Last updated: NOVEMBER 10, 2022
This Privacy Policy describes policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve
the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions


The words of which the initial letter is capitalized have meanings defined below or in Our License agreement located at our web site under: .
The following definitions shall have the same meaning regardless
of whether they appear in singular or in plural.


For the purposes of this Privacy Policy:
means a unique account created for You to access our Service or parts of our Service.
(referred to as either "the Company", "We", "Us" or "Our"
in this Agreement) refers to Social Links Inc., 228 Park Ave S, PMB 85451 New York, NY 10003, United States and its affiliates.

For the purpose of the GDPR, the Company is the Data Controller.
are small files that are placed on Your computer, mobile device or any other device by a website, containing
the details of Your browsing history on that website among
its many uses.
refers to: United States
Data Controller
for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes
and means of the processing of Personal Data.
means any device that can access the Service such
as a computer, a cell phone or a digital tablet.
Personal Data
is any information that relates to an identified or identifiable individual.

For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
refers to the SL PRO product of the Company.
Service Provider
means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate
the Service, to provide the Service on behalf of the Company,
to perform services related to the Service or to assist
the Company in analyzing how the Service is used.
For the purpose of the GDPR, Service Providers are considered Data Processors.
Usage Data
refers to data generated manually and/or automatically while You are using the Service with the limitations set out below.
refers to Social Links, accessible from
means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.

Collecting and Using Your Personal Data

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
Types of Data Collected
1) Your contact details (especially title, first name, last name, business email address, address, telephone numbers, job position, company details),
2) Your payment information (bank details).
We process personal data which we receive from our customers or other parties concerned in the course of our business relationship. In the context of the business relationship you are obliged to provide such personal data which is required in order to enter, conduct or terminate a business relationship and to perform the corresponding contractual obligations or such personal data which we are legally obliged to collect. Without this data we shall regularly not be able to conclude a contract with you or to conduct or terminate such a contract.

We do not use or access in any manner personal data that You may input or access when using our Service.

Usage Data

Usage Data is generated manually and/or automatically when You are using the Service.

Usage Data may include information such as Your data provided in the context of search queries with our software (IP address, contents of the search input, date and time of the request, operating system, language and version of the browser software).

We do not retain, use or access in any manner any Usage Data that relates to third parties and that You may input or access when You are using our Service.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:
Cookies or Browser Cookies
A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
Flash Cookies
Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how You can delete Flash Cookies, please read "Where can I change the settings for disabling, or deleting local shared objects?" available at
Web Beacons
Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use both Session and Persistent Cookies for the purposes set out below:
Necessary / Essential Cookies
Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

Cookies Policy /
Notice Acceptance Cookies
Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
Functionality Cookies
Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:
We process personal data in accordance with the provisions of the EU General Data Protection Regulation (GDPR) for the performance of contractual obligations (Article 6 (1) sentence 1 lit. b of the GDPR).

The processing of data is carried out in order to provide services in the course of the performance of the contracts with our customers or the performance of pre-contractual measures that are provided upon request. The purposes of the processing primarily depend on the actual product (e.g. distribution of software licenses) and can include, inter alia, needs analysis and consulting.
We may share Your personal information in the following situations:
With Service Providers
We may share Your personal information with Service Providers to monitor and analyze the use of our Service, for payment processing, to contact You.
For business transfers
We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
To the extent necessary for the performance of our services, we also process personal data which is transferred to us by our affiliates and partners
We also process personal data based on your consent (Article 6 (1) sentence 1 lit. a of the GDPR). If you give your consent to the processing of personal data for a specific purpose (e.g. disclosure of data to subcontractors, evaluation of license and payment data for marketing purposes, newsletters) the processing is considered lawful based on your given consent. Declarations of consent must be given freely. The declaration of consent must indicate the purpose of the processing of data. If you have given your consent to the processing of your data, you may withdraw your consent at any time without having to provide reasons. The lawfulness of processing based on an effectively given consent remains unaffected until the time the consent has been withdrawn.
When you participate in a webinar that is either hosted or co-hosted by the Company, you may
be asked to provide your personal information, which will allow you to sign into, or otherwise participate in, the webinar. Webinars may be hosted and recorded by the Company, its co-hosting partner and/or a sponsor of the webinar (each a "Host" and together the "Hosts", whereby all Hosts will be disclosed as part of the webinar offering). Please refer to all other Hosts' privacy policies for further information on how they use your personal information, as Hosts may collectively use and transfer amongst one-another your personal information, including, for example, your webinar sign-in information and any audio and/or video recordings of the webinar (if applicable) so long as the transfer is consistent with the uses contained in this paragraph and the relevant Host's privacy policy. Accordingly, you will be asked to provide your consent to our and our Hosts' use
of your personal information for such purposes. Subject to any other terms and conditions of your consent, in addition to using your personal information for providing you with webinar access, information collected during a webinar may also
be used by the Company or a Host to understand industry wide pain points, to enhance the Company's or a Host's products and/or service offerings,
or for the Company's or any Host's general
marketing purposes.
The processing of your personal data can also take place if this is necessary to realise the legitimate interests of the Company (Article 6 (1) sentence 1 lit. f of the GDPR). Legitimate interests exist for example, if we assert a legal claim against you or we need to defend ourselves in a legal dispute. The processing of personal data on the basis of a legitimate interest shall not take place if there is an indication that the interest in the processing is overridden by your legitimate interest in that particular case. The existence of legitimate interests shall be assessed in each case of processing.
With Affiliates
We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
With business partners
We may share Your information with Our business partners to offer You certain products, services or promotions.

Particularly, We may share your data that are received under you contest with our partners Arina AG (if you are in the DACH region) or to ASIC Technologies, JSC (if you are in Vietnam). Anyway, we remain responsible under this DPA and applicable personal Data Protection Laws to fulfill our obligations regardless the fact of data transfer and your data remains available for deletion or revocation by your request as part of the normal procedure set out in this DPA.
With Your consent
We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with Our contractual obligations, resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes, such as number of queries daily. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

We do not retain any personal data that relates to third parties and that You may input or access when using our Service.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.
Within Social Links your data may only be accessed by those who need this data to fulfil our contractual and legal obligations. Service Providers can also receive data for this purpose. We only pass on your personal data to third parties, if:
you have explicitly given your consent to this in accordance with Article 6 (1) sentence 1 lit. a of the GDPR,
this is permitted by law and - in accordance with Article 6 (1) sentence 1 lit. b of the GDPR - necessary to process contracts we concluded with you,
in case there is a legal obligation to transfer personal data according to Article 6 (1) sentence 1 lit. c of the GDPR, and
the transfer pursuant to Article 6 (1) sentence 1 lit. f of the GDPR is necessary for the establishment, exercise or defence of legal claims and there is no reason to believe that you have an overriding legitimate interest in not passing on your data.

Detailed Information on the Processing
of Your Personal Data

Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.

We may use Email Marketing Service Providers to manage and send emails to You.
We partially use external service providers to process your data. These have been carefully selected and commissioned by us.
They are bound by our instructions and controlled regularly.
ActiveCampaign is an email marketing sending service provided by ActiveCampaign LLC.Name and address of the service provider: ActiveCampaign, LLC, 1 N Dearborn St Fl 5, Chicago, Illinois, 60602, United StatesLegal basis: Performance of contract, Article 6 (1) sentence 1 lit. b of the GDPRCategories of personal data: Customer dataPurpose of the processing: Sending order confirmationsFor more information on the privacy practices of ActiveCampaign, please visit their Privacy policy:


We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g. payment processors).

We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
PayPro Global
Name and address of the service provider: PayPro Global, Inc., 225 The East Mall, Suite 1117, Toronto, ON, M9B 0A9

Legal basis: Performance of contract, Article 6 (1) sentence 1 lit. b of the GDPR

Categories of personal data: Credit card information, customer data, contract data

Purpose of the processing: Payment processing

Their Privacy Policy can be viewed at

CRM system

We may use third-party Service Providers to manage the customer relationships.
Name and address of the service provider: Pipedrive Inc., 490 1st Ave South, Suite 800, St. Petersburg, Florida, 33701, USA

Legal basis: Performance of contract, Article 6 (1) sentence 1 lit. b of the GDPR

Categories of personal data: Customer data

Purpose of the processing: Management of customer relationships

Their Privacy Policy can be viewed at

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:
You have given Your consent for processing Personal Data for one or more specific purposes.
Performance of a contract:
Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
Legal obligations:
Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
Vital interests:
Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
Public interests:
Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
Legitimate interests:
Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.
In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether
the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:
Request access
to Your Personal Data
The right to access, update or delete the information We have on You. Whenever made possible, you can access, update
or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
Request correction
of the Personal Data that We hold about You
You have the right to have any incomplete or inaccurate information We hold about You corrected.
Object to processing
of Your Personal Data
This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want
to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.Processing Personal Data is related to a task that
is carried out in the public interest or in the exercise of official authority vested in the Company.
Request erasure
of Your Personal Data
You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
Request the transfer
of Your Personal Data
We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies
to automated information which You initially provided consent for Us to use or where We used the information to perform
a contract with You.
Withdraw Your consent
You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make
a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information,
if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy
of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy,
You can contact us:
By email
By phone number
+31 85 208 4014