Privacy Policy

Visualfox LinkedIn Personal Data Portability Tool · Effective date: 4 May 2026 · Last updated: 4 May 2026

This Privacy Policy describes how Visualfox (“we”, “us”, “the operator”) processes personal data within its LinkedIn Personal Data Portability Tool (the “Application”), a private, self-hosted application that ingests the operator’s own LinkedIn member data via LinkedIn’s Member Data Portability API (“DMA API”) for personal productivity purposes.

The Application is a single-user, self-use application. It is operated by Visualfox solely for the personal use of its sole operator, Michael Bohl, residing in Zürich, Switzerland. It is not offered as a service to third parties.

1. Data Controller

Visualfox
Michael Bohl
Zürich, Switzerland
Contact: michael@visualfox.ch

2. Scope of this Policy

This policy covers all personal data processed by the Application that originates from the LinkedIn Member Data Portability API. It applies exclusively to the operator’s own LinkedIn member account and to data the operator has lawful access to as the data subject.

3. Categories of Data Processed

The Application ingests the following categories of LinkedIn member data, retrieved exclusively via the official Member Data Portability API endpoints (memberSnapshotDatamemberChangeLogs):

  • Profile data of the operator (own LinkedIn profile, headline, summary, positions, education)
  • Connection data (1st-degree connections of the operator)
  • Messaging history (conversations and messages of the operator)
  • The operator’s own posts, articles, and shares
  • The operator’s own comments
  • The operator’s own reactions and engagement events
  • Items saved by the operator
  • Invitations sent and received by the operator
  • Follows and endorsements relating to the operator

No data of LinkedIn members other than the operator’s own connections (and only as exposed by the DMA API to the operator as data subject) is processed. No data is acquired through scraping, unofficial APIs, or any means outside the authorized DMA API.

4. Purposes of Processing

The data is processed for the following strictly personal purposes:

  • Building a private, searchable knowledge base of the operator’s own LinkedIn history
  • Providing semantic search and recall over the operator’s own messages, posts, and comments
  • Powering a private personal-productivity assistant that supports the operator

The data is never used for advertising, profiling of third parties, resale, redistribution, training of public AI models, or any commercial offering.

5. Legal Basis

Processing is based on the following legal grounds under Swiss data protection law (revFADP) and the EU General Data Protection Regulation (GDPR), where applicable:

  • Art. 6(1)(a) GDPR – the data subject’s consent, granted via the LinkedIn OAuth authorization flow
  • Art. 6(1)(f) GDPR – legitimate interest of the data subject in exercising data portability rights over their own data
  • Art. 20 GDPR and the EU Digital Markets Act (DMA) – the right to data portability of one’s own personal data

The processing operates exclusively within the rights of the data subject (the operator) over their own personal data.

6. Data Storage and Security

  • All data is stored on infrastructure owned and operated by Visualfox (self-hosted).
  • Data is encrypted at rest using industry-standard encryption.
  • Access is restricted to the operator via authenticated, encrypted channels.
  • No data is transferred to cloud providers, external SaaS vendors, or third parties.
  • OAuth credentials and access tokens are stored in encrypted local secret stores.

7. Data Sharing

No personal data processed by the Application is shared with, sold to, or made accessible to any third party. There are no data processors, no sub-processors, and no integrations with external analytics, advertising, or marketing services.

8. International Transfers

All data remains on infrastructure located in Switzerland. No cross-border data transfers occur.

9. Retention

Data is retained for as long as the operator, as data subject, has a continuing legitimate basis to keep their own personal data. Upon any of the following events, the corresponding data is deleted without undue delay:

  • Revocation of the LinkedIn OAuth authorization
  • Deletion or removal of the Application
  • The operator’s decision to delete the local datastore

10. Data Subject Rights

As the sole data subject, the operator can at any time exercise full rights over the data, including:

  • Access and inspection of the stored data
  • Rectification or deletion
  • Withdrawal of consent (by revoking the LinkedIn app authorization at linkedin.com/psettings/permitted-services)
  • Data export or destruction of the local datastore

11. Compliance with LinkedIn’s DMA Portability Terms

The Application is operated in compliance with LinkedIn’s Member Data Portability API Terms. Specifically:

  • LinkedIn data is not combined with third-party datasets in a way that would create derived profiling of LinkedIn members.
  • LinkedIn data is not redistributed in standardized form.
  • LinkedIn data is not used to train public or shared machine learning models.
  • Access to LinkedIn data is strictly limited to the authenticated operator.

12. Cookies and Tracking

This privacy policy page itself does not use cookies, analytics, or trackers. The Application is a backend system without a public web interface and likewise does not use cookies or trackers.

13. Changes to this Policy

This policy may be updated to reflect changes in processing or applicable law. The most recent version is always available at the URL where you are reading this document. Material changes will be reflected in the “Last updated” date at the top of this page.

14. Contact and Complaints

For any questions regarding this policy, contact michael@visualfox.ch.

Data subjects have the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC / EDÖB) or, where applicable, with the competent supervisory authority in their country of residence.


© 2026 Visualfox · Zürich, Switzerland