This Policy relates to the Apps named Link-ages Go and Link-ages Hub, separately and collectively, both being referred to as “Link-ages” where the context so requires. This policy is applicable to Link-ages Apps downloaded from the 1st June 2020 onwards.
Link-ages is a private communication system for closed groups of people such as family members, friends and carers which includes an App, Link-ages Hub, specifically designed for use by older or less experienced users (“Hub User”).
The main purpose of Link-ages is to provide a secure and private way for family members and friends to communicate with each other using text messaging, voice messaging and video messaging, and to share photographs and other information with each other and with a Hub User. In a care setting, this extends to authorised and approved care staff and managers.
Ensuring the privacy and security of the users’ data is the essence of the Link-ages concept. Many people are justifiably concerned by the thought of their messages and data being publicly available on the internet, or having their online activity analysed by organisations unknown to them and being bombarded with unwelcome targeted adverts, as is the case with many forms of social media. The result is that many people are, with good reason, reluctant to use such forms of electronic communication.
This issue is particularly valid when trying to ensure the protection of the young, the elderly and other vulnerable people from the potential risks of online communication.
Link-ages addresses this issue of maintaining the privacy of users’ communications and data by only permitting communication between people within a closed, private group, which we call a Bubble.
A user can only join a Bubble if they are specifically invited to do so. A Bubble cannot be accessed from outside or through an internet search.
Typically, a Bubble might be composed of members of a single family, or of a group of family members and friends that can include Hub users. A user can belong to several different Bubbles.
All content shared between Link-ages users remains entirely private and can only be seen by those intended.
Unlike many other communication apps Link-ages does not access or request access to contacts or other personal data on a user’s device. Link-ages Tech Ltd. does not sell users’ personal data to third parties for the purposes of marketing.
Link-ages is made up of two complementary apps, “Link-ages” and “Link-ages Hub”. These are designed to work together to the benefit of a wide range of user types.
Link-ages is designed to be used on Smartphones (Android and Apple). Link-ages Hub is for use on tablets and iPads, generally by older people who have little or no computer skills.
In order to make things easier for new users, the initial set-up of Link-ages Hub on a tablet can be done by someone else on behalf of the Hub user such as a family member, a friend or a carer. This is more fully explained on our website (www.link-ages.com).
This person can then continue to support the Hub user remotely, e.g. setting alarms, adding and editing contacts etc.
Link-ages Tech Ltd. is a UK Registered Company and under the terms of GDPR is the ‘data controller’. (‘Controllers can determine the purposes and means of processing alone, or jointly with others – as a joint controller. Article 26(1) of the GDPR states that: “Where two or more controllers jointly determine the purposes and means of processing, they shall be joint controllers” Joint controllers decide the purposes and means of processing together – they have the same or shared purposes.)
Users must confirm that they have read and agreed to terms of this Privacy Policy in order to use these apps. By agreeing, you consent to Link-ages Tech Ltd. and its partners and subcontractors processing your data for the purposes of delivering and improving Link-ages. This will be done in a way that will not contravene your individual rights, freedoms, or legitimate interests. Link-ages Tech Ltd. will require that any third-parties that have access to your data are fully GDPR compliant.
Link-ages users’ data is stored partly on the users’ own devices and partly on remote servers or in the Cloud using Google Firebase. Google has a worldwide network of Data Centres (see compliance information below), however Link-ages data is stored in the United States (which can include any or all of the following locations: Berkeley County, South Carolina, Council Bluffs, Iowa, The Dalles, Oregon, Douglas County, Georgia, Henderson, Nevada, Jackson County, Alabama, Lenoir, North Carolina, Loudoun County, Virginia, Mayes County, Oklahoma, Midlothian, Texas, Montgomery County, Tennessee, New Albany, Ohio, Papillion, Nebraska.) Link-ages is available through the App Store and Google Play in all countries in which these stores are allowed to provide apps.
• Google Firebase:
Firebase is fully GDPR and CCPA (California Consumer Privacy Act, January 2020) compliant. Firebase operates as our ‘data processor’ (Under GDPR ‘processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller. Processors act on behalf of the relevant controller and under their authority. In doing so, they serve the controller’s interests rather than their own. Although a processor may make its own day-to-day operational decisions, Article 29 says it should only process personal data in line with a controller’s instructions, unless it is required to do otherwise by law.)
• Privacy Shield:
In July 2016, the European Commission concluded that the EU-U.S. Privacy Shield Framework provides an adequate mechanism to allow EU companies to comply with requirements under GDPR in connection with transfer of personal data from the European Union to the United States. Google LLC is certified under both the EU-U.S. and Swiss-U.S. Privacy Shield frameworks.
• Data Encryption and Security:
Firebase services encrypt data in transit using HTTPS and customer data is logically isolated. Stored data is also encrypted. To keep data safe, Firebase also employs extensive security measures to restrict access and logs details of any such access.
• Data Processing:
Firebase Authentication: For passwords and email addresses the data is used to enable end-to-end authentication and facilitate end-user account management. Data is retained for the customers use until a deletion request is received. Data will then be removed from live and backup systems within 180 days.
The collection of Link-ages users’ personal information is kept to the minimum required to enable Link-ages to function and will be used for that purpose only. To enable user-to-user communication we process the information that you enter into the app that facilitates direct communication with other users within your Bubbles. This will include text and audio information if you chose to use these offerings. Unlike most other Apps the privacy of users’ data is fundamental to the Link-ages concept. Users’ personal data will not be divulged other than following a lawful request from the Police or similar government agency. In the event of such a request be received Link-ages Tech Ltd. will take all reasonable steps to ensure that the request is justified and is in compliance with local and/or international law.
Unlike many other Apps, the absence of any advertising is fundamental to the Link-ages concept. Link-ages users will not be subjected to any advertising in any Link-ages product. Similarly, Link-ages users will not be offered any in-App purchases other than the monthly subscription cost associated with a Plus Bubble. This cost is shown when Users sign up. The first subscription payment is taken by the App Store or Google Play when a Plus Bubble is set-up and then monthly thereafter.
No security system can guarantee to prevent all potential security breaches but Link-ages Tech Ltd. will use physical, electronic and procedural processes to protect the confidentiality of the information and content that Link-ages users provide (e.g. passwords, data, etc.). Access to this information and content will be limited only to employees, contractors and associated entities who need the information in order to run, maintain and develop the Apps.
To set up and use Link-ages you will need to choose some information that will identify your family group including a username and a password. Each individual is also identified by a randomly generated pin. Please take care to keep this information confidential and do not disclose or share this information with anyone other than individuals whom you wish to invite to join your private group. If you do disclose this information you will be solely responsible for any breaches of your account. Link-ages Tech Ltd. do not knowingly solicit data from or market to children under the age of 13.
Whenever you interact with Link-ages Apps or with the website Link-ages.com, Link-ages Tech Ltd automatically receives and records information on server logs from your browser or device including, but not limited to, your IP address, device identification and “cookie” information. You can remove or block cookies in your browser settings. Link-ages Tech Ltd does not collect precise real time information about the location of your device. You can stop the collection of all information by uninstalling Link-ages but information previously gathered may persist in back-up copies for a period of time. Link-ages Tech Ltd. uses analytics software (including, but not limited to, Google Analytics and Facebook Ad Manager) to analyse patterns of usage of our software in order to ensure that we can respond effectively to the needs of our users and for the continuing development of the Link-ages suite of Apps.
Link-ages has been designed to be suitable for private use and for use within care facilities by staff, residents and family members. Link-ages Tech Ltd. is cognisant of the particular challenges the care sector poses with regard to the potential vulnerability of users, and this privacy policy applies equally to this sector. Care providers must make all necessary changes to their own internal policies and procedures to enable staff to assist residents with the use of Link-ages without compromising residents’ personal data.
It is a condition of use of Link-ages that users will not use the service for any inappropriate or illegal purpose or in a manner which breaches copyright or intellectual property rights or which utilises storage and bandwidth resources significantly more heavily than would be the case for the average user. We reserve the right to suspend accounts for breach of copyright or intellectual property rights and for excessive consumption of resources.
Link-ages and Link-ages Hub and all logos, designs, software and code are covered by Copyright.
Link-ages and the information and materials that it contains are the property of Link-ages Tech Ltd. and are protected from unauthorized copying and dissemination by copyright law, trademark law, and other intellectual property laws.
Subject to these terms, when you sign up to Link-ages you are granted a non-exclusive license to download, install and use the respective App on a smartphone or tablet computer, as the case may be, that you own or control.
Link-ages Apps are provided “as is.” We disclaim all representations, warranties and conditions, either express, implied or statutory, including any implied warranties of merchantability, non-infringement, title, satisfactory quality or fitness for a particular purpose. We will not be liable for the loss of any type of data or content loaded onto or exchanged by means of Link-ages.
Link-ages Tech Ltd. accept no liability for any loss or damage, of whatever nature and howsoever caused exceeding £20 in aggregate.
Link-ages Tech Ltd. may alter, suspend, or discontinue Link-ages, or any part thereof, at any time and for any reason, but we will endeavour to provide advance notice of any such occurrence on our website.
Link-ages may be unavailable from time to time due to maintenance or malfunction of computer or network equipment or for other reasons.
Link-ages Tech Ltd. may revise this policy from time to time. The most current version will be available on our website.
This policy is to be read in conjunction with the latest or appropriate version of the Apple Privacy Policy (www.apple.com/uk/privacy/privacy-policy) or Google Privacy Policy (policies.google.com/privacy). In the event of contradiction or conflict the Apple Policy or Google Policy whichever is appropriate shall take precedence.