Privacy Policy

This policy explains how Communiq Network MB processes personal data in connection with the Communiq Network website and services (the “Services”). Communiq Network is an independent B2B deal-protection platform: a user registers a protected introduction, a counterparty sees an authorised preview, and the protected information is disclosed only after the applicable terms are accepted and payment requirements are satisfied. Relevant events are recorded in an evidence record.

The Services are intended for business users. This policy does not form part of any commercial agreement between users introduced through the platform.

Communiq Network MB is the controller for the personal data described here. Communiq Network is operated by Communiq Network MB, company code 307939093, registered at Žaliųjų Ežerų g. 13-65, LT-08407 Vilnius, Lithuania.

Registered address: Žaliųjų Ežerų g. 13-65, LT-08407 Vilnius, Lithuania. Company code: 307939093. Privacy contact: info@communiqnetwork.com.

Account and profile information. Name, email address, organisation, account identifiers and any profile details you provide.

Identity and business verification. Where verification applies, we process the verification status, the result and identifiers supplied by a verification provider, together with business information used to confirm that a provider and the underlying opportunity exist. Where identity documents are collected by a specialist verification provider, those documents are handled by that provider under its own arrangements; Communiq Network does not maintain a store of identity documents unless that is expressly stated at the point of collection.

Transaction and payment information. Transaction and deal identifiers, fee amounts, currency, payment and payout status, timestamps and identifiers returned by a payment provider. Card and bank credentials are entered with, and processed by, the payment provider. They do not pass through and are not stored by Communiq Network.

Deal and introduction information. The opportunity title and direction, the public preview, the protected information, buyer or supplier details, business contact and counterparty details, supporting documents, the applicable terms, acceptance records and disclosure records.

Evidence and audit information. Transaction identifier, verification status, terms version, acceptance timestamp, payment event, disclosure timestamp, a description of what was disclosed and integrity information such as content hashes.

Technical information. IP address, browser and device information, authentication events, security logs and system events.

Referral and campaign information. Where you arrive through a partner or campaign link, the referral and campaign parameters contained in that link.

Communications. Support requests and other correspondence with us.

A user may submit information relating to another individual — for example a buyer representative, supplier representative, business contact, counterparty or another person connected to a commercial introduction or opportunity.

If you submit such information, you are responsible for ensuring that you have a lawful basis or other legal authority to provide and disclose it through the Services. You must not submit information that you are prohibited from disclosing by law, by contract, by a confidentiality or professional obligation, or by any other applicable restriction.

We may process such information to:

• administer the protected transaction
• keep protected information restricted prior to authorised disclosure
• control authorised disclosure
• prevent fraud and abuse
• maintain transaction integrity
• generate evidence and audit records
• establish, exercise or defend legal claims where applicable

Where personal data has not been obtained directly from the individual concerned, the GDPR may require that the individual be informed, including under Article 14. That requirement is subject to the exemptions available under applicable law, for example where the individual already has the information, where providing it would be impossible or would involve disproportionate effort, or where disclosure is restricted by an obligation of professional secrecy. We assess this on the facts of the individual case. An individual who believes their information has been submitted to the platform may contact us at info@communiqnetwork.com.

• directly from you, when you use the website, create an account, register an introduction, accept terms, pay or contact us
• from another user, where they submit information concerning you as a counterparty or business contact
• from service providers, such as verification results or payment confirmations
• automatically, through technical and security logs generated when the Services are used

• to create and manage accounts and authenticate users
• to provide the Services and administer protected transactions
• to verify users, businesses and submitted information where applicable
• to create previews and keep protected information restricted
• to control access and record acceptance of the applicable terms
• to process payments and payouts and to perform authorised disclosure
• to generate and maintain evidence records
• to prevent fraud, abuse and unauthorised access, and to maintain security
• to provide support and maintain transaction integrity
• to comply with legal obligations, including accounting and tax requirements
• to establish, exercise or defend legal claims
• to maintain and improve the technical reliability of the Services
• to attribute a registration to a referral partner where you arrived through a partner link

Performance of a contract — processing necessary to provide the Services to you and to administer a transaction you take part in.

Legal obligation — accounting, tax and other statutory and regulatory requirements.

Legitimate interests — platform security, fraud and abuse prevention, transaction integrity, maintaining appropriate evidence, protecting legal rights and operating a reliable B2B service. We rely on this basis only where those interests are not overridden by the interests or fundamental rights of the individuals concerned.

Consent — where consent is legally required, in particular for optional cookies and similar technologies. Consent can be withdrawn at any time without affecting processing carried out before withdrawal. We do not rely on consent as the legal basis for processing that is necessary to provide the Services.

• Information you designate as protected is stored separately from the public preview.
• The receiving party initially receives only the authorised preview.
• Protected information remains restricted until the applicable transaction requirements — acceptance of the terms and satisfaction of the payment requirement — are met.
• Once those requirements are met, the protected information may be disclosed to the authorised receiving party.
• We record the events associated with the transaction and the disclosure in the evidence record.

After information has lawfully been disclosed to another business or user, that recipient independently decides how it subsequently uses that information and is therefore generally a separate controller for that subsequent processing. Communiq Network does not control processing carried out independently by a counterparty after disclosure.

We use a limited number of providers to operate the Services. Each is used for the purpose stated and receives only the data needed for that purpose.

• Lovable Cloud (backend platform built on Supabase) — application database and server-side storage. Used today for a limited set of form submissions; it will hold account, transaction, deal and evidence data once accounts and payments go live.
• Cloudflare — hosting, content delivery and edge execution of the website and its server functions: technical and connection data such as IP address and request metadata.
• No advertising, analytics or third-party tracking provider is used. The optional referral-tracking script previously used was removed in August 2026.
• Google Search Console — search-performance verification through a meta tag only; no visitor tracking script is embedded.
• Google Fonts — web fonts are requested from Google servers when a page loads, which discloses your IP address and browser request data to Google. No cookies are set by this request and no profile is built by us.

We may also disclose personal data to a counterparty as part of an authorised reveal, to professional advisers, and to public authorities or courts where required by law. We do not sell personal data and we do not use it for advertising.

Where a payment or verification step is carried out through a specialist provider, a distinction applies between (a) information processed by Communiq Network, such as transaction identifiers, status, amount and timestamps, and (b) information collected directly by that provider, such as card or bank credentials and identity documents. Information in category (b) is entered with the provider and does not pass through Communiq Network systems.

For regulated activities such as payment processing and identity verification, the provider generally acts as an independent controller for its own compliance obligations, and as our processor only for the parts of the service performed on our instructions. Where you are directed to such a provider, its own privacy terms apply to the information you give it directly.

Transaction support and disputes. If you contact us about a payment or transaction problem at support@communiqnetwork.com, we process the contact details you use, the deal and transaction identifiers you provide, our correspondence with you, any supporting material you choose to send, and the related transaction and evidence records already held by us. We do this to review and respond to your request (legitimate interests in operating the service and handling complaints) and, where relevant, to establish, exercise or defend legal claims. If a payment provider notifies us of a refund or payment dispute, we record the provider’s reference and the outcome against the relevant transaction. Please do not send card details, bank credentials or identity documents by email.

We aim to keep processing within the European Economic Area. Some providers, in particular hosting and content-delivery infrastructure, may process limited data outside the EEA. Where that happens, we rely on the transfer mechanisms available under the GDPR — an adequacy decision, Standard Contractual Clauses or another lawful safeguard — as applicable to the provider concerned. You can request further information about the mechanism relied on for a specific provider by contacting info@communiqnetwork.com.

We retain personal data according to the following criteria.

Account data — for the duration of the account relationship and for a limited period afterwards, where needed to handle queries, disputes or legal claims.

Transaction and evidence data — for as long as required to evidence the transaction and to meet accounting, tax and other legal obligations, and for as long as a related claim may be brought under the applicable limitation period. This category is generally retained longer than account data and is not deleted simply because an account is closed.

Protected deal content and documents — for as long as needed to operate and evidence the transaction; where the substance is no longer required, we prefer to retain an integrity reference such as a hash rather than a further copy of the content.

Security and technical logs — for a short period appropriate to security monitoring and fraud prevention.

Support communications — for the period needed to handle the matter and any follow-up, and thereafter where required for legal purposes.

Where a longer period is required by law, that period applies. Specific retention periods per category are set internally and may be requested at info@communiqnetwork.com.

We apply access controls and authentication, database-level access rules, encryption in transit, restricted internal access on a need-to-know basis, separation of protected information from public preview content, logging of relevant events and data minimisation. Protected deal content is not sent to analytics or advertising systems and is not intentionally included in error reports.

No service can guarantee absolute security. We do not claim that transmission or storage is entirely free of risk.

Subject to the conditions in applicable law, you have the right to:

• request access to your personal data
• request rectification of inaccurate or incomplete data
• request erasure
• request restriction of processing
• object to processing based on legitimate interests
• receive certain data in a portable format
• withdraw consent where processing is based on consent
• lodge a complaint with a supervisory authority

These rights are not absolute. In particular, we may be unable to delete transaction and evidence records on request where they must be retained for legal compliance, tax and accounting, fraud prevention, the establishment or defence of legal claims, or the integrity of the evidence function. Where we cannot satisfy a request in full, we will explain why.

To make a request, email info@communiqnetwork.com with a description of the request. We ask only for the information needed to identify you and locate the relevant records.

You may lodge a complaint with the Lithuanian supervisory authority, the State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija – VDAI), vdai.lrv.lt. You may also be entitled to complain to the supervisory authority of your EU/EEA country of residence or place of work, or where the alleged infringement occurred.

We use strictly necessary browser storage to operate the website and one optional third-party referral-tracking script, which is loaded only with your consent. Details of each technology, its purpose and its duration are in the Cookie Policy. You can change or withdraw your choice at any time through Cookie settings.

We do not make decisions producing legal effects concerning you, or similarly significantly affecting you, based solely on automated processing within the meaning of Article 22 of the GDPR. We do use routine automated checks for security, access control and fraud prevention — for example rate limiting and anomaly flags — which may restrict access to the Services. Such checks are subject to human review where they would materially affect a transaction.

Communiq Network is a business-to-business, professional service. It is not directed to children and we do not knowingly collect personal data from children. If you believe a child has provided personal data, contact info@communiqnetwork.com.

We may update this policy to reflect changes to the Services, our providers or legal requirements. The date at the top shows when it was last updated. Where a change is material, we will take reasonable steps to bring it to your attention and, where consent is required, ask for it again.

Communiq Network MB, Žaliųjų Ežerų g. 13-65, LT-08407 Vilnius, Lithuania. Privacy and data protection requests: info@communiqnetwork.com. General enquiries: support@communiqnetwork.com.