Effective JUNE 1, 2022

Minilink.io ("Minilink", "we", or "us") values your trust and a key part of earning your trust is being upfront and clear in how we gather and use your information. We created this Policy to inform you on what data we collect, how we collect your data, how we share your data, and your rights around the data. This Policy applies when you use our services available through Minilink.io ("Site") either as creator of a Minilink Link (as defined below) or clicking on a Minilink Link. For the purposes of this Policy, the Site, features, content, applications, and other services provided by Minilink will be referred to as the "Services". This Policy works in conjunction with the Site's Terms and Conditions. Any capitalized terms used, but not defined, in this Policy have the meanings provided in the Terms and Conditions. If you do not agree with our policies and practices, please do not use our Services. By accessing or using our Services, you agree to this Policy.

Controller and Processor

Data protection laws and privacy laws in certain jurisdictions differentiate between "controllers" and "processors" of personal information. A controller decides why and how to process personal information. A processor processes personal information on behalf of a controller based on the controller’s instructions. When you create a Minilink Link (a "User"), we are acting as a controller. When you click on a Minilink Link created by a User, we are acting as a processor.

Broadly speaking, we use Personal Information to further our legitimate interests to:

• understand who our users are,
• manage our relationship with you and other Users,
• carry out core business operations such as billing and fulfilling regulatory obligations; and
• help detect, prevent, or investigate security incidents, fraud, and other abuse or misuse of our Services.

WHAT INFORMATION WE COLLECT AND HOW WE COLLECT IT

While using our Services we may collect information that identifies, relates to, describes, is reasonably capable of being associated with or could reasonably be linked, directly or indirectly, to you ("Personal Information"). This does not include aggregated or de-identified information that is maintained in a form that is not reasonably capable of being associated with or linked with you.

You may provide us with Personal Information in several ways.

• Account Creation: When you create an account, we collect personal information from you such as your name, email address, and other relevant information (your "Account"). If you create an Account using your login from a third-party account, such as Facebook, Google, Apple, we will access and collect your personal information provided by that third-party account. The amount of information that is shared with us from that third-party account depends on your privacy settings on your third-party account.
• Create a Minilink Link: By using our Services, Users can create shortened URLs of websites ("Minilink Link" or "Minilinks). Users can create Minilinks without registering for an Account. When you create a Minilink Link, Minilink collects and stores the original URL and the shortened URL and links it with your session. This applies to both User who are logged in and to those who are not.
• User Support: If you contact us for assistance or support, we may collect your name, email address, or any other content that you send us.
• Social Media Interaction: We may collect information from your social media account if you interact with our social media presence.

INFORMATION COLLECTED AUTOMATICALLY

• Log Data: When you use our Services, whether as a registered user or a non-registered user, our servers may automatically record information that your browser sends whenever you create or use a Minilink Link ("Log Data"). This Log Data may include information such as your Internet Protocol ("IP") address, device settings (such as browser type, operating system, language), the time and date you create the Minilink Link, the referring website, the time and date of each access, device settings, and analytics on the sharing of the Minilink Link on third party services, such as Facebook. We use this information to monitor and analyze use of the Services, for the Site's technical administration, to increase our Site's functionality and user-friendliness, and to better tailor it to our visitors` needs.
• Mobile Devices: We may collect information from your mobile device, such as unique identifying information broadcast from your device when visiting our Services.
• Cookies and Similar Technology: "Cookies" are a small data file that we transfer to your computer's hard disk for record-keeping purposes.

Minilink USES THREE TYPES OF COOKIES

Necessary Cookies
These are essential cookies that let you to use the Dashboard and use its features depending on the device you’re using (language, screen performances, OS...). Without them, the quality of your navigation could not be ensured. These cookies don’t collect any information about you that could be used for marketing or remembering where you’ve been on the internet.

Performance Cookies
These collect information about how you use a website, for instance, which pages you go to most often, and if you get error messages. They don’t collect information that identifies you; all the information is anonymous. It is used only to improve how the website works and how we can provide you with more relevant content.

Third-party Cookies
A third-party cookie is set by someone else. Sometimes targeting cookies are linked to other sites, such as Facebook.

The issue and the use of cookies by third parties are subject to the protection of privacy policies of these third parties. We inform you of the purpose of cookies that we know and means you have to make choices regarding cookies.

If you decide you’re not happy with the use of cookies on the WebApps website or on your instance of the Hitpath software you can easily delete them from the cookie folder of your browser. You can also set your browser to block cookies or to send a warning notice before a cookie is stored on your computer. You can exercise your disagreement by changing the configuration of your browser.

• For Microsoft Edge
• For Safari
• For Chrome
• For Firefox
• For Opera

INFORMATION COLLECTED FROM OTHER SOURCES

• Social Media Services: Our Services allow you to interact with social media platforms and other third-party services (e.g., Facebook, Twitter, LinkedIn). If you choose to share your Minilink Link using third party services, we may collect information related to your use of those third-party services. Additionally, if you access the Services using one of these social media platforms or other third-party services, we may receive information about you from those third parties such as account and profile data. Please note that third-party services may have the ability to restrict the information that is provided to us based on your privacy settings of that account.

NO SPECIAL CATEGORY OF PERSONAL INFORMATION

We do not require or collect any sensitive personal data or any special category of personal data, as such terms are defined under applicable privacy laws, as a condition of using the Services.

PURPOSES FOR WHICH WE USE YOUR PERSONAL INFORMATION

We will share Personal Information in the following circumstances:

• To operate our Site and provide the Services.
• To process and complete requested transactions.
• Where it is necessary for our legitimate interest (or those of a third party) and your interests and fundamental rights do not override those interests.
• To comply with legal or regulatory requirements.
• To enforce our Terms of Use and as otherwise described in this Policy.

We have also created a list and description of the categories of Personal Information we collect, the legal basis for our collection and use of the Personal Information, and the categories of third parties with whom some or all the Personal Information may be shared.

Categories of Personal Information Collected include:

• Identifiers (such as name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, or other similar identifiers)
• Commercial information (such as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies)
• Internet or other electronic network activity information (such as information regarding a consumer’s interaction with an Internet website, application, or advertisement)
• Non-Precise Geolocation information (such as zip or area code, state, country)
• Inferences drawn from the above information about your predicted characteristics and preferences
• Other information about you that is linked to the personal information above

Purposes for Collection, Use, and Sharing include:

• To provide the Services
• Customer support
• Security and fraud prevention
• Advertising
• To provide and improve the Services
• Fraud and cybersecurity
• Analytics

Categories of Third Parties with Whom Some or All the Personal Information May Be Shared include:

• Ad networks
• Analytics services
• Technology service providers

NO SPECIAL CATEGORY OF PERSONAL DATA

The purpose of our Services is to allow you to share information and to receive information on the Minilinks you create. As a result, some Personal Information may be shared with third parties as described below:

• Minilinks You Create: When you create a Minilink Link, the shortened URL and the original URL it refers to is publicly available to anyone provided or with access to the Minilink Link.
• Information We Share with Users: We may share the Personal Information we collect as described in this Policy with our Users. When a Minilink Link is created, the User who created the link may be able to view aggregated information about clicks and views of the Minilink Link, including the number of times the Minilink Link was shared, whether or not it was viewed, comparison of that Minilink Link’s performance to that of all Minilinks pointing to the same content, whether others are sharing a Minilink Link to the same content, geographic regions where the content is being viewed, and identification of social networks or websites on which the Minilink Link appears.
• Service Providers: We may employ third party companies and individuals to facilitate our Services, to provide the Services on our behalf, to improve our Services and to perform Site-related services (e.g., without limitation, maintenance services, database management, web analytics, payment processing, fraud detection and improvement of the Site's features) or to assist us in analyzing how our Site and Services are used. These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
• Analytics and Search Engine Providers: We may share Personal Information with analytics and search engine providers that assist us in the improvement and optimization of the Service.
• Feedback: We may collect feedback from you about your experience to compare your experience with other Users of the Services to improve the quality of the Services. This feedback is the property of Minilink, and we reserve the right to share it with any third-party.
• Acquisition, merger, or bankruptcy: Minilink may sell, transfer, or otherwise share some or all its assets, including your Personal Information, in connection with a merger, acquisition, reorganization, sale of assets, or in the event of bankruptcy.
• Disclosures without Your Consent: We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in the event of an emergency, to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or act regarding possible illegal activities, suspected fraud, the safety of person or property, or a violation of our policies.
• Disclosures with Your Consent: We will share information about you when you instruct us to do so, such as when you share Minilinks or content with others through the Services or if we notify you that the information you provide will be shared in a particular manner and you provide such information (such as posting it to a third-party service).

We may also share aggregated information that does not include Personal Information and we may otherwise disclose non-identifying information and Log Data to parties for industry analysis, demographic profiling, and other purposes. Any aggregated information shared in these contexts will not contain your Personal Information.

MARKETING AND ADVERTISING

We use your Personal Information to tailor our marketing and advertising efforts. To do this, we provide your information to third party advertising networks (such as but not limited to Google, Doubleclick, etc...) and social media companies (such as Facebook, Instagram, and other social media platforms). When we provide data to agencies, ad networks, and other parties for targeted advertising, we do not provide them with your name, financial information, or any sensitive information. We use online identifiers such as email, cookies, and device identifiers to help us provide targeted advertising to you and others like you.

We may also use aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal information we have collected from you to enable us to display advertisements to target audiences.

To opt out of targeted advertising, you may use the following links provided by third parties that manage opt outs for some ad networks:

• http://preferences-mgr.truste.com
• http://www.networkadvertising.org/managing/opt_out.asp
• http://www.aboutads.info/
• https://policies.google.com/privacy/partners

DO NOT TRACK SIGNALS

Your browser settings may allow you to automatically transmit a "Do Not Track" signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do regarding these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or act with respect to "Do Not Track" signals. For more information on "Do Not Track," visit http://www.allaboutdnt.com.

EMAIL MARKETING AND RETARGETING

If you sign up for our Services, we will send you marketing emails. If you change your mind, you can opt-out at any time by selecting the unsubscribe option when you receive an electronic marketing communication from us. The withdrawal of your consent will not impact the lawfulness of processing based on your consent prior to the withdrawal.

Please note that even if you opt-out of receiving commercial emails, you will still receive emails that are transactional in nature, such as actions taken on your account, updates to our online policies, and other transactional communications. We may use the information we collected as a mean to retarget you on the internet while use third party software.

INTERNATIONAL TRANSFERS

When you use our Services, your Personal Information may be transferred to our service providers and trusted partners who maintain processing facilities outside the European Economic Area ("EEA"). This is only for the purposes of providing, and to the extent necessary to provide, the Services to you. The privacy laws in these countries may not be as protective with your information as the laws in your jurisdiction. Nonetheless, Minilink takes reasonable measures to ensure that adequate security measures are in place to safeguard and maintain the integrity of your Personal Information on transfer.

RETENTION OF YOUR PERSONAL INFORMATION

We will retain your Personal Information only for as long as is necessary for the purposes set out in this Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your Personal Information to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

YOUR DATA RIGHTS

• Deletion: You can ask us to delete all or some of your Personal Information (e.g., if it is no longer necessary to provide Services to you). In such case you may no longer be able to use the Services unless you create a new account with us.
• Change or Correct: You can edit some of your Personal Information through your Account. You can also ask us to change, update, or fix your Personal Information in certain cases, particularly if it is inaccurate.
• Object to, or Limit or Restrict, Use of Information ("Opt-Out"): You can ask us to stop using all or some of your Personal Information or to limit our use of it (such as objecting to the processing of your Personal Information for our marketing purposes).
• Right to Access and/or Take Your Information: You can ask us for a copy of your Personal Information and can ask for a copy of Personal Information you provided in machine readable form.
• Right to Non-Discrimination: We will not discriminate against you for exercising your data rights.

To make a request please email [email protected]. We will consider your request in accordance with applicable laws.

Please note that when certain requests will be subject to necessary verification requirements. Only you or someone legally authorized to act on your behalf may exercise the right to deletion and the right to access/and or take your information. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

You do not need to create an account with us to exercise your Right to Know or Right to Delete. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Information associated with that specific account.

We will only use Personal Information provided in the request to verify the requestor’s identity or authority to make it.

PERSONAL INFORMATION SALES OPT-OUT AND OPT-IN RIGHTS

Minilink does not sell personal information to third parties for monetary value. However, to the extent that "sale" is interpreted under applicable laws to include interest based advertising or other data uses described in the "Purposes for Which We Use Your Personal Information" and "How We Share Your Information" Sections above, we will comply with those laws in regards to those activities.

To exercise the Right to Opt-Out, you (or your authorized representative) may submit a request to us by emailing us at [email protected].

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Information sales.

You do not need to create an account with us to exercise your Right to Opt-Out. We will only use Personal Information provided in an opt-out request to review and comply with the request.

Please note that your decision to opt out of the sale of your Personal Information may impact the availability and quality of some of our Services provided to you. Furthermore, your Personal Information may still be shared pursuant to the terms the Policy, where such sharing does not constitute a sale Security

The security of your Personal Information is important to us. As such, Minilink uses standard physical, technical, and administrative measures designed to reduce risk of loss, misuse, unauthorized access, disclosure, or modification of your Personal Information. Unfortunately, no system or network can be guaranteed to be 100% secure, as such we cannot and do not guarantee or warrant the security of any information that you transmit on or through the Services or that we otherwise maintain.

NOT DIRECTED TO CHILDREN

Our Services are not directed to persons under 18. We do not knowingly collect information from persons under 18. As such, we do not knowingly "sell," as that term is defined under applicable law, including the CCPA, the Personal Information of minors. If you are a parent or guardian of a minor who is under 16 years old and using our Services, you may contact us at [email protected] to request and arrange for deletion of any Personal Information, if any, we may have collected about the minor. For privacy reasons we may request proof of relationship to the minor.

UPDATES TO THE PRIVACY POLICY

We may update this Policy from time to time. When we update the Policy, we will notify you by updating the "Effective Date" date at the top of this Policy, posting the new Policy, and providing any other notice required by applicable law. We recommend that you review the Policy each time you visit the Site to stay informed of our privacy practices. If you do not agree or consent to these updates or changes, do not continue to use the Services.

LINKS TO THIRD PARTY WEBSITES

Our Services, email updates, and other communications may, from time to time, contain links to and from the websites of others, including our partner networks, advertisers, and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.

CONTACT US

If you have any questions about this Policy, please contact us at: [email protected].