PRIVACY POLICY

Linker, a product by PortfoPlus Limited ("Linker", "we", "us", "our"), is committed to protecting your privacy. This Privacy Policy outlines how we collect, use, store, share, and protect your information when you use Linker's websites, mobile applications, and related services (collectively, the "Services"). It complies with the Personal Data (Privacy) Ordinance of Hong Kong SAR, Chapter 486 (the "Ordinance").

BY USING THE SERVICES VIA OUR WEBSITE OR MOBILE APPLICATION, OR BY OTHERWISE GIVING US YOUR INFORMATION, YOU ACKNOWLEDGE AND AGREE TO THE TERMS OF THIS PRIVACY POLICY. Do not use the Services or give us any of your information if you do not agree to the terms of this privacy policy.

1. Information We Collect

To provide you with our Services, we may collect the following types of personal data:

a) Account & Profile Information
When you register for a Linker account, we collect your name, email address, phone number, profile photo, occupation, team name, links to social platforms, and other information you voluntarily provide in your digital card.

b) Usage & Device Information
We collect data about how you interact with our Services, including:

• Device data (e.g. IP address, browser, operating system, device type)
• Location data (if enabled)
• Log data and clickstream behavior on the app or website

c) Payment Information
When you subscribe to a paid plan, payment processing is handled securely by third-party platforms (such as Stripe, Apple Pay, or Google Pay). We do not store your full credit card details.

d) Communications
We may store communications between you and Linker, including customer support inquiries and email correspondence.

e) AI-Generated Inputs
If you use AI-powered features (e.g., voice-to-text, smart suggestions), we may temporarily collect and process your voice data, text inputs, and related interaction data. We do not retain this data beyond the necessary processing time unless you explicitly save it.

2. How We Use Your Information

2.1 General Use

We use your information for the following purposes:

• To create and manage your account
• To enable you to create, share, and manage your digital business card(s)
• To enable interactive features (e.g., contact sharing via NFC)
• To personalize your experience and display relevant content
• To process payments and manage subscriptions
• To send you service updates, newsletters, or promotional offers (you may opt out at any time)
• To monitor usage trends and improve our Services
• To ensure user safety and comply with legal obligations
• To notify you of service changes
• To carry out our obligations arising from any contracts entered into between you and us and/or to provide the Services, including (but not limited to) providing relevant information or advice, processing your enquiries, and undertaking administration, planning and account management functions as well as other associated business processes.

2.2 Direct Marketing

We may conduct direct marketing via fax, email, direct mail, telephone, and other means of communication or send e-newsletters to you about our products, services, and promotions.

You may choose not to receive promotional materials at any time by:

• Clicking the "unsubscribe" link in our marketing emails
• Contacting us directly at hello@portfoplus.com

We will honor your request without charge, and you may withdraw your consent to marketing at any time.

3. Use of AI Features

Certain Linker features may be powered by artificial intelligence (AI) to enhance your experience. These may include:

• Smart tag suggestions
• Usage pattern analysis
• Personalized recommendations

These features may process your user inputs, content, and interaction data. Linker uses third-party AI providers such as Microsoft Azure OpenAI and Google Gemini. Linker is not liable for inaccuracies or outcomes from AI-generated content, as further detailed in our Terms of Use & Disclaimer.

Please do not submit sensitive personal data (e.g., identity numbers, passwords, or financial details) to AI-powered features.

AI-generated content is not stored unless explicitly saved by the user.

Our AI providers may change from time to time. A current list of providers is available upon request by contacting hello@portfoplus.com.

4. Disclosure of Your Information

4.1 Sharing Your Information

We keep your data confidential but may share it with:

• Personnel, agents, contractors, or service providers for operations.
• Affiliates or business partners.
• Persons under confidentiality obligations.
• Entities as required by law in or outside Hong Kong.
• Actual or proposed transferees or participants of our services.

4.2 Third-Party Service Providers

We use the following third-party analytics and service providers to help us analyze how users use our site and/or mobile application, improve our services, and communicate with you. Please refer to their respective privacy policies for details on data handling:

Google Analytics is used on our website to help analyze how users use the site. Google Analytics is a web analysis service provided by Google Inc. Google utilizes the data collected to track and examine the use of our website, to prepare reports on its activities and share them with other Google services. Google's ability to use and share information collected by Google Analytics regarding your visits to this site is restricted by the Google Analytics Privacy Policy: https://policies.google.com/privacy

MIXPANEL is used on our website to help analyze how users use the site. MIXPANEL is a web analysis service provided by Mixpanel. Mixpanel utilizes the data collected to track and examine the use of our website, to prepare reports on its activities. Mixpanel's ability to use and share information collected by Mixpanel regarding your visits to this site is restricted by the Mixpanel Privacy Statement: https://mixpanel.com/legal/privacy-policy/

AMPLITUDE is used on our website to help analyze how users use the site. AMPLITUDE is a web analysis service provided by AMPLITUDE. AMPLITUDE utilizes the data collected to track and examine the use of our website, to prepare reports on its activities. AMPLITUDE's ability to use and share information collected by AMPLITUDE regarding your visits to this site is restricted by the AMPLITUDE Privacy Policy: https://amplitude.com/privacy

Each of these platforms has its own privacy policy governing the use and protection of your data.

All third-party vendors and service providers engaged by us are contractually bound to strict confidentiality and data protection obligations.

5. Cookies and Tracking technologies

5.1 How We Use Cookies

Our website and mobile applications use cookies, device identifiers, and similar tracking technologies to distinguish you from other users. This helps us improve our services and provide a better user experience. By continuing to browse the site or use our mobile applications, you are agreeing to our use of these technologies.

5.2 Types of Cookies We Use

a) Strictly necessary cookies: These are cookies and similar technologies that are required for the operation of our website and mobile applications. They include, for example, technologies that enable you to log into secure areas, maintain session state, or use core functionality.

b) Analytical/performance cookies: They allow us to recognize and count the number of visitors and app users, and to see how visitors and users move around and interact with our services. This helps us to improve the way our website and mobile applications work, for example, by ensuring that users can find what they're looking for easily.

c) Functionality cookies: These are used to recognize you when you return to our website or mobile applications. This enables us to personalize our content for you, greet you by name, and remember your preferences.

d) Targeting cookies: These technologies record your visits to our website and mobile applications, the features you've used, and your interaction patterns. We use this information to make our services and the content displayed more relevant to your interests.

5.3 Mobile Device Identifiers

Our mobile applications may use device identifiers (such as IDFA on iOS devices or Advertising ID on Android devices) and other mobile analytics tools to collect information about how you use our applications. These technologies function similarly to cookies on websites but are managed differently on mobile devices.

5.4 Cookie Management

For Website Cookies:
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our site.

For Mobile Applications:
iOS Devices: You can opt out of interest-based ads by going to Settings > Privacy > Advertising and turning on "Limit Ad Tracking"
Android Devices: You can opt out of interest-based ads in the Google Settings app under "Ads" or "Google" > "Ads"

6. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this policy, including legal, accounting, and business needs. Generally, account data is retained for up to 7 years post-account deletion, and usage logs for up to 2 year, unless a longer retention period is required by law. Retention periods are reviewed annually to ensure compliance with data minimization principles.

You may delete your account at any time, after which your data will be removed from our active systems, subject to any legal retention requirements.

7. Data Security

7.1

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition:

• All information you provide to us is stored on our secure servers.
• Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site and/or mobile application, you are responsible for keeping this password confidential.
• We use encryption to protect sensitive data transmitted to and from our site and/or mobile application.
• We regularly review and update our security practices.
• In the event of a data breach that poses a risk to your rights and freedoms, we will notify affected users within 72 hours of becoming aware of the breach, where feasible, in accordance with applicable laws.

7.2

We take all reasonable and appropriate technical and organizational measures to protect your personal data from loss, misuse, unauthorized access, alteration, or disclosure.

8. Your Rights

8.1 Your Consent

By using our service, making an application, or visiting our website and/or mobile application, you consent to the collection and use of your information and other activities as outlined in this Privacy Policy.

8.2 Your Rights Under Hong Kong Law

Under the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong, you have the right to:

• Access your personal data held by us
• Request correction of any inaccurate data
• Opt out of direct marketing communications

8.3 Exercising Your Rights

To exercise any of these rights, to cease communications, and/or to submit any questions or complaints about our privacy practices, please contact us at:

Email: hello@portfoplus.com

We will respond to verified data access or correction requests within 40 days as required by the Ordinance.

We may charge a reasonable fee for processing data access requests.

9. International Data Transfers

Where necessary, the Company may transfer your personal data to third parties outside of Hong Kong for the purposes specified in this Privacy Policy. We will ensure that any international transfer of your personal data is made pursuant to appropriate safeguards in accordance with the Ordinance as well as applicable laws and regulations in Hong Kong. Safeguards include contractual clauses ensuring data protection standards equivalent to those required under Hong Kong law.

10. Children's Privacy

Linker is not intended for use by individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that a child under 18 has provided personal data, we will delete such data as soon as reasonably practicable.

11. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. All changes will be posted on this page with an updated "Last Updated" date. Please check back frequently to see any updates or changes to our Privacy Policy. The updated version will be effective as of the "Last Updated" date at the top of this policy. Continued use of the Services after changes constitutes your acceptance. We commit to reviewing this Policy annually to ensure it remains relevant and compliant with applicable laws.

12. Governing Law

This Privacy Policy is governed by the laws of the Hong Kong Special Administrative Region. Any disputes shall be subject to the exclusive jurisdiction of the Hong Kong courts.