Privacy Policy

This Privacy Policy explains how Timelake, UAB ("Timelake", "we", "us", or "our") handles information in connection with the Plink Vision mobile application ("Plink" or the "App") and the website at plink.vision (the "Website").

Timelake, UAB is the data controller responsible for personal data processed as described in this Privacy Policy.

1. Overview

Plink is a mobile application that receives cycling and device data from compatible cycling computers and uses that data to display a heads-up display on compatible smart glasses.

Plink is designed to process cycling telemetry locally on your device. We do not operate a Plink user account service, and we do not receive or store your cycling telemetry on our servers.

Plink does not use your data for advertising or cross-app tracking, and we do not sell your personal data. The Website uses consent-based analytics as described below; this does not change the App’s local processing of cycling telemetry.

2. Information Processed by Plink

Cycling telemetry

Plink may receive cycling telemetry from a compatible cycling computer or connected device. Depending on the devices and features you use, this data may include information such as:

• speed;
• cadence;
• power;
• distance;
• altitude;
• elapsed time;
• heart rate; and
• device or sensor status information.

Plink processes this data locally on your device for the purpose of presenting selected information on compatible smart glasses and providing the App's cycling HUD functionality.

Timelake does not receive or store this cycling telemetry on its servers.

Connected device information

Plink may process information about compatible devices used with the App, such as device identifiers, device model information, connection status, and battery or device status information.

This information is used locally on your device to establish and manage connections between Plink, compatible cycling computers, and compatible smart glasses.

App settings and HUD configuration

Plink stores settings and HUD configuration information on your device. This may include your selected units, configured HUD pages, displayed data fields, and other App preferences.

This information is stored locally on your device and is used to provide and remember your chosen App configuration.

3. Bluetooth and Device Communication

Plink uses Bluetooth to communicate with compatible smart glasses and may use device communication technologies or frameworks provided by device manufacturers to communicate with compatible cycling computers.

Bluetooth access is required for functionality involving compatible Bluetooth devices.

Information exchanged with connected devices is used to provide the App's functionality. We do not use Bluetooth or connected-device information for advertising or tracking.

4. Information You Provide to Us

Plink does not require you to create a user account.

If you contact us, for example by sending an email to hello@plink.vision, we may receive personal data that you voluntarily provide. This may include:

• your email address;
• your name, if provided;
• the contents of your message; and
• any other information you choose to include in your communication.

We use this information to respond to your request, provide support, investigate reported issues, and maintain reasonable business records relating to our communications.

Please avoid sending cycling telemetry, health information, or other sensitive personal data to us unless it is necessary for us to address your request.

5. Analytics, Advertising, and Tracking

Plink does not use advertising SDKs.

Plink does not use your information for targeted advertising or cross-app tracking.

We do not sell your personal data.

We do not use cycling telemetry to create advertising or marketing profiles.

The Website uses Google Analytics 4 through Google Tag Manager only after you grant Analytics consent in the Website’s cookie preferences. We use it to understand website visits, acquisition sources, page performance and interactions such as navigation, FAQ use, video controls, contact links and clicks to external app stores.

Depending on your browser and consent choice, website analytics information may include page URLs and titles, referrer and campaign information, interaction events, approximate location, and browser and device information. Google Analytics uses a pseudonymous client identifier stored in first-party cookies. We do not send cycling telemetry, HUD configuration or other information processed locally by the App to Google Analytics.

Our Google Analytics measurement ID is G-QW5E76NC6B and our Google Tag Manager container ID is GTM-K9LZ4T6S. The Website uses Basic Consent Mode, so these services do not load or send analytics events before Analytics consent. You can withdraw consent at any time using “Cookie settings” in the Website footer. See our Cookie Policy for details.

No advertising or marketing tag is currently configured on the Website. If we introduce App analytics, crash reporting, advertising technology or other data collection that materially changes our privacy practices, we will update this Privacy Policy and the applicable disclosures.

6. Third-Party Devices and Technologies

Plink is designed to work with compatible third-party devices and technologies, including cycling computers and compatible smart glasses.

Communication with these devices may rely on software, frameworks, or services provided by their manufacturers or technology providers.

Your use of third-party devices, software, or services may also be subject to the privacy practices and terms of the relevant third party. This Privacy Policy describes Timelake's processing of personal data in connection with Plink and does not govern independent processing carried out by third parties.

7. How We Use Personal Data

Where Timelake receives personal data directly, such as when you contact us, we may use it to:

• respond to questions and support requests;
• investigate technical issues and bug reports;
• communicate with you about your request;
• protect our legal rights and comply with legal obligations; and
• maintain reasonable business records.

We do not use cycling telemetry processed locally by Plink for these purposes because Timelake does not receive that telemetry.

8. Legal Bases for Processing

Where the General Data Protection Regulation ("GDPR") or similar data protection laws apply, we process personal data only where we have a valid legal basis.

Depending on the circumstances, we may rely on:

Performance of a contract. We may process information where necessary to provide functionality or services you request.

Legitimate interests. We may process personal data where necessary for our legitimate interests, such as responding to support requests, investigating technical issues, and operating and protecting our business, provided those interests are not overridden by your rights and interests.

Legal obligations. We may process personal data where necessary to comply with applicable law or a legally binding request.

Consent. Where required, we may process personal data based on your consent. You may withdraw your consent at any time, without affecting the lawfulness of processing carried out before withdrawal.

We rely on consent for optional Website analytics.

9. Data Sharing

We do not sell your personal data.

We may disclose personal data that Timelake holds only where reasonably necessary:

• to service providers that process information on our behalf and under appropriate contractual obligations;
• to comply with applicable law, a court order, or another legally binding request;
• to establish, exercise, or defend legal claims; or
• in connection with a merger, acquisition, reorganisation, or transfer of all or part of our business.

Because cycling telemetry and App configuration are processed locally by Plink and are not received by Timelake, we do not share that data from our servers.

When you consent to Website analytics, Google receives the analytics information described in section 5 to provide Google Analytics and Google Tag Manager. For more information, see how Google uses information from sites that use its services and the Google Privacy Policy.

10. Data Retention

Cycling telemetry processed by Plink is used locally to provide the App's functionality and is not stored by Timelake on its servers.

App settings and HUD configuration may remain stored on your device until you change them, remove the relevant App data, or uninstall the App, subject to the behaviour of your device and operating system.

If you contact us, we retain your communication and related personal data only for as long as reasonably necessary to respond to your request, maintain appropriate business records, resolve disputes, or comply with legal obligations.

User-level and event-level data in our Google Analytics property is configured to be retained for 14 months. This setting does not necessarily control aggregated reports or information Google processes under its own applicable terms. Analytics cookie durations are described in our Cookie Policy.

When personal data is no longer required, we will delete or anonymise it where reasonably practicable and required by applicable law.

11. Data Security

We use reasonable technical and organisational measures designed to protect personal data that we process.

However, no method of electronic communication or storage can be guaranteed to be completely secure.

The majority of data used by Plink to provide its cycling HUD functionality is processed locally on your device and is not transmitted to Timelake.

12. International Data Transfers

Timelake is established in Lithuania and is subject to European Union data protection law.

If personal data is transferred to a service provider or other recipient outside the European Economic Area, we will use appropriate safeguards where required by applicable data protection law. Google may process Website analytics information outside the European Economic Area under its applicable data protection terms.

13. Your Privacy Rights

If the GDPR or other applicable data protection laws apply to you, you may have rights regarding personal data held by Timelake, including the right to:

• request access to your personal data;
• request correction of inaccurate personal data;
• request deletion of your personal data;
• request restriction of processing;
• object to certain processing;
• receive certain personal data in a portable format, where applicable; and
• withdraw consent where processing is based on consent.

These rights may be subject to conditions and limitations under applicable law.

To exercise your rights, contact us at hello@plink.vision.

Because Timelake does not receive or store cycling telemetry or locally stored App configuration, we cannot access, provide, correct, or delete data that exists only on your device.

If you are located in the European Economic Area and believe that your personal data has been processed unlawfully, you also have the right to lodge a complaint with your local data protection supervisory authority.

In Lithuania, the supervisory authority is the State Data Protection Inspectorate.

14. Children's Privacy

Plink is not specifically directed at children, and we do not knowingly collect personal data from children through user accounts or profiles because Plink does not provide user accounts or profiles.

If you believe that a child has provided personal data directly to Timelake, for example through a support communication, please contact us at hello@plink.vision.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to Plink, our data processing practices, or applicable legal requirements.

When we update this Privacy Policy, we will change the "Last updated" date at the top of the policy.

If changes materially affect how we process personal data, we will provide additional notice where required by applicable law.

16. Contact Us

If you have questions about this Privacy Policy or our privacy practices, or if you wish to exercise your data protection rights, contact us at:

Timelake, UAB Šv. Stepono g. 27B-2
LT-01315 Vilnius
Lithuania

Email: hello@plink.vision