LINKD LTD
GDPR PRIVACY AND COOKIES POLICY
MAY 2018

Privacy policy

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information concerning who we are and how and why we collect, store, use and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event that you have a complaint.

Who is responsible for your data?

The websiteswww.thelinkdapp.com, www.linkd.co, www.linkdcard.co, www.linkdcard.comand www.linkd.uk,their mobile versions, and the mobile apps “LINKD” and “LINKDCARD” (together the “Sites”) are owned and operated by LINKD Ltd.

LINKD Ltd collects, uses and is responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

Our registered office is: 2 Azura Court, 48 Warton Road, London, E15 2JS.
We are registered as a company in England and Wales under company number 09403491.

Key terms

Below is an explanation of some key terms used in this policy:

We, us, ourLINKD Ltd 

Personal information - Any information relating to an identified or identifiable individual

Special category personal information - Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership, genetic and biometric data
data concerning health, sex life or sexual orientation
 
Personal information we may collect about you

Depending on how you use our services, we may collect and use the following
personal information about you:

Your name and contact information, including email address and telephone number 
When you fill in forms/create an account on the Sites. When you register to use the Sites
When you speak to us via telephone. When you report a problem with one or more of the Sites

Your online presence, including but not limited to your gender information, profile photo, email address, date of birth, education history, current city, current occupation, personal description, interests, and details of your connections on LinkedIn and friends on Facebook
When we view the publically available information on your Facebook and/or LinkedIn profile pages

Location data
Where this setting is activated on your desktop and/or mobile device

Information about your participation and actions on our platforms
When you are using our services provided through our Sites

Information you give to us for example: feedback, complaints or commentary on our Sites
When you contact us and/or respond to our requests for feedback

Information about how you use our website, IT, communication and other systems,  information about your interests, your computer and/or your mobile device, including, where available, your IP address, operating system and browser type
When you use our digital systems and services. When you accept our cookies placed on your device. When you open our marketing emails. When you click on our banner adverts. When you opt in to receiving messages from us

Your responses to surveys, competitions and promotions
When you participate in such activities
 
How and why we use your personal information

Under data protection law, we can only use your personal information if we have one or more of the following lawful reasons for doing so:

  • to comply with our legal and regulatory obligations;
  • for the performance of our contract with you or to take
    steps at your request before entering into a contract;
  • for our legitimate interests or those of a third party; or
  • where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.
In the table below, we have set out the different ways in which we use your personal data and the reasons we rely on for using that data.

What we use your personal information for

  • To provide services to you
  • To notify you about changes to our service;
  • To respond to complaints and seek to resolve them
  • To communicate with you and manage our relationship with you
  • To personalise and improve your customer experience
  • To provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you
  • Ensuring business policies are adhered to, for example, policies concerning security and internet use
  • Operational reasons, such as improving efficiency, troubleshooting, research, statistical, training and quality control purposes
  • Updating customer records
  • To obey laws and regulations which apply to us and the way we deliver our services

Our reasons

  • For the performance of our contract with you or to take steps at your request before entering into a contract.
  • For the performance of our contract with you or to take steps at your request before entering into a contract.
  • With your consent
  • For our legitimate interests or those of a third party:- 
  • keeping our records up to date, working out which of our products and services may interest you
  • identifying or defining types of customers for new products of services
  • For our legitimate interests or those of a third party:-
  • to make sure we are following our own internal procedures so that we can
    deliver the best service to you
  • For our legitimate interests or those of a third party:-
  • to be as efficient as we can so we can deliver the best service for you
  • to allow you to participate in interactive features of our service, when you choose to do so
  • for system administration and to report aggregate information to our advertisers
  • For the performance of our contract with you or to take steps at your request
    before entering into a contract

  • To comply with our legal and regulatory obligations

  • To comply with our legal and regulatory obligations

Special category personal information

Certain kinds of personal data, such as data about your racial or ethnic origin, your physical or mental health, your religious beliefs or alleged commission or conviction of criminal offences, are special categories of personal data which by law require additional protection. We try to limit the circumstances in which we collect sensitive personal data of this kind, but we do collect and process it when for example you disclose your personal attributes (including but not limited to your gender and religious beliefs),  when using certain LINKD Sites.

By providing any sensitive personal data, you explicitly agree that we may collect it and use it to provide services to you.

Cookies

In order to improve the Sites, we may use small files commonly known as “cookies”. A cookie is a small amount of data which often includes a unique identifier that is sent to your computer or mobile phone (referred to in this policy as a ‘device’) from the Sites and is stored on your device’s hard drive.

A cookie records on your device information relating to your internet activity (such as whether you have visited our website before). The cookies we use on the Sites won't collect personally identifiable information about you and we won't disclose information stored in cookies that we place on your device to third parties.
How can you control the use of cookies from our website?

If you don't want us to use cookies when you use the Sites, you can adjust your internet browser settings not to accept cookies. Your web browser's help function should tell you how to do this. Alternatively, you can find information about how to do this for all the commonly used internet browsers on the website: http://www.aboutcookies.org/default.aspx. This website will also explain how you can delete cookies which are already stored on your device.

Cookie | Purpose

fbm_ and fbsr_
These will be used to identify your Facebook account and coordinate with Facebook servers, once you have signed up with Facebook.

_ga and _gat
These cookies are used for Google analytics. This allows us to see anonymous information on the demographics of our users. We do not and cannot use this to identify any individual, but we will use this to track anonymous and aggregated data on the users of our Sites.

ci_session
This cookie is a session cookie that will let us see when you have logged in or out or the Sites. This cookie may be used to store information for us to recall the preferences you’ve set on the Sites, or for us to remember you the next time you sign into the Sites.

Promotional communications

We may send you marketing communications by email if you have indicated that you are happy to receive such. Our marketing communications include information about our new and existing services, special offers we think you might like and other travel services and products which we think might be useful to you.
 
Please note that if you ask us to stop sending marketing emails, we will keep a note of your personal information and your request so that we can make sure you are excluded from the emails when they are sent out.

You have the right to opt out of receiving promotional communications at any time by:
 
1.     contacting us – please see the “How to contact us” section below; or
2.     using the ‘unsubscribe’ link in emails

Who we share your personal information with

We routinely share personal information with:
·      companies within the LINKD Ltd group
·      third parties we use to help us run our business, e.g. website hosts;
·      third parties approved by you, e.g. social media sites you choose to link your account to
 
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information.
 
We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Where possible, personal information will be anonymised. The recipient of the information will be bound by confidentiality obligations.

Age of users on our platforms

Usage of our LINKD platform is reserved for users over the age of 18. We therefore do not knowingly collect any personally information from individuals under the age of 18 in respect of this platform. If we become aware that we have collected any personally identifiable Information from any individual under the age of 18, we will promptly take steps to delete such information and terminate that individual’s account.
In addition, usage of our LINKDCARD platform is reserved for users over the age of 13.
How long your personal information will be kept
We will keep your personal information while you have an account with us or we are providing servicesto you. Thereafter, we will keep your personal information for as long as is necessary:
 
·     to respond to any questions, complaints or claims made by you or on your behalf;
·     to show that we treated you fairly;
·     to keep records required by law.
 
We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

Storing your personal data

The data that we collect from you will be stored on our secure servers within the European Economic Area ("EEA").

Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Sites, you are responsible for keeping this password confidential. You should not share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Sites. Once we have received your information, we will use procedures and security features to try to prevent unauthorised access.

Transferring your personal information out of the EEA
We will only send data outside of the European Economic Area (‘EEA’) to work with our agents and advisers who we use to deliver services to you or to comply with a legal duty. If we do transfer data outside the EEA, we will make sure that it is protected in the same way as if it were being used in the EEA. We will use one of the following safeguards to ensure that it is protected:
·      Transfer the data to a non-EEA country which has privacy laws at least as protective as those within the EEA
·      Put in place a contract with the recipient of the data which means the recipient must protect the data to the same standards as required within the EEA, or
·      Transfer it to organisations which are part of the Privacy Shield. The Privacy Shield is a framework which sets out the standards for data to be sent between the United States and European countries. The Privacy Shield ensures that data is protected to the same standards as used within the EEA.
 
Your rights
You have the following rights, all of which you can exercise free of charge:

Access
The right to be provided with a copy of your personal information (the right of access)

Rectification
The right to require us to correct any mistakes in your personal information

To be forgotten
The right to require us to delete your personal information—in certain situations

Restriction of processing
The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data

Data portability
The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations

To object
The right to object:
—at any time to your personal information being processed for direct marketing (including profiling);
—in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.

Not to be subject to automated individual decision-making
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
 
If you would like to exercise any of those rights, please:
1.    Email, call or write to us - see below: ‘How to contact us’; and
2.    Let us have enough information to identify you (e.g. your full name and email address); and
3.    Let us know what right you want to exercise and the information which your request relates to.

How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.
 
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.

Changes to this privacy policy
This privacy notice was last updated on 22 May 2018.
 
We may change this privacy notice from time to time—when we do so we will inform you via our website or via email.

How to contact us
Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.
 
Our contact details are shown below:
Email address: team@linkd.co
Office Address: 2 Azura Court, 48 Warton Road, London, E15 2JS
Contact number: +44 7881 455 670