Privacy policy

1. Introduction

If you have just a few minutes, we will explain in a simple way what we do with your personal data that we collect when you access and use our services on www.link.biz (‘LinkBiz’ or the ‘Service’).

The applicable legislation, mainly consisting in the Regulation (EU) 2016/679 (General Data Protection Regulation, ‘GDPR’) and relevant member States’ implementation laws, together with the European Data Protection Board’s and national Supervisory Authorities’ decisions and provisions (all together, the ‘Privacy Law’), identifies a number of actors which must – or simply may – go on the stage, taking part in the personal data processing operations. Their roles and responsibilities vary based on their decision-making power and degree of involvement as to how and why the data will be processed.

Data Controller

The main actor, named 'data controller' freely determines the purposes, methods and tools of the processing, being therefore required to guarantee the security of your personal data and to protect all of your rights on the Privacy Law.

In its quality as developer and owner of the Service, the data controller of the processing operations carried out through LinkBiz is Glickon S.r.l., a company duly incorporated under the laws of Italy, with registered office in Milan, via Nino Bixio 7, VAT/registration number 08573820969 ('Glickon', 'Controller' or 'we/us')

There may be other players on the scene who, however, play a supporting function in favour of the data controller, rather than a leading role. More in detail, the Privacy Law establishes that one or more specific data processing activities can be entrusted by the controller to reliable external providers, named ‘data processors’, who are only allowed to act on behalf and upon written instructions – and so as an ‘operating arm’ – of the controller.

Keep in mind that whenever in this policy we refer to a ‘processing’ of data, it will be an operation carried out, whether or not by automated means, with or through personal data, such as by way of example collection, recording, organization, storage, extraction, modification, consultation, use, disclosure by transmission, dissemination or otherwise making available, comparison and deletion of data.

That being said, it must be specified that ‘personal data’ are not only those immediately referable to you (e.g. name and surname), but also those which, in combination with other information available to us or to any third party, would still allow your identification (e.g. your tax/fiscal code or the IP address of the device by which you access the Service).

2. The service settings to protect your privacy

The Service has been designed and set up in such a way as to reduce as much as possible the collection and use of your personal data, excluding the processing in all cases when it is possible to rely on less privacy-intrusive methods.

This Privacy Policy governs exclusively the data processing operations carried out through the Service and must never apply to third-parties’ websites, applications and web platforms accessible in any manner from or via LinkBiz, including in particular any Content (as defined in the applicable Terms & Conditions) you may upload or made available on or through the Service.

Therefore, we invite you to carefully read any third party’s privacy policy before accessing its websites, platforms or applications, or using its services, in order to better understand how your personal data will be processed.

3. Types of data collected and processed

The data that we will collect and process for the purposes described in Par. 4 are the following:

  • Web browsing necessary data

    The computer systems used to ensure that the Service properly runs gather, during their normal operation, some data necessary for the use of Internet network protocols (e.g. the IP address of the device you use to access and browse the Service). In the absence of additional information, this type of data does not allow us to identify you, but only to enable your access and navigation on and proper use of the Services.

  • Data collected by means of cookies

    We use technical and functional cookies – namely web tracking tools – to make your browsing on the Service easier and smoother. For more detailed information regarding the processing of your data deriving from the cookies that may be installed on LinkBiz, please read the applicable Cookie Policy.

  • Contact details

    We may collect the data you will provide to us in connection with and in the context of your requests for information or assistance.

    In case you write to support@glickon.com for any kind of request (e.g. general information or technical assistance), we will receive your e-mail address, as well as any other information and personal data you will decide to share with us in the subject, content and any attachment of your communication.

    Note that we do not need to receive additional or different data than those indicated above. Therefore,please do not share with us any personal data which is not necessary to allow us to reply and give effect to your request. In most cases, we will delete such additional data, except when Glickon is explicitly permitted to lawfully process them in accordance with the applicable Privacy Law.

  • Registration data

    You will be required to register, or log-in (if you are already registered), in order to access and use the Service.

    We will ask your name and surname, the name of the company you work for and your corporate e-mail address, as well as to choose a suitable personal password, to be then kept secure and confidential under your responsibility.

  • Payment details

    Should you choose to purchase or activate the full version of the Service (as defined in our Terms & Conditions), you will also be required to provide us with certain payment information, including credit card details, VAT number and billing address, needed to enable us to charge and invoice the applicable fees.

4. Purposes and Legal bases of the processing

Control over what is done with your personal data is and must remain solely in your hands.

For this reason, it is our duty to provide you with any necessary details about all the processing operations we can carry out through the Service and, for each of them, indicate the legal basis that permits us - or would permit us, if the processing relies on your consent – to perform such activities.

  • Browsing the Service

    Based on our legitimate interest (Art. 6.1, f), of the GDPR), we will collect and process only few technical data which are needed to enable you to easily access and smoothly navigate on LinkBiz, using the Service without slowdowns or hindrances deriving from the functioning of Internet protocols. Note that this information does not allow us to single-out any specific person without matching it with separate additional personal data.

  • Managing cookies

    For in-depth information regarding our use of cookies installed on LinkBiz, please read our Cookie Policy

  • Responding to your contact and support requests

    If you decide to contact us for any reason, such as requesting information or assistance regarding the Service, we will process your personal data for the exclusive purpose to reply and follow up on your request(Article 6.1, b) of the GDPR). In absence of your data, we will not be able to process and respond to your request.

  • Managing your registration to the Service

    In order to allow you to access and use the Service (Art. 6.1, b) of the GDPR), you will be required to finalize your registration, providing us with those data which are necessary for the creation of your LinkBiz account. In the event you prefer not to sign in, you will not be able to access the Service.

    We will use your registration data and e-mail address also to send you service communications, without any commercial nature or purpose , relating solely to the management of your LinkBiz account and page and the functioning of the Service.

  • Processing payments

    The fees applicable when the full version of the Service is activated cannot be charged and invoiced if you do not provide us with the necessary billing details. Such information will be processed for the exclusive purpose of managing the agreed payment plan and charging the relevant fees (Article 6.1, b) of the GDPR).

  • Soft-spam: informing you about other Glickon’s services

    Unless you object to this processing at any moment, we will use the email address provided during your registration to LinkBiz, to pursue our legitimate interest (Art. 6.1, f), of the GDPR) to inform you regarding other technological products and services offered by Glickon.

    Should we use different communication channels (other than e-mail) to send you marketing materials in the future, it will be our duty to ask your prior consent, when required, for this specific purpose.

  • Other purposes

    In addition to the above, we can process your data described in this Par. 4:

    • based on our legitimate interest to prevent and fight crimes and frauds committed on or through the Service, as well as to establish or exercise legal claims or defend our rights before competent Courts (Art. 6.1, f), of the GDPR);

    • based on our legitimate interest to elaborate and generate aggregate statistics that no longer allow your single-out (Art. 6.1, f), of the GDPR);

    • in order to comply with a legal obligation to which we are subject or to fulfill an order or a decision by public competent Authorities (Art. 6.1, c), of the GDPR).

5. Who can access and process your personal data

The access to your data will be allowed exclusively to Glickon’s personnel, duly trained on the applicable privacy and security safeguards and authorized in writing to process only those data which are necessary to carry out their respective job tasks.

Should we outsource specific data processing activities relating to the functioning and provision of LinkBiz, each vendor engaged will be bound to guarantee at least the same levels of protection of your data offered by us, by signing a specific agreement with Glickon under Art. 28.3 of the GDPR, so acting as our data processor.

Your data will not be disclosed in any way, nor communicated to third parties, except to comply with orders or provisions issued by competent authorities.

In any case, we have adopted a series of technical and organizational measures to ensure appropriate levels of security, so to prevent all reasonably foreseeable risks that may jeopardize your personal data, with particular but not limited reference to accidental or unlawful destruction, loss, alteration, or unauthorized disclosure or access to such data.

6. Transfer of data to Third Countries

The processing operations carried out in connection with LinkBiz will always take place within the European Economic Area (‘EEA’).

Should for any reason become necessary to transfer your personal data to third countries located outside the EEA that do not guarantee adequate levels of protection as required by the applicable Privacy Law, we will first of all specifically inform you about this need and then impose on the data importer the same obligations of security and protection of your personal data guaranteed by us, as described in this privacy policy (e.g. by signing Standard Contractual Clauses and, where needed, carrying out a ‘Transfer impact assessment’).

7. For how long we will process your data

We will retain your personal data only for the time necessary to achieve the purposes described above. This means that the data collected:

  • to allow your access and use of the Service will be processed for the sole time of your navigation on LinkBiz, or until you decide to delete them (by eliminating technical and functional cookies – see here below);

  • by means of the cookies installed on LinkBiz will be processed only for the duration – i.e. until the expiry date – of each specific cookie to which they are associated, as specified in the applicable Cookie Policy;

  • in relation to your contact or support requests will be processed only for the time necessary to provide you with the needed information and/or assistance, so to properly handle and follow-up your request. At the latest 1 (one) year after the last response sent by us to you, the data will be deleted;

  • to allow and manage your registration to the Service will be processed until you decide to delete your personal account on LinkBiz, or in any case to terminate your agreement with Glickon under the applicable Terms and conditions. With specific reference to soft-spam, the e-mail associated with your LinkBiz account will be used to send you communications regarding other services and products offered by Glickon until you object, at any moment, to this processing;

  • to charge and invoice the applicable fees will be processed for 10 (ten) years from the moment that each payment is finalized.

Following the expiry of the terms set out above, we will be entitled to keep processing your data for those purposes which are permitted, or even mandatory, under the laws in force from time to time (e.g. to establish and/or exercise legal claims and/or defend our rights before competent Courts).

As soon as no longer necessary in accordance with the above, your data will be cancelled.

8. Your rights

You can exercise your rights at any time according to the applicable Privacy Law, including:

  • Access: accessing your personal data, obtaining evidence – among others – of the purposes of the processing by Glickon, the categories of data involved, the recipients to whom the data may be disclosed, the applicable storage period, the existence of any automated decision-making process;

  • Rectification: having incorrect personal data referred to you rectified without any undue delay;

  • Erasure: having your data erased, unless a specific exemption applies, when such data (i) are no longer necessary in relation to the purposes for which they were collected or otherwise processed; or (ii) have been unlawfully processed; or (iii) are subject to a processing that you have objected to on the basis of your particular situation, as set out in point f. below, and there are no overriding legitimate grounds which allow us to keep processing the data; or (iv) are undergoing a processing for direct marketing purposes; or (v) have to be erased for compliance with a legal obligation applicable to Glickon;

  • Restriction of processing: obtaining restrictions to the processing operations concerning your data, when (a) you contest the accuracy of your personal data (solely for the period enabling us to verify their accuracy); (b) the processing is unlawful and you oppose the erasure of your data and request the restriction of their use; (c) we do no longer need your personal data for the purposes identified above, but you require them for the establishment, exercise or defense of legal claims; (d) you have objected to the processing of your data, pending our verification as to whether overriding legitimate grounds exist which allow us to keep processing your data;

  • Portability: requesting to receive in a structured, commonly used and machine-readable format the data you have provided to us or, where technically feasible, having them transmitted directly to another controller;

  • Objection: impeding at any time the processing of your data for direct marketing purposes (soft spam) and, on grounds relating to your particular situation, any processing activity based on our legitimate interest (Art. 6.1, f), of the GDPR), as described in Par. 4 above;

  • Enforce your rights: lodging a complaint to the competent Supervisory Authorities.

To exercise your rights and for any information or clarifications regarding the data processing operations described in this policy, please just send us a written request at any time, by paper mail, to Glikon S.r.l., Via Nino Bixio 7, Milan (20129), or by e-mail to privacy@glickon.com

Last update: 20 May 2021