Legal document

Privacy
Policy

In effect since May 10, 2026. What we collect, why, and how to take back control of your data.

Section 1

Introduction and Data Controller

This Privacy Policy (the “Policy”) explains how LINQFOLIO SAS (“we,” “LINQFOLIO”) collects, uses, processes, and protects your personal data when you use our platform, LinQfolio (the “Platform”).

Data controller

  • LINQFOLIO SAS
  • A Société par Actions Simplifiée (simplified joint-stock company) with capital of €3,000
  • Incorporated on January 6, 2026 by private deed
  • Registered office: 142 rue de Rivoli, 75001 Paris, France
  • Paris Trade and Companies Register (RCS Paris): 102 625 183
  • SIRET: 10262518300011
  • Intra-Community VAT number: FR83102625183
  • Email: dpo@linqfolio.com

We are committed to respecting your privacy and protecting your data in accordance with Regulation (EU) 2016/679 of April 27, 2016 on the protection of natural persons with regard to the processing of personal data (GDPR) and French Law No. 78-17 of January 6, 1978, known as the “Data Protection Act” (Loi Informatique et Libertés).

Section 2

Personal Data We Collect

We collect the following categories of data:

2.1 Data required at sign-up

  • Email address
  • Username/handle
  • Password (stored securely)
  • First and last name (optional)
  • Account creation date

2.2 Content-related data

  • Reviews, write-ups, and ratings of the books you publish
  • Reading lists you create
  • Comments on other users’ posts
  • Photos of books or reading spaces
  • History of your reading activity and interactions

2.3 Technical data

  • IP address
  • Browser type and operating system
  • Pages visited and time spent on the site
  • Session data and cookies
  • Approximate (non-precise) location information

2.4 Communication data

  • Error messages and support requests
  • Correspondence with our support team
  • Notifications and alerts
Section 3

Use of Personal Data

Your data is used for the following purposes:

3.1 Providing the service

  • Create and manage your account
  • Let you publish and share content
  • Display your profile and interactions to other users
  • Handle your requests and complaints

3.2 Improving the Platform

  • Analyze how the Platform is used
  • Develop and test new features
  • Fix bugs and technical issues
  • Optimize performance

Legal basis: Improving the Platform relies on our legitimate interest (Art. 6(1)(f) GDPR) in providing a reliable, high-performing service. Where we implement audience-measurement tools that require non-essential trackers, we apply the required consent rules.

3.3 Communications

  • Send notifications about your account
  • Inform you of updates and changes to the Platform
  • Contact you for support purposes
  • Send you legal or regulatory information

3.4 Security and legal compliance

  • Detect and prevent abuse, fraud, or unlawful conduct
  • Enforce our Terms of Use
  • Comply with legal obligations
  • Protect the rights and safety of our users

Important: LINQFOLIO does not sell your personal data and does not transfer it to third parties for advertising or commercial purposes. Service providers may, however, process certain data on our behalf (hosting, security, support) under contracts governing data processing arrangements (see Sections 5 and 7.4).

Section 4

Legal Basis for Processing

The processing of your personal data relies on the following legal bases:

Method: each purpose is linked to a specific legal basis in our internal records of processing activities. The paragraphs below summarize the most common situations; where several bases are mentioned, the basis that applies depends on the nature of the processing involved (account, security, newsletter, optional trackers, etc.).

4.1 Consent

Where the law requires it (for example, for certain electronic communications or for trackers that are not strictly necessary), we obtain prior consent, granular where relevant, and you may withdraw it at any time without affecting the lawfulness of processing based on other grounds before withdrawal. Account settings and the cookie banner let you exercise these choices where available on the relevant Platform.

4.2 Performance of the contract

Processing is necessary to perform the Terms of Use and to provide the services.

4.3 Legal obligations

We must process certain data to comply with our legal and regulatory obligations.

4.4 Legitimate interests

We process certain data in our legitimate interests, in particular the security of the Platform and the prevention of abuse.

4.5 Data breach notification

In accordance with Articles 33 and 34 of the GDPR, in the event of a personal data breach likely to result in a high risk to your rights and freedoms, LINQFOLIO undertakes to inform you as soon as possible, and to notify the competent supervisory authority (the CNIL, France’s data protection authority) within 72 hours of becoming aware of the breach.

Section 5

Sharing of Data

LINQFOLIO does not sell your personal data and does not transfer it to third parties for their own marketing or advertising purposes.

5.1 Access by service providers and controlled disclosures

Data may be disclosed to service providers acting on our behalf and under our instructions (processors within the meaning of the GDPR), only to the extent necessary for the purpose pursued:

  • Technical service providers: hosting, security, maintenance, customer support, under contracts providing for confidentiality and obligations equivalent to those of the GDPR
  • Legal authorities: where legally required to do so by public authorities (police, courts)
  • Protection of rights: to defend our legal rights or those of our users

5.2 Public data

Your profile, reviews, write-ups, and lists are public by default and visible to other users. Your personal data (email, password) is never shared publicly.

Section 6

Data Retention Periods

Data is retained for the following periods:

6.1 While your account is active

Your account and your data are retained for as long as your account remains active.

6.2 After account deletion

  • Account data: deleted within 30 days of the deletion request, then kept in an intermediate archive for 3 years to comply with legal obligations (the civil statute of limitations)
  • Public content: reviews and write-ups may be retained in anonymized form for statistical and archival purposes
  • Log data / technical logs: retained for 12 months from collection, in accordance with connection-data retention obligations, then deleted
  • Billing data (where applicable): retained for 10 years from the close of the accounting year, in accordance with accounting and tax obligations (Art. L. 123-22 of the French Commercial Code)

6.3 Inactive data

Accounts inactive for more than 24 months may be deleted. A warning will be sent by email before deletion.

Section 7

Data Security

LINQFOLIO implements robust security measures to protect your data:

7.1 Technical measures

  • SSL/TLS encryption for all data transmissions
  • Password encryption in the database (secure hashing)
  • Firewalls and intrusion-detection systems
  • Regular backups and data redundancy
  • Periodic security audits

7.2 Organizational measures

  • Access to data limited to authorized personnel
  • Confidentiality agreements with all service providers
  • Staff training on data protection
  • Incident-response and notification procedures

7.3 Your responsibility

You are responsible for keeping your password confidential. Never share it. Report any unauthorized access immediately to support@linqfolio.com.

7.4 Processors

In accordance with Article 28 of the GDPR, LINQFOLIO ensures that its processors provide sufficient guarantees regarding the implementation of appropriate technical and organizational measures. A data processing agreement compliant with GDPR requirements is entered into with each processor that has access to Users’ personal data.

Section 8

Cookies and Tracking Technologies

We use cookies and similar technologies in accordance with the applicable framework (in particular the CNIL’s guidelines on trackers and the GDPR). Details by name, purpose, and legal basis are aligned with the Cookie Policy of the marketing website when you visit the relevant pages. We do not deploy third-party advertising cookies.

8.1 Consent mechanism (banner)

linqfolio-consent (local storage, exempt from consent): Purpose: remember your answer to the banner, whether you accepted or declined. Without this key, a refusal could not be remembered and you would be asked again on every page. Duration: 6 months, after which we ask again.

8.2 Interface preferences

  • linqfolio-lang (local storage, exempt): Purpose: remember the language you picked, French or English. Duration: persistent until you clear the site's data.
  • linqfolio-theme (local storage, exempt): Purpose: remember the light or dark theme you picked. Duration: persistent until you clear the site's data.

8.3 Internal audience counters (no consent)

Every page view increments counters hosted on our own infrastructure, in Ireland: one row per day and per indicator, a number inside it. Nothing is written to your device — no cookie, no local storage key. No visitor or session identifier is created, no IP address is kept, no individual row exists, and nothing is passed to a third party.

This system therefore processes no personal data at rest: the result is anonymous from the moment it is written, since there were only ever numbers. It meets the conditions the CNIL sets for audience measurement exempt from consent — a single purpose, strictly anonymous results, a scope limited to our site alone, no cross-referencing.

Your IP address reaches our server, as it does for any web request, and is used only to limit automated replays. This mechanism neither writes nor logs it.

8.4 Google Analytics 4 (consent required)

Google Analytics requires cookies and processing by a third party. The CNIL does not grant it the exemption described in 8.3: it is neither loaded, nor executed, nor contacted until you accept on the banner. Before you answer and after a refusal, your browser makes no contact with Google at all.

  • _ga (consent required): Purpose: tell visitors apart, so a returning visit can be recognised and a sign-up connected to the campaign that brought it. Duration: 13 months.
  • _ga_<measurement ID> (consent required): Purpose: keep the state of the current session. Duration: 13 months.

After acceptance, data is processed by Google Ireland Limited acting as a processor, with IP address anonymization. Advertising signals, ad personalization, and sharing with Google's advertising products stay denied at all times, including after you accept. The cookies are cleared immediately if you withdraw your consent.

8.5 Newsletter

The sign-up form uses no cookie. Your address, the page language, and the form's location are recorded with your request, on the basis of the consent you give by submitting it.

8.6 Social networks

The links to our Instagram, TikTok, X, LinkedIn, and Discord accounts are plain outbound links. No pixel, share button, or embedded content from those platforms is loaded on the site: they only see you from the moment you click.

8.7 Managing and withdrawing consent

The Cookie Policy page shows your current answer on Google Analytics and lets you change it in one click, at any time. Withdrawal takes effect immediately and clears the _ga cookies already set. You can also delete all of the site's data from your browser settings.

The counters in section 8.3 come with no refusal option: they keep nothing about you, so there is no trace to access and none to erase.

Reminder: no advertising cookies; no transfer of data to advertising networks for their own purposes.

Section 9

Your GDPR Rights

In accordance with the GDPR, you have the following rights over your personal data:

9.1 Right of access

You may request a copy of the personal data we hold about you; we process the request within the timeframes set out in the GDPR (see Section 9.7).

9.2 Right to rectification

You can correct or update inaccurate or incomplete data through your account settings.

9.3 Right to erasure (“right to be forgotten”)

You may request the deletion of your account and your personal data. See Section 6.2 for details on the retention of public content.

9.4 Right to restriction of processing

You may request that we restrict the processing of your data in certain circumstances.

9.5 Right to data portability

You may request a copy of your data in a readable, structured format.

9.6 Right to object

You may object to the processing of your data for certain purposes, in particular marketing.

9.7 How to exercise your rights

To exercise your rights, write to dpo@linqfolio.com with, for example, the subject line: “GDPR Request, Right of Access,” “GDPR Request, Erasure,” “GDPR Request, Restriction,” etc. We respond without undue delay and, except in complex cases provided for by the regulations, no later than the applicable legal deadline (typically one month from the request, with the possibility of a reasoned extension).

Section 10

International Transfers

LinQfolio hosts its data within the European Union to ensure GDPR compliance.

10.1 Data location

The Platform’s servers are hosted by Amazon Web Services (AWS), in the eu-west-1 region (Ireland), within the European Union. Your data is not transferred outside the EU, except where legally required.

10.2 Exceptional transfers

Should a transfer outside the EU become necessary, we will implement appropriate safeguards (European Commission standard contractual clauses, adequacy decision) in accordance with Articles 44 to 49 of the GDPR.

Section 11

Children’s Data

The Platform is reserved for people aged 16 and over. No one under the age of 16 is permitted to create an account.

This age is higher than the threshold of 15 set by France under Article 8 of the GDPR and Article 45 of the Data Protection Act, below which consent to data processing must be given or authorized by the holder of parental authority. By setting the threshold at 16, LINQFOLIO does not need to obtain parental consent: all of its users validly consent on their own.

11.1 Protection of minors

  • We never use children’s data for marketing purposes
  • Parents or legal guardians may contact us at support@linqfolio.com to exercise their child’s rights
  • Any user can report an account held by someone under 16 from within the app

11.1 bis Procedure applicable to an account held by someone under 16

When LINQFOLIO becomes aware, through a report or by any other means, that an account is held by someone under 16: the account holder is informed by email of the reason for the closure, its effective date, and the option to obtain a copy of their content beforehand; at least fifteen (15) days elapse between this notice and the actual deletion, except where the safety of the person concerned requires immediate action; the profile, posts, comments, and messages are then irreversibly deleted, with only the data that the law requires us to keep being retained, for the period it provides for. The holder of parental authority may exercise the child’s rights at any time by contacting support@linqfolio.com and may lodge a complaint with the CNIL. This procedure applies without prejudice to the right to erasure set out in Article 17(1)(f) of the GDPR, which expressly covers data collected from a child.

11.2 Minors and French / European Union law

For services offered directly to children within the meaning of the GDPR, specific rules may apply. For other users, the minimum age may be higher depending on the country; LINQFOLIO adjusts its age thresholds and mechanisms whenever applicable regulations require parental authorization or notice to holders of parental authority. If there is doubt about a user’s actual age, we may suspend the account while we carry out proportionate checks.

Section 12

Changes to This Policy

LINQFOLIO may amend this Privacy Policy to reflect legal, technical, or organizational developments.

12.1 Notice of changes

  • Material changes will be announced by email and/or in-app notification and published on this page
  • A reasonable notice period will be given before material changes take effect: in the ordinary course of business, at least seven (7) calendar days’ notice, except where a legal obligation or an urgent security measure requires a shorter period (with proportionate notice)
  • For processing based on consent, a material amendment may require us to collect your consent again where the law so requires; absent an objection made in the manner indicated, continuing to use the Platform after the change takes effect may constitute acceptance of the contractual changes only, without prejudice to your rights

12.2 Last updated

This Policy was last updated on May 10, 2026.

Section 13

Contact and Complaints

Data Protection Officer contact information

For any question, GDPR request, or complaint: dpo@linqfolio.com. Please specify the nature of your request in the subject line (e.g., “Privacy,” “Exercising my rights,” “Processing complaint”) to help us route your case.

Acknowledgment or initial response: generally within two business days for routine requests; GDPR timeframes apply to the full response, as indicated in Section 9.7.

Legal information

  • LINQFOLIO SAS, Société par Actions Simplifiée (simplified joint-stock company)
  • 142 rue de Rivoli, 75001 Paris, France
  • Share capital: €3,000
  • Paris Trade and Companies Register (RCS Paris): 102 625 183
  • SIRET: 10262518300011
  • Intra-Community VAT number: FR83102625183

Supervisory authority

If you believe that your GDPR rights have not been respected, you may lodge a complaint with the competent supervisory authority: the CNIL (Commission Nationale de l’Informatique et des Libertés, France’s data protection authority), 3 Place de Fontenoy, 75007 Paris, France (www.cnil.fr).

A question about your data?

Write to us directly.