Last Updated: 26 FEB 2020
UPLINX SLU registered office is at Cami dels Plans 53, AD400 La Massana, ANDORRA, with company registration number 925983 and tax registration L-711298-N. The GDPR regulation of the European Union applies to our business.
UPLINX processes your personal information to meet our legal, statutory and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way, other than as specified in this notice. Personal data refers to any information that tells us something about you or that we can link to you. We process the following categories of information:
We collect your personal information that we received from you when you use the Website, including personal information you provide to us including when you: enquire or make an application for one of our products or our service, register to use and/or use any of our services and when you communicate with us through e-mail, the Website, or any other electronic means.
The personal data that we collect may include your name including first name and family name, e-mail addresses, billing address, telephone numbers, username, password.
We collect information about the services that you use and how you use them, like when you visit our Website, licensing portal or online shop and interact with our content. This information includes:
Device information. We collect device specific information such as IP address, access dates and times, hardware and software information, device information, cookie data.
Geo-location Information. When you use certain features of the Website, we may collect information about your approximate location as determined through data such as your IP address.
Usage Information. We collect information about your interactions with the Website such as the content you view, your searches queries and other actions on the Website.
Payment Transaction Information. We collect information related to your payment transactions through the payment platform, including the payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, PayPal email address, IBAN information, your address and other related transaction details.
We may collect information, including personal information that others provide about you when they use the Website, or obtain information from other sources and combine that with information we collect through the Website. We do not control, supervise or respond for how the third parties providing your information process your personal data, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.
UPLINX uses 3rd party payment processors to receive payment for orders. Credit card information is not supplied to UPLINX by a 3rd party payment processor. Credit card information is entered directly on the 3rd party payment processor web page . The 3rd party payment processor will only transmit the result of a payment operation such as payment successful or failed. UPLINX will only store the result of a payment operation and has no access to Credit card information.
UPLINX takes your privacy very seriously and will never disclose, share or sell your data without your consent; unless required to do so by law. We only retain your data for as long as is necessary and for the purpose(s) specified in this notice. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time. The purposes and reasons for processing your personal data are detailed below:
We process this information given our legitimate interest in protecting the Website or pursued by a third party and to comply with applicable laws.
As noted in the 'How We Use Your Personal Data' section, we occasionally process your personal information under the legitimate interests' legal basis. Where this is the case, we have carried out a thorough Legitimate Interests' Assessment (LIA) to ensure that we have weighed your interests and any risk posed to you against our own interests; ensuring that they are proportionate and appropriate.
We use the legitimate interests' legal basis for processing of orders and quotes, email notifications for license or contract renewals for you or your users by us or our automated systems and have identified that our interests are to provide you with timely notifications or security alerts about our services and products.
Cookies are text files that are placed by the browser in the memory of a user's device when our website is visited. Our website uses session cookies and persistent cookies. The user can disable the cookie function in his browser options. Please see the specific information of the browser used for visiting this website. For details how to control and/or delete cookies, see aboutcookies.org. If cookies are disabled the user might not be able to use all the functions and services of the Website.
In addition, we use Google Analytics, a web analytics service provided by Google, Inc. (hereinafter referred to as "Google"), using third-party cookies that enable Google to analyze the use of the Website. The information generated by the cookie about the use of this website is transferred to a Google server in North America.
Google will use this information on our behalf to evaluate the use of the Website, to compile reports for activities on the Website, and to provide other services to us relating to the Website.
Google Analytics operates under the following terms:
Terms of Service: http://www.google.com/analytics/terms/gb.html
The user can prevent Google from collecting and processing the data concerning the use of the Website (including the IP address) by installing a browser-plug-in which is available under https://tools.google.com/dlpage/gaoptout.
Note that all data is kept in a secure environment. We protect personal data by using appropriate safeguard procedures and measures, in particular:
If you know or have reason to believe that your account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your account, please 'Contact Us'.
You have the right to access any personal information that UPLINX processes about you and to request information about:
If you believe that we hold any incomplete or inaccurate data about you, you have the right to ask us to correct and/or complete the information by 'Contact Us' and we will strive to do so as quickly as possible; unless there is a valid reason for not doing so, at which point you will be notified. If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.
You also have the right to request erasure of your personal data or to restrict processing (where applicable) in accordance with the data protection laws; as well as to object to any direct marketing from us.
If we receive a request from you to exercise any of the above rights, we may ask you to verify your identity before acting on the request; this is to ensure that your data is protected and kept secure.
We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement.
You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself within your account).
We only ever retain personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. We are required under Andorran tax law to keep your basic personal data (name, address, contact details) for a minimum of 6 years after which time it will be destroyed. If you no longer want us to use your information to provide any services to you, you can request that we erase your personal information and close your account. Please note that if you request the erasure of your personal information:
We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend an account for fraud or safety reasons, we may retain certain information from that account to prevent that user from opening a new account in the future.
We may retain and use your personal information to the extent necessary to comply with our legal obligations.
Because we maintain the Website to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
Any comments, complaints or questions concerning this policy or complaints or objections about our use of your personal information should be addressed by directing your comments to UPLINX's Data Protection Officers, whose contact information is found in 'Contact Us'.
Personal data in the European Union is protected by the General Data Protection Regulation (GDPR) but some other countries may not necessarily have the same high standard of protection for your personal data.
We utilise some products or services (or parts of them) that may be hosted or stored in the United States, which means that we may transfer any information which is submitted by you through the website outside the European Economic Area ("EEA") for the below purposes:
Therefore, when you use our website, send us an email, contact us, the personal information you submit may be stored on servers which are hosted in the United States. Where this is the case, we will take steps to ensure that those providers use the necessary level of protection for your information.
You may contact our Data Protection Officer at or by mail to:
Cami dels Plans 53
AD400 La Massana