Privacy Policy

Key Terms & Scope of Privacy Notice

Key Terms:

• “User” Any individual or entity accessing or using the LinkkoAds platform, including but not limited to those connecting their wallets, viewing advertisements, or interacting with any features or services provided by LinkkoAds.
• “Blockchain Data” Information recorded on a public ledger in a secure and verifiable manner, typically associated with digital assets and transactions.
• “Non-Blockchain Data" Information not directly linked to blockchain records, including but not limited to geographic data and user-provided information necessary for providing targeted advertising services.
• “Advertiser” An individual, organization, or entity that utilizes the services of LinkkoAds to create and promote targeted advertising campaigns to reach specific audiences. Advertisers use the LinkkoAds platform to display their promotional content to users whose wallet profiles match the criteria set by the advertisers, aiming to increase brand visibility, engagement, and conversions.
• “Data Hosting” The process of storing and managing data on a third-party server, ensuring the security, integrity, and confidentiality of all user data.
• “Data Protection Laws” Legal frameworks and regulations that govern the collection, use, storage, and sharing of personal data, ensuring the protection of individuals' privacy and rights.
• “Data Protection Laws” The handling of personal information, including but not limited to the collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination, alignment, combination, restriction, erasure, or destruction of data.
• “Services” means any support and other services provided by us as part of or in connection with the use and/or access of the Linkko Service.
• “LinkkoAds” The advertising platform provided by LinkkoAds that allows users to connect their wallets, view targeted advertisements, and earn rewards based on their interactions with the provided content and services.
• “Linkko Website” means Linkko’s corporate website located at www.linkko.io.
• “Visitor” means a visitor or user of the Linkko Website.

Scope of this Privacy Notice:

This Privacy Notice applies to all Users, and covers personal information that we collect, use, share, and otherwise process when you:

• Visit, browse, or interact with the Linkko Website
• Download and/or use the Linkko App.
• Visit any Verification Site.
• Interact with and/or use any Services.
• Access or use any other websites, products, applications, and/or services that include an authorized link to this Privacy Notice.

Changes to this Privacy Notice

Linkko reserves the right to update or modify this Privacy Notice at any time.  When we update this Privacy Notice, we will revise the “Last Updated” date at the top of this Privacy Notice and post a link to the updated Privacy Notice on our Website. In addition, if you have downloaded the Linkko App or Verifier App, we may provide notice through the user-interface of the applications. Changes to this Privacy Notice are effective when they are posted. If we make any material changes, we will provide you with notice as required under applicable law. Please review this Privacy Notice periodically to ensure you are aware of any such changes.

If you do not agree to any updates or modifications to the Privacy Notice, you may stop accessing and using the Linkko Service.  Your continued use of the Linkko Service after the applicable effective date of the revised Privacy Notice, signifies to us that you acknowledge and agree to be bound by the revised Privacy Notice.

Information We Collect

The personal information we collect directly from you depends on how and why you use the Linkko Service. For instance, the information that we process when you are a Visitor just browsing the Linkko Website or requesting to receive marketing materials, is more limited than the information you provide if you are an User accessing and using LinkkoAds.

• Information from Visitors;
• Information from Users;

Please be advised that we may ask you to update your information from time to time in order to keep it accurate. 

If you provide personal information to us about someone else, you must ensure that you are entitled to disclose that information to us and that, without us taking any further steps required by data protection laws, we may collect, use and disclose such information for the purposes described in this Privacy Notice. For example, you should ensure the individual concerned is aware of the terms detailed in this Privacy Notice.

You may choose not to provide information directly to us or to not use the Linkko Service. However, some personal information is necessary so that we can provide you with the Linkko Service you have requested or, where you are an End User of a Admin User, Linkko Service related to the Gated Experience you wish to participate in. Failure to provide this information may prevent us from providing you with access to our Linkko Service.

Information Collected from Visitors

Information Visitors Provide Directly to Us

If you are a Visitor, Linkko collects the following types of information directly from you:

• Contact Information. We collect contact information, such as your email, your first name, last name and company name), if you contact us through the Website, or if you sign-up to receive our marketing communications and/or newsletters.
• Verifier Request Information. If you submit a request to use the Linkko Service as a verifier, we collect your name, email, organization, your organization’s website or social media account, how you would like to work with us, and any additional information you share with us in the request form.
• Communication and Feedback Content: We collect the information you may provide by filling out forms or by contacting us (such as your feedback or other communications with us).

Visitor Information Collected Automatically

We may automatically collect information about the actions Visitors take when interacting with the Website, as described in the Information Collected Indirectly section below.

Visitor Information Provided to Us by Third Parties

We may collect, receive or otherwise access information about our Visitors from certain third parties such but not limited to analytics providers.

Information Collected from Users

If you are a User, Linkko collects the following types of information directly from you:

• To access the platform, users are required to provide their email addresses. It acts as a unique identifier for the account. The email address is used solely for the purpose of user identification and communication.
• When users connect their wallets to LinkkoAds, we collect blockchain-related information, including assets owned, transaction history, net worth, and other relevant data associated with the blockchain.
• We collect limited non-blockchain data, including geographic information (such as the country/city of connection), solely for the purpose of providing targeted advertisements in compliance with the applicable advertising regulations and standards.

Use of Information

We use blockchain data to match users with relevant advertisements based on their wallet profile, transaction history, geographic information, nationality, and religion, where relevant. Advertisers are provided with aggregated information about the types of audiences and wallets that engage most with their ads, ensuring compliance with advertising laws and regulations while safeguarding user privacy.

Aggregated Data

With the personal information and other data (including, Usage Information) collected by us, we process “Aggregated Data”, such as statistical or demographic data. Aggregated Data may be derived from personal information, but is not considered personal information under the law if it does not directly or indirectly reveal an individual’s identity. If we combine or connect Aggregated Data with personal information so that it can directly or indirectly identify an individual, we treat the combined data as personal information, which will be processed in accordance with this Privacy Notice.

Cookies & Similar Technologies

We do not utilize any browsing cookies to track user browsing activities online for targeting purposes. Our platform strictly adheres to the principles of non-intrusive data collection and respects user privacy and confidentiality, as specified in our Cookie Policy and in compliance with relevant international laws and regulations governing online privacy and data protection.

Children’s Privacy

Linkko does not target the Linkko Service to persons under the age of 16, nor does Linkko knowingly collect personal information from, persons under the age of 16 or the equivalent legal age as specified by law in the applicable jurisdiction. Therefore, we ask you not to provide us with personal information of persons under the age of 16 or the equivalent age as specified by law in your jurisdiction. If we learn that personal information of persons under the age of 16 or the equivalent age as specified by law in the applicable jurisdiction, has been collected on or through the Linkko Service, then we may deactivate the account or otherwise terminate access to the Linkko Service and/or make the user content inaccessible.

User Anonymity

Linkko does not require you to provide any sensitive data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic, and biometric data to use the Linkko Service.

Sharing Personal Information

Aside from disclosing personal information to those of our personnel who are authorized to process the information in order to provide the Linkko Service and who are committed to confidentiality, we disclose personal information only to the third parties as described below.

Third-Party Service Providers

We share personal information of all Users with third-party vendors, consultants, agents, contractors, and service providers that provide services to us that help us in the operation, provision, administration and management of the Linkko Service and to otherwise operate our business (“Service Providers”). Depending on how you use the Linkko Service, the following categories of third parties collect data on our behalf or receive personal information:

• Hosting services providers;
• Analytics providers;
• Payment processing providers;
• Advertising and marketing providers;
• Providers of business operations and communication tools;
• Other third-party service providers that help us provide features and functions for the Linkko Service (e.g., customer support providers); and
• Professional service providers, such as auditors, lawyers, consultants, accountants and insurers.

Business Transfers

We may also share data with third parties to whom we choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this Privacy Notice.

Affiliates and Subsidiaries

Personal information that we collect about you through the Linkko Service may be shared with the employees, contractors, and agents of Linkko and our affiliated and subsidiary entities (“Affiliates”) who are involved in providing or improving the Linkko Service that we offer to you. We obligate the employees, contractors and agents of Linkko and our Affiliates to ensure the security and confidentiality of your personal information and to act on that personal information only in a manner consistent with this Privacy Notice.

 Communications

Direct Marketing

If you have not otherwise opted out, or if you have opted in to receive direct marketing emails from us, we may use your personal information to send you marketing information about the Linkko Service, other Linkko products and services, new product releases, and new feature releases of the Linkko Service, that we think may interest you. We carry out direct marketing by email.

Your Choices

Updating and Correcting Personal information

If you would like to correct or update certain personal information (such as your contact information) please contact us and we will use reasonable efforts to correct and/or update such information.If you are an Authorized User or End User, please contact the relevant Admin User if you wish to request the removal of personal information under their control.

Please note that if you are an User, we may forward your request to update or correct your information to the relevant Admin User with respect to the information controlled by such Admin User

Direct Marketing

You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any of our marketing e-mails. We will use commercially reasonable efforts to process such requests in a timely manner. You cannot opt out of receiving transactional e-mails related to the Linkko Service (e.g., requests for support)

Please note that we do not control the direct marketing of our Admin Users.  If you wish to opt out of marketing communications from a Admin User, please contact the applicable Admin User.

Additional European and International Data Rights

If you are a resident of the European Economic Area, United Kingdom, or Switzerland, you may have additional rights you can exercise as described in Section 15.

Do not Track (DNT) Preferences

The Linkko Service does not monitor for or behave differently if your browser or device transmits a “Do Not Track” or similar message.

Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. There is no consensus among industry participants as to what "Do Not Track" means in this context. Like many websites and online services, Linkko does not currently alter our practices when we receive a "Do Not Track" signal from a browser except as specifically required by law. For information about "Do Not Track" please visit All About DNT.

Data Retention

Personal information is processed for the period necessary to fulfill the purposes for which it is collected (for example, in connection with the Linkko Service provided), to comply with legal and regulatory obligations and for the duration of any period necessary to establish, exercise or defend any legal rights.

In order to determine the most appropriate retention periods for your personal information, we consider the amount, nature and sensitivity of your such information, the reasons for which we collect and process your such personal information, and applicable legal requirements.

In some instances, we may choose to anonymize your personal information instead of deleting it, for statistical use, for instance. When we choose to anonymize, we make sure that there is no way that the personal information can be linked back to you or any specific individual.

If you are an User contact us if you wish to request the removal of personal information under their control.

Data Protection and Security

All data is securely hosted on Google Cloud, adhering to industry-standard security measures and compliance with data protection laws and regulations, ensuring the confidentiality and integrity of all user data in accordance with the terms of our Data Security and Compliance Policy.

Additional European and International Data Rights

The European Union’s General Data Protection Regulation and certain other countries’ data protection laws provide certain rights for data subjects. If you are a resident of the European Economic Area, the United Kingdom, Switzerland or another country with data protection laws that provide for certain data subject rights, you may submit a request to exercise your rights.

We respond to all requests we receive from individuals wishing to exercise their data rights in accordance with applicable data protection laws.

Depending on your country of residence, your rights may include.

• The right to be informed – that’s an obligation on us to inform you how we use your personal data (and that’s what we’re doing in this Privacy Notice);
• The right of access – that’s a right to make what’s known as a ‘data subject access request’ for a copy of the personal data we hold about you;
• The right to rectification – that’s a right to request that we correct personal data about you that may be incomplete or inaccurate (though we generally recommend first making any changes in your account if you have one);
• The right to erasure (also known as the ‘right to be forgotten’) – that’s where in certain circumstances you can ask us to delete the personal data we have about you (unless there’s an overriding legal reason we need to keep it);
• The right to restrict processing – that’s a right for you, in certain circumstances, to ask us to suspend processing personal data;
• The right to data portability – that’s a right for you to ask us for a copy of your personal data in a common format (for example, a .csv file);
• The right to object – that’s a right for you to object to us processing your personal data (for example, if you object to us processing your data for direct marketing); and
• Rights in relation to automated decision-making and profiling – that’s a right you have for us to be transparent about any profiling we do, or any automated decision-making.
• Withdraw Consent—that’s the right to revoke any consent you may have previously given us at any time, if we have collected and processed your personal data with your consent. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.
• File a complaint—that’s the right to file a complaint with a supervisory authority about our collection and processing of your personal data.

Exercising Your Rights

These rights are subject to certain rules around when you can exercise them. If you are located in the European Economic Area and wish to exercise any of the rights set out above, please contact us.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights) unless your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

We will respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated as required by law.

If you no longer wish to receive our marketing/promotional information, you may opt out as described in the Your Choices section above.

Finally, you have the right to make a complaint at any time to the supervisory authority for data protection issues in your country of residence. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact us first.

Please note that if you are an Authorized User or End User, we may forward your request to exercise your rights to the relevant Admin User with respect to the information controlled by such Admin User.

Social Media “Share” Buttons

On or through the Linkko Service we may provide third-party “share” buttons or other integrated tools that enable you to share certain content via social media sites (e.g., Facebook, Twitter, Instagram, YouTube, and LinkedIn). These “share” buttons may function as web beacons when you interact with the button. Please note that when you “share” using the buttons, you may send to the third party provider of the “share” button the information that you are viewing. If you are logged in to your account with the third party, then the third party may be able to link information or actions about your interactions with the Linkko Service to your account with the applicable third party provider. Please refer to each third party’s privacy policies to learn more about its data practices.

App Stores & External Websites

If you download the Linkko App, your app store (e.g., Apple App Store or Google Play) may collect certain information in connection with your use of the applications, including, without limitation, personal data, geolocational information, and other usage-based data. We have no control over the collection of such information by a third-party app store, and any such collection or use will be subject to that third party’s applicable privacy policies.

In addition, on or through the Linkko Service, we may provide or make available, for informational purposes only, links to other websites or resources, including, but not limited to, the websites of our Admin Users or Verification Sites that are hosted and controlled by the relevant Admin User, with which we do not have a contractual relationship and over which we do not have control (“External Websites”). Such links are not paid advertisements, nor do they constitute an endorsement by Linkko of those External Websites, and are provided only as a convenience. By clicking on links to External Websites, the operators of the External Websites may collect personal information. We are not responsible for the content or data collection practices of those External Websites, and the use of External Websites is subject to their respective terms of use and privacy policies.

Contact Us

If you have any questions about this Privacy Notice, have additional questions, you can contact us as follows support@linkko.io