Privacy Policy

Last updated: January 26th , 2026

PenLink Ltd. and its affiliates (referred to as “Penlink,” “we,” “us,” or “our” in this Privacy Notice) value your privacy and are dedicated to safeguarding your personal information.

Penlink provides intelligence and analytics platforms (the “Platforms”) to support its Customers’ complex investigations and enhance its Customers’ security. As used in this Privacy Notice, a “Customer” means a third party who uses the Platforms from Penlink pursuant to an agreement between the parties.

In most cases, Penlink processes information solely at the direction of its Customers (“Customer Data”), including data uploaded by Customers to the Platforms or data obtained through third-party APIs made available to Customers by Penlink. In these cases, our Customer is the “data controller” of Customer Data and we are the “data processor.” Our processing of Customer Data is governed by our agreements with Customers and not this Privacy Notice.

This Notice applies when Penlink acts as the data controller of your information, which includes when we:

• Collect information from visitors to our websites (including https://www.penlink.com/ and other domains operated by Penlink on which we post this Privacy Notice) (“Websites”);
• Collect information from third-party sources and license such information to our Customers; and
• Otherwise interact with you through online and offline channels.

This Notice outlines our practices regarding the collection, use, and protection of such information, and provides information about your privacy rights. PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION.

 

 

1. Information We Collect

We collect information: a) directly from you, b) automatically using cookies and other similar technologies, and c) from third parties.

Information You Provide Directly to Us. We collect information about you that you provide to us when you use the Platforms or Websites or otherwise interact with us through online or offline channels. For example, we collect information from you when you:

• Visit our Websites;
• Register for and use the Platforms;
• Fill out a form on the Websites or download material, including software, from us;
• Correspond with us via the Websites or through other channels, including via phone, email, a chat functionality, or otherwise, such as for customer support purposes;
• Subscribe to our mailing lists, newsletters, or other forms of marketing communications;
• Respond to or participate in surveys;
• Attend our conferences or events, or otherwise interact with us at other conferences or events.

Depending on how you interact with us, the types of information we collect directly from you may include:

• Contact information (e.g., first and last name, email address, mailing address, country of origin, and telephone number);
• Log-in credentials for the Platforms;
• Employment information (e.g., your company or organization name; your job title). Job applicants may be asked to provide a resume or other professional biography;
• Transaction information, such as your purchase history and records of purchases;
• In accordance with applicable legal requirements, recordings or transcripts of sales and customer service calls with us (whether over the phone, Zoom, or another platform);
• Payment information, which is collected and processed by our third-party payment processors on our behalf;
• Any other information you choose to provide directly to us.

You may choose whether to provide certain information to Penlink, but if you choose not to provide certain information, we may not be able to provide the Platforms to you or respond to your other requests.

Information We Collect Automatically. When you use our Websites and Platforms, we and our vendors automatically collect certain information about your device and how you use the Websites and Platforms, including your IP address, browser type, browser language, operating system, the state or country from which you accessed the Websites and Platforms, software and hardware attributes (including device IDs), referring and exit pages and URLs, platform type, the number of clicks, search terms, files you download, domain names, landing pages, pages and features viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Websites and Platforms, error logs, and other similar information. From your IP address, we may be able to infer your general location (e.g., city/state or postal code).

To collect this information, we and our vendors may use “cookies,” server logs, and other similar technologies that track, measure, and analyze the behaviors and usage patterns on our Websites and Platforms. We may also allow third parties to place cookies and other similar technologies on our Platforms. Cookies are small data files that can be stored on your browser and device. We use cookies for a variety of purposes, including analytics and advertising purposes, to recognize you when you return to the Platforms, to deliver certain features of the Platforms, to help us understand how users engage with the Platforms, and to improve your experience. You may set your web browser to notify you when you receive a cookie and to accept or refuse certain cookies. However, if you elect not to accept cookies, some functionality and areas of the Platforms may be impacted. To learn how to manage your cookies, please follow the instructions from your specific browser, or if accessing the Platforms via a mobile device, refer to the device manufacturer’s instructions.

For more details, please refer to the “Online Analytics and Advertising” section below.

Information We Collect from Third Parties.

Information relating to Customers. From time to time, we may collect information about you from other sources, including our corporate affiliates, marketing vendors, survey providers, data enhancement services, data brokers, other websites and services, social media, conferences, and other industry events, to the extent permitted by applicable law.

Information licensed to Customers. We may receive information about individuals from other sources, including from data aggregators, data brokers, other companies, social media platforms, public databases, and other commercially available sources. Such information may include your name, email, phone number, address, approximate date of birth, educational and employment information, information you include in social media profiles (including picture), and historical information about the precise geolocation of your device (which may constitute “sensitive information” under certain U.S. state laws). This information is made available to Customers in connection with their use of the Platforms.

 

 

2. How We Use Your Information

We and our service providers may use your information for various purposes, depending on the context and the type of information, including to:

• Provide Customers with access to the Websites and Platforms;
• To provide, operate, maintain, administer, and analyze our Websites and Platforms;
• Communicate with you with transactional information about the Websites and Platforms, respond to your requests, and provide you with more effective and efficient customer service, including via email, and postal mail;
• Contact you by email or postal mail with statements, updates, information, promotions, surveys or contests relating to the Websites or Platforms or other services that may be of interest to you, in accordance with applicable legal requirements related to such communications;
• Engage in analysis and research regarding use of the Platforms, to improve our Platforms, and develop new Platforms (which may involve the use, in accordance with applicable law, of artificial intelligence and large language model processing technologies);
• Allow us and our advertising partners to personalize the content and advertising that you see on the Websites and on third-party websites;
• Measure the effectiveness of our advertising and deliver relevant advertising to you;
• Secure our Websites and Platforms and resolve technical issues;
• Comply with applicable laws, rules, and regulations, obtain legal counsel, and establish, exercise, or defend our legal rights;
• Protect the safety, rights, property or security of the Websites, Platforms, us, our users, employees, third parties, and members of the public;
• Prevent fraud and enforce our legal terms and policies; and
• With your consent or at your direction, for any other purpose.

Aggregate/De-Identified Information. We may aggregate and/or de-identify any information that we collect so that such information can no longer be linked to you or your device (“De-Identified Information”). We may use De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also disclose such data to any third parties, including advertisers, partners, and sponsors.

Combined Information. We may combine the information that we collect from any source listed in this Notice and use such combined information in accordance with this Notice.

Legal Bases for Using Your Information. In applicable jurisdictions, we rely on the following legal bases for using your information as set out in this Notice, as relevant given the type of information and the context and purpose for using it:

• Where we need to perform the contract we are about to enter into or have entered into with you for the Platforms;
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
• Where processing is necessary in order to protect the vital interests of the data subject or of another natural person;
• Where we need to comply with a legal or regulatory obligation; or
• Where we have your consent to process your information in a certain way.

 

 

3. How We Disclose Your Information

We may disclose your information to the following categories of recipients:

• Affiliates and subsidiaries. We may disclose the information we collect within the Penlink family of companies.
• Our Customers. We provide information we collect, including combined information, to our Customers as part of provision of our Platforms.
• Service providers and advisors. We may disclose your information to our service providers and advisors that perform services on our behalf, which may include billing and payment, sales and marketing, customer relationship management, data storage, web hosting, security, fraud prevention, analytics, lead generation, content, legal, or consulting services.
• Advertising and related analytics partners. We may allow third-party advertising technologies (e.g., ad networks and ad servers) to use cookies and similar technologies on the Platforms to deliver relevant and targeted content and advertising to you on other websites you visit and applications you use, as explained further in “Online Analytics and Advertising” below.
• Purchasers and third parties in connection with a business transaction. We may disclose your information to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business, including for the purpose of determining whether to proceed or continue with such transaction or business relationship.
• Law enforcement, regulators, and other parties for legal reasons. We may disclose your information to third parties as required by law or if we believe in good faith that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) enforce our agreements, including terms applicable to the Platforms, or to protect the security or integrity of our Platforms; and/or (c) exercise or protect the rights, property, or personal safety of Penlink, our agents and affiliates, our customers, or others.
• Otherwise with your consent or at your direction. In addition to the disclosures described in this Notice, we may disclose your information to third parties whenever you consent to or direct such disclosures (subject to any restrictions in our agreements with our customers).

 

 

4. Online Analytics and Advertising

Online Analytics. We may use third-party web analytics services (such as those of Google Analytics) on our Websites to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; and provide certain features to you. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here. If you receive email from us, we may use certain analytics tools, such as clear GIFs, to capture data, such as when you open the email or click on any links or banners in the email. This data allows us to gauge the effectiveness of our communications and marketing campaigns.

Tailored Online Advertising. We allow select third party advertising technology partners to place cookies or other tracking technologies on the browser of your device to collect information about you through our Websites, as discussed above. These third parties (e.g., ad networks and ad servers such as Google) may use this information to serve relevant content and advertising to you as you browse the Internet, and may access their own cookies or other tracking technologies on your browser to assist in this activity. For more information about these online advertising activities, and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative, the Digital Advertising Alliance’s Consumer Opt-Out link, or Your Online Choices to learn how to opt-out of receiving tailored advertising. We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms. Please note that if you use these mechanisms, you may still see advertising about our Websites and Platforms or across the Internet, but it may not be tailored to you based on your online behavior over time.

For more information about your choices regarding use of these technologies, please see the “Your Rights and Choices” section below.

 

 

5. Security, Retention, and Transferring Your Information

Security. We implement a variety of technical, administrative, and organizational measures to protect your information against accidental or unlawful access, destruction, loss, misuse, change or damage. However, no Internet or email transmission is ever fully secure or error-free. Please keep this in mind when disclosing any information to us.

Retention of your information. We will only retain your information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of our legitimate business interests and satisfying any legal or reporting requirements.

International transfers of your information. Please note that we are based in the United States, and may also process information in other locations, such as the European Union and United Kingdom. You should be aware that any information we process is transmitted to us in the United States and other locations where we or our vendors or partners are located. Your information will be protected subject to this Notice and applicable law, which may be different from the laws in your country. By using the Platforms or accessing the Websites, you acknowledge such transfers.

 

 

6. Your Rights and Choices

Marketing Communications. In accordance with applicable law, we may send you marketing communications regarding our Platforms or the services of third parties that we believe will be of interest to you. You may use the unsubscribe link found at the bottom of emails we send to you to opt out of receiving future marketing emails. Please note that, regardless of your request, we may still use and disclose certain information as permitted by this Notice or as required by applicable law. For example, you may not opt out of certain administrative or transactional emails from us, such as those confirming your requests or providing you with updates regarding this Notice or our other terms.

Rights Regarding Your Information. Depending on your jurisdiction of residence (including the EU, UK, California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah and Virginia and other U.S. states with similar privacy laws), you may have the right, in accordance with applicable data protection laws, to make requests related to your “personal information” or “personal data” (as such terms are defined under applicable law, and collectively referred to in this section as “personal information”). These rights differ by jurisdiction and by your relationship with us. Specifically, you may have the right to ask us to:

• Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties to which we disclose personal information;
• Confirmation that we are processing your personal information;
• Provide you access to and/or a copy of personal information we hold about you in a readily usable format (where technically feasible and legally required);
• Correct or update personal information we hold about you;
• Delete personal information we have about you;
• Restrict or object to certain uses of your information;
• Opt you out of the processing of your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable; or
• Oregon and Minnesota residents only: request a list of the specific “third parties” other than natural persons (as “third party” is defined under the Minnesota Consumer Data Privacy Act and the Oregon Consumer Privacy Act), to which we have disclosed information (subject to any applicable exemptions).

You may also have the right to opt out of “sales” of your information and “sharing/processing” of your personal information for targeted advertising as described below. If you are a California resident, please see our notice to California residents below. The California section also contains information about our disclosure of personal data that is required under Colorado law.

Please note that certain information may be exempt from such requests under applicable law. For example, we need certain information in order to provide the Platforms to you or comply with applicable law or cooperate with law enforcement requests or investigations. We may also withhold information to the extent that it is a trade secret protected from disclosure under applicable law.

We may take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address, or your IMEI or other device ID. If we are unable to verify your identity, we may be unable to respond to your requests. As provided in applicable law, you also have the right to not be discriminated against for exercising your rights.

To exercise any of these rights, you can reach us by using this form or by contacting us at [email protected]. California residents may designate an authorized agent to make the requests listed above on your behalf. Depending on the request made on your behalf, in order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request as permitted by applicable law.

If you are a resident of Colorado, Connecticut, Delaware, Iowa, Indiana, Kentucky, Maryland, Minnesota, Montana, Oregon, Nebraska, New Hampshire, New Jersey, Rhode Island, Tennessee, Texas, or Virginia and we deny your information request, you may have the right to appeal our decision to deny your request. We will provide information about how to exercise that right in our response denying the request. You also have the right to lodge a complaint with a supervisory authority.

If you believe we process your information on behalf of a Customer under an agreement with such Customer, please direct your query to the relevant Customer, as this may expedite the completion of your request.

Notice of Right to Opt Out of Sales of Personal Information and Processing/Sharing of Personal Information for Targeted Advertising Purposes. If you are a resident of one of the U.S. states listed in the previous section, you or your authorized agent may also have the right to opt out of “sales” of your personal information and “sharing/processing” of your personal information for targeted advertising.

Cookie-based opt-out. As explained in the “How We Disclose Your Information” and “Online Analytics and Advertising” sections above, we may provide personal information (including device and network identifiers and browsing history) to third-party advertising providers for targeted advertising purposes or use related analytics partners to assist us in analyzing use of our Websites and Platforms. Under applicable law, the disclosure of your personal information to these third parties for these purposes may be considered a “sale” of personal information or the processing/sharing of personal information for targeted advertising purposes.

If you would like to opt out of the disclosure of your information to such third parties through cookies and similar tools for purposes that could be considered “sales” for those third parties’ own commercial purposes, or “sharing” or processing for purposes of targeted advertising, please click the “Your Privacy Choices” link on our website footer. Note that you will need to opt out on each device you use to access the Platforms. Note, if you use a cookie blocker such as Ghostery, it may block visibility of the link or impede functionality of the link.”

Opt out of sales of personal information to Customers and limit use of sensitive personal information. We may also make information we obtain from third parties and/or combined information (which may include name, email, phone number, address, approximate date of birth, educational and employment information, information you include in social media profiles (including picture, and any other information, including sensitive information, that you include in such profile), and historical information about the precise geolocation of your device (which may constitute sensitive personal information under applicable laws)) available to our Customers as part of the Platforms. You may send us a request to opt out of our disclosure of your information for these purposes, or to limit the use of your sensitive personal information, via this form.

Please note that we require authorized agents to provide proof of authorization from the consumer to make an opt-out request on behalf of a consumer.

 

 

7. Notice to California Residents

If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and disclose your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)).

Throughout this Notice, we discuss in detail the specific categories of personal information we collect from and about you. As set forth in “Information we collect” above, we collect information directly from you, automatically using cookies and other similar technologies, and from third parties such as data aggregators, data brokers, other companies, social media platforms, public databases, and other commercially available sources.

We provide additional information required by the CCPA below.

Category of Personal Information Collected	Purpose of Use of Personal Information	Categories of Other Parties to Which this Personal Information is Disclosed
Contact Information (such as your name, address, email address)	• Provide the Platforms and respond to your requests • Contact you with relevant information and offers • Customize content, and analyze use of and improve the Platforms • Business Transfers • Comply with law or defend our legal rights • Security/fraud prevention • Create aggregate/de-identified information	• Affiliates and Subsidiaries • Service Providers • Our Customers • Advertising and Related Analytics Providers • Entities for legal purposes or with your consent
Financial information (e.g., bank account or credit card details)	• Provide the Platforms and respond to your requests • Business Transfers • Comply with law or defend our legal rights • Security/fraud prevention	• This information is collected by third-party payment processors on our behalf
Commercial information (such as subscriptions you have purchased)	• Provide the Platforms and respond to your requests • Contact you with relevant information and offers • Customize content, and analyze use of and improve the Platforms • Business Transfers • Comply with law or defend our legal rights Security/fraud prevention • Create aggregate/de-identified information	• Affiliates and Subsidiaries • Service Providers • Advertising and Related Analytics Providers • Entities for legal purposes or with your consent
Login Information (such as your account name and password)	• Provide the Platforms and respond to your requests • Business Transfers • Comply with law or defend our legal rights • Security/fraud prevention • Create aggregate/de-identified information	• Affiliates and Subsidiaries • Service Providers • Entities for legal purposes or with your consent
Device and Online Information (such as device identifiers, IP address, browsing history, and usage information)	• Provide the Platforms and respond to your requests • Customize content, and analyze use of and improve the Platforms • Business Transfers • Comply with law or defend our legal rights • Security/fraud prevention • Create aggregate/de-identified information	• Affiliates and Subsidiaries • Service Providers • Our Customers • Advertising and Related Analytics Providers • Entities for legal purposes or with your consent
Professional or employment-related information (such as your job title and company or organization name)	• Provide the Platforms and respond to your requests • Contact you with relevant information and offers • Customize content, and analyze use of and improve the Platforms • Business Transfers • Comply with law or defend our legal rights • Security/fraud prevention • Create aggregate/de-identified information	• Affiliates and Subsidiaries • Our Customers • Service Providers • Entities for legal purposes or with your consent
Historical Precise geolocation data	• Provide the Platforms • Business Transfers • Comply with law or defend our legal rights • Security/fraud prevention	• Affiliates and Subsidiaries • Our Customers • Service Providers • Entities for legal purposes or with your consent
Audio or visual data	• Provide the Platforms • Respond to your requests • Business Transfers • Comply with law or defend our legal rights • Security/fraud prevention	• Affiliates and Subsidiaries • Our Customers (photo only) • Service Providers • Entities for legal purposes or with your consent
Inferences (derived from the above categories of personal information)	• Contact you with relevant information and offers • Customize content, and analyze use of and improve the Platforms • Business Transfers • Comply with law or defend our legal rights • Security/fraud prevention • Create aggregate/de-identified information	• Affiliates and Subsidiaries • Service Providers • Advertising and Related Analytics Providers • Entities for legal purposes or with your consent

Opt Out of Sale/Sharing of Personal Information. The CCPA sets forth certain obligations for businesses that “sell” personal information or “share” personal information for cross-context behavioral advertising purposes.

If you would like to opt out of our use of your personal information through cookies and similar technologies for purposes that are considered a “sale” or “sharing” for cross-context behavioral advertising purposes under the CCPA (as indicated in the chart above), please click the “Your Privacy Choices” link on our website footer. If you have a legally recognized opt out preference signal turned on via your device browser, such as Global Privacy Control, we recognize the preference expressed by such signal for that browser in accordance with applicable law.

You may send us a request to opt out of our disclosure of your information to Customers for purposes that are considered a “sale” or “sharing” for cross-context behavioral advertising under the CCPA via this form.

We do not knowingly sell the personal information of minors under 18 years of age.

Right to Limit Use of Sensitive Personal Information. We may collect certain categories of information about you that are considered “sensitive personal information” under the CCPA, including precise geolocation or other sensitive information that you may include in a social media profile. To exercise your right to limit our use of such information, please submit your request via this form.

Additional California Privacy Rights. California residents may make certain requests about their personal information under the CCPA as set forth in “Your Rights and Choices” section above.

If we ever offer any financial incentives in exchange for your personal information, we will provide you with appropriate information about such incentives.

Shine the Light. The California “Shine the Light” law gives residents of California the right under certain circumstances to request, on a yearly basis, information about our disclosure of certain categories of “personal information” (as defined in the Shine the Light law) to third parties for their own “direct marketing purposes” (as defined in the Shine the Light law), or in the alternative, that we maintain a policy of providing a cost-free means for consumers to opt out of any such disclosure. You can exercise your rights under the California “Shine the Light” law – which gives you the right to opt out of the sharing of certain categories of personal information (as defined in the Shine the Light law) with third parties for their own direct marketing purposes – by emailing us at [email protected] with the subject line “Shine the Light Request”. If you want to opt out of activities that are considered “sales” or “sharing” under the California CCPA, please follow the instructions above.

Do Not Track. California law requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Because there currently isn’t an industry or legal standard for recognizing or honoring DNT signals, we don’t respond to them at this time. Please note that Do Not Track is a different mechanism than the legally recognized browser-based opt out preference signal mentioned above.

 

 

8. Third-Party Links

The Website and Platforms may include links to third-party websites, plug-ins and applications. Clicking on those links or interacting with such content may allow your data to be shared with the relevant third-party. We do not control these third-party websites and are not responsible for their privacy statements; we therefore recommend that you read the privacy notice of every website you visit.

 

 

9. Changes To this Notice

We reserve the right to change this Notice at any time. If we do so, we will post an updated version of this Notice. Your continued use of our Website and Platforms after any change to this Notice will constitute your acceptance of such changes.

 

 

10. Notice to Customer End Users

Where you use the Platforms in connection with a Customer’s subscription to the Platforms (a “Customer End User”), that Customer is the administrator of the Platforms and is responsible for the accounts over which it has control. If you are a Customer End User, please direct your privacy questions and any requests to exercise any rights you may have regarding your information to such customer, as your use of the Platforms is subject to that organization’s policies. Please note that our customers may make decisions about how you use the Platforms in accordance with their own policies and procedures, including by requiring you to use identity verification tools or location-based features, and choosing whether to integrate with third-party apps and integrations.

In addition, please be aware that the administrator of your account may be able to view and access information that you provide to the Platforms and information about your use of the Platforms. Our Agreements with our Customers may require or permit us to provide certain information we collect to such Customers.

Please contact your organization or refer to your administrator’s organizational policies for more information.

 

 

11. Contact Us

If you have any questions or would like to speak with us regarding this Notice, please, contact us through our Contact Us page, email us at [email protected], or call us at +1-402.421.8857