Privacy Policy

Last updated: Aug 18, 2020

1.          Introduction

1.1        This Privacy Policy applies to how we collect and use your Personal Data when you interact with us, visit our Website or use any of the Services.

1.2        We will use your Personal Data only for the purposes and in the manner set forth below and we take steps to ensure the processing of your Personal Data is in compliance with the Privacy Act.  We will also comply with any obligations that we have under other applicable law, to the extent that is applicable, including the GDPR.

1.3        By visiting our Website or using our Services you agree to our use of your Personal Data in accordance with this Privacy Policy (as amended from time to time).

1.4        If you do not agree with or are not comfortable with any aspect of this Privacy Policy, you should not use our Website or the Services.

1.5        This Privacy Policy is updated from time to time; therefore, you  should  review it occasionally.  Your continued use of our Website or the Services following the changes shall be deemed acceptance of the changes.

2.          Definitions and Interpretation

2.1        The following terms have the following meanings:

2.1.1     "us" or "we" refers to jLynx Limited, the owner(s) of our Website;

2.1.2     "you"  refers to the user or viewer of our Website;

2.1.3     “GDPR” refers to the General Data Protection Regulation;

2.1.4     “Personal Data” is any information that can or may be used to identify you and may include the information set out in clauses 4.1 and 4.2.

2.1.5      “Privacy Act” means the Privacy Act 1993;

2.1.6     “Services” refers to the services we provide via or through our Website; and

2.1.7     “Website” refers to our website, which  you use in conjunction with the Services.

2.2        References to the Privacy Act or other legislation includes any subordinate legislation, by-law, regulation, order, statutory instrument or determination made under it, any re-enactment of, or amendment to it and all legislation passed in substitution for that legislation.

3.          When does this Privacy Policy apply

3.1        This Privacy Policy applies to Personal Data that we collect, use and otherwise process about you.  We collect Personal Data from you in the following circumstances:

3.1.1     When you visit our Website;

3.1.2     When you request or use any of the Services

3.1.3     When you register, create or update an account with us;

3.1.4     When you purchase or order products or services from us;

3.1.5     When you communicate with us including when you make any inquiry or complaint;

3.1.6     When you comment or submit information in any online form; and

3.1.7     Where we are permitted to do so under law (including the laws of any foreign jurisdiction).

3.2        We gather some information automatically through our or third party systems we use including by the use of cookies (see below).

4.          Collection 

4.1        We may collect the following information:

4.1.1     Contact details, including your name, email address, physical and/or postal address, telephone number and other contact details;

4.1.2     Payment information;

4.1.3     Information that you provide when you communicate with us;

4.1.4     Information that you submit including in any forms you fill out on our Website;

4.1.5     Information about the location of your device; and

4.1.6     Information on the Services that you use.

4.2        We may also collect a series of general data and information when you visit our Website. This general data and information are stored in the server log files. The following information may be collected:

4.2.1     The browser types and versions used,

4.2.2     The operating system used by the accessing system;

4.2.3     The website from which an accessing system reaches our Website (so-called referrers);

4.2.4     The date and time of access to our Website;

4.2.5     An Internet protocol address (IP Address);

4.2.6     The Internet service provider of the accessing system, and

4.2.7     Any other similar data and information that may be used in the event of attacks on our information technology systems.

4.3        We do not draw any conclusions about the data subject and cannot identify a data subject as an individual.  

5.          Collection of other information

5.1        Some of the Services collect further information about other individuals including the following information:

5.1.1     The browser types and versions used;

5.1.2     The operating system used by the accessing system;

5.1.3     The website from which an accessing system reaches our Website (so-called referrers);

5.1.4     Information sent by your browser or application;

5.1.5     The date and time of the click on the short URL or view of the user’s website or social media channel with published IP-informer or IP-counter on it;

5.1.6     An IP Address of the user that clicked on the short URL or view of the user website or social media channel with published IP-informer or IP-counter on it;

5.1.7     The Internet service provider (ISP) of the user that clicked on the short URL or view of the user website or social media channel with published IP-informer or IP-counter on it;

5.1.8     Information about the geographical location of the ISP available from the publically available databases, and

5.1.9     Time zone and language.

5.2        You acknowledge and agree that you are responsible for receiving an acknowledgment, agreement and clear consent from any person to whom you send links using the Services or from whom you receive information.

6.          What Do We Use Your Personal Data For?

6.1        The main purposes for which we use your Personal Data are:

6.1.1     To process your account;

6.1.2     To provide the Services;

6.1.3     To develop and improve the Services (including service communication, insight, research, customer surveys and feedback);

6.1.4     To analyse and evaluate the use of our Services;

6.1.5     To support other administrative purposes;

6.1.6     To comply with all legal and regulatory requirements;

6.1.7     Where you have given us permission, to contact you from time to time to keep you up to date with limited offers, new services, company news and other promotions which we consider may be of interest to you;

6.1.8     Deliver the content of our Website correctly;

6.1.9     Optimize the content of our Website as well as its advertisement;

6.1.10   Ensure the long-term viability of our information technology systems and website technology;

6.1.11   To communicate with you and assist with your queries, requests or complaints;

6.1.12   To send you communications that we are required by law or which we need to provide;

6.1.13   To verify your identity and enable you to access our services in case you forget your password or account details;

6.1.14   Where necessary, to enforce any legal rights we may have, or to protect the rights, property and safety of you, us and others, including to provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack;

6.1.15   To provide adverts on our Website (see “Other Third Party Providers” below); and

6.1.16   Any other uses to which you consent.

7.          Entitlement

7.1        The legal basis for this use and other processing will include (as relevant):

7.1.1     You have provided us with your consent to the processing of your Personal Data;

7.1.2     To enable us to perform our obligations under any contract with you and other users;

7.1.3     To enable us to comply with any other contractual or legal obligation; and

7.1.4      For our legitimate interests provided these are not overridden by your interests and fundamental rights and freedoms

8.          Sharing Personal Data

8.1        We may disclose your Personal Data in the following circumstances:

8.1.1     To third parties who provide services for us, including auditors and professional advisors;

8.1.2     Where this is necessary to enforce our rights against you;

8.1.3     Governmental and regulatory authorities upon a valid request or as required by law including to comply with a court order or a request from a regulator or similar legal process or where otherwise necessary to comply with a legal obligation or for the administration of justice;

8.1.4     In the event of a merger, acquisition, or any form of sale of some or all of our assets to a third party, we may disclose your Personal Data to the third parties concerned or their professional advisors; and

8.1.5     Other third parties, where it is permitted by law, or where we have your consent.

9.          International transfers

9.1        Due to the global nature of our Website, our users may be located worldwide and your Personal Data may be transferred to third parties located in other countries. These other countries may either have different data protection laws than your country of residence or they may not have data protection laws. You consent to your Personal Data being transferred outside your country of residence.

9.2        We take reasonable steps to ensure that your Personal Data is adequately protected in accordance with the Privacy Act and the GDPR and not shared with third parties without your consent.

10.        Period for which the Personal Data will be stored

10.1     Your Personal Data will not be kept for longer than is necessary to fulfil the specific purposes outlined in this Privacy Policy and to allow us to comply with our legal requirements.

10.2     The criteria we use to determine data retention periods includes the following:

10.2.1   Retention in case of queries. 

We may retain your Personal Data for a reasonable period after you have enquired about Services, in case of follow up queries from you.

10.2.2   Retention in case of claims

We may retain your Personal Data for the period in which you might legally bring claims against us if and to the extent this is relevant.

10.2.3   Retention in accordance with legal and regulatory requirements

We may retain your Personal Data after the period of retention in the case of queries or claims (above) because of a legal or regulatory requirement. Some or all of these criteria may be relevant to retention of your Personal Data collected from you in connection with our Services.

10.2.4   Retention permitted under applicable law

10.2.5   We may retain your Personal Data  where this is necessary to provide the Services where the retention is necessary for the purposes of pursuing our legitimate interests or where it is necessary for public interest purposes.

10.3     Although reasonable efforts will be taken, it may not always be possible to completely remove or delete all of your Personal Data from our databases because of back-ups and other technical reasons. Where this is the case, we will take steps to ensure that your Personal Data is suppressed in order to render it unusable

10.4     Information such as IP Address, browser, operating system, HTTP Referrer and user agent, collected for your shorten URLs, counters and informers, designed for you to be able to collect statistics about visitors for your website, blogs or other resources on the internet, will be removed from the database after 1 year from the date of collection.

11.        Cookie Usage

11.1     There are instances where we may use cookies when you visit our Website or use the Services. 

11.2     Cookies are files that are downloaded to your computer automatically.

11.3     Cookies provide information about how visitors use our Website and Services and are used to help us improve our Website and the Services.

11.4     Any information collected not contain  any Personal Data which directly identifies  you as an individual.  

11.5     Your browser has the ability to decline cookies. This is done by setting your browser options to decline all cookies. If you do decline cookies, you may not be able to access some aspects of our Website or the Services.

11.6     Our advertisers may download cookies to which we have no control. If used, these cookies are downloaded by clicking on an advertisement found on our Website.

11.7     Please click here to learn more about the cookies that we use and how they are used them.

11.8     Please also see clause 12 and 13.

12.        Google

12.1     Google's advertising requirements can be summed up by Google's Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en

12.2     We use Google AdSense Advertising on our Website.

12.3     Google, as a third-party vendor, uses cookies to serve ads on our site. Google's use of the DART cookie enables it to serve advertisements to our users based on previous visits to our site and other sites on the Internet. You  may opt-out of the use of the DART cookie by visiting the Google Ad and Content Network privacy policy.

12.4     We have implemented the following:

12.4.1   • DoubleClick Platform Integration

We along with third-parties , including  Google use first-party cookies (such as the Google Analytics cookies and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our Website.

12.4.2   Opting out:

You can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising initiative opt out page or permanently using the Google Analytics Opt Out Browser add on.

12.5     We use Google Analytics that may collect Personal Data. Please read carefully Google services privacy policy by the link: https://policies.google.com/technologies/partner-sites .

13.        California Consumer Privacy Act (“CCPA”)

13.1     Under CCPA, Californian residents have the right to declare their preferences on the sale of data for advertising and marketing purposes. If you wish to change your preferences, click this link to launch our preference portal:

13.2     Californian residents also have the right to access and/or delete collected data about them. If you wish to invoke either right, please see this link. We use a third-party to provide monetisation technologies for our site. You can review their privacy and cookie policy here.

14.        Other Third Party Providers

14.1     We use the following third party providers who will or may use your Personal Data to provide their services:

14.1.1   Buysellads.com;

14.1.2   Tawk.to;

14.1.3   Google for the purposes described in clause 12; and

14.1.4   Other third party providers that provide services to us from time to time.

15.        Your Rights

15.1     You may have various rights under data privacy laws in your country. These may include (as relevant):

15.1.1   The right to request access to or a copy of the Personal Data we hold about you;

15.1.2   The right to rectification including the right to require us to correct inaccurate Personal Data;

15.1.3   The right to request that we erase your Personal Data in specific circumstances:

(a)        Where the Personal Data are no longer necessary in relation to the purpose for which it was originally collected/processed;

(b)        Where, in circumstances where we process Personal Data by virtue of your consent, you withdraw consent and there is no other ground for the processing; or

(c)         Where, in circumstances where processing Personal Data is necessary for our legitimate interests, you object to us processing your information and there are no legitimate grounds for processing; or

(d)        Where Personal Data are processed for direct marketing;

15.1.4   The right to request restriction of processing concerning you or to object to processing of your Personal Data in certain circumstances;

15.1.5   The right to data portability including to obtain Personal Data in a commonly used machine readable format where our processing of it is based on your consent and the processing is carried out by automated means;

15.1.6   The right, where we process your Personal Data for our legitimate interests, to object to the processing unless there are compelling legitimate grounds for the processing;

15.1.7   The right to withdraw your consent to the processing of your Personal Data;

15.1.8   The right to object to the processing of Personal Data for marketing;

15.1.9   The right not to be subject to automated decision making including profiling (if any) that has a legal or significant effect on you as an individual;  and

15.1.10            The right to any details of any persons to whom we disclose your Personal Data (unless we are prohibited from providing such information pursuant to applicable law).

15.2     To make any request under this clause you should:

15.2.1   Contact us via the details provided in the Contact section of this Privacy Policy; or

15.2.2   Complete the online form on our Website.

15.3     You can require that we cease the use of your Personal Information for marketing purposes by:

15.3.1   Using the unsubscribe feature in any message that we send to you; or

15.3.2   Logging in to your account and updating the appropriate preferences (if available) for that account;

16.        Security

16.1     We endeavour to use appropriate technical and physical security measures to protect your Personal Data from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access. These measures include: storing Personal Data in a private database which is accessed via an internal control panel protected with the username, password and IP Address of our authorised users; storing hashed information as opposed to passwords and using secure cloud storage on Azure for database backups. Our service providers are also selected carefully and required to use appropriate protective measures.

16.2     As effective as modern security practices are, no physical or electronic security system is entirely secure. The transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data and any other information that you provide, we cannot guarantee its security and any transmission is at your own risk.

16.3     Once we receive your Personal Data, we will use appropriate security measures to seek to prevent unauthorised access.  

16.4     In the event that there is an interception or unauthorised access to your Personal Data, we will not be liable or responsible for any resulting misuse of your Personal Data.

17.        Third Party Links

17.1     Our Website may contain links to third party websites.  These websites may or may not have privacy policies similar to our own.  You should check any relevant privacy policies or statements before providing your Personal Data to any third party.  We have no responsibility for Personal Data provided to third parties or for the policies or practices of third parties.  You access any third party websites at your own risk.

18.        Your Right to Lodge a Complaint with a Supervisory Authority

18.1     Without prejudice to any other administrative or judicial remedy you might have if you have any concerns or complaints about the manner in which your Personal Data has been collected, managed or processed by us, please contact us.

18.2     We will endeavour to resolve any complaint to your satisfaction. However, if you are unhappy with our response, you may contact the Privacy Commissioner who may investigate your complaint further. Further information about the application of the Privacy Act can be found at the website of the Privacy Commissioner at www.privacy.org.nz.

19.        Contacting Us

19.1     If you want to contact us with queries, requests, or comments you may have about our Privacy Policy or wish to exercise any of your rights under this Privacy Policy please get in touch via the following methods:

19.1.1   Contact form available on our Website;

19.1.2   Email: support@grabify.link or legal@grabify.link.

19.1.3   Postal address: P.O Box 66 Kumeu Auckland 0841 New Zealand