Page Insights Joint Controller Addendum (the “Addendum”)
Applicability, Parties, and Definitions
This Addendum sets out the responsibilities of LinkedIn and You with respect to the processing of Page Insights.
This Addendum applies if personal data relating to Members in the European Economic Area or Switzerland is processed when generating Page Insights from, and relating to, Your Page. LinkedIn Ireland Unlimited Company (“LinkedIn”) provides Page Insights to You, and You and LinkedIn are joint controllers of such Page Insights for the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679, “GDPR”).
This Addendum is an addendum to (and incorporated into) the LinkedIn Pages Terms. Capitalized terms have the meaning set forth in the LinkedIn Pages Terms, unless otherwise defined in this Addendum. The terms “controller”, “data subject”, “joint controller”, “personal data” and “supervisory authority” in this Addendum have the meanings set out in the GDPR.
Information on Page Insights and Data Subject Rights
When a Member visits, follows or engages with the Page, LinkedIn processes personal data to provide Page Insights to You. In particular, LinkedIn will process data that was provided by the Member to LinkedIn, such as job function, country, industry, seniority, company size, and employment status data from a Member’s profile. Additionally, LinkedIn will process information on how a Member has interacted with your Company page, e.g., whether a Member is a follower.
LinkedIn only processes and retains personal data for Page Insights in accordance with its User Agreement and Privacy Policy.
Page Insights provided to You consist of aggregated data and, notwithstanding any joint controller status, LinkedIn will not provide You personal data of Members with regard to Page Insights or enable You to link Page Insights back to individual Members.
LinkedIn ensures the security of the processing of Member data and providing Page Insights by implementing appropriate technical and organisational measures; more information can be found here: https://security.linkedin.com/.
Members can exercise their data subject rights through their account settings or by reaching out directly to LinkedIn
Responsibilities
LinkedIn agrees to take responsibility under the GDPR for the provision of Page Insights and will comply with all applicable obligations under the GDPR with respect to its processing of Page Insights (including, but not limited to, Articles 12-22 and Articles 32-34 of the GDPR). This means that LinkedIn will, among other things, ensure that Members are informed about the data being processed and support Members’ right to access and deletion. LinkedIn decides in its sole discretion how to comply with its obligations under this Addendum.
You must comply with applicable legal obligations including any obligations arising under the GDPR from Your use of the Page Insights.
Requests
If You are contacted by a data subject or a supervisory authority under the GDPR (or other applicable law) with regard to the processing of Page Insights and/or the obligations assumed by LinkedIn and You under this Addendum (each such contact, a “Request”), You will notify LinkedIn immediately and in any event within three working days by filling out the following form and You will provide LinkedIn with all information we reasonably require in relation to such Request.
LinkedIn will answer Requests in accordance with our obligations under this Addendum, the GDPR, and other applicable law. You agree to take all reasonable efforts to cooperate with LinkedIn in a timely manner in answering any such Request.
Additional Terms
You acknowledge that the lead supervisory authority for data processing under this Addendum is the Irish Data Protection Commission. You agree that the laws of Ireland, without recourse to its conflict of law provisions, will govern this Addendum and You irrevocably submit to the exclusive jurisdiction of the courts of Ireland for the purpose of litigating any claim, cause of action or dispute You have against LinkedIn that arises out of or relates to this Addendum and/or the Page Insights.