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CREATELINK.LINK — PRIVACY POLICY

Effective Date: September 16, 2026

This Privacy Policy ("Policy") explains how the operator of CreateLink.link ("Platform", "Service", "We", "Us", "Our", "Operator") collects, uses, discloses, and protects information in connection with the Service. This Policy forms part of, and should be read together with, Our Terms of Service. The Service is currently operated by an individual based in Ukraine. [If/when a legal entity (e.g., ФОП/LLC) is registered to operate the Service, this section will be updated to identify that entity, its registration number, and registered address, which will also serve as the data controller for purposes of this Policy.]

INFORMATION WE COLLECT

1.1. Account Information: When You register, We collect Your email address and generate a unique User ID. Registration also requires a first name, a last name and a country of residence; a phone number is optional. We do not require Your physical address, and We do not verify the names provided. 1.2. Payment Information: Credit purchases are processed by our third-party cryptocurrency payment processor, NOWPayments. We receive confirmation of payment, transaction amount, and a transaction identifier. We do NOT collect, process, or store Your wallet private keys, seed phrases, or full payment credentials — these are handled entirely by NOWPayments under its own privacy policy, available at nowpayments.io. 1.3. Link and Redirect Data: When You create a short link, We store the destination URL You provide, the generated short link, and any custom configuration (e.g., redirect rules, filtering settings) You set. 1.4. Traffic and Analytics Data: For each click/visit routed through Your links, We may collect: IP address (see Section 4 for how it is stored), approximate geographic location derived from IP, device type, browser/user-agent string, referrer URL, timestamp, and bot/human classification signals used by our filtering system. 1.5. Automatically Collected Technical Data: Server logs, error logs, and security-monitoring data (including data generated by Our automated link-screening system described in Our Terms of Service) may be collected to operate, secure, and troubleshoot the Service. 1.6. Cookies and Similar Technologies: We use essential cookies/local storage to keep You logged in and to operate the dashboard. See Section 7 for details. 1.7. Information We Do Not Intentionally Collect: We do not knowingly collect sensitive personal data (e.g., health data, biometric data, political or religious beliefs) and We do not knowingly collect data from individuals under 18 years old, consistent with the eligibility requirement in Our Terms of Service.

HOW WE USE INFORMATION

We use collected information to: 2.1. Provide, operate, and maintain the Service, including generating and resolving short links; 2.2. Process credit purchases and maintain Your credit balance; 2.3. Detect, investigate, and prevent fraud, phishing, malware distribution, and other violations of Our Acceptable Use Policy (including automated screening of destination URLs against third-party threat databases such as Google Safe Browsing, VirusTotal, and PhishTank); 2.4. Generate aggregated analytics and reporting dashboards for Your own links; 2.5. Communicate with You regarding Your account, security alerts, policy violations, or appeal decisions; 2.6. Comply with applicable legal obligations, respond to lawful requests from public authorities, and enforce Our Terms of Service; 2.7. Improve the reliability, security, and performance of the Service. We do not sell Your personal data to third parties, and We do not use Your data for third-party advertising or ad-targeting purposes.

LEGAL BASIS FOR PROCESSING (FOR USERS IN THE EEA/UK)

Where applicable data protection law (e.g., GDPR) requires a legal basis, We process Your data on the following grounds: 3.1. Performance of a contract — to provide the Service You registered for; 3.2. Legitimate interests — to secure the Platform, detect fraud/phishing, and prevent abuse (Section 2.3), balanced against Your rights; 3.3. Legal obligation — where required to comply with applicable law, financial regulation, or law-enforcement requests; 3.4. Consent — for optional cookies or communications, where applicable (see Section 7).

DATA MINIMIZATION AND IP ADDRESS HANDLING

4.1. Click and traffic events currently store the visitor IP address in full for the retention period stated in Section 6.2, after which the event itself is deleted; only aggregate counters survive. We do not truncate or hash IP addresses today, and this Policy will be updated if that changes. 4.2. Full, unmasked IP addresses associated with a specific click may be retained for a limited period (see Section 6) where necessary to investigate a specific abuse report, security incident, or legal request.

HOW WE SHARE INFORMATION

We share information only in the following circumstances: 5.1. Infrastructure and Security Providers: With Cloudflare (proxy/CDN and DDoS protection) and third-party threat-intelligence services (e.g., Google Safe Browsing, VirusTotal, PhishTank) strictly to operate and secure the Service. 5.2. Payment Processor: With NOWPayments, solely to process credit purchases. 5.3. Legal and Safety Disclosures: With law-enforcement authorities, regulators, or courts where We are legally required to do so, or where necessary to investigate suspected fraud, phishing, or other violations of Our Terms of Service, or to protect the rights, property, or safety of Us, Our Users, or the public. 5.4. Business Transfers: In connection with a merger, acquisition, restructuring, or sale of assets, subject to this Policy continuing to apply to the transferred data (or the User being notified of a materially different policy). 5.5. With Your Consent: For any other purpose, only with Your explicit consent. We do not share Your personal data with third parties for their own independent marketing purposes.

DATA RETENTION

6.1. Account Data: Retained for as long as Your account remains active, and for a reasonable period afterward (e.g., no additional retention period — account data is erased when the account is deleted, except for the payment records described in 6.3) in case of disputes, legal claims, or fraud investigation, after which it is deleted or anonymized. 6.2. Traffic/Click Analytics Data: Retained in identifiable form for 90 days (click and email-open events; the personal link codes themselves are removed after 60 days), after which it is aggregated and/or anonymized for long-term statistical purposes. 6.3. Payment Records: Retained as required by applicable tax, accounting, and anti-money-laundering laws (typically several years), even after account closure. 6.4. Data related to a confirmed Acceptable Use Policy violation, suspension, or appeal (Section 4 of Our Terms of Service) may be retained longer where necessary to prevent repeat abuse or to comply with legal/regulatory obligations.

COOKIES AND TRACKING TECHNOLOGIES

7.1. Essential Cookies: Used to maintain Your login session and basic site functionality. These cannot be disabled without breaking core functionality. 7.2. Analytics Cookies (if applicable): We do not use analytics cookies and We do not embed any third-party tracker, analytics script, or advertising pixel on the Service. 7.3. You can control cookies through Your browser settings; disabling essential cookies may prevent You from logging in or using the dashboard.

INTERNATIONAL DATA TRANSFERS

8.1. Depending on where Our infrastructure and service providers (e.g., Cloudflare, NOWPayments, hosting providers) are located, Your data may be transferred to and processed in countries outside Your own, including countries that may not have data protection laws equivalent to those in Your jurisdiction. Where required, We rely on appropriate safeguards (such as standard contractual clauses or the provider's own compliance certifications) for such transfers.

YOUR RIGHTS

Depending on Your jurisdiction, You may have the right to: 9.1. Access the personal data We hold about You; 9.2. Request correction of inaccurate data; 9.3. Request deletion of Your data, subject to Our legal retention obligations (Section 6) and legitimate fraud-prevention needs; 9.4. Object to or restrict certain processing (e.g., processing based on legitimate interests); 9.5. Request a portable copy of Your data in a machine-readable format; 9.6. Withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing before withdrawal; 9.7. Lodge a complaint with Your local data protection authority. To exercise any of these rights, contact Us at info@createlink.link. We may need to verify Your identity before fulfilling a request.

DATA SECURITY

10.1. We implement reasonable technical and organizational measures (including Cloudflare proxy protection, access controls, and encrypted connections) to protect Your data against unauthorized access, loss, or misuse. 10.2. No method of transmission or storage is 100% secure, and We cannot guarantee absolute security, consistent with the disclaimers in Our Terms of Service. 10.3. In the event of a data breach affecting Your personal data, We will notify affected Users and/or relevant authorities as required by applicable law.

CHILDREN'S PRIVACY

11.1. The Service is not directed to, and We do not knowingly collect personal data from, individuals under 18 years old. If We become aware that We have inadvertently collected data from a minor, We will delete it promptly.

THIRD-PARTY LINKS AND DESTINATION URLS

12.1. Short links created by Users redirect to destination URLs controlled entirely by those Users, not by Us. We are not responsible for the privacy practices or content of destination websites. Visiting a destination URL is subject to that website's own privacy policy.

CHANGES TO THIS POLICY

13.1. We may update this Policy from time to time. Material changes will be reflected by an updated "Effective Date," and, where required by law, We will provide additional notice. Continued use of the Service after changes take effect constitutes acceptance of the revised Policy.

CONTACT US

14.1. Questions, requests, or complaints regarding this Policy may be directed to info@createlink.link.


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