Privacy Policy

01Who We Are

Linkstone Holdings LLC is a company organized in the United States, with its principal place of business at:

We carry on business in both the United States and the United Kingdom. For the purposes of the UK GDPR and the Data Protection Act 2018, Linkstone Holdings LLC acts as the data controller in respect of personal data it collects from, or relating to, individuals in the United Kingdom, unless otherwise stated.

02Scope of This Policy

This Policy applies to personal information we collect:

• Through our websites, applications, and other digital services;
• In connection with the sale or provision of our products and services;
• From customers, prospective customers, business contacts, and vendors;
• Through customer support, sales, and marketing interactions;
• From publicly available sources, third-party partners, and service providers acting on our behalf.

This Policy does not apply to information collected by third parties, including through any third-party application, website, product, or service that may link to or be accessible from our services, or to information we process on behalf of our business customers as a service provider or processor, which is instead governed by our contractual arrangements with those customers.

03Personal Information We Collect

The categories of personal information we may collect about you include:

• Identifiers: name, postal address, email address, telephone number, date of birth, and government-issued identification numbers where required.
• Commercial information: records of products or services purchased, obtained, or considered, and other purchasing or consumption histories.
• Financial information: payment card details, bank account information, billing address, and transaction history (typically processed via a third-party payment processor).
• Online identifiers and usage data: IP address, device identifiers, browser type, operating system, pages viewed, referring URLs, and interaction data collected via cookies and similar technologies.
• Professional or employment-related information: job title, employer, and business contact details, where you interact with us in a business capacity.
• Correspondence: information you provide when you contact us, including customer support communications and survey responses.
• Special category / sensitive data: we do not intentionally collect sensitive personal data (such as health information, racial or ethnic origin, or religious beliefs) unless you voluntarily provide it or it is otherwise necessary and lawful to do so.

We collect this information directly from you, automatically through your use of our services, and from third parties such as service providers, business partners, and publicly available sources.

04How We Use Personal Information

We use personal information for the following purposes:

• To provide, operate, and maintain our products and services;
• To process transactions, orders, and payments;
• To communicate with you, including responding to inquiries and providing customer support;
• To send marketing communications, subject to your preferences and applicable consent or opt-out requirements;
• To personalize and improve our services, including through analytics;
• To maintain the security and integrity of our services, prevent fraud, and enforce our terms;
• To comply with applicable legal, regulatory, and contractual obligations;
• For internal business purposes, including recordkeeping, auditing, and corporate governance.

05Legal Bases for Processing (United Kingdom)

Where the UK GDPR applies, we rely on the following legal bases to process your personal data:

• Performance of a contract: where processing is necessary to perform a contract with you or to take steps prior to entering into one;
• Legitimate interests: where processing is necessary for our legitimate business interests (such as improving our services, preventing fraud, or direct marketing), provided those interests are not overridden by your interests or fundamental rights;
• Consent: where you have given clear consent for us to process your personal data for a specific purpose, such as certain marketing communications or non-essential cookies;
• Legal obligation: where processing is necessary for us to comply with a legal or regulatory obligation.

You may withdraw consent at any time where consent is the basis for processing, without affecting the lawfulness of processing carried out before withdrawal.

06How We Share Personal Information

We do not sell personal information for money. We may share personal information with the following categories of recipients:

• Service providers and processors who perform services on our behalf, such as payment processing, IT hosting, analytics, and customer support, under contractual obligations to protect your data;
• Professional advisors, including legal, accounting, and financial advisors;
• Regulators, law enforcement, and other public authorities, where required by law or to protect our rights, property, or safety, or that of others;
• Business transaction parties, in connection with a merger, acquisition, financing, reorganization, or sale of some or all of our assets;
• Affiliates and related companies, for purposes consistent with this Policy.

As noted in Section 10 below, Linkstone does not currently meet the applicability thresholds under U.S. state privacy laws such as the CCPA/CPRA. If this changes, we will comply with any applicable requirements relating to the sale or sharing of personal information.

07Cookies and Similar Technologies

We and our service providers use cookies, web beacons, and similar tracking technologies to operate our services, remember your preferences, and understand how our services are used, including for analytics and advertising purposes. Where required by applicable law (including the UK's Privacy and Electronic Communications Regulations), we will obtain your consent before placing non-essential cookies on your device and will provide mechanisms for you to manage your cookie preferences. You can also control cookies through your browser settings; please note that disabling cookies may affect the functionality of our services.

08International Data Transfers

Because we operate in both the United States and the United Kingdom, personal information may be transferred between these jurisdictions, and to other countries in which we or our service providers operate. Where personal data originating in the United Kingdom is transferred to the United States or another country that has not been recognized as providing an adequate level of data protection, we will implement appropriate safeguards as required by the UK GDPR, such as the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses, or another lawful transfer mechanism.

09Data Retention

We retain personal information for as long as necessary to fulfil the purposes for which it was collected, including to provide our services, comply with legal, tax, and accounting obligations, resolve disputes, and enforce our agreements. Retention periods vary depending on the nature of the information and applicable legal requirements. When personal information is no longer required, we securely delete, destroy, or anonymize it.

10Your Privacy Rights – United States

A number of U.S. states have enacted comprehensive consumer privacy laws (such as the California Consumer Privacy Act, as amended by the California Privacy Rights Act, and similar laws in states including Colorado, Connecticut, Utah, and Virginia). These laws generally apply only to businesses that meet certain thresholds, such as minimum annual revenue or minimum volumes of consumer personal information processed.

Based on the nature and scale of its operations, Linkstone Holdings LLC does not currently meet the applicability thresholds under these state privacy laws. Nonetheless, we are committed to handling personal information responsibly, and if Linkstone's activities change such that any U.S. state privacy law becomes applicable, we will comply with the rights afforded under that law and will update this Policy accordingly. If you have questions about how we handle your personal information, you may contact us using the details at the end of this Policy.

11Your Privacy Rights – United Kingdom

If you are located in the United Kingdom, you have the following rights under the UK GDPR and the Data Protection Act 2018, subject to certain exceptions:

• Right of access to your personal data;
• Right to rectification of inaccurate or incomplete personal data;
• Right to erasure ("right to be forgotten") in certain circumstances;
• Right to restrict processing in certain circumstances;
• Right to data portability, where processing is based on consent or contract and carried out by automated means;
• Right to object to processing based on legitimate interests or for direct marketing purposes;
• Rights related to automated decision-making and profiling, where applicable;
• Right to withdraw consent at any time, where processing is based on consent.

You also have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) if you believe our processing of your personal data infringes applicable data protection law. Further information is available at www.ico.org.uk.

12Children's Privacy

Our services are not directed to children, and we do not knowingly collect personal information from children under the age of 13 (or under 16, where applicable under U.S. state law, or under 13 under the UK GDPR and the Data Protection Act 2018) without appropriate consent. If we become aware that we have inadvertently collected personal information from a child in violation of applicable law, we will take steps to delete such information promptly.

13Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, disclosure, alteration, or destruction. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

14Third-Party Links

Our services may contain links to third-party websites or services. We are not responsible for the privacy practices of third parties, and we encourage you to review their privacy policies before providing any personal information.

15Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The updated version will be posted or otherwise made available, and material changes will be communicated in accordance with applicable legal requirements.

16Contact Us

If you have questions about this Privacy Policy or wish to exercise any of the rights described above, you may contact us at: