The engagement data rule
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Why the rule exists#
On our reading of LinkedIn's developer terms (D1 open), the "Restricted uses" page (API version 2026-09) says member data, explicitly including "posts, comments, and reactions", must not be used "to identify sales or marketing prospects or prospective talent for hire, for lead creation, to enhance customer data in a CRM or marketing automation platform, to build an audience list". Three more limits:
- No exporting: member data "can't be exported, distributed, or otherwise transferred from your application (including to your customers)".
- No combining: it "can't be combined with your data, any other LinkedIn data, or any third party data to create, supplement, verify, or append to user profiles, leads".
- Limited audience: data obtained to manage a Page or Profile "may only be displayed to individuals associated with that Page or Profile". A report emailed to 20 people or a client share link may fail this: hence the outputs rule.
Members' social activity may be stored for 48 hours (profile data cached for 24). Reading reactions on personal posts needs a permission granted "to select developers only". Maktura's own records name its engagement data route as a risk, and the route has not been confirmed to the pack's authors.
The approved spoken answer#
To "Where does the engagement data come from?" or "Is that allowed?", say, as written:
Say"Publishing runs through LinkedIn's own connection: we don't ask for your password and we don't hold one. On the engagement side, I'll get you a written answer from our legal team rather than paraphrase it, because your compliance people will want it exactly right."
Then send the question to John Cooper the same day. Tell the buyer you'll confirm when they'll have the answer once John has a date, then do. Go no further: no explaining collection, no discussing LinkedIn's terms, no reassurance of your own. The old answer ("publicly visible activity on public posts...") is retired.
The buyer's own obligations#
If a buyer plans to contact people who engage, say: "How you follow up with people is governed by your own policies and data protection rules. It's worth your compliance team looking at that before you start." Advise no further.