BLINK PRIVACY POLICY

BLINK Global, LLC (“BLINK”, “us” or “we”) recognizes that you, as a user of our website(s) (“Website”) or a BLINK service (“Service”), value your privacy.  This Privacy Policy explains how and why we collect and use the personal information you provide to BLINK.  Personal information includes data such as: your name, address, telephone number, email address, and other data collected that could directly or indirectly identify you (“Personal Information”).

For ease of reference, this Privacy Policy is separated as follows:

  • Website User
  • Service Users
  • General Privacy Conditions – All Users

Each section details important information regarding the use and disclosure of your Personal Information in conjunction with how you’ve chosen to interact with us, as well as options we make available to you to update, access, or otherwise take control of the Personal Information you provide to BLINK.

If, at any time, you have any questions about this Privacy Policy, or you wish to discuss your rights as described herein, please reach out to us at privacy@bl.ink, and our dedicated team will be happy to provide you with support.

1)  WEBSITE USERS (Cookie Policy)

INFORMATION WE COLLECT

We collect information you provide to BLINK when choosing to participate in various activities on the Website.  Such information may, or may not, include Personal Information.

WEBSITE USERS INFORMATION

If you submit Personal Information to us through the Website, then we may use it to operate, maintain, and provide to you the features and functionality of the Website, including, when applicable, sending you information.

Personal Information or other content that you voluntarily disclose online (on discussion boards, in messages and chat areas) may become publicly available and can be collected and used by others, including BLINK, without any additional permission.  We may use your email address to send commercial, marketing, or other messages regarding the Website or our Services without additional consent.  We may share non-personally-identifiable information (such as anonymous user usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with third parties to assist us in understanding the usage patterns for certain content, services, advertisements, promotions, and/or functionality on the Website.  We may disclose Personal Information and/or non-personally-identifiable information if required to do so by law, or in the good faith belief that such action is necessary to comply with state and federal laws or respond to a court order, subpoena, or search warrant.  BLINK reserves the right to disclose Personal Information and/or non-personally-identifiable information that BLINK believes, in good faith, is appropriate or necessary to take precautions against liability, to investigate and defend itself against any third party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of our Website, to protect the rights, property, or personal safety of BLINK, our users or others, and to protect the rights, property, or personal safety of BLINK, our users or others.

COOKIES / LOG FILES

We may use both your Personal Information and certain non-personally-identifiable information (such as anonymous user usage data, cookies, IP addresses, browser type, click stream data, etc.) to improve the quality and design of the Website and to create new features, promotions, functionality, and Services by storing, tracking, and analyzing user preferences and trends.  We may use and disclose to trusted third parties cookies and log file information to: (a) monitor the effectiveness of our marketing campaigns; and (b) monitor aggregate metrics such as total number of visitors, pages viewed, etc.

COOKIE NAME

CaptureSession Is a random hash value that we use to identify visitors and logged in users of our software.

_jsuid Is a random number used for site analytics to see how visitors interact with the site to enhance the service we provide.

first_pv_66469927 A session cookie that is set on the very first visit to a page on our site. Its purpose is so that certain parts of the site analytics code only fire on the first page view, making it faster and more efficient.

clicky_olark A session cookie that works with chat software in combination with our site analytics software in order to initiate the chat.

_ok Cookie used by chat software to provide a real-time chat service with customer service representative.

_okac Cookie used by chat software to provide a real-time chat service with customer service representative.

_okbk Cookie used by chat software to provide a real-time chat service with customer service representative.g

_okla Cookie used by chat software to provide a real-time chat service with customer service representative.

_oklv Cookie used by chat software to provide a real-time chat service with customer service representative.

hblid Cookie used by chat software to provide a real-time chat service with customer service representative.

olfsk Cookie used by chat software to provide a real-time chat service with customer service representative.

omp__super_properties Cookie used by chat software to provide a real-time chat service with customer service representative.

wcsid Cookie used by chat software to provide a real-time chat service with customer service representative.

BLINK utilizes captivating messages across the web to effectively communicate how our Services are capturing data and managing, monitoring and measuring web links.  Third-parties, including Google, communicate that message on sites across the Internet, and use cookies to deliver our captivating messages based on first time or return visits to our website.  For more information on how visitors can opt out of this use of cookies can visit Google’s Ads Settings, or other third party’s Network Advertising Initiative opt-out page.

MANAGING COOKIES

Within your browser you can choose whether you wish to accept cookies or not. Different browsers make different controls available to you and so we provide links below to popular manufacturers’ instructions on how you can do this. Generally, your browser will offer you the choice to accept, refuse or delete cookies at all times, or those from providers that website owners use (“third party cookies”), or those from specific websites. Our cookies are set to expire after 30 days unless indicated. Should you wish to manage cookies from within your browser, the following links will aid you to make the necessary settings changes to some of the most widely used browsers:

Your use of the Website constitutes your agreement to this Privacy Policy and any future revisions.

DATA SUBJECT REQUESTS

Should you, as a Website user, believe the data provided through the Website, and held by us, is inaccurate and requires rectification, BLINK shall, when notified, make all necessary and timely attempts to update and correct such an identified inaccuracy.

BLINK Service Users / Account Holders

GENERAL ACCOUNT INFORMATION

BLINK ordinarily asks that you to provide us with information required for the proper maintenance and administration of your user account(s) with us.  Such information is necessary for ensuring the proper administration of your account(s) (including contact email and telephone number) and for ease of contacting you in relation to your account(s) and Services.

BILLING INFORMATION / PAYMENT DETAILS

Information necessary for collecting payment for the Services and products that you purchase or obtain from us is also collected and processed.  BLINK does not directly process any payments; we use a 3rd party providers to process any payments on our behalf.

DATA NECESSARY FOR THE SPECIFIC PRODUCT/SERVICE OBTAINED BY YOU

Depending on the Service you obtain, we may need additional information, or to use your data in another manner specific and necessary to that Service.  Please refer to the individual product/Service sections below.

2)     BLINK SERVICE USERS / ACCOUNT HOLDERS

BLINK, acting as Data Controller, collects information necessary to provide Services to our customers, including email address and contact details.  We collect and store your email address when you sign up and use this to communicate with you about account services, updates, and news from BLINK.

CUSTOMER USE OF BLINK SERVICES

When a customer uses a BLINK Service, we are acting as data processor.  Customers are required to abide by the terms of this Privacy Policy and shall comply with all applicable laws, policies, and regulations relating to the collection of data.

IMPORTANT NOTE: Where required by applicable rules, law or regulations, Service users must post a suitable privacy policy which must provide adequate notice, where necessary, of their use of cookies which are used to collect data, via any use of the BLINK service.

URL INFORMATION

At the core of BLINK’s services is the creation of a shortened link to websites (“Links”), as specified by You.  When you create such a Link, on your instructions, we collect and store the following:

  • The original URL and the shortened URL.
  • Your IP address
  • The time and date on which you shortened the original URL
  • Which user (as per your account) carried out the action.

When you share your shortened URL via the platform, we also shall store the information on the channels (such as Facebook and Twitter) through which the BLINK Link was shared.

METRICS AND ANALYTICS

BLINK collects information about accesses (such as clicks) of every shortened link created through our services. This information includes, but is not limited to:

  • the IP address and corresponding registered location of the devices accessing the created Link (limited to country and city only);
  • any referring websites or services; and
  • the time and date of each access and the browers and language preferences.

This information is used by BLINK and its partners to provide your chosen Services. We also use this information to further improve Service and products available to you.

INFORMATION COLLECTED FROM THIRD PARTY SERVICES

Some features of the Services allow you to share your content and created Links through your accounts with other companies such as Facebook and Twitter.  If you choose to connect BLINK to such third party services, we may collect information related to your use of those third party services, such as authentication tokens that allow us to connect to your third party services accounts.  We will ask you for permission before you authorize our collection of this information.  We will only use that information for the specific reason for which it was provided to us.  We may also collect information about how you are using the Services to interact with connected third party services.  Note that third party services may have the ability to restrict the information that is provided to us based on your privacy settings of that account.

INFORMATION COLLECTED AUTOMATICALLY

BLINK automatically receives and records information from your web browser when you interact with the Services (including creating or clicking on Links), such as your IP address, browser type, your general location and cookie information. This information may be used to help us understand how users transit a website, to fight spam/malware, to facilitate collection of data concerning your interaction with the Services (e.g., what BLINK Links you have clicked on) and for other similar purposes.

BLINK also automatically receives and records information that your mobile device transmits when you access the Services, like a device identifier, device settings, and operating system. This information is used to facilitate your access and use of the Services, to access and use other Third Party Services, and for other similar purposes.

Generally, the Services automatically collect website usage information, such as the number and frequency of visitors to the Site.  BLINK may use this data in aggregate form, that is, as a statistical measure.  This type of aggregate data enables us and third parties authorized by us to figure out how often individuals use parts of the website so that we can analyze and improve them.

We will collect information about your general location (such as your city and state, which is derived from your IP address) when you visit the Website or use the Services, such as by clicking a Link and we may use various technologies to determine your location (if you enable this feature), when you access and use the Services through a mobile device.

We may receive a confirmation when you open an email from us. We use this confirmation to improve our customer service.

COOKIES INCLUDED IN BLINK PROVIDED LINKS

We collect http header information and remote IP addresses as available.  This information is limited to the publicly provided details as available from any web server logs.  BLINK’s services ordinarily require the use of cookies. Such cookies allow BLINK, on behalf of our service users, to track the various clicks on a created Link as provided by BLINK.  Each click of a Link is tracked using a unique identifier assigned to you in one or more cookies stored by your web browser and associated with BLINK. We may associate the unique identifier in our cookies with the other information we automatically collect when you use the Services, as described above, including your IP address, created Links you click, Links you create, and information regarding your Account if you have one.

Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. If you disable cookies, you will not be able to use some features of the Services.  BLINK cookies are set to automatically expire after 6 months from when they are set.

You may also ask BLINK not to place cookies on your web browser. When cookies are disabled in this manner, clicks on BLINK Links are not tied back to or associated with your web browser.  However, we will still automatically collect the IP addresses of computers or mobile devices that click on or create BLINK Links.

DOMAIN NAME REGISTRATION SERVICES

Before registering a domain name you must familiarize yourself with this Privacy Policy and we urge you to raise any queries with us prior to proceeding with your registration(s).

ROLES OF THE INVOLVED PARTIES

In the domain registration process, a number of parties, are necessarily involved to register your chose domain:

BLINK (RESELLER)

We collect and processes Registrant Data (defined below) to enable you to register a domain.  In this instance, BLINK is acting as a data processor, responsible for the following:

  • collection of registration data;
  • providing you notice and an opportunity to review both our Privacy Policy, the privacy policy of the relevant registrar and registry;
  • providing you with adequate information and a means by which you may exercise your individual privacy rights, such as data access, deletion, and rectification; and
  • this Privacy Policy sets out, in detail, both the purposes and the legal basis for our data processing.

REGISTRAR

With specific reference to the registration of a domain name, BLINK has entered into an agreement with Name.com to act as the registrar, the data controller, which is responsible for escrowing your Registrant Data and passing your Registrant Data to the registry as required by its contracts with ICANN and the applicable registry.

REGISTRY OPERATOR

A registry operator, as a joint data controller, will receive your Registrant Data from the registrar and is responsible for the processing of data necessary for the registration and maintenance of domains within one of their top-level domains (“TLD”).  This includes escrowing of your Registrant Data as required by ICANN.

CHOICE OF REGISTRY: You should only choose a TLD with whom you feel comfortable sharing your information. It is important that you familiarize yourself with and understand the individual and specific privacy policy of the registry who is responsible for the TLD of your choice. See the list of specific privacy policies that relate to each TLD here. If you do not understand such policies, or you have questions regarding any of their policies, you should discuss this with the registry operator of your chosen domain, prior to registering via our service.

ICANN

The Internet Corporation for Assigned Names and Numbers (“ICANN”) is the private-sector body responsible for coordinating the global Internet’s systems of unique identifiers.  The mission of ICANN is to coordinate the stable operation of the Internet’s unique identifier systems.  More information about ICANN can be found here: www.icann.org.  ICANN is responsible for identifying and requiring, by contract, both registry operators and registrars to provide to them registration data.  Registrant Data we collect and process is data which ICANN deems necessary to ensure the ongoing security and stability of the DNS. ICANN is also considered to be a joint data controller with regards to the collection, processing and publication of Registrant Data.

DOMAIN REGISTRANT DATA

BLINK is a reseller of Name.com is required by contract, to collect data relating to the registration of domain names (“Registrant Data”) and then share such data with Name.com, who in turn shares it with the relevant registry operator (depending on the TLD you wish to register).  The sharing and use of this data is required by our Reseller Agreement with Name.com and in turn as per the terms of their Registrar Accreditation Agreement with ICANN, and for each TLD’s Registry Agreement with ICANN, for the proper registration of your domain name.

To provide you with domain name registration Services, we typically require the following registrant data (“Registrant Data”):

  • Domain Name
  • Nameservers
  • Registration Data
  • Registrant Name
  • Registrant Organization
  • Registrant Address
  • Registrant Email
  • Registrant Fax
  • Registrant Phone number
  • Administrative Contact
  • Administrative Contact Organization
  • Administrative Contact Address
  • Administrative Contact Email
  • Administrative Contact Fax
  • Administrative Contact Telephone Number
  • Technical Contact
  • Technical Contact Organization
  • Technical Contact Address
  • Technical Contact Email
  • Technical Contact Fax
  • Technical Contact Telephone Number
  • Billing Contact
  • Billing Contact Organization
  • Billing Contact Address
  • Billing Contact Email
  • Billing Contact Fax
  • Billing Contact Telephone Number

NOTE: Specific data collections may vary based on the TLD’s specific requirements as promulgated by its registry operator.

For clarity, Registration Data are in the format as specified by ICANN (compatible with the relevant technical standards as stated in the IETFs RFCs).  This ensures that all Registration Data, in our system is held in a form that is easily transferable from one registrar to another (following stated transfer processes dictated by ICANN).

PURPOSE / LEGAL BASIS FOR PROCESSING

We use your Registrant Data for the following purposes:

  • to register the domain name;
  • to enable Name.com to provide the applicable registry with authoritative data to ensure the ongoing continuity, stability and resiliency of the DNS;
  • to enable our ongoing mitigation of DNS abuse, including but not limited to the investigation and mitigation of reported instances of abuse to BLINK as a reseller of Name.com, and as are considered to be contrary to the terms of Name.com’s Acceptable Use Policy and the Acceptable Use policy of the relevant Registry Operator;
  • maintained integrity of the current dual failsafe system at the registrar and registry levels;
  • verification of registrant eligibility, where applicable; and
  • to update and improve our Services, systems and ability to provide you with a secure and stable Service experience.

OTHER WAYS WE USE YOUR INFORMATION

First and foremost, BLINK uses your Registration Data to arrange your registration and supported functionality of your domain(s) with the Registrar and Registry operator.  Additionally, BLINK may use Registrant Data to (i) improve our Services, promotions and functionality, (ii) develop and collect aggregate statistics (ensuring appropriate anonymization) regarding our systems and Services; and (iii) communicate with you regarding your registration or related Services.

DISCLOSURE OF DATA

There are instances where BLINK may have to disclose your Personal Information.  At all times however, such disclosure shall be limited and subject to the required safeguards.

EXCEPTIONS TO DISCLOSURE LIMITATIONS

BLINK limit its disclosure of your Personal Information to the terms of this Privacy Policy.  There are however times where we may disclose information.  Such instances are limited to the following permitted disclosures:

  • necessary to fulfill a transaction or provide information you have requested;
  • in your vital interests or in the vital interests of another person, including events of an emergency that poses a threat to your safety;
  • required by ICANN;
  • required by law or necessary to respond to legal process;
  • in circumstances in which BLINK believes that its websites, domain names, or Services are being used in the commission of a crime;
  • necessary to enforce our Acceptable Use Policy, and to protect the security or integrity of the BLINK service, the DNS, or our Website;
  • as necessary to establish, assert, defend, or protect our rights or property; or
  • as necessary to meet the requirements of requests, lawfully made by public authorities, including requests to meet national security or law enforcement requirements.

WHOIS

Registrant Data required to register a domain will be provided to Name.com, who as registrar in turn is required by its contracts with ICANN, to make certain data available to the public via an interactive webpage and via a “port 43” WHOIS service (together, “WHOIS”).  Similarly, Name.com as the registrar may pass your Registrant Data on to the applicable registry which may be required by its contracts with ICANN, to make certain data available to the public via their WHOIS service.

THIRD PARTIES PROCESSING DATA ON OUR BEHALF

We ordinarily require that third parties receiving data agree, by way of a written agreement, to process such information in compliance with this Privacy Policy.  BLINK will use reasonable efforts to limit any third party’s use of such information in compliance with applicable data privacy laws.

3)     GENERAL PRIVACY CONDITIONS ALL USERS

FAMILY OF COMPANIES

BLINK is a part of the Donuts Inc. family of companies (the “Family of Companies”).  As part of the Family of Companies, we may share information we have about you within the Family of Companies.  Such sharing however shall be strictly limited in use. We will only share information about you to such members of the Family of Companies to facilitate, support and integrate their activities in a manner that is consistent with, and related to, the original stated use of the information, as explained to you upon collection, and to improve the provision of our services to you.

The Family of Companies includes the following companies: Dozen Donuts, LLC; Rightside Group, Ltd; Nametrust, LLC; Rightside Operating Co.; Domain Protection Services, Inc. Name.com, Inc.;  Name.net, Inc.; Name104, Inc.; Name105, Inc.; Name106, Inc.; Name107, Inc.; Name108, Inc.; Name109, Inc.; Name110, Inc.; Name111, Inc.; Name112, Inc.; Name113, Inc.; Name114, Inc.; Name115, Inc.; Name116, Inc.; Name117; Name118, Inc.; Name119, Inc.; Name120, Inc.; Mobile Name Services Incorporated; Sipence, Incorporated; Vedacore.com, Inc.; Binky Moon, LLC; Corn Lake, LLC; Dog Beach, LLC; John Island, LLC; Pixie North, LLC; BLINK Global LLC.  The Family of Companies also includes the following non-U.S. based companies: BLINK (HK) Limited; Capable Network Technology (Shanghai) Co., Ltd.; Rightside Domains Europe Limited; Name.com Canada Corp; Hot Media Inc, Acquire This Name, Inc.; and Rightside Canada Inc.

INFORMATION SECURITY

BLINK has physical, electronic, and managerial procedures to help safeguard, prevent unauthorized access, maintain data security, and correctly use your Personal and non‑personal information.  To that extent, we employ security measures that are deemed commensurate to the quality of data held, with due regard to the state of the art and cost of the available security measures, and the risk to the privacy rights of you, as data subject.  We do not, nor can we, guarantee security.  Neither people nor security systems are foolproof, including encryption systems.

DATA BREACHES

Where a breach occurs, BLINK shall, upon discovering such a breach, ensure that our obligations are met under applicable data privacy requirements, and with specific acknowledgement of Articles 33 and 34 of the GDPR, where applicable.

RETENTION OF DATA

BLINK does not retain any Personal Information for longer than is necessary.

CREATED LINK DATA

At all times BLINK service users have the ability to delete the data associated with the Link that they have created. Where the service user does not delete that data, BLINK shall delete account data after a reasonable period (generally 6 years after the closure of the account, so as to protect or prepare BLINK against any legal action)

REGISTRANT DATA

Where the registry is investigating or has taken action relating to a specific domain or domains, which have been flagged or confirmed as engaged in abusive behaviors (as per BLINK Acceptable Use Policy) we will ordinarily retain such data until such a time that such data is no longer necessary to defend against current or possible future suit(s).  This period depends on limitation periods applicable, however should ordinarily be no longer than six (6) years.

COOKIE DATA

See Section on Website Users.

NOTE REGARDING SENSITIVE PERSONAL INFORMATION

“Sensitive Personal Information” refers to personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying sex life of the individual.  BLINK does not ordinarily or knowingly require or collect Sensitive Personal information.  Where such collecting is required, we will not disclose such information with third parties without your consent.

NOTE REGARDING CHILDREN (under 18 years of age)

Please note that we do not knowingly permit or solicit information from individuals under eighteen (18) years of age. In addition, we do not knowingly market Services to individuals under eighteen (18) years of age.

DATA SUBJECT RIGHTS

ACCESS TO PERSONAL INFORMATION

Where applicable, you have the right to obtain from us a confirmation as to whether or not Personal Information concerning you is processed by us.  In addition, where such processing is confirmed, and you request it, we will arrange access to the Personal Information along with the following information:

  • the categories of Personal Information collected and processed;
  • the recipients or categories of recipients to whom the Personal Information has been or will be disclosed, in particular recipients in third countries (outside of the European Economic Area (“EEA”) or international organizations;
  • the period for which the Personal Information will be stored, or, if not possible to be determined, the criteria used to determine that period;
  • the existence of the right to request from us, rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
  • the right to lodge a complaint with a supervisory authority;
  • where Personal Information was not collected directly from the you, any available information as to its source;
  • the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
  • Where your Personal Information is transferred to a third country, you also have the right to be informed of the appropriate safeguards we have put in place pursuant to Article 46 of the GDPR relating to the transfer.

COPIES OF THE DATA

BLINK may provide, where requested, a copy of that data, relating to you, which are being processed, subject to the restrictions as noted in Article 23 of the GDPR.

RECTIFICATION

All Personal Information held by us, is as disclosed to us by you. To view or change this information, you should log in to your account. When you update information, we usually keep a copy of the prior version for our records. If this is deemed insufficient, or you are experiencing any difficulties in making the required updates, please contact us.

DELETION/ERASURE

Where you, as the data subject, wish the erasure of your Personal Information, BLINK will fulfill your request should one of the following grounds apply:

  • the Personal Information is no longer necessary in relation to the purposes for which it was collected or otherwise processed, e.g. the provision of our Services;
  • where processing is based solely upon your required consent, and you withdraw this consent on which the processing is based;
  • where you object to the processing, and where there are no overriding legitimate grounds for the processing;
  • where you can demonstrate that the Personal Information has been unlawfully processed;
  • where you provide notice that the Personal Information must be erased for compliance with a legal obligation as contained in a stated Union or Member State law to which the controller is subject; or
  • where BLINK is unable to demonstrate proper reliance on an exception under 17 (3) of the GDPR.

RIGHT TO BE FORGOTTEN

Where BLINK has publicly disclosed your data and where you have made a valid request to erase your Personal Information, BLINK will, taking into account the available technology and the cost of implementation, take reasonable steps, including technical measures, to inform any controllers which are processing that personal data, of your request for erasure.

DATA PORTABILITY

BLINK shall provide an ability for any client to obtain a copy of all data within their account regarding any created Links, save such data which has been erased by you as a Service user.

CHANGES AND UPDATES TO THIS PRIVACY POLICY

This Privacy Policy may be revised periodically and this will be reflected by the date below.  Please revisit this page to stay aware of any changes..

SPECIAL NOTES FOR INTERNATIONAL USERS

FOR EUROPEAN UNION & SWISS CITIZENS

Transfer of data outside of the European Economic Area (“EEA”) – BLINK is a US registered entity, and all our primary servers are located within the USA.  Your choice to use of our Services may involve the transfer of data outside of the EEA.

PRIVACY SHIELD FRAMEWORKS

As a member of the Donuts Family of Companies, BLINK complies with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland transferred to the United States pursuant to Privacy Shield. We have certified that we adhere to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this Policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

Note that you have the right to access, correct, delete, and limit the use and disclosure of your Personal Information processed by us. For assistance with accessing, correcting, or deleting your personal data, please contact us at privacy@bl.ink. Please be aware that deleting your Personal Information may result in termination of the services you receive through us.

BLINK’s accountability for the personal data that it receives under the Privacy Shield, and subsequently transfers to a third party, is described in the Privacy Shield Principles. In particular, we remain responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless BLINK proves that it is not responsible for the event giving rise to the damage.

In compliance with the Privacy Shield Principles, We commit to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this Policy should first contact our Legal Department at privacy@bl.ink or by certified mail (return receipt requested) at:

BLINK Inc., c/o Donuts Inc., Attn: Legal Department, 5808 Lake Washington Blvd NE, Suite 300, Kirkland, WA 98033 USA.

We have further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers  for more information and to file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction

Note that the US Federal Trade Commission has enforcement authority over our compliance with this Policy.

CONTACT US

If you have any questions, concerns or complaints about our Privacy Policy and how it related to our products and services, you may contact us by email at privacy@bl.ink or by mail to one of the following addresses:

BLINK
c/o Donuts Inc.
ATTN: Data Privacy Section, Legal Department
5808 Lake Washington Blvd NE
Suite 300
Kirkland, WA 98033
USA

Or for customers established in the EEA:

BLINK
c/o Donuts Inc.
ATTN: Data Privacy Section, Legal Department
Suite 106
The Victorians
15-18 Earlsfort Terrace
Dublin 2, County Dublin
Ireland

If you are a resident of the EEA and believe we maintain your personal data subject to the General Data Protection Regulation, you may direct questions or complaints to our lead supervisory authority, the Office of the Data Protection Commissioner, as noted below:

Office of the Data Protection Commissioner.

Canal House, Station Road, Portarlington, Co. Laois, R32 AP23, Ireland.

Phone +353 (0761) 104 800 | LoCall 1890 25 22 31 | Fax +353 57 868 4757 Email info@dataprotection.ie