Privacy Policy

PRIVACY POLICY

Last Updated: December 8, 2025

LYBER S.R.L. ("Lyber", "we", "us", or "our") operates the Liink content recommendation and advertising technology (the "Service"). We are committed to protecting the privacy of our Partners ("Publishers") and the end-users ("Users") visiting websites where our technology is installed.

This Policy describes how we collect, use, process, and share information, including our use of Artificial Intelligence and Advertising technologies.

1. DATA CONTROLLER

The Data Controller for the processing of Partner Data and the aggregate controller for the technology is:
LYBER S.R.L.
VAT ID: 03245020601
Email: info@liink.ai

2. DATA COLLECTION AND SOURCES

We collect data from three distinct sources:

A. Partner Data (B2B)

Information collected when you register for a Liink Dashboard account:

  • Registration Data: Company name, business email, encrypted password, and contact details.

  • Billing Data: VAT number, billing address, and payment records (if using the Enterprise model).

  • Technical Logs: IP address, login timestamps, and user-agent of the device used to access the Dashboard.

B. End-User Data (AI & Recommendation)

Information collected automatically via the Liink widget script to provide content recommendations:

  • Contextual Data: URL of the page being visited, page title, content keywords, and category.

  • Behavioral Data: Time spent on page, scroll depth, clicks on recommendations, and mouse movements within the widget area.

  • Technical Data: Browser type, device type (Mobile/Desktop), Operating System, and screen resolution.

  • NO PII / NO IP Storage: We do not collect Names, Emails, Phone Numbers, or precise geolocation. User IP addresses are processed momentarily for security (bot detection) and coarse geolocation (country/city level) but are never stored permanently.

C. Advertising Data (Monetization)

As part of our "Free/Ad-Funded" model, we display third-party advertisements within the widget. Our Advertising Partners (SSPs, DSPs, Ad Networks) may collect:

  • Ad Interaction Data: Impressions, viewability metrics, and clicks on ads.

  • Tracking Technologies: Third-party cookies, beacons, and pixels used to measure ad performance, frequency capping (limiting how many times a user sees an ad), and fraud detection.

3. PURPOSES OF PROCESSING

We process data for the following specific purposes:

  1. Service Provision & AI: To analyze browsing context and deliver relevant content recommendations to Users using our proprietary AI algorithms.

  2. Advertising & Monetization: To display Native Advertising within the widget. This allows us to provide the Service for free to Publishers. We share technical signals (e.g., User Agent, coarse location) with Ad Partners to request and serve ads.

  3. Analytics: To generate aggregated performance reports (e.g., Recirculation Rate, Revenue) accessible via the Dashboard.

  4. Security & Fraud Prevention: To identify and block Invalid Traffic (IVT), bots, and malicious crawlers.

  5. Legal & Billing: To comply with tax obligations and manage the contractual relationship with the Partner.

4. LEGAL BASIS (GDPR)

  • For Partner Account Data: Performance of a Contract (Terms of Service).

  • For AI Recommendations: Legitimate Interest (improving user experience and recirculation).

  • For Advertising & Cookies: CONSENT. The storage of information (cookies) and access to information stored in the user's terminal equipment for advertising purposes requires the User's explicit consent.

    • Important Note: The Publisher (Partner) is responsible for obtaining this consent via their Consent Management Platform (CMP) before the Liink script loads advertising components.

5. DATA SHARING AND THIRD PARTIES

We do not sell Personal Data (PII). However, in the context of the Advertising Service, technical data may be shared with:

  1. Advertising Partners: We work with third-party Supply Side Platforms (SSPs) and Ad Exchanges to fill ad slots. These partners may act as independent Data Controllers.

  2. Service Providers (Processors):

    • Google Cloud Platform (GCP): For cloud hosting, database, and AI computation (Servers located in the EU).

    • Analytics Providers: For internal monitoring of system performance.


  4. Legal Authorities: If required by law or to protect our rights.

6. COOKIES AND TRACKING TECHNOLOGIES

The Liink widget may utilize the following technologies:

  • Functional Cookies/Storage: To maintain session continuity for recommendations (e.g., to avoid showing the same article twice).

  • Advertising Cookies (Third-Party): Dropped by our Ad Partners to track ad performance and attribution. These are subject to the privacy policies of the respective third parties.

7. INTERNATIONAL DATA TRANSFERS

Our primary infrastructure is located in the European Union (Italy/Belgium via GCP).
However, in the context of Programmatic Advertising, technical data may be processed by Ad Partners located outside the European Economic Area (EEA), including the USA. We ensure that such partners adhere to the Data Privacy Framework (DPF) or have signed Standard Contractual Clauses (SCCs) to guarantee an adequate level of protection.

8. DATA RETENTION

  • Partner Data: Retained for the duration of the contract + 10 years (legal obligation).

  • User Behavioral Data: Retained in raw form for a limited period (max 12 months) to train AI models, then aggregated or deleted.

  • Advertising Logs: Retained according to the policies of our Ad Partners.

9. PARTNER OBLIGATIONS (DISCLAIMER)

If you are a Publisher using Liink:

  1. You are the Controller: You determine the purposes of processing on your website.

  2. Consent Collection: You warrant that you utilize a CMP (Consent Management Platform) compliant with the IAB TCF or applicable laws to collect User consent for "Measurement" and "Personalized Ads".

  3. Transparency: You agree to list Lyber and its Ad Partners in your Cookie Policy and Privacy Policy.

  4. Liability: Lyber shall not be liable for the Publisher's failure to collect valid consent from End-Users.

10. USER RIGHTS

Under the GDPR and CCPA, users have the right to access, rectify, delete, or object to the processing of their data.

  • For Dashboard Data: Partners can edit their info directly in the Dashboard.

  • For Widget Data: Since we do not store PII (names/emails), we cannot identify a specific user upon request to provide data portability or deletion, unless the user provides additional technical identifiers. Users can opt-out of personalized advertising via their browser settings or "Your Online Choices" platforms.

11. CHANGES TO THIS POLICY

We may update this policy to reflect changes in our technology or legal requirements. We will notify Partners of material changes via the Dashboard.