LinkySales – Privacy policy

1. GENERAL

1.1 This privacy policy (“Privacy Policy”) governs the processing of your personal data in connection with the use of our website or application (https://www.linkysales.com (the “Website”), URL APP. (the “Application”)). This processing is carried out by Doolead SRL (company number 0776.669.694) (“Company”, “we”, “us”, “our”) in compliance with the applicable data protection legislation otherwise referred to as RGPD.

1.2 By using the Website or the Application, you acknowledge that you have carefully read this Privacy Policy and accept it without reservation. We reserve the right to modify, change or amend the Privacy Policy at our discretion from time to time. Such modifications, changes or amendments will be communicated on the Website. By checking the box ‘I have read and agree to the Privacy Policy’, you declare that you have read and accept this Privacy Policy without reservation. You declare that you understand the purpose(s) for which your personal data are processed. You agree that by continuing to use the site, you maintain your consent. You may withdraw your consent at any time by sending an e-mail to [email protected]. Please note that as part of the website or application we may use cookies or similar technologies. Cookies are small text files stored on a device’s hard disk containing information and sometimes personal data. For further information on how we use cookies, please consult our Cookie Usage Policy.

1.3 By accepting this Privacy Policy you give your consent to LinkySales SPRL to rent or sell your data to its customers and partners in order to provide you with information, products and services related to their business(es).

1.4 This Privacy Policy was last updated on May 08/01/2019

2. WHAT DO WE TREAT AND WHY?

2.1 When using the website or our application, we process personal data about you. This personal data includes: your cell phone number, your zip code, your first and last name and your date of birth. This data may vary depending on the supplier with whom you have registered. See full table ([email protected])

2.2 In principle, we obtain the above-mentioned personal data directly from you when you register with a partner store. In addition to the above-mentioned purposes, we may process your personal data:

2.2.1 To provide you with the information, products and services you request via the website, e-mail, telephone or social media in an efficient and personalized manner. For direct marketing purposes, i.e. to be able to provide you with targeted communications, promotions, offers and other advertising from us or from our selected partners.

2.2.2 To carry out statistical analyses in order to improve our website or to develop new products and/or services.

2.2.3 To transfer them to the financial institution or payment service provider to enable them to meet their legal obligations.

2.2.4 To transfer them to the police or judicial authorities as evidence or if there are justified suspicions that you have committed an illegal act or offence by means of your use of the website.

2.2.5 To inform third parties in the context of a possible merger, acquisition of / by or demerger by a third party, even if this third party is located outside the EEA.

2.3 If and when your use of the website or our application may be considered (a) a violation of the terms or intellectual property rights or any other rights of any third party, (b) a threat to the security or integrity of the Services, (c) a danger to the website or any of our subcontractors’ underlying systems due to viruses, Trojan horses, spyware, malware or any other form of malicious code, or (d) hateful, obscene, discriminatory, racist, insulting, malicious, offensive, inappropriate or unlawful, we are entitled to process your personal data to protect our legitimate interests, those of our partners or third parties.

3. TO WHOM DO WE TRANSFER DATA?

3.1 We will only share your personal data with the following categories of recipients: all customers and subcontractors, mainly: Digital Ocean(storage), OVH, Google, Facebook, Spryng… We may use third-party subcontractors to provide you with the website or our application. We will ensure that third-party processors are only authorized to process your personal data on our behalf upon our written instruction. We guarantee that all third-party processors are selected with due care and that they are trained to be aware of the security and integrity of your personal data.

3.2 We may transfer anonymized and/or aggregated data to other organizations that may use it to improve products and services, as well as to customize the marketing, presentation and sale of these goods and services.

4. WHERE DO WE PROCESS?

4.1 We and our processors will process your personally identifiable data within the EEA. We may transfer your anonymised and/or aggregated data to organisations outside the EEA. If such a transfer takes place, we will ensure that appropriate safeguards are in place to ensure that you can benefit under applicable law.

5. HOW DO WE PROCESS DATA?

5.1 We will do everything in our power to process only the personal data necessary for the purposes listed in this Privacy Policy. We will process your personal data lawfully, fairly and transparently. We will do everything in our power to ensure that personal data is accurate and up-to-date.

5.2 Your personal data is only processed for the time necessary to achieve the purposes listed in this Privacy Policy or until you withdraw your consent to its processing. Please note that withdrawing your consent may result in you no longer being able to use all or part of the website or application.

5.3 We will take appropriate technical and organizational measures to prevent unauthorized access or theft as well as accidental loss, alteration or destruction of your personal data. Access by our staff or that of our third party subcontractor is only on a ‘need to know’ basis and in accordance with strict confidentiality obligations. You understand, however, that safety and security are best efforts obligations and can never be guaranteed.

6. YOUR RIGHTS

6.1 You have the right to request access to all your personal data processed by us. Abusive requests for access (maximum twice a year) which are submitted to us manifestly to cause us harm will not be processed.

6.2 You have the right to request, free of charge, the correction of any incorrect personal data concerning you. If you are registered for our application, you can correct most of this data yourself in your profile. If a request for correction is submitted, this request will be accompanied by proof of the inaccuracy of the data whose correction is requested.

6.3 You have the right to withdraw your consent to the processing of personal data. You may withdraw your consent at any time by sending an e-mail to [email protected].

6.4 You have the right to request that personal data concerning you be deleted if it is no longer necessary in the light of the purposes set out in this Privacy Policy or if you withdraw your consent to its processing. However, you should be aware that any request for deletion will be examined in the light of legal or regulatory obligations or administrative or judicial orders that may oppose deletion.

6.5 Instead of deletion, you may also request that we restrict the processing of your personal data if and when (a) you object to the processing of your personal data, or (b) you request that we restrict the processing of your personal data.

(b) the processing is unlawful or (c) the data is no longer necessary for the purposes listed, but you need it to defend yourself in legal proceedings.

6.6 You have the right to object to the processing of personal data if you can prove that there are serious and justified grounds for such objection based on specific circumstances. However, if the intended processing can be qualified as direct marketing, you have the right to object to such processing free of charge and without justification.

6.7 If you wish to submit a request to exercise one or more of the rights listed above, you may send an e-mail to [email protected]. This request must clearly indicate the right you wish to exercise and, if applicable, the reasons for the request. The request must also be dated and signed, and accompanied by a scanned copy of your valid identity card proving your identity.

6.8 We will inform you promptly of the receipt of your request. If the request is valid, we will honour it as quickly as possible and no later than thirty (30) days following receipt of the request.

6.9 If you have a complaint about our processing of your personal data, you can contact us at any time at [email protected]. If you are still not satisfied with our response, you are free to lodge a complaint with the competent data protection authority (e.g.: for Belgium, the Belgian Commission for the Protection of Privacy (privacycommission.be http://www.privacycommission.be/); for France, the CNIL (cnil.fr).

6.10 If your personal data is processed on the basis of consent or contract and the processing is carried out by automated means, you will have the right to receive your personal data, which you have provided to us, in a structured, commonly used, machine-readable and interoperable format and, if technically possible, you will have the right to transmit such data directly to another service provider.