Table of Contents
1. INFORMATION WE COLLECT AND USE
Generally. We collect personal information from our users in order to provide you with a personalized, useful and efficient experience. The categories of information we collect can include:
Information you provide. We may collect and store personal information when you register for our Service, correspond with us online, or otherwise provide us your information, including your name, business or school name, email address, user name and password, and location. We may also collect any communications between you and us, as well as any information you provide if you take part in any interactive features of the Service. Once you begin using the Lingk Service, we will keep records of activities related to the Service. We use this information to operate, maintain and provide the features and functionality of the Service, to analyze our Service offerings and functionality and to communicate with our Customers and website visitors.
Customer Data. We also collect and store the Customer Data that you upload or otherwise make available on the Service. We access and use your Customer Data only for the purpose of providing the Services to our Customer or on our Customer’s behalf and for our own internal purposes, such as measuring, analyzing, improving and enhancing our Service offerings or enforcing our rights under the Terms. As stated in our Terms, we will re-direct all requests from third parties, including students and parents, to the applicable school or institution, but we may collect the personal information of such third party, only as necessary to effectively respond and re-direct the request. See “Sharing Information” below for more information on the limited ways in which we share Customer Data.
Information we may receive from third parties: We may receive information about you from third parties. For example, if you access our websites or Service through a third-party connection or log-in, for example, through Facebook or Google or GitHub, or by interacting with our brand on social media sites, that third party site will pass certain information about your use of its service to Lingk. This information could include, but is not limited to, the user ID associated with your third party account (for example, your Facebook UID), an access token necessary to access that service, any information that you have permitted the third party to share with us, and any information you have made public in connection with that service. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to the Service. You may also unlink your third party account from the Service by adjusting your settings on the third party service.
We automatically collect certain types of usage information when you visit our website or use our Service. When you visit the Service, we may send one or more cookies — a small text file containing a string of alphanumeric characters — to your computer that uniquely identifies your browser and lets us help you log in faster and enhance your navigation through the site. A cookie may also convey information to us about how you use the Service (e.g., the pages you view, the links you click, how frequently you access the Service, and other actions you take on the Service), and allow us to track your usage of the Service over time. We may collect log file information from your browser or mobile device each time you access the Service. Log file information may include anonymous information such as your web request, Internet Protocol (“IP”) address, browser type, information about your mobile device, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information. We may employ clear gifs (also known as web beacons) which are used to anonymously track the online usage patterns of our Users. In addition, we may also use clear gifs in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Service. We may also collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Service and to understand more about the demographics of our users. These tools collect information sent by your browser or mobile device, including the pages you visit, your use of third party applications, and other information that assists us in analyzing and improving the Service. Although we do our best to honor the privacy preferences of our visitors, we are not able to respond to Do Not Track signals from your browser at this time.
We use or may use the data collected through cookies, log file, device identifiers, location data and clear gifs information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide and monitor the effectiveness of our Service; (c) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website and our Service; (d) diagnose or fix technology problems; and (e) otherwise to plan for and enhance our Service. We do not allow third party advertising networks to use these types of technologies to collect information from users of our site or Service.
2. SHARING INFORMATION
We may share your personal information in the instances described below. For further information on your choices regarding your information, see the “Your Choices Regarding Your Information” section below.
We may share your personal information with:
Our affiliates and other companies owned by or under common ownership with Lingk, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies will use your personal information in the same way as we can under this Policy;
Third party vendors, consultants and other service providers that perform services on our behalf, in order to carry out their work for us, which may include content or service fulfillment, or providing analytics services. For avoidance of doubt, we will not share with third parties for the purposes of identifying and serving targeted advertisements;
Other parties in connection with any company transaction, such as a merger, sale of all or a portion of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party or in the event of bankruptcy or related or similar proceedings. In the event of such a transaction, Lingk shall not transfer personally identifiable Customer Data until it has provided Customers at least 30 days’ notice and an opportunity to opt-out of having the data transferred to the new party ; and
Law enforcement officials or third parties as required to (i) satisfy any applicable law, regulation, subpoena/court order, legal process or other government request, (ii) enforce our Terms, including the investigation of potential violations thereof, (iii) investigate and defend ourselves against any third party claims or allegations, (iv) protect against harm to the rights, property or safety of Lingk, its Users, any student or other persons’ privacy rights or the public as required or permitted by law and (v) detect, prevent or otherwise address criminal (including fraud or stalking), security or technical issues.
3. YOUR CHOICES REGARDING YOUR INFORMATION
Profile and Data Sharing Settings. You may change some of your data sharing preferences on your Account Settings page.
Marketing Communications. If you do not wish to receive promotional emails, you can change your email preferences on your Settings page on our websites, or you can click the “unsubscribe” button on promotional email communications. Note that you are not permitted to unsubscribe or opt-out of non-promotional messages regarding your account, such as account verification, donation confirmations, change or updates to features of the Service, or technical and security notices.
Data Retention: We will retain your information for as long as your account is active or as needed to provide you services. Please contact us at [email@example.com] if you wish to delete your account. Upon the termination of the Customer account, we will delete or anonymize Customer Data as disclosed in our Terms of Service.
4. SECURITY AND STORAGE OF INFORMATION
Lingk cares about the security of your information. While we use physical, administrative, and technological safeguards to preserve the integrity and security of all information we collect and share, no security system is impenetrable and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take all reasonable steps necessary to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
5. INTERNATIONAL DATA
Your Personal Information may be stored and processed by us in any country where we have facilities (e.g. the U.S.). It may therefore be processed outside of your country of residence, which may have different data protection rules to those of your country. Where we do so, our collection, storage and use of your Personal Information will at all times be in accordance with this Privacy Statement and applicable laws.
Specifically, we may transfer your Personal Information to Lingk, Inc. for processing in the U.S.
Does Lingk adhere to Privacy Shield?
We're committed to the Privacy Shield principles of notice, choice, accountability, security, data integrity and purpose limitation, access and recourse, and are certified by the U.S. Department of Commerce. Lingk’s Privacy Shield notice means that we are deemed to provide "adequate" privacy protection which is a requirement for the transfer of personal data under the General Data Protection Regulation (GDPR).
EU-U.S. Privacy Shield
When transferring any Personal Information from the EEA (including UK) to the U.S., we adhere to the EU-U.S. Privacy Shield Frameworks, as set forth by the U.S. Department of Commerce. Lingk Inc. has certified adherence to and commits to apply the Privacy Shield Principles to all Personal Information it processes in reliance on the Privacy Shield.
For the purposes of enforcing compliance with the Privacy Shield, we are subject to the investigatory and enforcement authority of the U.S. Federal Trade Commission.
For more information about the Privacy Shield, and to view our certification, see the U.S. Department of Commerce’s Privacy Shield website located at: https://www.privacyshield.gov
If we have received your Personal Information in the U.S. and subsequently transfer it to a third-party agent or service provider for processing, and such third party agent or service provider processes your Personal Information in a manner inconsistent with the Privacy Shield Principles, we remain responsible under the Privacy Shield unless we can prove we are not responsible for the event giving rise to the damage.
You can direct any questions or complaints about the use or disclosure of your Personal Information to us at firstname.lastname@example.org. We will investigate and resolve any complaints or disputes regarding the use of Personal Information within forty-five (45) days of receiving your complaint.
If you have an unresolved Privacy Shield complaint that we have not addressed satisfactorily, we commit to cooperate with the panel established by the EU data protection authorities (DPAs), as applicable, and to comply with the advice given by them in respect of the complaint. Click here for a list of EU DPAs.
You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances. To find out more about the Privacy Shield’s binding arbitration scheme please see https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
For information on how to request access, rectify or deletion of your Personal Information if it is inaccurate or processed in violation of the Privacy Shield, see “Questions or Concerns” below. Furthermore, we commit to giving you an opportunity to opt out if Personal Information we control about you is to be disclosed to any independent third parties, or is to be used for a materially different purpose from the purposes set out in this Privacy Statement. If you otherwise wish to limit the use or disclosure of your Personal Information, please write to us at the contact details further below.
6. PERSONS UNDER THE AGE OF 13
The Service and its content are not directed at children under the age of 13. In the event that we learn that we have collected personal information from a child under age 13 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any information collected from a child under 13 without requisite consent, please contact us at [email@example.com].
7. LINKS TO THIRD PARTY WEBSITES
The Services may contain links to and from third party websites of our business partners, advertisers, social media sites, and campaign sponsors and our users may post links to third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.
8. UPDATES TO THIS POLICY
9. CONTACTING US
If you have questions about this Policy, please contact us at [firstname.lastname@example.org] or by writing to us at:
4115 Blackhawk Plaza Circle, Suite 100
Danville, CA 94506
10. LAST REVISION DATE
This Policy was last revised on, and effective as of, Oct 4, 2018.