INTRODUCTION

Welcome to Linka!

Linka is a Service of Linka Technology. Inc. All visitors to our Service (“Visitors”) who register with the Service and join a Linka Platforms are Members or Admins. Admins are the organizers of Linka Platforms. Members register and participate in Linka Platforms. Admins decide who can join their Linka Platform and whether they choose paid Member subscriptions on their Linka Platform. This Privacy Policy describes how we, Linka Technologies, Inc., obtain and use information about you and your visits to our website at joinlinka.com and your participation in a Linka platform and your use of Linka Technology mobile applications. To offer the personalized experience of Linka, we collect personal information about you (“Personal Data”). This policy describes how we collect, use, and share your Personal Data with your Admin and other Members in connection with your use of the Service, including our mobile applications. Unless defined here, capitalized words have the same meaning as in the Linka Technology Terms of Use, which this Privacy Policy is part of.

For residents of New York, the New York Privacy Notice and EU/ EEA/ UK Privacy Notice supplement and form part of this Privacy Policy.

COLLECTION OF INFORMATION

1.Information we collect and how we use it When you visit our website, join or create a Platform, interact with us or your Admin through the Service, or use our mobile applications, we, as the service provider for your Admin, collect Personal Data and other information from you (collectively, “Data”). We use your Personal Data to be able to provide the Service to you:

We collect Personal Data when you share it voluntarily.

We collect some Personal Data automatically when you visit our website, use the Service or use our Linka mobile applications.

We and your Admins use your Personal Data to provide and improve the Service, understand how you and other Members are using Linka and to inform you about products and services that may be of interest to you.

Data does not include Your Content or User Generated Content. As we explain in our Terms of Use, you (and the people you license Your Content from) keep complete ownership of all Your Content. By posting Your Content on the Service, you grant us a license to use it, but you and your licensors still own it.

A. Personal Data you provide directly

‘Personal Data or Personal Information’ means any information relating to you from which you can be identified, directly or indirectly, including your name, identification number, location, online identifier such as your IP address or device ID, or one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity.

‘Special Categories of Personal Data’ means data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and data concerning your health, sex life or sexual orientation.

‘Aggregated Data’ is data in a summary form for statistical analysis. A common purpose of aggregation is to get more information about particular groups based on specific variables such as age, profession, or income level.

‘Pseudonymisation’ means the processing of your personal data in a way that the personal data can no longer identify you without the use of additional information, so long as the additional information is kept separately and is subject to technical and organizational measures to prevent you from being identified or identifiable. We store and use your Personal Data together with an ID we assign each time you join a new Linka Platform.

Name and Email Address. When you register as a Admin or Member of a Linka Platform, we ask you for your real name and your email address. Both we and the Admin of the Linka Platform receive access to this information and use it to communicate with you about the Service. In addition, we and your Admin may use this address to email you about products or services believed to be of interest to you. If you are a paying Admin or Member, we may also collect your mailing address and zip code for billing purposes. Admins may decide to collect your mailing address, via our Services.

Social Media Profiles. You can also register with your Facebook, Google, or LinkedIn account. When you register this way, you give us permission to access your Facebook, Google, or LinkedIn profile and photo. Your profile and photo will become part of your Linka profile. See below for more information on Integrated Services like Facebook and LinkedIn.

Profiles and Topics. When you join a Linka Platform, you will be prompted to add a profile, including a short bio, and choose groups or events to join. From this information, Linka Technology personalizes your experience in each Linka Platform. Your Admin can also choose and customize categories of Personal Data to collect from you including, if you agree, Special Categories of Personal Data.

Your Location. We ask you for your location so that we can facilitate interactions with other Members in your geographic area. In addition, if you opt-in our mobile app collects your GPS location information. If you enable location features, or do notdisable GPS on your mobile device, other Members may be able to see your location.

Other Personal Data You Provide Directly. You may also provide us Personal Data when you use certain features of the Service such as participating in conversations or polls in your Linka Groups, contact us with inquiries, or respond to one of our surveys.

B. Personal Data and Information we collect automatically

You have the option of registering using an Integrated Service, such as Facebook. Please see the section below on Integrated Services for more detail. Information About Your Use of the Service. Our servers automatically record your visits to the Service. Like all other website and mobile app servers, ours compiles a log that records the date, time, browser (i.e., Firefox), device type (i.e., iPhone), operating system (i.e. Android), and originating IP address of each page you visit.

We use cookies to collect information about your visits to our website and Service. Cookies are text files placed on your computer by websites to collect standard log information and visitor behavior information. Our cookies collect the following information about you: which website or ad you visited right before ours, which pages you visited on our Service, and how much time you spent on each section of our Service. We may also collect other data about your visit, such as search requests and results. We use this information for our legitimate interests to track usage of our Service, to measure the number of unique visitors to the different sections of our Service, to understand how Members find and Linka Technology, and to help us make our Service more valuable to every Admin and Member. The use of this information is called “analytics.” Often information used for analytics is aggregated.

Our mobile applications on iOS (Apple) and Android (Google) have to interact with our computer servers. We assign your device a token so that you do not have to log in every time you use the Service via our mobile apps.

You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some of our Service features may not work properly without cookies. Most browsers accept cookies automatically but allow you to disable them. For more information about cookies visit https://www.allaboutcookies.org.

Information About Your Location. From your IP address, we can tell generally where you are when you are accessing our Service, such as which city. We start by choosing a location for you based on the IP address of your Internet connection. You can update or remove this location at any time by logging in to your account on the Service.

C. Personal Data and Information Third Parties collect automatically

Third-Party Cookies for Site Use Analysis. We use third parties such as Google to help us analyze how people are using our Service. We also use the Google Analytics service to provide us with demographic data about our Admins and Members, such as age and gender. Google uses a cookie that can be recognized by Google or its affiliate DoubleClick when you visit other websites. For more information about how Google collects, uses, and shares your information, please visit the Google Privacy Policy- Partners website at https://www.google.com/policies/privacy/ partners/.

Third-Party Cookies Used to Target Ads on Other Websites.

“Beacons” are transparent pixel images that are used in collecting information about website usage across websites and over time. Our Admins may use their own or third party cookies or beacons to target Admin ads to you when you visit other websites. Our Admins may also work with other companies who use their cookies or beacons to target third party ads to you on other websites based on your prior visits to the Admin’s Platform on our website Service. This is called online behavioral advertising (“OBA”), because you receive ads based on your prior online behavior. We do not have access to these cookies; it is third parties who engage in OBA.

OUR SHARING OF PERSONAL DATA AND OTHER INFORMATION

2. Our Sharing of your Personal Data and other information We consider personalizing your Linka experience an important part of our Service. We want you to understand what Personal Data gets shared with your Admins/Admins, other Members of your Linka Platforms, other Admins or Members of our Service, and other third parties as part of the Service.

‘Third Party’ means a person or company who is not an Admin or another Linka Member, and government bodies and public agencies and authorities. Third Parties include our service providers whom we authorize, through a data processing agreement, to process your personal data or information to help us with: development, maintenance, and support of our websites and mobile applications, marketing and advertising, marketing research and analysis, communications, and customer service. We do not permit our Third Party service providers to use your personal data for any other purpose. We do not share Personal Data with any person or company unless we have an agreement with them that controls their use of the data.

‘Processing’ or ‘Process’ means any operation or set of operations performed on personal data or on sets of personal data, including by automatic methods, such as collecting,

recording, organizing, structuring, storing, adapting or altering,retrieving, consulting, using, disclosing, transmitting, sharing or otherwise making available, aligning or combining, restricting, erasing or destroying.

‘Consent’ or ‘Agree’ means you’re freely given, specific, informed and unambiguous expression of your wishes through a statement or other clear affirmative action such as checking a box which indicates your agreement to our processing of personal data relating to you.

If you are not comfortable with this type of sharing, don’t use our Service.

A. Personal Data shared within the Service

Your Admin. Your Admin, or Admins if are there more than one, will have access to your name, email address, and all personal or contact information that you provide when you register for that Admin’s Linka Platform. In order to facilitate Member engagement, our Admin will also have access to Data regarding your usage activity, in both aggregated and personally identifiable forms. For example, Admins will be able to see aggregated Member activity within a Linka Platform, as well as specific information like how many people cheered in response to a comment you made. Your Admin also will be able to associate Your Content, and any Personal Information it contains, with your contact information. Your Admin may communicate with you outside of the Service about the Linka Platform or relevant topics of interest to you, and may retain your personal information after you leave the Linka Platform, unless you request otherwise. Admins have committed in the Linka Technology Terms of Use (/terms-of-use) to comply with applicable laws and regulations about their handling of Data and not to sell your information to third-parties. You should only join a Linka Platform if you are comfortable sharing your personal information with the Admin of that Linka Platform. If your Admin has an additional privacy policy covering the Admin’s use of Personal Data, youshould review it carefully to understand how your Admin may use Personal Data.

Searching and Messaging by Others. Visitors to our Service may be able to search for you by your name and location if you are a Member of a Linka Admin. Members of your Linka Admin can search for you by location, Topics, or other personal information so that they may message you within the Linka Admin. Whether your information is available to other Visitors and Members depends on whether the Linka Platform or Group is Public, Private, Open Paid or Private Paid.

Public, Private, Open Paid, and Private Paid Linka Platform or Group. A Admin can select whether to make a Linka Platform Public, Private, Open Paid, and Private Paid.

In Public Linka Platforms or Groups, all Visitors (including Admins and Members) can see your name and photo (“Profile”), as well as Your Content and activity. Unless your Admin specifies otherwise, in a Public Linka Platform, search engines like Google index all public activity, including Profiles.

In Private Linka Platforms or Groups, any Visitor can find the Linka group but cannot enter without an invitation or membership request approval. Only Admins and other Members can see Profiles, Your Content, and activity.

In Open Paid Linka Platforms or Groups, Visitors can see the content but will be prompted to join to unlock more content. It is available to search engines. Admins and other Members can see Profiles, Your Content, and activity.

In Private Paid Linka Platforms or Groups, Visitors can find the Linka Platform or Group, but cannot enter without paying the fee. Only Admins and other Members can see Profiles, Your Content, and activity. Personal Information Included in Your Content. If you include personal information in Your Content, it will be displayed to other

Members based on the privacy levels defined above.

B. Personal Data and Information shared with Third Parties

Integrated Services. If you have used the option to register using an Integrated Service, such as Facebook, we share your information with the operators of the Integrated Service. More information is in the sections below entitled “Integrated Services.”

This applies to the Google Play store for the app Linka created by Linka Technologies. We take your privacy seriously and are committed to protecting your personal data.

Information We Collect- The app only collects personal data that you voluntarily provide to us. The personal data collected may include your:

• Name
• Email address
• Any other personal information you choose to provide

How We Use Information Any personal data you provide through the app is used only to provide and improve the app’s services. We do not share your personal data with any third parties without your consent.

Security- We have implemented technical and organizational measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration or disclosure. However, we cannot guarantee that unauthorized third parties will never be able to overcome those measures or use your personal information for improper purposes.

Business Transfers. As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution, or similar event, Personal Data may be part of the transferred assets.

Agents, Consultants and Third Parties Whom We Have Contracts With. Linka Software, Inc., like many businesses, sometimes hires other companies to perform certain business-related functions. Examples include emailing information to you, maintaining our website, databases and mobile applications, processing payments, marketing and advertising, marketing research and analysis, and customer service. When we employ another company to perform a function of this type, we only provide them with the Personal Data and Information they need to perform their specific function and we do not authorize these service providers to use or disclose your personal information except as necessary to perform the tasks we have asked them to do for us or to comply with legal requirements. Our list of the Third Parties we use to assist us with our personal data or information needs is here.

Legal Requirements. We may disclose your Personal Data if required to do so by law or in the good faith belief that suchaction is necessary to (i) comply with a legal obligation, (ii) cooperate with a legal investigation or a request from a government authority, (iii) protect and defend the rights or property of Linka Software, Inc., (iv) protect the legal rights, safety, and security of users of our website and the Service, (v) protect our legal rights and legitimate interests, and those of our business partners, service providers, and customers; (vi) prevent fraud; (vii) act in urgent circumstances to protect the personal safety of users of the Service or the public, or (v) protect against legal liability.

C. Aggregated data shared

We disclose aggregated statistics, such as number of Admins and Members, in order to describe our Service to current and prospective business partners, and to our Third Party service providers for our legitimate interests and other lawful purposes.

PERSONAL DATA RIGHTS

3. Your Personal Data Rights

You have rights regarding the Personal Data and Information we have about you.

You may object to, or restrict, our collection, use, sharing, transfer and/or storage of your personal information. You may also request a copy of the information that we have about you. You may also ask us to correct or remove personal information you think is incorrect.

If an Admin (the data controller) is using the Service to process your personal information, you may contact the Admin to object, restrict, access, correct or delete your personal information. If you need help finding contact information for your Admin’s privacy officer, please contact us at [email protected]

If you have a registered account in the Service, you may object, restrict, access, correct, or request deletion or a copy of some or all of your Personal Data or Information by logging in to your account.

If you do not have a registered account in the Service and you would like to object, restrict, access, correct, delete, or request a copy of some or all of your personal information, please email, write, or call us.

Please note, we will keep your personal information for as long as necessary for us to provide the Service to you. We will also keep and use your personal data or information to comply with laws including tax laws and other applicable laws. We will also keep your Personal Data and Information as necessary for backup, archiving, audit, preventing fraud, resolving disputes, and troubleshooting problems.

If you are a New York resident, please see our New York Privacy Notice for more details about our compliance with New York’s privacy laws.

If you are a member of the EU/ EEA/ UK, please see our EU/ EEA/ UK Privacy Notice for more details about our compliance with EU/ EEA/ UK privacy laws.

YOUR CHOICES

4. Your choices

A. Linka Technology and Admins you trust

You get to decide the Linka Platforms you want to join. You also get to decide whether you trust your Admin with the information sharing described in this policy.

B. Public, Private, Open Paid, or Private Paid Linka Technology settings

An Admin can choose to make a Linka Technology Public, Private, Open Paid or Private Paid as described above.

C. Adjust your notification settings

In your account settings, you can control the frequency, type, and mode of notifications you receive through the Service. You can choose to be notified by email or mobile alerts, both, or neither. You can choose to turn on or off your notifications by type, such as cheers on your posts and direct chat messages.

D. Opt out of email

We would like to send you information about our services that you may be interested in. If you have agreed to receive marketing messages from us, you may opt-out at any time. We provide an opt-out link at the bottom of each email message.

Because we plan our communications in advance, it may take several weeks for your opt-out request to take effect. If you continue to receive marketing messages from us or an Admin after you opt-out, please let us know so that we can investigate the situation.

E. Opt out of Google Analytics

To prevent your data from being used by Google Analytics, click here for instructions.

F. Opt out of Google behavioral advertising

To opt out of Google behavioral advertising, click here to see your Google ad settings.

G. Opting out of tracking

Please see our Cookie Policy for important information about non-Google cookies that are placed by us or by our business partners on your computer, mobile phone or other device and how to opt out. We do not have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologiesthat may be placed on your computer, mobile phone, or other device by non-affiliated, third-party ad technology, ad servers, ad networks, or any other non-affiliated third parties. If you would like to learn more about OBA or to opt out of having this information used by companies that are part of the Advertising Initiative to deliver targeted ads, please visit https://www.networkadvertising.org/managing/opt_out.asp , or if you are located in the UK, European Union/European Economic Area, please visit European Interactive Digital Advertising Alliance (EDAA) Your Online Choices website at http://www.youronlinechoices.eu/. Please note you will continue to receive generic ads.

H. Deleting cookies

To manage or delete browser cookies, please see your browser’s privacy settings.

ACCOUNT TERMINATION

5. Account termination

You can leave one or more of your Linka Technology, or delete your Linka Technology account. As soon as you leave, we stop collecting your Personal Data for that Linka Technology.

6. Exclusions

This Privacy Policy does not apply to any Personal Data collected by Linka Technology, Inc. outside the Service, such as a telephone call. This Privacy Policy does not apply to any unsolicited information you provide to Linka Technology, Inc. through the Service or through any other means, such as information posted to any public areas of the Service, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and Linka Technology, Inc. shall be free to reproduce and use such Unsolicited Information without limitation orattribution. We respect your copyrights in Your Content, as outlined in our Terms of Use.

DISPUTES WITH ADMINS OR OTHER MEMBERS

7. Disputes with Admins or other Members

Linka Technology cannot control the actions of Admins or other Members; if you have a privacy-related dispute with an Admin or another Member, you should contact that person directly. You should alert us [email protected] if you believe that an Admin or another Member has violated this Privacy Policy or our Acceptable Use Policy.

CHILDREN

8. Children

Linka Technology does not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, please do not use the Service or submit any Personal Data through the Service. If you have reason to believe that a child under the age of 13 has provided Personal Data to Linka Technology through the Service, please contact us at [email protected] and we will look to delete that information from our databases.

LINKS TO OTHER APPS

9. Links to other web applications

This Privacy Policy applies only to the Service. The Service may contain links to other websites not operated or controlled by Linka Technology, Inc. (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. The links from the Service do not imply that Linka Technology, Inc. endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information about their privacy policies and practices.

10. Integrated services

One of the special features of the Service is that it allows you to enable various online Third Party services, such as social media and social networking services like Facebook and LinkedIn (each, an “Integrated Service”), to integrate directly into your LinkaTechnology. By directly integrating these services, we make your use of Linka Technology richer and more personalized. To enable Integrated Services, we will ask you to authorize Linka Technology to access the Integrated Services (or vice versa). When you add an Integrated Service account to a Linka Technology (or vice versa), your log-in information, Personal Data, non-personal data, location information, your content, your Linka Technology name, your Linka Technology location, your Linka Technology affiliation, profile photo, Facebook Connect ID, Profile (if you are integrating your Facebook account) and other relevant personal information may be passed through to, or received from, the Integrated Service in connection with your use of the Service. We may import, use, disclose, and retain such data and information to, among other things, customize and improve the Service for you and others. Note that Integrated

Services may also import, use, and retain this information. You may be able to control how certain information is shared with us in your privacy settings within the Integrated Services. However, please remember that the manner in which Integrated Services collect, use, store, and disclose your information is governed solely by the policies of the companies operating those Integrated Services, and we shall have no liability or responsibility for the privacy practices or other actions of any Integrated Service that may be enabled within the Service. If, and only if, you have elected to integrate your Linka Technology with an Integrated Service, we may share your information with Integrated Services. This may happen when you first register with Linka Technology, when you log into Linka Technology from time to time, or in emails or other communications we may send you consistent with this Privacy Policy. We may from time to time share your Personal Data and anonymous data, your location information, your Linka Technology Membership, your Linka Technology URL, your location, and your use of certain features on Linka Technology with Integrated Services to facilitate and enhance your use of the Integrated Services. Please keep in mind that services providedby Integrated Services are not provided by us and therefore your use of the Integrated Services will be governed by the Integrated Services’ Terms of Use and other policies, and that the collection, use, and disclosure of information provided by you or us to Integrated Services is not governed by this Privacy Policy.

SECURITY OF PERSONAL DATA

11. Security of Your Personal Data

We use appropriate technical and organizational measures including encryption, aggregation, and pseudonymization to protect your Personal Data provided via the Service from loss, misuse, and unauthorized access or use, disclosure, alteration, or destruction. However, no Internet, email, or other electronic transmission is ever 100% secure or error free, so we cannot guarantee that your Personal Data will never be accessed, used, or disclosed, so you should take special care in deciding what information you share on the Service. “Phishing” is a scam designed to steal your Personal Data or Information. If you receive an emaile-mail that looks like it is from us asking you for information about you, please contact us at [email protected]

YOUR NY PRIVACY RIGHTS

12. Your New York privacy rights

Residents of New York should review the New York Privacy Notice for more information about your rights and our compliance with New York privacy laws

YOUR EU/EEA/UK PRIVACY RIGHTS

13. Your EU/ EEA/ UK privacy rights

Our Service is provided from within the United States and subject to state and federal laws of the United States. If you are located outside the United States, your Personal Data is being transferred to, stored, used, and shared in the United States. If you are a resident of the EU/ EEA or UK, please see our EU/ EEA/ UK Privacy Notice for more information about your rights and our compliance with applicable laws.

14. Access to information; contacting us

To keep your Personal Data accurate, current, and complete, please update your account settings or contact us at the email address below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Service.

Please also feel free to contact us if you have any questions about Linka Technology’s Privacy Policy or the information practices of the Service. Our email address for privacy issues is [email protected].

CHANGES TO PRIVACY POLICY

15. Changes to Linka Technology’s Privacy Policy

We keep this Privacy Policy under regular review, and we will notify you when we make changes in the future. Please review this policy periodically, and especially before you provide any Personal Data to us. We will also place any updates on our website. This privacy policy was last updated on the date indicated at the top of this document.

We have no liability or responsibility for the privacy policies or practices of our Admins or other actions of any Integrated Service that may be enabled within the Service.