1. Security and performance

We respect each site visitor's right to personal privacy. To that end, we collect and use information throughout our website only as disclosed in this Privacy statement. This Privacy statement applies solely to information collected by this website. It discloses the privacy practices for www.linkplusit.com. Hereafter, the terms 'LinkPlus IT', 'us' or 'we' refer to the owner of the website whose registered office is located at Icon Tower, 12th Floor, no.46, 10000 Prishtine, Kosovo. The term 'you' refers to the user or viewer of our website. We take the protection of our users’ personal data very seriously, and want each user to feel secure and at ease while visiting our internet pages and/or interacting with them. Any details that you enter in one of our online forms will be stored electronically by us. Should you wish for any modifications, corrections or deletion of these stored data, please contact us by e-mail at informationsecurity@linkplus-it.com We have no authority over the design or development of the content of other companies' internet pages that are accessible via links from our website. Therefore we disclaim any responsibility for the content, design and/or policies of these internet pages. Furthermore, we expressly disassociate from any internet content that might be illegal or offensive. If you use links on our website to access other companies' internet pages, you do so on your own responsibility. The content of this website is intellectual property protected by law. The information and content provided may not be re-used without our explicit permission, except for private or other personal use within the meaning of the Data Protection Act. The press releases and articles from our press service presented on the site are available to the editors of newspapers or periodicals for publication. If they are published, we would request the publisher to send us a proof copy. We reserve the right to make changes to this Privacy statement at any time without notice. If you disagree with any part of this Privacy statement, please do not use our website.

1.1 How we use your information

This privacy policy is meant to inform you on what to expect when we, LinkPlus IT, collect personal information.

1.2 Data Protection Policy

Link Plus IT has established a Data Protection Policy which ensures its employees, clients, resellers, and stakeholders that their data is protected and handled accordingly with absolute caution and confidentiality. Please read our Data Protection Policy on our website.

1.3 Visitors of the LINK PLUS IT website and account creation

When you visit our website, you should be aware that we use third party services, such as Google Analytics, to collect standard internet log information and details of visitor behavior patterns. This operation is performed in order to provide us information regarding the number of visitors to the various parts of the site. The processing of this information does not provide any kind of identification of the visitors. Google Analytics does not make any attempt to reveal the identities of those visiting our website. The only case when Link Plus IT collects personally identifiable information through the website is when a visitor voluntarily creates a user account. We provide full transparency in these cases. We make sure to express it clearly and intelligibly when we collect personal information and provide an unambiguous explanation on what we intend to do with the information collected. We collect personally identifiable information only with the consent of the natural person (data subject) and assure that the data collected is used only for the stated purpose.

1.4 Consent to Your Information Being Collected

The submission of information to Link Plus IT by users is done on a voluntary basis. When a user clicks the "Submit" button on any of our web forms at our website www.linkplusit.com, the users are indicating that they are aware of the LinkPlus IT Terms, Conditions, Policy provisions and voluntarily consent to the conditions outlined therein.

1.5 Search engine

LINKPLUS IT reserves the right to build a search engine within the website to help its visitors find information easier. The search engine serves as a means to search publicly available information on our website, and not personally identifiable information of users.

2. Security and performance

We take precautions to protect your information and privacy. When you submit information via the form(s) available on our website, your information is protected both online and offline. Only employees who need the information to perform a specific task (for example, billing or customer service) are granted access to personally identifiable information. The computers/servers in which we store personally identifiable information are kept in a secure environment, monitored with a strictly controlled access. We use a third-party service to help maintain the security and performance of our website. However, no transmission of data on the Internet can be guaranteed to be completely confidential. Therefore, we cannot guarantee that any information you send us will not be lost, used unlawfully or modified in a fraudulent manner and we bear no liability for the use that may be made of the information provided by you or any third party.

2.1 Our Service Providers

To provide our services and publish our website www.bambusgropu.com, we use the G Suite. The G Suite Privacy Policy is available online at https://policies.google.com/privacy?hl=en-US . We do not grant any permission to the OVH to share any personal information we collect from our account holders on our website.

3. People who email us

We use G Suite as our e-mailing system as a third-party service provider. We chose G Suite because it complies with the information security requirements, including but not limited to ISO 27001 and EU GDPR. Emails sent by LinkPlus IT will be encrypted in transport by G Suite by default. We do not guarantee that the recipients of our emails have enabled or available encryption, therefore it is your responsibility to ensure encryption in your end. We will also monitor any emails sent to us for viruses or malicious software, including file attachments. Please be aware that you have a responsibility to ensure that any email sent to us by you is legally compliant.

4. Human Resources

4.1 Job applicants, current, and former Link Plus IT employees

LinkPlus IT is the data controller of the information you provide during the processes of job application, unless otherwise stated. If you have any questions about the process or the way your information is handled, please contact us at informationsecurity@linkplus-it.com

4.2 What will we do with the information you provide us?

All of the information you provide during the process is only used for the purpose of proceeding your application or to fulfill legal and/or regulatory requirements if necessary. We do not share any of the information you provide during the recruitment process with any third-parties. The information you provide will be held securely by us and/or our Human Resources Office whether the information is in electronic or physical format. We use the contact details you provide to us in order to contact you for the purpose of progressing your application. We use other information you provide to assess your suitability for the role you have applied for.

4.3 What information do we ask for, and why?

We do not collect more information than we need to fulfill our stated purposes and do not retain any information for longer than is necessary. The information we ask for is used to assess your suitability for employment.

5. Children

This privacy statement is not intended for use by children. We understand the importance of protecting children’s information, especially in an online environment, and we do not knowingly collect or maintain information about children.

6. Complaints

Link Plus IT strives to meet the highest standards of data protection when collecting and using personal information. For this reason, we take any complaints we receive very seriously. We encourage our website users, visitors and any concerned party to bring to our attention any observation or opinion which is thought to indicate unfair, misleading or inappropriate information collection and/or usage. This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive details of all aspects of Link Plus IT’s collection and usage of personal information. However, we are happy to provide any additional information or explanation needed. Any requests of this nature should be sent to the address below. If you want to make a complaint about the way we have processed your personal information, you can do it by following the steps described in our Complaint and Appeal Procedure.

6.1 Access to personal information

Individuals can learn if we hold any personal information by making a request for information we hold about them to our Information Security Manager. If we hold information about you we will: ● provide you a description of it; ● inform you on the reasons we are holding it; ● provide you with information on parties it could be disclosed to; and ● provide you with a copy of the information in an intelligible form. To make a request to LinkPlus IT for any personal information we may hold the need to put the request in writing and addressing it to our Information Security Manager by writing at the email address informationsecurity@linkplus-it.com If we hold information about you that you deem to be incorrect, you can ask us to correct mistakes, by contacting our Information Security Manager. If we hold information that you consider to be kept by us without reason, you can ask us to delete your information at any time. Please keep in mind that we do not delete all of your information when requested, due to legal obligations, such as the financial transactions evidence.

6.2 Disclosure of personal information

In general and in all circumstances, we will not disclose personal data without consent. However, when we are asked by the regulatory body, supervisory authority, or for other necessary legal operations, we may disclose your information. Links to other websites This privacy notice does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit.

7. Changes to this privacy policy

We keep our privacy notice under regular review. This privacy notice was last updated on September 01, 2023. You will not be notified for changes in our privacy policy, and you are required to visit the privacy policy on our website. How to contact us If you want to request information about our privacy policy you can email us or write to: LINKPLUS IT Headquarters informationsecurity@linkplus-it.com Icon Tower, 12th Floor, no.46, 10000 Prishtine, Kosovo +38348224445

Foreword

LinkPlus IT is fully committed to adhere to the highest ethical conduct and values. The LinkPlus IT Management is dedicated to share the code of ethics principles within the organization by assuring that every employee understands the importance of behaving and exhibiting great responsibility, competence and fairness towards each colleague and client. We believe that organizational success is assured when an organization fully understands its customer needs and desires. We help consumers and businesses get the products and services they want and need. We keep our companies in business with our talented problem solvers that combine the skills and technology needed to improve business performance and services that improve the quality of life for everyone. LinkPlus IT Code of Ethics describes the values and procedures which are expected from our employees. We believe that strong ethical values are the prerequisite to a healthy work environment and foster great working relationships internally and externally. Every employee is responsible to understand these principles and make sure that they are implemented successfully in their aspects of operation or for procedures which are under their competence. Anyone who is unaware of any procedure mentioned in this document or who needs a more detailed clarification is encouraged to contact us. It will be our pleasure to explain any and all of these principles and its implementations in great detail.

Applicability

LinkPlus IT Code of Conduct is applicable to all LinkPlus IT Professionals. This includes all clients, partners, employees, and other relevant stakeholders. However, if an employee violates the premises of ethical behavior, LinkPlus IT contract may be terminated and contract revoked. Not only is it important for LinkPlus IT employees to adhere to the principles expressed in this Code, we believe that a basic Code of Conduct will inspire virtues of human decency and highest professionalism among all coworkers and stakeholders.

LinkPlus IT professionals will:

1. Conduct themselves professionally, with honesty, accuracy, fairness, responsibility and independence.
2. Act at all times solely in the best interest of their employer, their clients, the public, and the profession by acting in accordance with the professional standards and applicable techniques while performing professional services.
3. Maintain competency in their respective fields and strive to constantly improve their professional skills.
4. Offer only professional services for which they are qualified to perform, and adequately inform clients and consumers about the nature of proposed services, including any relevant concerns or risks.
5. Inform each employer or client of any business interests or affiliations which might influence their judgment or impair their fairness.
6. Treat in confidential and private manner information acquired during professional and business dealings of any present or former employer or client without its proper consent.
7. Comply with all laws and regulations of the jurisdictions where professional activities are conducted.
8. Respect the intellectual property and contributions of others.
9. Not act in any manner that could compromise the reputation of LinkPlus IT or its certification programs
10. FullycooperateontheinquiryfollowingaclaimedinfringementofthisCodeofEthics.

Integrity

We wholly understand the importance of truthfulness and integrity when establishing procedures, policies and services. We ensure that every answer, conduct, recommendation, suggestion and assistance provided is true and of the highest norm. We attempt to provide services without prejudice against anyone’s background and preference of any kind. We believe that employees shall not be driven and dominated only by regulations or requirements but also by their self-initiative on promoting actions that are ethically right. We highly condemn sales practices, customer services or product developments that are governed by inaccurate information or misrepresentation facts.

A Culture of Integrity

When facing any doubt of potential conflict arising from a breach of our Code of Ethics, LinkPlus IT Professionals should ask the following questions:
● Do I suspect that the particular course of action may be illegal or unethical?
● In what way am I involved?
● What are the principles or rules infringed?
● Could this action undermine my professional and personal character?
● Does the proposed course of action involve being untruthful and/or unsafe?
● Could the proposed course of action damage LinkPlus IT (directly or indirectly) or its reputation?
● Does the proposed course of action have a legitimate business purpose, and is there any alternative?
If the proposed course of action fails any of these questions, LinkPlus IT Professionals should seek advice and re-consider the decision. The existence of a problem should never be ignored.

Impartiality

We are fully aware of the importance of impartiality in carrying out our operational activities. We ensure to treat everybody involved in our business with respect, dignity and fairness. We have documented structures, policies and procedures to manage impartiality and to ensure that our activities are undertaken impartially and followed by top management commitment. We analyze, document and eliminate the potential conflict of interests arising from our service activities which are structured and managed so as to safeguard impartiality. Our aim is to inspire and prove confidence in the distribution of our services and products.

Conflict of Interest

Conflicts of interest may arise when a candidate requests a service at LinkPlus IT, and has a financial interest or close personal relationship with anyone from the LinkPlus IT staff involved in business decisions. This principle and procedure applies for all business processes. Conflicts may lead to, or be accompanied by, the inappropriate handling and decision making for the exclusive benefit of the employees. In order to identify, minimize, manage conflict of interests, our staff members are responsible to report circumstances where potential conflict of interests may arise. Then, procedures for documenting and controlling conflict of interests are initiated.

Confidentiality

Information should always be protected, regardless of how it is formed, shared, communicated or stored. Information can exist in many forms. It can be printed or written on paper, stored electronically, transmitted by post or by using electronic means, shown on films, or spoken in conversation. Information security is the protection of information from a wide range of threats in order to ensure business continuity, minimize business risk, and maximize return on investments and business opportunities.
Our Information Security priorities are:
● Strategic and operational information security risks are understood and treated to be acceptable to the organization.
● The confidentiality, integrity and availability of customer information, product development and all confidential information are assured.
Each employee is responsible to provide factually accurate information. Our team is aware and assures that every information circulated or publicly distributed complies with LinkPlus IT Information Security, Data Protection and Confidentiality policies. Sensitive information shall never be shared without prior permission of the person who grants the ownership of the information. All employees shall become aware and respect the sensitivity factor and impact of information, and therefore, are made accountable for information that belongs under their roles and responsibilities

Responsibility

We understand and know how to assess customer needs. Sometimes failures are only perceived as negative outcomes of productivity within a company. However, many great organizations understand that there is no success without failure. Without identifying failures, it would be hard to improve an organization. We ensure that every issue is treated with responsibility and priority. We have implemented procedures for addressing issues, providing correct feedback, listening to customer’s concerns and translating every raised issue into an opportunity for continual improvement and perfection. Our Compliance Team knows how to empathize and communicate in response to our customer needs. Thus, we are trained to understand and investigate the root cause of raised issues and provide controls and actions for eliminating them. Working with International clients, means to follow professional ethical codes. Our team knows how to analyze, comply and embed international standards requirements into every procedure. We understand that any violation of our Code and Ethics will bring damaging consequences on our credibility. LinkPlus IT has put in place an adequate procedure to deal with all forms of complains. This applies in the event of a complaint or appeal received from customers and other parties concerned with the rules, policies, procedures, services, or overall LinkPlus IT operations. This procedure covers the assessed actions, response, recommendations and the role of the Appeal Board when reaching a conclusive settlement on account of the appeal.

Competence

A member of our Team is qualified and aware of the roles and responsibilities they shall follow in fulfilling the organizational objectives and meeting customer expectations. In this context, our strategy is primarily focused in detecting the nature of problems through root-cause analysis and providing solutions with a focus towards efficiency and satisfaction. Our Team understands how to address and when to prioritize issues. We have set a clear definition of the responsibilities that everyone in our organization has in communicating concepts for establishing a collaborative approach that is important for management development in a collective manner. Issues or concerns are seen as productive features for putting in place preventive measures and controls. One of our ways to ensure workplace competency is to initiate continual training and awareness sessions by using real-life examples and scenarios. It is our core objective to make sure that our Team understands the theoretical and practical aspects of management principles and standard requirements.

Respect and Dignity

Every person must be treated with respect and dignity. No action taken within our organization shall be discriminatory or offensive, but built upon the norms of fundamental and universal human rights values. Every person should be respected and treated equally regardless of race, gender, religion, sexual orientation or world view. We encourage freedom of speech, expression of opinions and thoughts by cultivating a work environment with a strong emphasis for multicultural awareness and tolerance. Anti-bribery and Anti-Corruption We are committed in the fight against bribery worldwide, and as such reject any form of bribery or corruption, direct or indirect, including kickbacks, the use of funds or assets for any unethical purposes. This categorical rejection of bribery practice also includes the use of other routes or channels for provision of improper benefits from or to customers, partners, associates, and government authorities. In this effort we promote full compliance against anti bribery through local and international requirements such as ISO 37001.

Code of Ethics Evaluation

Being compliant with the LinkPlus IT Code of Ethics principles is essential for all LinkPlus IT professionals, including LinkPlus IT employees, partners, and other associates. Compliance is included in the performance evaluation of each stakeholder and continuous monitoring is performed regularly. Any LinkPlus IT Professional who fails to comply with the LinkPlus IT Code of Ethics shall be subject to disciplinary measures which may include the termination of their contract, and in cases when the impact is severe, legal measures will be followed. In all cases, the author of any violation shall have the right to be heard and to defend him or her –self before a disciplinary measure is imposed.

Environmental Awareness

Our organization is aware of the damages and externalities that unconscious human actions can cause to the natural world. Therefore, we seek to improve our business process to reach an ideal level of environmental protection and operate in the best way possible.

Contact us

Should any stakeholder witness any breach of LinkPlus IT Code of Ethics by LinkPlus IT Professionals, we highly encourage you to report it to our Compliance representative. We are committed to investigate each case to the full extent necessary to ensure highest ethical standards. Icon Tower, 12th Floor, no.46, 10000 Prishtine, Kosovo hr@linkplus-it.com +38348224445

Introduction

Our Data Protection policy indicates that we are dedicated to and responsible for processing the information of our customers, stakeholders, employees and other interested parties with absolute caution and confidentiality. This policy describes how we collect, store, handle and secure our data fairly, transparently, and with confidentiality. This policy ensures that Link Plus IT follows good practices to protect the data gathered from its customers, employees, and stakeholders. The rules outlined in this document apply regardless of whether the data is stored electronically, on paper or on any other storage device.

1. Policy Elements

As a key part of our operations, we gather and process any information or data that makes an individual identifiable such as full name, physical address, email address, photographs, etc. This information is collected only with the full cooperation and knowledge of interested parties. Once this information is available to us, the following rules apply to our company.
Our data will: Be precise and consistently updated; Is collected legitimately and with a clearly stated purpose; Be processed by the company in line with its legal and ethical binds; Have a protection measure that protects it from any unauthorized or illegal access occurring by internal or external parties.
Our data will NOT: Be communicated informally; Exceed the specified amount of time stored; o Therefore, personal data of employees, customers, and affiliates who no longer use Link Plus IT services will be archived for 3 years and deleted afterwards; Be transferred to organizations, states or countries that do not acquire proper data protection policies; Be spread to any party unless approved by the data’s owner (except for the legitimate requests demanded from law enforcement authorities).

2. Roles and Responsibilities

Everyone who works for or with Link Plus IT is responsible for ensuring that the collection, storage, handling, and protection of data is being done appropriately. Email: informationsecurity@linkplus-it.com Phone: +38348224445 In addition, the following functions within Link Plus IT hold the key areas of responsibility:
Information Security Manager and Data Protection Officer (DPO) is responsible for:

- Informing and advising LinkPlus IT in regards to the data protection and privacy for the natural persons;
- Monitoring Data Protection and privacy compliance of Link Plus IT with the data protection requirements applicable in EU;
- Providing advice with regard to data protection impact assessments;
- Cooperating and liaise with the supervisory authority;
- Be a point of contact for data subjects at: informationsecurity@linkplus-it.com;
- Providing oversight and continuous enhancement of cyber security and in risk management awareness programs and improvements;
- Leading the design and operation of related compliance monitoring and improvement activities to ensure compliance with both internal security policies, and applicable laws and regulations;
- Developing and managing controls to ensure compliance with the wide variety and ever-changing requirements resulting from standards and regulations. IT Systems Manager:
- Strictly complying with all Link Plus IT policies related to non-disclosure, non-competition and confidentiality of information;
- Constantly staying up to date on various web technologies and tools;
- Performing networking systems hardware and software upgrades, and installing security patches as needed;
- Checking and monitoring the general health of networks and networking devices;
- Performing daily system monitoring, verifying the integrity and availability of all hardware, server resources, systems and key processes, reviewing system and application logs, and verifying completion of scheduled tasks;
- The implementation, configuration and maintenance of computer networks, software, and digital security. Systems Administrator:
- Ensuring that access to personal data of users registered on the Link Plus IT Website is restricted only to authorized personnel;
- Ensuring that access to the personal data of users registered on the Link Plus IT website will not be shared with or provided to unauthorized personnel.

3. General guidelines

● Access to data covered by this policy is restricted only to those who need it for their work;
● Data is not to be shared informally. When access to confidential information is required, employees request it from their line managers;
● We provide comprehensive training to all employees to help them understand their responsibilities when handling data;
● Employees keep all data secure, by taking sensible precautions and following the Data Storage guidelines specified below;
● In particular, strong passwords are used and never shared;
● Personal data is not disclosed to unauthorized people, within the company or externally;
● Employees request help from their line manager or the data protection officer when they are unsure about any aspect of data protection.

4. Data Storage

These rules describe how and where data is safely stored. When data is stored on paper, it is kept in a secure place accessed only by authorized personnel.
● These guidelines also apply to data that is usually stored electronically but has been printed out for certain reasons:
● The paper or files are kept in a locked drawer or filing cabinet;
● Employees make sure paper and printouts are not left unattended;
● Data printouts are securely shredded and disposed when no longer needed
When data is stored electronically, it must be protected from unauthorized access, accidental deletion and malicious internal or external threats.
● Data should be protected by strong passwords that are updated regularly and never shared among employees;
● If data is stored on removable media (like a CD or DVD, External HDD, etc.), these should be kept locked away securely when not being used;
● Data should only be stored on designated servers at Link Plus IT premises, and should only be uploaded on to approved cloud computing services;
● Servers containing personal data are sited at secure locations, where access is restricted for authorized personnel only and monitored;
● Data is never saved directly in permanent computers or other portable devices like tablets or smartphones, etc;
● All servers and computers containing data are protected by the monitoring system and the firewall system;

5. Data usage

● All data collected by Link Plus IT is strictly for Link Plus IT-related services required to ensure a complete
response/service is being provided by Link Plus IT. No other non-Link Plus IT related service will be offered from the data collected;
● When working with personal data, employees ensure their computer screens are always locked when left unattended;
● Data is encrypted before being transferred electronically;
● Employees do not save copies of personal data into their own computers. The access and update of a copy is always made at the central copy of the data.

6. Data accuracy and actions

To exercise data protection, Link Plus IT takes reasonable steps and is committed to:
● Restrict and monitor access to sensitive data, and keep it in as few places as possible;
● Establish effective data collection procedures;
● Provide employees with online privacy and security measures training;
● Build secure network to protect online data from cyber attacks;
● Establish clear procedures for reporting privacy breaches or data misuse;
● Include contract clauses or communicate statements on how we handle data;
● Update the data continuously and as mistakes are discovered;
● Ensure the marketing databases are checked against industry suppression files;
● Establish data protection practices (document shredding, secure locks, data encryption, frequent backups,
access authorization etc.).

7. Subject access requests

All individuals and organizations who are the subject of personal and other data held by Link Plus IT are entitled to:
● Ask what information LINK PLUS IT holds about them and why.
● Ask how to gain access to it.
● Be informed how to keep it up to date.
● Be informed how the company is meeting its data protection obligations.

If an individual contacts the company requesting this information, this is called a subject access request. Requests from individuals should be made by email, addressed to the data protection officer at informationsecurity@linkplus-it.com. The data controller can supply a standard request form, although individuals do not have to use this.
Our clients can contact us directly requesting this information through the subject access request. Such requests can be made via email addressed to our team at informationsecurity@linkplus-it.com. We will always verify the identity of anyone making a subject access request before handing over any information. Confirmation will be asked from the data subject using the email data subject used to register an account at LINK PLUS IT.
We will aim to provide the relevant data within 14 days.

7.1. Data Modification

Our clients can contact us requesting data modification and/or correction by sending an email to information.security@linkpusit.com or through the digital form available here. LINK PLUS IT will verify the identity of anyone making a data subject access request before modifying or correcting any information.

7.2. Data erasure

Our clients can contact us requesting data erasure via email at informationsecurity@linkplus-it.com. In addition, the data subject will be provided with all necessary information before proceeding with erasure. Before proceeding with the erasure, the data subject will read the statement of our data protection officer, explaining the outcome of the data being deleted. Erasure of data can be requested at any time.

8. Children

Our website is not appealing to children, nor are they directed to children younger than 16. LINK PLUS IT does not knowingly collect personally identifiable data from persons under the age of 16, and strives to comply with the provisions of The European Union General Data Protection Regulation (EU GDPR). If you are a parent of a child under 16, and you believe that your child has provided us with information about him or herself, please contact us at informationsecurity@linkplus-it.com

9. Disclosing Data

In certain circumstances, when required, LINK PLUS IT can disclose data to law enforcement agencies without the consent of the data subject. However, the data controller will ensure the request is legitimate, seeking assistance from the board and from the company’s legal advisers where necessary.

10. Privacy Policy

We have a privacy policy available on our website, stating out how data relating to customers, stakeholders, employees, and other parties involved is used in our company.