Privacy Policy

Last updated: April 16, 2026.

This Privacy Policy ("Policy") describes how Jelena Bradić PR Studio 98, with registered office at Vodovodska 69/24, Belgrade, Serbia, registration number 67977700, VAT number 114950878, operating under the name Linkyco ("Linkyco", "we", "us" or "our"), as the personal data controller, collects, processes, stores and protects your personal data when using the affiliate network available at the domain linkyco.com ("Linkyco", "Platform" or "Network").

This Policy is compliant with the Law on Personal Data Protection ("Official Gazette of the RS", No. 87/2018) ("LPDP"), Regulation (EU) 2016/679 ("GDPR"), and other applicable regulations of the Republic of Serbia.

Please read this Policy carefully before using the Platform. By using the Platform, you confirm that you are familiar with its content.

1. DATA CONTROLLER

Jelena Bradić PR Studio 98
Registered office: Vodovodska 69/24, Belgrade, Serbia
Registration number: 67977700
VAT number: 114950878
Web: https://linkyco.com
E-mail: privacy@linkyco.com

2. DEFINITIONS

For the purposes of this Policy, the following terms have the meanings set out below:

"Personal data" — any information relating to an identified or identifiable natural person, directly or indirectly (e.g. name and surname, email address, identification number, location data);

"Processing" — any operation performed in connection with personal data (collection, recording, storage, use, disclosure by transmission, erasure, etc.);

"Controller" — a natural or legal person who, alone or jointly with others, determines the purposes and means of processing personal data;

"Processor" — a natural or legal person who processes personal data on behalf of the controller;

"Influencer" / "Creator" — a legal entity (company or sole trader) that registers on the Linkyco Platform for the purpose of promoting advertisers' products and services and earning commissions;

"Advertiser" / "Brand" — a legal entity that uses the Linkyco Platform to enable influencers to promote its products and services;

"Master network" — an international affiliate network within which Linkyco may act as a sub-publisher to expand the advertiser catalogue.

3. CATEGORIES OF DATA SUBJECTS

Linkyco processes personal data of the following categories of individuals:

Representatives of Influencers — natural persons representing an Influencer as a legal entity (sole trader, statutory representative of a company, or authorised contact person);

Representatives of Advertisers — natural persons representing advertisers as contact persons or authorised representatives;

Platform Visitors — natural persons visiting the domain linkyco.com without registering.

Note: Linkyco does not register natural persons as Influencers — Influencers may only be registered legal entities (companies or sole traders). Data relating to legal entities (company name, VAT number, registration number, registered address) are not in themselves personal data within the meaning of the LPDP and GDPR. However, data relating to the natural persons representing those legal entities (name, surname, email, phone number, etc.) constitute personal data and are processed in accordance with this Policy.

4. DATA WE COLLECT

4.1. Data collected during Influencer registration

When submitting a registration request on the Linkyco Platform, we collect the following data:

Legal entity data: company name, VAT number, registration number;
Identification and contact data of the representative: name and surname, email address;
Account access credentials: password (stored exclusively in encrypted form — hashed; we never see your password in readable form);
Creator profile data: primary social media URL, number of followers.

After submission, Linkyco performs a manual review and approves or rejects the registration in accordance with its internal criteria.

4.2. Data collected for payment processing and invoicing

Following approval of registration and earned commissions, we collect additional data necessary for the lawful execution of payments and the issuance of accounting documents:

The Influencer's business account number (IBAN), bank name and SWIFT/BIC code (where applicable);
The registered address of the Influencer's legal entity (a mandatory element of invoices under the Value Added Tax Act and the Accounting Act).

Payments to Influencers are made exclusively by bank transfer from Linkyco's business account to the Influencer's business account as a legal entity.

4.3. Data collected during Advertiser registration

When establishing cooperation with Advertisers, we collect: company name, VAT number, registration number, registered address, contact details of the authorised person (name, surname, email, phone number) and data necessary for the fulfilment of contractual obligations.

4.4. Data automatically generated through Platform use

When using the Platform and during the technical processing of affiliate activities, the following data are automatically collected and processed:

User IP address and technical device information (browser type, operating system);
Data on access time, pages visited within the Platform and actions taken;
Tracking identifiers — unique Influencer ID in the system, campaign ID, data on clicks and conversions;
Data contained in cookies (see section 9 of this Policy).

4.5. Data received from other sources

For the purpose of verifying data about the Influencer's or Advertiser's legal entity, we may check publicly available data from the Business Registers Agency (BRA) and the Central Register of Taxpayers of the Tax Administration.

5. PURPOSES AND LEGAL BASES FOR PROCESSING

We process your personal data exclusively for specified, explicit and legitimate purposes, on the basis of the following legal grounds provided for in Article 12 of the LPDP and Article 6 of the GDPR:

5.1. Performance of a contract (Art. 12(1)(2) LPDP / Art. 6(1)(b) GDPR)

We process your data for the performance of the contractual relationship established by accepting our General Terms and Conditions, which includes:

Registration and management of your account on the Platform;
Tracking clicks, conversions and other affiliate activities;
Calculation and payment of commissions;
Communication relating to the provision of services;
Sharing necessary data with Advertisers for the purpose of conducting campaigns.

Important: Given that the sharing of certain data with Advertisers and (where applicable) master affiliate networks is technically necessary for tracking conversions and calculating commissions, the only way to prevent this processing is to not use the Linkyco Platform, or to terminate the cooperation in accordance with the General Terms and Conditions.

5.2. Compliance with legal obligations (Art. 12(1)(3) LPDP / Art. 6(1)(c) GDPR)

We process your data to fulfil Linkyco's legal obligations as a controller, particularly in relation to:

The Accounting Act — issuing invoices, keeping business books, retaining accounting documentation;
The Value Added Tax Act and other tax regulations — tax calculation and reporting, submitting data to the Tax Administration;
The Anti-Money Laundering and Counter-Terrorism Financing Act (where applicable);
Responding to requests from competent authorities (courts, prosecution offices, police, Tax Administration, Commissioner for Information of Public Importance and Personal Data Protection).

5.3. Legitimate interests

We process data on the basis of legitimate interests, provided that such processing does not override your rights and freedoms. This includes:

Platform security and protection against misuse;
Detection of fraudulent clicks and conversions;
Processing of IP addresses, device identifiers and tracking data for the purpose of accurate commission calculation;
Internal analytics and service improvement;
Keeping records (including blacklists);
Legal protection and dispute resolution.

Within these activities, limited profiling may be carried out solely for the purpose of preventing misuse, without automated decision-making with legal effect.

5.4. Consent (Art. 12(1)(1) LPDP / Art. 6(1)(a) GDPR)

In certain cases — such as sending promotional emails that are not strictly necessary for the performance of the contract, or the use of optional cookies — processing is based on your prior, freely given, specific, informed and unambiguous consent. You may withdraw your consent at any time, without providing reasons, in the manner described in section 8 of this Policy. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

6. RECIPIENTS OF PERSONAL DATA

6.1. Linkyco employees and engaged persons

Access to your data is granted exclusively to Linkyco employees and engaged persons who require the data to perform their work duties, and only to the extent strictly necessary (need-to-know principle). All such persons are bound by confidentiality obligations.

6.2. Data processors

Linkyco engages third parties as data processors (Art. 45 LPDP / Art. 28 GDPR) who process data exclusively on behalf of and under the instructions of Linkyco, on the basis of concluded data processing agreements that guarantee adequate technical and organisational protection measures. Categories of processors we engage include:

The provider of the software solution for technical support of the affiliate system, which enables conversion tracking, commission calculation and account management;
Hosting infrastructure providers for the website and business email;
An accounting agency with registered office in the Republic of Serbia, for the purpose of keeping business books and fulfilling tax obligations;
Banks and payment institutions, for the purpose of executing payment transactions;
Legal advisors, lawyers, auditors and other professional advisors, where necessary to protect our legal interests or fulfil legal obligations.

The identity of specific processors is provided to the data subject upon written request sent to privacy@linkyco.com.

6.3. Advertisers

Advertisers, as independent controllers, are given access to aggregated campaign performance statistics and individual transaction data (number of clicks, number of conversions, value of conversions), while Linkyco does not disclose to Advertisers the identity of the specific Influencer who generated a particular conversion. Cooperation with Advertisers is based on separate business cooperation agreements.

6.4. Master affiliate networks

Linkyco may cooperate with international affiliate networks (master affiliate networks) as a sub-publisher, in order to expand the catalogue of advertisers available to our Influencers. Where a particular campaign is conducted through a master network, certain data associated with the Influencer (such as the Influencer's unique system identifier and data on conversions achieved) may be forwarded to the master network and the end advertiser for the purposes of technical tracking and commission calculation. In such relationships, Linkyco and the master network may have the status of joint controllers within the meaning of Art. 43 LPDP and Art. 26 GDPR. An up-to-date list of master networks with which we currently cooperate is available upon request sent to privacy@linkyco.com.

6.5. State authorities and other legally authorised recipients

We may disclose your data to state authorities (courts, prosecution offices, police, Tax Administration, Commissioner for Information of Public Importance and Personal Data Protection, inspectorates) where there is a legal basis for doing so and where we are required to do so under the law of the Republic of Serbia or pursuant to a binding request from a competent authority.

7. TRANSFER OF DATA TO OTHER COUNTRIES

Linkyco primarily processes personal data in the territory of the Republic of Serbia and the European Economic Area (EEA). In certain cases, processors we engage may be located in EU member states or in countries for which an adequate level of data protection has been determined in accordance with a European Commission adequacy decision, or in accordance with Art. 64 of the LPDP.

In the event of a transfer of data to countries that do not ensure an adequate level of protection, such transfer is carried out exclusively with appropriate safeguards as provided for in Art. 65 of the LPDP and Art. 46 of the GDPR, primarily through the conclusion of standard contractual clauses adopted by the European Commission.

Further information about any transfers of data to third countries is available upon request sent to privacy@linkyco.com.

8. YOUR RIGHTS

In accordance with Arts. 21–38 of the LPDP and Arts. 12–22 of the GDPR, as a data subject, you have the following rights:

8.1. Right to information and right of access

You have the right to obtain from us confirmation as to whether we are processing your personal data, as well as access to that data and information about the purposes of processing, categories of data, recipients, retention period and other relevant circumstances.

8.2. Right to rectification and completion

You have the right to request the rectification of inaccurate personal data relating to you, or the completion of incomplete personal data.

8.3. Right to erasure ("right to be forgotten")

You have the right to request the erasure of your personal data, in particular where the data are no longer necessary for the purpose for which they were collected, where you withdraw consent (and there is no other legal basis), or where you lodge a valid objection to processing. This right is not absolute — Linkyco may retain data where there is a legal obligation to do so (e.g. retention of accounting documentation under the Accounting Act) or for the establishment, exercise or defence of legal claims.

8.4. Right to restriction of processing

You have the right to request the restriction of processing of your data in cases provided for by law (e.g. while the accuracy of data you have contested is being verified).

8.5. Right to data portability

You have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format, and to transmit that data to another controller, where technically feasible.

8.6. Right to object

You have the right to object at any time to the processing of your data based on our legitimate interests, on grounds relating to your particular situation. In that case we will cease processing, unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.

8.7. Right to withdraw consent

Where processing is based on consent, you have the right to withdraw your consent at any time, without providing reasons. Withdrawal of consent does not affect the lawfulness of processing that was carried out on the basis of consent prior to its withdrawal.

8.8. Right not to be subject to automated decision-making

You have the right not to be subject to a decision based solely on automated processing, including profiling, where that decision produces legal effects concerning you or significantly affects you. Linkyco currently does not carry out automated decision-making that produces legal effects on Influencers or significantly affects them.

8.9. Right to lodge a complaint with the Commissioner

You have the right to lodge a complaint with the supervisory authority in the Republic of Serbia — the Commissioner for Information of Public Importance and Personal Data Protection:

Address: Bulevar kralja Aleksandra 15, 11000 Belgrade
Phone: +381 11 3408 900
E-mail: office@poverenik.rs
Web: www.poverenik.rs

Data subjects from other EU member states may also contact the competent supervisory authority in their country.

8.10. How to exercise your rights

All of the above rights may be exercised by sending a written request to privacy@linkyco.com. Linkyco will respond to your request without undue delay, and no later than 30 days from the date of receipt of the request. In justified cases, this deadline may be extended by a further 60 days, of which you will be notified. The exercise of rights is free of charge, except in the case of manifestly unfounded or excessive requests.

To prevent misuse, Linkyco reserves the right to request additional information necessary to verify the identity of the applicant before acting on a request.

9. COOKIES AND SIMILAR TECHNOLOGIES

Cookies are small text files that a website you visit stores on your device. Linkyco currently uses exclusively strictly necessary (technical) cookies, which are essential for the proper functioning of the Platform and for providing the services you have explicitly requested (e.g. maintaining a user session after login, security checks).

Strictly necessary cookies are placed without prior user consent pursuant to Art. 126 of the Electronic Communications Act of the Republic of Serbia and Art. 5(3) of the ePrivacy Directive (Directive 2002/58/EC), as they are necessary for the provision of the service.

You may change your cookie settings at any time in your web browser, including blocking cookies entirely. If strictly necessary cookies are blocked, certain Platform functionalities may not be available.

In the event that Linkyco introduces analytical, marketing or other non-essential cookies in the future (e.g. Google Analytics or other tools), this Privacy Policy will be updated and your explicit consent will be sought before placing such cookies through an appropriate mechanism (cookie banner / consent management platform).

10. DATA RETENTION PERIODS

We retain your personal data only for as long as is necessary to fulfil the purposes for which they were collected, or as required by law. The specific retention periods are as follows:

Data of active Influencers and Advertisers: for the duration of the contractual relationship (existence of a registered account on the Platform);
Data after termination of the contractual relationship (termination or deletion of account): up to 5 years from the termination of the contractual relationship, for the establishment, exercise or defence of legal claims, in accordance with the general limitation period for claims under the Law on Obligations;
Accounting documents (invoices, statements, contracts with financial consequences): at least 10 years, in accordance with Art. 25 of the Accounting Act;
Data for tax purposes: for the periods prescribed by applicable tax regulations;
Tracking data (clicks, conversions, IP addresses): up to 24 months from the date of collection, unless longer retention is necessary for commission calculation or dispute resolution;
Email and support system communications: up to 3 years from the last correspondence;
Data provided on the basis of consent (e.g. marketing consents, where applicable): until withdrawal of consent, or until the expiry of the reasonable period for which consent was given.

Upon expiry of the above periods, data are permanently deleted or anonymised so that it is no longer possible to identify the data subject.

11. DATA SECURITY

Linkyco implements appropriate technical, organisational and personnel protection measures to ensure an adequate level of personal data security, in accordance with Art. 50 of the LPDP and Art. 32 of the GDPR. The measures we apply include, among others:

Encryption of communications using SSL/TLS protocols;
Storage of passwords exclusively in encrypted (hashed) form;
Access control on a need-to-know basis — access is granted only to persons who require it to perform their work duties;
Regular data backups;
Contractual binding of processors to apply adequate security measures through data processing agreements;
Internal training of engaged persons on data protection rules;
Regular review and improvement of applied protection measures.

Despite the application of appropriate protection measures, no internet data transmission system or electronic storage system is absolutely secure. Therefore, we cannot guarantee the absolute security of data, but we undertake to treat any personal data breach seriously and to act in accordance with the law.

12. PERSONAL DATA BREACH PROCEDURE

In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of data subjects, Linkyco will notify the Commissioner for Information of Public Importance and Personal Data Protection without undue delay, and no later than 72 hours after becoming aware of the breach, in accordance with Art. 52 of the LPDP and Art. 33 of the GDPR.

Where the breach is likely to result in a high risk to the rights and freedoms of data subjects, Linkyco will also notify the affected data subjects without undue delay, in accordance with Art. 53 of the LPDP and Art. 34 of the GDPR.

Linkyco maintains an internal record of personal data breaches, in accordance with the law.

13. MINORS

The Linkyco Platform is not intended for persons under the age of 18. Given that Influencers may only be registered legal entities (companies or sole traders), registration of persons under 18 as Influencers is not possible.

If we determine that we have inadvertently collected personal data of a minor without an appropriate legal basis, such data will be deleted without delay.

14. AMENDMENTS TO THIS POLICY

Linkyco reserves the right to amend this Policy at any time, in particular in the event of changes in regulations, the introduction of new services, changes in business processes or the engagement of new processors (e.g. the introduction of analytical tools or cooperation with new master affiliate networks).

We will notify you of material changes to the Policy by publishing a notice on the Platform and/or by email to your registered email address, at least 15 days before the changes take effect, except where changes result from an obligation to comply with amended regulations or a binding request from a competent authority.

The current version of the Policy is always available at https://linkyco.com/privacy. The date of the last amendment is stated at the beginning of this Policy.

By continuing to use the Platform after the amended Policy takes effect, you confirm that you are familiar with the changes.

15. CONTACT

All questions, requests, complaints and other enquiries regarding the protection of your personal data and this Policy may be directed to:

privacy@linkyco.com

This Privacy Policy enters into force on the date of its publication on the Platform.

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