Privacy Policy

LINK Messaging AG is a service-oriented company specialized in providing Telecom and Marketing services. Bulk SMS Wholesale allows direct connection to LINK Messaging SMS Gateway that allows you to send large quantities of SMS messages worldwide quickly, efficiently and securely. LINK Messaging Bulk SMS service is ideal for SMS Aggregators, ISP’s, telecom companies and mobile operators which would like to send A2P (Application to Person) or P2P (Person to Person) messages to their customers. We provide this Privacy Policy to inform you of our policies regarding the collection, use, disclosure and protection of information. This Privacy Policy applies to all of the LINK Messaging websites or mobile and messaging features or services that link to it (“LINK Messaging Services”).

Topics that will be discussed in this Privacy Policy are listed below:

• Information We Collect from You Directly
• Information We Gain from Our Customers
• How We Share Information
• Security of Your Data
• Access to Your Information, Correction and Right to Be Forgotten
• Legal Interception and Retention Period
• Cookies and Analytics
• Our Policy Towards Children
• Changes to Our Privacy Policy
• How to Contact Us

Information We Collect from You Directly – LINK Messaging as Data Controller

When we collect some personal data from you directly we are acting as Data Controller. Here you can see how, for what purposes and what personal data we collect from you: when you fill out our Contact Forms, register to our Newsletter, contact us directly or register to our services. In section that considers Security of your data you can find out where we store and how we protect your data. For any of these situations we are highly determined to guarantee security and appropriate use of your data.

Contact Forms

When you fill out our Contact Form on any LINK Messaging’s website, either to ask us something about our products or to request a recall or offer, you are providing us with your personal data like: e-mail address, first name, last name, etc. We will use this data only to provide you with appropriate answer and to give you adequate update regarding our products. Depending on subject of your request, we might ask you to fill out some additional fields, like company name, to assure that you are legitimate potential customer.

Newsletter

If you want to subscribe to our Newsletter we will need to collect your e-mail address. We will use your e-mail address for sending you our Newsletter information and give you proper update regarding our products and services and to inform you about any news that could be of interest to you as our subscriber.

Direct contact

When you ask for assistance from our Customer Support team, or make any kind of direct contact with us, we may collect and store contact information you provide (generally your name and e-mail address), as well as information about your usage of LINK Messaging Services so that we can appropriately respond to inquiries. We will also store the correspondence and any related information.

Registration to our services

In the process of creating your account, we collect and store your personal data which are then bound to your user account. This process is led and managed by our Customer Support team. For the purposes of security issues mitigation and auditing, in case that some problem occurs, we also track changes you make in your account during the usage of our services. When you create or confirm activation of your account on any of our websites, we will collect and store your personal data in order to provide you with requested service. All collected data will be used only for the purposes of providing you specified service and appropriate support.

Job Applications and HR

Every time you apply for a position in LINK Messaging, we collect, process and store your personal data, including: your e-mail address, name, surname and information in your CV, during selection process period. Personal data you sent us, either using our application form or sending your application to our job application e-mail address, will be only used for potential employment purposes. After selection process is finished, we will store your data during six months period in case there is another suitable position for you. After that period your personal data will be erased from our systems. We also collect and store personal data of our employees, both on our servers and hard copy due to legal obligations.

Information We Gain from Our Customers – LINK Messaging as Data Processor

In accordance with our Data Protection Agreement we process personal data obtained from our customers only to provide requested service and appropriate support. In these cases, we act as Data Processor. Our customers are Data Controllers and they have provided us with personal data they collected lawfully as regulated in our Terms of Use. For providing our Bulk SMS services we only require and process data subjects’ phone numbers and text of processed SMS. We store and process our customer’s personal data in ISO 27001 and PCI DSS certified data center in Zurich and we do not transfer any data outside EEA area, unless it is specifically requested by our customer for personal data they are responsible for.

How We Share Information

In some cases we might share personal data and information we colected or we gained from our customers, as described in previos sections of this Policy. In this section we provide you with information in which cases and to whom we provide personal data and what we do in order to maintain privacy of shared data.

Link Mobility GROUP

Link Mobility GROUP is a group of companies that are processing, either collected or customers’ personal data, for providing mutual services. Link Mobility GROUP members apply the same information security and privacy measures following GDPR requrements and information security and privacy related practices. In order to provide mutual services, with other group members, LINK Messaging might share personal data of it’s customers to another member of Link Mobility GROUP. Since we are providing telecomunication related sevices LINK Messaging might also engage third party telecom supplier, from the group, or telecom operator. Note that we will make sure that there is signed DPA between LINK Messaging and any supplier that is not a part of our group.

Our Sub-Contractors

There are cases where we use services of third party companies that are somehow involved in processing of personal data. List of these sub-contractors are given on our page Sub Contractors. These companies process only personal data we collected and they do not process any personal data of our customers. If you provide us with your personal data we might use some software or service of Sub-Contractor and in these cases, we are Data Controllers (cases described in previous section) and Sub-Contractors are acting as Data Processors. LINK Messaging performs due diligence on the information security practices and data protection compliance of all sub-contractors and requires each to commit to written obligations (Data Protection Agreement) regarding their security controls and applicable regulations for the protection of personal data.

Legal Requests and Safety

We may transfer and disclose information, including personal information and usage information and your device identifier (including IP address), to third parties to comply with a legal obligation: when we believe in good faith that the law requires them; at the request of governmental authorities conducting an investigation; to verify or enforce our Terms of Use or other applicable policies; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, users of the LINK Messaging services or the public. We may also use device identifiers to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers or law enforcement agencies, in our discretion. Such disclosures may be carried out without notice to you.

Change of Ownership or Control

LINK Messaging reserves the right to disclose and transfer user information, including personal information, in connection with a corporate merger, consolidation, restructuring, the sale of certain stock and/or assets, or other corporate change including, without limitation, during the course of any due diligence process.

Security of Your Data

We take precautions to protect your information. When you submit personal information via the website, your information is protected both online and offline. While we use encryption to protect sensitive information transmitted online, we also protect your information offline. Only employees who need the information to perform a specific job (for example, billing or customer service) are granted access to personally identifiable information. The computers/servers in which we store personally identifiable information are kept in a secured environment.

We implemented technical and organizational security measures for the protection of personal data before processing of any personal data and additional security measures as mutually agreed with our customers. LINK Messaging has been adopting security measures including encryption, pseudonymization, resilience of processing systems and backing up personal data in order to be able to reinstate the system.

Security and privacy of our information, including personal data as important information asset, is build and based on our Information Security Policies and Procedures and applied measures in accordance to these documents. All of organizational and technical measures are applied in accordance with ISO 27001 standard and GDPR requirements.

Access to Your Information, Correction and Right to Be Forgotten

You have the right to request a copy of the information that we hold about you. If you would like a copy of personal data we have on you, where we store it and how we use it please send us your request. We might make a small charge for this service. We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate or use your right ̎to be forgotten ̎ with consideration of lawfull interception bounds. You can also unsubscribe from specificed channel or service using „Unsubscribe your data“ option on our website or you can send your request to our DPO by sending an e-mail to jan.wieczorkiewicz@linkmobility.com. Requests regarding changes or deletation of any data we gained from our customers have to come from that customer as described in our Data Protection Agreement.

Retention Period and Legal Interception

The duration of the processing of data we gained from our customers is limited to the duration needed to perform our obligations considering Contract of providing services between our companies, unless a legal obligation applies. Our obligation with regard to the data processing shall in any case continue until the data has been properly deleted or has been returned at the request of our customer. For the purposes of fulfillment of our legal obligation, we will store data for the period of six months in separate, encrypted instance, in case of legal interception request. This applies also to any request, regarding unsubscribing from our services, we obtain from any data subject. Their user accounts will be removed from our services but their data will be stored for additional six month on encrypted instance, after expiration of this period data will be permanently deleted from our systems.

Cookies and Analitics

Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. This information is used to track visitor use of the website and to compile statistical reports on website activity. You can set your browser not to accept cookies if you are not confortable with them. On our sites we are using Cookies listed below:

Cookie provided by	Cookie name	Expiration time	We use it for
PHP session cookie	PHPSESSID	Session	The PHPSESSID cookie is native to PHP and enables websites to store serialized state data.
Matomo	_pk_id.1.a91e	1 year	These cookies are used by the analytics software Matomo to allow us to count page visits and traffic sources, so we can measure and improve the performance of our site
Matomo	_pk_ses.1.a91e	30 min
LINK	saved_lang	60 min	Save language of our visitors
Google Analytics	_ga	2 years	Helps to identify sessions of visitors
Google Analytics	_gid	1 day
Google Analytics	__utma	2 years
Google Analytics	_utmb	30 min	Helps to identify new visitors to the Site
Google Analytics	__utmc	Session
Google Analytics	__utmt_UA-47738979-13	10 min	Helps to throttle traffic rate for Google servers
Google Analytics	_gat_UA-47738979-13	6 months
Google Analytics	__utmz	1 min	Helps to identify the traffic source of visitors
Google	1P_JAR	1 month	Google advertising cookie used for user tracking and ad targeting purposes
Google Adwords	HSID	2 years	Provides information about the effectiveness of Google Adwords
Google Adwords	NID	6 months
Google maps	APISID	2 years	Google maps associated cookies are used to display a user-friendly map and location designations.
Google maps	SIDCC	3 months
Google maps	SSID	2 years
Google maps	SAPISID	2 years
Google maps	SID	2 years
Google Tag Manager	_dc_gtm_UA-66028946-1	1 min	These cookies collect information in an anonymous form. This includes the number of visitors to the site
LinkedIn	BizoID	6 months	LinkedIn Ad analytics
LinkedIn	bcookie	2 years	Browser ID cookie
LinkedIn	bscookie	2 years	Secure browser ID cookie
LINK	lidc	1 day	Used for routing
LinkedIn	UserMatchHistory	6 months	LinkedIn Ad analytics

We use Google Analytics to measure and evaluate access to and traffic on the Public Area of the Site, and create user navigation reports for our Site administrators. Google operates independently from us and has its own Privacy Policy, which we strongly suggest you to review. Google may use the information collected through Google Analytics to evaluate Users’ and Visitors’ activity on our Site. For more information, see Google Analytics Privacy and Data Sharing. We also use Matomo that helps us gather and analyze some statistic information about our users and track key performance Indicators such as: visits, goal conversion rates, downloads, keywords, etc.

We implemented Matomo service on premise and we control and protect any analysis and data we collect from Matomo. We take measures to protect the technical information collected by our use of Google Analytics and Matomo. Colected data will only be used for analitics and on a need to know basis to resolve technical issues, administer the site and identify visitor preferences. In these cases, the data will be in non-identifiable form. We do not use any of these information to identify visitors or users.

Our Policy Towards Children

The Services are not directed to individuals under 16. We do not knowingly collect personal information from children under 16. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact our support services.

Changes to Our Privacy Policy

LINK Messaging may update this policy from time to time and any changes will be effective upon posting. We will notify you about significant changes in the way we treat personal information by sending a notice to the primary email address specified in your LINK Messaging account or by placing a prominent notice on our site. However, we will use your personal information in a manner consistent with the Privacy Policy in effect at the time you submitted the information, unless you consent to the new or revised policy.

How to Contact Us

Please contact us with any questions or comments about this Policy, your personal data or your consent choices. If you have any concerns to adress, any questions or complaints about this Policy or your personal data, you may contact Data Protection Officer of LINK Messaging by sending an email to jan.wieczorkiewicz@linkmobility.com.