Date Effective: January 1st, 2020
Thanks for choosing Linkfire!
At Linkfire, we want to give you the best possible experience to ensure that you enjoy our service today, tomorrow, and in the future. To do this we collect information to understand how our services are used, so we can deliver that exceptional and personalized service specifically for you. That said, your privacy and the security of your personal data is, and will always be, enormously important to us. So, we want to transparently explain how and why we gather, store, share and use your personal data – as well as outline the controls and choices you have around when and how you choose to share your personal data.
2. About this Policy
This Policy sets out the essential details relating to your personal data relationship with Linkfire ApS and subsidiaries. The Policy applies to all Linkfire Services and any associated services (referred to as the ‘Linkfire Services’). The terms governing your use of the Linkfire Services are defined in our Terms and Conditions of Use (the “Terms and Conditions of Use”).
From time to time, we may develop new or offer additional services. If the introduction of these new or additional services results in any change to the way we collect or process your personal data we will provide you with more information and additional terms or policies. Unless stated otherwise when we introduce these new or additional services, they will be subject to this Policy.
The aim of this Policy is to:
- Ensure that you understand what personal data we collect about you, the reasons why we collect and use it, and who we share it with;
- Explain the way we use the personal data that you share with us in order to give you a great experience when you are using the Linkfire Services; and
- Explain your rights and choices in relation to the personal data we collect and process about you and how we will protect your privacy.
We hope this helps you to understand our privacy commitments to you. For further clarification of the terms used in this Policy please visit our Privacy Center on linkfire.com. For information on how to contact us if you ever have any questions or concerns, please see the ‘How to Contact Us’ section.
3. Your rights and your preferences: Giving you choice and control
Linkfire has always believed in privacy and your right to know your digital footprint and we take great pride in being transparent about it. Accordingly, we have implemented transparency and access controls in our Privacy Portal to help users take advantage of those rights. As available and except as limited under applicable law, the rights afforded to individuals are:
- Right of Access – the right to be informed of and request access to the personal data we process about you;
- Right to Rectification – the right to request that we amend or update your personal data where it is inaccurate or incomplete;
- Right to Erasure – the right to request that we delete your personal data;
- Right to Restrict – the right to request that we temporarily or permanently stop processing all or some of your personal data;
- Right to Object –
- the right, at any time, to object to us processing your personal data where you believe we don’t have a legitimate interest to do so;
- the right to object to your personal data being processed for direct marketing purposes;
- Right to Data Portability – the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service; and
In order to enable you to exercise these rights with ease and to record your preferences in relation to how Linkfire uses your personal data, we provide you with access to the following settings via the following:
- Privacy Settings – allows you to control various categories of data collection; and
- Data Subject Request (DSR) form – allows you an easy route to access a copy of your data or to exercise your right to rectify, restrict, erase, and or port your data to another service.
The Privacy Settings put you in control of how Linkfire processes your personal data. If we send you electronic messages based on your consent or as otherwise permitted by applicable law, you may, at any time, respectively withdraw such consent or declare your objection (“opt-out”) at no cost. The electronic marketing messages you may receive from Linkfire (e.g. those sent via email) also will include an opt-out mechanism within the message itself (e.g. an unsubscribe link in the emails we send to you).
If you have any questions about your privacy, your rights, or how to exercise them, please contact our Data Protection Officer using the details laid out in the ‘Contact Us’ section in the Privacy Portal. We will respond to your request within a reasonable period of time upon verification of your identity where required. If you are unhappy with the way we are using your personal data you can also contact and are free to lodge a complaint with the Danish Data Protection Authority (Datatilsynet) or your local Data Protection Authority.
4. How do we collect your personal data?
We collect your personal data in the following ways:
- Through the use of the Linkfire Services – when you use the Linkfire Services, we collect personal data about your use of the Linkfire Services, such as what campaigns you have visited.
- When our customers onboard for the Linkfire Services (specifically the Linkfire Suite – https://app.linkfire.com & https://v1.linkfire.com) – when you are signed up to the Linkfire Services, we collect certain personal data so you can use the Linkfire Services.
- Personal data collected that enables us to provide you with additional features/functionality – from time to time, you may also provide us with additional personal data or give us your permission to collect additional personal data e.g. to provide you with more features or functionality.
We use anonymized and aggregated information for purposes that include testing our IT systems, research, data analysis, creating marketing and promotion models, improving the Linkfire Services, and developing new features and functionality within the Linkfire Services.
5. What personal data do we collect from you and why?
When you use or interact with the Linkfire Services, we use a variety of technologies to process the personal data we collect about you for various reasons. We have set out in the tables below the reasons why we process your personal data, the associated legal basis we rely upon to legally permit us to process your personal data, and the categories of personal data (identified in Section 5 ‘What personal data do we collect from you?’) used for these purposes:
We would like to take a moment to explain that we do not collect any special categories of personal data (https://gdpr-info.eu/art-9-gdpr/), nor do we process any personal information in a way that could pose a high risk to data subject’s rights or freedoms (https://gdpr-info.eu/recitals/no-75/).
Linkfire does not use any data for automated-decision making purposes.
- *.lnk.to & associated custom domains
5.2. Linkfire visitors:
5.3. Linkfire customers:
In order to provide customers with Linkfire services you may expect personal data processing under the following categories:
6. Sharing your personal data
We have set out the categories of recipients of the personal data collected or generated through your use of the Linkfire Services.
We rely on legitimate interest as our legal reasoning for sharing this data, aside from legal requirements like regulatory institutions or tax authorities.
7. Data retention and deletion
We keep your personal data only as long as necessary to provide you with the Linkfire Services and for legitimate and essential business purposes, such as maintaining the performance of the Linkfire Services, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes.
** Notification Contact Details: < 12 months = 1 month after release date + campaign duration (limited to 11 months prior to release)
7.2 Linkfire Customer
8. Cross Border Transfer
Linkfire complies with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use and retention when a customer and Linkfire have agreed by contract that transfers of personal information from the European Economic Area (“EEA”), the UK, and/or Switzerland will be transferred and processed pursuant to the Privacy Shield for the relevant services. When conducting those activities on behalf of its EEA, UK and/or Swiss customers, Linkfire holds and/or processes personal information provided by the EEA, UK, and/or Swiss customer at the direction of the customer. Linkfire will then be responsible for ensuring that third parties acting as an agent on their behalf do the same. Linkfire will also be responsible for ensuring that any third party receiving data from Linkfire adheres to the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks principles in regards to personal data.
With respect to personal information received or transferred pursuant to the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, Linkfire is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.
9. Dispute Resolution
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at this link: https://www.jamsadr.com/eu-us-privacy-shield or directly writing to Mediate@jamsconnect.com. Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
We may display advertisements from third parties and other content that links to third-party websites. We cannot control or be held responsible for third parties’ privacy practices and content. If you click on a third-party advertisement or link, please understand that you are leaving the Linkfire Service and any personal data you provide will not be covered by this Policy. Please read their privacy policies to find out how they collect and process your personal data.
11. Keeping your personal data safe
We are committed to protecting our users’ personal data. We implement appropriate technical and organizational measures to help protect the security of your personal data; however, please note that no system is ever completely secure. We have implemented various policies including anonymization, pseudonymization, encryption, access, and retention policies to guard against unauthorized access, unauthorized alterations or deletion, as well as unnecessary retention of personal data in our systems. Please visit our Technical and Operational Measures for more information.
Your password protects your Linkfire Suite user account, so we encourage you to use a unique and strong password, limit access to your computer and browser, and log out after having used the Linkfire Service (Suite).
The Linkfire Services is not directed to children under the age of 13 years. However, in some countries, stricter age limits may apply under local law. Please see our Terms and Conditions of Use for further details.
We do not knowingly collect personal data from children under 13 years or under the applicable age limit (the “Age Limit”). If you are under the Age Limit, please do not use the Linkfire Services, and do not provide any personal data to us.
If you are a parent of a child under the Age Limit and become aware that your child has provided personal data to Linkfire, please see the ‘How to Contact Us’ section, and you may request exercise of your applicable rights detailed in the ‘Your rights and your preferences: Giving you choice and control’ Section 3 of this Policy.
If we learn that we have collected the personal data of a child under the age of 13 years, we will take reasonable steps to delete the personal data.
13. California Consumer Privacy Act
If you are a California resident, the processing of certain personal data about you may be subject to the California Consumer Privacy Act (“CCPA”) and other applicable California state privacy laws. Please refer to our Additional California Privacy Disclosures.
We may occasionally make changes to this Policy.
When we make material changes to this Policy, we’ll provide you with prominent notice as appropriate under the circumstances, we may notify you in advance.
Please, therefore, make sure you read any such notice carefully.
15. How to contact us
Artillerivej 86, 3.,
2300 Copenhagen S, Denmark
CVR no. 35835431
We hope you enjoy Linkfire!
© Linkfire ApS.