Privacy Policy

Last Updated: 2024-03-01 09:50 UTC

We understand that you value the confidentiality of your information, and we are committed to handling it with care and prudence. By using our Services, you agree to the data practices outlined in this Privacy Policy, as detailed in our Policies. This Privacy Policy explains how we collect, obtain, use, retain, share, transfer, and process your Personal Data, as well as your options and rights regarding your Personal Data. For the purposes of this Privacy Policy, "Personal Data" refers to any information that relates to an identified or identifiable individual. If you do not agree with our Privacy Policy, please refrain from using our Services.

Our Customers may collect and manage Personal Data while using our Services. As a processor, we process Personal Data on behalf of our Customers, who are responsible for complying with any applicable regulations or laws that require notice, disclosure, or consent before processing Personal Data using our Services. Please refer to the sections "Data We Process on Behalf of Customers" and "Data We Collect from Our Services" as well as our Data Processing Agreement (DPA) for more information. If you have any concerns, please do not hesitate to contact us.

1. What information do we collect?

The data we collect from Users, Clients, Customers, and Visitors enables us to personalize and enhance your experience with our Services and is often necessary to provide our Services to you. When you utilize our Services, we may collect data as outlined below:

a. Information You Provide to Us

When you engage with our websites or any other sites or services that link to this Privacy Policy or use any of our Services, we may collect Personal Data and other information from you, as detailed further below:

When You Visit Our Websites

We gather Personal Data from you when you submit web forms or interact with our website. For instance, we may request your email address, name, job title, and other relevant business information when you register for one of our Services, or request support. You can explore our website without providing any Personal Data about yourself.

When You Register for an Event

When you register for an event we manage, we collect information such as name, address, phone number, and email address. We use this information to communicate with you and, in some cases, facilitate your registration. Additionally, we may share your registration data with service providers to provide event information and enhance your experience at an event or future events we operate.

Account and User Information

We collect Personal Data when you sign up for an Account, create or modify User information, set preferences, or provide any other related information to access or utilize our Services.

Payment Information

We collect payment and billing information when you register a Subscription. For example, we may ask you to provide a billing address and a billing contact for your Account. If you provide us with payment information, we use it solely as authorized by you under this Privacy Policy. You may also provide payment information, such as credit card numbers or bank account numbers when purchasing our Services. We utilize secure third-party payment service providers to manage payment processing, which is collected through a secure payment process.

Customer Testimonials

We showcase customer testimonials and comments on our websites, which may include Personal Data. We obtain each Customer's consent via email or through other agreements before posting the Customer's name and testimonial.

b. Information We Process on Behalf of Customers

Our Services facilitate customers' creation and sharing of information. During the use of our Services, Customers may accumulate Personal Data, including, but not limited to: first and last name, email address, physical address, phone number, or other details about you. We classify the information customers submit or gather via our Services as "Customer Data" under our Terms of Service.

We do not govern customers' data content or the types of Personal Data they may decide to collect or manage using our Services. We store customers' information on our service providers' servers, processing it as a processor, per our customers' instructions and our Terms of Service, which restrict us from utilizing the information except as necessary to deliver and optimize our Services and as required by law.

Customers have control over and are responsible for rectifying, deleting, or updating the information they process using our Services and for adhering to any applicable regulations or laws requiring notice, disclosure, and/or consent before transferring Personal Data to our Services.

c. Information We Collect From Use of Our Services

Usage Data

We collect usage data when you and your Account's Users engage with our Services. Usage data includes metrics and information related to your interaction with the Services, such as the most frequently used features, process start and completion times, and the frequency of specific feature usage (like processes) in your Account.

Mobile

When you access or use our Services via mobile applications, we automatically collect information such as your device model and version, operating system, or device identifier.

Third-Party Integrations

You may connect third-party integrations to your Account, which may request specific permissions to access data or transmit information to your Account. It is your responsibility to review any third-party integrations you authorize. We may collect information regarding the types of integrations you use in your Account.

By granting any permissions to third-party integrations, you allow them access to your data, which may include Account data (among other things); this may enable third-party applications to view, store, and modify your Account data. We are not responsible for the practices of third-party integrations, so please carefully review the permissions you grant to third-party applications.

d. Information We Collect From Other Sources

Marketing Partners

We may receive information regarding you or other Account Users from our network of partners, which could stem from our deal and lead registration process. We may also gather information about you through marketing partnerships, such as attending events, signing up for webinars, or downloading whitepapers published with our partners.

Third Parties

We may receive information from third-party service providers, affiliated companies, and business partners.

Combining of Personal Information

We may merge the personal information we collect from you with other information we receive from various sources, such as third-party providers of business information and publicly available sources (like social media platforms). This may include details such as physical and mail addresses, job titles, email addresses, phone numbers, IP addresses, and social media profiles. We do this to enhance our records, discover new customers, create more tailored advertising, suggest products and services that may interest you, deliver personalized communications, and promote events. Kindly note that third-party providers' collection of your personal data is governed by their respective privacy policies.

Log Files

Similar to most websites and internet-based services, we automatically collect and store information about your computer hardware and software when you visit our websites or use our Services. This may include details like your IP address, browser type, domain names, Internet service provider (ISP), viewed files on our websites, operating system, access times, and referring website addresses. We collect and store this information when a User signs in to the Services and accesses pages within the Services or visits our website.

Social Media

Our website may feature social media elements (such as the Facebook "like" button) and widgets (such as the share button or interactive mini-programs) that run on our websites. These features may collect your IP address and the page you are visiting on our sites, and they may set a cookie to enable the feature to function correctly. Please note that these features are governed by the privacy policies of the companies providing them, not our Privacy Policy.

Our Affiliates

We may receive information about you from other companies that are owned or affiliated with us.

e. Information We Collect From Social Media

We maintain online profiles on social networks to interact with our Users, Clients, Customers, and Visitors and share information about our Services. As a result, we may receive information, as permitted under GDPR article 6(1)(a)-(b), such as aggregated statistics on the use of our online profiles. These statistics may contain demographic information and data on the interaction with our online profiles and the distributed content.

Please find below the list of social networks we use as operators of our online profiles, along with relevant details and links:

Facebook

USA and Canada: Facebook Inc., 1601 Willow Road, Menlo Park, California 94025, USA; all other countries: Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland

1. Operation of the Makánal Tech Facebook page 🌐 https://www.facebook.com/makanaleu in joint responsibility based on 🌐 an agreement on joint processing of data (so-called Page Insights Supplement regarding the controller).
2. Information about Page Insights data: 🌐 https://www.facebook.com/legal/terms/information_about_page_insights_data
3. Privacy Policy: 🌐 https://www.facebook.com/about/privacy
4. Manage data used to show you ads on Facebook: 🌐 https://www.facebook.com/adpreferences/ad_settings

Google

Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland

1. Operation of the YouTube Channel 🌐 https://www.youtube.com/@makanaltech
2. Privacy Policy: 🌐 https://policies.google.com/privacy
3. Opt-out: 🌐 https://adssettings.google.com/authenticated

Google Business Profile

Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland

1. We operate a so-called Google Business Profile. Should you find us in this way, we make use of the information and services offered by Google.
2. We would like to point out that you use the Google site and its functions on your responsibility. This applies in particular to the use of social and interactive functions (e.g. commenting, sharing, rating, and direct messaging). When you visit and interact with our Google Business Profile, Google also collects your IP address and other information that is present on your device in the form of cookies. This information is used to provide us, as the operator of the Google Business Profile, with statistical information about the use of Google services. The data collected about you in this context will be processed by Google and may be transferred to countries outside the European Union. Google describes what information it receives and how it is used in its privacy policy.
3. Privacy Policy: 🌐 https://policies.google.com/privacy
4. We do not know how Google uses the data from the visit for its purposes, to what extent activities of individual users are assigned, how long Google stores this data and whether data is passed on to third parties. When accessing Google services, the IP address assigned to your device is transmitted to Google. Google also stores information about its users' end devices; this may enable Google to attribute IP addresses to individual users or user accounts.
5. If you contact us via a Google Business Profile or other Google services by direct message, we cannot rule out the possibility that these messages may also be read and evaluated by Google (both by employees and automatically). We, therefore, advise against providing us with personal data there. Instead, another form of communication should be chosen as early as possible. We delete conversations no later than 14 days after the last chat activity, or immediately after switching to another communication channel. The use of this service is subject to the Google Privacy Policy, which you - by using the service - have already agreed to.
6. We, as the operator of a Google Business Profile, do not collect or process any further data from your use of this Google service. Beyond that, we do not use any Google functions on our website.

LinkedIn

LinkedIn Ireland Unlimited Company Wilton Place, Dublin 2, Ireland

1. Operation of the LinkedIn company page 🌐 https://www.linkedin.com/company/makanal (and affiliated showcase pages) in joint responsibility based on 🌐 an agreement on joint processing of personal data (so-called Page Insights Joint Controller Addendum).
2. Information about Page Insights data: 🌐 https://legal.linkedin.com/pages-joint-controller-addendum
3. Privacy Policy: 🌐 https://www.linkedin.com/legal/privacy-policy
4. Manage retargeting settings on LinkedIn: 🌐 https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out

Twitter

Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07 Ireland

1. Operation of the Twitter handle 🌐 @makanaleu
2. Privacy Policy: 🌐 https://twitter.com/privacy
3. Opt-Out: 🌐 https://twitter.com/personalization

2. How We Use Your Information

a. To Communicate With You

We use the Account information you provide when signing up for our Services to send you transactional emails or in-app notifications regarding billing, account management, and other administrative matters. We may also send you updates about our Policies and communicate with you about security incidents via email or in-app notifications.

Customer support is provided using your information to address technical issues you encounter and analyze product outages or bugs.

For users of our mobile applications, we may send push notifications from time to time to update you about events and promotions. If you no longer wish to receive such communications, you may disable them in your device settings.

b. To Provide Our Services

We use your Account information and Customer Data to provide our Services to you. For instance, we use the email address you provide when signing up for Services to create your Account, and we use payment information to process payments for paid use of the Services in the form of a Subscription. We also use this information to authenticate you when you sign in and provide customer support.

c. To Improve and Develop Our Services

We collect usage data about how you or your Users interact with our Services. This data is used to develop and improve our Services. For instance, we use usage data to analyze trends and usage across the Services to help us determine what new features or integrations Users may be interested in.

We use Customer Data in an anonymized manner for machine learning that supports certain product features and functionality of the Services. For example, machine learning helps provide meaningful insights, such as suggested improvements to make common types of business processes more efficient. You may opt out of including your Customer Data for machine learning purposes by submitting a support request from your Account.

We may publish data about how our Services are being used across our customer base. When we share statistical information externally in this way, the data will be aggregated and we will not identify individual Users or Customers. For example, we may publish blog posts on trends or insights into how Users are interacting with our Services.

d. To Secure and Protect Our Services and Users

We use your Account information to investigate and help prevent security incidents, as well as to comply with legal requirements. We use this information to verify Accounts and to detect and prevent abuse of our Services, including enforcing our Acceptable Use Policy.

We use log files to provide general statistics regarding your use of the Services, including details about how you use our websites, your country of sign-in (for analytics, export control, and regulatory purposes), and to improve the navigation experience. Your IP address is also collected and logged for security and debugging purposes, tracking access patterns, and investigating security events and incidents.

For these purposes, we link this automatically collected data to other personal data provided by you, such as name, email address, physical address, and phone number.

e. To Market and Promote Our Services

We use the information you provide to promote the use of our Services to you and share promotional and informational content based on your communication preferences.

We may reach out to you via telephone to discuss other Services you may be interested in. If you have a call scheduled with one of our representatives, we may record and transcribe the call. You will be notified before the call that the call is being recorded, and you will be given an opportunity to opt out of having the call recorded.

We receive information from third-party service providers and other sources, such as third-party business information and publicly available sources. We may use this information from these service providers and other sources in combination with other information we collect through other means described in this Privacy Policy to provide you with updates and improvements to our Services, like personalized communications, event promotion, and tailoring our websites or Services to improve user experience.

f. Other Purposes With Your Consent

We share your data with third parties when you grant us consent to do so.

g. Legal Basis for Processing Personal Data (EEA and the UK Only)

If you are a website visitor located in the European Economic Area ("EEA") or the United Kingdom ("UK"), our legal basis for collecting and using the Personal Data described in this Privacy Policy will depend on the Personal Data concerned and the specific context in which we collect it. We will typically collect Personal Data from you only when we have your consent to do so, when we need the Personal Data to perform a contract with you, or when the processing is in our legitimate interests and not overridden by our data protection interests or your fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Data from you.

If we ask you to provide Personal Data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data). If we collect and use your Personal Data in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

3. How We Share Information We Collect

a. Third-Party Service Providers

We use third-party service providers to support our Services. For example, we use service providers for data hosting, application development, and marketing. We may need to share your information with these service providers to provide information about our Services to you. Examples include removing repetitive information from prospect lists, analyzing data or performing statistical analysis on your use of the Services or interactions on our websites, providing marketing assistance, processing bank card payments, supplementing the information you provide us to provide you with better service, developing and improving our Services, and providing customer service or support. These service providers are prohibited from using your Personal Data except for these purposes, and they are required to maintain the confidentiality of your information. In all cases where we share your information in this way, we explicitly require the third-party service providers to acknowledge and adhere to our privacy and data protection policies and standards.

b. Partners

We may share data with trusted partners to contact you based on your request to receive such communications, help us perform statistical analysis, or provide sales or customer support. Partners are prohibited from using your Personal Data except for these purposes, and they are required to maintain the confidentiality of your data.

c. Corporate Events

If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy, or otherwise, that company would receive all information gathered through our websites and Services. In this event, you will be notified via email and/or a prominent notice on our website of any change in ownership, uses of your Personal Data, and choices you may have regarding your Personal Data.

d. Public Forums

Our website may offer publicly accessible message boards, blogs, and community forums. Please be aware that if you disclose any information directly through these public forums (including profile information associated with the identity you use to post the information), it may be read, collected, and used by any member of the public who accesses our websites. Your posts and certain profile information may remain even after you terminate your Account. We encourage you to consider the sensitivity of any information you may disclose in this way. We will correct or delete any information you have posted on the websites if you so request, as described in the section "How to Access & Control Your Personal Data". In some cases, we may not be able to remove your information, in which case we will let you know if we are unable to and why.

e. Compelled Disclosure

We reserve the right to use or disclose your Personal Data if required by law or if we reasonably believe that such use or disclosure is necessary to protect our rights, ensure your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process. If you use our Services, Customer Data is considered Confidential Information, and you should review the confidentiality terms in our Terms of Service.

4. How We Transfer Data Internationally

a. International Transfers Between Affiliates

To facilitate our global operations, we may transfer information to our affiliates in different countries for the purposes described in this Privacy Policy. Please see the Data Processing Agreement for a list of affiliates and their locations. This Privacy Policy will apply even if we transfer Personal Data to other countries. We have taken appropriate safeguards to require that your Personal Data will remain protected wherever it is transferred. When we share Personal Data of individuals in the European Economic Area ("EEA"), Switzerland, or the United Kingdom ("UK") within and among our affiliates, we make use of the Standard Contractual Clauses (which have been approved by the European Commission) and the UK Addendum (as defined within our Data Processing Agreement) as well as additional safeguards where appropriate (such as commercial industry-standard secure encryption methods to protect customer data at rest and in transit, TLS for our websites, web application firewall protection, and other appropriate contractual and organizational measures). We also adhere to the EU-US and Swiss-US Privacy Shield Principles to help safeguard the transfer of information we collect from the EEA, Switzerland, and the UK.

b. International Transfers to Third Parties

Some of the third parties described in this Privacy Policy, which provide services to us under contract, are based in other countries that may not have equivalent privacy and data protection laws to the country in which you reside. When we share the Personal Data of individuals in the EEA, Switzerland, or the UK with third parties, we make use of a variety of legal mechanisms to safeguard the transfer including the European Commission-approved Standard Contractual Clauses, as well as additional safeguards where appropriate. For transfers to or from the UK, we make use of the UK Addendum.

c. Privacy Shield Notice

We and our affiliates comply with the EU-US Privacy Shield Framework and Swiss-US Privacy Shield Framework (collectively, "Privacy Shield Frameworks") regarding the collection, use, and retention of Personal Data of individuals in the European Union, Switzerland, and the UK. We are committed to subjecting all Personal Data received from European Union (EU) member countries, Switzerland, and the UK following the Privacy Shield Principles. Please note that we do not rely on the EU-US Privacy Shield as a data transfer mechanism. To learn more about the Privacy Shield Principles, visit the U.S. Department of Commerce's Privacy Shield List at https://www.privacyshield.gov.

5. How We Store and Secure Your Information

a. Data Storage and Security

Security is built into our Services from the ground up. Your information is encrypted while in transit and "at rest" while stored in world-class data centers on secure servers. We have physical, electronic, and managerial procedures to help safeguard, prevent unauthorized access, maintain data security, and correctly use your information. However, no people or security systems are foolproof, including encryption systems. Additionally, people can commit intentional crimes, make mistakes, or fail to follow policies. Therefore, while we use reasonable efforts to protect your personal information, we cannot guarantee its absolute security. If applicable law imposes any non-disclaimable duty to protect your personal information, you agree that intentional misconduct will be the standard used to measure our compliance with that duty.

b. Retention of Personal Data

The length of time we keep the information we collect about you depends on the type of information and how we collect and store it. We retain Personal Data that you provide to us as long as we have an ongoing legitimate business need to do so (for example, as needed to comply with our legal obligations, resolve disputes, and enforce our agreements). When we no longer have an ongoing legitimate business need to process your Personal Data, we securely delete the information or anonymize it, or if this is not possible, securely store your Personal Data and isolate it from any further processing until deletion is possible. We will delete this information at an earlier date if you so request, as described in the section "How to Access & Control Your Personal Data".

If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us or ceased using your Account. We retain information derived from cookies and other tracking technologies for a reasonable period from the time such information was created.

The data our Customers process in connection with our Services is retained according to our Terms of Service and Data Processing Agreement (DPA).

c. Processing E-mail Communications

We utilize a range of public and shared email mailboxes (e.g. service@makanal.eu ) to receive personal information (i.e. name, email address). Our employees or representatives will never request any individual to share personal or sensitive information via email, and we strongly advise against sending unsolicited personal or sensitive information via email.

All Makánal Tech email mailboxes are hosted by Microsoft within the European region where our corporate Microsoft tenant resides. As an additional security measure, we prevent all public and shared mailboxes from being added to the desktop or mobile versions of Outlook or other mail reader applications. Our employees and representatives can only access these mailboxes by signing into Microsoft 365 or HubSpot with their identity and two-factor authentication method (i.e. mobile device verification code, biometric confirmation).

d. Processing Voice and Video Communications

We use various tools to manage live voice and video communications, including phone, online, and video calls. Our service providers include Microsoft, HubSpot, and Sonetel. When you call us or receive a call from us (i.e. returning your calls) by phone, your call may be handled by HubSpot, Sonetel, or both depending on the geographical location. All calls are recorded to ensure we provide you with the highest level of service possible. Recordings are kept while your inquiry remains open and are deleted when no longer needed.

6. Cookies and Similar Technologies

a. Cookies

Upon visiting our websites, signing up for an Account, participating in a virtual event, or requesting further information about us or our Services, we automatically collect information through tracking technologies, such as cookies and tracking pixels.

We (and our partners) utilize cookies and similar technologies (such as web beacons and JavaScript) to analyze trends, operate our websites, track the navigation paths of Visitors, and collect demographic information about our Visitors and Customers as a whole.

For more information about how we use cookies on our website and how to manage your cookie preferences, please refer to our Cookie Policy.

b. Advertising

We collaborate with third-party ad networks to display advertisements on our website or manage our advertisements on other websites. Our ad network partners use cookies and web beacons to collect information about your activities on this and other websites to provide you with targeted advertising based on your interests. If you prefer not to have this information used to serve you targeted ads, you may opt out by utilizing these services:

🌐 https://optout.networkadvertising.org

🌐 https://optout.aboutads.info

🌐 http://www.youronlinechoices.eu/

c. Third-Party Tracking Technologies

The use of cookies and web beacons by any tracking utility company is not governed by our Privacy Policy or Cookie Policy.

7. How to Access & Control Your Personal Data

a. Reviewing, Correcting, and Removing Your Personal Data

You have the following data protection rights:

1. You can request access, correction, updates, or deletion of your Personal Data.
2. You can object to our processing of your Personal Data, ask us to restrict the processing of your Personal Data or request portability of your Personal Data.
3. If we have collected and processed your Personal Data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted before your withdrawal, nor will it affect the processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
4. You have the right to complain to a data protection authority about our collection and use of your Personal Data. Contact details for data protection authorities in the EEA are available 🌐 here.

To exercise any of these rights, please submit a support request from your Account or contact us at privacy@makanal.eu.

We will respond to your request to change, correct, or delete your data within a reasonable timeframe and notify you of the action we have taken.

If you are a Customer, or otherwise interact with a Customer that uses our Services and would like to access, correct, amend, or delete your data controlled by the Customer, please contact the relevant Customer directly. We act as a processor for our Customers and will work with our Customers to fulfil these requests when applicable.

b. Anti-Spam Policy

Our Acceptable Use Policy applies to both us and our Customers, and it includes provisions that prohibit the use of our Services to send unsolicited commercial e-mails in violation of applicable laws and require the inclusion of an "opt-out" mechanism and other necessary information in every e-mail sent using our Services. We mandate that all of our Customers commit to comply with the Acceptable Use Policy at all times. Any breaches of the Acceptable Use Policy by a Customer may result in immediate suspension or termination of the Account.

c. To Unsubscribe From Our Communications

You may unsubscribe from our marketing communications through one of the following methods:

1. by clicking the "unsubscribe" link located at the bottom of our e-mails;
2. updating your communication preferences from within your Account;
3. by contacting us at privacy@makanal.eu 

Customers cannot opt out of receiving transactional e-mails related to their Account or our Services.

d. To Unsubscribe From Our Customers' Communications

Our Customers bear sole responsibility for their e-mails and other communications. We cannot unsubscribe you from their communications. If you are a Customer or interact with a Customer, you can unsubscribe from the Customer's communications by clicking on the "unsubscribe" link at the bottom of their e-mails or by contacting them directly.

8. California Privacy Rights

a. Applicability

This section applies exclusively to California consumers. "Personal Information" holds the meaning given in the California Consumer Privacy Act ("CCPA"). It outlines how we collect, use, and share California consumers' Personal Information in our capacity as a business, and the rights associated with such residents. The CCPA obligates businesses to disclose whether they sell Personal Information.

We do not sell Personal Information.

We may share Personal Information with third parties if they are authorized service providers or business partners who have agreed to our contractual limitations regarding their retention, use, and disclosure of such Personal Information.

If you are unable to access this Privacy Policy due to a disability or any physical or mental impairment, please contact us, and we will arrange to provide you with the information you need in an alternative format that you can access.

b. How We Collect, Use, and Share Your Personal Information

We have collected the following statutory categories of Personal Information in the past twelve (12) months:

1. Identifiers, such as name, e-mail address, and phone number. We collect this information directly from you or third-party sources.
2. Commercial information, such as subscription records. We collect this information directly from you.
3. Internet or network information, such as browsing and search history. We collect this information directly from your device.
4. Geolocation data, such as IP address. We collect this information from your device.
5. Financial information, such as Payment Information or financial account numbers in the process of providing you with a Subscription. We collect this information from you.
6. Inferences.
7. Other Personal Information, when you interact with us online, by phone, or by mail in the context of receiving help through our help desks or other support channels; participation in customer surveys or contests; or in providing our Services.

The business and commercial purposes for which we collect this information are described in Section 2 of this Privacy Policy. The categories of third parties to whom we "disclose" this information for business purposes are described in Section 3 of this Privacy Policy.

c. Your California Rights

California residents have specific rights regarding the Personal Information we collect or maintain about them. However, please note that these rights are not absolute, and there may be instances when we decline your request as permitted by law.

1. The right of access means that you have the right to request that we disclose what Personal Information we have collected, used, and disclosed about you in the past 12 months.
2. The right of deletion means that you have the right to request that we delete Personal Information collected or maintained by us, subject to certain exceptions.
3. The right to non-discrimination means that you will not receive any discriminatory treatment when you exercise one of your privacy rights.

We do not sell Personal Information to third parties (under California Civil Code §§ 1798.100-1798.199, also known as the California Consumer Privacy Act of 2018).

d. How to Exercise Your California Rights

You can exercise your rights yourself or you can alternatively designate an authorized agent to exercise these rights on your behalf. Please note that to protect your Personal Information, we will verify your identity by a method appropriate to the type of request you are making. We may also request that your authorized agent has written permission from you to make requests on your behalf, and we may also need to verify your authorized agent's identity to protect your Personal Information.

Please use the contact details below if you would like to:

1. Access this policy in an alternate format;
2. Exercise your rights;
3. Learn more about your rights or our privacy practices; or
4. Designate an authorized agent to request on your behalf.

9. Data Protection Officer

If you have any questions about this Privacy Policy or our privacy practices, or if you have a disability and need to access this notice in a different format:

1. Submit a support request from your Account.
2. Contact us at privacy@makanal.eu

If you have concerns about data protection, you can also contact our Data Protection Officer:

Makánal Tech, Data Protection Officer, 1077 Budapest, Rózsa u. 38/A., Hungary

E-mail: hdavidson@makanal.eu 

10. Other Important Privacy Information

a. We Never Sell Personal Data

We will never sell your Personal Data to any third party.

b. Information About Children

Our Services, including our websites, are not intended for or targeted at children under 16, and we do not knowingly or intentionally collect Personal Data about children under 16. If you believe that we have collected Personal Data about a child under 16, please contact us at privacy@makanal.eu , so that we may delete the information.

c. Governing Law

This Privacy Policy is governed by the laws of Hungary without regard to its conflict of laws provision. You consent to the exclusive jurisdiction of the courts in connection with any action or dispute arising between the parties under or in connection with this Privacy Policy.

The laws of Hungary, excluding its conflicts of law rules, shall govern this Privacy Policy and your use of our Services. Your use of our Services may also be subject to other local, state, national, or international laws.