Privacy Policy

1. Introduction

This Privacy Policy, effective as of October 16, 2025, explains how Freenance ("we", "our", or "us") collects, uses, and protects your personal information when you use our financial management platform. We are committed to protecting your privacy and ensuring the security of your personal data in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR) and Polish data protection laws.

2. Definitions

• "User" — a natural person using the Freenance platform.
• "Controller" — Rafał Bajda conducting business activity under the name "Rafał Bajda".
• "Personal Data" — any information enabling the identification of a user within the meaning of GDPR.

3. Data Controller

Freenance is operated as a Polish sole proprietorship (Jednoosobowa Działalność Gospodarcza - JDG) by Rafał Bajda and is the data controller responsible for processing your personal data.

• Address: Przeworska 9b/62, 04-382 Warszawa, Poland
• Email: support@freenance.io

4. Personal Data We Collect

We collect the following categories of personal data:

• Personal identification data (name, email address, phone number)
• Financial data (account balances, transactions, investment portfolios)
• Technical data (IP address, device information, browser type)
• Usage data (how you interact with our platform, features used)

5. Purpose of Data Processing

We process your personal data for the following purposes:

• Providing and maintaining our financial management services
• Managing your user account and authentication
• Analyzing your financial data to provide insights and recommendations
• Communicating with you about our services and updates
• Complying with legal and regulatory requirements
• Preventing abuse, fraud, and ensuring service security

6. Legal Basis for Processing

We process your personal data based on the following legal grounds:

• Contract performance - to provide our services under the terms of service
• Consent - for marketing communications and optional features
• Legitimate interest - for service improvement and fraud prevention
• Legal obligation - to comply with financial regulations

7. Data Sharing and Third Parties

We may share your personal data with third parties in the following circumstances:

• Hosting Services: We use Railway for hosting and deployment of our services, and Cloudflare for content delivery and security. Your data is stored on servers located within the European Economic Area (EEA) or in regions with equivalent data protection standards, ensuring compliance with EU data protection requirements.
• Monitoring Services: We use Sentry for frontend error monitoring to ensure service quality and performance. This service helps us identify and resolve technical issues.
• Communication tools and customer support providers.
• Payment service providers – Stripe, only to the extent necessary for payment processing and subscriptions. Stripe may process data outside the European Economic Area (EEA). In such cases, appropriate safeguards are applied, including standard contractual clauses approved by the European Commission.
• Data Minimization: We only share the minimum amount of data necessary for these services to function properly. No sensitive financial data is shared with monitoring services.
• Legal Basis: Data sharing with these third parties is based on our legitimate interest in maintaining service quality and security, as well as contractual necessity for service provision.

8. Transfer of Data Outside EEA

We do not transfer personal data outside the European Economic Area (EEA). If this becomes necessary in the future, data transfer will only occur based on appropriate safeguards, such as standard contractual clauses approved by the European Commission.

9. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements. Financial data is typically retained for 7 years in accordance with financial regulations.

• Financial data: 7 years after termination of cooperation (in accordance with financial regulations).
• Account data: until account deletion by the user.
• Marketing data: until consent withdrawal.

10. Anonymized and Aggregated Data Usage

We may process your personal data to create anonymized and aggregated datasets that cannot be used to identify individual users. Such anonymized and aggregated data may be used for:

• Statistical analysis and service improvement - to understand general usage patterns and trends
• Research and development - to enhance our platform features and user experience
• Benchmarking and reporting - to provide industry insights and comparative analytics

Legal Basis: Processing of anonymized and aggregated data is based on our legitimate interest (Art. 6(1)(f) GDPR) in improving our services and understanding market trends. Once data is truly anonymized (irreversibly de-identified), it is no longer considered personal data under GDPR and may be used without additional consent.

No Individual Identification: We ensure that anonymized data cannot be used to identify, contact, or locate individual users. All personally identifiable information is removed or encrypted before aggregation.

11. Voluntary Nature of Data Provision

Providing personal data is voluntary, but necessary to create an account and use Freenance platform services. Failure to provide required data may prevent service provision. Where data processing is required by law (e.g., tax obligations), data provision is mandatory.

12. Your Rights

Under GDPR and Polish data protection laws, you have the following rights:

• Right of access - to obtain a copy of your personal data
• Right of rectification - to correct inaccurate personal data
• Right of erasure - to request deletion of your personal data
• Right of restriction - to limit how we process your data
• Right of data portability - to receive your data in a structured format
• Right of objection - to object to certain types of processing
• Right to withdraw consent - to withdraw your consent at any time where processing is based on consent

To exercise your rights, you can contact us at support@freenance.io.

10. Complaints to Supervisory Authority

You have the right to file a complaint with the supervisory authority – the President of the Personal Data Protection Office, ul. Stawki 2, 00-193 Warszawa, Poland, https://uodo.gov.pl.

14. Profiling and Automated Decision-Making

The Freenance platform may analyze user financial data to provide personalized insights and investment recommendations. However, we do not make decisions that have legal effects or similarly significantly affect the user, which would be based solely on automated data processing (profiling).

10. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. This includes encryption, secure servers, access controls, and regular security audits.

• Encryption - all data in transit and at rest is encrypted using industry-standard protocols
• Secure storage - data is stored on servers located within the European Economic Area (EEA)
• Access controls - strict access controls limit data access to authorized personnel only
• Security audits - regular security audits and penetration testing ensure ongoing protection
• Backup and recovery - encrypted backups are created regularly to prevent data loss

16. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience. For detailed information about our use of cookies, please see our Cookie Policy.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Last Updated" date.

18. Contact Information

If you have any questions about this Privacy Policy or our data practices, please contact us:

Email: support@freenance.io

Address: Rafał Bajda, Przeworska 9b/62, 04-382 Warszawa, Poland