PenLink Ltd. (referred to as “we,” “us,” or “our” in this Privacy Notice) values your privacy and is dedicated to safeguarding your personal information.
This privacy notice (“Notice”) aims to inform you about how we handle your personal data when you visit our website (https://www.penlink.com/) (“Website”) and to make you aware of your privacy rights. This Notice outlines our practices regarding the collection, use, and protection of your personal information.
This Privacy Notice complements other notices you might receive from us in the context of our interactions or those provided by other entities, but it is not meant to replace them.
CCPA Compliance. For residents of California, the CCPA provides certain rights regarding the collection, use, and sharing of personal data. We respect those rights and provide California residents with the ability to access, delete, or opt-out of the sale of their personal data. We do not sell personal information, and we take steps to ensure that your personal data is handled securely and in accordance with your preferences.
GDPR Compliance. For individuals within the European Economic Area (EEA), the GDPR offers comprehensive data protection rights. We adhere to GDPR principles by ensuring lawful processing of personal data, providing clear information about data use, and respecting your rights to access, correct, delete, restrict, or object to the processing of your personal data. Furthermore, we implement robust data protection measures to secure your information and minimize data transfer risks.
Personal Data We Collect
Website Data. Personal data means any information about an individual from which that person can be identified. When you use this Website, we may collect the following types of personal data on you:
- Identity Data includes first name, last name, company, job title, and country of residence. Career applicants may also provide a curriculum vitae or a link to their LinkedIn profile.
- Contact Data includes email address and telephone number.
- Usage Data includes information about how you use our Website (such as, date and time on which you entered the Website, system specifications and how long you stayed in the Website) as well as your IP address.
- Additional Inquiry Data includes additional information that you may provide when you contact us through the Website.
Statistical Data. We also collect, use and share aggregated data such as statistical data for any purpose. Such information does not reveal your identity and therefore is not considered personal data. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature.
Third Parties Data. May include mobile location data associated with mobile advertising Ids. This information is not associated with your name, email address, or phone number.
Protecting the Privacy Rights of Third Parties. If you provide any personal data relating to others to us, you must make sure that you have permission to do so.
Opt-out Requests. To opt out of our disclosure of your personal or advertising Id data, please send us an email and provide your name, email address and related the identifiers, so we can see if we have any associated data and communicate with you about this request.
How We Collect Personal Data
We use different methods to collect data from and about you including through
- Direct interactions. You may provide us your Identity Data and Contact Data by entering your details on our Website, including when you apply for open positions that we post on our Website, or by providing such details to PenLink representatives in events and conferences.
- Automated technologies or interactions. As you interact with our Website, we may automatically collect Technical Data on equipment, browsing actions and patterns. We collect this data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
- Third parties. We may receive personal data about you from third parties, such as Usage Data provided by analytics providers.
You are not legally obligated to provide any personal data to PenLink. Any personal data that you choose to provide to PenLink, is provided at your own free will.
How We Use Personal Data
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
Promotional Offers. We may use your Identity, Contact and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
Cookies. When you visit our Website, we may place cookies onto your device, or read cookies already on your device, subject to your consent where required by applicable law.
Third-Party Links. This Website 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.
We share personal data with third party service providers that provide us services in connection with the purposes listed above (such as sales, business management and marketing services) as sub-contractors in terms of Art. 28 GDPR. We may also share your personal data with:
- legal and regulatory authorities to the extent required by applicable law;
- our professional advisors (e.g. lawyers, accountants) to the extent necessary for the provision of their services; and
- third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets, or parties whose business we wish to acquire.
Sharing Personal Data With Others
We share personal data with third party service providers that provide us services in connection with the purposes listed above (such as sales, business management and marketing services) as sub-contractors in terms of Art. 28 GDPR. We may also share your personal data with:
- legal and regulatory authorities to the extent required by applicable law;
- our professional advisors (e.g. lawyers, accountants) to the extent necessary for the provision of their services; and
- third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets, or parties whose business we wish to acquire.
We require such third parties to respect the security of your personal data and to treat it as required by applicable law and/or in accordance with binding contractual obligations of confidentiality. We permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
Data Providers Information
When an End User engages with an App, we will only collect the information detailed below from your device if you have expressly consented to third-party collections. we may obtain this information through our trusted partners, who are obligated to secure your explicit consent beforehand.
Data Identifiers: This includes the hashed MD5 email of End Users (applicable if the mobile application offers in-app sign-in), the iOS® Identifier for Advertising (for iOS devices), or the Android™ Advertiser ID (for Android deices).
Technical Data: This encompasses details about the mobile device you use, such as the manufacturer and model, operating system and platform, and location on the devices you employ to access data providers.
To opt out of our disclosure of your advertising ID and location data, please provide your name and email address so we can communicate with you about this request, and provide your mobile ad ID and device type so we can check to see if we have any data associated with your device.
Cookies Policy
What are Cookies?
Cookies are small text files sent to your device by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.
How We Use Cookies And Online Tracking Technologies?
- When you use and access the Website, we may place multiple cookies files in your web browser. We use third party cookies in our Website, i.e., cookies that are stored by a website other than the one you are visiting. We use the following types of third-party cookies:
- Performance Cookies collect data on the performance of our Website such as the number of visitors, the time spent on the Website, which pages are visited most often, etc.
- Necessary Cookies are necessary to allow the technical operation of a website (e.g., they enable you to use its features).
- Functionality Cookies enable a website to remember certain user preferences with respect to the website.
- Targeting Cookies make advertising on a website and on other platforms more relevant to users.
Please note that this Cookies Policy does not apply to, and we are not responsible for, the privacy practices or policies of third party websites which may be linked to or accessible through this Website.
Your Choices: Managing Cookies And “Opting Out”
Most web browsers allow some control of most cookies through the browser settings. Each browser and device is different, so check the settings menu of your browser or device to learn how to change your advertising settings/cookie preferences.
For more information about cookies, including how to see what cookies have been set, visit http://www.aboutcookies.org or www.allaboutcookies.org. In particular, for more information on how you can control or limit the information Google collects using cookies, please review Google’s notice on how it uses information from sites or apps that use Google services and Google’s privacy policy.
Please note:
PenLink has no affiliation with, and is not responsible for, these third party websites.
If you choose not to receive cookies at any time, the Website may not function properly and certain services will not be provided.
Data Security and Retention
We have put in place appropriate security measures to prevent your personal data from accidental or unlawful loss, use, alteration or disclosure. We also maintain reasonable technical and physical safeguards to protect your personal data. Unfortunately, we cannot guarantee against the loss or misuse of your personal data or secure data transmission over the Internet because of its nature.
We retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for accounting, legal or reporting requirements. If it is not necessary for achieving that purpose, we will delete it automatically. If personal data has been processed for several purposes and is only necessary for one of these purposes anymore, it will only be processed for such valid purpose. This can e.g. be the case with regard to our legal bookkeeping obligations.
In order to determine the appropriate retention period for personal data, we consider the following criteria: the volume, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data, the purposes for which we collect and process personal data, the timeframe during which we may require such personal data in connection with potential litigation, and applicable legal requirements.
GDPR Notice
If you are located in the European Economic Area or if the EU General Data Protection Regulation 2016/679 (“GDPR”) applies to your personal data, you may be entitled to the following rights regarding the personal data that we process:
- The right to be informed of the usage of your personal data;
- The right to access the personal data we have on you. This includes confirming if your personal data is being processed, access to the data and information about the processing purposes; the types of personal data involved; the recipients or categories of recipients who have or will receive your personal data; the planned storage duration of the data; your rights to correct, delete, or limit the processing of your personal data or to oppose such processing; the right to file a complaint with a supervisory authority; the source of the data if not collected directly from you; any automated decision-making processes, including profiling; and the safeguards for transferring your personal data outside the EEA.
- The right to have inaccurate personal data corrected;
- The right to deletion of your data under certain conditions;
- The right to limit the processing of your personal data;
- The right to oppose processing if it is based on our legitimate interests;
- The right to withdraw consent for data processing at any time when consent is the basis of processing;
- The right to oppose the processing of personal data for direct marketing at any moment;
- The right to data portability, allowing you to request a transfer of your data to you or a different service provider when processing is based on consent and carried out by automated means.
- The right to lodge a complaint with your local Supervisory Authority as defined under the GDPR.
To exercise any of these rights, as they apply to you, please contact us using the provided contact details. We aim to respond to your request within the timeframe required by applicable law. While we make every effort to accommodate your requests, there may be instances where we cannot fulfill your request if it is considered unfounded or not applicable under relevant laws. In such cases, we reserve the right to refuse your request regarding your personal data. We may need to verify your identity by requesting specific information or identification before we can fulfill any request.
CCPA/CPRA Notice
Pursuant to the California Consumer Privacy Act of 2018 as amended (“CCPA”), PenLink, in scope of the CCPA are providing this California Consumer Privacy Act Notice (“CCPA Notice”). This CCPA Notice supplements our Privacy Policy and applies solely to California consumers, effective January 1, 2020. Terms used but not defined shall have the meaning ascribed to them in the CCPA. This CCPA Notice does not apply to personal information that we collect from job applicants, contractors or employees.
PenLink may collect personal information from our affiliates; our customers; data suppliers and service providers; partners with which we offer co-branded services or engage in joint event or marketing activities; and social networks. We may share this personal information with: our affiliates; our customers; service providers, agents and representatives; joint venture partners; and other parties where required by law or to protect our rights.
We may use this personal information to operate, manage, and maintain our business, to communicate with you, for our vendor management purposes, and to accomplish our business purposes and objectives, including, for example, using personal information to: personalize, advertise, and market our products and services; conduct research, analytics, and data analysis; maintain our facilities and infrastructure; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform accounting, audit, and other internal functions; comply with law, legal process, and internal policies; maintain records; exercise and defend legal claims; and fulfill legal obligations.
You have the right to request that we disclose to you (i) the categories of personal information we collected about you and the categories of sources from which we collected such information; (ii) the specific pieces of personal information we collected about you; (iii) the business or commercial purpose for collecting personal information about you.
You have the right to request that we delete personal information we collected from you subject to certain exceptions. You also have the right to not be discriminated against in pricing and services because you exercise any of your rights under the CCPA.
You may make a request for the disclosures, opt-out, or deletion described above through our Contact Us page.
You may be required to submit proof of your identity for these requests to be processed. Such information may include your First Name, Last Name, Street Address, City, Zip, and Date of Birth and either your Social Security Number or your Driver’s License Number and State. This information will be used only for the purposes of verifying your identity and processing your request. We may not be able to comply with your request if we are unable to confirm your identity or to connect the information you submit in your request with personal information in our possession. You may designate an authorized agent to make a request on your behalf subject to proof of identity and written authorization.
We will update this CCPA Notice from time to time. Any changes will be posted on this page with an updated revision date.
Changes To This Privacy Notice
We reserve the right to change this Privacy Notice at any time. If we do so, we will post an updated version of this Privacy Notice so that our users and customers are always aware of what information we collect, use, and disclose. Your continued use of our Website and services after any change to this Privacy Notice will constitute your acceptance of such change. This version was last updated in February 2024.
Contact Us
If you have any questions or would like to speak with us regarding changes to your personal information, please email us at [email protected], call us at +1-402.421.8857