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Effective Date: 09 Jun 2025
Last Updated: 09 Jun 2025

Linkx.ee ("we," "us," "our"), operated by MCR One Oy, respects your privacy and is committed to protecting your personal information. This Privacy Policy details how we collect, use, disclose, and safeguard your data when you access our website at Linkx.ee, or use our digital business card and networking platform (collectively, "Services").

This policy complies with the EU General Data Protection Regulation (GDPR), the Personal Information Protection and Electronic Documents Act (PIPEDA, Canada), and the California Consumer Privacy Act/California Privacy Rights Act (CCPA/CPRA, USA).

Please read this Privacy Policy carefully.

Information We Collect

Information You Provide Directly

We collect personal information you voluntarily provide, including:

Identity Data: Name, username, profile photo.
Contact Data: Email address, phone number, mailing address.
Professional Information: Company name, job title, industry.
Billing Information: Payment method, billing details.
Account Information: Preferences, settings, social media links, testimonials, and custom content.
Customer Support Communications: Interactions through support or feedback.

Information Collected Automatically

When you use the Linkx.ee Services, we collect certain information automatically from your device. In some countries, including countries in the European Economic Area(EU,EEA) and the UK, this information may be considered personal information under applicable data protection laws. Specifically, the information we collect automatically may include information like

IP address, browser type, operating system, device details, geographic location (city/country level), usage patterns, page interactions, and click data.
Cookies and similar tracking technologies (please see our separate Cookie Policy for detailed information).

Further, we may undertake automatic scanning of User Profiles and links to support compliance with our Terms of Service and/or Community Standards, which may include determining whether mandatory or default sensitive content warnings should be applied and presented to people who wish to access the relevant User Profile or linked content. The results of this scanning may also help determine if any content should be removed or any User Profiles should be suspended in line with our Community Standards and/or Terms of Service, while also informing suitability for certain features, including monetisation opportunities such as affiliate marketing and sponsorships. When a Linkx.ee User changes their User Profile, we may also notify relevant subscribers to that User Profile that updates have been made.

Information from Third Parties

From time to time, we may receive personal information about you from third-party sources. Those sources include service providers that assist with marketing campaigns or competitions, and our partners who help us provide our Linkx.ee Services. For example, social media networks may provide your profile picture and follower information to help us connect Linkx.ee Users (including you) with brands, retailers and affiliate networks.

We may obtain personal information from third-party services, such as payment processors, analytics providers, affiliate partners, or social media platforms.

In all cases, we ensure that these third parties have your consent or are otherwise legally allowed or required to share your personal information with us.

How We Use Your Information

We process your data for the following specific purposes:

Service Delivery and Personalisation: Providing, maintaining, personalising, and improving our Services.
Billing and Payment Processing: Managing payments, subscriptions, and preventing fraud.
Communication: Responding to your inquiries, providing updates, notifications, and promotional offers (with opt-out).
Customer Support: Managing support requests and troubleshooting.
Analytics and Market Research: Understanding user behaviour and preferences to enhance our offerings.
Security and Compliance: Ensuring security, fraud detection, compliance with legal obligations and our terms.

Legal Bases for Processing (GDPR Specific)

We process your personal data based on:

Consent: Explicit consent for marketing and specific processing activities.
Contractual Necessity: Processing required to fulfil our contractual commitments.
Legitimate Interests: Enhancing, securing, and maintaining our Services.
Legal Obligation: Complying with legal and regulatory requirements.

Sharing Your Personal Information

We do not sell your personal data. However, we may disclose your personal information to the following categories of recipients:

Our Company group: to our group company and third party services providers (for example, to support the delivery of the Linkx.ee Services, provide functionality, facilitate payments, fulfil tax obligations, or enhance the security of the Linkx.ee Services). A list of our current group companies is available here, and a list of our current service providers is available below. We also facilitate third-party payment providers, and this is set out in more detail below.
With other Linkx.ee Users: if you choose to subscribe to or sign up to be part of their community, or download or purchase content from them. If you engage with a Linkx.ee User in these ways, they receive information about you to help them better understand and serve their community, including information needed to add you to their community outside of the Platform, where applicable, and information needed to be able to provide the paid content.
With third parties who facilitate log-in to the Linkx.ee Services: such as Apple, Google, Facebook, X and any other social media platform that we introduce for social log-in;
Third-party Service Providers: Payment gateways, analytics providers (Google Analytics), cloud hosting, marketing services.
Legal Authorities: to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
To an actual or potential buyer (and their agents and advisers): in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer they must use your personal information only for the purposes disclosed in this Privacy Notice; and
Business Transfers: During mergers, acquisitions, or asset transfers, subject to confidentiality.
With Your Consent: Explicitly shared with your permission.

Depending on how you use the Linkx.ee Services and your geographic location, we may disclose your personal information to third parties whose products are advertised on our Platform or who wish to engage in advertising on our Platform.

In order to facilitate paid products and/or services within the Linkx.ee Services, and to provide Linkx.ee to you, we use third-party payment service providers.

We reconcile transactions internally and send aggregate balances to our payment service providers, who manage transfers to your connected account. We will not store or collect your payment card or bank account details; this information is provided directly to our third-party payment service providers, whose use of your personal information is governed by their privacy policies and their terms and conditions in their role as data controllers for these processing activities. These payment service providers adhere to the standards set by Payment Card Industry Data Security Standards (“PCI-DSS”) as managed by the Payment Card Industry Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information. The payment processors we work with are:

Stripe (their privacy policy can be viewed at https://stripe.com/us/privacy);
PayPal (their privacy policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full); and
Square (their privacy policy can be viewed at https://squareup.com/au/en/legal/general/privacy).

Disclosure of personal information to other countries

Your personal information may be transferred to and processed in countries other than the country in which you are a resident. These countries may have data protection laws that differ from, and in some cases may be less protective than, the laws of your country.

Specifically, Linkx.ee may transfer personal information to Finland (where our headquarters are based), the United States and other countries where we conduct business. We may also subcontract certain activities and share your personal information with third parties located in other countries. The countries where these organisations are located will vary, but we generally disclose personal information to organisations located in Finland or the EU. These transfers are necessary to provide the Linkx.ee Services and carry out the activities described in this Privacy Notice.

We have taken appropriate safeguards to ensure that your personal information remains protected in accordance with this Privacy Notice and applicable data protection laws. These safeguards include entering into data transfer agreements between our group companies. Similar safeguards have been implemented with our third-party service providers and partners, and further details can be provided upon request.

We will not transfer your personal information to another country unless we believe there to be adequate safeguards in place. This includes, where applicable, utilising standard contractual clauses approved by the European Commission/EU Standard Contractual Clauses (SCCs) and by other relevant authorities, or relying on determinations from the European Commission and other relevant authorities about whether countries have adequate levels of protection. We also implement measures to ensure the security of your personal information wherever it is transferred. For more details, please see the “How do we secure your personal information” section below.

How do we use cookies and similar tracking technology?

We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Notice.

How long do we retain your personal information?

We will retain your personal information for the period necessary to fulfil the purposes outlined in this Privacy Notice and in accordance with applicable legal and regulatory requirements in respect of permitted or required retention periods and limitation periods relevant to legal action.

How do we secure your personal information?

We have implemented technical, administrative, and physical safeguards to ensure the security of your personal information. These controls include industry-standard encryption, firewalls, intrusion detection, logging, monitoring and regular audits.

In the unlikely event of a data breach, we have a robust incident response plan to mitigate harm and notify affected individuals where we are legally required to do so.

What are your rights concerning personal information?

Your rights may depend on where you live and the laws that apply to you.

Access, correct, update or request deletion of your personal information.
Object to or restrict how we process your personal information.
Request the portability of your personal information.
Opt out of receiving marketing communications. You can also exercise this right by clicking on the unsubscribe or opt-out link in the marketing materials we send you.

If you have given consent to the processing of your personal information, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on other lawful grounds. Depending on the country in which you live and the laws that apply to you, you may also have additional data protection rights. If you are located in the UK or the European Economic Area, you also have the right to complain to a data protection authority (contact details for data protection authorities in the European Economic Area, UK, and Switzerland are available here, here, and here).

We use cookies and other tracking technologies to display advertisements about our products to you on nonaffiliated websites, applications, and online services. This is considered “targeted advertising” under applicable privacy laws. When we engage in those activities. In addition, depending on how you use the Linkx.ee Services, we may disclose your personal information (i.e., customer account and commercial information) to third parties whose products are advertised on our Platform or who wish to engage in advertising on our Platform.

To exercise your rights, please submit a request through our Data Request Form. If legally required, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the individual on whose behalf you are making such request. To do so, we will ask you to verify data points based on information we have in our records. If you are submitting an opt-out request on behalf of another individual, please use the same contact methods described above. We will process requests from authorised agents in accordance with applicable law. If we refuse to take action regarding your request, you may appeal our decision by replying to the email you received from us in response to your request.

If you would like to opt out of targeted advertising, you may also alter your cookie preferences. For further information about how you can control cookies, please see our Cookie Notice.

Your U.S. State Privacy Rights and Additional Disclosures

Depending on the U.S. state in which you reside, you may have certain privacy rights regarding your personal information. If you are a California resident, please see the “Supplemental Information for California Residents” section below. For other state residents, your privacy rights may include (if applicable):

The right to confirm whether or not we are processing your personal information and to access such personal information and the categories of personal information we are processing or have processed about you;
The right to obtain a copy of your personal information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another controller without hindrance, where the processing is carried out by automated means;
The right, at our option, to obtain a list of the categories or specific third parties to which we have disclosed your personal information;
The right to delete your personal information, subject to certain exceptions;
The right to correct inaccurate personal information that we maintain about you, subject to certain exceptions;
The right, if applicable, to opt out of the processing of your personal information for purposes of (1) targeted advertising; (2) the “sale” of your personal information (as that term is defined by applicable law); and (3) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
If we are required by applicable law to obtain your consent to process sensitive personal information, the right to withdraw your consent; and
The right not to receive discriminatory treatment by us for the exercise of your privacy rights.

To exercise your rights, please submit a request through our Data Request Form. If legally required, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the individual on whose behalf you are making such request. To do so, we will ask you to verify data points based on information we have in our records. If you are submitting an opt-out request on behalf of another individual, please use the same contact methods described above. We will process requests from authorised agents in accordance with applicable law. If we refuse to take action regarding your request, you may appeal our decision by replying to the email you received from us in response to your request.

If you would like to opt out of targeted advertising, you may also alter your cookie preferences. For further information about how you can control cookies, please see our Cookie Notice.

Supplemental Information for California Residents

The California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (“CCPA”), requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, sale, sharing, and retention of personal information and of the rights of California residents regarding their personal information. This section of the Privacy Policy is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this section does not apply to you, and you should not rely on it.

The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, de-identified or aggregated information or lawfully obtained, truthful information that is a matter of public concern. For purposes of this “Supplemental Information for California Residents” section, we will refer to this information as “Personal Information.”

1. Collection and Use of Personal Information

(a) Categories of Personal Information We Have Collected:

Identifiers such as name, alias, postal address, online identifier (e.g. cookies) and other similar identifiers;

Personal records such as payment information;
Characteristics such as age, gender and other demographic data;
Customer Accounts / Commercial information such as the User Profile, records of products or services purchased, obtained, or considered;
Online usage information such as Internet and other network activity information, such as, but not limited to, browsing history, search history and information on interactions with the Linkx.ee Services;
Geolocation data such as country and zip code;
Sensory information such as recordings of customer service calls, and
Inferences derived from personal information such as purchase preferences, interests and characteristics. There may be additional information that we collect that meets the definition of personal information under California law but is not reflected in a category, in which case we will treat it as personal information as required under California law, but will not include it when we are required to describe our practices by category of personal information.

(b) Categories of Sources of Personal Information that We Collect:

Directly from you. For example, when you create an account, make a purchase, browse our Platform, or use the Linkx.ee Services.

Directly and indirectly from activity on the Platform and/or using the Linkx.ee Services.
Social networks (to the extent we introduce social media log-ins in the future).
Service providers who provide services on our behalf, such as those used to fulfil orders, process your payments and requests, verify your information, monitor activity on the Platform and/or use the Linkx.ee Services provides analysis and analytics, maintains databases, administers and monitors emails and marketing, administers and sends mobile messages, serves ads on this and other services, and provides consulting services.

In addition to the purposes stated above in the section “Why do we collect your personal information?”, we currently collect and have collected the above categories of personal information for the following business or commercial purposes:

Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
Helping to ensure security and integrity to the extent that the use of your personal information is reasonably necessary and proportionate for these purposes.
Debugging to identify and repair errors that impair existing intended functionality.
Short-term, transient use, including, but not limited to, personalised advertising shown as part of your current interaction with us, provided that your personal information is not disclosed to another third party and is not used to build a profile about you or otherwise alter your experience outside the current interaction with us.
Performing services, including maintaining or servicing accounts, providing customer service, providing analytic services, or providing similar services.
Providing advertising and marketing services, except for cross-context behavioral advertising, to you provided that, for the purpose of advertising and marketing, our service providers and/or contractors shall not combine the personal information of opted-out consumers that the service provider or contractor receives from us, or on our behalf with personal information that the service provider or contractor receives from, or on behalf of, another person or persons or collects from its own interaction with you.
Undertaking internal research for technological development and demonstration.
Undertaking activities to verify or maintain the quality or safety of a service that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service that is owned, manufactured, manufactured for, or controlled by us.
Advancing our commercial or economic interests, such as by inducing another person to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction.

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2. Sale, Sharing, and Disclosure of Personal Information

(a) Sale and Sharing of Personal Information

Depending on how you use the Linkx.ee Services, we may sell your customer account and commercial information to brand partners to advance our commercial and economic interests. Our use of Cookies may also constitute a sale or sharing of personal information under California law.

(b) Disclosure of Personal Information

In the 12 months preceding the last updated date of this Privacy Notice, we have disclosed the following categories of personal information to service providers for a business purpose, or, at your direction, as with sponsors of promotions, sweepstakes, or contests. We have disclosed the following:

Categories of Personal Information Disclosed for a Business Purpose

Identifiers;
Personal records;
Characteristics;
Customer Accounts / Commercial information;
Online usage information;
Geolocation data;
Sensory information; and
Inferences derived from personal information.

Categories of Recipients of Disclosed Personal Information

Service providers;
Group companies, and
Governmental authorities and agencies.

For the avoidance of doubt, we do not sell or share the personal information of individuals under 16 years of age. We do not use sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations.

3. Retention of Personal Information

We retain your Personal Information for as long as necessary to fulfil the purposes for which we collect it, such as to provide you with the service you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us.

4. California Privacy Rights

(a) Right to Know

You have the right to request that we disclose to you the following information about the personal information we collect from you:

categories of personal information collected;

categories of sources of personal information collected;

the business or commercial purpose for collecting, selling, or sharing personal information (if applicable);

the categories of third parties with whom we share personal information (if applicable); and

The specific pieces of personal information we have collected about you over the past 12 months.

(b) Right to Request Deletion of Personal Information

You have the right to request the deletion of your personal information collected or maintained by us, subject to certain exceptions permitted by law.

‍(c) Right to Correct Personal Information

You have the right to correct inaccurate personal information that we maintain about you.

(d) Right to Opt Out of Selling or Sharing of Personal Information

You have the right to opt out of the sale or sharing of your Personal Information.

(e) Right to Limit Use or Disclosure of Sensitive Personal Information

You have the right to limit the use or disclosure of your sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations.‍

(f) Right to Non-Discrimination

You have the right not to be treated in a discriminatory manner for exercising your privacy rights. We do not use the fact that you have exercised or requested to exercise any privacy rights for any purpose other than facilitating a response to your request.

5. Exercising Your California Privacy Rights

To exercise your rights, you can contact us:

By email at [email protected]

By visiting this page on our website: Linkx.ee/support

By completing our Data Request Form.

Your Privacy Rights in short

You have rights regarding your personal data, depending on your jurisdiction:

European Union (GDPR)

Access: Right to access personal data.

Rectification: Right to correct inaccuracies.

Erasure: Right to request data deletion.

Restriction: Limit data processing under specific conditions.

Portability: Receive data in machine-readable format.

Objection: Object to data processing for specific purposes.

Withdraw Consent: Revoke previously given consent.

Complaint: Right to complain to a supervisory authority.

California, USA (CCPA/CPRA)

Know: Information about data collection and use.

Delete: Request deletion of personal data.

Correct: Correct inaccurate information.

Opt-out: Opt out from data selling/sharing.

Limit Use of Sensitive Data: Restrict processing of sensitive personal data.

Non-discrimination: Equal service after exercising your rights.

Canada (PIPEDA)

Access: View personal data collected.

Correction: Correct inaccuracies.

Withdraw Consent: Stop or limit data collection/use.

Complain: File complaints with the Privacy Commissioner.

Once we receive your request, we are required to verify that you are the person who is the subject of the request. This verification process consists of matching the identifying information provided by you with the information we have about you in our records. Upon making a request, you will be asked to provide your name, email address, and request details. A confirmation email will be sent to the email address you provide to begin the process to verify your identity. If we cannot verify your identity, we will not be able to respond to your request.

You may designate an authorised agent to exercise any of the above privacy rights on your behalf, subject to the agent's request requirements under California law. Please note, for your safety and security, we will require authorised agents to provide proof of consent and designation of the authorised agent, and will also require authorised agents to provide information necessary to verify the identity of the individual who is the subject of the request. We may also require that the individual verify their own identity directly with us before we respond to an authorised agent’s request. We reserve the right to deny requests in certain circumstances, such as where we have a reasonable belief that the request is fraudulent.

To exercise these rights, contact us at: [email protected].

6. Opt Out Preference Signal

The Website recognises the Global Privacy Control (“GPC”) signal. If you are using a browser setting or plug-in that sends an opt-out preference signal to each website you visit, we will treat that as a valid request to opt out. To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.

California law requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Because there currently isn’t an industry standard for recognising or honouring DNT signals, we do not respond to them at this time.

7. California’s Shine the Light law

We do not share personal information with third parties for their direct marketing purposes absent your consent as defined by California Civil Code Section 1798.83 (“Shine the Light law”). To opt-out of future sharing with third parties for their direct marketing purposes, use our Data Request Form. Any such request must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year.

Complaints

We take your privacy concerns seriously. If you have a complaint regarding our handling of your personal information or concerning our privacy practices, you may file a complaint with us using the contact details provided under the “How you can contact us” heading below. We will confirm receipt of your complaint and, if we believe it necessary, we will open an investigation.

We may need to contact you to request further details of your complaint. If an investigation has been opened following a complaint made by you, then we will contact you with the result as soon as possible. In the unlikely circumstances we are unable to resolve your complaint to your satisfaction, you may contact the local privacy and data protection authorities in your jurisdiction.

Data Security Measures

We employ rigorous security practices, including:

SSL/TLS encryption for data transfers.
Role-based access control and authentication measures.
Regular security audits and assessments.
Incident response and breach notification processes.

However, no system guarantees absolute security. We encourage you to protect your login details.

Data Retention Policy

We retain your data only as long as necessary to fulfil the purposes outlined or as required by law. When no longer needed, we securely delete or anonymise data.

Children’s Privacy

The “Age Limit”: Our services are not intended for use by children under the age of 18. If you are under the Age Limit, please do not use the Linkx.ee Services and do not provide us with your personal information. We do not knowingly collect, use, or disclose personal data from individuals under these age thresholds.

If you are a parent or legal guardian and believe your child has provided us with personal data without your consent, please contact us immediately at [email protected]. Upon becoming aware that we have collected personal data from a minor without verified parental consent, we will take prompt steps to delete such data from our systems in accordance with applicable law.

In cases where we rely on consent as the legal basis for processing personal information, and the applicable law in your country requires parental or guardian approval for individuals under a certain age, we may require verifiable parental consent before collecting or using any such data.

We strongly encourage parents and guardians to supervise their children’s online activities and ensure that children do not submit personal information through our Services.

Cookies and Tracking Technologies

Please refer to our detailed Cookie Policy for comprehensive information about cookies, their purposes, and your management options.

Third-Party Links

Our Services may contain third-party links or integrations that are not operated by Us. If you click on a third-party link, you will be directed to that third party's site. We are not responsible for the privacy practices of external sites. Always review their privacy policies before engaging.

Changes to Our Privacy Policy

We may update our Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.

You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.

13. Complaints and Contact Information

We take privacy concerns seriously. To submit complaints, questions, or to exercise your rights, contact our Data Protection Officer (DPO):

Email: [email protected]

Mailing Address:
MCR One Oy
Tietäjänkatu 5
55120 IMATRA
Finland

Service Providers and Partners

Our key third-party service providers include (not limited to):

Stripe, PayPal, Google Analytics, Heap, Bing, Amazon Web Services, Google Cloud, Hetzner, Cloudflare, Meta, SendGrid, HubSpot, Mailchimp, Intercom, HubSpot, AWS(Amazon Web Services) Security Services, Google Cloud, Gemini, Open AI

Final Note:
This Privacy Policy is comprehensive, reflecting current best practices and legal requirements across the EU, Canada, and the US (as of April 2025). We recommend regularly reviewing this policy for updates.

Thank you for trusting Linkx.ee.