Privacy Policy

Last updated: September 2020

This privacy policy (the "Privacy Policy") governs how LINC S.A., a Limited Company of Luxembourg Law, established and headquartered 55, Rue de Luxembourg à L - 4391 Pontpierre and registered in the Register of Trade and Companies, Luxembourg, Section B, under the number 143207 ("THE SOCIETE") processes personal data collected under the website linc.lu and applications accessible or used through this site, including, if necessary, mobile applications associated with the site (the "Platform") in its capacity as the processing manager.

1. Compliance with data protection legislation

SOCIETE undertakes to do everything possible to comply with laws and regulations governing the handling of personal data, including, but not limited to, the European Parliament and Council Regulations (EU) 2016/679 on the protection of individuals with regard to the processing of personal data and on the free movement of personal data and any other applicable national law or regulation governing the handling of personal data.

2. Who are the people involved?

The Platform provides information on the services and products offered by SOCIETE and allows interested customers and prospects to contact SOCIETE via a contact form.

The persons concerned, i.e. the persons whose PERSONAL data is collected by SOCIETE, are visitors to the Platform who may be private, independent professionals or representatives (managers, employees, etc.) acting as a point of contact for legal entities (the "Users").

Users' personal data is subject to THE SOCIETE under the very responsibility of the Users who commit to pass them on to THE SOCIETE to have all the legal permissions to do so. The data will only be used by SOCIETE if it is necessary in connection with the provision by THE SOCIETE of its services.

3. What personal data is collected by SOCIETE and why is it used?

Contact information: Users' contact information corresponds to the user's email address. Disclosure of contact information is mandatory to allow the Company to contact users again following the submission of their contact form. They will be used by THE SOCIETE to respond to user requests and can be used to send Marketing Communications (see for more details point 4. below).

Content of Users' messages submitted within a form accessible on the Platform or through any other chosen mode of communication: Users can contact THE SOCIETE through various means, including through Social Networks, to request additional information, solve a problem encountered, participate in a contest game or issue a claim for example. THE SOCIETE will process this data to enable it to respond to requests from Users.

Content and metadata: These elements correspond to the operations performed on the platform, i.e. the data streams generated by user activity. In principle, this data is not used by THE SOCIETE, whose Platform is simply the medium for the exchange of this data. THE SOCIETE, however, reserves the right to use this data to personalize the customer's browsing experience and Marketing Communications.

Technical information: This technical information corresponds to the type of browser, language settings, country and time zone, cookie ID and settings, type of device used for connection, hardware model and operating system, unique identifiers such as IDFA (for iOS), MAC address or user ID, IP addresses and mobile network information, social network sharing, geolocation data. THE SOCIETE never uses the precise GPS location of the User's device except after receiving explicit consent. This data is used to ensure optimal use of the Platform and customize the Platform to each User (by adapting the language by which the Platform is displayed, for example, or by offering the Platform in a mobile version if the connection came from a mobile phone).

Some of this data is required for SOCIETE to provide its services. These will always be identified in a specific way within the forms for submitting this data. Subject to contrary provisions in this Privacy Policy, this data is processed on the basis of the performance of the contract with SOCIETE. Other data are provided by Users if they deem it appropriate and will only be used by THE SOCIETE if they are necessary in relation to the purposes outlined in this Privacy Policy and if THE SOCIETE has a valid legal basis: either on the basis of its legitimate interests or on the basis of the explicit consent of the user concerned according to the terms specified in this Privacy Policy.

Any other data collected in the context of Social Networks and advertising campaigns, as explained below, is based on THE legitimate interest of LA SOCIETE in using it for marketing and enhancement of its advertising materials as well as its image based on voluntary information transmitted or published by users.

4. Communications Marketing

THE SOCIETE may send informative and commercial emails (the "Marketing Communications") to people whose electronic contact information it obtained by providing its services through the Platform when the User concerned has not objected to such use when collecting his email address. Marketing Communications is intended to provide users with marketing offers, information on new products, special offers or on events organized by THE SOCIETE.

The User concerned has the option to object to such use of his email address, free of charge and in a simple way, by clicking on the opt-out link within each email sent in this context.

If the User objects to receiving all Marketing Communications, he will not receive any as soon as he has expressed his opposition through one of the identity channels in the previous paragraph and his contact information will be removed from the ESTABLISHed LA SOCIETE database for Marketing Communications within 90 days from that time.

These treatments are based on the legitimate interest of LA SOCIETE to inform about its activity, to value its Professional partners vis-à-vis Customers and thus promote its image vis-à-vis Users.

5. Using Social Networks

Users' personal data collected as part of the use of social networks (the "Social Networks") may be processed by THE SOCIETE.

THE SOCIETE is present on various Social Networks and can intervene as a joint treatment manager with them for certain treatments including when the logo of the social network used appears on the Platform. All related information can be found directly on the website of the Social Networks concerned.

For more information on the processing of personal data on different Social Networks, Users can check out the following information instructions:

* Facebook

* Instagram

*Twitter

Other Social Networks may also be added at any time by THE SOCIETE.

6. Advertising campaigns

THE SOCIETE also carries out advertising campaigns using the services of Facebook and Google.
Users can change their privacy settings on the pages of these providers by clicking on the following links:

7. Using cookies

THE SOCIETE also uses "cookies" to make the Platform easier to use and to better customize the Platform and its services to the interests and needs of Users. Cookies can also be used to enhance users' future activities and experience on the Platform as well as for advertising purposes.

THE SOCIETE also uses cookies to compile global and anonymous statistics to understand users' use of the Platform and improve its structure and content.

Some cookies do not require the consent of Users because they are purely technical and their use is in the legitimate interests of THE SOCIETE. For others, THE SOCIETE collects the consent of users before collecting personal data about them via cookies.

Some cookies allow us to establish statistics on how Users use the Platform. These statistics can be passed on to Professionals once anonymized regarding their own page on the Platform to the exclusion of any other data. THE SOCIETE alone determines the purpose of these statistics and their content.

For more information, including how long cookies will last, Users can view THE SOCIETE's cookie management policy by clicking on the following link https://www.linc.lu/cookies

8. Sharing personal data

THE SOCIETE can share users' personal data:

To its subcontractors, which are companies of the group to which SOCIETE belongs, within the limits of outsourced services and as long as this is necessary in light of the purposes set out in point 3. above (e.g. IT service providers, accounting providers, marketing and advertising partners, etc.) and their subsequent subcontractors;

With third-party companies providing services on the Platform, for example: online payment service providers or fraud detection services, etc.
SOCIETE may also disclose Users' personal data if it deems this disclosure necessary to comply with the law, enforce the terms and conditions of the use of its websites, or protect its rights, property or security, or those of others.

9. Data retention

SOCIETE takes all reasonable steps to ensure that personal data is processed and retained for the minimum period necessary for the purposes of this Privacy Policy.
Unless a more specific provision is indicated to Users (cookies, game or Communications Marketing), the general principle applied by THE SOCIETE is to keep users' personal data:

For all Users: Backups are kept for four (4) weeks.

THE SOCIETE undertakes to delete or anonymize users' personal data at the end of the retention period described above, increased by a few days if necessary to ensure the deletion or anonymization of the relevant data in practice, unless a compelling reason arises (for example in the context of litigation).

10. Data security and data transfer

SOCIETE implements appropriate security measures for data collection, storage and processing to protect against unauthorized access, falsification, disclosure or destruction of personal identification data.

Users are responsible for ensuring that all personal data they send to SOCIETE is safe.

THE SOCIETE does not transfer personal data outside the European Economic Area or to an international organisation outside the use of Social Networks (including cookies placed by Social Networks in connection with their use) and the conduct of advertising campaigns according to the above terms.

In this context, users' personal data could be transferred to the United States. Prior to 16 July 2020, these transfers were based on a European Commission (PrivacyPrivacy Shield)adequacydecision. Since and pending work at the European Data Protection Committee, Facebook and Twitter would transfer users' personal data on the basis of standard contractual clauses and the need for such transfers to provide their services (Article 49, 1. (b) the European Parliament and Council Regulations (EU) 2016/679 on the protection of individuals in relation to the processing of personal data and the free movement of personal data, and repealing Directive 95/46/EC (General Data Protection Regulation)). THE SOCIETE notes that a complaint is being considered by the data protection authorities concerning Facebook and Google and is closely monitoring developments in this area.

THE SOCIETE will keep its users informed and adapt its operation following the position taken by the supervisory authorities.

11. Data management and minimisation

THE SOCIETE takes reasonable steps to:
Ensure that Users' personal data is accurate and, if necessary, updated by allowing Users to change data that would be inaccurate at any time;
Ensure that Users' personal data is collected based on the needs set out in this Privacy Policy.

12. Human rights

Each User benefits under applicable legislation regarding the protection of personal data, a right of access, modification, limitation and opposition to the processing of his personal data, a right to delete and a right to portability of his personal data by sending an email to privacy@linc.lu . These rights can only be exercised within the limits of any contractual or legal obligation.

Each User also has the right to file a complaint with the Luxembourg supervisory authority, namely the National Data Protection Commission (https://cnpd.public.lu/fr.html). Where the processing of the User's personal data is based on consent, the User concerned has the right to withdraw his consent at any time, without impairing the legality of the treatment based on consent made before the withdrawal of the user; Users are encouraged to contact THE SOCIETE in advance to find a practical solution to the problem.

13. Learning about this Privacy Policy

By using the Platform, Users acknowledge that they have read the terms of this Privacy Policy.

14. Changes to this Privacy Policy

SOCIETE reserves the right to update this Privacy Policy at any time.

THE SOCIETE will revise the last update date at the bottom of this page.

SOCIETE encourages Users to check frequently for changes to this page and will send Electronic Communication to Subscriber Users or will notify Users through embedded platform information ("pop-up") when changes to this Privacy Policy are over.

Users recognize and agree that it is their responsibility to regularly review this Privacy Policy and to inquire about changes.

The continued use of the Platform following the publication of changes to this Privacy Policy will be worth accepting of these changes.