1. What Information Do We Gather?
When you use our app, (“App”) we collect only the information and personal data you have agreed to provide to us that is necessary to identify your needs and to provide you with better service. Through your use of the App or registration as a new user, we may request personal data including, but not limited to:
- Name, company and job title
- Contact information including email address and cell phone number
- Demographic information including postal code, product preferences and interests
- Internet Protocol (“IP”) Address and other persistent identifiers
- Other information relevant to customer surveys and offers
- If you become a registered user or if you conduct transactions through this App, we will collect information about the transactions you engage in while on the App and other potential activities on the App. This information may include, without limitation, areas of the App that you visit, transaction type, content that you view, download or submit, transaction amount, payment, and billing information as well as the nature, quantity and price of the goods or services you exchange and the individuals or entities with whom you communicate or transact business.
Some of this personal data, including name, company and contact information, will only be collected if you voluntarily provide it during the user registration process. We may also track information such as the domain name and the name of the web page from which you entered our App, and how much time you spend on each of our pages. We collect information that is combined with other web visitors’ information, such as how many times visitors click on each web page and the methods by which our App was found.
2. What Do We Do with the Personal Information We Collect?
You will be asked to provide personal data in certain fields on this App that allow you to be able to use our Services. The personal data we collect is used only for the purpose we state at the time of collection or for purposes contained below. For example, our uses may include, but are not limited to, the following:
- To process transactions. Netlink uses personal data such as name, physical address, telephone number, email address, and company/institution to engage in interactions with you, including contacting you about your transactions with the App.
- To process payments. We use financial/credit card and payment information to process your order and may need to share some of this information with delivery services, credit card clearing houses, and other third parties to complete the transaction.
- To provide support or other services. NETLINK may use your personal data to provide you with support or other services that you have ordered or requested. NETLINK may also use your personal information to respond directly to your requests for information, including registrations for newsletters, webinars, or other specific requests, or pass your contact information to the appropriate NETLINK distributor or reseller for further follow-up related to your interests.
- To provide information based on your needs and respond to your requests. NETLINK may use your personal data to provide you with notices of new product releases and service developments.
- To select content, improve quality, and facilitate use of the websites. NETLINK may use your personal data, including the information gathered as a result of site navigation and electronic protocols and cookies (including third-party cookies), to help create and personalize website content, improve website quality, track marketing campaign responsiveness, evaluate page response rates, conduct usability testing, and facilitate your use of the websites (for example, to facilitate navigation and the login process, avoid duplicate data entry, enhance security, keep track of shopping cart additions, and preserve order information between sessions).
- To serve personalized advertising to you. We don’t share your personal data with advertisers without your consent. We allow advertisers to choose the characteristics of users who will see their advertisements, and we may use any of the non-personally identifiable data attributes we have collected to select the appropriate audience for those advertisements. When you click on or otherwise interact with an advertisement, there is a possibility that the advertiser may place a cookie in your browser and that your attributes meet the criteria the advertiser selected.
- To assess usage of Netlink products and services. NETLINK may track your usage of NETLINK products and services to determine your level of usage, and those usage statistics may be made available to NETLINK’s content licensors and your company/institution.
- To communicate with you about events. We may communicate with you about events hosted or co-sponsored by NETLINK or one of our business associates. This may include information about the event’s content, event logistics, payment, updates, and additional information related to the event. Information you provide when registering for or participating in a conference managed or co-sponsored by parties, other than or in addition to NETLINK may be shared with those parties, and the treatment of such information is further subject to the privacy policies of those parties. NETLINK and its conference co-sponsors may contact you after the event about the event, subsequent iterations of the event and related events. Please note that NETLINK event organizers, co-sponsors, exhibitors, and other third parties may directly request your personal information at their conference booths or presentations. Providing your information to them is optional, and you should review their privacy policies to address your particular needs and concerns about how they will treat your personal information.
- To update you on relevant NETLINK benefits, programs, and opportunities. NETLINK may communicate with you regarding relevant NETLINK benefits, programs, and opportunities available to you.
- To engage with third parties. NETLINK may share your personal data with third parties in connection with services that these individuals or entities perform for or with NETLINK. These third parties are restricted from using this data in any way other than to provide services for NETLINK or for the collaboration in which they and NETLINK are contractually engaged (for example, hosting a NETLINK database or engaging in data processing on NETLINK’s behalf, or mailing you information that you requested). These third parties are carefully selected by NETLINK and obligated to keep your data secure. From time to time, we may also share your information with third parties whom we think might provide content, products, or services of interest to you.
- To get feedback or input from you. In order to deliver products and services of most interest to our customers, from time to time, we may ask members, customers, volunteers, and website visitors to provide us input and feedback (for example through surveys, usability studies, focus groups).
- To protect Netlink information assets as well as your own personal data. The NETLINK Information Security Program protects the confidentiality, integrity, and availability of NETLINK information assets by following a risk management approach based on policies, standards, guidelines, and procedures to meet security objectives while supporting business and operational goals.
- To assist in Business Transfers. As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions, (including in contemplation of such transactions) user information may be among the transferred assets. If a portion or all of NETLINK’s assets are sold or transferred to a third-party, customer personal data (including your email address) would likely be one of the transferred business assets. If such transfer is subject to additional mandatory restrictions under applicable laws, NETLINK will comply with such restrictions.
To the extent that we collect certain demographic information about you, we may use this information in our market research, but we will do so only after we “anonymize” or “pseudonymize” the data, i.e., remove information that would confirm your identity. We will not use your personal data, however, to send commercial or marketing messages to you unless we have a legal basis for doing so, such as your consent or a contract with us for which, in either case, you will have the ability to opt out of by sending an email to firstname.lastname@example.org.
This App does not collect personal data when you browse the App and request pages from our servers unless you voluntarily and knowingly provide such information to us. This means that we will not know your name, your email address, or any other personal data just because you browse the App unless you:
- access the App from a link in an email that we have sent to you;
- have created a profile and you either log-in to your account or choose to be remembered via your cookie or your web-enabled mobile device.
In these cases, we will know who you are based on the information you previously supplied to us. When you request a page from our App, our servers log the information provided in the HTTP request header including the IP number, the time of the request, the URL of your request and other information that is provided in the HTTP header. We collect the HTTP request header information in order to make our App functions correctly and provides you with the functionality that you expect to see. We also use this information to personalize content presented to you, better understand how visitors use our App and how we can better tune it, its contents, and functionality to meet your needs. We only use your personally identifiable information for those activities listed at the time you submit your information to us. For example, if you provide us with an email to inform you of special events, then that is what we will use your email address to do. If we would like to use your personally identifiable information for an unrelated activity, we will first request your consent to do so.
3. Who Can Use the Information We Collect and How?
We may provide your personal data to third parties, or third parties may collect personal data from you on our behalf if we have contracted with that third party to provide some part of the information or service that you have requested. Other than those who act on our behalf and except as explained in this Policy, personal data you provide at this App will not be transferred to unrelated third parties, unless we have a legal basis to do so. However, please note that personal data provided to this App is subject to disclosure pursuant to judicial or other government subpoenas, warrants or orders. We will only provide this information after approximately two weeks following receipt of a valid subpoena or other legal process in a civil case.
4. How Do We Protect the Personal Information We Collect?
Security of Personal Data
We are committed to protecting the security of your personal data. Depending on the circumstances, we may hold your information in hard copy and/or electronic form. For each medium, we use technologies and procedures to protect personal data. We review our strategies and update as necessary to meet our business needs, changes in technology, and regulatory requirements. We take our security obligations seriously and so should you. While we are responsible for maintaining the security of this App, you must also access and use this App in a manner that is responsible and secure. We adhere to internationally recognized security standards and our information security management system relating to client confidential data is independently certified as complying with the requirements of SSAE 18 Type 2 SOC 2 relevant to Security and PCI DSS 3.2 Data Security Standards. In addition, we have implemented a series of policies, procedures, and training to address data protection, confidentiality, and security, and we update and review the appropriateness of these measures on a regular basis.
Storage and Transfer of Personal Data
NETLINK also collaborates with third parties such as cloud hosting services and suppliers located around the world to serve the needs of our business, workforce, and customers. In some cases, we may need to disclose or transfer your personal data within NETLINK or to third parties in areas outside of your home country. When we do so, we take steps to ensure that personal data is processed, secured, and transferred according to applicable law.
If you would like to know more about our data transfer practices, please contact email@example.com.
Retention of Personal Data
NETLINK retains personal data for as long as necessary to provide the services and fulfill the transactions you have requested, or for other business purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. We are required by law to keep some types of information for certain periods of time (e.g., statute of limitations). If your personal data is no longer necessary for the legal or business purposes for which it is processed, we will generally destroy or anonymize that information.
5. What Are Your Rights Regarding Your Personal Data?
We respect your right to access and control your personal data. You have choices about the data we collect. When you are asked to provide personal data that is not necessary for the purposes of providing you with our Products and Services, you may decline. However, if you choose not to provide data that is necessary to provide a Service, you may not have access to certain features, Sites, Products, or Services.
Access to personal data: In some jurisdictions, you have the right to request access to your personal data. In these cases, we will comply, subject to any relevant legal requirements and exemptions, including identity verification procedures. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data. We may also charge you a fee for providing you with a copy of your data (except where this is not permissible under local law).
Correction and deletion: In some jurisdictions, you have the right to correct or amend your personal data if it is inaccurate or requires updating. You may also have the right to request deletion of your personal data. Please note that such a request could be refused because your personal data is required to provide you with the products or services you requested, e.g. to deliver a product or send an invoice to your email address, or that it is required by the applicable law.
Portability: If you reside within the European Union, you have the right to ask for a copy of your personal data and/or ask for it to be ported to another provider of your choice. Please note that such a request could be limited to the only personal data you provided us with or that we hold at that given time and subject to any relevant legal requirements and exemptions, including identity verification procedures.
Marketing preferences: If you have provided us with your contact information, we may, subject to any applicable Spam Act or similar regulation, contact you via email, postal mail or telephone about NETLINK products, services and events that may be of interest to you, including newsletters.
E-mail communications you receive from NETLINK will generally provide an unsubscribe link allowing you to opt-out of receiving future email or to change your contact preferences. E-mail communications may also include a link to directly update and manage your marketing preferences. If you have an online account with NETLINK, you can also change your contact preferences through firstname.lastname@example.org Please remember that even if you opt out of receiving marketing emails, we may still send you important Service information related to your accounts.
If you are in the EU/UK, you have certain additional privacy rights that are listed below in Section 12.
6. How Do You Opt-out of Personal Information Sharing with Our Business Partners?
For more information about how targeted Network Advertising works, please visit: http://www.youradchoices.com/ or http://www.networkadvertising.org/understanding-online-advertising.
You may opt-out of third-party targeted advertising or analytics in two ways: 1) By directly notifying a Network Advertising service provider via its opt-out tools (Please see above), or 2) using your browser’s Do Not Track (DNT) settings to indicate that you do not wish to receive targeted advertising based on your overall internet usage. For more information about DNT and how it works, please visit the Future of Privacy Forum’s website: http://www.allaboutdnt.com/.
We will make a good faith reasonable effort to honor your DNT browser settings for opting out of receiving targeted third-party advertising based on your overall Internet usage. Please note that various browsers frequently update technology or change their settings and business practices without advance notice, and we may not have the latest information on how to honor your preferences. If you exercise either opt-out option – the cookie opt-out or the browser opt-out – you will continue to receive advertising, but such advertising may not relate to your specific interests, previous purchases, or search history.
However, you cannot opt-out of our contextual analytics and advertising, which is based on your usage of only our Services. We will continue to serve you contextual advertising. We will also continue to monitor your usage and search or transaction history to provide us with analytics on how well our Services, features, and activities are functioning and used. We will also share this information in an aggregated or anonymized form (meaning that no one individual person can be identified) within NETLINK.
You can also opt out of our marketing emails at any time by contacting us at email@example.com or by sending us a post card to “OPT OUT”, Netlink Software Group America, Inc. – 999 Tech Row, Madison Heights, MI 48071.
7. How Do You Correct and Update Your Personal Data?
We aim to keep all personal data that we hold accurate, complete and up to date. While we will use our best efforts to do so, we encourage you to tell us if you change your contact details. If you believe that the information, we hold about you is incorrect, incomplete or out-of-date, please contact firstname.lastname@example.org.
You can change or correct your personal data at any time. Just send an email with your old information and your corrections to email@example.com with “Correction” in the subject line.
We understand the importance of protecting the privacy of all individuals, especially the very young. Our services are intended for United States audiences over the age of 18. Our App and its Services are not directed to children, and you may not use our Services if you are under the age of 13. You must also be old enough to consent to the processing of your personal data in your country (in some countries we may allow your parent or guardian to do so on your behalf). You must be at least 16 years of age to use the App Forums. Subscribing to our Services is restricted to adults who are either 18 years of age or older or as otherwise legally defined by the country of your residency.
9. What Happens When You Link to a Third-Party Web Site?
11. Your California Privacy Rights
If you are a California resident and have an established business relationship with us and want to receive information about how to exercise your third-party disclosure choices, you must send a request to the following address with a preference on how our response to your request should be sent (email or postal mail). You may contact us in two ways. Send an email to firstname.lastname@example.org.
Alternatively, you may contact us at:
Netlink Software Group America Inc.
999 Tech Row,
Madison Heights, MI 48071, USA
Attn: Your California Privacy Rights
c/o Privacy Administrator
For requests sent via email, you must put the statement “Your California Privacy Rights” in the subject field of your email. All requests sent via postal mail must be labeled “Your California Privacy Rights” on the envelope or post card and clearly stated on the actual request. For all requests, please include your name, street address, city, state, and zip code. (Your street address is optional if you wish to receive a response to your request via email. Please include your zip code for our own recordkeeping.) We will not accept requests via the telephone or by facsimile. We are not responsible for responding to notices that are not labeled or not sent properly, or do not have complete information.
If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, California Business and Professions Code Section 22581 permits you request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to email@example.com Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.
12. Your European Union Privacy Rights
If you are in the European Union, under the General Data Protection Regulation (Regulation EU 2016/679) (also known as GDPR), you may have certain rights as a data subject. A data subject is a person who can be identified by a name, identification number, location, online identifier, or other physical, physiological, genetic, mental, economic, cultural or social identity of the person. Under the GDPR, personal data is information that relates to a data subject. The processing of your data is either based on your consent or in case the processing is necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract, cf. GDPR art. 6(1)(a)-(b). If the processing is based on your consent, you may at any time withdraw your consent by contacting us at firstname.lastname@example.org.
In order to enter into a contract to use our Services, you must provide us with the required personal data. If you do not to provide us with all the required information, it will not be possible to deliver the Service.
To request information about or avail yourself of those rights, please send an email to email@example.com with “GDPR Request” in the subject line. In the email please describe, with specificity, the GDPR right you are requesting assistance with. Please note additional information may be requested prior to initiation of a request and that NETLINK reserves the right to charge a fee with respect to certain requests. Upon NETLINK’s completion of its review you will be notified if your request has been granted, denied, or exemptions apply.
The Data Controller and Processor for Personal Data
A Data Controller is a company that collects people’s personal data and makes decisions about what to do with it. A Data Processor is a person or company that deals with personal data as instructed by a Data Controller for specific purposes and services. The Data Controller’s information is as follows:
Netlink Software Group America Inc.
999 Tech Row,
Madison Heights, MI 48071, USA
The Data Processor’s information is as follows:
Netlink Software Group America Inc.
999 Tech Row,
Madison Heights, MI 48071, USA
The Purpose and Legal Basis for Collection
The Legitimate Interest
In Netlink’s adherence with the GDPR, we have a legitimate interest which allows us to process your personal data. This legitimate interest of Business purpose.
Recipients of Your Data and Categories of Data Collected
Data Protection Officer
Netlink’s parent company Netlink is headquartered in 999 Tech Row, Madison Heights, MI 48071. COMPANY has appointed an internal Data Protection Officer/ the following contact person for you to contact if you have any questions or concerns about the Company’s personal data policies or practices. COMPANY’s Data Protection Officer’s/Contact’s name and contact information are as follows:
Data Protection Officer
999 Tech Row, Madison Heights,
Transferring personal data from the EU to the US or other jurisdictions
The 8 Rights of Individuals
Under the GDPR, you will benefit from increased rights including:
- The right to be informed
The right to be informed encompasses the obligation to provide you with ‘fair processing information.’ It emphasizes the need for transparency over how your personal data is used.
- The right of access
Under the GDPR, you will have the right to obtain confirmation that your data is being processed, access to your personal data, and other supplementary information.
- The right to rectification
You are entitled to have your personal data rectified if it is inaccurate or incomplete.
- The right to erasure
The right to erasure is also known as ‘the right to be forgotten.’ You may request the deletion or removal of personal data where there is no compelling reason for its continued processing.
- The right to restrict processing
We are permitted to store your personal data, but not further process it without consent.
- The right to data portability
The right to data portability allows you to obtain and reuse your personal data for your own purposes across different services. You may move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability.
- The right to object
You have the right to object to processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling), direct marketing (including profiling); and processing for purposes of scientific/historical research and statistics.
- Rights in relation to automated decision making and profiling
The GDPR provides safeguards for you against the risk that a potentially damaging decision is taken without human intervention.
13. Google Action – Netlink AI
Netlink (“us”, “we”, or “our”) operates the “Netlink AI” the Google Assistant App (the “Service”).
Information Collection and Use
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to, your email address & name.
We collect this information for the purpose of providing the Service, identifying and communicating with you, responding to your requests, and improving our services.
We may also collect information that your browser sends whenever you visit our Service (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, and the pages of our Service that you visit, the time and date of your visit, the time spent on those pages and other statistics.
Do Not Track Disclosure
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
The security of your Personal Information is important to us, and we strive to implement and maintain reasonable, commercially acceptable security procedures and practices appropriate to the nature of the information we store, in order to protect it from unauthorized access, destruction, use, modification, or disclosure.
However, please be aware that no method of transmission over the internet, or method of electronic storage is 100% secure and we are unable to guarantee the absolute security of the Personal Information we have collected from you.
Only persons aged 18 or older have permission to access our Service. Our Service does not address anyone under the age of 13 (“Children”). We do not knowingly collect personally identifiable information from children under 13. If you are a parent or guardian and you learn that your Children have provided us with Personal Information, please contact us at firstname.lastname@example.org If we become aware that we have collected Personal Information from a children under age 13 without verification of parental consent, we take steps to remove that information from our servers.
14. What If You Have Questions?
If you have questions or concerns regarding this statement, you should first contact us via email at email@example.com.