DATA PROCESSING ADDENDUM (DPA)

1. Parties

Data Controller (“Controller”)
The linkks User who creates and uses Forms to collect personal data.

Data Processor (“Processor”)
Individual Entrepreneur Spievakova Maryna Hennadiivna
Registration number: 22240000000086519
EDRPOU: 3177907526
Address: Pavla Niryberga Street 10/134, Dnipro, Ukraine
Email: hey@linkks.cc

(“linkks”)

2. Scope and Subject Matter

This DPA governs the processing of personal data by linkks on behalf of the User when the User:

• creates Forms;
• collects leads or contact information;
• conducts surveys or receives messages via Forms.

3. Roles of the Parties

The User acts as the Data Controller, as the User determines:

• the purposes of processing;
• the categories of personal data collected;
• the lawful basis for processing;
• retention periods.

linkks acts as a Data Processor, providing technical infrastructure to:

• receive;
• transmit;
• store personal data solely to deliver the Platform functionality.

linkks does not process Form data for its own independent purposes.

4. Categories of Personal Data

Depending on Form configuration, personal data may include:

• name;
• email address;
• phone number;
• message content;
• survey responses;
• any other data defined by the User.

5. Categories of Data Subjects

• visitors of the User’s pages;
• potential customers or subscribers;
• survey respondents.

6. Purpose of Processing

Personal data is processed exclusively for:

• delivering Form submissions to the User;
• technical storage and display in the User dashboard;
• ensuring proper operation of the Forms feature.

7. User Instructions

linkks processes personal data only in accordance with documented instructions from the User, which are defined by:

• Form configuration;
• account settings;
• User actions performed on the Platform.

8. Obligations of the User (Controller)

The User agrees to:

• have a valid lawful basis for collecting personal data (e.g., consent, contract);
• provide appropriate privacy notices to data subjects;
• comply with all applicable data protection laws;
• avoid collecting excessive or unlawful data;
• handle and respond to data subject requests independently.

9. Obligations of linkks (Processor)

linkks agrees to:

• process personal data confidentially;
• not disclose personal data to third parties except for technical sub-processors;
• implement appropriate technical and organizational security measures;
• not use personal data for its own purposes;
• reasonably assist the User with data subject requests where technically feasible.

10. Sub-processors

linkks may engage sub-processors (e.g., hosting, infrastructure, logging providers) solely to provide the Platform.

All sub-processors are subject to contractual confidentiality and data protection obligations consistent with this DPA.

11. Data Location and Transfers

Primary data storage is located in Spain (European Union). Personal data may be processed in other jurisdictions only where appropriate safeguards are in place.

12. Security Measures

linkks implements measures including:

• HTTPS encryption;
• access controls;
• logging and monitoring;
• protection against unauthorized access.

13. Data Retention

Personal data collected via Forms is retained:

• for as long as the User account remains active;
• until deleted by the User;
• or until account deletion, followed by permanent erasure after 30 days, unless retention is required by law.

14. Deletion or Return of Data

Upon termination of Form usage or deletion of the User account:

• personal data is removed from active systems;
• residual data in backups is deleted in accordance with technical retention cycles.

15. Liability

The User bears full responsibility for:

• the legality of data collection;
• the content and configuration of Forms;
• any further use of collected personal data.

linkks is not a party to the relationship between the User and the data subjects.

16. Acceptance of this DPA

By using Forms on linkks, the User automatically agrees to this DPA.

17. Contact

For data protection inquiries:

Email: hey@linkks.cc

Address: Pavla Niryberga Street 10/134, Dnipro, Ukraine