR. Where possible, we always enter into Data Processing Agreements (DPAs) and Non-Disclosure Agreements (NDAs) with them and treat personal data transfer seriously. Where the Contractor has an appropriate data processing agreement in place, Makedeal may adjoin such data processing agreement. If so, Makedeal and the Contractor may regulate the transfer of the personal data to such Contractor by means of this data processing agreement.

Transferring your personal data outside of the European Economic Area

For transfers to countries that do not fall under requirements of Article 45 of the GDPR on the adequacy of the level of protection, we may transfer your personal data to the third countries outside the EU and the EEA, including the onward transfers of the personal data from the third countries to another third countries, under Article 46 of the GDPR with the appropriate safeguards, including the SCC.

We disclose your personal data to the countries outside the EU and the EEA, in compliance with our internal International Transfer Procedure in order to adduce adequate safeguards with respect to the protection of privacy and fundamental rights and freedoms of natural and legal persons.

We put supplementary technical and organizational measures in place when transferring data outside the EU and the EEA. e.g. prior assessment of the service supplier’s reliability and personal data protection practices, encryption of the transferred personal data, prompt reacting to any threats to confidentiality, integrity and availability of the personal data, conducting transfer impact assessments (TIA) when necessary, etc.

Your Rights under the GDPR

You may exercise the following rights by submitting your request at support@makedeal.io.

When we act as a joint controller with regard to particular processing of personal data, you may exercise your rights under the GDPR in respect of and against both advertising platforms and us.

Rights under the GDPR

• right of access means that you may ask us to send you the copy of your personal data collected together with information regarding the nature, processing and disclosure of that personal data;
• right to rectification means that you may ask us to update and correct the false data, missing or incomplete personal data.
• right to erasure (to be “forgotten”) means that you may ask us to delete your personal data collected, except insofar it is prohibited by appropriate laws.
• right to restriction of processing means that you may ask us to restrict processing where:
  • 1your personal data is not correct or outdated;
  • 2the processing is unlawful.
• right to object to the processing means that you may raise objections on grounds relating to your particular situation;
• right to data portabilitymeans that you may ask us to transfer a copy of your personal data to another organisation or to you;
• right to withdraw the consentwhen your personal data processed on a basis of your consent;
• right to lodge a complaint with the supervisory data protection authoritypertaining to the processing of your personal data. You may submit the complaint to the supervisory authority of your place of residence within the EU or to the data protection authority stated in this Policy.

Please, note that we may need to confirm your identity to process your requests to exercise your rights under the GDPR. Thus, we may not be able to satisfy your request if you do not provide us with sufficient detail to allow us to verify your identity and respond to your request.

Data Protection Authority under the GDPR

Please, note that we may need to confirm your identity to process your requests to exercise your rights under the GDPR. Thus, we may not be able to satisfy your request if you do not provide us with sufficient detail to allow us to verify your identity and respond to your request.

We kindly invite you to share your concerns with us in the first place regarding any issue related to your personal data processing. You may contact us to address your inquiries: support@makedeal.io.

Supervisory Authority under GDPR:

In case of any questions regarding data protection, you can apply to the supervisory authority. We will cooperate with the appropriate governmental authorities to resolve any privacy-related complaints that cannot be amicably resolved between you and us. You can find the full list of EU supervisory authorities through the link.

Children’s Privacy

Generally, our Site and Services are intended for general audiences and are not directed to children under 13. We do not knowingly collect any personal information from children under the age of thirteen without seeking any required parental approval in accordance with applicable legal and regulatory obligations, such as the U.S. Children’s Online Privacy Protection Act (“COPPA”).

If we become aware that a child has provided us with personal information without a parent’s permission, we will promptly delete this information. If you become aware that a child has provided us with personal information without parental consent, please contact us by email at link.

Changes to the Privacy Policy

This Policy may be changed from time to time due to the implementation of new updates, technologies, laws’ requirements or for other purposes. We will send notice to you if these changes are dramatic and where required by applicable laws, we will obtain your consent for the subsequent processing. In any case, we encourage you to regularly review this Policy to check for any changes.

Such notification may be provided via your email address, announcement published on our Site on in the App and/or by other means, consistent with applicable law.

How to Contact Us

If you have a question related to this Privacy Policy, our processing activities, or your data subject rights under GDPR and other applicable laws, you can contact us directly using the following details:

• Our email: support@makedeal.io
• Our telephone: +48 795 991 686
• Our address: ul. HUMAŃSKA, nr 8, lok. ---, miejsc. WARSZAWA, kod 00-789, poczta WARSZAWA, kraj POLSKA