LYNQLY PRIVACY POLICY

Effective Date: February 10, 2026

Last Updated: February 10, 2026

01WHO WE ARE

Lynqly LLC, and its parents, subsidiaries, affiliates, agents, representatives, consultants, employees, officers, and directors — collectively, "Lynqly," "we," "us," or "our"). Lynqly is a Wyoming limited liability company providing AI-powered domain intelligence services.

02CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. If we do, we'll let you know about any material changes, either by notifying you on the Site or by sending you an email. New versions of this Policy will never apply retroactively — we'll tell you the exact date they go into effect. If you keep using Lynqly after a change, that means you accept this updated Privacy Policy.

03HOW THIS POLICY APPLIES

This Privacy Policy describes the information we collect from you, how we use that information, and our legal basis for doing so. It also covers whether and how that information may be shared and your rights and choices regarding the information you provide to us.

If you see a capitalized word, it's defined in our Terms of Service.

By using the Services offered by Lynqly, you're acknowledging you have agreed to our Terms of Service and that you have read and understood this Privacy Policy.

04DATA YOU PROVIDE TO US

We collect information you provide directly to us, information from third parties, and information that we collect through automated means. For example, we collect:

Account and Registration Information

• Account Creation: When you create an account, we collect your name, email address, username, password, and any other information you choose to provide.
• Profile Information: Any optional information you add to your profile, such as profile pictures, bio, location, website, or social media links.
• Identity Verification: For certain features or purchases, we may collect identity verification information including date of birth, address, or payment verification details.

Project and Service Usage Information

• Project Briefs: The project descriptions, business information, target market details, and other content you provide when using our domain intelligence Services.
• Domain Preferences: TLD preferences, industry focus, budget constraints, and other parameters you specify.
• Decision Activity: Your interactions with domain suggestions, including domains you track, lock, pass, or analyze.
• Search and Query Data: Search terms, filters, refinements, and other query information.
• Feedback and Communications: Information in customer support requests, survey responses, feedback forms, or other communications with us.

Transaction Information

• Purchase Information: When you purchase a Project Pass or other Services, we collect transaction details including purchase type, date, amount, and payment method information (processed through third-party payment processors).
• Billing Information: Billing name, address, and payment method details necessary to process your purchase.
• Refund Requests: Information provided in connection with refund requests under our money-back guarantee.

Technical and Usage Information

We automatically collect certain information when you use our Services:

• Usage Data: Pages viewed, features used, time spent on pages, navigation paths, clickstream data, and interaction with specific features.
• Device Information: Device type, operating system, browser type and version, screen resolution, device identifiers, and hardware model.
• Location Information: IP address, which may be used to infer general geographic location (city/region level) and timezone.
• Log Data: Server logs recording access times, pages requested, errors encountered, referring URLs, and other standard log information.
• Cookie and Tracking Data: Information collected through cookies, web beacons, pixels, and similar tracking technologies. Please see our Cookie Policy section below for details.

Third-Party and Social Login Information

• Social Network Data: If you access the Services through a third-party connection or log-in (such as Google, Facebook, or other authentication providers), we may collect certain information from your social network profile, including name, email address, profile picture, and any other information you authorize the third-party service to share with us.
• Third-Party Integration Data: Information from third-party services you integrate with Lynqly, subject to your authorization.

Information From Other Users

• Referral Information: If another user refers you to Lynqly, we may receive your name and email address.
• Collaborative Projects: If you collaborate with other users on projects, we may collect information shared in that collaborative context.

Optional Information

You may decline to provide us with certain information. However, this may limit your ability to register for an account, use specific features, or access certain Services. You may review, change, or remove your information through your account settings.

05HOW WE COLLECT INFORMATION

Information You Provide

We collect information you provide when you:

• Create an account or update your profile
• Purchase Services or make payments
• Submit project briefs or use domain intelligence features
• Contact customer support or communicate with us
• Respond to surveys or provide feedback
• Participate in promotions, contests, or research studies
• Otherwise interact with us online or offline

Automatic Collection

We collect information through a variety of technologies, including:

• Cookies: Small text files stored on your device that help us recognize you, remember your preferences, and improve our Services.
• Web Beacons and Pixels: Small graphic images embedded in web pages or emails that track page views, email opens, and user activity.
• Analytics Tools: We use analytics services including Google Analytics, Mixpanel, and similar tools to understand how users interact with our Services.
• Log Files: Our servers automatically record information about your use of the Services.
• Device Identifiers: Unique identifiers associated with your device.

Please see our Cookie Policy section below for more information, including how to manage your cookie preferences.

Third-Party Sources

We may acquire information from trusted third-party sources to update or supplement the information you provided, such as:

• Data Enrichment Services: To validate addresses, enhance contact information, or append demographic data
• Payment Processors: Transaction confirmation and fraud prevention information
• Marketing Partners: Information about your interests and preferences for marketing purposes (with your consent where required)
• Public Sources: Publicly available information that may be relevant to providing Services

Applicable law may require that you authorize the third party to share your information with us before we can acquire it.

06HOW WE USE YOUR INFORMATION

Per applicable law and controls that may be available to you, we may use information collected from you, or from devices associated with you, to:

Provide and Improve Our Services

• Service Delivery: Enable you to access and use our Services, process project briefs, generate domain suggestions, perform availability scans, conduct AI-powered analysis, and deliver intelligence reports
• Account Management: Create and maintain your account, authenticate your identity, and manage your access to features
• Personalization: Personalize your experience, tailor content and recommendations based on your projects, preferences, and usage patterns
• Service Improvement: Analyze usage patterns, conduct research, test features, troubleshoot problems, and improve the functionality, quality, and performance of our Services
• AI Model Training: Train, test, and improve our artificial intelligence models, algorithms, and domain intelligence systems using aggregated, anonymized, or de-identified data

Communications

• Transactional Communications: Send you service-related emails including account confirmations, project status updates, payment receipts, refund notifications, and security alerts
• Customer Support: Respond to your inquiries, provide customer support, and resolve technical or account issues
• Service Announcements: Notify you of important changes to our Services, Terms, Privacy Policy, or other important information
• Feedback Requests: Request feedback about your experience with our Services through surveys or other research methods

Marketing and Promotional Activities

• Marketing Communications: With your consent where required, send you promotional emails, newsletters, feature announcements, and offers for our Services or partner services
• Personalized Marketing: Tailor marketing messages based on your activity, preferences, and interests
• Advertising: Display targeted advertising on our Sites and Services or through third-party platforms based on your activity

You can opt out of marketing communications at any time through unsubscribe links or account settings.

Analytics and Research

• Usage Analytics: Analyze how users interact with our Services to understand usage patterns, popular features, and user journeys
• Market Research: Conduct user research, surveys, and market analysis to inform product development and business strategy
• Performance Metrics: Monitor and analyze Service performance, conversion rates, feature adoption, and business metrics
• A/B Testing: Test different versions of features, interfaces, or algorithms to optimize user experience

Security and Legal Compliance

• Security: Detect, investigate, and prevent fraudulent activities, abuse, security incidents, and activities that violate our policies or are illegal
• Legal Compliance: Comply with legal obligations, respond to legal requests, enforce our Terms, protect our rights and property, and ensure the safety of our users and others
• Dispute Resolution: Investigate and resolve disputes, claims, or complaints
• Risk Management: Assess risk, prevent fraud, and protect against liability

AI and Machine Learning Development

• Model Training: Use aggregated, anonymized, or de-identified data to train, validate, and improve our AI models, including domain generation models, ranking algorithms, and brand analysis systems
• Algorithm Optimization: Develop and refine algorithms for domain scoring, market intelligence, availability prediction, and other intelligence features
• Quality Assurance: Evaluate the accuracy, relevance, and quality of AI-generated suggestions and analysis
• Research and Development: Conduct research to advance our AI capabilities and domain intelligence technology

Important Note on AI Training: While we use aggregated and anonymized data for AI model training, your specific project briefs and domain selections remain private and are not used to train models in a way that could expose your specific data to other users.

Aggregated and De-Identified Data

We may aggregate and/or anonymize any information collected through the Services so that such information can no longer be linked to you or your device ("Aggregated Data"). We may use Aggregated Data for any purpose, including:

• Market research and trend analysis
• Benchmarking and industry reports
• Service improvement and development
• Sharing with third parties, including advertisers, partners, and researchers

07HOW THIS INFORMATION IS SHARED

Information That Is Shared Publicly

By default, your Lynqly account and project information are private. You can control what information, if any, is made public through your privacy settings.

If you choose to make your profile public or share specific information, others may be able to see:

• Your username and the date your account was created
• Any profile information you choose to make public (profile picture, bio, location)
• Public portfolio items or projects you designate as shareable
• Any activity you designate as public in your settings

Your domain selections, project briefs, search history, and AI-generated analysis are always kept private unless you explicitly choose to share them.

Information That Is NOT Shared Publicly

The following data will not be publicly displayed or revealed to other users without your explicit consent:

• Payment information and billing details
• Password and authentication credentials
• IP addresses and device identifiers
• Email address and phone number
• Private project briefs and domain selections
• AI-generated analysis and domain intelligence reports
• Domain tracking, locking, or passing decisions
• Personal preferences and account settings
• Communications with customer support
• Usage analytics and behavior data

Information You Choose to Share With Others (User-Initiated Sharing)

Project Sharing Features:

Lynqly provides features that allow you to voluntarily share your project results, domain intelligence, and analysis with specific individuals you choose. This sharing is entirely optional and controlled by you.

What You Can Share:

Through our sharing features, you can grant others access to:

• Your project briefs and business descriptions
• Domain name suggestions generated for your project
• AI analysis, rankings, and scores -Brand analysis dossiers
• Decision tracking (domains you've tracked, locked, or passed)
• Any other project-related content you created

How Sharing Works:

1. Invite by Email: You enter email addresses of people you want to invite; we send them an invitation link
2. Shareable Links: You generate a shareable link with access permissions you configure
3. Access Management: You control who has access and can revoke access through your account settings

Who Can See Your Shared Information:

• Only people you explicitly invite or share links with can access your shared projects
• We do not make your projects public - they are only accessible to recipients you authorize
• Recipients can view, copy, screenshot, or download information from shared projects during the period they have access
• Revoking access prevents future access but does not erase information already viewed or copied

Your Responsibility:

When you use sharing features, you are responsible for:

1. Vetting Recipients: Ensuring you trust the people you invite and that sharing with them is appropriate
2. Confidentiality Risks: Understanding that sharing reduces confidentiality and creates risks of information misuse
3. Data Privacy Compliance: If you share projects containing personal information of others (team members, collaborators), you must comply with applicable privacy laws and obtain necessary consents
4. Consequences of Sharing: Any consequences of your sharing decisions, including theft of ideas, competitive disadvantage, or confidentiality loss

What We Do NOT Do:

• We do NOT review, approve, or monitor who you share with
• We do NOT impose confidentiality obligations on recipients
• We do NOT control how recipients use or further share information you give them access to
• We do NOT mediate disputes between you and recipients

Recipients' Data:

When you invite someone via email:

• We collect their email address to send the invitation
• We create a temporary access token for their access
• We do not create accounts for them unless they separately register
• Their viewing activity may be logged for security purposes
• We do not share information about your recipients with third parties except as required by law

Shared Project Access Logs:

We maintain logs of who accessed shared projects for security and account management purposes. Access logs may include:

• Email addresses of invited recipients
• Access timestamps
• IP addresses of access (for security)
• Actions taken (viewed, copied link, etc.)

Privacy Recommendation:

🔴 IMPORTANT: Sharing exposes your information to others. Consider privacy implications before sharing projects containing:

• Sensitive business strategies
• Confidential domain ideas that could be registered by recipients
• Personal information of team members or collaborators
• Trade secrets or proprietary information

Your sharing decisions are irreversible in practice - once information is viewed, it cannot be "unshared."

Information Shared With Third-Party Service Providers

We may share your information with trusted third-party service providers who help us operate our business and provide Services to you, including:

Essential Service Providers

• Cloud Infrastructure: Hosting providers (Cloudflare, AWS, etc.) that store and process data
• Payment Processors: Stripe, PayPal, or other payment processors to handle transactions (they receive only information necessary for payment processing)
• Email Services: Email delivery services for account notifications and communications
• Authentication Services: Third-party authentication providers (Google, etc.) if you use social login

Analytics and Optimization

• Analytics Providers: Google Analytics, Mixpanel, and similar services to analyze usage and improve Services
• Performance Monitoring: Services that monitor application performance and errors
• A/B Testing: Services that help optimize user experience through testing

Marketing and Communications

• Marketing Platforms: Email marketing services, CRM systems, and marketing automation tools (only with your consent for marketing communications)
• Advertising Networks: Ad networks and platforms for targeted advertising (subject to your privacy choices)
• Customer Support: Help desk and support ticketing systems

AI and Data Services

• AI Model Providers: Third-party AI services and APIs (OpenAI, Anthropic, etc.) that power our domain intelligence features
• Data Providers: Services that provide market data, domain availability information, or enrichment data
• Domain Services: Domain availability checking services and registrar APIs

Third-Party Service Provider Requirements:

When we share data with third-party service providers, we require that they:

• Use your information only for the purposes we've authorized
• Protect your personal information with security standards at least as stringent as ours
• Comply with applicable data protection laws
• Not sell your personal information to others

We may also share information that is aggregated and anonymized in a way that doesn't directly identify you.

Information Shared With Domain Registrar (NameSilo, LLC)

Domain Registration Through Authorized Reseller Partnership:

Lynqly facilitates domain name registration through our authorized reseller partnership with NameSilo, LLC (https://www.namesilo.com), an ICANN-accredited domain registrar. When you register a domain through Lynqly:

Registration Data We Collect and Transmit:

We collect and transmit the following domain registration information to NameSilo, LLC (the "Sponsoring Registrar"), applicable TLD registry operators, and other required parties:

• Registrant Contact Information: Full legal name (individual or organization), organization name (if applicable), complete mailing address (street, city, state/province, postal code, country), email address, phone number (with country code)
• Administrative Contact Information: Name, address, email, phone number (may be same as registrant contact)
• Technical Contact Information: Name, address, email, phone number (may be same as registrant contact)
• Billing Contact Information: Name, billing address for transaction records
• Domain Selection Data: The domain name(s) you wish to register, TLD selection, registration period
• Account Identifiers: Your Lynqly account ID correlated with your domain registrations
• Transaction Data: Registration date, expiration date, renewal status, auto-renewal preferences
• Authorization Data: Confirmation of your agreement to registrar terms and ICANN policies

Recipients of Your Domain Registration Data:

When you register a domain through our Services, your registration data is shared with:

1. NameSilo, LLC (Sponsoring Registrar)

   • Purpose: Process, maintain, and administer your domain registration
   • Data Received: Complete registration contact information, domain selection, transaction details
   • Privacy Policy: https://www.namesilo.com/support/privacy-policy
   • Legal Basis: Contractual necessity to provide domain registration services

2. TLD Registry Operators (e.g., Verisign for .com, Public Interest Registry for .org, etc.)

   • Purpose: Create and maintain domain registration in registry database
   • Data Received: Registrant and contact data as required by registry-registrar agreements
   • Legal Basis: Contractual necessity and regulatory compliance (ICANN requirements)

3. ICANN (Internet Corporation for Assigned Names and Numbers)

   • Purpose: Regulatory oversight, compliance monitoring, policy enforcement
   • Data Received: Registration data as required by ICANN accreditation agreements
   • Legal Basis: Regulatory compliance

4. ICANN-Designated Escrow Providers

   • Purpose: Data protection and continuity (registrar failure scenarios)
   • Data Received: Complete registration data for escrow/backup purposes
   • Legal Basis: Regulatory compliance (ICANN requirement)

5. WHOIS Privacy Service Provider (PrivacyGuardian.org or NameSilo-designated provider)

   • Purpose: Provide WHOIS privacy/proxy services where supported by TLD
   • Data Received: Your actual registration contact information (replaced in public WHOIS with privacy service contact information)
   • Legal Basis: Contractual necessity to provide requested privacy service
   • Note: Privacy service availability varies by TLD; some TLDs prohibit privacy services

6. Public WHOIS/RDDS Database

   • Purpose: Public directory service required by ICANN policy
   • Data Disclosed:
     • Without WHOIS Privacy: Your registrant name, organization (if applicable), mailing address, email,phone number, and domain registration/expiration dates are publicly accessible
     • With WHOIS Privacy: Privacy service contact information is displayed instead of your actual contact details (where supported by TLD)
   • Legal Basis: Regulatory compliance (ICANN WHOIS/RDDS requirements)
   • Access: Publicly accessible via WHOIS lookup services at https://www.internic.net/whois.html and other WHOIS providers

7. Third-Party Requesters (Under Specific Circumstances)

   • Purpose: Legal process, dispute resolution, law enforcement, abuse prevention
   • Data Disclosed: Registration data may be disclosed to:
     • Law enforcement agencies with valid legal process
     • Parties with court orders or subpoenas
     • UDRP complainants in domain dispute proceedings
     • Registry operators investigating abuse
     • ICANN compliance staff
   • Legal Basis: Legal obligation, contractual necessity (ICANN/registry policies)

WHOIS Privacy Service Details:

When WHOIS privacy is available for your TLD and enabled with your domain registration:

• How It Works: PrivacyGuardian.org (or designated privacy provider) replaces your public WHOIS contact information with privacy service contact details

• What's Protected: Your name, postal address, email address, and phone number are hidden from public WHOIS lookups

• What's NOT Protected:

  • Organization name may still be visible for some TLDs
  • Your actual registration data remains on file with NameSilo and the registry
  • Registry operators and ICANN can access your actual data
  • Your data may be disclosed under legal process or dispute resolution proceedings

• TLD Restrictions: WHOIS privacy is NOT available for domains registered in certain TLDs including but not limited to:

  • .us (requires U.S. presence; prohibits proxies for U.S. registrants)
  • .eu (requires European Economic Area presence verification)
  • .ca (prohibited for Canadian registrants under CIRA policy)
  • .in (prohibited by .IN registry)
  • .co.uk and other Nominet TLDs (limited privacy options)
  • .tickets, .healthcare, and other highly-regulated TLDs
  • Various country-code TLDs (ccTLDs) with local restrictions

• Privacy Service Limitations: WHOIS privacy may be suspended or disabled when:

  • Required by valid court order or legal process
  • Requested by ICANN for policy compliance investigation
  • Required by registry operator for abuse investigation
  • Needed to resolve a UDRP or other domain dispute
  • Your TLD registry changes privacy policies

ICANN Requirements and Your Consent:

By registering a domain through Lynqly, you acknowledge and consent to the following as required by ICANN policies:

1. Accurate Data Obligation: You must provide accurate, complete, and current contact information and update it within seven (7) days of any changes. Willfully providing false information may result in domain suspension or cancellation.

2. Data Processing Consent: You consent to the processing of your registration data by:

   • The Sponsoring Registrar (NameSilo, LLC)
   • The applicable TLD registry operator
   • ICANN and ICANN-designated parties
   • Escrow providers for data protection purposes
   • Privacy service providers (if privacy service is enabled)
   • WHOIS database administrators and public access

3. WHOIS Publication Consent: You consent to publication of your registration data in WHOIS/RDDS databases as required by ICANN policy, unless WHOIS privacy is available for your TLD and enabled.

4. Purpose of Data Processing: Your registration data is processed for purposes including:

   • Domain name registration and maintenance
   • Generating WHOIS/RDDS records for public access
   • Compliance with ICANN policies and registry requirements
   • Facilitating domain transfers between registrars
   • Resolving domain disputes (UDRP and similar proceedings)
   • Investigating and preventing abuse, fraud, and policy violations
   • Law enforcement and legal compliance
   • Communication regarding domain status, renewals, and policy matters

5. Recipients of Data: You acknowledge that your data will be accessible to the parties listed above and may be accessed by anyone who performs a WHOIS lookup (unless privacy service is enabled and supported).

6. International Data Transfers: You acknowledge that your registration data will be transferred internationally to:

   • NameSilo's servers in the United States
   • Registry operator servers (locations vary by TLD)
   • ICANN's systems and designated escrow providers
   • WHOIS database systems accessible globally

7. Data Retention: Your registration data will be retained:

   • By NameSilo for the duration of your domain registration plus retention periods required by ICANN (currently minimum 2 years after registration expiration or deletion)
   • By registry operators per their retention policies and ICANN requirements
   • By ICANN and escrow providers per regulatory requirements
   • In WHOIS history databases and archives potentially indefinitely

Your Rights Regarding Domain Registration Data:

• Access: You can access your registration data through your Lynqly account, WHOIS lookup, or by contacting NameSilo
• Correction: You must correct inaccurate registration data through your account or by contacting Lynqly or NameSilo
• Limited Deletion: Registration data generally cannot be deleted while domain is active (ICANN requirement); data is retained even after domain expiration per ICANN policies
• WHOIS Privacy: You can enable/disable WHOIS privacy where supported (included free with domain registrations through Lynqly)
• Complaints: You may file complaints regarding data processing with:
  • Names Il's privacy team: privacy@namesilo.com
  • ICANN: https://www.icann.org/resources/pages/complaints-2012-02-25-en
  • Your local data protection authority (for EU/EEA residents)

Data Processing Agreements:

By registering a domain through Lynqly, you acknowledge that:

1. Your registration data will be processed by NameSilo in accordance with their privacy policy: https://www.namesilo.com/support/privacy-policy

2. Registry operators will process your data according to their agreements with ICANN and registrars

3. ICANN policies govern registration data collection, use, and disclosure, including:

   • Registration Data Access Protocol (RDAP)
   • Temporary Specification for gTLD Registration Data (as applicable)
   • Consensus policies regarding WHOIS and data protection

4. You have reviewed, or had the opportunity to review, NameSilo's privacy policy and registration agreement before completing domain registration

5. You consent to this data processing and international transfer as necessary to provide domain registration services

Updates to Registration Data Practices:

ICANN policies regarding registration data handling are evolving. Notable recent developments:

• ICANN Registration Data Policy (effective August 21, 2025): Replaces previous WHOIS requirements with updated registration data processing framework
• RDAP (Registration Data Access Protocol): Replacing legacy WHOIS protocol for registration data access
• Evolving Privacy Frameworks: ICANN continues adapting policies to balance WHOIS transparency with data protection laws (GDPR, etc.)

We will update this Privacy Policy to reflect material changes to registration data handling requirements.

Questions About Domain Registration Data Processing:

• Lynqly Privacy Questions: privacy@lynqly.com
• NameSilo Privacy Questions: privacy@namesilo.com or https://www.namesilo.com/support
• ICANN Information: https://www.icann.org/privacy
• WHOIS Lookup: https://www.internic.net/whois.html

Information Shared to Protect Lynqly and Comply With Law

We reserve the right to access, preserve, and disclose your information when we believe, in good faith, that doing so is reasonably necessary to:

• Legal Compliance: Comply with applicable laws, regulations, legal processes, or governmental requests
• Law Enforcement: Respond to valid requests from law enforcement or government authorities
• Enforce Terms: Enforce our Terms of Service, investigate potential violations, or protect our rights and property
• Protect Safety: Protect the safety, security, rights, or property of Lynqly, our users, or the public
• Prevent Fraud: Detect, prevent, or address fraud, security, or technical issues
• Corporate Transactions: In connection with a merger, acquisition, bankruptcy, reorganization, or sale of assets (where we will require the recipient to honor this Privacy Policy)

We will use reasonable efforts to notify you of such disclosures unless prohibited by law or court order.

Links to Other Websites and Services

Our Site may include links to other websites or services whose privacy practices may differ from Lynqly's. When you use a link to an external site or service, the privacy policy and data processing disclosures for that site or service govern. We are not responsible for the privacy practices of third-party websites or services.

08DATA RETENTION

How Long We Keep Your Information

Active Accounts: We will retain your information as long as your account is active, as necessary to provide you with the Services, or as otherwise set forth in this Policy.

Deleted Accounts: When you delete your account, we will delete or anonymize your personal information within 90 days, except as described below.

Legal and Business Purposes: We will retain and use information as necessary to:

• Comply with our legal obligations (e.g., tax records, transaction records)
• Resolve disputes and enforce our agreements
• Protect Lynqly's legal rights and prevent fraud
• Maintain business records and audit trails
• Comply with record retention requirements

Aggregated and Anonymized Data: We may retain aggregated, anonymized, or pseudonymized information indefinitely to:

• Improve our Services and AI models
• Conduct research and analytics
• Protect the safety and security of our Services
• Generate industry insights and benchmarks

Backup Systems: Information may persist in backup systems for a limited period after deletion for disaster recovery purposes.

09DATA TRANSFERS

International Data Processing

Lynqly LLC is a Wyoming, United States company. Your information will be collected, processed, and stored in the United States.

United States Data Protection: The United States has its own laws governing data protection and government access to information. The rules that protect your personal information under United States law may be different than in your home country.

European Economic Area (EEA) and United Kingdom: If you are located in the EEA or UK, your personal data may be transferred to and processed in the United States, which may not provide the same level of data protection as your home jurisdiction. By using our Services, you consent to the transfer of your information to the United States.

Standard Contractual Clauses: Where required by law, we use Standard Contractual Clauses or other approved mechanisms to legitimize data transfers.

Your Acceptance: If you choose to use the Services, you acknowledge and agree to our data processing practices as set out in this Privacy Policy and our Terms of Service.

10YOUR RIGHTS

Rights for All Users

Regardless of location, all Lynqly users can:

• Access Your Data: View and download your personal data from your account settings
• Update Information: Modify or correct your personal information through account settings
• Delete Your Account: Request deletion of your account and associated data
• Opt Out of Marketing: Unsubscribe from marketing emails at any time
• Control Cookies: Manage cookie preferences through browser settings or our cookie banner
• Contact Us: Reach out with questions or concerns about your data

Additional Rights for EEA, UK, and Certain U.S. Residents

Users residing in certain jurisdictions, including the European Economic Area (EEA), United Kingdom (UK), California, Virginia, Colorado, and other U.S. states with comprehensive privacy laws, may have additional rights:

European Data Protection Rights (GDPR)

If you are in the EEA or UK, you have the right to:

• Access: Request a copy of your personal data we hold
• Rectification: Correct inaccurate or incomplete personal data
• Erasure: Request deletion of your personal data ("right to be forgotten")
• Restriction: Request restriction of processing of your personal data
• Portability: Receive your personal data in a structured, commonly used format and transmit it to another controller
• Object: Object to processing of your personal data based on legitimate interests
• Withdraw Consent: Withdraw consent for processing based on consent (without affecting the lawfulness of processing before withdrawal)
• Lodge a Complaint: File a complaint with your local data protection authority

California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have the right to:

• Know: Request information about the categories and specific pieces of personal information we collect, use, disclose, and sell
• Delete: Request deletion of your personal information (with certain exceptions)
• Opt-Out: Opt out of the "sale" or "sharing" of personal information (Lynqly does not sell personal information in the traditional sense, but targeted advertising may qualify under CCPA)
• Non-Discrimination: Not be discriminated against for exercising your privacy rights
• Correct: Request correction of inaccurate personal information
• Limit Use: Limit the use and disclosure of sensitive personal information (if applicable)

Other U.S. State Privacy Rights

Residents of Virginia, Colorado, Connecticut, Utah, and other states with comprehensive privacy laws may have similar rights to access, correct, delete, and opt out of certain data processing activities.

How to Exercise Your Rights

To exercise any of these rights, you can:

1. Account Settings: Use the privacy and data controls in your account settings
2. Email Request: Send a request to privacy@lynqly.com with the subject line "Privacy Rights Request"
3. Support Ticket: Submit a support request through our help center

Verification: To protect your privacy, we may need to verify your identity before fulfilling your request. We will respond to verified requests within the timeframes required by applicable law (typically 30-45 days).

No Fee: We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded.

11EMAIL AND MOBILE NOTIFICATIONS

Email Communications

Transactional Emails: We will send you emails relating to your account, transactions, and use of our Services. These are necessary for Service delivery and cannot be opted out of while you use our Services:

• Account confirmations and security alerts
• Project status updates and completion notifications
• Payment receipts and billing statements
• Refund confirmations
• Important service announcements
• Customer support responses

Marketing Emails: You may elect to receive marketing email communications, including:

• Product announcements and new features
• Tips for using Lynqly effectively
• Special offers and promotions
• Industry insights and domain trends
• Newsletters and content updates

Opt-Out: You can opt out of marketing emails at any time by:

• Clicking the "unsubscribe" link in any marketing email
• Adjusting your email preferences in account settings
• Emailing support@lynqly.com with "Unsubscribe" in the subject line

We try to keep emails to a minimum and give you the ability to control your marketing communications preferences.

Mobile and Push Notifications

If you download the Lynqly mobile app (if available), you can manage push notifications through:

• Your mobile device settings
• The app's notification preferences
• Your account settings on the Lynqly platform

12SECURITY

Our Security Practices

We take security seriously, and the security of your personal data is important to us. We implement industry-standard security measures including:

• Encryption: HTTPS/TLS encryption for data in transit and encryption for sensitive data at rest
• Access Controls: Strict access controls limiting employee and contractor access to personal data on a need-to-know basis
• Authentication: Strong password requirements and support for two-factor authentication (2FA)
• Security Monitoring: Continuous monitoring for security threats and vulnerabilities
• Regular Audits: Periodic security audits and assessments
• Vendor Security: Vetting of third-party service providers' security practices
• Incident Response: Established procedures for detecting, responding to, and reporting security incidents

Security Limitations

However, no method of transmission over the internet or electronic storage is completely secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

Your Responsibility

You are responsible for:

• Choosing a strong, unique password and keeping it confidential
• Not sharing your account credentials with others
• Enabling two-factor authentication (we strongly encourage this)
• Promptly notifying us of any unauthorized access or security breach
• Keeping your device and software secure

Security Vulnerability Reporting

We encourage the responsible disclosure of security vulnerabilities. If you discover a security issue, please email security@lynqly.com with details. We are committed to working with security researchers to resolve vulnerabilities promptly.

13COOKIES AND TRACKING TECHNOLOGIES

What Are Cookies?

Cookies are small text files stored on your device when you visit our Site. They help us recognize you, remember your preferences, analyze usage patterns, and improve our Services.

Types of Cookies We Use

Essential Cookies (Required)

These cookies are necessary for the Site to function and cannot be disabled:

• Authentication: Remember your login status
• Security: Protect against fraud and abuse
• Session Management: Maintain your session across pages
• Load Balancing: Distribute traffic across servers

Functional Cookies (Optional)

These cookies enable enhanced functionality and personalization:

• Preferences: Remember your settings, language, and display preferences
• Features: Enable specific features you've requested
• User Interface: Remember your UI customizations

Analytics Cookies (Optional)

These cookies help us understand how users interact with our Services:

• Usage Analytics: Google Analytics, Mixpanel to track pages viewed, time spent, navigation patterns
• Performance Monitoring: Track load times, errors, and technical performance
• Feature Analytics: Understand which features are used most

Advertising Cookies (Optional)

These cookies are used for targeted advertising:

• Ad Targeting: Show relevant ads based on your interests and activity
• Ad Measurement: Measure ad effectiveness and conversions
• Retargeting: Show ads to users who previously visited our Site

Third-Party Cookies

Some cookies are placed by third-party services we use:

• Google Analytics
• Payment processors
• Social media platforms (if you use social features)
• Advertising networks

These third parties have their own privacy policies governing their use of cookies.

Managing Cookies

You can control cookies through:

Browser Settings

Most browsers allow you to:

• View and delete cookies
• Block all cookies
• Block third-party cookies
• Receive notifications when cookies are set

Instructions are typically in your browser's "Help" or "Settings" section.

Our Cookie Banner

When you first visit our Site, you'll see a cookie banner allowing you to:

• Accept all cookies
• Reject optional cookies
• Customize your cookie preferences

Do Not Track

Some browsers support "Do Not Track" (DNT) signals. Currently, there is no industry standard for handling DNT signals, and we do not respond to DNT signals at this time. We will update this policy if industry standards emerge.

Consequences of Blocking Cookies

If you block or delete cookies:

• Essential cookies: The Site may not function properly
• Functional cookies: Some features may not work, and preferences will not be remembered
• Analytics cookies: We won't be able to improve Services based on usage data
• Advertising cookies: You'll still see ads, but they may be less relevant

Cookie Duration

• Session Cookies: Deleted when you close your browser
• Persistent Cookies: Remain on your device for a specified period (ranging from hours to years) or until you delete them

14CHILDREN'S PRIVACY

Age Restriction

Lynqly restricts the use of the Site and Services to individuals age 18 and above. Our Services are not directed to children under 18.

No Knowing Collection

Lynqly does not knowingly collect personal information from children under the age of 18 (or the applicable age of majority in your jurisdiction).

Parental Notice

If we become aware that we have collected personal information from a child under 18 without parental consent, we will take steps to delete that information as quickly as possible.

If you believe we have collected information from a child under 18, please contact us immediately at privacy@lynqly.com.

15CALIFORNIA-SPECIFIC DISCLOSURES

California Consumer Privacy Act (CCPA) Notice

This section applies to California residents and supplements our Privacy Policy.

Categories of Personal Information Collected

In the past 12 months, we have collected the following categories of personal information:

• Identifiers: Name, email address, username, IP address, device identifiers
• Commercial Information: Purchase history, payment information, transaction records
• Internet Activity: Browsing history, search history, interaction with our Services
• Geolocation Data: General location derived from IP address
• Professional Information: Company name, job title, industry (if provided)
• Inferences: Preferences, interests, behavior patterns derived from other information

Sources of Personal Information

We collect personal information from:

• Directly from you (account creation, purchases, communications)
• Your devices automatically (usage data, cookies, logs)
• Third-party sources (data enrichment, analytics, social login)

Business Purposes for Collection

We use personal information for the business purposes described in the "How We Use Your Information" section, including:

• Providing and improving Services
• Communications and customer support
• Marketing (with consent)
• Security and fraud prevention
• Legal compliance

Categories of Third Parties We Share With

We share personal information with:

• Service providers (cloud hosting, payment processors, analytics)
• AI and technology providers
• Marketing and advertising partners
• Professional advisors (legal, accounting)
• Government authorities (when legally required)

Sale or Sharing of Personal Information

Lynqly does not sell personal information in the traditional sense. However, under the CCPA's broad definition, allowing third-party cookies for targeted advertising may constitute a "sale" or "sharing."

• Categories Sold/Shared: Identifiers, internet activity (through advertising cookies)
• Opt-Out: You can opt out by adjusting cookie settings or clicking "Do Not Sell My Personal Information" in the footer

We do NOT sell or share personal information of minors under 16.

Your California Privacy Rights

California residents have the right to:

1. Know: Request disclosure of personal information collected, used, disclosed, or sold
2. Delete: Request deletion of personal information
3. Opt-Out: Opt out of sale/sharing of personal information
4. Non-Discrimination: Not be discriminated against for exercising rights
5. Correct: Request correction of inaccurate information
6. Limit: Limit use of sensitive personal information (if applicable)

To Exercise Rights: Email privacy@lynqly.com or use account settings

Verification: We will verify your identity before fulfilling requests

Response Time: We respond within 45 days (may extend another 45 days if needed)

Authorized Agents: You may designate an authorized agent to make requests on your behalf. We will require proof of authorization.

California Shine the Light Law

California residents may request information about our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, email privacy@lynqly.com with "California Shine the Light Request" in the subject line.

16EUROPEAN ECONOMIC AREA (EEA) AND UK USERS

Legal Basis for Processing

If you are in the EEA or UK, we process your personal data based on the following legal grounds:

• Contract: Processing necessary to perform our contract with you (providing Services)
• Consent: Where you have given explicit consent (marketing emails, optional cookies)
• Legitimate Interests: Where necessary for our legitimate business interests (improving Services, security, analytics), balanced against your rights
• Legal Obligation: Where required to comply with legal obligations

Data Controller

For EEA and UK users, Lynqly LLC is the data controller responsible for your personal data.

Data Protection Officer

To contact our Data Protection Officer, please email: dpo@lynqly.com

Your GDPR Rights

You have the rights described in the "Your Rights" section above, including:

• Right to access
• Right to rectification
• Right to erasure
• Right to restrict processing
• Right to data portability
• Right to object
• Right to withdraw consent
• Right to lodge a complaint with a supervisory authority

Supervisory Authority

If you are located in the EEA or UK, you have the right to lodge a complaint with your local data protection authority if you believe we have violated your data protection rights.

• UK: Information Commissioner's Office (ICO) - https://ico.org.uk
• EEA: Your local data protection authority

International Data Transfers

When we transfer personal data from the EEA or UK to the United States or other countries, we use:

• Standard Contractual Clauses approved by the European Commission
• Other approved data transfer mechanisms
• Appropriate safeguards to protect your data

17NEVADA RESIDENTS

Nevada residents have the right to opt out of the sale of certain covered information that we may have collected or may collect about you. To exercise this right, please email privacy@lynqly.com with "Nevada Opt-Out Request" in the subject line. Note that Lynqly does not currently sell covered information as defined under Nevada law.

18CONTACT INFORMATION

Privacy Questions and Requests

For questions about this Privacy Policy or to exercise your privacy rights, please contact us at:

Email: privacy@lynqly.com
Support: support@lynqly.com
Data Protection Officer: dpo@lynqly.com
Security Issues: security@lynqly.com

Mailing Address:
Lynqly LLC
Privacy Department
[INSERT PHYSICAL ADDRESS]
[City, State ZIP]

Response Time: We will respond to privacy inquiries within 30-45 days (or as required by applicable law).

General Contact

Lynqly LLC
Website: https://www.lynqly.com
Email: support@lynqly.com

19UPDATES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, Services, legal requirements, or other factors. We will notify you of material changes by:

• Posting the updated Privacy Policy on our Site
• Updating the "Last Updated" date at the top of this document
• Sending you an email notification (for material changes)
• Displaying a notice on our Site or Services

Your Continued Use: Your continued use of the Services after we publish or notify you of changes constitutes your acceptance of the updated Privacy Policy.

Significant Changes: For significant changes that materially affect your rights, we may require you to affirmatively accept the new Privacy Policy before continuing to use the Services.

Review Regularly: We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and protect your information.

20EFFECTIVE DATE

This Privacy Policy is effective as of the date listed at the top of this document.

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End of Privacy Policy