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Loops – Privacy Policy for 2023

Introduction

We at Loops (“Loops“, “we” or the Company”) respect your right to privacy. For that reason, we have adopted this privacy policy (the “Privacy Policy”) to explain the way we gather information and our use practices regarding the information we collect from individuals who visit our Website and/or individuals who register to use the Services on behalf of a Customer and/or individuals who interact with us and provide us personal data in the course of our business activities. This Privacy Policy elaborates how we use and/or otherwise process such information. 

Please read this Privacy Policy carefully to understand how we handle your personal information. By accessing or browsing the Website, working with or for us, offering goods or services to us, using any of the services that we provide, or otherwise sharing your personal information with us, you confirm that you have read and understood the terms of this Privacy Policy. 

Our Customers are businesses that use our Services to collect examine and analyse information about their own services and users. Therefore, Customer Data may include, without limitation, Personal Data about data subjects who use the services of our Customers (“End Users“). This information may include, without limitation, name, e-mail address, IP address, phone number, actions they take while using our Customers’ services. We have no control over what types of Personal Data will be disclosed to us in the course of using the Services by our Customers (including whether or not it includes Personal Data). 

We do not collect Personal Data from End Users, whose Personal Data may or may not be incorporated in the Customer Data. Accordingly, this Privacy Policy does not apply to End Users, and we are not responsible for our Customers’ handling of the Customer Data. Our Customers have their own policies regarding the collection, use and disclosure of an End User’s personal information. For more information about how our Customer handles your personal information as an End User, please reach out to the Customer.

Definitions

  1. “Customer” means any company, enterprise, business or other organization that is interested in purchasing the Services and/or is using the Services (including, without limitations, for a trial period). 
  2. “Data Protection Laws” means the GDPR, the laws in the EEA implementing or supplementing the GDPR in the relevant countries, and any other data protection laws applicable to Loops in the scope of Processing Personal Data.  
  3. “Data Subject“, “Controller” “Processor” and “Supervisory Authority” shall have the meaning ascribed to such terms in the applicable Data Protection Laws, mutatis mutandis. 
  4. “GDPR” means General Data Protection Regulation (EU) 2016/679 (as may be amended, replaced or superseded from time to time).
  5. “Information” shall mean Personal Data and Non-Personal Data, together. 
  6. “Non-Personal Data” means any information, data or content that we collect about your use of the Website and/or Services that is anonymous and/or does not personally identify you and/or reveal your specific identity as an individual, and/or cannot be attributed to you (such as device information, clicks, time spent on the Website, etc.). 
  7. “Personal Data” shall have the meaning ascribed to it under the applicable Data Protection Laws (such as email address, phone number, name, etc.).
  8. “Services” Loops, AI-Augmented product growth and analytics platform designed to provide customers with data analytics and data science support services
  9. “Customer Data” means the Personal Data that may be disclosed or shared with  Loops in the course of providing the Services to the Customer, for which Loops may serve as a Processor (including, without limitation, during the trial period). 
  10. “User Data” means any Personal Data that Customer’s User provides Loops in the course of Loops’ business activities.  
  11. “Customer’s User” – means the individual who is using the Services on behalf of the  Customer. 
  12. “You” or “User” –  means Visitor or Customer User.
  13. “Visitor” – means an individual who is using the Website.
  14. “Website” – Our website which is located at getloops.ai
  15. “Website Data” – means any Personal Data a Visitor submits and/or otherwise uploads to the Website in order to contact us for any purpose. 

Personal Data do we collect about you

We collect and/or process two types of data and information: Personal Data and Non-Personal Data. As for Personal Data, the collection is further divided into three parts: Website Data, User Data and Customer Data. In any event, with respect to Website Data and Customer Data, the collection of Information commences on your first use of the Website and/or the Services (respectively), and with respect to User Data, the collection of Personal Data commences on your first interaction with Loops in the respective business activity. 

Personal information that you give to us.

Except as otherwise indicated below, the personal information you provide is such that we need in order to provide the Services. If you do not provide us with the requested personal information, we would not be able to do so. You may provide us with Personal Data as detailed below:  

  1. As a Visitor to the website – If you are a Visitor to our Website, we receive and store any information you knowingly provide to us when you fill any online forms on the Website, in order for us to communicate with you and provide you information about our products and services at your request. The Personal Information you may provide us on the Website includes: “Contact Information”, which includes your name, email, phone, business/organization. You may also provide information through the “free text” section in the contact form. Please do not provide any information that is not necessary in order to contact you.
  2. As a Customer – As a Customer, you may disclose to us various categories of personal information, such as information about your End Users, customers, employees or suppliers. This means that in providing the Services to Customers, we may process on behalf of Customers Personal Data they choose to share with Loops or grant us access to in the course of using our Services. The processing of Personal Data included in the Customer Data is governed by the applicable agreement between us and the Customer. 
  3. As a Customer’s User – User Data that you provide in the course of Loops’ business activities. In the course of our day-to-day business activities, we may collect and/or User may provide us with certain User Data in the scope of participating in our conventions, business meetings, registration to our marketing mailing list, etc., such as the User’s contact details (full name, e-mail address, phone number, User’s position/role) 

Non-Personal Data that we collect automatically 

In addition to the categories and types of Personal Data described above, our web servers may automatically collect Non-Personal Data which may include (by way of a non-exhausting list) website usage information from you when you visit and/or otherwise use our Website. Website usage information informs us about how visitors and subscribers use and navigate the Website, including the number and frequency of users to each web page, their IP address, the length of their stays, operating system version, browser type, etc. See further information below under “Information Gathering Tools”; 

How Do We Collect Information

  1. We collect Website Data through your entry, access and/or use of the Website and/or otherwise provided to us voluntarily. Further, we may receive access to Customer Data may by the Customer through the Services, in the course of using the Services. Personal Data collected and/or generated by us may be collected via Information Gathering Tool and we may also generate Non-Personal Data by using Information Gathering technological Tools as set forth below.
  2. Information Gathering Tools. We use commonly-used information-gathering tools, such as cookies and web beacons, to collect information as you navigate our Website (“Information Gathering Tools”). This section describes the types of Information Gathering Tools used on our Website and how this information may be used. We do not currently recognize automated browser signals regarding tracking mechanisms, which may include “Do Not Track” instructions.
    1. Cookies. We use cookies to make interactions with the Website easy and meaningful. When you visit the Website, our servers send a cookie to your computer. Standing alone, cookies do not personally identify you; they merely recognize your Web browser. Unless you choose to identify yourself to us, either by responding to a promotional offer, opening an account, or filling out a Web form, you remain anonymous to us. We use cookies that are session-based and persistent-based. Session cookies exist only during one session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer. Your choice: you may change your cookie settings at any time, but please note that if you disable your Web browser’s ability to accept cookies, you will be able to navigate our Website, but some features of the Services may not work. 
    2. IP Addresses. When you visit the Website, we collect your Internet Protocol (“IP”) addresses to track and aggregate Non-Personal Data. For example, we use IP addresses to monitor the regions from which customers navigate the Website. We also collect IP addresses from Customers when they log into the Services
  3. Information collected by cookies and similar technologies is treated as Non-Personal Data, except to the extent under local law IP addresses (or like identifiers) are otherwise considered Personal Data.
  4. We participate in behavior-based advertising, which means that a third party uses technology such as cookies to collect information about your use of our Website so that they can provide advertising about products and services tailored to your interests on our Website, or on other websites.

How We Use Your Personal Information 

  1. We use Website Data for the following main purpose:
    1. To allow you to access and use the Website;
    2. To ensure that the Website is functioning correctly and to monitor, and improve the Website;
    3. To provide support and respond to you with the information that you request from us;
    4. Create statistical information and learn about the preferences of Users and general trends on the Website (e.g. understand which features are more popular than others); 
    5. To improve and personalize your user experience; and  
    6. Keep the Website safe and secure and for the prevention of fraud.
  2. We process User Data and Customer Data for the following main purposes:
    1. Provide the Services to Customers in accordance with the applicable Customer agreements, and carry out our obligations arising from our agreement(s) with the Customer.
    2. To communicate with you regarding the Services as a Customer User, including by sending you Services’ announcements, technical notices, updates, security alerts, and support and administrative messages; 
    3. To send you certain communications (including by email or post) about our services such as service announcements and administrative messages and call you in relation thereto. 
  3. In addition, we may use Personal Data (whether as Website Data or Customer Data) for the following main purposes:
    1. To contact only a Customer’s User (including by email or post) with information about our products and services which either you request or which we feel will be of interest to you.  
    2. For internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research and development, and identifying and implementing business efficiencies.
    3. To comply with any procedures, laws, and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so.
    4. To establish, exercise, or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so.

Our legal justification for using your personal information

We will only use your personal information for the purposes set out in this Privacy Policy where we have a “legal basis” for handling it.  This means that at least one of the following conditions applies in each situation where your personal information is used by us:  

  1. Our use of your personal information is necessary to perform our obligations under any contract with you (for example,  provide you with the services that you have requested); or
  2. Our use of your personal information is necessary for complying with our legal obligations: for example, if we are requested to disclose your personal information to regulatory bodies or law enforcement authorities; or
  3. For Non-EU Users (excluding California residents): by entering, connecting to, accessing or using the Website and/or the Services or by providing User Data or any other Personal Data, you hereby provide your informed consent to the collection, use and process of your Personal Data incorporated in the Website Data and/or the Customer Data and/or User Data (including the transfer of your Personal Data to third parties) for the purposes and the terms as specified in this Privacy Policy.
  4. For Users in the EU: 
  1. As for Website Data and/or User Data: We only process Personal Data where we have a legal basis to do so. The legal basis will depend on the reason or reasons we collected and need to use the Website Data and/or User Data. The legal basis for processing Website Data and/or User Data will be: (a) to comply with our contractual obligations with the Customer with respect to the provision of the Services to the extent such obligations involve the Website Data and/or User Data) and/or to address your query (whether in the Website or in any other means – for example, in business meetings, for sending you newsletters, etc.); (b) there is a legitimate interest to process the Website Data (for example, to identify and prevent abuse of the Website or the Services, to improve the Services); (c) To comply with a legal obligation that applies to us (for example, to disclose information to authorities). 
  2. As for Customer Data: The Customer Data that we process is owned and controlled by the Customer, who is the Controller of such information, and may only act as a Processor on behalf of the Customer. We may process the Customer Data in accordance with the provisions of our agreement (or Data Processing Addendum to be entered into between Customer and us. The Customer initiates the collection of Customer Data, determines from whom to collect such data, defines what data to collect and how to use the collected Customer Data. As such, the lawful basis for the processing of Customer Data has been determined exclusively by the Customer. For further queries with respect to the Customer Data and the lawful basis of its processing, please review the Customer’s privacy policies and/or contact the Customer.

Sharing of Information collected

If you use our Service as a Customer’s User, please note that we do not share the personal information that you provide us with third parties without your consent, except as described below:  

  1. Service Providers. We may share information with our contracted service providers (such as cloud vendors, advertisers, partners, billing service providers, companies that provide analysis and processing activities, messaging services, etc.) so that these service providers can provide services on our behalf. Unless described in this Privacy Policy, we do not share, sell, rent, or trade any information with third parties for their promotional purposes.
  2. Affiliates. To facilitate our global operations, in order to help us improve the content of the Website and to provide you with the Services requested, we may transfer the collected information to our affiliates worldwide, provided that the receiving entity will comply with this Privacy Policy. 
  3. Business Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your Personal Data and other information may be transferred to a successor or affiliate as part of that transaction along with other assets.
  4. Official Authorities. We may need to disclose Personal Data in response to lawful requests by public authorities or law enforcement officials, including meeting national security or law enforcement requirements. We cooperate with government and law enforcement officials to enforce and comply with the law.
  5. Other Disclosures with Your Consent.  We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.
  6. Any third party we consider that it is in our legitimate interests to do so for internal administrative purposes, for example: ensuring consistent and coherent delivery of services to our customers, corporate strategy, compliance, auditing and monitoring, research and development and quality assurance.

Please note that we will never use or share the Personal Data of End Users that we may be granted access to.

International transfer of Personal Data

To facilitate our global operations, we may transfer and process your Personal Data from around the world, according to the terms herein: 

  1. For EU Users: Please note that Personal Data might be stored on secured servers located in countries outside the EEA. In order to keep your Personal Data safe, we apply strict safeguards when transferring it outside the EEA, which may include the following: (a) Transferring Personal Data to countries approved by the European Commission as having adequate data protection laws; (b) Entering into standard contracts that have been approved by the European Commission and which provide an adequate level of high-quality protection, with the recipients of Personal Data (standard contractual clauses); (c)complying with other specifically approved safeguards for data transfers (as recognized under EU Data Protection Laws and/or a European Commission finding of adequacy.
  2. For Non-EU Users: Personal Data is stored on secured servers located in countries outside of your jurisdiction, which may not be considered to offer an adequate level of protection as exists under your local laws. By providing us Personal Data in the course of our business activities as detailed above, and/or by submitting your Personal Data through the Website and/or in the Services, you hereby acknowledge, and provide your informed consent to such transfer, storing and/or processing of your Personal Data in such locations.

Your Rights

  1. Your rights with respect to Customer Data: As stated above, with respect to Customer Data, Loops may serve as a Processor or Service Provider (where applicable).  Accordingly, we have no control over what types of Personal Data will be disclosed to us or we will be granted access to in the course of the Customer’s use of the Services (including whether or not it includes Personal Data). We do not collect Personal Data from Data Subjects whose Personal Data may or may not be incorporated in the Customer Data, and have no contact with them (such as “End Users” as described above). Therefore, we are not able to communicate with any Data Subjects and/or grant them any rights. As a result, when a Customer or prospective customer shares Personal Data, the Customer or prospective customer is solely responsible for satisfying all legal obligations owed directly to the Data Subject to applicable Data Protection Laws. We are not responsible for Customers’ or prospective customers’ privacy policies or practices or for the Customers’ or prospective customers’ compliance with such policies or practices. We do not review, comment upon, or monitor Customers’ or prospective customers’ privacy policies or their compliance with such policies. We also do not review instructions or authorizations provided to us to determine whether the instructions or authorizations are in compliance with, or conflict with, the terms of a Customer’s or prospective customer’s published privacy policy or of any notice provided to Data Subjects. Customers and prospective customers are responsible for providing instructions and authorizations that comply with their policies, notices, and applicable laws. If you wish to execute your rights regarding Customer Data, please contact the Customer. 
  2. Your rights with respect to User Data and/or Website Data and/or any other Personal Data you provide us (excluding Customer Data): We hereby inform you of the following rights with respect to the processing of your Personal Data incorporated in the Website Data. Please note that these rights may differ, dependent on your jurisdiction:
  1. You may request access to your Personal Data. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you. Note that California residents may be entitled to ask us for a notice describing what categories of personal information (if any) we share with third parties or affiliates for direct marketing.
  2. You may have the right to have your Personal Data rectified (where applicable, if required by law), to the extent it is incorrect, incomplete or not processed in compliance with applicable Data Protection Laws;
  3. You may request that we delete your Personal Data.  If required by law, we will grant a request to delete information; 
  4. You may have the right of data portability of some of your Personal Data to other controllers. 
  5. In some circumstances, you have the right to object to or withdraw consent (where the legal basis for processing is consent). 
  6. Under certain circumstances, you may have the right to object to the processing of your Personal Data due to your particular situation. 
  7. If you reside in the EU, you have the right to lodge a complaint before the applicable Supervisory Authority of your jurisdiction.
  8. If you wish to exercise any of your rights, please contact us at:support@getloops.ai.We will act in accordance with the applicable Data Protection Laws, in order to comply with your request. Note that, as required by law, we will require you to prove your identity. We may also ask you to provide a signed declaration confirming your identity. Following a request, we will use reasonable efforts to supply, correct or delete personal information about you in our files.

Protecting Your Information

  1. We are committed to protecting the security of Personal Data. We use a variety of administrative, technical, and physical security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. We will not give, sell, rent, share, or trade any Personal Data about you to third parties or provide your Personal Data, including your name or electronic mail address, to third parties except as provided herein, or required by law, subpoena or court order. While we strive to protect your Personal Data, we cannot ensure or warrant that the Personal Data or private communications you transmit to us will always remain private and will not be illegally accessed, and accordingly, you assume all risk associated therewith and agree that we will not under any circumstances be liable to you in respect thereof. In the event that we are required by law to inform you of a breach to your Personal Data we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
  2. You may access your account information and our Services only through the use of an individual user ID and password. To protect the confidentiality of Personal Data, you must keep your password confidential and not disclose it to any other person. Please advise us immediately if you believe your password has been misused. If you have any questions about the security of your Personal Data, you can contact us at support@getloops.ai

Links to Other Websites

Our Website may contain links to other websites that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other websites or third parties. We encourage you to be aware when you leave our Website and to read the privacy statements of each and every website that may collect Personal Information.

Retention

  1. We retain different types of information for different periods, depending on the purposes for processing the data. We may retain Personal Data for as long as necessary in order to support our legitimate business purposes, for example, for storing data, documentation, cyber-security management purposes, legal proceedings and tax issues. 
  2. We may store aggregated Non-Personal Data without a time limit. In any case, as long as you use the Website and/or the service, we will keep information about you, unless we are legally required to delete it, or if you exercise your rights to delete the information.

Changes to this Privacy Protection Policy

This Privacy Policy may change from time to time. If we decide to change our Privacy Policy, we will post a new privacy policy on our Website accompanied by a notice indicating that some changes have been made. The new privacy policy will be effective from the date mentioned on the bottom page of the new policy. Your continued use of the Website and/or the Services after we post such notice constitutes your agreement to any such changes. Where such changes will require your specific consent, we shall obtain it before applying the changes to the processing of your Personal Information.

Our policy towards children

The Website and/or Services are intended for use by adults. However, we have no control over the age of Users who visit our Website. Therefore, if you are under the age of 18, please do not submit any Personal Data through the Website unless your parent or legal guardian has approved. 

Contacting Us

Questions regarding this Privacy Policy or the information practices of the Website should be directed to: support@getloops.ai.

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