Chatloop™ Privacy Policy

Introduction

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.

1. Important information and who we are

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.

The App is not intended for children and we do not knowingly collect data relating to children.

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 [June 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.

2. The data we collect about you

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 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; and

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 asthis data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Datato calculate the percentage of users accessing a specific App feature. However, if we combine or connectAggregated Data with your personal data so that it can directly or indirectly identify you, we treat thecombined 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 orphilosophical beliefs, sexual orientation, political opinions, trade union membership, information about yourhealth, and genetic and biometric data, subject to your consent. You have the right to withdraw this consentat 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 Appor services. In that case, we may have to cancel such services.

3. How is your personal data collected

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 interactingwith 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. As you interact with our App, we will automaticallycollect 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. Wemay also receive Technical Data about you if you visit other websites employing our cookies.Please see our Cookie Policy for further details.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personaldata:

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 interactingwith 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 interestsand 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 willrequest your consent before collecting any Special Categories of personal data or sending any third partydirect marketing communications to you via email or text message. You have the right to withdraw consentat 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.

Purpose/Activity Type of data Special Category Data Lawful Basis for Processing Lawful basis for processing Special Category Data
To register you as a new user. (a) Identity
(b) Contact
(c) Profile
(d) Financial
(e) Communications
Yes Performance of a contract with you Consent
To manage payments, fees and charges or collect and recover money owed to us. (a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Communications
No (a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
 
To manage our relationship with you which will include:
Notifying you about changes to our terms, business or privacy policy

Asking you to leave a review or take a survey.
(a) Identity
(b) Contact
(c) Profile
(d) Communications
No (a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how users use our services)
 
To deal with complaints and protect our users. (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Yes (a) Necessary for our legitimate interests (for running our business and protecting our users from abuse or harmful content)
(b) Necessary to comply with a legal obligation.
Consent
To administer and protect our business and App (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
No (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation.
N/A
To deliver relevant website content to you and measure or understand the effectiveness of the content we highlight to you. (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Yes Necessary for our legitimate interests (to study how users use our products/services, to develop them, to grow our business and to inform our marketing strategy) Consent
To use data analytics to improve our website, services, marketing, customer relationships and experiences. (a) Technical
(b) Usage
No Necessary for our legitimate interests (to define types of users for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)  
To make suggestions and recommendations to you about goods or services that may be of interest to you. (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
No Necessary for our legitimate interests (to develop our products/services and grow our business).  

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 thelegal basis which allows us to do so. Please note that we may process your personal data without yourknowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table atSection 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 ourassets. Alternatively, we may seek to acquire other businesses or merge with them. If a changehappens 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 withthe law. We do not allow our third-party service providers to use your personal data for their own purposesand only permit them to process your personal data for specified purposes and in accordance with ourinstructions.

6. International transfers

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 transferringyour personal data out of the UK.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentallylost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to yourpersonal data to those employees, agents, contractors and other third parties who have a business need toknow. They will only process your personal data on our instructions and they are subject to a duty ofconfidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you andany applicable regulator of a breach where we are legally required to do so.

8. Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes wecollected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reportingrequirements. We may retain your personal data for a longer period in the event of a complaint or if wereasonably 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 andsensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of yourpersonal data, the purposes for which we process your personal data and whether we can achieve thosepurposes 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.

9. Your legal rights

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 tocheck 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 astructured, commonly used, machine-readable format. Note that this right only appliesto automated information which you initially provided consent for us to use or where weused 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 rightto access your personal data (or to exercise any of your other rights). This is a security measure to ensurethat personal data is not disclosed to any person who has no right to receive it. We may also contact you toask 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.