Privacy Policy

Last updated: 31 October 2021

Louper.io Ltd Privacy Policy

At Louper, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.

Remember that your use of Louper's Services is at all times subject to our Terms of Service, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Service.

What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. "Personal Data" means any information that identifies or relates to a particular individual and also includes information referred to as "personally identifiable information" or "personal information" under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don't own or control or people we don't manage.

Personal Data

Categories of Personal Data We Collect

Profile or Contact Data

Examples of personal data we collect: First and last name, Email, Phone number, Unique identifiers such as hashed passwords, Company affiliation, Location

Categories of third parties with whom we share this personal data: Service Providers; Advertising Partners; Business Partners; Parties You Authorize; Access or Authenticate

Device/IP Data

Examples of personal data we collect: IP address; Device ID; Domain server; Type of device/operating system/browser used to access the Services

Categories of third parties with whom we share this personal data: Service Providers; Advertising Partners; Business Partners; Parties You Authorize; Access or Authenticate

Web Analytics

Examples of personal data we collect:  Web page interactions; Referring webpage/source through which you accessed the Services; Non-identifiable request IDs; Statistics associated with the interaction between device or browser and the Services

Categories of third parties with whom we share this personal data: Service Providers; Advertising Partners; Business Partners; Parties You Authorize; Access or Authenticate

Consumer Geographic Data

Examples of personal data we collect:  Zip Code

Categories of third parties with whom we share this personal data: Service Providers; Advertising Partners; Business Partners; Parties You Authorize; Access or Authenticate

Professional or Employment-Related Data

Examples of personal data we collect:  Job Title

Categories of third parties with whom we share this personal data: Service Providers; Advertising Partners; Business Partners; Parties You Authorize; Access or Authenticate

Geolocation Data

Examples of personal data we collect:  IP-address-based location information GPS data

Categories of third parties with whom we share this personal data: Service Providers; Advertising Partners; Business Partners; Parties You Authorize; Access or Authenticate

Inferences Drawn From Other Personal Data Collected

Examples of personal data we collect:  Profiles reflecting user attributes Profiles reflecting user behavior

Categories of third parties with whom we share this personal data: Service Providers; Advertising Partners; Business Partners; Parties You Authorize; Access or Authenticate

Other Identifying Information that You Voluntarily Choose to Provide

Examples of personal data we collect:  Identifying information submitted by you to the Services, or in emails or messages you send us Survey responses Content you upload to the Services

Categories of third parties with whom we share this personal data: Business Partners Parties You Authorize, Access or Authenticate

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

You

When you provide information directly to us.

When you create an account or use our interactive tools and Services.

When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.

When you send us an email or otherwise contact us.

When you use the Services and such information is collected automatically.

Through Cookies (defined in the "Tracking Tools, Advertising and Opt-Out" section below).

Vendors

We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.

We may use vendors to obtain information to generate leads and create user profiles, or otherwise in connection with sales and marketing efforts.

Advertising Partners

We receive information about you from some of our vendors who assist us with marketing or promotional services related to how you interact with our websites, applications, products, Services, advertisements or communications, including vendors who provide services related to customer messaging, surveying, advertising, marketing, social media, and analytics.

We receive information about you from third parties when you participate in our referral and promotional codes programs.

Our Commercial or Business Purposes for Collecting Personal Data

Providing, Customizing and Improving the Services

• Creating and managing your account or other user profiles.

• Processing orders or other transactions; billing.

• Operating and maintaining our features and Services.

• Providing you with the products, features, services or information you request.

• Meeting or fulfilling the reason you provided the information to us.

• Providing support and assistance for the Services.

• Responding to user inquiries.

• Improving the Services, including testing, research, internal analytics and product development.

• Providing and monitoring the effectiveness of the Services.

• Personalizing the Services, website content and communications based on your preferences.

• Remembering information so that you will not have to re-enter it during your visit or the next time you visit the Services;

• Monitoring aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website and our Services;

• Maintaining interoperability with third party services.

• Doing fraud protection, security and debugging.

• Diagnosing or fixing technology problems.

• Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the "CCPA").

Marketing the Services

• Marketing and selling the Services.

• Showing you advertisements, including interest-based or online behavioral advertising.

Corresponding with You

• Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Louper or the Services.

• Sending emails and other communications according to your preferences or that display content that we think will interest you.

Meeting Legal Requirements and Enforcing Legal Terms

• Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
• Protecting the rights, property or safety of you, Louper or another party.
• Enforcing any agreements with you.
• Responding to claims that any posting or other content violates third-party rights.
• Resolving disputes.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.

How We Share Your Personal Data

We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a "sale" of your Personal Data. For more information, please refer to the state-specific sections below.

Service Providers

These parties help us provide the Services or perform business functions on our behalf. They include:

• Hosting, technology and communication providers.
• Security, spam, and fraud prevention consultants and providers.
• Analytics providers.
• Monitoring service providers.
• Data management platforms.
• Support and customer service vendors.
• Product fulfillment and delivery providers.
• Payment processors.

Advertising Partners

These parties help us market our services and provide you with other offers that may be of interest to you. They include:

• Ad networks.
• Marketing partners and providers.

Business Partners

These parties partner with us in offering various services. They include:

• Businesses that you have a relationship with.
• Companies that we partner with to offer joint promotional offers or opportunities.

Parties You Authorize, Access or Authenticate

• Third parties you access through the services.
• Social media services.
• Other users.

Legal Obligations

We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under "Meeting Legal Requirements and Enforcing Legal Terms" in the "Our Commercial or Business Purposes for Collecting Personal Data" section above.

Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

Data that is Not Personal Data

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.

Tracking Tools, Advertising and Opt-Out

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, "Cookies") to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data-- usually text files -- placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support "Do Not Track" requests sent from a browser at this time.

We use the following types of Cookies:

Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable. Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region). Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services' content for those who engage with our advertising. For example, Google Inc. ("Google") uses cookies in connection with its Google Analytics services. Google's ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google's use of Cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/. Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled "Information about Interest-Based Advertisements."

You can decide whether or not to accept Cookies through your internet browser's settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.

To explore what Cookie settings are available to you, look in the "preferences" or "options" section of your browser's menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union.

Information about Interest-Based Advertisements

We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors ("Interest-Based Ads"). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users' activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a "web beacon") from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.

We comply with the Digital Advertising Alliance ("DAA") Self-Regulatory Principles for Online Behavioral Advertising. Through the DAA and Network Advertising Initiative ("NAI"), several media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of, and greater control over, ads that are customized based a consumer's online behavior across different websites and properties. To make choices about Interest-Based Ads from participating third parties, including to opt-out of receiving behaviorally targeted advertisements from participating organizations, please visit the DAA's or NAI's consumer opt-out pages, which are located at http://www.networkadvertising.org/choices/or http://www.aboutads.info/choices. Users in the European Union should visit the European Interactive Digital Advertising Alliance's user information website http://www.youronlinechoices.eu/.

Data Security and Retention

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanisms; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services, and for an additional two years or until we receive a request to delete it. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Personal Data of Children

As noted in the Terms of Service, we do not knowingly collect or solicit Personal Data about children under 16 years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at support@louper.io.

European Union Data Subject Rights

EU Residents

If you are a resident of the European Union ("EU"), United Kingdom, Lichtenstein, Norway or Iceland, you may have additional rights under the EU General Data Protection Regulation (the "GDPR") with respect to your Personal Data, as outlined below. For this section, we use the terms "Personal Data" and "processing" as they are defined in the GDPR, but "Personal Data" generally means information that can be used to individually identify a person, and "processing" generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Louper will be the controller of your Personal Data processed in connection with the Services. If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at support@louper.io. Note that we may also process Personal Data of our customers' end users or employees in connection with our provision of certain services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.

Personal Data We Collect

The "Categories of Personal Data We Collect" section above details the Personal Data that we collect from you.

Personal Data Use and Processing Grounds

The "Our Commercial or Business Purposes for Collecting Personal Data" section above explains how we use your Personal Data.

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our "legitimate interests" or the legitimate interest of others, as further described below.

Contractual Necessity: We process the following categories of Personal Data as a matter of "contractual necessity", meaning that we need to process the data to perform under our Terms of Service with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.

• Profile or Contact Data
• Payment Data
• Commercial Data

Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties:

• Profile or Contact Data

• Device/IP Data

• Web Analytics

• Consumer Demographic Data

• Professional or Employment Related Data

• Geolocation Data

• Inferences from Other Personal Data Collected

• Other Identifying Information that You Voluntarily Choose to Provide

• We may also de-identify or anonymize Personal Data to further our legitimate interests.

• Examples of these legitimate interests include (as described in more detail above):

• Providing, customizing and improving the Services.- Marketing the Services.- Corresponding with you.- Provision of customer support.- Protection from fraud or security threats.- Meeting legal requirements and enforcing legal terms.- Completing corporate transactions.

Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.

Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

Sharing Personal Data

The "How We Share Your Personal Data" section above details how we share your Personal Data with third parties.

EU Data Subject Rights

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at support@louper.io. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

• Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by logging on to your account.
• Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging on to your account. Please contact us as soon as possible upon noticing any such inaccuracy or incompleteness.
• Erasure: You can request that we erase some or all of your Personal Data from our systems.
• Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
• Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
• Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
• Restriction of Processing:You can ask us to restrict further processing of your Personal Data.
• Right to File Complaint:You have the right to lodge a complaint about Louper's practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here:https://edpb.europa.eu/about-edpb/board/members_en.

Changes to this Privacy Policy

Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our Privacy Policy. This Privacy Policy was last updated on 11 July 2021 and replaces any other Privacy Policy previously applicable from this date.

Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

www.louper.io

support@louper.io