Last update : September 2020

This privacy policy (the "Privacy Policy") governs the way in which LINC Technology Partner Sàrl, a limited liability company under Luxembourg law, established and having its registered office at 55, Rue de Luxembourg, L - 4391 Pontpierre and registered with the Trade and Companies Register, Luxembourg, section B, under number 234512 ("TECHNOLOGY PARTNER") processes personal data collected in the context of the https://www and the applications accessible or used through this site, including, where applicable, the mobile applications associated with the site (the "Platform") in its capacity as data controller.

  1. Compliance with data protection legislation

TECHNOLOGY PARTNER undertakes to make every effort to comply with the laws and regulations governing the processing of personal data, including, but not limited to, Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and any other applicable national laws or regulations governing the processing of personal data.



  1. Who are the data subjects?

The Platform provides information on the services and products offered by TECHNOLOGY PARTNER and enables interested customers and prospects to contact TECHNOLOGY PARTNER via a contact form.

The persons concerned, i.e. the persons whose personal data TECHNOLOGY PARTNER collects are visitors to the Platform who may be private individuals, independent professionals or representatives (managers, employees, etc.) acting as a contact point for legal entities (the "Users").

Users' personal data is submitted to TECHNOLOGY PARTNER under the responsibility of the Users themselves, who undertake, by transmitting it to TECHNOLOGY PARTNER, to have all the legal authorisations to do so. The data will only be used by TECHNOLOGY PARTNER if it is necessary for the provision of its services by TECHNOLOGY PARTNER.

  1. What personal data is collected by TECHNOLOGY PARTNER and why is it used?

- Contact details : Users' contact details correspond to the User's email address. The provision of contact details is mandatory to enable TECHNOLOGY PARTNER to contact Users following the submission of their contact form. They will be used by TECHNOLOGY PARTNER to respond to Users' requests and may be used to send Marketing Communications (see point 4. below for more details).

- Content of Users' messages submitted within a form accessible on the Platform or via any other chosen means of communication: Users may contact TECHNOLOGY PARTNER by various means, including via Social Networks, to request additional information, solve a problem encountered, participate in a competition or make a complaint, for example. TECHNOLOGY PARTNER will process this data to enable it to respond to requests made by Users.

- Content and metadata: these elements correspond to the operations carried out on the platform, i.e. the data flows generated by Users' activity. In principle, these data are not used by TECHNOLOGY PARTNER, whose Platform is simply the medium for the exchange of these data. However, TECHNOLOGY PARTNER reserves the right to use this data to personalise the Customer's browsing experience and Marketing Communications.

- Technical Information: This technical information corresponds to browser type, language settings, country and time zone, ID and cookie settings, type of device used for connection, hardware model and operating system, unique identifiers such as IDFA (for iOS), MAC address or user ID, IP addresses and mobile network information, Social Network sharing, geolocation data. TECHNOLOGY PARTNER never uses the precise GPS location of the User's device except with the User's explicit consent. This data is used to ensure optimal use of the Platform and to personalise the Platform for each User (by adapting the language in which the Platform is displayed, for example, or by offering the Platform in a mobile version if the connection comes from a mobile phone).

Some of this data is mandatory for TECHNOLOGY PARTNER to provide its services or to contact the User again after he/she has made contact via the Platforms. They will always be specifically identified in the forms used to submit these data. Subject to any provisions to the contrary within this Privacy Policy, this data is processed on the basis of the performance of the contract entered into with TECHNOLOGY PARTNER or within the framework of a pre-contractual relationship. Other data is provided by Users if they consider it appropriate and will only be used by TECHNOLOGY PARTNER if it is necessary for the purposes set out in this Privacy Policy and if TECHNOLOGY PARTNER has a valid legal basis: either on the basis of its legitimate interests or on the basis of the explicit consent of the User concerned in the manner specified in this Privacy Policy.

All other data collected within the framework of Social Networks and advertising campaigns, according to the methods explained below, are based on TECHNOLOGY PARTNER's legitimate interest in using them for marketing purposes and for improving its advertising materials and its image on the basis of voluntary information transmitted or published by Users.

  1. Marketing Communications

TECHNOLOGY PARTNER may send informative and commercial emails (the "Marketing Communications") to persons whose electronic contact details it has obtained by providing its services through the Platform when the User concerned has not objected to such use when collecting his/her email address. The purpose of Marketing Communications is to send Users marketing offers, information on new products, special offers or events organised by TECHNOLOGY PARTNER.

The User concerned has the possibility of opposing such use of his or her email address, free of charge and in a simple manner, by clicking on the unsubscribe link included in each email sent in this context.

If the User objects to the receipt of all Marketing Communications, he or she will not receive any as soon as he or she has expressed his or her objection through one of the channels identified in the previous paragraph and his or her details will be deleted from TECHNOLOGY PARTNER's database established for Marketing Communications within ninety (90) days from that moment.

This processing is based on TECHNOLOGY PARTNER's legitimate interest in providing information about its activity, in promoting its Professional partners to Customers and thus promoting its image to Users.

  1. Use of Social Networks

The personal data of Users collected in the context of the use of social networks (the "Social Networks") may be processed by TECHNOLOGY PARTNER.

TECHNOLOGY PARTNER is present on various Social Networks and may act as joint controller with them for certain processing operations, in particular when the logo of the social network used appears on the Platform. All related information can be consulted directly on the website of the Social Networks concerned.

For more information on the processing of personal data on the various Social Networks, Users may consult the following information notices:

Other Social Networks may also be added at any time by TECHNOLOGY PARTNER.

  1. Advertising Campaigns

TECHNOLOGY PARTNER also carries out advertising campaigns using the services of Facebook and Google. Users can change their privacy settings on the pages of these providers by clicking on the following links:

  1. Use of cookies

TECHNOLOGY PARTNER also uses "cookies" to make the Platform easier to use and to better personalise the Platform and its services to the interests and needs of Users. Cookies may also be used to improve Users' future activities and experience on the Platform and for advertising purposes.

TECHNOLOGY PARTNER also uses cookies to compile anonymous global statistics to understand the use of the Platform by Users and to improve its structure and content.

Some cookies do not require the consent of Users because they are purely technical and their use is in the legitimate interests of TECHNOLOGY PARTNER. For others, TECHNOLOGY PARTNER collects the consent of Users before collecting personal data about them via cookies.

Some cookies allow us to compile statistics on how Users use the Platform. These statistics may be transmitted to Professionals once they have been anonymised with regard to their own page on the Platform to the exclusion of any other data. TECHNOLOGY PARTNER alone determines the purpose of these statistics and their content.

For more information, in particular on how long cookies are stored, Users may consult TECHNOLOGY PARTNER's cookie management policy by clicking on the following link insert here a link to the "cookie management policy" page

  1. Sharing of personal data

TECHNOLOGY PARTNER may share Users' personal data:

- To its subcontractors, which are companies of the group to which TECHNOLOGY PARTNER belongs, within the limits of the subcontracted services and insofar as this is necessary with regard to the purposes set out in point 3. above (for example: IT service providers, accounting service providers, marketing and advertising partners, etc.) and to their subsequent subcontractors ;

- With third-party companies that provide services on the Platform. TECHNOLOGY PARTNER may also disclose Users' personal data if it deems such disclosure necessary to comply with the law, to enforce the terms and conditions of use of its websites, or to protect its rights, property or safety, or those of others.

  1. Retention of data

TECHNOLOGY PARTNER takes all reasonable steps to ensure that personal data is processed and kept for the minimum period necessary for the purposes set out in this Privacy Policy. Unless more specific provisions are indicated to Users (cookies, Game or Marketing Communications), the general principle applied by TECHNOLOGY PARTNER is to keep Users' personal data:

- For all Users: backups are kept for a period of four (4) weeks.

TECHNOLOGY PARTNER undertakes to delete or anonymise the personal data of Users at the end of the retention period described above, increased by a period of a few days if necessary to ensure the deletion or anonymisation of the data concerned in practice, unless an imperative reason intervenes (e.g. in the context of a dispute).

  1. Data security and data transfer

TECHNOLOGY PARTNER implements appropriate security measures for the collection, storage and processing of data to protect against unauthorised access, falsification, disclosure or destruction of personal identification data.

Users are responsible for ensuring that all personal data they send to TECHNOLOGY PARTNER is secure.

TECHNOLOGY PARTNER does not transfer personal data outside the European Economic Area or to an international organisation outside the use of Social Networks (and in particular the cookies placed by Social Networks in the context of their use) and the carrying out of advertising campaigns in accordance with the methods indicated above.

In this context, Users' personal data may be transferred to the United States. Prior to 16 July 2020, these transfers were based on an adequacy decision of the European Commission (Privacy Shield). Since then, and pending work at the level of the European Data Protection Committee, Facebook and Twitter would transfer Users' personal data on the basis of standard contractual clauses as well as on the necessity of these transfers to provide their services (Article 49, 1. b of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation)). TECHNOLOGY PARTNER takes note that a complaint is currently being examined by the data protection supervisory authorities regarding Facebook and Google and is closely monitoring developments in this area.

TECHNOLOGY PARTNER will keep its Users informed and will adapt its operation following the position taken by the supervisory authorities.

  1. Management and minimisation of data

TECHNOLOGY PARTNER shall take reasonable steps to :

- Ensure that Users' personal data is accurate and, if necessary, updated by allowing Users to modify any inaccurate data at any time;

- Ensure that Users' personal data is collected according to the needs defined in this Privacy Policy.

  1. Rights of the data subject

Each User has the right to access, modify, limit and object to the processing of their personal data, the right to have their personal data deleted and the right to have their personal data ported by sending an e-mail to These rights can only be exercised within the limits of any contractual or legal obligation.

Each User also has the right to file a complaint with the Luxembourg supervisory authority, namely the National Commission for Data Protection ( Where the processing of the User's personal data is based on consent, the User concerned has the right to withdraw his consent at any time, without prejudice to the lawfulness of the processing based on consent carried out prior to the withdrawal of consent; Users are invited to contact TECHNOLOGY PARTNER in advance to seek a practical solution to the problem.

  1. Acknowledgement of this Privacy Policy

By using the Platform, Users acknowledge that they are aware of the terms of this Privacy Policy.

  1. Changes to this Privacy Policy

TECHNOLOGY PARTNER reserves the right to update this Privacy Policy at any time.

TECHNOLOGY PARTNER will revise the date of the last update at the bottom of this page for this purpose.

TECHNOLOGY PARTNER encourages Users to check this page frequently for changes and will send an Electronic Communication to subscribed Users or inform Users by means of a pop-up notice on the Platform when changes to this Privacy Policy are apparent.

Users acknowledge and agree that it is their responsibility to regularly review this Privacy Policy and inform themselves of any changes.

Continued use of the Platform following the posting of changes to this Privacy Policy will constitute acceptance of those changes.

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