Last updated: June 2018
1. PERSONAL DATA COLLECTION
1.1. We collect personal data from you through your registration for and interaction with our products for the purposes described below. These purposes include providing our products, analyzing your use of our products, improving our products, and developing new products.
1.3. The personal data we collect from you depends on which of our products you use and the other interactions you have with us. This data may include:
- Device information and sign-on data (including device the ID)
- Name and contact information, if you have provided this to us. Personal data you provide us when registering for our products, including first and last name, email address, postal address, phone number, and similar information.
- Usernames and passwords you create to access and use our products.
- Demographic data. Your country of residence.
- Device and usage data. Personal data about your use of our products, including the activities you perform on your account, the Linkz webpages you visit, and the devices from which you access our products, including IP address and device identifier. This data may be obtained from your use of our software as integrated in third party products.
- Content you provide us through your use of our products. For example, images and audio content you upload to the Linkz Platform.
- Location data. Personal data about your device’s location, based on your device’s IP address.
- Other data you provide. Other personal data you provide us through use of our products, including messages, survey responses, and other feedback.
2. PERSONAL DATA USE
We use your personal data to provide products, operate our business, comply with our legal and contractual obligations, protect our systems and customers, and to fulfill our other legitimate interests.
- Provide our products. We use your personal data to operate our products and services.
- Improve our products and develop new products. We use your personal data to monitor and improve performance of our products and to develop new products. This may include our use of location-based product usage information to optimize delivery of our products and the performance of our products, and the use of error report information to diagnose and correct problems with our products.
- Provide customer support. We use your personal data to diagnose and correct problems with our products, including by responding to support requests and providing other support services.
- Provide promotional communications. We use your personal data to provide promotional communications. You can unsubscribe from these communications at any time by clicking the “unsubscribe” link in the footer of those communications.
- Negotiate and perform contracts. We use your personal data to negotiate contracts with you and to perform contracts we have entered with you.
- Transact commerce. We use your personal data to process commercial transactions you request to undertake with us.
- Comply with the law. We use your personal data to comply with our legal obligations.
3. PERSONAL DATA SHARING
We may share your personal data with our third party service providers. We may also share your personal data with third parties to exercise our legal rights and perform our legal obligations, and in other circumstances where you have granted us permission to share your personal data.
- Third parties for legal purposes. We may share your personal data as required by law or as necessary to exercise our legal rights. For example, we may share your personal data as required by law enforcement or in connection with legal proceedings, and transfer your data in connection with a sale, merger, transfer, or reorganization of our business or business assets.
- Permission. We may share your personal data in other circumstances where you have given us permission to do so.
4. WHERE WE PROCESS PERSONAL DATA
4.1. We may process your personal data in the United Kingdom and in any other country where we, or our service providers maintain facilities.
4.2. We may transfer personal data from the European Economic Area and Switzerland to other countries, some of which have been determined by the European Commission not to have an adequate level of data protection. To learn more about the European Commission’s decisions on the adequacy of the protection of personal data in non-European Union countries, please visit: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.
5. OUR RETENTION OF PERSONAL DATA
5.1 We retain your personal data as long as necessary to provide the products you have requested and to perform the contracts you have entered with us, to fulfill our legitimate interests, including to exercise our legal rights and to perform our legal obligations. Our need to retain personal data varies based on the type of data and the reasons we collected it, so our retention periods vary as well.
5.2. We use the following criteria to determine how long to retain personal data:
- Customer expectations. We retain personal data consistent your expectations concerning the performance of the products we provide you.
- Legitimate interests. We retain personal data to fulfill our legitimate interests.
- Third party contracts. Where our third party service providers use campaign data we may remove that data from our systems after a pre-determined period of time after it has been shared with them.
- Legal obligations. We retain personal data as required by data retention laws, to comply with government orders, and as necessary to meet preservation requirements in litigation. We also remove personal data if required to do so by law.
6. DATA SECURITY
The information we collect may be stored locally on your device and may be transmitted to our servers in the United States and/or European Union. We have implemented appropriate technical and organizational security measures pertaining to the storage and provision of personal data, in order to prevent access to your personal data by any unauthorized persons. However, the transmission of data over wireless and wired networks is not completely secure and, therefore, we do not guarantee and you should not expect that your personal information or private communications will always remain private.
Our products are intended to be used by adults. We do not intentionally or knowingly collect personal data from children and we ask that children not provide personal data to us.
10. CONTACT US
11. EUROPEAN ECONOMIC AREA AND SWITZERLAND RESIDENTS
If you are a resident of countries in the European Economic Area and Switzerland you have additional rights with respect to personal data. The following applies to residents of those countries with respect to whom we process personal data:
11.1. DATA CONTROLLER
Linkz IM Ltd
Tyrells End Farm, Tyrells End
Milton Keynes, MK17 9DS
11.2. PURPOSES AND LEGAL BASIS FOR DATA PROCESSING
The purposes for our processing of your personal data are described above.
The legal bases for our processing of your personal data are:
- With your consent. We process your personal data when you have provided us your consent to do so, consistent with the scope of that consent. Where you have provided us consent to process your personal data, you may withdraw that consent at any time.
- To fulfill a legitimate interest. We process your personal data to fulfill our legitimate interests.
- To enter or perform a contract. We process your personal data as necessary to enter into and to perform contracts we have entered into you.
- To comply with legal requirements. We process personal data as required by law.
Residents of countries in the European Economic Area and Switzerland have the following additional rights with respect to their personal data:
- Right to information. You have the right to be informed of what personal data about you we are processing and the rationale for that processing.
- Right of access. You have the right to request access to your personal data that we are processing.
- Right of rectification. You have the right to request that we correct your personal data that we are processing if you believe that data is not up to date or is not accurate.
- Right to withdraw consent. You have the right to withdraw your consent to our future processing of your personal data where our processing is based on your consent.
- Right to object. You have the right to object to our processing of your personal data.
- Right of erasure. You have the right to request that your personal data be deleted.
- Right to restrict. You have the right to request that we restrict our processing of your personal data.
- Right to data portability. You have the right to obtain a copy of your personal data in a structured and commonly used, machine-readable format where our automated processing of your personal data is based on your consent or based on a contract entered between us.
For residents of France, you have the right to send us specific instructions regarding the use of your data after your death. Please contact us at the email address above to provide instructions.