Privacy Policy
This Privacy Policy explains how ebats solutions UG (haftungsbeschränkt) and Icecream Ventures GmbH (together "we," "us") process personal data when you use linnx.ai, app.linnx.ai, the Linnx waitlist, and the Linnx product (together, the "Products"). The two companies share operational responsibility for the Products and therefore act as joint controllers within the meaning of Art. 26 GDPR.
1. Joint controllers
The joint data controllers within the meaning of Art. 4(7) and Art. 26 of the General Data Protection Regulation (GDPR) are:
ebats solutions UG (haftungsbeschränkt) Viechtacher Str. 16 10318 Berlin, Germany Amtsgericht Charlottenburg (Berlin) HRB 243939 B E-Mail: privacy@linnx.ai
Icecream Ventures GmbH Charlottenbrunner Str. 2 14193 Berlin, Germany Amtsgericht Charlottenburg (Berlin) HRB 263423 B E-Mail: privacy@linnx.ai
Joint-controllership arrangement. The two companies operate the Products jointly. Each company independently processes personal data for the purposes described below, and both companies share responsibility for ensuring compliance with the GDPR. A joint-controller agreement pursuant to Art. 26(1) GDPR is in place between the parties; the essence of that agreement is reflected in this Privacy Policy, and a summary is available on request at privacy@linnx.ai. You can exercise your rights under the GDPR against either company; we will handle your request jointly regardless of which company you contact. The primary point of contact for data-subject requests is privacy@linnx.ai.
The joint-controller arrangement may be amended on 30 days' notice, including transition to a single controller if one of the two entities is wound down, restructured, or transferred to a successor entity. We will notify you of any material change in the controller structure and update this Privacy Policy accordingly.
1a. Single point of contact
For all data-protection matters (access, rectification, erasure, objection, withdrawal of consent, complaints), write to privacy@linnx.ai. Your request is processed by both joint controllers.
2. What data we collect
2.1 Waitlist data
When you sign up for the Linnx waitlist, we collect:
- Email address
- Name (if provided)
- Product research responses you choose to share (for example, what tools you use today, what problems you want solved)
Legal basis: Art. 6(1)(a) GDPR (consent), and Art. 6(1)(b) GDPR (pre-contractual measures) for managing your place on the waitlist.
2.2 Usage data
When you visit linnx.ai, we may collect:
- IP address (truncated by our analytics tool where possible)
- Browser type and version, device information
- Pages visited, time on site, referral source
- Timestamps
Legal basis: Art. 6(1)(a) GDPR (consent). No analytics data is collected unless you accept the cookie banner. See Section 4.
2.3 Communication data
If you contact us by email, we collect the content of your message, your email address, and any information you voluntarily provide.
Legal basis: Art. 6(1)(b) GDPR (pre-contractual measures or contract performance) or Art. 6(1)(f) GDPR (legitimate interest in responding to inquiries).
2.4 Marketing consent data
If you opt in to marketing communications (for example via our waitlist form), we record:
- Your email address
- The fact that you gave consent and the date and time you did
- The exact text of the consent statement you agreed to (consent version), so we can prove later what you agreed to
- Where appropriate, the UTM source or referral parameters of the page you signed up on
Legal basis: Art. 6(1)(a) GDPR (consent).
2.5 Product data (Linnx app)
When you connect your LinkedIn account and use the Linnx product, we process:
- Authentication data (via Clerk): email, name, OAuth identifiers, session tokens
- LinkedIn account data (via Unipile): messages, connection requests, sent invitations, posts you've published, your connections list, and the metadata associated with each (timestamps, sender names, post engagement counts)
- AI categorisation results: the category tags our AI applies to your messages and connection requests, and the brief AI summaries shown alongside them
- AI Insights conversations: the questions you ask Linnx and the responses generated, retained so you can return to them
- Templates and shortcuts: the saved reply templates you create
- Subscription data (via Stripe): your plan, payment-method last 4 digits and expiry, subscription status, billing history
Data pulled regardless of plan. We sync the full set of LinkedIn account data described above for every connected account, regardless of which plan you are on. Some features built on this data (for example, post analytics) are only made available to you on higher-tier plans. We pull and retain the underlying data continuously so that, if you upgrade, the higher-tier features work immediately and you do not have to wait for a back-fill, and so that historical context is preserved for AI categorisation and Insights. Plan-gated data is not displayed to you outside the features you have access to, and it is never used for any purpose other than providing the Service to you.
Legal basis: Art. 6(1)(b) GDPR (contract performance) for processing strictly necessary to provide the Service, including the continuous sync described above. Art. 6(1)(a) GDPR (consent) for AI Insights conversations and AI categorisation, which you can disable.
2.6 AI processing
To deliver inbox triage, request triage, and AI Insights, message and post content is sent to a Large Language Model. We use Anthropic Claude via AWS Bedrock in the Frankfurt (eu-central-1) region. No content leaves the EU. Anthropic and AWS act as our processors under Art. 28 GDPR; neither retains your content for training purposes.
2.7 Data about your LinkedIn contacts
When you use Linnx, your LinkedIn inbox, connection requests, and connections list contain personal data about other LinkedIn users (your "Contacts"). Contacts are not Linnx users and have not entered into a contract with us. We process Contacts' personal data only to the extent necessary to deliver the Service to you, specifically:
- Storing the content of messages exchanged with your Contacts so you can read and reply to them in Linnx
- Storing connection requests, invitations, and connection metadata so you can manage them
- Applying AI categorisation and summaries to the messages you exchange with your Contacts
- Including post engagement metadata (likes, comments, reactions) where relevant to features you use
Before any Contact data is included in aggregated statistics (see Section 3b), it is irreversibly anonymised within the meaning of Recital 26 GDPR; we do not publish, share, or commercialise data that can identify any individual Contact.
Legal basis: Art. 6(1)(f) GDPR (legitimate interest). The legitimate interest pursued is the operation of an inbox-management product on behalf of our customer (you), whose ability to communicate effectively with their professional network depends on us processing those communications. We have conducted a balancing test and concluded that this processing has a minimal impact on Contacts because (i) the data is data they themselves chose to send to or receive from a LinkedIn user who pays for inbox tooling, (ii) we do not market to Contacts or use their data for purposes outside the Service, and (iii) Contacts can object to processing at any time (see below).
Objection mechanism for Contacts. If you are not a Linnx user but your personal data is being processed because someone you communicate with on LinkedIn uses Linnx, you may exercise the rights set out in Section 7 by writing to privacy@linnx.ai. In particular, you may object to processing under Art. 21 GDPR and request removal of identifying data from our systems. We will respond within 30 days. Note that we cannot delete the underlying LinkedIn message from LinkedIn itself; you may also wish to contact LinkedIn directly.
Customer responsibility. As our customer, you are responsible for ensuring you have a lawful basis under applicable data-protection law for processing your Contacts' personal data through the Service, and for informing your Contacts as required by Art. 13 and 14 GDPR. Our Terms of Service set out this allocation of responsibility in more detail.
3. How we use your data
We use your data to:
- Provide and operate the Linnx product (sync your LinkedIn inbox, categorise and score messages, generate AI summaries and insights, manage your account and subscription)
- Manage your place on the waitlist and notify you about launch and onboarding
- Send you transactional emails (account-related notices, billing receipts, security alerts, waitlist confirmations)
- With your explicit, freely given consent, send marketing communications about Linnx and related products from the joint controllers (see Section 3a)
- Inform our product development using anonymised survey responses and aggregate usage data
- Improve the website (aggregate, anonymised usage analysis)
- Publish anonymised benchmarks, industry insights, and marketing material drawn from aggregated usage of the Service (see Section 3b)
- Comply with legal obligations (tax and commercial record retention)
We do not sell your data. We do not share it with third parties for their own marketing purposes. We do not profile you for advertising. We do not use your LinkedIn message content or account data to train AI models.
3a. Marketing communications
Where you have given explicit consent (Art. 6(1)(a) GDPR), the joint controllers may send you marketing communications by email about Linnx (for example, launch announcements, beta access, product updates). Consent is freely given, specific, informed, and unambiguous. We do not make access to the waitlist or the product conditional on marketing consent. You can withdraw consent at any time by clicking the unsubscribe link in any marketing email we send, or by writing to privacy@linnx.ai. Withdrawal does not affect the lawfulness of processing before withdrawal.
3b. Aggregated and anonymised data
We may collect, aggregate, and use anonymised, aggregated statistics derived from Customer Data and Contact data ("Aggregated Data") — for example, "average reply rate across Linnx users" or "median number of categorised messages per week." Aggregated Data is irreversibly anonymised within the meaning of Recital 26 GDPR and does not contain any information that identifies you, any Contact, or any individual person. Aggregated Data is therefore not personal data and falls outside the scope of the GDPR.
We may use Aggregated Data to improve the Service, publish industry insights and benchmark reports, produce marketing material, and share with our subprocessors as needed to operate the Service. We only publish aggregated statistics drawn from at least 20 users, and only where no individual or organisation can be inferred.
Because Aggregated Data is no longer personal data, we may retain and continue to use it after termination of your subscription or deletion of your account. Aggregated Data also transfers with the business in the event of a corporate change as described in Section 11.
4. Cookies and tracking
4.1 Essential storage
We use the following strictly necessary storage entries that are required for the Products to function. Under Art. 6(1)(b) GDPR and Section 25(2) TTDSG these do not require consent:
- linnx_analytics_consent (local storage): your cookie-banner choice
- linnx_ref / linnx_attribution (cookies): your referral source / campaign (UTM) source, used for first-party attribution only
- Clerk session cookies (
__session,__client_uat, and similar): authentication state for signed-in users on app.linnx.ai. Cleared when you sign out. - __cf_bm (cookie): set by our CDN (Cloudflare) for bot management and security
None of these are used for tracking or advertising. You can change or withdraw your analytics choice at any time via the "Cookie settings" link in the site footer, which reopens the cookie banner.
4.2 No tracking before consent
We do not load any analytics, advertising, or tracking scripts before or without your explicit consent. Any analytics script (see Section 4.3) is only loaded after you click "Accept" on the cookie banner shown on your first visit. If you reject analytics, no tracking scripts are loaded and no data is collected.
4.3 Analytics (PostHog)
We use PostHog (hosted in Frankfurt, EU) for product and marketing analytics, to understand how the Service is used and improve it. Analytics run only after you accept the cookie banner; if you reject, no analytics scripts are loaded and no analytics data is collected.
With your consent, PostHog collects the pages you visit, clicks and similar interaction events, your device and browser metadata, and a truncated IP address. Once you are signed in, we associate these events with your account using your user ID and email address, and PostHog stores an analytics identifier in your browser (cookie or local storage) to recognise repeat visits. We do not record your screen or session (session replay is disabled), and we do not collect analytics on our login, sign-up, payment, or LinkedIn-connection pages.
Legal basis: Art. 6(1)(a) GDPR (consent).
5. Data processors
We use the following third-party service providers (subprocessors) to operate the Products:
| Provider | Purpose | Location | Data processed |
|---|---|---|---|
| Railway | Application and marketing-site hosting | EU | All app data, request metadata |
| Neon | Postgres database | Frankfurt, Germany (EU) | Account data, product data stored in our database |
| Clerk | Authentication | United States (EU-U.S. DPF) | Email, name, OAuth identifiers, session tokens |
| Unipile | LinkedIn API middleware | EU | LinkedIn messages, connection requests, posts, account sessions |
| AWS Bedrock | LLM inference infrastructure | Frankfurt, Germany (eu-central-1) | Inbox content, post content, AI Insights queries (no retention) |
| Anthropic | LLM provider (via AWS Bedrock) | EU only | Same as above; no retention, no training use |
| Stripe | Billing and payment processing | Ireland (EU) and United States (EU-U.S. DPF) | Email, payment method, subscription state |
| cron-job.org | External scheduler | Germany (EU) | Request metadata only (hits cron endpoints) |
| Brevo | Email marketing, transactional email, customer support | Germany (EU) | Email, name, consent record, email content |
| Tally.so | Waitlist and survey forms | Belgium (EU) | Email, name, survey responses |
| Google (Gmail) | Inbound email communication | United States (EU-U.S. DPF) | Email address, message content |
Transfers outside the EU/EEA. Clerk, Stripe, and Google are based in or transfer data to the United States. These transfers are conducted under the EU-U.S. Data Privacy Framework, which provides an adequacy decision by the European Commission (Implementing Decision (EU) 2023/1795). Where applicable, Standard Contractual Clauses (SCCs) are in place as a supplementary safeguard. All other processors above operate within the European Union.
We have entered into Art. 28 GDPR data-processing agreements with each subprocessor listed above.
Changes to subprocessors. We may add, replace, or remove subprocessors from time to time as the Service evolves. We will publish an updated subprocessor list (this Section 5) and notify customers by email at least 30 days before a new subprocessor processes personal data, except where a change is required urgently for security or legal reasons. If you object to a new subprocessor on reasonable grounds related to data protection, you may terminate your subscription (Section 8.1 of the Terms of Service) and receive a pro-rata refund of fees paid in advance for periods after termination.
6. Data retention
| Data type | Retention period | Reason |
|---|---|---|
| Waitlist data | Until product onboarding + 12 months, or until you unsubscribe | Pre-contractual measures, consent |
| Survey responses | 24 months, then anonymised | Product research |
| Marketing consent records | Until withdrawal + 3 years | Proof of consent in case of complaint or audit |
| Marketing mailing list membership | Until withdrawal | Consent (Art. 6(1)(a) GDPR) |
| Usage / analytics data | 90 days | Legitimate interest (site improvement) |
| Communication data | Duration of business relationship + 3 years | Dispute resolution, statute of limitations |
| Account data (Linnx product) | While your account is active; deleted within 30 days of account closure | Contract performance |
| LinkedIn account data (synced via Unipile) | While your account is active; deleted within 30 days of account closure or LinkedIn disconnection | Contract performance |
| AI Insights conversations | Until you delete them, or 30 days after account closure | Consent / contract performance |
| Billing records (Stripe-mediated invoices, receipts) | 10 years | German tax and commercial law (§147 AO, §257 HGB) |
After the retention period, data is deleted or irreversibly anonymised.
7. Your rights
Right of access (Art. 15 GDPR): You may request confirmation of whether we process your personal data and, if so, request a copy of that data.
Right to rectification (Art. 16 GDPR): You may request correction of inaccurate personal data or completion of incomplete data.
Right to erasure (Art. 17 GDPR): You may request deletion of your personal data where there is no longer a legal basis for processing, subject to legal retention obligations.
Right to restriction (Art. 18 GDPR): You may request restriction of processing in certain circumstances, for example while we verify the accuracy of contested data.
Right to data portability (Art. 20 GDPR): You may request your data in a structured, commonly used, machine-readable format (JSON) and have it transmitted to another controller.
Right to object (Art. 21 GDPR): You may object to processing based on legitimate interest (Art. 6(1)(f)). We will cease processing unless we demonstrate compelling legitimate grounds that override your interests.
Right to withdraw consent (Art. 7(3) GDPR): Where processing is based on consent, you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.
To exercise any of these rights, contact us at: privacy@linnx.ai
We will respond within 30 days. If we need more time (up to an additional 60 days for complex requests), we will inform you within the initial 30-day period.
8. Supervisory authority
You have the right to lodge a complaint with a data-protection supervisory authority. The competent authority for our company is:
Berliner Beauftragte für Datenschutz und Informationsfreiheit Friedrichstr. 219 10969 Berlin Germany https://www.datenschutz-berlin.de
9. Security
We implement technical and organisational measures to protect your data, including encryption in transit (TLS 1.3), encryption at rest for our database, access controls, principle-of-least-privilege for staff access, and a Content Security Policy on the website. We regularly review the security posture of our infrastructure and our subprocessors.
Personal data breach notification. If we become aware of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify affected users without undue delay and in any case within 72 hours of becoming aware of the breach, as required by Art. 33 and 34 GDPR. The notification will include the nature of the breach, the categories and approximate number of data subjects and records concerned, the likely consequences, and the measures we have taken or propose to take. Where applicable, we will also notify the competent supervisory authority within 72 hours.
10. Scope of this policy
This policy applies to:
- Visitors to linnx.ai (marketing pages, blog)
- People who sign up to the Linnx waitlist
- Customers of the Linnx product (app.linnx.ai)
- Anyone who contacts us directly
When you connect your LinkedIn account through Linnx, we act as the data controller for the data we process on your behalf to deliver the Service. Specific Art. 28 GDPR processor agreements are in place with each subprocessor listed in Section 5.
11. Transfer in the event of corporate change
In a merger, acquisition, asset sale, restructuring, transfer of business, insolvency, or other corporate change affecting either joint controller, personal data processed under this Privacy Policy may be transferred to the successor entity (for example, a future Linnx GmbH established to operate the Linnx business, or an external acquirer) as part of that transaction.
We will notify you by email and on the Service at least 30 days before such a transfer takes effect, except where the transfer must occur sooner for legal or insolvency reasons, in which case we will notify you as soon as reasonably practicable. The notification will identify the successor entity and the effective date of the transfer.
The successor entity will assume the obligations under this Privacy Policy without change, and your data will continue to be processed for the same purposes and on the same legal bases as before the transfer. If you do not agree to the transfer, you may delete your account before the transfer takes effect; on deletion, your Customer Data will be removed in line with the retention schedule in Section 6.
Aggregated Data, having been irreversibly anonymised, is not personal data and is transferred with the business unchanged.
12. Children
The Service is not directed at individuals under the age of 18. We do not knowingly collect personal data from minors. If we become aware that we have collected data from a minor, we will delete it promptly.
13. Changes to this Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of material changes via email or through the Service at least 30 days before the changes take effect. The "Last updated" date at the top of this page indicates when the most recent changes were made.
14. Contact
For privacy-related inquiries and data-subject requests, write to the single point of contact for both joint controllers:
E-Mail: privacy@linnx.ai
Postal address (primary): ebats solutions UG (haftungsbeschränkt) Viechtacher Str. 16 10318 Berlin, Germany
Postal address (Icecream Ventures GmbH): Icecream Ventures GmbH Charlottenbrunner Str. 2 14193 Berlin, Germany