Privacy Policy

1. Why this policy?

Whenever you use the platform accessible in Saas mode on the linkioo.io domain or the mobile application named ‘LINKIOO’ (together the “Platform”) for the purpose of subscribing to our products and services and/or using the provided services as described in the general terms and conditions, we may collect personal data about you. Personal data is any data that can be used to identify an individual directly or indirectly. The purpose of this policy is to inform you about the means we use to collect and use your personal data, in strict compliance with your rights. In this respect, we inform you that we comply, in the collection and management of your personal data, with the General Data Protection Regulation No. 2016/679 of 27 April 2016 and any local applicable law on data protection.

2. Who process your data?

The person who makes the decision to collect and use your personal data is the company WELINX LTD, a private company limited by shares under the laws of England and Wales, registered under number 15606100 with the Registrar of Companies for England and Wale, whose head office is located at 71-75 Selton Street, Covent Garden, London WC2H 9JQ, United Kingdom (hereinafter “Us” or « We »).

3. Which data are processed?

For the proper performance of the services we offer, we collect the following data directly from you:

  • For the Manufacturer and its authorised users:
    • information enabling you to be identified for the provision of the Services (professional email address and pseudo);
    • IP address;
    • Connection dates and times to the Platform.
  • For the Clients who use the mobile application: information enabling you to be identified for the provision of the Services (pseudo).

4. Why do we process your data?

Your personal data is collected and used for one or more of the following purposes:

  • (i) To manage your access and subscription to the services;
  • (ii) To optimise the operation and effectiveness of our products and services and the analytical tools we have developed;
  • (iii) To compile statistics on the use of and visits to our services;
  • (iv) To manage any disputes or legal proceedings arising from the use of our products and services;
  • (v) Handle your requests about accessing and using the Platform, the products and services we provide or simply for the right of access, rectification and opposition, deletion, limitation, portability or the right to lodge a complaint with the competent authority;

When collecting your personal data, we inform you whether certain data is mandatory or optional. We also tell you what the possible consequences are of not answering. Finally, we would like to point out that we never use your data to make automated decisions about you.

5. How we justify the collection and use of your data?

We can only use your data if the law allows us to do so. In this context, the legislator has provided for six cases in which the use of data is justified (called "legal bases"). The use of your personal data is always based on one of these six legal grounds. With regard to purpose (i), your data is collected and used for the performance of the services we offer you and is strictly necessary for the provision of these services. The basis of the use is the performance of the contract between us. Your express consent to this collection is therefore not required. For purposes (ii) to (vi), the collection and use of your personal data is in the legitimate interest of our company and is not subject to obtaining your prior consent. With regard to purpose (v), your data is collected and used to meet our legal obligations. Your consent is not required for this processing. For any use of your data that is not covered by this policy, we will seek your consent to any new use of your data where this is necessary. If your consent is not required, we will nevertheless inform you prior to the implementation of this new processing.

6. To whom your data is communicated?

Your data will be communicated only to those members of our staff who need to access your data, as well as to our possible technical subcontractors (IT service providers, website host). They will have access to your data only to the extent necessary for the performance of their respective tasks. Furthermore, our possible subcontractors act solely on our instructions for the sole purpose of carrying out the tasks that we entrust to them.

In the event of a dispute, your data may also be communicated to court officers, judicial officers (bailiffs, clerks) or magistrates. All recipients undertake to ensure the strictest confidentiality of your personal data in their possession. We also inform you that your data is not transferred to third parties, subsidiaries or partners located outside the European Union.

7. How long your personal data is kept?

Your data will only be kept for as long as is strictly necessary for the purpose for which it was collected. In any case, your personal data will not be kept beyond this period.

  • (i) Data relating to the access to the Services (purpose (i))
    • For the manufacturer using the Saas platform: When you open an account on our Platform, your personal data will not be kept beyond the time strictly necessary to manage our relationship with you, i.e. at the latest the closure of your account. You are informed that data enabling proof of a right or a contract to be established, which must be kept, in our intermediate archive, in order to comply with a legal obligation, will be kept for the period provided for by the law in force, i.e. for five (5) years.
    • For the client using the mobile application: Your personal data will not be kept beyond the time strictly necessary to manage our relationship with you. We keep your data for a maximum period of three (3) years from the date of the last contact from you or the closure of your account on the Platform. At the end of this three (3) year period, we may contact you again to find out whether you wish to continue to receive information about our services. You are informed that data enabling proof of a right or a contract to be established, which must be kept, in our intermediate archive, in order to comply with a legal obligation, will be kept for the period provided for by the law in force, i.e. for two (2) more years at the three (3) year period mentioned above.
    • Moreover, you are informed that any financial transactions relating to the payment of financing operations and fees via the Platform are entrusted to a payment service provider, which ensures that they run smoothly and securely. For the purposes of the services, this payment service provider may receive personal data relating to your bank details, in particular your bank card, which it collects and stores in our name and on our behalf. We do not have access to this data. To enable you to pay our fees on the Platform, your bank card details are kept for the time of your registration on the Platform and, at the very least, until you carry out your last transaction. By ticking the box expressly provided for this purpose on the Platform, you give us your express consent to this storage. Data relating to the visual cryptogram or CVV2, recorded on your bank card, is not stored. If you refuse to allow your personal data relating to your bank card numbers to be stored under the conditions specified above, we will not store this data beyond the time required to complete the transaction. In any event, the data relating to these transactions may be kept, for the purposes of proof in the event of the transaction being disputed, in intermediate archives, for a period of thirteen (13) months following the debit date. This period may be extended to fifteen (15) months to consider the possibility of using deferred debit payment cards.
  • (ii) Data relating to the proper functioning and optimisation of our services (purposes (ii) to (iii)) Data collected for the purpose of improving our services and compiling statistics are kept for a maximum period of one year.
  • (iii) Data used in the context of a dispute or legal proceedings (purpose (iv)) Data used to serve any dispute or legal proceedings, that may arise between us regarding the performance of our license agreement or the products and/or services we provide, are kept for the entire duration of the proceeding in progress and until a final court decision has been handed down.
  • (iv) Requests relating to the use of the services or the exercise of your rights (purpose (v)) When you contact us to request our assistance in using the services, to report a problem or simply to exercise one of your rights specified below, your data is kept for the time necessary to process your request. Beyond that, we keep this data in our intermediate archive for an additional period of up to five(5) years, corresponding to the period during which legal action could be taken on the basis of the processing of your request.

8. Security

We inform you that we take all necessary precautions, as well as all appropriate organisational and technical measures to preserve the security, integrity and confidentiality of your personal data and, in particular, to prevent them from being distorted, damaged or accessed by unauthorised parties.

9. Where your data is hosted?

We inform you that your data are kept and stored for the duration of their retention on the company's servers, located in Germany.

10. How you can access the personal data we hold about you?

You have the right to access your personal data in order to obtain communication and, if necessary, rectification or deletion, by sending us a letter to:

  • Email address : [email protected]
  • Postal address : 71-75 Selton Street, Covent Garden, London WC2H 9JQ, United Kingdom

We also remind you that any person may, on legitimate grounds, request the restriction of the processing of data concerning him or her or object to such processing. We inform you that in the event of rectification or deletion of your personal data, as well as limitation of processing, carried out following a request from you, we will notify the persons to whom we have communicated your data of such changes, unless such communication proves impossible.

11. Portability of your personal data

You have a right to the portability of the personal data you have provided to us in the context of using our platform and/or our products and services. We remind you that this right does not apply to data collected and processed on a legal basis other than consent or the performance of the contract binding us, and in particular to data collected in our legitimate interest. This right can be exercised free of charge, at any time, in order to recover and retain your personal data. In this context, we will send you your personal data, by any means deemed useful, in an open standard format commonly used and readable by machine, in accordance with the state of the art.

12. Complaining to a supervisory authority

You are also informed that you have the right to lodge a complaint with the Commission Nationale Informatique et Libertés if you consider that the processing of your personal data, which is the subject of this policy, constitutes a violation of the applicable texts. This recourse may be exercised without prejudice to any other recourse before an administrative or judicial jurisdiction. Indeed, you also have the right to an effective administrative or judicial appeal if you consider that the processing of your personal data, which is the subject of this Charter, constitutes a violation of the applicable texts.

13. Communication regarding personal data breach

If we become aware of a security breach in the processing of your data that could result in a high risk to your rights and freedoms, we will inform you as soon as possible. At that time, we will detail the nature of the breach and the measures put in place to put an end to it.

14. Entry into force

This policy is entered into force the 13.06.2024