- We do not collect identity information.
- We do not store or share your precise location.
- No personal data is stored by us.
- We do not keep any user data.
- We do not share your personal data with other companies.
- No ad companies collect data through our service.
- You can ask privacy questions. If you have any questions or concerns about our privacy policies, please contact us: email@example.com
- We do not use any vendors or analytics providers.
- No personal data is collected or stored.
- Since we do not collect any of your data, we never disclose personal data.
- You can review more privacy-related information.
StayLinked GDPR Compliance Statement
The E.U. General Data Protection Regulation (“GDPR”) became effective across the European Union on 25th May 2018, and brought with it the most significant changes to data protection law in two decades. Based on privacy by design and taking a risk-based approach, the GDPR has been designed to meet the requirements of the digital age.
The 21st century brings with it broader use of technology, new definitions of what constitutes personal data, and a vast increase in cross-border processing. The new Regulation aims to standardize data protection laws and processing across the E.U., affording individuals stronger, more consistent rights to access and control their personal information.
While StayLinked Corporation (“StayLinked” or “we” or “us” or “our”) does not, in the course of its normal business, collect personal data from our customers or business associates beyond email addresses, phone numbers, and business addresses voluntarily provided to StayLinked by individuals doing business with StayLinked, we are committed to ensuring the security and protection of the personal information that we process, as well as to providing a compliant and consistent approach to data protection. We have always had a robust and effective data protection program in place which complies with existing law and abides by data protection principles. However, we recognize our obligations in updating and expanding this program to meet the demands of the GDPR and the laws of the various members of the European Union.
StayLinked is dedicated to safeguarding the personal information under our possession and control, as well as to developing a data protection regime that is effective, fit for purpose, and demonstrates an understanding of and appreciation for the new Regulation. Our preparation and objectives for GDPR compliance have been summarized in this statement and include the development and implementation of new data protection roles, policies, procedures, controls, and measures to ensure maximum and ongoing compliance.
How We Are Implementing the GDPR
StayLinked already has a consistent level of data protection and security across our organization, and we believe that we are fully compliant with the GDPR.
Our GDPR implementation includes:
- No Personal Data Collected: We do not collect or hold the personal information of any individual with whom we conduct business or otherwise associate beyond the generic information identified herein above.
- Policies & Procedures: [revising/implementing new] We have verified that the data protection policies and procedures that have long been the policies and procedures of StayLinked fully meet the requirements and standards of the GDPR and any relevant data protection laws, including:
- Data Protection: Our main policies and procedures for data protection meet the standards and requirements of the GDPR, as we do not collect such data. Accountability and governance measures are in place to ensure that we understand and adequately disseminate and evidence our obligations and responsibilities, with a dedicated focus on privacy by design and the rights of individuals.
- Data Retention & Erasure: Our retention policy and schedule meet the “data minimization” and “storage limitation” principles so that in the event that in the future we collect personal data, that personal information is stored, archived, and destroyed compliantly and ethically. We have dedicated erasure procedures in place to meet the new “Right to Erasure” obligation and are aware of when this and other data subjects’ rights apply, along with any exemptions, response timeframes, and notification responsibilities.
- Data Breaches: Our breach procedures ensure that we have safeguards and measures in place to identify, assess, investigate, and report any personal data breach at the earliest possible time.
- International Data Transfers & Third-Party Disclosures: Where StayLinked stores or transfers personal information outside the E.U. (which is limited to the minimal information identified herein above), we have robust procedures and safeguarding measures in place to secure, encrypt, and maintain the integrity of the data. In the event that personal data is collected and so stored, our procedures will include a continual review of the countries with sufficient adequacy decisions, as well as provisions for binding corporate rules, standard data protection clauses, or approved codes of conduct for those countries without. As necessary, we will carry out strict due diligence checks with all recipients of personal data to assess and verify that they have appropriate safeguards in place to protect the information, ensure enforceable data subject rights and have effective legal remedies for data subjects where applicable.
- Subject Access Request (SAR): Our SAR procedures accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge. Our internal procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply, and internal policies to ensure that communications with data subjects are compliant, consistent, and adequate.
In the future event that StayLinked begins to collect personal data in excess of the minimal contact information identified herein above, we will take the following steps relative thereto:
- Legal Basis for Processing: We will review all processing activities to identify the legal basis for processing and ensure that each basis is appropriate for the activity it relates to. Where applicable, we will maintain records of our processing activities, ensuring that our obligations under Article 30 of the GDPR and Schedule 1 of the Data Protection Bill are met.
- Privacy Notice/Policy: We will revise and implement Privacy Notice(s) to comply with the GDPR, ensuring that all individuals whose personal information we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.
- Obtaining Consent: We will revise and implement our consent mechanisms for obtaining personal data, ensuring that individuals understand what they are providing, why and how we use it, and are given clear, defined ways to consent to us processing their information. We will develop stringent processes for recording consent, making sure that we can evidence an affirmative opt-in, along with time and date records; and provide an easily seen and accessible way to withdraw consent at any time.
- Direct Marketing: We will revise the wording and processes for direct marketing, including clear opt-in mechanisms for marketing subscriptions, a clear notice and method for opting out, and provide unsubscribe features on all subsequent marketing materials.
- Data Protection Impact Assessments (DPIA): Where we process personal information that is considered high risk, involves large-scale processing, or includes special category/criminal conviction data, we will develop stringent procedures and assessment templates for carrying out impact assessments that comply fully with the GDPR’s Article 35 requirements. We will implement documentation processes that record each assessment, allow us to rate the risk posed by the processing activity, and implement mitigating measures to reduce the risk posed to the data subject(s).
- Processor Agreements: Where we use any third party to process personal information on our behalf (e.g., payroll, recruitment, hosting), we will put into effect compliant Processor Agreements and due diligence procedures for ensuring that they (as well as we) meet and understand their (our) GDPR obligations. These measures include initial and ongoing reviews of the service provided, the necessity of the processing activity, the technical and organizational measures in place, and compliance with the GDPR.
- Special Categories Data: Where we obtain and process any special category information, we will do so in complete compliance with the Article 9 requirements and have high-level encryptions and protections on all such data. Special category data will only be processed where necessary and will only be processed where we have first identified the appropriate Article 9(2) basis or the Data Protection Bill Schedule 1 condition. Where we rely on consent for processing, this will be explicit and will be verified by a signature, with the right to modify or remove consent being clearly signposted.
Data Subject Rights
In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide easy-to-access information (via contacting our office) about an individual’s right to access any personal information that StayLinked processes about them and to request information about:
- What personal data we hold about them
- The purposes of the processing
- The categories of personal data concerned
- The recipients to whom the personal data has/will be disclosed
- How long we intend to store your personal data
- If we did not collect the data directly from them, information about the source
- The right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this
- The right to request erasure of personal data (where applicable) or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use
- The right to lodge a complaint or seek judicial remedy and who to contact in such instances
Information Security & Technical and Organizational Measures
StayLinked takes the privacy and security of individuals and their personal information very seriously and takes every reasonable measure and precaution to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorized access, alteration, disclosure, or destruction, and we have several layers of security measures.
GDPR Roles and Employees
StayLinked has designated Gary Brewsaugh, General Counsel, as our Appointed Person to ensure compliance with the new data protection Regulation. The Appointed Person, together with such additional personnel as may be necessary, is responsible for promoting awareness of the GDPR across the organization, assessing our GDPR readiness, identifying any gap areas, and implementing the new policies, procedures, and measures. StayLinked understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR, and has involved our employees in our preparation plans.