BLINKTECH, LLC Privacy Policy

Last Updated: March 4, 2025

1.              Introduction

BLINKTECH, LLC (together with its subsidiaries, divisions, and brands, collectively, the “Company,” “us,” “we,” or “our,” as the context may require) operates and provides blinkupapp.com (the “Site”) and the bLinkup meetup services that may be integrated into third-party apps (together with the Site, the “Services”). This Privacy Policy (this “Policy”) describes our privacy practices for the Services, including the types of information we may collect from you when you visit the Site or use the Services, and our practices for collecting, using, maintaining, protecting, and disclosing that information. We respect the privacy of the users of the Services (“you” or “your,” as the context may require) and we are committed to protecting your privacy and the security of your personal information through compliance with this Policy.

Please read this Policy carefully to understand our practices regarding your personal information. By accessing or using the Services, you agree to this Policy and our Terms of Use. If you do not agree with our policies and practices, please do not visit, access, use, or otherwise interact with the Services.

2.              The Interactions this Policy Covers

This Policy describes and applies exclusively to personal information (as defined below) that we collect on or in connection with the Services and in texts, emails, and other electronic communications sent through or in connection with the Services, including when you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy. Except as otherwise provided in this Policy or as required by applicable law, this Policy does not apply to information that is collected by us offline or through any other means, or by any app, website, or third party other than the Services, including through any app that the Services may be available through or that may access, be linked to, or otherwise be accessible from the Services. If you access the Services through a third-party app, be sure to review its privacy policy as well as this Policy, as that policy will also apply to your interactions with the app. If you visit an app, website, or third party that we mention or link to, be sure to review its privacy policy before providing it with any information, as that privacy policy will apply to your interactions with that app, website, or third party.

Except as otherwise provided in this Policy, “personal information” is information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you. “Personal information” does not include information which is generally not considered “personal information” under applicable law or is otherwise exempted under applicable law, such as information which is publicly available or subject to special data privacy laws and/or regulations, or information not otherwise considered “personal information” under applicable law.

3.              Information We Collect

We collect several types of information from and about you as a result of your use of the Services and as a result of your communication with us. This information may include:

·       Various categories of personal information, such as:

o   Identifiers, including your name, phone number, image (if you upload a profile picture), and other similar identifiers.

o   Your phonebook and contacts when you expressly consent to the collection of such information.

o   Location information, including general location and precise geolocation when you expressly consent to the collection of such precise geolocation information. Note that the Services require access to your real-time precise geolocation, but solely to determine whether you are or are not at an event. We do not store your precise geolocation.

o   Inferences drawn from any of the above.

o   Any other personal information that you upload or share to or on the Services, or which you otherwise provide directly to us.

·       Information that is about you but individually does not identify you, such as information which has been de-identified or aggregated in a manner where it can no longer be used to identify you.

·       Information about your internet connection and the equipment you use to access the Services; IP address and other unique device identifiers; your activity on the Services; and other usage details collected through your use of the Services.

·       Any other information, including personal information, which you disclose or share.

4.              How We Collect Personal Information

We may collect personal information:

·       Directly from you when you provide it to us;

·       Automatically when you use or access the Services, such as through cookies, web beacons, and other tracking technologies; or

·       From third parties, such as our service providers and event partners.

A.             Information We Collect Directly

The personal information we collect directly from you when you use or access the Services includes:

·       Information that you provide by visiting the Site or using the Services, such as by registering for an account to use the Services, checking into a location, connecting with other users of the Services, posting a review, or filling in forms on the Services.

·       Your voluntary responses to surveys that we might ask you to complete.

·       Records and copies of your communications when you contact us, including information you provide when requesting further information or reporting a problem with the Services.

B.             Information We Collect Automatically

As you navigate through and interact with the Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

·       Usage details. When you access and use the Services, we may automatically collect certain details of your access to and use of the Services, including traffic data, approximate location data, logs, and other communication data and the resources that you access and use on or through the Services.

·       Device information. We may collect information about your computer or mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, and mobile network information.

The information we collect automatically may include personal information. This information helps us to improve our Services and to deliver a better and more personalized service, including by enabling us to estimate our audience size and usage patterns, store information about your preferences, and recognize you when you return to the Services.

The technologies we use for automatic information collection on the Site may include cookies. A cookie is a small file containing a string of characters that is sent to your browser when you visit a website. When you visit the website again, the cookie allows that site to recognize your browser. Cookies may store unique identifiers, user preferences, and other information, such as what pages you visit, your IP address, or how you arrived on the website. Cookie information allows us to enable certain functions of the Site, to store your preferences and settings, and to analyze your use of the Site and improve your experience on the Site. Ultimately, a cookie allows us or a third party to recognize you and make the Site more useful to you. 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 browser. You can refuse to accept cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Site, and overall functionality of the Site may be impaired. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Site.

The Services may also contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or and for other related statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

We also utilize third-party analytics providers to help us market, troubleshoot, and provide information about our products and services. We use analytics tools provided by third parties including, but not limited to, Google Firebase and Google Analytics, which are third-party services that transmit user behavior and traffic data to Google services in the United States. We use the reports provided by Google and similar service providers to help us understand trends and other activity on the Services and to help us improve the Services. We only use this information to identify trends and potential issues; we do not use it in a way that individually identifies any of our users. For more information regarding Google and how it collects and processes your information, please see “How Google Uses Information From Sites or Apps That Use Our Services,” located at www.google.com/policies/privacy/partners.

C.             From Third Parties

We may also receive personal information or draw inferences about you from other sources, such as service providers who collect or process information on our behalf and event partners who provide the Services through their app.

5.              How We Use Your Personal Information

We may use the personal information that we collect about you or that you provide to us:

·       To provide you with the Services, all related content, and any other information, products, or services that you request from us.

·       To enable you to share your approximate location with and send messages to your contacts.

·       To help you identify which of your contacts are also users of the Services and allow you to invite contacts who are not users of the Services.

·       To communicate with you and to process your requests.

·       To market to you and notify you of changes or additions to any products or services we offer.

·       To help maintain the safety, security, and integrity of the Services, as well as our products, services, databases, and other technology assets.

·       To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.

·       For testing, research, analysis, and development, including to understand our audience, develop and improve the Services and the Company.

·       To respond to law enforcement requests and, as required by applicable law, court order or governmental regulations.

·       To evaluate, negotiate, or conduct a merger, divestiture, restructuring, reorganization, dissolution, other sale or transfer of some or all of our assets, or the negotiation thereof, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users and customers is among the assets transferred.

·       To fulfill any other purpose for which you provide it.

·       For any other purpose with your consent.

We may use your information to contact you about our goods and services that may be of interest to you. If you do not want us to use your information in this way, please contact us as provided in Section 13 (How to Contact Us). For more information, see Section 7 (Your Privacy Choices).

6.              Disclosure of Your Personal Information

We may disclose personal information that we collect or that you provide:

·       To our subsidiaries and affiliates.

·       To contractors, service providers, advisors, and other third parties we use to support our business, which may include advertisers, social media networks, or analytics providers.

·       To event partners who run events or provide services for events.

·       To an actual or prospective buyer or other successor in the event of an actual or proposed merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users is among the assets transferred.

·       To fulfill the purpose for which you provide it.

·       To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

·       To enforce our rights arising from any contracts entered into between you and us, and for billing and collection.

·       If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.

·       For any other purpose disclosed by us when you provide the information.

·       With your consent.

We do not sell personal information for monetary consideration.

We may use or disclose aggregated information about our users and information that does not identify any individual without restriction.

7.              Your Privacy Choices

We strive to provide you with choices regarding the personal information you provide to us. We have gathered the following mechanisms to provide you with control over your information:

·       Accessing, Correcting, and Updating Your Information. To access and update certain information (such as your name), you can login and edit your profile in the Services, or you can contact us as provided in Section 13 (How to Contact Us).

·       Deleting Your Account. To delete your account and the information associated with your account, you can select “Be Forgotten – Delete Account” in the Services, or you can contact us as provided in Section 13 (How to Contact Us).

·       Tracking Technologies; Device Permissions. You can set your browser to refuse all or some cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, some parts of the Services may then be inaccessible or not function properly. Mobile devices offer permission systems for specific types of device data and notifications, such as phone contacts, pictures, location, and push notifications. You can change your settings on your device to either consent to or refuse the collection or processing of the corresponding information or the display of the corresponding notifications. If you disable or refuse certain permissions, the Services may then be inaccessible or not function properly. Note that the Services do not currently respond to “do not track” (DNT) signals.

·       Promotional Offers from Us. If you do not wish to have your contact information used by us for promotions, you can opt-out by unsubscribing from any emails you receive from us. Additionally, you can also always opt-out by contacting us as provided in Section 13 (How to Contact Us).

·       Google Analytics. You can set your browser to refuse all or some cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, some parts of the Services may then be inaccessible or not function properly.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt-out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website, https://thenai.org/opt-out. Similarly, you can opt-out of receiving targeted ads from members of the Digital Advertising Alliance (“DAA”) on the DAA’s website, https://www.privacyrights.info.

8.              Security

We implement various physical, administrative, and technical safeguards to protect the security of your personal information both online and offline. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

9.              Retention of Personal Information

We retain your personal information only for as long as is necessary to fulfill the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws or until you withdraw your consent (where applicable).

To determine the appropriate retention period for your personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we use your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

10.           International Data Transfers

The Services are operated and managed on servers located and operated in the United States. Any information collected through the Services as described in this Policy is stored in the United States. If you are located outside of the United States, please note that we may transfer information, including personal information, to the United States, which may not have the same data protection laws as your jurisdiction, and you consent to the transfer of your personal information to, and the storage and further processing of your personal information in, the United States.

11.           Children’s Privacy

The Services are not directed to nor intended for use by anyone under 13 years old (a “Child” or “Children”). We do not knowingly collect personal information from Children. Children are not authorized to use the Services. If you are a Child, please do not provide any personal information to, on, or through the Services. If we learn we have collected or received personal information from a Child, we will delete that information. If you believe we might have any information from or about a Child, please contact us as provided in Section 13(How to Contact Us).

12.           Changes to this Policy

We reserve the right to review and revise this Policy from time to time, without prior notice, subject to applicable legal requirements to provide you prior notice or obtain your consent. If we make material changes to how we treat your personal information, we will notify you through a notice on the Services. The date this Policy was last reviewed and/or revised is noted at the top of the page. You are responsible for periodically visiting this Policy to check for any changes. Your continued use of the Services following the posting of changes constitutes your acceptance of such changes.

13.           How to Contact Us

To ask questions or comment about your personal information, this Policy, or our privacy practices, you may contact us:

·       Via email at blinktechmke@gmail.com

14.           Notice for California Residents

This Section 14 applies exclusively to visitors and users of the Services who reside in the state of California. California's “Shine the Light” law (California Civil Code Section 1798.83) permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. If you would like to exercise this right, please contact us as provided in Section 13 (How to Contact Us).

15.           Notice for Nevada Residents

This Section 15 applies exclusively to visitors and users of the Services who reside in the state of Nevada. Nevada provides its residents with a limited right to opt-out of certain personal information sales. Nevada residents who wish to exercise this sale opt-out right may email us at blinktechmke@gmail.com . Please include “Nevada” in your email subject line and include the following information in your email: (i) your name, (ii) Nevada resident address, and (iii) email address. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

16.           Notice for Individuals Located in the EEA, Switzerland, or the UK

This Section 16 applies exclusively to visitors and users of the Services who are located in the European Economic Area (“EEA”), Switzerland, or the United Kingdom (“UK”).

The data controller for the personal information that we collect directly from or about you is BLINKTECH, LLC, 3059 N. Weil St., Milwaukee, WI 53212, blinktechmke@gmail.com.

When we are the data controller of personal information, we need to inform individuals in the EEA, Switzerland, or the UK about the legal bases for our processing of their personal information. Our legal bases depend on the context in which the personal information is collected and processed. Generally, we only collect personal information when we need the personal information to perform a contract with an individual in the EEA, Switzerland, or the UK, when we have consent to do so, when necessary to comply with our legal obligations, or when the processing is in our legitimate business interests and not overridden by the privacy or other fundamental rights and freedoms of individuals in the EEA, Switzerland, or the UK.

If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest is typically to provide our Services and communicate with you as necessary to provide our Services to you, such as when we respond to your queries or send you information related to new products or services. We may have other legitimate interests and we will make clear our legitimate interests at the relevant time when necessary.

If you have questions about or need further information concerning which organization is acting as the data controller of your personal information or the legal bases on which your personal information is processed, please contact us as provided in Section 13 (How to Contact Us).

We want to make sure you are fully aware of all of your data protection rights, which include the following rights:

·       Right to Access. You have the right to request copies of your personal information. If you require more than one copy, we may charge you a reasonable fee.

·       Right to Rectification. You have the right to request that we correct any inaccurate personal information, or to complete any personal information which is incomplete.

·       Right to Erasure. You have the right to request that we erase your personal information, under certain circumstances.

·       Right to Restrict Processing. You have the right to request that we restrict the processing of your personal information, under certain circumstances.

·       Right to Object to Processing. You have the right to object to our processing of your personal information, under certain circumstances.

·       Right to Data Portability. You have the right to request we transfer data that we have collected to you or directly to another organization, under certain circumstances.

·       Right to Withdraw Consent. You have the right to withdraw your consent, explicit or otherwise, at any time. If we rely on your consent as the legal basis for our processing of your personal information, we will refrain from processing your personal information.

·       Right to Object to Automatic Decision-Making. You have the right not to be subject to automated decision-making, though note that we do not currently engage in any automated decision-making.

If you would like to exercise any of these rights, please contact us as provided in Section 13 (How to Contact Us).

For your protection, we may need to verify your identity before fulfilling your request. If we need more information to process a request, we will contact you by email or, if we do not have your email address on file, by the same method the request was made. We will try to comply with your request as soon as reasonably practicable and within the time periods required by applicable law. If we do not honor a request for legal or other reasons, we will explain why we did not honor the request, the right to appeal, and any right to file a complaint.

In the EEA, you have the right to lodge a complaint with your local data protection supervisory authority. In Switzerland, you have the right to lodge a complaint with the Federal Data Protection Information Commissioner. In the UK, you have the right to lodge a complaint with the Information Commissioner's Office.

17.           Notice for Individuals in Canada

This Section 17 applies exclusively to visitors and users of the Services who reside in Canada. We provide this notice to comply with Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (“PIPEDA”). We strive to protect your privacy by following each of the fair information principles set out by PIPEDA.

We want to make sure you are fully aware of all of your data protection rights, which include the following rights:

• Right to Access. You have the right to confirm that we hold personal information about you, receive an explanation about how we use your personal information, and obtain access to your personal information.

• Right to Rectification. You have a right to examine and challenge the accuracy and completeness of your personal information, and have your personal information amended where appropriate.

• Right to Withdraw Your Consent. You have the right to withdraw your consent to processing your personal information at any time, subject to legal or contractual restrictions and reasonable notice.

If you are resident of Quebec, Quebec law provides you with additional rights regarding the use of your personal information, which include:

• Right to Cease Dissemination. If the dissemination of your personal information is contrary to the law or a court order or if certain other conditions specified in the applicable law are met, you have the right to request that we cease dissemination your personal information.

• Right to De-Indexation or Re-Indexation. If the dissemination is contrary to the law or a court order or if certain other conditions specified in the applicable law are met, you have the right to request that we de-index any hyperlink attached to your name and providing access to personal information by a technological means. If certain conditions are met, you have the right to request that we re-index a hyperlink attached to your name and providing access to personal information by a technological means.

• Right to Portability. You have the right to request that computerized personal information collected from you be communicated to you in a commonly used technological format as well as to any person or body authorized by law to collect such information.

If you would like to exercise any of these rights, please contact us as provided in Section 13 (How to Contact Us).

For your protection, we may need to verify your identity before fulfilling your request. If we need more information to process a request, we will contact you by email or, if we do not have your email address on file, by the same method the request was made. We will try to comply with your request as soon as reasonably practicable and within the time periods required by applicable law. If we do not honor a request for legal or other reasons, we will explain why we did not honor the request, the right to appeal, and any right to file a complaint.

We recognize that we are responsible for personal information under our control. We have designated our CEO as our privacy official to ensure privacy compliance, including PIPEDA compliance.  If you have any concerns about our privacy practices and policies, you can contact our CEO at blinktechmke@gmail.com. We will thoroughly investigate any complaints received and try to substantively respond within thirty (30) business days of its receipt. If we need more time, we will inform you of the reason and extension period.

If our CEO is unable to resolve your concern, you may also contact the Office of the Privacy Commissioner of Canada or the appropriate provincial regulator.