Privacy Policy

Last updated: August 17, 2026

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal Data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

Words with initial capital letters have meanings defined under the following conditions. These definitions have the same meaning regardless of whether they appear in singular or plural.

Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for You to access our Service or parts of our Service.
Affiliate means an entity that controls, is controlled by or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
Business, for the purpose of the CCPA/CPRA, refers to the Company as the legal entity that collects Consumers' personal information.
CCPA/CPRA refers to the California Consumer Privacy Act, as amended by the California Privacy Rights Act.
Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to INCODE GROUP SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ, UL. SZLAK 77/222, KRAKÓW, Poland, 31-153.
Consumer, for the purpose of the CCPA/CPRA, means a natural person who is a California resident.
Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website.
Country refers to Poland.
Data Controller, for the purposes of the GDPR, refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.
GDPR refers to the EU General Data Protection Regulation.
Personal Data is any information that relates to an identified or identifiable individual.
Service refers to the Website.
Service Provider means any natural or legal person who processes the data on behalf of the Company.
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself.
Website refers to LinkedRefs, accessible from https://linkedrefs.com.
You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You ("Personal Data"). Personally identifiable information may include, but is not limited to:

Email address
LinkedIn™ profile
Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link.

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used include beacons, tags, and scripts to collect and track information and to improve and analyze Our Service.

The Cookies We use:

Necessary / Essential Cookies – Type: Session Cookies. Administered by: Us. Purpose: Provide You with services available through the Website, enable use of certain features, authenticate users, prevent fraudulent use and improve security.
Cookies Policy / Notice Acceptance Cookies – Type: Persistent Cookies. Administered by: Us. Purpose: Identify if users have accepted the use of cookies on the Website.
Functionality Cookies – Type: Persistent Cookies. Administered by: Us. Purpose: Remember choices You make such as login details, language preference, and other settings.
Tracking and Performance Cookies – Type: Persistent Cookies. Administered by: Third-Parties. Purpose: Monitor and analyze website traffic and user behavior.

Where required by applicable law, We obtain Your consent before placing non-essential cookies. You may withdraw consent at any time.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

To provide and maintain our Service, including to monitor the usage of our Service.
To manage Your Account: to manage Your registration as a user of the Service.
For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased.
To contact You: by email, telephone calls, SMS, or other equivalent forms of electronic communication, including push notifications regarding updates or informative communications.
To provide You with news, special offers and general information about other goods, services and events similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
To manage Your requests: To attend and manage Your requests to Us.
For business transfers: To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets.
For other purposes: data analysis, identifying usage trends, determining the effectiveness of promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

With Service Providers: to monitor and analyze the use of our Service, for payment processing, and to contact You.
For business transfers: in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business.
With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy.
With business partners: to offer You certain products, services or promotions.
With other users: when You share personal information or otherwise interact in public areas with other users.
With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

User accounts: duration of the relationship plus up to 24 months post-closure.
Support tickets and correspondence: up to 24 months from ticket closure.
Chat transcripts: up to 24 months for quality assurance and training.
Website analytics (cookies, IP addresses, device identifiers): up to 24 months.
Server logs (IP addresses, access times): up to 24 months.
Payment information: not stored on our servers; processed by Payment Service Providers. Transaction records retained up to 10 years for tax and regulatory compliance.
Billing and invoice records: up to 10 years.

Longer retention may apply where required for legal obligations, legal claims, explicit user request, or technical limitations. Deletion procedures include removal from systems, encrypted backup retention for a limited period, or anonymization for indefinite research and analytics retention.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to and maintained on computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy. International transfers include appropriate safeguards and supplementary measures such as encryption, access controls, data minimization, and vendor security reviews, including European Commission Standard Contractual Clauses (SCCs), UK International Data Transfer Agreement (IDTA), or UK SCC Addendum where required by law.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You. Our Service may give You the ability to delete certain information about You from within the Service. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law Enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other Legal Requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

Comply with a legal obligation
Protect and defend the rights or property of the Company
Prevent or investigate possible wrongdoing in connection with the Service
Protect the personal safety of Users of the Service or the public
Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Detailed Information on Processing of Personal Data

Analytics

Google Analytics – Google Analytics is a web analytics service. It tracks and reports website traffic. Google may use the data collected to contextualize and personalize the ads of its own advertising network. You can opt-out of Google Analytics by installing the Google Analytics opt-out browser add-on, which prevents ga.js, analytics.js, and dc.js from sharing information with Google Analytics about visit activity. Privacy Policy: https://policies.google.com/privacy

Ahrefs – Ahrefs analytics service. Privacy Policy: https://ahrefs.com/legal/privacy-policy

Payments

We provide paid products and/or services within the Service. We use third-party services for payment processing. We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover.

Stripe – Privacy Policy: https://stripe.com/us/privacy

GDPR Privacy

Legal Basis for Processing Personal Data

We may process Personal Data under the following conditions:

Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You.
Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
Public interests: Processing Personal Data is related to a task that is carried out in the public interest.
Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

The Company is happy to clarify the specific legal basis that applies to the processing upon request.

Your Rights Under the GDPR

If You are a resident of the European Economic Area, You have certain data protection rights. The Company aims to take reasonable steps to allow You to correct, amend, delete, or limit the use of Your Personal Data.

Right to access, update or delete: You have the right to access, update or request deletion of Your Personal Data.
Right of rectification: You have the right to have Your information corrected if it is inaccurate or incomplete.
Right to restriction: You have the right to request that We restrict the processing of Your Personal Data.
Right to object: You have the right to object to Our processing of Your Personal Data where We are relying on legitimate interests or direct marketing.
Right to erasure: You have the right to request that We erase Your Personal Data when there is no good reason for Us to continue processing it.
Right to data portability: You have the right to receive a copy of the information We hold about You in a structured, commonly used, machine-readable format.
Right to withdraw consent: You have the right to withdraw Your consent at any time where the Company relied on Your consent to process Your Personal Data.

You can exercise these rights by contacting Us. We will respond within one month, extendable by two additional months. You also have the right to complain to a Data Protection Authority in the European Economic Area.

CCPA/CPRA Privacy Notice (California Residents)

Categories of Personal Information Collected

We have collected the following categories of personal information in the past twelve (12) months:

Category A – Identifiers: real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, and similar identifiers. Collected: Yes
Category B – California Customer Records: name, signature, address, telephone number, financial information. Collected: Yes
Category C – Protected Classifications: age, race, color, ancestry, national origin, citizenship, religion, marital status, medical conditions, disabilities, sex, gender identity, sexual orientation, veteran/military status. Collected: No
Category D – Commercial Information: records of products or services purchased, obtained, or considered. Collected: Yes
Category E – Biometric Information: genetic, physiological, behavioral, and biological characteristics. Collected: No
Category F – Internet or Network Activity: browsing history, search history, interaction with websites and advertisements. Collected: Yes
Category G – Geolocation Data: approximate physical location. Collected: No
Category H – Sensory Data: audio, electronic, visual, thermal, olfactory, or similar information. Collected: No
Category I – Professional/Employment Information: current or past job history or performance evaluations. Collected: No
Category J – Non-Public Education Information: education records as defined by FERPA. Collected: No
Category K – Inferences: profiles reflecting preferences, characteristics, behavior, or attitudes. Collected: No
Category L – Sensitive Personal Information: government-issued IDs, financial accounts with credentials, precise geolocation, race/ethnicity, religious/philosophical beliefs. Collected: No

Sources of Personal Information

Directly from You (registration forms, preferences, purchases)
Indirectly from You (observing Your activity on our Service)
Automatically from You (cookies, device tracking)
From Service Providers (analytics, payment processors, third-party vendors)

Use of Personal Information for Business Purposes

Service operation and provision
Customer support and inquiry response
Fulfilling user requests
Law enforcement compliance
Internal administrative and auditing purposes
Security incident detection and malicious activity protection
Purposes consistent with the context of collection

Disclosure of Personal Information

In the past 12 months, We have disclosed the following categories of personal information for a business purpose:

Category A – Identifiers
Category B – California Customer Records
Category D – Commercial Information
Category F – Internet or Network Activity

Sale of Personal Information

We do not sell personal information in the traditional sense (no direct exchange for monetary consideration). However, Service Providers may use personal information for advertising, marketing, analytics, and cross-context behavioral advertising, which may constitute "sales" or "sharing" under CCPA/CPRA.

Your Rights Under CCPA/CPRA

Right to Notice: Notification of categories of personal information collected and the purposes for collection.
Right to Know / Access: Request disclosure of categories collected, sources, business purposes, third-party recipients, and specific pieces of personal information collected.
Right to Opt-Out: Direct Us not to "sell" Your personal information.
Right to Correct: Request correction of inaccurate personal information.
Right to Limit Use and Disclosure: Limit use of sensitive personal information to purposes necessary for providing the Service.
Right to Delete: Request deletion of Your personal information, subject to certain legal exceptions.
Right Against Discrimination: Not be discriminated against for exercising any of Your rights.

To exercise these rights, contact Us via email at [email protected] or via Our website at https://incode-group.com. We will respond within 45 days (extendable by an additional 45 days). Information provided covers the 12-month period preceding the request.

Do Not Sell or Share My Personal Data

You may opt-out of the "sale" of your personal information and interest-based advertising. On our Website, click "Privacy Preferences", "Update Privacy Preferences", or "Do Not Sell or Share My Personal Information" buttons. You may also opt out via third-party platforms:

On mobile devices: Android – "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization"; iOS – "Limit Ad Tracking". Note that opting out is browser-specific and must be repeated for each browser.

Do Not Track Policy

Our Service does not respond to Do Not Track signals. However, some third-party websites do keep track of Your browsing activities. You can enable or disable Do Not Track via Your web browser preferences.

California Privacy Rights (Shine the Light Law)

Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes. To make such a request, please contact Us using the information provided below.

California Privacy Rights for Minor Users

California Business and Professions Code Section 22581 allows California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted. To request removal, contact Us with the associated email address. Note that removal is not guaranteed in all circumstances, and the law may not require or permit removal in certain cases.

Children's Privacy

Our Service does not address anyone under the age of 16. We do not knowingly collect personally identifiable information from anyone under the age of 16. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 16 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to This Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page and, where appropriate, notifying You via email and/or a prominent notice on Our Service prior to the change becoming effective. The "Last updated" date at the top of this Privacy Policy will be revised accordingly. You are advised to review this Privacy Policy periodically for any changes.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

By email: [email protected]
By visiting: https://incode-group.com