© Copyright 2024. All rights reserved.
Welcome to the privacy Policy of Chatloop Ltd ("Chatloop")
Chatloop respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit our mobile application (the “App”), regardless of where you visit it from, and tell you about your privacy rights and how the law protects you. If we collect any personal data from you via website, this Policy will also apply.
This Privacy Policy aims to give you information on how Chatloop collects and processes your personal data through your use of our App, including any data you may provide when you create an account with us, sign up to notifications, create a Loop or subscribe to communications. This Privacy Policy sits alongside our Terms of Use.
It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.
Chatloop Ltd is the controller and responsible for your personal data (collectively referred to as "Chatloop", "we", "us" or "our" in this privacy policy).
If you have any questions about this Privacy Policy, including any requests to exercise your legal rights (see Section 9), please contact DPO@chatloop.com.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
We keep our Privacy Policy under regular review. This version was last updated in [December 2022]. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This platform 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 data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our App, we encourage you to read the privacy policy of every website you visit.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Includes the collection and storage of 3D face map data of our users faces. This serves the purpose of a liveness check to limit the presence of bots on the platform, and to check for the same user creating multiple accounts. This process prevents any banned users creating a new account to access the platform. For this reason, Facetec data will be retained indefinitely. The provision of this data is optional, however, refusal to provide said data will result in certain features within the app being unavailable such as loop creation and interaction with other users for the sake of their own protection.
This data will not be shared with any third parties and is encrypted and stored on our AWS servers.
Facetec data will only be stored for one year.
Includes first name, last name, username or similar identifier, marital status, title, date of birth and gender;
Includes your username and password, your interests, preferences, feedback and survey responses.
Includes billing address, email address and telephone numbers.
Includes bank account and payment card details.
Includes details about payments to and from you and other details of products and services you have purchased from us.
Includes internet protocol (IP) address, your login data, time zone setting and location, operating system and platform, and other technology on the devices you use to access this platform.
Includes information about how you use our App and services.
Includes your communication preferences and your preferences in receiving marketing from us and our third parties
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific App feature. 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.
We may collect any Special Categories of Personal Data about you such as race, ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data, subject to your consent. You have the right to withdraw this consent at any time by contacting us at DPO@chatloop.com.
Where we need to collect personal data by law, or under our Terms of Use which you have signed up to, and you fail to provide that data when requested, we may not be able to provide you with access to our Support services. In that case, we may have to cancel such services.
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Profile, Contact, Financial Data, Transactional Data and Marketing and Communications Data by filling in forms or by interacting with our App. This includes personal data you provide when you:
• create an account on our App;
• subscribe to our services or notifications;
• request marketing to be sent to you;
• post, message, Loop or otherwise use our App
• give us feedback or contact us. • Automated technologies or interactions.
We use PostHog as a data processor in our app and browser to collect and analyse usage and browsing data.
PostHog is a product analytics tool that enhances our understanding of user interactions, allowing us to improve our services and user experience.
As you interact with our App, we will automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.
Inferences. We may infer information about you and your interests based on the information you have provided us with and your use of the App. We use inferences to, for example, moderate content on our App, keep our users safe and to personalise your experience on the App.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data:
Direct interactions. You may give us your Identity, Profile, Contact, Financial Data, Transactional Data and Marketing and Communications Data by filling in forms or by interacting with our App. This includes personal data you provide when you:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
Click here to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will request your consent before collecting any Special Categories of personal data or sending any third-party direct marketing communications to you via email or text message. You have the right to withdraw consent at any time by contacting us at DPO@chatloop.com.
We have set out in the table below, a more detailed description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out below.
For more information about the cookies we use, please see Cookie Policy.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may share your personal data with the parties set out below for the purposes set out in the table in Section 4 above:
External third parties acting as processors to provide us services or host our App, including:
• Amazon Web Services.
• Zendesk Inc.
• Typeform SL.
• Google Firebase.
• Google Analytics.
• Zapier Inc.
Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way asset out in this Privacy Policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Some of our external third parties are also based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data. For further details on what is an adequate level of protection, see the ICO website here.
• Where a country does not have an adequate level of protection, we will only transfer your personal data where a binding agreement is in place with that third party in compliance with data protection laws.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see Section 9 below for further information.
Further, in some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
In relation to your personal data, you have the right to:
This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
This enables you to ask us to delete or remove personal data where there is no good7reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Where we are relying on a legitimate interest (or those of a third party), you may object to the processing on this ground if there is something particular about your situation which you feel impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
This enables you to ask us to suspend the processing of your personal data in the following scenarios: (i) if you want us to establish the data's accuracy; (ii) where our use of the data is unlawful but you do not want us to erase it; (iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Please note, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Further information: If you wish to exercise any of the rights set out above, contact us at: DPO@chatloop.com.
You will not have to pay a fee to access your personal data or to exercise any of the other rights mentioned above. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your righto access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
