Privacy Policy
1. Who We Are
linktwos.com ("the Website") is operated by PHM Ltd, a company registered in England and Wales under company number 16960300, with its registered office at Oakwood, Hook Heath Road, Woking, England, GU22 0LE ("we", "us", "our").
We are the data controller in respect of the personal data collected through this Website. This means we determine the purposes and means of processing your personal data.
Contact details for data protection matters:
Email: d4price@outlook.com
Post: PHM Ltd, Oakwood, Hook Heath Road, Woking, England, GU22 0LE
If you have any questions about how we handle your personal data, please contact us using the details above before raising a complaint with the regulator.
2. Scope of This Policy
This Privacy Policy explains what personal data we collect when you visit linktwos.com, why we collect it, the legal basis on which we process it, how long we keep it, who we share it with, and what rights you have under UK data protection law.
This policy applies to all visitors to linktwos.com.
3. The Legal Framework
We are subject to:
- the UK General Data Protection Regulation ("UK GDPR") as retained in domestic law by the European Union (Withdrawal) Act 2018 and amended by the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019; and
- the Data Protection Act 2018 ("DPA 2018").
The supervisory authority in the UK is the Information Commissioner's Office ("ICO"), reachable at ico.org.uk or on 0303 123 1113.
4. What Personal Data We Collect and How
4.1 Analytics Data (Google Analytics 4)
When you visit the Website, we use Google Analytics 4 ("GA4"), a web analytics service provided by Google LLC ("Google"). GA4 collects the following information automatically:
Identifiers and device information:
- A randomly generated client identifier stored in the
_gacookie on your device for approximately 2 years, used to distinguish returning visitors from new visitors - Your browser type and version, operating system, device type, screen resolution, and browser language settings
Approximate location:
- Country, region, and city, derived from your IP address. Google uses your IP address only for the purpose of determining your approximate location and does not retain or log full IP addresses in GA4 after geo-lookup
Traffic source information:
- The URL of the page that referred you to the Website (referring URL)
- Search engine used (where applicable)
- Campaign parameters appended to URLs (e.g., utm_source, utm_medium, utm_campaign, utm_content, utm_term)
Behavioural and engagement data (collected automatically via GA4 Enhanced Measurement):
- Every page view: the URL loaded, the page title, and the referring page
- Session start and first-visit events
- Scroll depth (an event fires when you scroll to approximately 90% of a page's length)
- Outbound link clicks (clicks on links that lead to external websites)
- URL-based search queries, where the URL contains a recognised search parameter (e.g.,
?q=) - File download events, where you click a link pointing to a downloadable file (e.g., PDF, ZIP)
- Form interaction events: when you begin completing a form on the Website and when you submit a form. GA4 records only that these events occurred; it does not capture the content of any form fields, including any email address or name you enter into our waitlist form
- Session duration, time on page, and engagement metrics
What GA4 does not collect through our current implementation:
- Your name, email address, telephone number, or any other information you enter into forms on the Website (form field values are not transmitted to GA4)
- Precise GPS or device-level location data
- Payment card or financial information
- Sensitive personal data as defined in Article 9 UK GDPR
4.2 Waitlist Form Submissions
If you submit the waitlist form on the Website, the information you provide (including your email address and any other fields in the form) is collected and stored by Netlify, Inc., the hosting and form-processing provider for the Website. Netlify Forms stores this data separately and independently from Google Analytics. We use this information solely to:
- notify you when linktwos.com launches or when the relevant product or service becomes available; and
- communicate with you in connection with your request to join the waitlist.
We do not share your waitlist form data with third parties for their own marketing purposes.
Voluntary nature of providing data: Submitting the waitlist form is entirely voluntary. You are under no obligation to do so. If you choose not to provide your details, the only consequence is that we will be unable to notify you when the service launches. You may withdraw from the waitlist at any time by contacting us at d4price@outlook.com, after which we will securely delete your personal data from our records.
5. Legal Basis for Processing
We are required by UK GDPR Article 13 to identify the legal basis on which we process your personal data. The applicable bases are as follows:
| Processing activity | Legal basis (UK GDPR) |
|---|---|
Analytics data collected via GA4, including placement of the _ga cookie |
Consent — Article 6(1)(a) UK GDPR. We will request your consent before loading GA4 or setting analytics cookies. You may withdraw consent at any time (see Section 11). |
| Waitlist form data (email address and other fields you provide) | Legitimate interests — Article 6(1)(f) UK GDPR. Our legitimate interest is in contacting people who have actively requested to be notified about the launch of our service. We have assessed that this interest is not overridden by your rights and freedoms, given that you initiated contact, the processing is limited to launch notification, and you can withdraw at any time (see Section 4.2). |
Note on consent for analytics cookies: Under Regulation 6 of the Privacy and Electronic Communications Regulations 2003 ("PECR"), we require your prior informed consent before placing non-essential cookies (including GA4 analytics cookies) on your device.
6. Cookies
We use cookies on the Website to support analytics (subject to your consent) and to remember your cookie-consent choice. A full standalone Cookie Policy will be published in due course; in the meantime, you can manage or change your analytics-cookie choice at any time using the link in Section 11.
7. Sharing Your Personal Data
We do not sell your personal data. We share your data with the following categories of third parties only to the extent necessary for the purposes described in this policy:
7.1 Google LLC (Google Analytics 4)
Analytics data is processed by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States. Google processes data collected via GA4 in accordance with its own privacy policy, available at https://policies.google.com/privacy. Google acts as a data processor in respect of analytics data collected on our behalf, subject to Google's Measurement Controller-Controller Data Protection Terms and/or Data Processing Terms (as applicable).
7.2 Netlify, Inc.
Waitlist form submissions are processed and stored by Netlify, Inc., 44 Montgomery Street, Suite 300, San Francisco, CA 94104, United States. Netlify acts as our data processor in respect of form data submitted through the Website. Netlify's privacy policy is available at https://www.netlify.com/privacy/.
7.3 Legal and regulatory disclosures
We may disclose your personal data to law enforcement agencies, regulatory bodies, or courts where we are required to do so by law, or where doing so is necessary to protect our rights, the safety of any person, or to detect or prevent fraud or criminal activity.
8. International Transfers of Personal Data
Both Google LLC and Netlify, Inc. are headquartered in the United States. Transfers of personal data from the UK to the United States are international transfers under UK GDPR.
We rely on the following transfer mechanisms to ensure an adequate level of protection:
- Google Analytics 4: Google LLC participates in and has certified its compliance with the UK Extension to the EU-US Data Privacy Framework and/or relies on the UK International Data Transfer Agreement ("IDTA") or UK Addendum to the EU Standard Contractual Clauses ("SCCs"), as applicable, which provide appropriate safeguards for the transfer of personal data to the United States. Further details are available in Google's data transfer documentation.
- Netlify: Netlify relies on the UK Addendum to the EU SCCs or equivalent transfer mechanism for transfers of data from the UK to the United States. Details are available in Netlify's DPA.
We take steps to ensure that any transfer of personal data outside the UK is subject to appropriate safeguards as described above, so that your rights and the protections afforded by UK data protection law continue to apply.
9. How Long We Keep Your Data
| Data category | Retention period |
|---|---|
| GA4 analytics data (aggregated and user-level) | Google's default GA4 data retention period is 14 months for user-level and event data, after which it is automatically deleted from Google's servers. Aggregated reporting data may be retained for longer. |
The _ga cookie on your device |
Approximately 2 years from the date of placement (or until you delete it). |
| Waitlist form submissions | We retain your contact details until the Website launches and you have been notified, or for 2 years from the date of submission if the service does not launch, after which data will be securely deleted. |
We will not retain your personal data for longer than is necessary for the purposes for which it was collected.
10. Your Rights Under UK GDPR
As a data subject under UK GDPR, you have the following rights. You can exercise these rights free of charge by contacting us at d4price@outlook.com. We will respond within one calendar month of receiving a valid request (this period may be extended by up to two further months in complex cases, in which case we will notify you).
Right of access (Article 15): You have the right to obtain confirmation of whether we process your personal data and, if so, to receive a copy of that data and information about how it is processed.
Right to rectification (Article 16): You have the right to require us to correct inaccurate personal data we hold about you, and to complete incomplete personal data.
Right to erasure (Article 17): You have the right to request that we delete your personal data in certain circumstances, including where the data is no longer necessary for the purpose for which it was collected, where you withdraw consent, or where the data has been unlawfully processed.
Right to restriction of processing (Article 18): You have the right to request that we restrict our processing of your personal data in certain circumstances, including while the accuracy of the data is contested or while you have objected to processing.
Right to data portability (Article 20): Where processing is based on consent or contract and carried out by automated means, you have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to have it transmitted to another controller where technically feasible.
Right to object (Article 21): Where we rely on legitimate interests as our legal basis, you have the right to object to our processing of your personal data on grounds relating to your particular situation. We will stop processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or unless processing is necessary for legal claims.
Right to withdraw consent (Article 7(3)): Where we process your data on the basis of consent (including for analytics cookies), you have the right to withdraw that consent at any time. Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal. To withdraw consent for analytics cookies, see Section 11 below.
Right to object to direct marketing (Article 21(2)–(3)): You have an unconditional and absolute right to object at any time to the processing of your personal data for direct marketing purposes, including any profiling carried out for direct marketing. Where you exercise this right, we will immediately cease processing your data for those purposes — we are not permitted to refuse or to weigh competing interests against this right. To exercise it, contact us at d4price@outlook.com or use the unsubscribe link included in any email we send you.
Rights related to automated decision-making: We do not make any decisions about you solely by automated means that produce legal or similarly significant effects.
11. Withdrawing Consent for Analytics and Opting Out
You may withdraw your consent for analytics data collection at any time by:
- Cookie preferences: — this will re-open the consent banner so you can change your choice.
- Browser settings: Most browsers allow you to delete and block cookies through their settings menus. Deleting the
_gacookie from your browser will reset your analytics identifier. Note that blocking all cookies may affect the functionality of some websites. - Google Analytics Opt-out Browser Add-on: Google provides a browser extension that prevents GA4 from collecting data about your visits. You can download it at https://tools.google.com/dlpage/gaoptout.
- Google's privacy settings: You can manage Google's use of your data at https://myaccount.google.com/data-and-privacy.
12. Security
We take appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. These measures include HTTPS encryption on all pages of the Website.
However, no transmission over the internet is completely secure. While we take reasonable steps to protect your data, we cannot guarantee the security of data transmitted to or from the Website.
13. Third-Party Links
The Website may contain links to third-party websites. This Privacy Policy applies only to linktwos.com. We have no responsibility for the privacy practices of third-party websites and encourage you to review their privacy policies before providing them with any personal data.
14. Children
This Website is not directed at children under the age of 13, and we do not knowingly collect personal data from children under 13. If you believe we have inadvertently collected personal data from a child under 13, please contact us immediately at d4price@outlook.com and we will take steps to delete it.
15. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. When we make material changes, we will update the "Last updated" date at the top of this page. We encourage you to review this page periodically.
Where required by law, we will notify you of significant changes (for example, by placing a notice on the Website).
16. How to Complain
If you have a concern about how we handle your personal data and are not satisfied with our response, you have the right, without prejudice to any other administrative or judicial remedy, to lodge a complaint with the Information Commissioner's Office ("ICO"):
Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Website: https://ico.org.uk/make-a-complaint/
Helpline: 0303 123 1113
We would, however, appreciate the opportunity to address your concerns before you contact the ICO, and ask that you contact us in the first instance.