MAKE DIVISION

Privacy Policy

Last updated: 2 August 2026

This Privacy Policy explains how Optimizuok MB (“we”, “us”, the “Company”) collects, uses and protects personal data when you visit makedivision.com (the “Site”) or purchase the AI Marketing Team System.

We are the data controller for the personal data described below.

1. Who we are

  • Company: Optimizuok MB
  • Registration code: 307019757
  • Registered address: Lauko g. 6-11, LT-99140 Šilutė, Lithuania
  • Email: tomas@makedivision.com

As a company established in Lithuania, we process personal data in accordance with the EU General Data Protection Regulation (GDPR) and the Lithuanian Law on Legal Protection of Personal Data.

2. What data we collect

Data you give us:

  • Purchase data — name, email address, billing address and country, and where applicable your VAT number, when you buy the product.
  • Correspondence — the content of emails you send us and any information you choose to include.

Data collected automatically:

  • Technical data — IP address, browser type and version, operating system, device type, referring page and timestamps, recorded by our web server in its normal operation.
  • Usage data — pages viewed, time on page and interactions, collected through analytics and advertising cookies where you have consented (see section 6).
  • Server-side event data — where you have consented to advertising cookies, we also send a copy of certain events (such as viewing the product page or completing a purchase) to Meta directly from our server through the Meta Conversions API. Where available, this includes your email address and name in an irreversibly hashed form, used only so that Meta can match the event to an existing Meta account. Browser and server copies of the same event share an identifier so that Meta can deduplicate them. No such data is sent before you consent.

We do not collect or store your card details. Card payments are processed by Stripe (see section 5).

We do not knowingly process special categories of personal data (such as health, biometric or political data), and we ask that you do not send such data to us.

3. Why we process your data, and on what legal basis

Purpose Legal basis (GDPR Art. 6)
To sell and deliver the product, provide access and handle refunds Performance of a contract (Art. 6(1)(b))
To respond to your support or general enquiries Performance of a contract, or our legitimate interest in answering you (Art. 6(1)(b) / (f))
To meet accounting, tax and VAT obligations Legal obligation (Art. 6(1)(c))
To keep the Site secure and prevent fraud or abuse Legitimate interests (Art. 6(1)(f))
To measure site usage and advertising performance via analytics and advertising cookies, including server-side event data Your consent (Art. 6(1)(a))
To record and retain proof of your cookie consent choices Legal obligation (Art. 6(1)(c))
To send transactional emails about your purchase Performance of a contract (Art. 6(1)(b))

We do not currently operate a marketing mailing list. If we introduce one, it will be based on your separate, freely given consent and you will be able to unsubscribe at any time.

4. Automated decision-making

We do not use your personal data for automated decision-making or profiling that produces legal or similarly significant effects on you.

5. Who we share data with

We never sell or rent your personal data. We share it only with service providers who process it on our behalf, under contract and only as needed:

  • Stripe — payment processing. You submit your card details directly to Stripe; we receive only confirmation of payment and limited billing information. See Stripe’s Privacy Policy.
  • Our hosting provider — stores the Site and its database on our instruction.
  • Google (Google Analytics 4 and Google Tag Manager) — site analytics, where you consent. Google Tag Manager loads on every visit but does not itself set cookies or collect personal data; it only decides which measurement tools may run, based on your consent choices. See Google’s Privacy Policy.
  • Meta Platforms (Meta Pixel and Meta Conversions API) — advertising measurement, where you consent. This covers both the pixel in your browser and the server-side copy described in section 2. See Meta’s Privacy Policy.
  • CookieYes (WebToffee) — our consent management platform. It displays the cookie banner, applies your choices across the Site and stores a record of the consent you gave, so that we can demonstrate compliance. See CookieYes’ Privacy Policy.
  • Professional advisers and authorities — our accountants, or public authorities where we are legally required to disclose data.

International transfers. Some of these providers are based outside the European Economic Area, including in the United States. Where data is transferred outside the EEA, it is protected by an adequacy decision of the European Commission and/or the European Commission’s Standard Contractual Clauses.

6. Cookies and consent

Cookies are small files stored on your device. We manage them through CookieYes, which shows a consent banner the first time you visit the Site.

Nothing beyond strictly necessary cookies is set until you choose. Analytics and advertising tools stay switched off, and no data is sent to Google or Meta, until you give consent. If you decline, they stay off.

We group cookies into the following categories:

  • Necessary — required to run the Site, keep your basket and checkout working, remember your consent choice and keep the Site secure. These are always active and do not require consent.
  • Functional — support optional conveniences such as remembering preferences.
  • Analytics — Google Analytics 4, to understand how the Site is used.
  • Performance — help us measure loading and responsiveness.
  • Advertisement — Meta Pixel and the Meta Conversions API, to measure the performance of our advertising.

How your choice is enforced. For Google services we use Google Consent Mode: until you consent, Google’s tags are told that analytics and advertising storage are denied, so no analytics cookies or identifiers are created. For Meta, our site holds both the browser pixel and the server-side Conversions API until you grant the Advertisement category; events that occur before your choice are held and are only sent if you consent, and discarded if you do not.

Changing or withdrawing consent. You may withdraw or change your consent at any time, and it is as easy to withdraw as it was to give. You can do this through the cookie settings on the Site, or by clearing the cookies for makedivision.com in your browser, which will make the banner appear again on your next visit. You may also email us at tomas@makedivision.com and we will action your request. Withdrawing consent does not affect processing that took place before you withdrew it.

Most browsers also let you refuse or delete cookies entirely — note that blocking strictly necessary cookies may stop parts of the Site, including checkout, from working.

7. How long we keep data

  • Order and invoicing records — 10 years, as required by Lithuanian accounting and tax law.
  • Customer account and product access data — for as long as your access remains active.
  • Email correspondence — normally up to 2 years after the matter is closed.
  • Server logs — normally up to 12 months.
  • Analytics and advertising data — according to the retention settings of the relevant provider, normally up to 14 months.
  • Cookie consent records — retained by CookieYes for up to 12 months from the date of your choice, as evidence that consent was given or refused.

8. Your rights

Under the GDPR you have the right to:

  • access the personal data we hold about you;
  • have inaccurate data corrected;
  • have your data erased, where the law allows;
  • restrict or object to our processing, including processing based on legitimate interests;
  • receive your data in a portable, machine-readable format;
  • withdraw consent at any time, without affecting processing carried out before withdrawal.

To exercise any of these rights, email tomas@makedivision.com. We will respond within one month.

If you believe we have handled your data unlawfully, you may lodge a complaint with the Lithuanian State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija), L. Sapiegos g. 17, Vilnius, vdai.lrv.lt, or with the supervisory authority in your country of residence.

9. Children

The Site and the product are intended for business users and are not directed at children. We do not knowingly collect personal data from anyone under 14. If you believe a child has provided us with personal data, contact us and we will delete it.

10. Security

We use appropriate technical and organisational measures to protect personal data, including encrypted connections (HTTPS), access controls and trusted processors. However, no transmission over the internet can be guaranteed to be completely secure, and any transmission is at your own risk.

11. Links to other sites

The Site may link to third-party websites. We are not responsible for their content or privacy practices. Please read their privacy policies before providing them with any personal data.

12. Changes to this policy

We may update this Privacy Policy from time to time. The revised version takes effect when published on this page, and the “last updated” date above will change. Please check this page periodically.

13. Contact

Questions about this policy or about how we handle your data:
Optimizuok MB
Email: tomas@makedivision.com