Privacy Policy and License Agreement 

This privacy policy (the “Policy”) describes the privacy policies and practices of Link International Limited (“us”, “we”, “our” or “Link”) for Services and other matters offered through Link’s website at www.linkkyc.com (the “Site”). This Policy aims to provide a summary of the type of personal data that we collect through the Site, how such personal data is used, transferred, disclosed, shared and stored. This Policy does not cover any external third party websites that may be accessed through links provided on our Site.

To better protect your personal data, we provide this notice explaining our online information practices. Link is committed to the full implementation and compliance with the six data protection principles and the requirements of the Personal Data (Privacy) Ordinance (Cap. 486, Laws of Hong Kong) to safeguard your personal data.

By visiting or accessing this Site, or by registering for our Site you thereby agree to this Policy. Link will not use any personal data for any other purpose nor disseminate this personal data to any third parties. 

In connection with the Services, you will be agreeing to additional agreements with Link or its affiliate(s) or other third parties. In the event of conflicts between the terms of such agreements and the terms of this Policy, the terms of this Policy will prevail insofar as it relates to Link’s commitments related to protection of your personal data collected through this Site.

The terms of this Policy have been drafted solely in accordance with the laws of Hong Kong and are therefore subject to Hong Kong law. We do not represent or warrant that this Policy complies with the privacy laws of any other jurisdiction and accordingly, you shall not construe this Policy as such.

Personal Information Collection Statement

Link will use, share, transfer and disclose such personal data for the purposes and in the manner described in this Policy. 

Personal data means any information relating to an individual from which the identity of the individual can be ascertained, directly or indirectly. We respect your personal data. Link collects personal data you provide or upload through the Site. There are portions of our online Services where we may collect personal data for identification purposes, to fulfill your online requests, or where we believe it is reasonably required for provision of our Services. The information we collect varies based on our Services you choose to use through the Site.

Examples of personal data Link may collect include, without limitation, the following information:

• name;

• postal or email address;

• telephone, numbers;

• account number, username and password;

• correspondence addresses;

• communications between you and Link; and

• data regarding your visits to and use of the Site.

When you visit the Site or use our Services through the Site, we may automatically collect certain data which may, when combined with other information about you, be personal data, including but not limited to:

• attributes of the computer or other device you are using, such as the operating system, hardware version, device settings, software and device identifiers;

• computer or other device locations, including specific geographic locations identified through GPS, Bluetooth or WiFi signals or other means;

• connection information such as the name of your mobile operator, ISP or other service provider, browser type and IP address;

• the website from which you have reached the Site;

• the pages on our Site you viewed or visited, average time spent on these pages and when they were viewed or visited;

• details of the information and Services on the Site that you look at, information, tools and content available on the Site that you use; and

• links from the Site that you click on.

User-Supplied Information

Upon performing the registration process, you will be asked to provide certain information (including but not limited to personal data), such as your first and last name, address, and other identifying information as well as a username and password. The username and password are used to ensure that no user other than yourself will have access to such information you have provided. You are solely responsible for maintaining the secrecy of any password you use to register, and you should always be careful whenever disclosing information online.

The amount of personally identifying information you provide is up to you, and you are not legally obligated to provide such information. However, your use of the Site or the Services may be curtailed if certain of such information is not provided.

The Site and Services may only be used by individuals over the age of 18.

Use of Personal Data

Personal data collected will be used by Link, and its employees and consultants and may be transferred by Link to Link Affiliates and their respective service providers, legal advisers and auditors in connection with the operation and management of the Site and provision of the Services, or to any other users who are registered with us in accordance with your instructions, to enhance performance of the Site, to tailor the Site to users’ preferences, and to analyse trends, including, without limitation, as follows:

• To enable us to verify your credentials, in order to maintain reasonable security, provide developers with the information that is useful in developing new features and Services for our users, enable us to develop and improve the features, contents, and Services available, fulfill your requests for our products and Services, in connection with your use of the Site or Services, to respond to your inquiries about our Services, to offer you our products or Services that we believe may be of interest to you, to carry out transactions which you have requested, to enforce our rights and resolve disputes.

• We will retain information transmitted to us in the context of use of Services for further internal use in connection with our efforts to improve our Services and products.

• Newsletters: If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. Out of respect for your personal data, we provide you a way to unsubscribe by following the unsubscribe link located at the bottom of each newsletter communication or by emailing us at info@hifromlink.com.

• We may use non-personally identifying information that we collect to provide statistical information about users of the Site or Services, to improve the quality, design and content of our Site, to analyse the use of our Site and to cooperate with law enforcement.

We may use your personal data for marketing or offering our products or Services to you and by aggressing to these terms you will automatically consent. If you wish to opt out you can email us at info@hifromlink and we will remove you from correspondence lists. 

Disclosure

We may provide your personal data to other third parties business partners within our Site. Where we provide such information to third parties, other than for use on our behalf, it will be provided either in aggregated form that does not identify your identity, or in a form that does not link the information to any PII. In other words, we will only provide to such third parties non-personally identifiable identification (for example, gender) in connection with an IP address.

We will not sell, share (other than sharing with Link Affiliates and third party service providers as described in this Policy), rent or trade your personal data or information with third parties unless we have your consent.

We may disclose or transfer your personal data or information to:

• Third-party vendors who provide services or products to us for operation of the Site or provision of our Services or facilitate or evaluate the Sites or Services, such as e-mail service providers sending emails on our behalf

• Link Affiliates that are involved in operating or providing the Services. We may share your personal data or information with Link Affiliates. Link Affiliates will follow practices that are at least as restrictive as the practices described in this Policy, including requests that personal data or information will only be used to provide you with Services.

• We may share aggregated or anonymous data with third parties for any use whatsoever without restriction.

We also may share or provide your personal data or information:

• In response to subpoenas, court orders, or other legal process or in response to a law enforcement agency’s request; to establish or exercise our legal rights; to defend against legal claims; or as we reasonably believe appropriate to comply with applicable laws, regulations, orders, legal processes or government or regulatory requests, as well as in order to comply with anti-money laundering laws and regulations. In such cases we reserve the exclusive right to raise or waive any legal objection or right available to us.

• When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of Link or any Link Affiliates, or this Site, our customers, or others; and in connection with our Terms of Use and the terms of other agreements to which Link or any of Link Affiliates is a party, including where we believe you may have breached such Terms of Use or the terms of such agreements, to detect, prevent or otherwise address fraud or illegal behaviour, security or technical issues, or protect against imminent harm to the rights, property or safety of Link or any of Link Affiliates, or users or the public as required or permitted by law.

• In the event that Link goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your PII will likely be among the assets transferred. You will be notified via email or prominent notice on our Site for 30 days (or such longer period as may be required by applicable law) before any such change in ownership or control of your personal information.

Other than as set out above, you will be notified when your personal data or information will be shared with third parties, and you will have an opportunity to choose not to have any of them shared.

Notifications & Direct Marketing

The Site sends new registered users a welcoming email to verify password and username. After you register with the Site, subject to your consent to direct marketing services, we may send you on a regular basis via emails information on other services or products (other than the updates on the Site or the Services) that we believe may be of interest to you. Out of respect for your personal data, we give you the option at all times to opt-out of these types of communications. By choosing not to opt out, you consent to these communications.

The Site may also send you notifications regarding updates to the Site and Services. We may also communicate with you to provide requested Services and with respect to issues relating to your account via email or phone. You will not be able to opt-out of service announcements that contain important information about the Service.

Opt-out

You may ‘opt-out’ of having your personal data or information used for any purpose not directly related to the Site upon registration to the Site. You may not opt out of administrative emails (for example, electronic delivery of invoices, or emails about your transactions or our policy changes). However, if you no longer wish to receive additional information or promotional materials from Link, you may opt-out of receiving these communications by sending an email with the word ‘unsubscribe’ in the subject line or otherwise sending a request to info@hifromlink.com, or using the opt-out mechanism described in the relevant email.

Access & Correction of Personal Information

Under the Personal Data (Privacy) Ordinance (Cap. 486, Laws of Hong Kong), you have the right: (a) to check whether Link holds personal data about you and to access such data; and (b) to require Link to correct, amend or update your personal data. Link encourages you to review your information regularly to ensure that it is correct and complete. As a registered user, you can access, correct, change or update your personal data or information by emailing us at info@hifromlink.com. In accordance with the Personal Data (Privacy) Ordinance (Cap. 486, Laws of Hong Kong), we have the right to charge a reasonable fee for the processing of any data access request.

Links

The Site contains links to other sites. The inclusion of such links does not imply our endorsement of the linked website or service. Information you disclose to other parties or through such websites is subject to the privacy practices and policies of those parties or websites. Link is not responsible for the content or security of such linked websites or services and has no liability for privacy policies and/or practices on other sites. We disclaim all liability whatsoever with regard to your access to such linked websites or services. We advise you to read the privacy policy stated on other sites you link to through the Site. Our Policy only governs information that we collect by Link on the Site or through other means.

Security

We take appropriate precautions to protect users’ personal data or information by using physical as well as technological security devices. Additionally, we have implemented physical, electronic and procedural safeguards that are designed to protect the security of your personal data or information in compliance with Personal Data (Privacy) Ordinance (Cap. 486, Laws of Hong Kong). These include advanced firewall and password protection for our databases and restricted access to your personal data or information to employees that need to know that data or information to provide, operate, maintain, develop or improve our Services. We have invested in software, systems and procedures to offer you safe and secure Sites and Services and protect your personal information. While no security system is absolutely impenetrable, we will continually monitor the effectiveness of our security system and refine and upgrade our security technology as new tools become available. Link’s employees are kept up-to-date on security and privacy practices. As the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data or information which is transferred from you or to you via the internet. You should also be mindful that you are responsible for keeping your access rights confidential and secure at all times. If you have any questions about the security measures we use on the Site please contact us by sending an email to info@hifromlink.com.

Retention

Personal data will be held for as long as it is necessary to fulfill the purpose for which it was collected, or as required or permitted by applicable law. We will retain your data or information for as long as your account is active or as needed to provide you Services or as required in accordance with applicable law.

You can also request that we close your Link account, or request that we no longer use your personal data or information to provide you Services, by emailing us at info@hifromlink.com. After we close your account, we may retain some personal data or information to comply with law, prevent fraud, assist with investigations, resolve disputes, analyse or troubleshoot programs, enforce our Terms of Use and take actions otherwise permitted by law. If your account is terminated or suspended, we may retain some personal data or information to prevent re-registration.

Link shall cease to retain personal data/information or remove the means by which personal data/information can be associated with particular user, as soon as it is reasonable to assume that the purpose for which that personal data/information was collected is no longer valid and retention of such personal data/information is no longer necessary for legal or business purposes.

Notification of Changes

This Policy may change from time to time and we will post the amended terms on the Link Site and notify you by email of major changes. Amended terms will take effect immediately for new users, and 30 days (or such longer period as may be required by applicable law) after they are posted for existing users. You should review our Policy periodically to ensure that you have received the latest version and our updates. You agree to accept posting of a revised Policy as actual notice to you. Your continued use of the Site after any changes to this Policy have been posted (or, if applicable, notified) signifies your acceptance of those changes. If we become involved in a merger or acquisition or sale of assets, we will provide notice before personal data or information is transferred or becomes subject to a different privacy policy.