What Does this Privacy Policy Cover?
THELOOPSAI respects your privacy and is committed to protecting your Personal Data. This Privacy Policy applies to information, including Personal Information, THELOOPSAI collects through your use of THELOOPSAI’s Services. By using THELOOPSAI’s Services and accepting the Terms of Service, as applicable, you also agree to this Privacy Policy. If you do not agree to this Privacy Policy, you must not use THELOOPSAI’s Services. The terms “We,” “Us,” “Our,” “TheLoops” or “THELOOPSAI” includes THELOOPSAI and our affiliates. It explains how we may collect, use, and disclose information we obtain through “THELOOPSAI’s Services.” The Privacy Policy is intended to meet our duties of Transparency under the “General Data Protection Regulation” or “GDPR.”
We will post any modifications or changes to this Privacy Policy on this page.
Who We Are
THELOOPSAI, Inc. is the Controller (for the purposes of the GDPR) of your Personal Data (referred to as either THELOOPSAI or TheLoops), “we”, “us,” or “our” in this Privacy Policy).
Our address is: 550 S. Winchester Boulevard, Suite 620, San Jose, CA 95128
How to Contact Us
You can contact us by emailing: security@theloops.ai
What Personal Data We Collect
All the Personal Data we collect, both from you and from third parties about you, is outlined in the table below.
| Category of Personal Data collected | What this means |
|---|---|
| Identity Data | First name, surname, maiden name, last name, company name, title. |
| Contact Data | Work address, billing address, email address, and telephone numbers. |
| Transaction Data | Any details about payments and communications to and from you and other details of subscriptions and services you have purchased from us, including of your transactions with third parties. |
| Marketing and Communications Data | Your preferences in receiving marketing from us and our third parties and your communication preferences. |
| Behavioral Data | Inferred or assumed information relating to your behavior and interests, based on your online activity, including information about your use of the Services. |
| Technical Data | Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website or use our services. |
Aggregated Data
We also collect, use, and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data, but once in aggregated form it will not constitute considered Personal Data for the purposes of the GDPR as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data, which will be used in accordance with this Privacy Policy.
How We Use Your Personal Data and Why
We will only use your Personal Data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your Personal Data for an unrelated purpose, we will update this Privacy Policy and we will explain the legal basis which allows us to do so.
What is our “Legal Basis” for Processing Your Personal Data?
In respect of each of the purposes for which we use your Personal Data, the GDPR requires us to ensure that we have a “legal basis” for that use. Most commonly, we will rely on one of the following legal bases:
- Where we need to perform a contract we are about to enter into or have entered into with you (“Contractual Necessity”).
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your Personal Data for is set out in the table below.
- Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
- Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).
Generally we do not rely on your Consent as a legal basis for using your Personal Data other than in the context of direct marketing communications. We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your Personal Data.
| Purpose | Category(ies) of Personal Data involved | Why do we do this | Our legal basis for this use of data |
|---|---|---|---|
| Account Creation | Identity Data Contact Data | To register you as a new customer. | Contractual Necessity |
| To process payments for subscriptions to the Products and Services. | Identity Data Contact Data Finance Data Transaction Data | To process and deliver your order including manage payments, fees and charges. | Contractual Necessity |
| Fraud Prevention | Identity Data Contact Data | To keep our website, our services and associated systems operational and secure. | Legitimate Interests. We have a legitimate interest in ensuring the ongoing security and proper operation of our services, website and associated IT services and networks. |
| Troubleshooting | Technical Data | To track issues that might be occurring on our systems. | Legitimate Interests. It is in our legitimate interests that we are able to monitor and ensure the proper operation of our Sites and associated systems and services. |
| Marketing | Identity Data Contact Data Marketing and Communications Data. | To determine what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you. | Legitimate Interests. We have a legitimate interest in providing you with updates on our Sites and related offers where you have purchased or shown interest in similar services from us. |
| BetaTrial Subscription | Identity Data Contact Data Marketing and Communications Data Behavioral Data Technical Data | To evaluate you as a potential user of the pre-release software; to establish an account to enable your use; to evaluate interest and actual use of the software. | Legitimate Interests. To indicate an interest in participating in the pre-release software trial and to actually do so; for research and development, to analyze who and how the pre-release software is used. |
What Happens When You Do Not Provide Necessary Personal Data?
Where we need to process your Personal Data either to comply with law, or to perform the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with the functionalities of the Site).
In this case, we may have to stop you using our Services or Site but we will notify you if this is the case at the time.
Personal Data From Third Party Sources
In addition to the Personal Data that we collect directly from you (as described in the section immediately above this one), we also collect certain Personal Data from third party sources. These sources are broken down in the table below, together with a description of whether they are publicly available or not.
| Third-party Data Source | Publicly Available? | Category(ies) or Other Types of Personal Data Received |
|---|---|---|
| Credit Reference Agencies | No | Identity Data Contact Data Transaction Data |
| Social Media Sites | No | Identity Data Contact Data |
| Our Affiliates | No | Identity Data Contact Data Marketing and Communications Data |
| Analytics Providers | No | Behavioral Data Technical Data |
| Advertisers | No | Behavioral Data Technical Data |
| Data Brokers | No | Identity Data Contact Data Behavioral Data Technical Data |
How We Use Cookies and Other Tracking or Profiling Technologies
Cookies
What Are Cookies?
We may collect information using “cookies”. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on our Sites.
We Use Two Broad Categories of Cookies:
- First party cookies, served directly by us to your computer or mobile device; and
- Third party cookies, which are served by our partners or service providers on our Site.
Cookies We Use
Our Sites use the following types of cookies for the purposes set out below:
| Type of Cookie | Purpose |
|---|---|
| Essential Cookies | These cookies are essential to provide you with services available through our Services and Sites and to enable you to use some of its features. For example, cookies allow you to log in to secure areas of some of our Sites. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services. |
| Functionality Cookies | These cookies allow our Sites to remember choices you make when you use our Sites, such as remembering your language preferences, remembering your login details, remembering previously completed form data, and remembering the changes you make to other parts of our Site which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences or contact information every time you visit our Sites. |
| Analytics and Performance Cookies | These cookies are used to collect information about traffic to our Services and Sites and how users use our Services Sites. The information gathered via these cookies does not “directly” identify any individual visitor. However, it may render such visitors “indirectly identifiable” This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access our Sites. The information collected is aggregated and anonymous. It includes the number of visitors to our Sites, the websites that referred them to our Sites, the pages they visited on our Services and Sites, what time of day they visited our Services and Sites, whether they have visited our Sites before, and other similar information. We use this information to help operate our Services and Sites more efficiently, to gather broad demographic information and to monitor the level of activity on our Services and Sites.We use Google Analytics for the above purpose. Google Analytics uses its own cookies. It is only used to improve how our Services and Sites operate: developers.google.com/analytics/resources/concepts/gaConceptsCookies. You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html. |
| Targeted and Advertising Cookies | These cookies track your browsing habits to enable us to show advertising that is more likely to be of interest to you. These cookies use information about your browsing history to group you with other users who have similar interests. Based on that information, and with our permission, third party advertisers can place cookies to enable them to show adverts which we think will be relevant to your interests while you are on third party websites. |
| Social Media Cookies | These cookies are used when you share information using a social media sharing button or “like” button on our Sites or you link your account or engage with our content on or through a social networking website such as Facebook or Twitter. The social network will record that you have done this. |
Disabling Cookies
You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help,” “tools,” or “edit” facility). Many browsers are set to accept cookies until you change your settings.If you do not accept our cookies, you may experience some inconvenience in your use of our Services or Sites or be prevented from using the Services entirely. For example, we may not be able to recognize your computer or mobile device and you may need to log in or re-enter your contact information every time you visit our Sites.
Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org and www.youronlinechoices.com/uk/.
In particular, you can disable cookies which remember your browsing habits and target advertising at you by visiting www.youronlinechoices.com/uk/your-ad-choices. If you choose to remove targeted or advertising cookies, you will still see adverts but they may not be relevant to you. Even if you do choose to remove cookies by the companies listed at the above link, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored adverts from companies that are not listed.
You can also prevent the use of Google Analytics relating to your use of our Sites by downloading and installing the browser plugin available via this link: tools.google.com/dlpage/gaoptout?hl=en-GB
Who We Share Your Personal Data With
The table below describes who we share your Personal Data with, what we share, and why we share it.
We share your Personal Data within THELOOPSAI, Inc.
Many of our external third parties are based outside Europe, so their processing of your Personal Data will involve a transfer of data to countries based outside of Europe.
We endeavor to ensure that people to whom we provide Personal Data hold it subject to appropriate safeguards and controls. Whenever we transfer your Personal Data, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented.
Many of our external third parties are based outside Europe, so their processing of your Personal Data will involve a transfer of data to countries based outside of Europe.
We endeavour to ensure that people to whom we provide Personal Data hold it subject to appropriate safeguards and controls. Whenever we transfer your Personal Data, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented.
- We may transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission. For further details, see European Commission: Adequacy of the protection of Personal Data in non-EU countries.
- Where we use service providers outside Europe, we may use specific contracts approved by the European Commission, which give Personal Data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of Personal Data to third countries.
| Recipients | Category(ies) of Personal Data We Share | Why We Share It | Location(s) |
|---|---|---|---|
| Our Affiliates | Identity Data Contact Data |
Our affiliates help us provide our service and help manage our customer relationships (including providing customer support, customer liaison etc). | Within Europe The United States |
| Service Providers | Identity Data Contact Data Technical Data |
Our service providers provide us with IT and system administration services. | Within Europe The United States |
| Professional advisers | Identity Data Contact Data | Our lawyers, bankers, auditors and insurers provide consultancy, banking, legal, insurance, and accounting services. | Within Europe The United States |
How We Keep Your Personal Data Secure
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used, or accessed in an unauthorized way, altered or disclosed.
We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality.
We have put in place procedures to deal with any actual or suspected Personal Data breach. In the event of any such breach, we have systems in place to work with applicable regulators. In addition, in certain circumstances (e.g., where we are legally required to do so) we may notify you of breaches affecting your Personal Data.
How Long We Store Your Personal Data
We will only retain your Personal Data for so long as we reasonably need to use it for the purposes set out above “How we use your Personal Data and why”, unless a longer retention period is required by law (for example for regulatory purposes).
The table below shows our standard retention practices:
| Category of Personal Data | Retention Period |
|---|---|
| Behavioral Data | For so long as retention is necessary to fulfill the Purposes/Use for which it is used. |
| Identity, Contact, Marketing and Communications Data | For so long as you remain a customer of ours. |
Third-party Links
Our Sites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share your Personal Data. We do not control these third-party websites and are not responsible for their privacy statements. When you leave one of our Sites, we encourage you to read the privacy policy of every site you visit.