- “LINKPIN“, “our“, “us” or “we” means LINKPIN International, Inc., including its global subsidiaries and affiliated companies
- “LINKPIN products” includes all LINKPIN, branded apps, products and services; and
If you are in the European Economic Area (“EEA“), for the purposes of the EU General Data Protection Regulation 2016/679 (“GDPR“), the data controller is LINKPIN Limited of Shipton Way, Express Park, Rushden, Northants, NN10 6GL, UK.
Personal Information. This means any information that (either in isolation or in combination with other information) can be used to identify you directly or indirectly. Some examples of Personal Information include your name, address, email address, phone number, any ID number or location data.
Aggregated Information. Information may be aggregated and/or anonymized. When information is aggregated, it is combined with information about other customers and users. Aggregated information that includes Personal Information is considered Personal Information until it has been anonymized.
Anonymized Information. When information is anonymized, Personal Information is removed from collected data and the remaining portion of the data is repurposed for internal or external use, such as, for example, to determine how many users of a particular router include an Internet-enabled television in a home network environment, or how many users viewed a particular website video or advertisement. Such information cannot be used to identify you. Some examples include usage data relating to LINKPIN websites and LINKPIN products, language preferences and LINKPIN website page views.
In general, usage data collected when you visit LINKPIN websites or use LINKPIN products is both aggregated and anonymized so it does not identify you personally and therefore is not Personal Information.
How We Collect Information
We collect and process the following data about you:
Information you give us. If you fill in forms on LINKPIN websites or correspond with us by phone, email or otherwise, you may be providing us with information about you, which may include Personal Information. This includes information you provide when you register on LINKPIN websites, register or return a LINKPIN Product, subscribe to any of our services, search for a product, place an order on LINKPIN websites, participate in discussion forums or other social media functions on LINKPIN websites, enter a competition, promotion or survey, participate in a training session or other event, download firmware, software and apps, or when you report a problem with LINKPIN websites or LINKPIN products or otherwise request support. Personal Information you give us may include your name, address, email address, phone number and other contact information, financial and credit card information and any other information that can be used to personally identify you.
Information we collect about you. We automatically collect information when you use LINKPIN websites or LINKPIN products, including:
- technical information, including the Internet protocol (“IP“) address used to connect your computer or other device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform and language preferences. This information is all normally provided by your web browser, and we do not specifically request it;
- information about your visit to LINKPIN websites, including the full Uniform Resource Locators (“URL“) clickstream to, through and from LINKPIN websites (including date and time); products you viewed or searched for; page response times; download errors; length of visits to certain pages; videos watched; page interaction information (such as scrolling, clicks, and mouse-overs); and methods used to browse away from the page;
- any phone number or email address used to contact customer support;
- usage data about how and when you use LINKPIN products, other devices that are connected to LINKPINproducts and what features of LINKPIN products you use;
- technical information and data gathered when your LINKPIN products are connected to the Internet, such as how many and which devices are connected to your home network, when you use the devices and the amount of network traffic generated. We also collect environmental data when you use certain LINKPIN products, such as utility settings, temperature and light readings in the home, motion detection and alarm events; and
- if you consent, certain apps collect information about your location. If you do not want this information collected, do not consent, or consult your device manual for instructions on how to change location settings.
Information we receive from other sources We work closely with third parties who provide services to us (including, for example, business partners, subcontractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and we may receive information about you from them.
How We Use Information
We use the information we collect for a number of purposes. These purposes will be consistent with the reason you provided the information to us or for a directly related purpose. The uses we make of such information are to:
- set up an account for you on LINKPIN websites or LINKPIN products;
- facilitate your purchase and/or download of LINKPIN products;
- authenticate use of your account or purchases and/or use of a LINKPIN Product;
- register your LINKPIN Product in our product database;
- carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- assist you with customer support;
- provide the LINKPIN products you request;
- provide you with information about the LINKPIN products you use, such as new features, bug fixes, service downtimes or upgrades;
- help us develop new LINKPIN products and improve current LINKPIN products;
- provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. We (or selected third parties) will contact you by electronic means only if you have opted-in to receive marketing information. “Opt-in” means that you have taken an affirmative action to receive information, such as by checking a box or clicking a button;
- notify you about changes to LINKPIN websites and LINKPIN products and changes to our terms, conditions and policies;
- administer LINKPIN websites and LINKPIN products for internal operational purposes, including troubleshooting, data and statistical analysis, testing, research and survey purposes;
- improve LINKPIN websites and LINKPIN products and to ensure that content is presented in the most effective manner for you and for your computer or device;
- ensure the security of LINKPIN websites and LINKPIN products;
- monitor and regulate interactive features of LINKPIN websites and LINKPIN products that you choose to participate in, including online forums and chat rooms relating to LINKPIN products;
- help you navigate LINKPIN websites;
- help you access and use certain features of LINKPIN products remotely and to help you monitor and safeguard your home and home network;
- provide you with information and recommendations about Internet and utility usage in your home;
- measure or understand the effectiveness of advertising we serve to you and others who visit LINKPIN websites and to deliver relevant personalized advertising to you and others; and
- determine which aspects of LINKPIN websites and LINKPIN products are most useful to you and other users of LINKPIN websites and LINKPIN products.
Why We Use Information
We also use your Personal Information to protect our business (for example, against fraud), or to comply with legal requirements to which we are subject (for example, tax or financial reporting requirements).
We will always seek your consent before we send you any direct marketing communications
Under no circumstances do we rent or sell your Personal Information to third parties for marketing purposes. We only share your Personal Information with third parties for marketing purposes if you have granted us permission to do so, and in accordance with the?Marketing?section below. We share Personal Information in the following ways:
- within LINKPIN for purposes of data processing or storage;
- withbusinesspartners,servicevendors,authorizedthird-partyagentsorcontractorstoprovidearequested service or transaction, including processing orders, hosting websites, storing your information, providing email communications on our behalf and providing customer support. For example, when making purchases on the LINKPIN website stores, LINKPIN uses a payment processor to verify your payment card information. Your payment card information is passed through to the payment processor and is not collected or stored by LINKPIN. The payment processor is authorized to use this information only to authenticate your purchase and for no other purpose. We only provide these third parties with the minimum amount of Personal Information necessary to complete or provide the requested service or transaction, and we do not allow third parties to use your Personal Information for a different purpose than what was disclosed to you;
- withserviceproviders,advisorsorotherthirdpartiestotheextentreasonablynecessarytoproceedwiththe negotiation or completion of a merger, acquisition or sale of all or a portion of our assets. If LINKPIN merges with or acquires or is acquired by another entity, Personal Information would be transferred as a whole to the successor entity;
- to comply with the law or legal process (such as responding to subpoenas or court orders), to comply with government reporting obligations and to exercise our legal rights or defend against legal claims; and
In addition, we share aggregated anonymized information, including usage data about LINKPIN products, with third parties for a variety of purposes, including to analyze trends about home networking and utility use, to show third parties how their products could work with LINKPIN products and to generally improve home networking. We’ve taken steps to ensure that this information cannot be linked back to you and we require third parties to keep all shared information in its anonymized form.
Any third parties with whom we share your Personal Information are required to maintain the confidentiality of the information and are prohibited from using it for any other purpose. We will take all reasonable steps to make sure these third parties comply with the same privacy principles that govern our collection of your Personal Information.
We will ask for your consent, such as by email response, opt-in box or click through agreement acceptance, before we use or share your Personal Information for any other purpose
You have the right to ask us not to process your Personal Information for marketing purposes. We will inform you (before collecting your Personal Information) if we intend to use your Personal Information for marketing purposes, or if we intend to disclose your Personal Information to any third party for marketing purposes.
If you do not wish to receive direct marketing material from us or a third party, in addition to following the “Unsubscribe” instructions in a marketing email, you can send us an email request at?[email protected].
Where We Store Your Information
The data that we collect from you may be transferred to, and stored at, various locations globally, including the United States. It may also be processed by LINKPIN staff or contractors operating outside your country of residence, who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. We also use cloud-based applications and services to store and process your Personal Information, which may result in your Personal Information being stored outside your country of residence.
Accessing and Updating Your Personal Information
We need your help in keeping your Personal Information accurate and up to date, so please notify us of any changes to your Personal Information. You can access and update your Personal Information and communication preferences at any time in the following ways:
- by clicking the “Unsubscribe” link in any email you receive from us;
- by sending an email to?[email protected]. Please be sure to include your name, email address and specific relevant information about the information you would like to change or the material that you no longer wish to receive; or
- for many LINKPIN websites and LINKPIN products, by signing in to your online account located at the URL provided when you signed up for the LINKPIN website or service.
We will honor your request to:
- correct your data if it is inaccurate or incomplete;
- transfer Personal Information you have provided to us to a third party if we are processing that data on either on the basis of your consent or to perform a contract with you;
- delete your Personal Information, unless we are required to retain it by law or to establish, exercise or defend legal claims; and/or
- provide you with a copy of your Personal Information held on our current records. If you are outside the EEA, we may make a reasonable charge if records must be accessed from backed up or archived records.
You can make a request to exercise any of these rights in relation to your Personal Information by sending the request by email to?[email protected]
Retention of Personal Information
To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Cookies, Web Beacons and Other Web Tools
We strive to maintain appropriate administrative, technical and physical safeguards designed to protect the information collected by LINKPIN websites and LINKPIN products. Unfortunately, the transmission of information via the Internet is not 100% secure.
It is important to note that if you use a computer or device that can be accessed by others, other people may be able to access unencrypted Personal Information. If you do not want your information to be available to others, exercise caution when using public computers or devices or when using any computer or device to which users unauthorized by you may have access.
We recommend that you take every precaution in protecting your Personal Information when you are on the Internet. For example, change your passwords often, use a combination of letters and numbers when creating passwords, and make sure you use a secure browser. You should also be aware that names that you give your Wi- Fi-enabled devices, home networks and services (also known as “friendly names”) may be detectable by others outside your home, so you should not use Personal Information as part of your friendly names.
Updates and Upgrades
LINKPIN products may be updated or upgraded from time to time to provide additional features, address technical issues, and generally make your user experience better. Some LINKPIN products include an auto-update feature, which gives us the ability to make updates automatically. You can change auto-update options by changing your settings within the LINKPIN Product account information. In very limited cases, updates may still be automatically applied, regardless of the auto-update setting. For example, we may provide an automatic update that prevents or fixes a security vulnerability or breach to your network.
Third Party and Social Media Linked Sites
If you participate in or post information to a discussion forum or chat room on any LINKPIN website or LINKPIN Product, you should be aware that the information you provide there will be made broadly available to others, and can be read, collected, forwarded or used by other users of these forums, potentially inside or outside LINKPIN, who have access to that forum. This information could also be used to send you unsolicited messages. Please recognize that individual forums may have additional rules and conditions. Each participant’s opinion on a forum or chat room is his or her own and should not be considered as reflecting the opinion of LINKPIN. We are not responsible for Personal Information or any other information you may choose to submit in these forums, or the consequences of any submission. If at any time you would like to remove a posting, please email us at?[email protected]. Keep in mind that removal of a posting from a forum or chat room does not mean that the posting will be deleted from our systems, or that it has been completely removed from the Internet.
How to Contact Us
Updated July 3, 2019