MEETLIFY PRIVACY POLICY

DEFINITIONS
1. “MEETLIFY” or “We” – Meetlify spółka z ograniczoną odpowiedzialnością (a limited liability company incorporated under the laws of Poland) with its registered office in Kraków at the address: 27/1 Aleksandra Lubomirskiego Street, 31-509 Kraków, Poland, entered into the national court register by the District Court for Kraków-Śródmieście in Kraków, XI Commercial Division of the National Court Register under the national court register number (KRS): 0000768770, tax identification number (NIP): 6751694288, statistical number (REGON): 382425232, with share capital of 341,000.00 PLN paid in full;

2. the “App” – mobile application designed for facilitating event management, networking, contact exchange and precise location provided by MEETLIFY, to which this Privacy Policy applies;

3. the “Privacy Policy” – this document together with its annexes (if such shall be made from time to time);

4.GDPR” – Regulation of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (Data Protection Directive);

5. the “Customer” – a natural person or institution to whom MEETLIFY provides services regarding the use of the App under the separate agreement;

6. the “Customer Representative” – any person, who represents a Customer either based on a legal or factual relationship, in particular under a power of attorney;

7. the “User” – a natural person, including a Customer or a Customer Representative, who uses the App in particular to interact with other Users in relation to an event run by the Customer;

8. “Personal Data” – personal data as defined by GDPR;

9. the “Controller” – controller as defined by GDPR;

10. the “Data Processor” data processor as defined by GDPR;

11. the “Recipient” – recipient as defined by GDPR.

INTRODUCTION
1.
the App is a multifunctional mobile app developed and provided by Meetlify sp. z o.o. with its registered office in Kraków, which facilitates event management to the benefit of both Clients and Users by optimizing the results of business meetings.

2. As We take a special care about the privacy of users of our solutions, We would like to be transparent about how we maintain your privacy while you use the App.

3. This Privacy Policy outlines the rules for the processing of non-personal and Personal Data through the App. We want this Privacy Policy to allow you to better understand what information we collect, the reasons why we do so, and how you can manage your information while we process them.

4. This Privacy Policy specifically addresses the processing of Personal Data by MEETLIFY when acting as a Controller, in line with applicable data protection laws and regulations. As the Controller, MEETLIFY establishes the reasons and methodologies for processing Personal Data. We are fully committed to ensuring the safeguarding, confidentiality, and correct handling of the Personal Data under our care.

5. In certain instances where MEETLIFY may serve as a Data Processor, undertaking the processing of Personal Data on behalf of another party (Customer), such activities are not covered by this Privacy Policy. If you have questions or concerns about those specific processing activities, it is advisable to consult the privacy policy or corresponding documentation of our respective Customer, who acts as the Data Controller.

HOW TO CONTACT US
Via e-mail:
office@meetlify.com; or
Via mail: 27/1 Aleksandra Lubomirskiego Street, 31-509 Kraków

GENERAL INFORMATION
MEETLIFY is a Controller of Personal Data that it collects through the App for the purposes set out under the heading PURPOSES OF DATA COLLECTION below.

The App is intended for individuals who are at least 18 years old. MEETLIFE thereby does not allow any individuals who have not yet turned 18 to use the App.

PERSONAL DATA WE COLLECT
MEETLIFY collects the following Personal Data that may be provided by the User as part of the use of the functionalities of the App:

1. Users

A) name,

B) personal photo,

C) voluntary data: non personal or Personal Data you voluntarily provide through the App while using the application, in particular by completing section “just a few words about you” when you create your User profile in the App.

MEETLIFY does not allow you to share through the App any sensitive and/or private Personal Data either about yourself or any other individual, including but not limited to personal financial or healthcare information.

PURPOSES OF DATA COLLECTION:
MEETLIFY collects non-personal and Personal Data for the following purposes:

1. to provide services to Customers under the relevant agreements between MEETLIFY and Customers;

2. to operate, maintain and develop the App;to provide Customers and Users with support allowing for undisturbed use of the App;

3. to market services of MEETLIFY;

4. to establish, pursue, enforce or defense against claims.

THE METHODS OF DATA COLLECTION:
To the extent necessary for the purpose of the processing:

MEETLIFY collects non-personal and Personal Data of Customers or other Users, which they enter through the App’s user interface, in particular by completing section “just a few words about you” when they create their in-App profile.

Data collected from User may be disclosed subsequently through the App to other Users, subject to each User may decide which other Users they would like to interact with by choosing the option available at the App’s user interface to invite or to block the other User. Selecting the “block option” prevents further interactions between the block-taker and the recipient.
 
LEGAL BASISMEETLIFY
processes Personal Data collected through the App on the following legal grounds:

Customers:
1. To provide services to Customers under the relevant agreements between MEETLIFY and Customers – Article 6(1)(b) GDPR;

2. to operate, maintain and develop the App – Article 6(1) letters (b), (f) GDPR;

3. to provide Customer and Users with the support for the undisturbed use of the App – Article 6(1) letters (b), (f) GDPR;

4. to market services of MEETLIFY – Article 6(1) letters (a), (f) GDPR;

5. to establish, pursue, enforce or defence against claims – Article 6(1) letter (f) GDPR.

Other Users:
1. To provide services to Customers under the relevant agreements between MEETLIFY and Customers – Article 6(1) letters (a), (f) GDPR;

2. to operate, maintain and develop the App – Article 6(1) letter (a), (f) GDPR;

3. to provide Customer and Users with the support for the undisturbed use of the App – Article 6(1) letter (f) GDPR;

4. to market services of MEETLIFY – Article 6(1) letter (a) GDPR;

5. to establish, pursue, enforce or defence against claims – Article 6(1) letter (f) GDPR.

DATA RETENTION
MEETLIFE automatically delete your in-App profile after 24 hours from its creation. MEETLIFY, however, may retain your Personal Data for a longer period, if it is reasonably necessary to fulfill the purpose for its collection or to comply with the relevant legal obligations.

As a rule, such longer period of Personal Data retention cannot extend 3 years, unless otherwise required to pursue the relevant purpose for its collection. After that time, MEETLIFY will use adequate means to delete your Personal Data.

RECIPIENTS OF PERSONAL DATA
MEETLIFY does not disclose your Personal Data, except that to the extent necessary for the purpose of the processing, MEETLIFY may from time to time provide your Personal Data to the following Recipients:

1. Other Users;

2. Suppliers that process Personal Data on MEETLIFY’s behalf, such us entities operating IT systems and/or providing IT services;

3. Entities providing MEETLIFY with consulting, auditing or legal services,

4. Other entities to whom MEETLIFY is believed to disclose Personal Data to comply with the relevant law, to enforce its rights, or to protect the rights and safety of others, such as e.g., public authorities.

INTERNATIONAL DATA TRANSFER
MEETLIFY, as a rule, does not transfer Personal Data outside the European Economic Area (EEA).However, if Personal Data will be transferred outside the EEA, MEETLIFY will make all necessary efforts to ensure that such transfer complies with applicable regulations, including in particular those set forth in chapter V (Articles 44-49) of GDPR. If the Personal Data transfer is made to an entity from a third country as to which the European Commission has not yet issued a decision as referred to in Article 45 GDPR, such transfer may take place under so-called standard contractual clauses as referred to in Article 46 (2) letter c GDPR.

THE RIGHTS OF DATA SUBJECT
1. The right to withdraw consent – legal basis: Article 7 (3) GDPR:

A) Regarding Personal Data managed on the basis of your consent (Article 6 (1) letter a GDPR) – you have the right to withdraw your consent given to MEETLIFY at any time.

B) Withdrawal of consent has effect from the moment of withdrawal of consent and shall not affect the lawfulness of processing based on consent before its withdrawal.

C) Withdrawal of consent shall not entail any negative consequences to you, however may prevent you from further use of some functionalities of the App that requires consent.

2. Right to object to data processing – legal basis: Article 21 GDPR:

A) Regarding Personal Data managed on the basis of the legitimate interests pursued by the controller or by a third party (Article 6 (1) letter f GDPR) you have the right to object at any time – for reasons related to your particular situation – to the processing of your Personal Data.
B) If your objection proves to be justified and MEETLIFY has no other legal basis for the processing of Personal Data, your Personal Data to the processing of which you have objected will be deleted.

3. Right to erase (demand erasure) (“right to be forgotten”) – legal basis: Article 17 GDPR:

A) You have the right to request the deletion of either all or some of the Personal Data.

B) You have the right to request the deletion of Personal Data if:
- the Personal Data are no longer necessary for the purpose for which they were collected or otherwise processed;

- you withdrew a consent on which the processing is based, to the extent that Personal Data were processed on the basis of this consent;

- you objected to the processing pursuant to Article 21(1) GDPR and there are no overriding legitimate grounds for the processing, or you objected to the processing pursuant to Article 21(2)

- Personal Data have been processed unlawfully;

- Personal Data have to be erased for compliance with a legal obligation under Union law or the law of a Member State to which MEETLIFY is subject;

- Personal Data have been collected in relation to the offer of information society services referred to in Article 8(1) GDPR.

4. Right to restrict data processing – legal basis: Article 18 GDPR:

A) You have the right to request the restriction of the processing of your Personal Data.

B) You have the right to request the restriction of the use of Personal Data in the following cases:

- you contest the accuracy of your Personal Data – for a period enabling MEETLIFY to verify the accuracy of Personal Data;

- when the processing of data is unlawful, and you oppose the erasure of your Personal Data and request the restriction of their use instead;

- your Personal Data are no longer necessary for the purposes for which they were collected or used, but you require them to establish, exercise or defend against legal claims;

- you have objected to processing of your Personal Data pursuant to Article 21(1) – pending the verification whether the legitimate grounds of MEETLIFY override those of you.

C) Submitting a request may prevent you from using the specific functionalities of the App, which involve the processing of Personal Data covered by the request.

5. Right to access the data – legal basis: Article 15 GDPR:

A) You have the right to obtain from MEETLIFY confirmation whether Personal Data concerning you are being processed, and, where that is in the case, access to the Personal Data and the following information:

- the purpose of the processing;

- the categories of Personal Data concerned;

- the Recipients or categories of Recipient to whom the Personal Data have been or will be disclosed, in particular recipients in third countries or international organizations;

- where possible, the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria used to determine that period;

- the existence of the right to request from MEETLIFY rectification or erasure of Personal Data or restriction of processing of Personal Data concerning you or to object to such processing;

- the right to lodge a complaint with a supervisory authority;

- where the Personal Data are not collected from you, any available information as to its source;

- the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you;

- where Personal Data are transferred to a third country or to an international organization, you have the right to be informed of the appropriate safeguards pursuant to Article 46 GDPR relating to the transfer;

- a copy of the personal data undergoing processing

6. Right to rectification of data – legal basis: Article 16 GDPR:

A) You have the right to request from MEETLIFY without undue delay the rectification of inaccurate Personal Data concerning you. Considering the purposes of the processing, you have the right to have incomplete Personal Data completed, including by providing a supplementary statement.

7. Right to data portability – legal basis: Article 20 GDPR:

A) You have the right to receive your Personal Data, which you have provided to MEETLIFY, in a structured, commonly used and machine-readable format. You have the right to transmit such data – without hindrance from MEETLIFY – to another controller  to which the personal data have been provided, where:

- the processing is based on consent pursuant to point (a) of Article 6(1) GDPR or on a contract pursuant to point (b) of Article 6(1) GDPR; and

- the processing is carried out by automated means.

8. Except from the rights referred to in points 1-7 above, you have the right to lodge a complaint with the supervisory authority, which is the President of the Personal Data Protection Office (2 Stawki Street, 00-193 Warszawa), if you consider that the processing of your Personal Data relating infringes this GDPR.

9. If you submit a request regarding the rights referred to in points 1-7 above, MEETLIFY shall provide you with the information on action taken regarding this request without undue delay, but no later than within one month of the receipt of the request. That period may be extended by two further months when necessary, considering the complexity and number of the requests. MEETLIFY shall inform you of any such extension within one month of receipt of the request, together with the reasons for the delay. Where you make the request by electronic form means, the information shall be provided by electronic means where possible, unless otherwise requested by you.

FINAL PROVISIONS

10. To the extent not regulated by the Privacy Policy, the provisions of generally applicable law – in particular GDPR – shall apply.

11. MEETLIFY may change the Privacy Policy from time to time; therefore, We encourage you to review the Privacy Policy periodically. Any changes to the Privacy Policy are binding subject to their prior publication.

12. Publication of the last update: [_].