Privacy policy

Dear User,

from May 25, 2018, all entities processing personal data in the EU are required to apply Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of individuals about the processing of personal data and the free movement such data and repealing Directive 95/46/EC (hereinafter "GDPR"). The same provisions also apply in the territory of the United Kingdom, where the Data Protection Act 2018 adapts the GDPR for the UK context.

In connection with the above, the administrator of this website www.linity.com (hereinafter "LINITY Website"), which is LINITY OÜ, a company incorporated and operating under the law of Estonia, with the registry number of 16748002 and its registered office at Tallinn, Lõõtsa tn 5 // Sepapaja tn 4, 11415 Estonia (hereinafter "LINITY", "We" or "Us") informs that the provisions of this privacy policy document (hereinafter "Privacy Policy") apply to the personal data of the LINITY Website Users to meet the information obligations set out in Art. 13 and 14 of the GDPR.

In this Privacy Policy, We would like to provide the User with information about Us and the nature, scope, and purposes of data processing, and thus familiarize the User with the processing of the User’s data on the LINITY Website.

LINITY respects the Users' right to privacy and declares that it makes every effort not to collect any data except for the data necessary for the proper functioning of the LINITY Website or the data the collection of which is aimed at increasing the usefulness of the LINITY Website.

The LINITY Website uses cookies. Information on what they are and how cookies are used can be found in the "Cookie Policy" tab on the LINITY Website. The Cookie Policy may be amended from time to time by LINITY Website, in which case You will be duly notified.

I. Privacy Policy

LINITY ensures that the processing of personal data is in accordance with the legislation regarding the protection and security of personal data, in particular:

GDPR;
The Personal Data Protection Act of May 10, 2018 (Polish Journal of Laws of 2019, item 1781, as amended);
Act on the provision of electronic services on July 18, 2002 (Polish Journal of Laws of 2020, item 344, as amended);
Personal Data Protection Act on December 12, 2018 (Estonian Journal of Laws, RT I, 04.01.2019, 11)
Data Protection Act 2018 (UK 2018 CHAPTER 12).

LINITY applies utmost importance to protecting the privacy and confidentiality of Your data and with the utmost care selects and applies technical and organizational measures to ensure their proper protection. LINITY protects Your data against disclosure to unauthorized persons, loss, destruction, or unauthorized modification, as well as against their processing in violation of applicable laws.

II. On what basis do We process Your data

By using the LINITY Website, You acknowledge and accept the processing of Your data, including but not limited to collection, storage, disclosure, modification, and use in another form by LINITY under the conditions provided for in this Privacy Policy. LINITY processes Your data necessary for provision of services.

Thus, We process Your data for the following purposes and on the following grounds:

By concluding a contract with Us on Our behalf - We process Your data to the extent necessary to conclude and perform contractual obligations, the purpose of which is creating account to access features on the LINITY Website (legal basis: Article 6 sec. 1 (b) of the GDPR);
By concluding a contract with Us on behalf of and for the benefit of a legal person or organizational unit without the legal personality that You represent (hereinafter "Organization") - We process Your data based on a legitimate interest within the meaning of Article 6 sec. 1 (f) of the GDPR, which is the implementation of Our rights and obligations under this contract. Without this, We would not be able to provide the Organization You represent, and the Organization would not be able to use it;
By providing Your data to make contact with Us (legal basis: Article 6 sec. 1 (f) of the GDPR) - We process Your data based on a legitimate interest , which is the implementation of Our rights and obligations under this contract, including contacting Us via the LINITY Website or otherwise;
Legitimate interests (legal basis: Article 6 sec. 1 (f) of the GDPR) - Such legitimate interests are in particular:
1. establishing contact requested by You,
2. ensuring security of the service,
3. making statistical measurements, improving Our services, and adjusting them to the needs and convenience of Users (e.g. personalizing content in services),
4. pursuing or securing claims or defending against them.
Processing is necessary to comply with legal obligations (legal basis: Article 6 sec. 1 (c) of the GDPR) - for ongoing compliance with laws, regulations and other requirements.
Consent (legal basis: Article 6 sec. 1 (a) of the GDPR) - conducting direct marketing or promoting Our services, for marketing purposes and to adjust the content of Our websites, We can also analyze the content that has been launched or displayed on the pages You have visited and the method of launching or displaying them.

III. What data do We collect and process

To be able to conclude and perform the contract with You or the Organization You represent, and thus provide services by Us, We may require You to provide the following personal data:

Personal information - name and surname, social media handles (Discord, X (ex-Twitter)), crypto wallet address, that We use to contact You and to verify Your identity.

LINITY can also collect the following categories of data:

Device information - including information about Your devices or browsers that indicate Your behavior on the internet or the way You use devices. Information about Your devices is collected by the LINITY Website, and information about Your browsers is collected by Our cookies, tags, and pixels. This is often required for network security reasons. This includes, inter alia, IP address, date and time of entering Our website, time of stay, amount of data transferred, referring URL (in the case of switching to Our website from another website or via an advertisement), pages visited on Our website, type of Your browser (language and software version), browser add-ons, device identifier and features, device type and version, operating system.
Contact details - Your telephone number, e-mail address, and other communication channels that You use to contact Us for further information. We use them to verify You as Our user and to contact You for a variety of reasons depending on the purpose.

IV. How We collect Your data

By concluding a contract with Us on Your behalf or behalf of Your Organization - We receive Your data directly from You during the conclusion of the contract. The contract is considered to have been concluded when You start using Our website.

By providing Your data to make contact with Us - We receive Your data directly from You when You provide it in the contact form on Our website.

V. Disclosure of personal data

LINITY engages third-party service providers to perform functions on Our behalf, such as user management, data analysis, marketing, and customer support. These service providers have access to Your personal data only to the extent necessary to perform their services, and they are contractually obligated to maintain the confidentiality and security of Your data.

We act as a data controller and the service provider acts as a data processor in the following data processing activities:

entities providing services that ensure appropriate technical and organizational measures for the LINITY (e.g. IT service providers, entities providing maintenance services);
entities providing legal services, in the event of the need to pursue due claims (including courts or enforcement authorities) or financial services (e.g. banks);
entities authorized based on generally applicable legal provisions;
entities authorized to carry out inspections, supervision, or audits, including the Administrator's bodies or certifying entities.
We act as a data processor and the service provider acts as a data controller in the following data processing activities;
Third Party Sites on a basis described below in Section VI.

We will notify You of legitimate requests to disclose Your data, unless prohibited by law or a court decision, or if the request is urgent. We may contest such requests if We believe they are too broad, inaccurate, or illegal.

VI. Third Party Sites and Social Media Sites

LINITY Website, emails sent by Us, and other promotional messages may contain hyperlinks to websites operated by third parties. Those third-party sites are not governed by Our Privacy Policy. Accordingly, We advise You to read the privacy policies of such third-party websites before using them and to exercise caution when submitting any personal information to such third-party websites. We would like to emphasize that We are not responsible for any acts or omissions, or for any loss or damage that You may suffer in connection with Your use of or access to such third-party websites.

LINITY may use social networking sites and networks, such as Twitter, Discord, Google, among others (collectively "social networks"), to connect to Your social networks or enable You to use logins through them to register an account on LINITY Website, access Your account, Our website, applications, APIs, other services or products.

In order to enable You to use social login to register an account with the LINITY Website, to access Your account, the service, and the services or products among Your social network contacts, and to enable You to share Your interest in the LINITY Website, the and the services, LINITY may provide access to the LINITY Website to third-party social networks, and therefore the LINITY Website may include links to such social networks. The above does not imply endorsement of any third-party services and We recommend that You read their Privacy Policies and Terms of Use before using them to protect Your personal information.

LINITY Website contains links to third-party sites that include information about cryptocurrencies that do not constitute an offering of securities or securities tokens, and other related information about digital currencies. Such information (or links to such information) may be made available, for example, through YouTube or the use of YouTube’s API services (as defined in the “YouTube Terms of Service” located at https://www.youtube.com/t/terms), You hereby agree that in order to access the aforementioned videos and podcasts, You must agree to abide by all provisions contained in the YouTube Terms of Service, as well as Google’s Privacy Policy at https://www.google.com/policies/privacy, otherwise You will not be able to access the aforementioned links.

VII. How long do We keep the data

Data retention period

If You decide to withdraw Your consent to the processing of Your data by Us or request their removal, all Your data held by LINITY will be deleted, except for the data needed for LINITY to fulfill its contractual obligations, legal obligations under the law and to comply with statutory limitation periods. They will not be removed but only minimized to the necessary extent. Such data will be stored for the period specified by law regulations and financial reporting regulations, and in the scope of investigation or security against claims, no longer than until the end of the calendar year in which the longest possible period of limitation of potential claims under civil law contractual liability expires under the applicable provisions of law or tort related to cooperation with LINITY.

VIII. Your rights

Withdrawal of consent. For future data processing, You can withdraw Your consent at any time - in cases requiring consent to the processing. However, this does not affect the lawfulness of data processing based on the consent granted before its withdrawal. In some cases, We may continue to process Your data after You withdraw Your consent, if We have a different legal basis for processing such data or if Your withdrawal was limited to certain processing activities.

Right of access. You have the right to obtain (i) confirmation as to whether We process Your data, and if so, (ii) detailed information about this data. Detailed data include the purposes of the processing, categories of data, potential recipients, or the storage period.

Right to rectification. You have the right to apply for rectifying incorrect data concerning You. If the data processed by Us is not correct, We will correct it without undue delay and notify You of the correction.

Right to erasure. You have the right to delete the data We store about You. Removal of data may limit or prevent the use of the System.

Right to data portability. You have the right to (i) receive a copy of Your data in a structured, commonly used and machine-readable format, and (ii) send this data to another data Administrator without obstruction on Our part.

Right to object. You have the right to object at any time to the processing of data, the legal basis of which is Our legitimate interest. This also applies to profiling based on these provisions. You also have the right to object to the processing of data for marketing purposes.

Right to restriction of the processing. In the following cases, You have the right to limit the processing of Your data by us:

You think that the processing of Your data is unlawful, but You do not want to delete it;
You still need the data to establish or pursue legal claims or defend against such claims; or
You have objected to the processing.

Exercising Your rights. To exercise the rights, as well as in the event of questions regarding the privacy rules and the processing of personal data, the Administrator should contact the following way:

i. at the email address: [email protected];

ii. in writing by sending correspondence to the following address: LINITY OÜ, Harju maakond, Tallinn, Lõõtsa tn 5 // Sepapaja tn 4, 11415 Estonia

However, We reserve that any such request, motion, or objection will be verified by Us in advance by the applicable provisions on the protection of personal data. These rights are not absolute, the provisions provide for exceptions to their application.

Right to lodge a complaint. You also have the right to lodge a complaint with the relevant authorities if You believe that the processing of Your data violates the provisions of the GDPR. The action should be brought, in particular, in the Member State of the person's habitual residence, place of work, or place of the alleged infringement. In the case of the territory of Poland, it will be the President of the Office for Personal Data Protection. For the UK it will be the Information Commissioner's Office. For Estonia, it will be Andmekaitse Inspektsioon (Estonian Data Protection Inspectorate).

In some cases, refusal to provide certain data will prevent Us from providing the requested services.

IX. Transferring Your data to countries outside the European Economic Area

Your data may be transferred outside the European Economic Area (EEA) to entities that meet an adequate level of protection, through:

cooperation with entities processing personal data in countries for which a relevant adequacy decision of the European Commission has been issued, such as US companies adhering to the Data Protection Framework.
use of standard contractual clauses issued by the European Commission.

X. Processing of data in an automated manner

Your data will be processed in an automated manner (including in the form of profiling), however, it will not cause any legal effects to You or similarly significantly affect Your situation.

XI. Changes to the Privacy Policy

We periodically review and update the Privacy Policy to keep it up to date with changes resulting from our ongoing business activities. You can always check the date of the privacy notice to find out when We last made changes. We will notify You when We make significant changes that You should be aware of. Version 2.0 is valid from 1^st of September 2023.