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Privacy Policy

Last updated February 2024

This Privacy Policy applies to the online platform Linework (“Website”) and the associated software (“Software”) which
constitutes a unique service (jointly referred to as the “Service”)

The Service is operated by

LINEWORK USA, INC.
800 North State Street, Suite 304
City of Dover, County of Kent, Delaware – USA
ZIP Code 19901


The operator id further referred to as “We”, “Us” or “Linework”.

Privacy and information protection are the core principles on which our Service is based. This Privacy Policy sets out our current policies and commitment to information protection and privacy. According to this, we aim to collect and process only information strictly necessary for our relationships with customers, partners, and users to provide our Services.

We make our Privacy Policy available in our Service in its most recent version. Please review it carefully. By accessing and/or using the Service and accepting our Terms & Conditions, you confirm that you have read, understood, and agreed to this Privacy Policy.

If you have questions or comments about this Privacy Policy, you may contact our Data Protection Officer (DPO) by e-mail at dataprotection@linework.online or by mail using our address provided above.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? Unless you are registering using an e-mail address, we do not require you to provide your personal data to us to use the Service. We will never ask you to share your private keys or wallet seed. Never trust anyone or any site that asks you to enter your private keys or wallet seed. It is important to note that your blockchain transactions may be relayed through servers or nodes and will be publicly visible due to the public nature of distributed ledger systems. We may collect limited information about you from your devices or from various sources, as described below. We may collect personal contact information to provide customer assistance or other relevant services, which will be stored only for the time necessary to provide you those services. Using different services of the App ecosystem requires different data to be collected. Please read carefully any other Privacy Notice provided.


Do we process any sensitive personal information? We do not process sensitive personal information.

Do we receive any information from third parties? We receive information from third parties that you decide to share with us, as described below.


How do we process your information? We process your information to provide, improve, and administer our Service, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information. 

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information. 


How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe. 


What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights

How do you exercise your rights? The easiest way to exercise your rights is by clicking on this LINK or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.


Want to learn more about what Linework does with any information we collect? Review the Privacy Policy in full.

1. WHAT INFORMATION DO WE COLLECT?

We collect personal information that you voluntarily provide to us when you register on the Service, when you express an interest in obtaining information about us or our products or, in general, when you contact us. Our overriding policy is to collect as little user information (personal data included) as possible to ensure a private user experience when using the Service.

1.1 Information you give us

The personal information that we collect depends on the context of your interactions with us and the Service, the choices you make, and the products and features you use. The personal information we collect may include the following:

  • E-mail address (only if you register with your e-mail address and/or if you subscribe to our Newsletter);
  • Password (only if you register with your e-mail address);
  • Wallet seed (only if you register with Metamask or WalletConnect)


You will be provided with a random username, but if you want to manage your profile and add more information, then we will also collect the following:

  • Username;
  • First name;
  • Last name;
  • Location.


We are active on Twitter, Instagram, LinkedIn, and Reddit. Any information, communication, or material you submit to us via social media platforms is done at your own risk without any guarantee of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.

1.2 Visiting linework.online website: We employ the most secure and privacy compliant service analytics tool, if you need more information on the service we use you can visit https://matomo.org/privacy-policy/. Analytics are anonymized whenever possible and stored on Matomo cloud. IP addresses are not retained and stored for such analytics.

1.3 Communicating with Linework: Your communications with us, such as report request, bug reports, or feature requests may be saved by our staff.

1.4 Payment information. We rely on third parties to process transactions and must therefore share payment information with them.

1.5 Analytics: When you use our Service, we may collect certain information. We may use mobile analytics software to send crash information to our developers in order to rapidly fix bugs. Some platforms, such as Google’s Play Store or Apple’s App Store may also collect aggregate, anonymous statistics, which may be governed by their respective privacy policies and terms and conditions. Such statistics can include most commonly used devices and operating systems, total number of installs an uninstalls, and the total number of active users. Our application does not access or track any location-based information from your device.

1.6 Blog: we have a public blog on our website. If any of your personal information appears on our blog and you want it removed, contact us using dataprotection@linework.online.

Sensitive information
We do not process sensitive information.

Cookies
Like many businesses, we collect information through cookies and similar technologies. You can find out more about this in our Cookie Policy.

2. HOW DO WE PROCESS YOUR INFORMATION?

We process your personal information for a variety of reasons, depending on how you interact with our Service, including:

 

  • To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log into your account, as well as keep your account in working order.
  • To enable you to access and use the Service, and to process and complete transactions, and send you related information, including confirmations, technical notices, updates, security alerts, support, and administrative messages. We may process your information in order to provide to you, as a user, the full availability of our Service.
  • To send administrative information to you. We may process your information to send you details about our product and services, changes to our terms and policies, and other similar information.
  • To provide user-to-user communications. We may process your information in order to allows communication with other users. Please remember to not share any personal information with other user to improve your privacy.
  • To understand and analyse how you use our Service and develop new products, services, features, and functionality. We may process your information in aggregated and anonymised form in order improve our Service.
  • To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing e-mails at any time. For more information, see “What are your privacy rights?” 
  • To protect our Service. We may process your information to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
  • To comply with our Terms & Conditions or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency. We may process your information for general compliance purposes.
  • To contract with thirdparty API providers, including providing customer service, providing advertising or marketing services, providing analytics services. We may process your information to the extent necessary for the development of our services.
  • To save and protect an individual’s interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
If you are located in the European Economic Area, we only process your personal data when we have a valid “legal basis”, including:

  • Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.  
    This legal basis is used for the following process:
    • To send you marketing and promotional communications
    • To provide you information about our events and collaboration.

  • Performance of a contract. We may process your information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Service or at your request prior to entering into a contract with you. This legal basis is used for the following process:
    • To facilitate account creation and authentication and otherwise manage user accounts.
    • To enable you to access and use the Service, and to process and complete transactions, and send you related information, including confirmations, technical notices, updates, security alerts, support, and administrative messages.
    • To provide user-to-user communications.
    • To send administrative information to you.

  • Legitimate interest. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not overweight your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
    • To send you marketing and promotional communications.
    • To understand and analyse how you use our Service and develop new products, services, features, and functionality.
    • To protect our Service.
    • To contract with third-party API providers, including providing customer service, providing advertising or marketing services, providing analytics services.

  • Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

  • Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving threats to the safety of any person.
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We do not share the information that you provide to us with other organizations without your express consent, except
as described in this Privacy Policy. We disclose information to third parties under the following circumstances:

  • Affiliates. We may disclose your information to our subsidiaries and corporate affiliates (i.e. our family of companies that are related by common ownership or control) for purposes consistent with this Privacy Policy.
  • Business transfers. We may share the information when we do a business deal, or negotiate a business deal, involving the sale or transfer of all part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceedings.
  • Business partners. We may share your information with our business partners to offer certain products, services, or promotions.
  • Analytics partners. We use analytics services such as Matomo Analytics to collect and process certain analytics data. These services also may collect information about your use of other websites and online resources.
  • Compliance with law. We may share the information for legal, protection, and safety purposes. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (i) comply with applicable laws and regulations; (ii) respond to law enforcement requests and legal process, such as a court order or subpoena; or (iii) protect our rights, property, and safety, our employees, agents, customers, and others, including to enforce our agreements, policies and terms of use.
  • Service providers. We may share information with those who need it to do work for us. These recipients may include third party companies and individuals to administer and provide the service on our behalf, as well as lawyers, bankers and auditors.
  • Consent. You may permit us to share your information with other companies or entities of your choosing. Those uses will be subject to the privacy policies of the recipient entity or entities.
  • Other users. When you share personal information (for example, by posting comments, contributions, or other content to the Service) or otherwise interact with public areas of the Service, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile

4.1 DATA PROCESSORS

Third Party processors

AWS Services

  • Purpose: to provide the hosting services for the App.
  • Data processing location: France.


Matomo Analytics

  • Purpose: provide analytics on our Service
  • Data processing location: Europe


Tawk.to

  • Purpose: provide a software for the Customer Service
  • Data processing location: Ireland



4.2 NETWORK TRAFFIC THAT MAY GO THROUGH THIRD-PARTIES

The routing technology on which Linework relies allows Linework to bypass many censorship blocks, but in doing so your network traffic may go through third party networks, which we do not control. This could enable a third party to record your IP address or see that you are using Linework Service (the same information that your internet service provider is able to see). These third parties cannot see your actual data, which remain encrypted. By default, alternative routing is not used for Linework Service unless they detect that censorship measures are active on your network. Alternative routing can also be disabled in the settings panel of your mobile and desktop applications. However, doing so may cause you to be unable to accesso your account from a network that is censoring Linework.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set in our Cookie Policy.

6. DO WE MAKE ANY CROSS-BORDER INFORMATION TRANSFER?

Please be aware that none of your information processed by Linework per se will be transferred to, processed, and stored out of the EEA (European Economic Area).

Whenever we decide to proceed in information cross-border transfers, such transfers will be based on a data transfer mechanism recognized by the European Commission If the country and/or organization cannot provide an adequate level of personal information protection.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

We will keep your information as long as reasonably required for us to provide the requested customer support and inquiry services. If you delete or uninstall the App from your device or request that your information will be deleted, we still may retain some information that you have provided to us to maintain our App or to comply with relevant laws.

Provided that the Service is based on the blockchain technology, for the part managed by our App the following terms applies:

  • Users information: until the end of the contract/account deletion + 24 months;
  • Users with marketing consent: the period of marketing consent + 24 months;
  • Call recordings: typically 24 months or less;
  • Correspondence: until the end of the contract + 24 months.

8. HOW DO WE KEEP YOUR INFORMATON SAFE?

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the internet of information storage technology can be guaranteed to be 100% secure, se we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information, Although we will do our best to protect your personal information, transmission of personal information to and from our Service is at your own risk. You should only access the Service within a secure environment.

Your personal data are stored in servers located in the EU and protected with encryption and anonymization techniques.

9. DO WE COLLECT INFORMATIONS FROM MINORS?

We do not knowingly solicit data from or market to children under 18 years of age. By using the Service, you represent that you are at least 18. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data, we may have collected from children under age 18, please contact us at dataprotection@linework.online.

10. WHAT ARE YOUR PRIVACY RIGHTS?

Through your Account interface, you can directly access, edit, delete, or export personal data processed by the Company in your use of the Service.

If your Account has been suspended for a breach of our terms and conditions, and you would like to exercise the rights related to your personal data, you can make a request to our support team.

In case of violation of your rights, you have the right to lodge a complaint to the competent supervisory authority.

You have certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:

Opt-out. You may contact us anytime to opt-out of: (i) any consent you previously provided to us regarding the processing of your information; or (ii) the transfer of your information outside the EEA. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent. Please note that your use of parts of our Application may be ineffective upon opt-out. You may unsubscribe from our promotional emails via the link provided in the emails. Even if you opt out of receiving marketing and promotional messages from us, you will continue to receive administrative messages from us.

Access
. Provide you with information about our processing of your information and give you access to your information.

Amend
. You may update or correct any inaccuracies in your information by contacting us.

Restrict. Restrict the processing of your information.

Object. Object to our reliance on our legitimate interests as the basis of our processing of your information that impacts your rights.

Delete. In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you may request that we erase your data.

You can submit these requests by email to dataprotection@linework.online. We may request specific information from you to help us process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your information, you may contact us at dataprotection@linework.online or submit a complaint to the data protection regulator in your jurisdiction.


Cookies and similar technologies. Most web browser are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Service. For further information please see our Cookie Policy.

11. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice is a revised version of this privacy notice.

12. DO WE MAKE UPDATES TO THIS NOTICE?

We may update this privacynotice from time to time. The updated version will be indicated by an update “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification, We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.