Effective date: July 12, 2018
Link-up Holdings Pty Ltd. (“us”, “we”, or “our”) operates the https://app.instinctivedrives.com/
website and I.D. Connect by Instinctive Drives app (the “Service”).
This page informs you of our policies regarding the collection, use, and disclosure of personal
data when you use our Service and the choices you have associated with that data.
We use your data to provide and improve the Service. By using the Service, you agree to the
collection and use of information in accordance with this policy. Unless otherwise defined in
and Conditions, accessible from https://app.instinctivedrives.com/
Service is the https://app.instinctivedrives.com/ website and I.D. Connect by Instinctive Drives
app operated by Link-up Holdings Pty Ltd.
Personal Data means data about a living individual who can be identified from those data (or
from those and other information either in our possession or likely to come into our
Usage Data is data collected automatically either generated by the use of the Service or from
the Service infrastructure itself (for example, the duration of a page visit).
Cookies are small pieces of data stored on your device (computer or mobile device).
Data Controller means the natural or legal person who (either alone or jointly or in common
with other persons) determines the purposes for which and the manner in which any personal
information are, or are to be, processed.
Data Processors (or Service Providers)
Data Processor (or Service Provider) means any natural or legal person who processes the data
on behalf of the Data Controller.
We may use the services of various Service Providers in order to process your data more
Data Subject (or User)
Data Subject is any living individual who is using our Service and is the subject of Personal Data.
Information Collection and Use
We collect several different types of information for various purposes to provide and improve
our Service to you.
Types of Data Collected
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
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• 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 or instructions
provided in any email we send.
We may also collect information how the Service is accessed and used (“Usage Data”). This
Usage Data may include information such as your computer’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
We may use and store information about your location if you give us permission to do so
(“Location Data”). We use this data to provide features of our Service, to improve and
customize our Service.
You can enable or disable location services when you use our Service at any time, through your
Tracking & Cookies Data
Cookies are files with small amount of data which may include an anonymous unique identifier.
Cookies are sent to your browser from a website and stored on your device. Tracking
technologies also used are beacons, tags, and scripts to collect and track information and to
improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent.
However, if you do not accept cookies, you may not be able to use some portions of our
Examples of Cookies we use:
• Session Cookies. We use Session Cookies to operate our Service.
• Preference Cookies. We use Preference Cookies to remember your preferences and
• Security Cookies. We use Security Cookies for security purposes.
Use of Data
Link-up Holdings Pty Ltd. uses the collected data for various purposes:
• To provide and maintain our Service
• To notify you about changes to our Service
• To allow you to participate in interactive features of our Service when you choose to do
• To provide customer support
• To gather analysis or valuable information so that we can improve our Service
• To monitor the usage of our Service
• To detect, prevent and address technical issues
• To provide you with news, special offers and general information about other goods,
services and events which we offer that are similar to those that you have already
purchased or enquired about unless you have opted not to receive such information
Legal Basis for Processing Personal Data Under General
Data Protection Regulation (GDPR)
If you are from the European Economic Area (EEA), Link-up Holdings Pty Ltd. legal basis for
Personal Data we collect and the specific context in which we collect it.
Link-up Holdings Pty Ltd. may process your Personal Data because:
• We need to perform a contract with you
• You have given us permission to do so
• The processing is in our legitimate interests and it’s not overridden by your rights
• For payment processing purposes
• To comply with the law
Retention of Data
Link-up Holdings Pty Ltd. will retain your Personal Data only for as long as is necessary for the
necessary to comply with our legal obligations (for example, if we are required to retain your
data to comply with applicable laws), resolve disputes, and enforce our legal agreements and
Link-up Holdings Pty Ltd. will also retain Usage Data for internal analysis purposes. Usage Data
is generally retained for a shorter period of time, except when this data is used to strengthen
the security or to improve the functionality of our Service, or we are legally obligated to retain
this data for longer time periods.
Transfer of Data
Your information, including Personal Data, 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 than those from your jurisdiction.
If you are located outside Australia and choose to provide information to us, please note that
we transfer the data, including Personal Data, to Australia and process it there.
your agreement to that transfer.
Link-up Holdings Pty Ltd. will take all steps reasonably necessary to ensure that your data is
Data will take place to an organization or a country unless there are adequate controls in place
including the security of your data and other personal information.
Disclosure of Data
If Link-up Holdings Pty Ltd. 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
Disclosure for Law Enforcement
Under certain circumstances, Link-up Holdings Pty Ltd. 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).
Link-up Holdings Pty Ltd. may disclose your Personal Data in the good faith belief that such
action is necessary to:
• To comply with a legal obligation
• To protect and defend the rights or property of Link-up Holdings Pty Ltd.
• To prevent or investigate possible wrongdoing in connection with the Service
• To protect the personal safety of users of the Service or the public
• To protect against legal liability
Security of Data
The security of your 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
Your Data Protection Rights Under General Data
Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection
rights. Link-up Holdings Pty Ltd. aims to take reasonable steps to allow you to correct, amend,
delete, or limit the use of your Personal Data.
If you wish to be informed what Personal Data we hold about you and if you want it to be
removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
• The right to access, update or to delete the information we have on you. Whenever
made possible, you can access, update or request deletion of your Personal Data directly
within your account settings section. If you are unable to perform these actions
yourself, please contact us to assist you.
• The right of rectification. You have the right to have your information rectified if that
information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your Personal Data.
• The right of restriction. You have the right to request that we restrict the processing of
your personal information.
• The right to data portability. You have the right to be provided with a copy of the
information we have on you in a structured, machine-readable and commonly used
• The right to withdraw consent. You also have the right to withdraw your consent at any
time where Link-up Holdings Pty Ltd. relied on your consent to process your personal
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of
your Personal Data. For more information, please contact your local data protection authority
in the European Economic Area (EEA).
We may employ third party companies and individuals to facilitate our Service (“Service
Providers”), to provide the Service on our behalf, to perform Service-related services or to assist
us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf
and are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers to monitor and analyze the use of our Service.
Google Analytics is a web analytics service offered by Google that tracks and reports website
traffic. Google uses the data collected to track and monitor the use of our Service. This data is
shared with other Google services. Google may use the collected data to contextualize and
personalize the ads of its own advertising network.
You can opt-out of having made your activity on the Service available to Google Analytics by
installing the Google Analytics opt-out browser add-on. The add-on prevents the Google
Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy &
Terms web page: https://policies.google.com/privacy?hl=en
We may provide paid products and/or services within the Service. In that case, we use thirdparty services for payment processing (e.g. payment processors).
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
managed by the PCI Security Standards Council, which is a joint effort of brands like Visa,
Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure
handling of payment information.
The payment processors we work with are:
Links to Other Sites
Our Service may contain links to other sites 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
We have no control over and assume no responsibility for the content, privacy policies or
practices of any third party sites or services.
Our Service does not address anyone under the age of 18 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of
18. 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 children without verification of parental consent, we take steps to remove that
information from our servers.
We will let you know via email and/or a prominent notice on our Service, prior to the change
By email: email@example.com
By visiting this page on our website: https://www.instinctivedrives.com/Installation-contact/
Privacy Notice for California Residents
Last updated on December 20, 2019
This Privacy Notice for California Residents supplements the information contained in Link-up
in the State of California. We adopted this notice to comply with the California Consumer
Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when
used in this notice.
1. Information We Collect
Our website collects information that identifies, relates to, describes, references, is capable of
being associated with, or could reasonably be linked, directly or indirectly, with a particular
consumer or device (personal information). In particular, our website has collected the
following categories of personal information from its consumers within the last twelve (12)
Category Examples Collected
A. Identifiers. A real name, alias, postal address, unique personal
identifier, online identifier, Internet Protocol
address, email address, account name, Social
Security number, driver license number, passport
number, or other similar identifiers.
categories listed in
A name, signature, Social Security number, physical
characteristics or description, address, telephone
number, passport number, driver license or state
identification card number, insurance policy
statute (Cal. Civ.
number, education, employment, employment
history, bank account number, credit card number,
debit card number, or any other financial
information, medical information, or health
Some personal information included in this category
may overlap with other categories.
under California or
Age (40 years or older), race, color, ancestry,
national origin, citizenship, religion or creed, marital
status, medical condition, physical or mental
disability, sex (including gender, gender identity,
gender expression, pregnancy or childbirth and
related medical conditions), sexual orientation,
veteran or military status, genetic information
(including familial genetic information).
Records of personal property, products or services
purchased, obtained, or considered, or other
purchasing or consuming histories or tendencies.
Genetic, physiological, behavioral, and biological
characteristics, or activity patterns used to extract a
template or other identifier or identifying
information, such as fingerprints, faceprints, and
voiceprints, iris or retina scans, keystroke, gait, or
other physical patterns, and sleep, health, or
F. Internet or other
Browsing history, search history, information on a
consumers interaction with a website, application,
G. Geolocation data. Physical location or movements. NO
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or
similar information. NO
I. Professional or
Current or past job history or performance
information (per the
Rights and Privacy
Act (20 U.S.C.
Section 1232g, 34
C.F.R. Part 99)).
Education records directly related to a student
maintained by an educational institution or party
acting on its behalf, such as grades, transcripts, class
lists, student schedules, student identification
codes, student financial information, or student
K. Inferences drawn
from other personal
Profile reflecting a person’s preferences,
characteristics, psychological trends,
predispositions, behavior, attitudes, intelligence,
abilities, and aptitudes.
Personal information does not include:
• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPAs scope, like certain health or medical information
and other categories of information protected by different laws.
We obtain the categories of personal information listed above from the following categories of
• Directly from you. For example, from forms you complete or products and services you
• Indirectly from you. For example, from observing your actions on our website.
2. Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following
• To fulfill or meet the reason you provided the information. For example, if you share your
name and contact information to request a price quote or ask a question about our
services, we will use that personal information to respond to your inquiry. If you provide
your personal information to purchase a product or service, we will use that information
to process your payment and facilitate delivery. We may also save your information to
facilitate new product orders or process returns.
• To process your requests, purchases, transactions, and payments and prevent
• To provide you with support and to respond to your inquiries, including to investigate and
address your concerns and monitor and improve our responses.
• To respond to law enforcement requests and as required by applicable law, court order,
or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth
in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution,
or other sale or transfer of some or all of our or our affiliates assets in which personal
information held by us or our affiliates about our website users is among the assets
We will not collect additional categories of personal information or use the personal
information we collect for materially different, unrelated, or incompatible purposes without
providing you notice.
3. Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we
disclose personal information for a business purpose, we enter a contract that describes the
purpose and requires the recipient to both keep that personal information confidential and not
use it for any purpose except performing the contract.
We share your personal information with the following categories of third parties:
• Service providers.
• Data Aggregators.
4. Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal
information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection
and use of your personal information over the past 12 months. Once we receive and confirm
your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights),
we will disclose to you:
• The categories of personal information we have collected about you.
• The categories of sources for the personal information we have collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we have collected about you (also called a
data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate
• sales, identifying the personal information categories that each category of
recipient purchased; and
• disclosures for a business purpose, identifying the personal information categories
that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected
from you and retained, subject to certain exceptions. Once we receive and confirm your
verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we
will delete (and direct our service providers to delete) your personal information from our
records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our
service provider(s) to:
• Complete the transaction for which we collected the personal information, provide a
good or service that you requested, take actions reasonably anticipated within the
context of our ongoing business relationship with you, or otherwise perform our contract
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal
activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code
• Enable solely internal uses that are reasonably aligned with consumer expectations based
on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the
context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a
verifiable consumer request to us by:
• Emailing us at DataPrivacyMgr@InstinctiveDrives.com
Only you, or a person registered with the California Secretary of State that you authorize to act
on your behalf, may make a verifiable consumer request related to your personal information.
You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a
12-month period. The verifiable consumer request must:
• Provide sufficient information that allows us to reasonably verify you are the person
about whom we have collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand,
evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot
verify your identity or authority to make the request and confirm the personal information
relates to you.
Making a verifiable consumer request does not require you to create an account with us.
We will only use personal information provided in a verifiable consumer request to verify the
requestors identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its
receipt. If we require more time, we will inform you of the reason and extension period in
We will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable
consumer requests receipt. The response we provide will also explain the reasons we cannot
comply with a request, if applicable. For data portability requests, we will select a format to
provide your personal information that is readily useable and should allow you to transmit the
information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is
excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee,
we will tell you why we made that decision and provide you with a cost estimate before
completing your request.
Personal Information Sales
We will not sell your personal information to any party. If in the future, we anticipate selling
your personal information to any party, we will provide you with the opt-out and opt-in rights
required by the CCPA.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by
the CCPA, we will not:
• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting
discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different
level or quality of goods or services.
6. Other California Privacy Rights
California’s Shine the Light law (Civil Code Section 1798.83) permits users of our website that
are California residents to request certain information regarding our disclosure of personal
information to third parties for their direct marketing purposes. To make such a request, please
send an email to DataPrivacyMgr@InstinctiveDrives.com or write to us at Link-up Holdings Pty
Ltd., Attn: Data Privacy Manager, C/- Martini Akpovi Partners, 16830 Ventura Boulevard, Suite
#501, Encino CA 91436 California, 93401.
7. Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we
make changes to this privacy notice, we will post the updated notice on our website and update
the notices effective date. Your continued use of our website following the posting of changes
constitutes your acceptance of such changes.
8. Contact Information
If you have any questions or comments about this notice, the ways in which we collect and use
such use, or wish to exercise your rights under California law, please do not hesitate to contact