Privacy Policy of the PraeDeals Platform

Version: 1.2    Effective date: 22.04.2026

1. General provisions

This Privacy Policy (the “Policy”) sets out the procedure for the collection, processing, storage, and protection of personal data of users of the PraeDeals platform (the “Platform”).

By using the Platform, the user confirms that they have read this Policy and understand the conditions under which their personal data are processed.

PraeDeals processes personal data in accordance with Regulation (EU) 2016/679 (the General Data Protection Regulation, “GDPR”) and other applicable legislation of the European Union.

2. Roles of the parties in the processing of personal data

Depending on the stage and context of interactions on the PraeDeals Platform, the roles of the parties in relation to personal data processing may differ.

2.1. Processing within the operation of the Platform

With respect to personal data processed for the purposes of registration, authentication, account management, billing, security, and the technical operation of the Platform, the PraeDeals operator acts as the data controller within the meaning of the GDPR.

2.2. Processing within PraeDeal transactions

With respect to personal data disclosed between Platform users within a PraeDeal transaction through the use of a PraeKey, each user who receives such data acts as an independent and separate controller of personal data.

PraeDeals provides only the technical infrastructure to facilitate contact and limited access to data, but it does not determine the purposes or means of any further processing of personal data by the parties to a transaction.

PraeDeals is not a joint controller of personal data processed by users within PraeDeal transactions and does not control any further use of such data.

2.3. EU Representative (Article 27 GDPR)

As the PraeDeals operator is established outside the European Union, it has appointed an EU representative in accordance with Article 27 of the GDPR.

The EU representative acts as a contact point for supervisory authorities and data subjects in the European Union with regard to matters related to personal data processing.

The EU representative does not participate in the processing of personal data and does not determine the purposes or means of such processing.

3. Categories of personal data processed

PraeDeals may process the following categories of users’ personal data:

• identification data (first name, last name, nickname);
• contact data (email address, phone number);
• account and user profile data;
• professional information (CV/resume, skills, work experience, portfolio);
• company or buyer profile data;
• communications data within the Platform;
• technical and operational data (IP address, device type, logs);
• payment information (in a limited form, processed via payment providers).

PraeDeals does not intentionally process special categories of personal data within the meaning of Article 9 of the GDPR.

4. Purposes of processing

Personal data are processed for the following purposes:

• user registration and account administration;
• providing the Platform’s functionality;
• enabling professional interaction between users;
• processing subscriptions, payments, and other financial operations;
• user support and communications;
• compliance with legal obligations;
• ensuring the security of the Platform;
• analytics and improving the Platform’s quality.

5. Legal bases for processing

Personal data are processed on the following legal bases:

• performance of a contract with the user, entered into upon registration and use of the Platform;
• the data subject’s consent;
• compliance with legal obligations imposed on PraeDeals;
• PraeDeals’ legitimate interests, including security, abuse prevention, and analytics.

5.1. Expression of user consent

Registration on the PraeDeals Platform requires mandatory verification of the email address by entering a unique verification code sent to the user.

Completion of registration and entry of the verification code means that the user:

• confirms the accuracy of the contact data provided;
• confirms that they have read the Platform’s Terms of Use and this Privacy Policy;
• gives consent to the processing of their personal data to the extent necessary to provide the Platform’s functionality, perform the contract, and comply with applicable law;
• confirms the conclusion of an agreement to use the Platform in electronic form.

Consent is deemed to be given through the user’s conscious and active actions, including account registration, email verification, profile completion, and use of the Platform’s functions.

Where applicable law requires separate consent (for example, for marketing communications or the use of certain cookies), such consent is requested separately through the relevant interfaces of the Platform.

5.2. Infrastructure and Hosting

We process personal data using secure infrastructure and hosting services provided by professional data center operators acting as data processors within the meaning of Article 28 of the General Data Protection Regulation (GDPR).

Such providers process personal data exclusively on our documented instructions and are contractually bound to implement appropriate technical and organizational measures in accordance with Article 32 of the GDPR.

Our primary hosting and infrastructure services are located within the European Union. Personal data are not transferred to third countries outside the EU unless appropriate safeguards under Chapter V of the GDPR are in place.

6. Disclosure of personal data to third parties

PraeDeals may disclose personal data to the following categories of recipients:

• payment providers;
• hosting and cloud infrastructure providers;
• analytics and technical service providers;
• public authorities, where there is a lawful request.

PraeDeals does not sell users’ personal data. Any disclosure of personal data to third-party advertising platforms for conversion tracking or measurement purposes is carried out only where the user has provided the required consent and only to the extent necessary for such purposes.

PraeDeals is not responsible for the processing of personal data by Platform users carried out outside of the Platform’s functionality or within their independent obligations as data controllers.

6.1. Advertising and conversion tracking

The Platform may use third-party advertising and tracking technologies to measure the effectiveness of advertising campaigns and optimise user acquisition.

Such technologies may include services provided by:

• Meta Platforms Inc.;
• Google LLC;
• TikTok Technology Limited.

Where the user has provided the required consent, PraeDeals may transmit to such providers certain data related to a conversion event, including:

• hashed email address;
• phone number;
• IP address;
• browser and device data;
• event data (for example, submission of a “Lead” form).

These providers may act as independent data controllers with regard to the personal data they receive.

PraeDeals does not control the further processing of data by such providers after transmission.

The legal basis for such processing is the user’s consent (Article 6(1)(a) GDPR).

7. International transfers

Where personal data are transferred outside the European Union, PraeDeals ensures an appropriate level of protection in accordance with the GDPR, including by using Standard Contractual Clauses.

8. Retention periods

Personal data are retained for no longer than is necessary to achieve the purposes of processing or for the periods required by applicable law.

When processing is no longer necessary, personal data are deleted or anonymised.

9. Data subject rights

The user has the right to:

• obtain information about their personal data;
• access personal data;
• rectify inaccurate or incomplete data;
• erase personal data (“right to be forgotten”);
• restrict processing;
• data portability;
• withdraw consent where processing is based on consent;
• lodge a complaint with a personal data protection supervisory authority in the European Union.

Exercise of data subject rights in relation to processing carried out by Platform users within PraeDeal transactions is performed directly between the relevant users without involvement of PraeDeals.

10. Security of personal data

PraeDeals implements appropriate technical and organisational measures to protect personal data against unauthorised access, loss, destruction, alteration, or unlawful use.

Such measures include, in particular, access control, activity logging, encryption, and data segmentation.

Where applicable, we rely on technical and organizational security measures implemented by our infrastructure providers, including measures audited under internationally recognized information security standards.

11. Cookies and similar technologies

The Platform may use cookies and similar technologies to ensure proper operation, analyse Platform usage, and improve user experience.

Cookie settings may be managed by the user via the Platform’s interfaces (where available) or through browser settings.

12. Changes to this Policy

PraeDeals reserves the right to amend this Policy.

The current version of the Policy is always available on the Platform. Material changes will be communicated to users in advance or by other appropriate means.

13. Contacts

For matters related to the processing of personal data within the operation of the Platform, the user may contact the PraeDeals operator using the contact details provided on the Platform.

A data protection contact person may be indicated separately on the Platform.

For matters related to the processing of personal data within PraeDeal transactions, users interact directly with each other as independent controllers of personal data.

EU data subjects may also contact the appointed EU representative for matters related to personal data protection in accordance with Article 27 of the GDPR.