Privacy Policy

PEN-LINK, LTD is committed to respecting your privacy. This Privacy Policy (“Policy”) describes how PEN-LINK, LTD collects, uses and discloses information, and what choices you have with respect to the information. This Privacy Policy applies to all of PEN-LINK, LTD’s applications, Websites and Services, whether accessible via your web browser, SMS, or other medium. If you do not agree with the terms, do not access or use the Services, Websites or any other aspect of PEN-LINK, LTD’s business.

Definitions

“Customer” means a customer of PEN-LINK, LTD.

"Website" means any PEN-LINK, LTD content accessed through a web browser which does not require a user account.

"Application" means any PEN-LINK, LTD content accessed through a web browser via a registered user account.

"Service" means any PEN-LINK, LTD Application, Website or other service accessible via a web browser, SMS, or other medium.

"User" refers to anyone interacting with PEN-LINK, LTD Services according to our Policies. Users may be visitors to an PEN-LINK, LTD Website, Customers of PEN-LINK, LTD Applications, or employees, agents or representatives of Customers.

"Personal Data" means any information relating to an identified or identifiable natural person.

Information We Collect and Receive

When you use many features of our Services (for example, upload an image or bookmark a search) you create "User Data".

Additionally, when you use our Services, PEN-LINK, LTD may collect or generate “Other Information” on your behalf in a variety of ways:

  • Usage Information. When you interact with our Services, metadata is generated that provides additional context about the way Users work. For example, PEN-LINK, LTD logs the content, links and application features you interact with.

  • Account information. To use some of our Services you must create an account, and supply account details including contact information.

  • Log data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Service, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.

  • Device information. PEN-LINK, LTD collects information about devices accessing our Services, including type of device, what operating system is used, and device settings. Whether we collect some or all of this information depends on the type of device used and its settings.

  • Location information. We receive information from you and other third-parties that helps us approximate your location. We may, for example, use an IP address received from your browser or device to determine approximate location.

  • Cookie Information. PEN-LINK, LTD uses cookies and similar technologies in our Services. For more details about how we use these technologies, please see our Cookie Policy.

  • Additional Information Provided to PEN-LINK, LTD. We receive Other Information submitted to our Services when you request support, email us or otherwise communicate with PEN-LINK, LTD.

 

How We Use Information

In the event that a User is a Customer interacting with a Service, User Data will be used by PEN-LINK, LTD in accordance with the Customer’s provided instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and as required by applicable law. In this case, PEN-LINK, LTD is a processor of User Data and the Customer is the controller. The User may configure settings, access, modify, export, share and remove User Data and otherwise apply its policies to the Services.

Other Information generated during a User visit to an PEN-LINK, LTD Website is used by PEN-LINK, LTD in accordance with applicable law. In this case, PEN-LINK, LTD is the controller and processor of this Other Information, and may share this data with subprocessors as well (see our Subprocessor Policy for more information).

PEN-LINK, LTD uses Other Information in furtherance of our legitimate interests in operating our Services and business. More specifically, PEN-LINK, LTD uses Other Information:

  • To provide, update, maintain and protect our Services and business. This includes use of Other Information to support delivery of the Services under a Customer Agreement, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities or at a User’s request.

  • To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Other Information to respond.

  • To develop and provide additional features. PEN-LINK, LTD tries to make the Services as useful as possible for Users. For example, we may improve application functionality by using Other Information to help determine identify which features are being used by Users.

  • To send emails and other communications. We may send you service, technical and other administrative emails, messages and other types of communications. We may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. In addition, we sometimes send emails about new product features or other news about the Services. These are marketing messages so you can control whether you receive them.

  • For billing, account management and other administrative matters. PEN-LINK, LTD may need to contact you for invoicing, account management and similar reasons and we use account data to administer accounts and keep track of billing and payments.

  • To investigate and help prevent security issues and abuse.

  • If Information is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, PEN-LINK, LTD may use it for other business purposes (see below).

 

Data Retention

In the event that a User is a Customer interacting with a Service, PEN-LINK, LTD will retain User Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and as required by applicable law. The deletion of Customer Data and other use of the Services by Customer may result in the deletion and/or de-identification of certain associated Other Information.

PEN-LINK, LTD may retain Other Information collected through a Service for as long as necessary for the purposes described in this Privacy Policy. This may include keeping your Other Information after you have deactivated your account for the period of time needed for PEN-LINK, LTD to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

How We Share and Disclose Information

Customers of our Services determine their own policies and practices for the sharing and disclosure of Information, and PEN-LINK, LTD does not control how they or any other third parties choose to share or disclose Information.

  • Customer’s Instructions. PEN-LINK, LTD will solely share and disclose User Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and in compliance with applicable law and legal process.

  • Displaying the Services. When a User submits Other Information, it may be displayed within an Application Service to other Users in the same or connected Organization. For example, an Authorized User’s name may be displayed with their profile.

  • Collaborating with Others. Some Services provide different ways for Users to collaborate. Other Information, such as basic profile information, may be shared if the User chooses to collaborate.

  • Customer Access. System Administrators, Organization Owners, Users and other Customer representatives and personnel may be able to access, modify or restrict access to Other Information. This may include, for example, your employer using Service features to export logs of User activity, or accessing or modifying your profile details.

  • Third Party Service Providers and Partners. We may engage third party companies or individuals as service providers or business partners to process Other Information and support our business. These third parties may, for example, provide virtual computing and storage services. Additional information about the subprocessors we use to support delivery of our Services is set forth in the Subprocessor Policy.

  • Affiliates and Partners. PEN-LINK, LTD may share Other Information with its corporate affiliates, parents, partners and/or subsidiaries.

  • During a Change to Business. If PEN-LINK, LTD engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of PEN-LINK, LTD’s assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence), some or all Other Information may be shared or transferred, subject to standard confidentiality arrangements.

  • Aggregated or Non Personally Identifiable Data. We may disclose or use automatically-collected, aggregated, or otherwise non-personally-identifiable Other Information. For example, we may share aggregated or non-personally-identifiable Other Information with prospects or partners for business or research purposes, such as telling a prospective customer the average amount of time spent using a typical feature.

  • To Comply with Laws. If we receive a request for information, we may disclose Other Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process.

  • To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property or safety of PEN-LINK, LTD or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.

  • With Consent. PEN-LINK, LTD may share Other Information with third parties when we have consent to do so.

 

Security

We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We maintain appropriate administrative, technical and physical safeguards to protect data against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the data in our possession. This includes, for example, firewalls, password protection and other access and authentication controls.

We use TLS technology to encrypt data during transmission through public internet, and we also employ application-layer security features to further anonymize your data. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential.

However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store on the Service, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you believe your data has been compromised, please contact us as set forth in the “Contact Information” section.

If we learn of a security systems breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.

Age Limitations

To the extent prohibited by applicable law, PEN-LINK, LTD does not allow use of our Services and Websites by anyone younger than 16 years old. If you learn that anyone younger than 16 has unlawfully provided us with Personal Data, please contact us and we will take steps to delete such information.

 

International Data Transfers

PEN-LINK, LTD may transfer your User Data to countries other than the one in which you live. Our Data Processors and Subprocessors may operate in Canada, the United States or the European Union. We use safeguards if PEN-LINK, LTD transfers User Data originating from the European Union or Switzerland to other countries not deemed adequate under applicable data protection law. PEN-LINK, LTD offers Standard Contractual Clauses to meet the adequacy and security requirements for our Customers that operate in the European Union, and other international transfers of User Data. You can view a copy of our standard data processing addendum.

Data Controller and Data Processor

Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, the Customer is the controller of Customer Data. In general, PEN-LINK, LTD is the processor of User Data and the controller of Other Information. Different PEN-LINK, LTD entities provide the Services in different parts of the world. See the Subprocessor Policy.

Your Rights

Individuals located in certain countries, including the European Economic Area, have certain statutory rights in relation to their Personal Data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. You can usually do this using the settings and tools provided in your Services account. If you cannot use the settings and tools, contact us for additional access and assistance.

To the extent that PEN-LINK, LTD’s processing of your Personal Data is subject to the General Data Protection Regulation, PEN-LINK, LTD relies on its legitimate interests, described above, to process your data. PEN-LINK, LTD may also process Other Information that constitutes your Personal Data for direct marketing purposes and you have a right to object to PEN-LINK, LTD’s use of your Customer Data for this purpose at any time.

Updates

From time to time, PEN-LINK, LTD may modify these Terms or Policies. We will endeavor to provide the owner of Customer’s account with notice of any changes, along with posting such updates here. Please check back frequently for updates. The date these policies were last updated can be found at the top of this page.

 

Contact Information

You can contact us online at support@penlink.com, or by mail at:

PEN-LINK, LTD 5944 VANDERVOORT DRIVE

LINCOLN, NE 68516

USA