Privacy policy
Effective date: [Effective Date]
This policy explains what personal data [Company Legal Name], [Registered Address] ("we", "us") handles, why, for how long, and what rights you have. Questions go to privacy@[domain]. [Data protection officer or privacy contact, and EU and UK representatives if required.]
1. Two roles
We handle personal data in two different roles.
- As a controller we decide why and how the data is used. This covers the people who sign up and use our website and app (account holders, members, invitees) and visitors to our pages.
- As a processor we handle the data of leads and of the people who write back to them, on the instructions of our customer. The customer is the controller of that data and decides whom to contact and why. The Data processing agreement applies. If you are a lead and want to see, correct or delete your data, or want to stop being contacted, write to the person who contacted you, or to us at privacy@[domain] and we will pass the request on and add you to our do-not-contact list.
2. What we collect
| Data | Whose | Our role | Why |
|---|---|---|---|
| Name, email address, password hash, sign in and two factor settings, role and workspace membership | Account holders and members | Controller | To run your account and keep it secure |
| Billing contact, plan, seat count and payment status (card details stay with our payment provider) | Customers | Controller | To charge for the service |
LinkedIn session cookies (an allowlist: li_at, JSESSIONID, bcookie, bscookie, lidc), the browser's user agent and client hints, the member id and the country | The person who owns a connected account | Processor for the customer | To act on the customer's connected LinkedIn account |
| The profile of the connected account (name, headline, location, tier, connection count, and the date we first saw the account) | The person who owns a connected account | Processor | To show the account and apply safe limits |
| Leads: LinkedIn profile link, profile id, first and last name, company, title, and the extra columns the customer imports | Leads | Processor | To run the customer's campaigns |
| Campaign steps, message templates, the text of messages sent and received, replies and conversation threads | Leads and the customer's users | Processor | To send the customer's messages and show replies in the inbox |
| A record of each action (type, status, time and profile id) | Leads and account owners | Processor, and controller for the budget history | To count limits and keep the account safe |
| Technical and security data: IP address of the connection to our app, request logs without bodies, audit records of sign in and administration | Users and operators | Controller | To secure and operate the service |
| Support messages | Anyone who writes to us | Controller | To help you |
We never collect LinkedIn passwords in the first release. Conversations that belong to no lead or campaign are not copied into the inbox unless the person who connected the account turns that on, and then only that person sees them.
3. How a LinkedIn session is protected
When you connect an account, the extension or the paste page encrypts the cookies in your own browser to the public key of our worker. Our web servers receive only an opaque encrypted block that they cannot open. Only the worker holds the private keys. A new session has no effect until the worker has verified that it belongs to the account you named. Cookie values are never written to logs, error reports, job payloads or the admin console, and the cookies in a replaced or rejected session are deleted. Our worker uses a fixed IP address for each account when it contacts LinkedIn.
4. Why we use data (legal bases)
- To provide the service you asked for: performance of a contract.
- To keep the service and your accounts secure, prevent abuse, and keep the budget history that protects an account from LinkedIn limits: our legitimate interests. We have weighed these against your rights and keep the data to what is needed.
- To meet legal duties, such as tax records and answering lawful requests: legal obligation.
- Where we ask you to agree, such as on the extension's consent screen: your consent, which you can withdraw.
For lead data, the customer chooses the legal basis and tells the lead about it.
5. How long we keep data
These periods are enforced by code and are the same ones the product uses.
| Data | How long | Source in code |
|---|---|---|
| Message text and its hash on the action record | Cleared 30 days after the action finishes, and at once when an account or workspace is deleted | ACTION_TEXT_RETENTION_DAYS is 30 |
| Messages in the inbox | Until the workspace or the account is deleted, unless the workspace chooses to keep them 30, 90, 180 or 365 days, after which older messages are deleted | MESSAGE_RETENTION_CHOICES_DAYS |
| Action records without content (type, status, times, profile id) | While the LinkedIn identity is active and for 24 months after its last action | ACTION_LOG_RETENTION_MONTHS is 24 |
| Stored LinkedIn sessions | Purged 30 days after a subscription ends. Replaced or rejected sessions are cleared at once. Deleted when the account is removed | SESSION_PURGE_AFTER_DAYS is 30 |
| Accounts still connected after the purge | Disconnected 30 days later | DISCONNECT_AFTER_PURGE_DAYS is 30 |
| A deleted workspace | Paused at once and kept for 30 days so the deletion can be cancelled, then purged (WORKSPACE_DELETION_GRACE_DAYS) | Counsel to confirm the wording |
| A deleted lead | The lead, its conversations and messages are deleted, and the lead links on action records are cleared | On request or by the customer |
| Finished background jobs | 7 days (failed jobs 30 days) | FINISHED_JOB_RETENTION_DAYS is 7, FAILED_JOB_RETENTION_DAYS is 30 |
| Extension access token | 90 days, renewed while the account is connected, revoked when it is removed | EXTENSION_TOKEN_TTL_DAYS is 90 |
| Connect links and invitations | 7 days | CONNECT_LINK_TTL_DAYS is 7, INVITATION_TTL_DAYS is 7 |
| Backups | Encrypted, kept for up to 30 days (BACKUP_RETENTION_DAYS), so deleted data can remain in a backup until it expires | Confirm the scheduled dump is running at launch |
| Billing records | As the tax law of [Governing Law] requires |
6. Who receives data
We use the sub-processors listed on the Sub-processors page for hosting, the database, payments, email, error reporting and the IP addresses our worker uses. We do not sell personal data and we do not use it for advertising. We may disclose data to meet a legal duty, to protect rights and safety, or in a sale of the business.
7. Transfers outside your country
Some of our providers process data outside the UK and the European Economic Area. Where that happens, we use the European Commission's standard contractual clauses and the UK addendum, or another lawful transfer mechanism, as set out in the data processing agreement. [Counsel to confirm the regions in the sub-processor table.]
8. Your rights
Depending on where you live, you may have the right to access, correct, delete or move your data, to object to or restrict our use of it, and to withdraw consent. To use a right as an account holder, write to privacy@[domain]. You can also complain to your data protection authority: [Supervisory Authority]. For lead data, ask the customer first.
If you live in California, we do not sell or share personal information, and when we act for a customer we act as its service provider.
9. Security
The measures are summarized on our Security page. They include sealed sessions, strict separation of customers' data, required multi factor sign in for our operators, encrypted backups and audited access. No system is perfectly secure. We tell affected customers without undue delay if there is a breach.
10. Children
The service is for business use and is not directed at people under 18.
11. Chrome extension: Limited Use statement
This section applies to our Chrome extension and to any data it reads.
What the extension reads. After you agree on a consent screen, the extension reads only the cookies on a fixed allowlist (li_at, JSESSIONID, bcookie, bscookie and lidc), your browser's user agent and client hints, and your LinkedIn member id. It gets the member id with one ordinary request to LinkedIn from your own browser. It has no content script on LinkedIn, and it does not read your pages, messages or contacts.
What it does with it. It encrypts the cookies in your browser to the public key of our worker and sends the encrypted block, the key id, the user agent, the claimed member id and a token for that one account to our servers. It refreshes the block when the cookies change, at most once every 15 minutes.
Limited Use. The use of information received through the extension adheres to the Chrome Web Store User Data Policy, including its Limited Use requirements. In particular:
- We use this data only to provide and improve the single purpose that the extension describes in its store listing: connecting your LinkedIn account to the service so that it can act for you at your request.
- We do not transfer this data to others, except to provide that purpose, to comply with the law, or as part of a merger, acquisition or sale of assets with notice to you.
- We do not use or transfer this data for personalized, retargeted or interest based advertising.
- We do not allow people to read this data. Our web servers cannot open it, and our staff cannot see cookie values. The only exceptions are where you ask for support and agree, where it is needed for security, or where the law requires it.
- We do not sell this data and we do not use it to decide credit or lending.
[Counsel to check this wording against the current Chrome Web Store User Data Policy before each listing submission.]
12. Changes and contact
We will post changes on this page and tell account holders about material changes. Contact: privacy@[domain], [Registered Address].