LKDN Autopilot
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Privacy notice

LKDN Autopilot (lkdnautopilot.com)

Version 1.0, 24 October 2026

Notice given pursuant to Arts. 13 and 14 of Regulation (EU) 2016/679 (GDPR) and to Law of the Republic of San Marino no. 171/2018.

1. In short #

LKDN Autopilot is a subscription service, reserved for professionals and businesses, that works on your LinkedIn account according to the instructions you yourselves give: it searches for the people you have decided to meet, visits their profile, sends a connection request and, if it is accepted, asks one single question. When the person replies, the automation stops and we notify you by email.

In this service we process data of two kinds of people:

We do not sell data. We do not advertise. We do not use profiling cookies. Your LinkedIn password does not reach us: we do not see it and we do not store it.

2. Who we are: the data controller #

For customer data the data controller is:

The Service is sold by the same company through the MigaMATCH store. Data relating to the purchase and to payment are also processed in that context, according to the privacy notice published in the store.

3. Data protection officer and representative in the EU #

Data protection officer (DPO)

Representative in the European Union (Art. 27 GDPR)

4. Which customer data we process #

CategoryWhatWhere it comes from
Purchase and contact datafirst name, last name, email, telephonefrom the purchase, which creates your account
Access dataemail, password (stored only in encrypted form), sign-in sessionfrom you, at the first sign-in
Configuration datadescription of your business, whom you want to meet, your best clients (label, note, LinkedIn address if any), proposed segments and your choices, texts of the invitation note and of the opening question, daily limits, hours, working days, time zone, pause daysfrom you, in the guided setup
Data of your LinkedIn accountconnection status, technical identifier, name, professional headline, number of connections, type of plan (free, paid, Sales Navigator), public profile datafrom LinkedIn, through the technical provider of the connection, after your consent
Summary of your networkonly aggregate counts by sector, seniority level and region, with the sample size and the date. We do not store the list of peoplecalculated from your LinkedIn contacts (section 7.6)
Usage logsactions performed by the Service for your account, outcome, errors, limits applied, acceptances of terms and consents with the date and version of the textgenerated by the Service
Emailthe emails we send you (reply alerts, daily summary, disconnection alerts, subscription status changes) and those you write to us at info@lkdnautopilot.comfrom the Service and from you

We do not collect special categories of data (Art. 9 GDPR) and we do not ask you to enter them. We ask you not to enter them in the free-text fields.

LinkedIn password. The connection to your account takes place on a sign-in page hosted by the technical provider that manages the connection. Your LinkedIn password, verification codes and security answers are typed on that page and do not pass through our systems, our logs or our error-monitoring tools.

PurposeLegal basis
Creating and managing your account, performing the Service, sending the alerts and summaries that are part of the Service, providing supportPerformance of the contract (Art. 6.1.b GDPR)
Using an artificial intelligence model to propose to you draft texts and segments of people to contact, which you edit, approve or rejectPerformance of the contract (Art. 6.1.b)
Complying with legal obligations (tax, accounting, requests from the authorities)Legal obligation (Art. 6.1.c)
Security of the Service, prevention of abuse and fraud, technical and system logs, defence of a right in court, retention of support requestsLegitimate interest of Migastone (Art. 6.1.f)
Respecting the objections of the contacted persons (exclusion list, section 7.5)Obligation to act on the objection (Art. 21 GDPR) and legitimate interest in not contacting again those who have objected (Art. 6.1.f)
Sending you marketing communications about other productsOnly with your separate and revocable consent (Art. 6.1.a). Without consent we do not send them. Service emails are not marketing communications

Providing the purchase and configuration data is necessary to provide the Service. Without them we cannot activate it.

For the purposes based on legitimate interest we have assessed that your interests, rights and freedoms do not override them. You can ask us for information about this assessment by writing to info@lkdnautopilot.com.

Service reserved for professionals. The Service is intended exclusively for professionals and businesses acting in the course of their own business. It is not offered to consumers and consumer protection rules do not apply.

6. Automated decisions #

The Service does not take decisions based solely on automated processing that produce legal effects concerning you or other people, or that similarly significantly affect them (Art. 22 GDPR).

For clarity, this is how the automation works:

Whoever receives a connection request or a message suffers no legal consequence from this contact and can ignore it, decline it or ask us not to be contacted any more.

7. The people the customers choose to contact (the "contacted persons") #

This section is addressed to those who have been contacted and to the customers who use the Service.

7.1 Roles #

For the data of the contacted persons:

The Customer accepts the data processing agreement (appointment as processor) together with the terms of service.

7.2 Which data of the contacted persons we process #

Public professional data from the LinkedIn profile, needed to write a true sentence about the person and to avoid duplicates:

We do not store the Customer's message inbox, we do not archive conversations and we do not store the full content of the profile beyond 30 days. We do not search for or add email addresses or telephone numbers. We do not sell or share the data of the contacted persons and we do not build lists shared between customers: one customer's contacted persons are never visible to another.

When a person replies, the reply may appear in the alert email we send to the Customer. For this reason the text of the reply is also stored in the archive of alert emails, for the same period as the messages (section 7.4).

LinkedIn, as the platform on which the Customer operates, in turn processes its users' data as an independent controller, according to its own terms and its own privacy notice.

7.3 Why: the Customer's legitimate interest #

The legal basis on which the Customer relies is, as a rule, the legitimate interest in developing business-to-business professional relationships (Art. 6.1.f GDPR): a single, targeted contact, based on public professional data, with one single question and no sequence of follow-ups. It is for the Customer, as controller, to verify that this legal basis is valid in its case, to inform the contacted persons (Art. 14 GDPR) and to respond to their requests. The Customer undertakes to do so in the terms of service. This notice is public and can also be consulted by the contacted persons.

7.4 How long we keep the data of the contacted persons #

DataRetention
Records of the contacted persons and history of the messages sent and received (including the text of a reply reproduced in the alert emails)180 days from the last activity concerning the person
Full content of the profile (raw data)30 days
Event log (without the text of the messages), for the Customer's statisticsup to 24 months
Technical events received from the connection provider30 days
Exclusion list (only LinkedIn identifier, reason and date)for as long as needed to respect the objection

At the end of the relationship with the Customer, the data of the contacted persons are returned to the Customer on request and in any case deleted within 90 days (Annex A to the terms of service).

7.5 How to object, request access or erasure #

If you have been contacted and no longer wish to be, you can:

The exclusion list contains only the LinkedIn identifier (or the public address of the profile), the reason and the date. It remains even if your other data are deleted: it serves to avoid contacting you again. The Service checks this list before visiting a profile, not only before sending the invitation, and does not act if it cannot consult it.

For access, rectification, erasure or other rights over the data of the contacted persons, you can contact the Customer who contacted you (the controller) or us. If you write to us, we forward the request to the Customer and, to the extent the Customer's instructions allow, we carry it out. You can also contact the DPO (section 3) and the supervisory authority (section 13).

7.6 The Customer's network #

To propose the segments, the Service reads only once, with the Customer's consent, a limited sample (a few hundred) of the Customer's existing LinkedIn connections and calculates which sectors, seniority levels and regions prevail. Of those people we store only the aggregate counts, never the list. The sample is read only for the time needed for the calculation.

8. To whom we disclose the data #

We do not sell the data. We disclose them only to the parties indicated below, which process the data on our behalf as processors or sub-processors, bound by contract.

PartyWhat it doesWhere
Hetzner Online GmbHhosts the website, the application, the system logs and our mail serversGermany (EU)
Supabase Inc.database and functions of the Servicedata in the EU (Ireland, AWS eu-west-1); functions in European regions. US company: for any access from outside the EU the standard contractual clauses apply
Technical provider of the connection to LinkedInintegration with LinkedIn: connection to the account, reading of profiles, sending of requests and messagesFrance (EU)
Anthropic PBC (Claude)artificial intelligence model for the drafts, the segments and the extraction of the sectorUnited States. Transfer under standard contractual clauses and/or the EU-US Data Privacy Framework; by contract the data are not used to train the models
Our own mail serverssending of alerts and storage of the mail receivedoperated by Migastone on Hetzner infrastructure, Germany (EU)

We also disclose the data to tax, legal and insurance advisers bound by professional secrecy, to judicial, administrative and supervisory authorities when the law so requires, and, in the event of a transfer of the business or of a branch of the business, to the successor, with prior notice.

9. Transfers of data outside the European Union #

The data of the Service are stored on servers located in the European Union (Ireland and Germany). Migastone is established in the Republic of San Marino, which is not a Member State of the EU: access by staff takes place through encrypted channels, and we have designated a representative in the Union (section 3).

Two providers are US companies:

We also adopt technical measures such as encryption in transit and at rest. You can request a copy of the safeguards adopted by writing to info@lkdnautopilot.com.

10. How long we keep customer data #

DataRetention
Account and configuration datafor the duration of the subscription and for 90 days after it ends, then deleted or irreversibly anonymised
Link to the LinkedIn accountsevered at the end of the subscription and after 30 days of pause of the Service. On resumption we ask you to reconnect the account
Event log of the accountup to 24 months, and in any case deleted or anonymised within 90 days from the end of the subscription
System, technical and administrative audit logs12 months
Service and support emails (sent and received, including mail to info@lkdnautopilot.com)24 months. The exception is the reply alert emails, which reproduce the text of a contacted person's reply: 180 days (section 7.4)
Accounting and invoicing data (handled as part of the purchase)10 years from the close of the financial year
Proof of acceptances (terms, appointment as processor, consents)duration of the relationship and 10 years afterwards, to defend a right in court
Data relating to disputesduration of the dispute and 10 years afterwards

On expiry the data are deleted or irreversibly anonymised.

11. Website, cookies and mail archives #

The public website does not use cookies and does not load third-party resources. The application uses only the browser's local storage for the sign-in session, which is strictly necessary. We do not use analytics, advertising or profiling tools. Details in the Cookie policy.

Emails written to info@lkdnautopilot.com are copied into our mail archive, together with the metadata of the attachments (name, type and size, not the content). They are not visible to other customers.

12. Your rights #

For the data of which Migastone is the controller, you can exercise at any time the rights provided for by Arts. 15 to 22 GDPR and by Law no. 171/2018:

How to exercise them. Write to info@lkdnautopilot.com, stating the right you wish to exercise. To avoid handing data over to the wrong person, we may ask you to prove your identity. We reply within one month of the request, extendable by two months if the request is complex. You can also contact the DPO or the representative in the EU (section 3). Exercising the rights is free of charge, except for manifestly unfounded or excessive requests.

13. Complaint to the supervisory authority #

Without prejudice to any other remedy, you have the right to lodge a complaint with the supervisory authority.

14. How we protect the data #

In plain words:

15. Changes to this notice #

We may change this notice, for example because of new rules or new features. The version in force is always the one published on the website, with its number and date. If the change is significant, we notify you by email before it comes into force.

16. Contacts #

LinkedIn is a third-party trademark. LKDN Autopilot is not affiliated with LinkedIn and is not endorsed by it.