Privacy Policy

1. Introduction
   1. We are committed to safeguarding the privacy of our website visitors.
   2. This policy applies where are acting as a data controller with respect to the personal data of our website visitors; in other words, where we determine the purposes and means of the processing of that personal data.
   3. We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website, we will ask you to consent to our use of cookies when you first visit our website.
   4. Our website incorporates privacy controls, which affect how we will process your personal data. By usinf the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls via linkonair.com/wp-admin.
   5. In this policy, “we”, “us” and “our” refer to Link S.r.l. For more information about us, see section 12.
2. How we use your personal data
   1. In this section we have set out:
      (a) the general categories of personal data that we may process;
      (b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
      (c) the purposes for which we may process personal data;
      (d) the legal bases of the processing.
   2. We may process data about your use of our website and services (“usage data”). The usage data may be include you IP address, geographical location, browser type and versiom, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usafe data is our analytics tracking system, Google Analytics. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is consent OR our legitimate interests, namely monitoring and improving our website and services.
   3. We may process your account data (“account data”). The account data may include your name and email address. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent OR our legitimate interestsm namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
   4. We may process your information included in your personal profile on our website )”profile data”). The profile data may include your name, address, telephone number, email, address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business.
   5. We may process your personal data that are provided in the course of the use of our services (“service data”). The service data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The source of the service data is you or your employer. The service data may be processed for the purposes of operating our websitee, providing our services, ensuring the security of our website and services, maintaining back-ups of our databeses and communicating with you. The legal basis for this processing is consent OR our legitimate interestsm namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
   6. We may process information that you post for publication on our website or through our service (“publication data”). The publication data may be processed for the pruposes of enabling such publication and administering our website and services. The legal basis for this processing is consent OR our legitimate interestsm namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
   7. We may process information contained in any enquiry you submit to us regarding good and/or services (“enquiry data”). The enquiry data may be pocessed for the purpose of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.
   8. We may process information relating to our customer relationships, including customer contact information (“customer relationship data”). I dati sulla relazione con il cliente possono includere il tuo nome, il tuo datore di lavoro, il tuo titolo professionale o ruolo, i tuoi dati di contatto e le informazioni contenute nelle comunicazioni tra noi e te o il tuo datore di lavoro. The source of customer relationship data is you or your employer. The costumer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is consent OR our legitimate interests, namely the proper management of our costomer relationships.
   9. We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data”). The transaction data may include your contact details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests namely the proper administration of our website and business.
   10. We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletter (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
   11. We may process information contained in or relating to any communication that you send us (“correspondence data”). The correspondence data may incude the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
   12. We may process any of your personal data identified in this policy where necessary for establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
   13. We may process any of your personal data identified in this policy where necessary for the purpose of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely to proper protection of our business against risks.
   14. In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where suck processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
   15. Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3. Providing your personal data to others
   1. We may disclose your personal data to anu member of the group companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out this policy. Information about our group of comoanies can be found at www.linkonair.com/about-us.
   2. Financial transactions relating to our website and services may be handled by our payment services providers, BNL or Paypal. We will shake transaction data with our payment services providers only to the extent necessary for the purposes of processing your paymentsm refunding such payments and dealing with complaints and queries relating to such payments and refunds.
   3. In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosures is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interest of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise of defence of a legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. International transfers of your personal data
   1. In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
   2. We and our group companies have offices and facilities in USA. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to USA will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, OR the use of binding corporate rules.
   3. You acknowledge that personal data taht you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misure) of such personal data by others.
5. Retaining and delating personal data
   1. This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we complu with our legal obligations in relation to the retention and deletion of personal data.
   2. Personal data that we process for any purpose shall not be kept for longer than is necessary.
   3. We will retain your personal data as follows:
      All will be retained for a minimum period of 12 months following May 28th 2019, and for a maximum period of 10 years following May 28th 2019.
   4. Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order toprotect your vital interests of another natural person.
6. Amendments
   1. We may update this policy from time to time by publishing a new version on our website.
   2. You should check this page occasionally to ensure you are happy with any changes to this policy.
   3. We may notify you of a significant changes to this policy by email or through the private messagging system on our website.
7. Your rights
   1. In this Section 7, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
   2. Your principal rights under data protection law are:(the toght to access; (b) the right to rectification; (c) the right to erasure;

      (d) the right to restrict processing;

      (e) the right to object to processing;

      (f) the right to data portability;

      (g) the right to complain to a supervisory authority;

      (h) the right to withdraw consent.

   3. You have the right to confirmations as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recupients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data The first copy will be provided free of charge, but additional copies may be subbject to a reasonable fee. You can access your personal data by visitin www.linkonair.com/wp-admin when logged into our website if you have created an account. Otherwise only generic cookie data is stored.
   4. You have the right to have any inaccurate personal data about you rectidied and, taking into account the purposes of the processing, to have any incomplete personal data about tou completed.
   5. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for excercising the right of freedom of expression and information; for compliance with a legal obligation; or fot the establishment, exccercise or defence of legal claims.
   6. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processinf is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for establishment, execrise or defence of legal claims; and you have objected toprocessing, pending the verification of that objection, Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, the exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
   7. You have the right to object to our processing od your personal data on g rounds relating toyour particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the excercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interestsm rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
   8. You have the right to object to our processing of your personal data for direct marketinf purposes (includin profiling for direct marketing purposes). If you make such an objection, we will cease toprocess your personal data for this purpose.
   9. You have the right to onject to our processing of your personal data for scientific or historical research or statistical purposes on grounds relating to your particular situazione, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
   10. To the extent that legal basis for our processing of your personal data is:
       (a) consent; or
       (b) that the processing is necessaey for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
       and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
   11. If you consider that our porcessing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
   12. To the extent that the legal basis for our processing of your personal information is consentm you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
   13. You may excercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 7.
8. About cookies
   1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web to server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
   2. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored bu a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookies, on the other hand, will expure at the end of the user session, when the web browser is closed.
   3. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
9. Cookies that we use
   1. We use cookies for the following purposes:
      (a) authentication – we use cookies to identify you when you visit our website and as you navigate our website (cookies used for this purpose are: wordpress cookies);
      (b) status – we use cookies to help us to determine if you are logged iinto our website (cookies used for this purpose are: wordpress cookies);
      (c) personalisation – we use cookies to store information about your preferences and to personalise the website for you (cookies used for this purpose are: wordpress cookies);
      (d) security: we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally (cookies used for this purpose are: wordpress cookies);
      (e) analysis: we use cookies to help us to analyse the use and performance of our website and services (cookier used for this purpose are: Google Analytics cookies); and
      (f) cookies consent: we use cookies to store your preferences in relation to the use of cookies more generally (cookies used for this purpose are: wordpress cookies).
10. Cookies used by our service providers
    1. Our service providers use cookies and yhos cookies may be stores on your computer when you visit our website.
    2. We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The informatio gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://support.google.com/chrome/answer/95647?hl=it (Chrome);
11. Managing cookies
    1. Most browser allow you to refuse to accept cookies and to delate cookies. The methods for doing so vary from browser, and from version to version. You can however obtain up-to-date information about blocking and delating cookies via these links:
       (a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
       (b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
       (c) https://www.opera.com/help/tutorials/security/cookies/ (Opera);
       (d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
       (e) https://support.apple.com/kb/PH21411 (Safari);
       (f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
    2. Blocking all cookies will have a negative impact upon the usability of many websites.
    3. If you block cookies, you will not be able to use all the features on our website.
12. Our details
    1. This website is owned and operated by Link S.r.l.
    2. We are registered in Italy under number 01883121004 , and our registered office is at Via Bruno Pontecorvo 10, 00012 Guidonia RM – Italy.
    3. Our principal place of business is at Via Bruno Pontecorvo 10, 00012 Guidonia RM – Italy.
    4. You can contact us:
       (a) by post, to the postal address given above;
       (b) using our website contact from;
       (c) by telephone, on the contact number published on our website;
       (d) by email, using the email address published on our website