This Privacy Policy explains how Datalinker (hereinafter referred to “we”) collects, uses and secures Personal Data of users and customers of Datalinker (hereinafter “you”) and the means by which is done.

This Privacy Policy also describes how Datalinker safeguards the confidentiality of the Personal Data processed.

1. Definitions

• Personal Data: data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
• Metadata: data about data, such as file names or information about when some data was sent, etc. Some metadata are explicitly edited by the user and others are automatically generated by the use of Datalinker.
• Data Controller: a person who determines the purposes for which and the manner in which Personal Data are, or are to be, processed.
• User: any living individual using Datalinker
• Customer: any company or individual that signs-up for Datalinker
• Service Providers / Data Processor: any person who processes the data on behalf of the Data Controller.
• Linker Service: any service that you provide on Datalinker either for sending or receiving data.
• Linker Session: any transmission between two individual users of Datalinker associated with the same or different linker services.
• Encryption / decryption key: An encryption key is a random string of bits used for encrypting data into a form that cannot be deciphered without the corresponding decryption key. It is however still possible to infer the approximate length of the data from the length of the encrypted form.

2. Personal Data

2.1 Types of collected personal data

When a Customer signs-up for Datalinker, we may ask to provide us with certain personally identifiable information (Personal Data) that can be used to contact or identify the Customer.

Personally identifiable information may include, but is not limited to:

• First name and last name
• Email address
• Phone number
• Address, State, Postal code, City
• Bank details
• Affiliated organizations

While using Datalinker, we may collect the following information:

• Information regarding the operating system and the operating system version
• Information regarding the browser and browser version
• Information regarding the used hardware
• The set time zone on the device
• The set language on the device
• Error messages
• The used version and build number of the app and its constituents used by you
• Crash logs
• Randomly generated IDs provided by the operating system for sending push notifications
• Date and time (UTC), the internal characterization of the functions or functionalities used by you, as well as the user-ID generated automatically and randomly at the first start or the installation of the app using the service
• Metadata about the data being transmitted, used for handling and display within the service and/or connected third-party services.
• Information provided by you such as the organization, services offered via Datalinker and billing information.

2.2 Data sent via datalinker

All data sent via Datalinker are encrypted with the exception of the metadata associated with it. The encryption is always performed on the sending device before transmission of the encrypted data to the Datalinker server. We cannot decrypt user data on our own for services other than datalinker analytics as the decryption key always remains in the sole possession and responsibility of the Customer.

This decryption key is and can never be stored on the Datalinker server. It is strictly forbidden to send unencrypted data to Datalinker. In the case of datalinker analytics, it is strictly forbidden to add data that may be used to identify a single individual such as e-mail addresses, internal user IDs, IDs used for loyalty programs or IP addresses.

Metadata does not contain personally-identifiable information. Metadata can be extended by the provider of a linker service. In this case, it is strictly forbidden to add data that may be used to identify a single individual such as e-mail addresses, internal user IDs, IDs used for loyalty programs or IP addresses.

2.3 Processing of child's data

Where the child is below the age of 16 years, processing shall be lawful only if and to the extent that consent is given or authorized by the holder of parental responsibility over the child.

2.4 Usage data

Usage data is statistical data which provides us with information about the use of Datalinker, such as the number of sessions opened between services and users and the type of data being transmitted. This usage data is completely non-identifying and will be disclosed to the provider of the linker services involved for inspection and analysis of linker service usage.

3. Uses of Data

We use your Personal Data for various purposes:

• To provide and maintain services offered by Datalinker
• To notify you about changes to Datalinker
• To monitor the usage of Datalinker
• To detect, prevent and address technical issues
• To gather analysis for linker service usage by you
• To provide you with detailed billing information

4. Rights of the User

4.1 Access to personal data

You are entitled to view, amend, correct, delete and limit the use of your Personal Data that we hold.

More precisely, you have the right to:

• Receive a copy of your Personal Data in commonly used electronic format
• Rectify any Personal Data held about you that is inaccurate
• Request the deletion of Personal Data held about you
• Request that the Data Controller, where possible, to transmit that data directly to another Data Controller.

Your identity may be verified before responding to such requests.

We do not charge for this service and your request will be processed within 10-15 business days of the date on which we receive it, and in any event no more than one month. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests.

4.2 Withdraw consent

You have the right to withdraw your consent at any time but this will not affect the lawfulness of processing based on consent before your withdrawal.

4.3 Right to complain to a data protection authority

If you are not satisfied with our response or believe we are processing your Personal Data not in accordance with the law you can complain to the EU Data Protection Authority of the country in which you live.

5. Data controller

Our Data Controller is:

Mr. Moritz DIETSCHE
Gewerbestrasse 24
CH – 4123 Allschwil
+41 61 511 52 71
privacy@datalinker.io

6. Service Providers / Data Processor

We may employ companies and individuals to provide services on our behalf and to assist us in developing Datalinker.

These companies and individuals have access to your Personal Data only to perform these tasks on our behalf and are obliged not to disclose or use it for any other purpose. Your Personal Data are only processed by the authorized personnel.

7. Security of Data

We have a data protection regime in place to oversee the effective and secure processing of your Personal Data.

In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure your Personal Data.

8. Retention of Data

We are required under Swiss law to keep your Personal Data for ten years after which time it will be destroyed. This may include but is not limited to:

• Commercial correspondences
• Invoices
• Contracts
• Records and any other documentation relating to customs operations

Other Personal Data will be retained only for as long as is necessary for the purposes set out in this Privacy Policy.

9. Transfer of Data

For the purposes of IT hosting and maintenance your information, including your Personal Data, may be transferred to and maintained on servers located within the European Union (Netherlands) or Switzerland.

We take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy.

10. Disclosure of Data

We only to disclose information to third parties under the following circumstances:

• As required by law or other legal process
• When explicitly requested by public authorities (courts, government agencies)

11. Further Processings and Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will let you know via email and / or a prominent notice on our website prior to the change becoming effective.

If we wish to use your Personal Data for a new purpose, not covered by this Data Security and Privacy Policy, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.