Main Website Privacy Policy

LAST UPDATED: August 17, 2022

SECTION I: Introduction

This Privacy Policy applies to activities by Loop Data (founded under the name Obi LLC) and all affiliates, subsidiaries and related entities (collectively “Loop Data,” “we” or “us”). The terms "You" and "User" refer only to organizations that have entered into a contract with Loop Data or may do so in the future.

The Loop Data web site (https://www.loopdataservices.com/) contains no cookies, trackers, or any other code or data that could be used to identify any visitor. Loop Data doesn't collect any data about any individuals through its web site. This privacy policy (“Privacy Policy”) describes our policies and procedures about the collection, use, disclosure and sharing, or other processing of your personal information that we obtain from marketing programs or from you directly when you participate in our events, programs, trainings or other services (collectively, the “Services”). The Privacy Policy does not apply to information collected about Loop Data employees or contractors; that information is provided in contracts and employee handbooks.

For purposes of the GDPR and similar laws using the same terms, Loop Data is the controller of all of your personal information that we have collected. Where processing of personal information is undertaken by our affiliates, subsidiaries and related entities, they are a joint controller with Loop Data for your personal information.

Capitalized terms that are not defined in this Privacy Policy have the ordinary meaning given them in common American English usage.  In this Privacy Policy, “personal information” includes references to “personal data” as defined under applicable laws. Your use of our Sites and Services, and any dispute over privacy, is subject to this Policy, including the applicable limitations on damages and the resolution of disputes.

SECTION II: Personal Information That Loop Data Collects About Users (You)

We collect personal information about Users directly from those individuals, from educational institutions, and from other third parties. In no case do we collect information automatically. You do not have to provide us your personal information, but if you purchase products or services we will require some personal information in order to deliver them.

User Registration Information. We collect personal information when your employer is a customer of Loop Data and an authorized person adds a user account with your name or email address.

Business Information. In the normal course of business we collect contact information for people we serve or work with, such as customers, prospective customers, partner organizations, contractors, and vendors.

Your Content. If your employer is a customer of Loop Data, we collect and store the information in your support requests and configuration changes.

Communications. When you communicate with us (via email, phone, through our support site or otherwise), we may maintain a record of your communication.

Payment Information. Loop Data sells to organizations, not to individuals. No additional data about you is collected in the process of payment.

Limited Use of Automatically Collected Information. Loop Data's web site does not use cookies, web beacons, or other tracking technologies. If you submit the contact form, we will record whatever data you enter in our marketing database but will not track you thereafter. However, certain emails we send will contain web beacons, cookies or other technologies to tell us if you opened the email.

SECTION III: Purposes and Legal Bases for Our Using of Personal Information

Purposes and Legitimate Interests For Using Your Information
Loop Data uses the personal information we collect for our legitimate business interests, which include the following purposes:

• Providing our services. To provide the services, to communicate with you about your use of our services, to respond to your inquiries, to provide troubleshooting of the services and for other support and account management purposes.
  
• Personalization. To tailor the content and information that we may send or display to you, to offer location customization and personalized help and instructions and to otherwise personalize your experiences.
  
• Marketing and Promotions. For marketing and promotional purposes, such as to send you news and newsletters, special offers, and promotions, or to otherwise contact you about new features, events, trainings or other information we think may interest you related to Loop Data.
  
• No Analytics. Loop Data does not gather web site analytics.
  
• Compliance. To comply with legal obligations and requests. For example, to comply with laws that compel us to disclose information to public authorities, courts, law enforcement or regulators, maintain records for a certain period, or maintain records demonstrating enforcement and sublicensing of our trademarks.
  
• Business and Legal Operations. As part of our general business and legal operations (e.g., accounting, record keeping, and for other business administration purposes), and as necessary to establish, exercise and defend (actual and potential) legal claims.
  
• Prevent Misuse. We use personal data where we believe it necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of this Privacy Policy or any relevant contractual terms.
  
  

Disclaimer of Use for Targeted Advertising

No Advertising. We never use targeted advertising; not on our own sites and not on third-party sites or via third-party ad networks and services. We do not track any person's information for measuring the effectiveness and reach of ads and services, whether that person is a visitor to our site or a registered user of our services.

Purposes and Legal Bases

Purposes of Processing (see above)	Legal Bases of Processing (EU Users)
Providing our services	Our Legitimate Business Interests Where Necessary to Enter into or Perform a Contract with You (upon your request, or as necessary to make the Services available) Compliance with Law Where permitted, with Your Consent (where we process any sensitive personal information you voluntarily provide)
Personalization	Our Legitimate Business Interests
Marketing and Promotions	Our Legitimate Business Interests With Your Consent
Advertising	Our Legitimate Business Interests With Your Consent
Analytics	Our Legitimate Business Interests Where permitted, with Your Consent (where we process any sensitive personal information you voluntarily provide – e.g., for diversity-related purposes)
Compliance	Our Legitimate Business Interests Compliance with Law As Necessary to Establish, Exercise and Defend Legal Claims
Business and Legal Operations	Our Legitimate Business Interests Compliance with Law Necessary to Establish, Exercise and Defend Legal Claims
Prevent Misuse	Our Legitimate Business Interests Compliance with Law As Necessary to Establish, Exercise and Defend Legal Claims

Sharing of Personal Information
We disclose personal information of all types as set forth below:

• Service Providers. We may share your information with third party service providers who use this information to perform services for us, such as payment processors, hosting providers, integration providers, auditors, advisors, contractors and consultants.
• Affiliates. The information collected about you may be accessed by or shared with subsidiaries and affiliates of Loop Data, whose use and disclosure of your personal information is subject to this Privacy Policy, unless an affiliate has its own separate privacy policy which is equally or more protective of individual privacy.
• Organizational Events. We may disclose or transfer information, including personal information, as part of any merger, sale, and transfer of our assets, or restructuring of all or part of our business operations, bankruptcy, or similar event, including in negotiations, due diligence, and integrations related to such transactions. .
• Legally Required. We may disclose your information if we are required to do so by law (including to law enforcement in the U.S. and other jurisdictions).
• Protection of Rights. We may disclose information where we believe it necessary to respond to claims asserted against us or, comply with legal process (e.g., subpoenas or warrants), enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation, and protect the rights, property or safety of Loop Data, its Users, participants in its events or Projects, or others.

Cookies, Tracking, and Interest-Based Ads
We do not use cookies, clear GIFs/pixel tags, JavaScript, local storage, log files, or any other mechanisms to automatically collect and record information about Your usage and browsing activities on our web site, nor do we do so across third party sites or online services. Targeted Ads. We never use targeted ads, either on our own or with third party advertisers. We will never display ads to you based on your visit to our sites or to other third party sites.

Data Security
We have implemented commercially reasonable precautions designed to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee 100% security.

You should take steps to protect against unauthorized access to your passwords, phone, and computer by, among other things, signing off after using a shared computer, choosing robust passwords that nobody else knows or can easily guess, not using a password for more than one site or service, and keeping your logins and passwords private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.  We ask you to promptly notify us if you become aware that any information provided by or submitted to us is lost, stolen, or used without permission at privacy@loopdataservices.com.

Marketing Choices
You may opt out of or withdraw your consent to receive direct marketing emails from us by using the unsubscribe or opt out mechanisms included in our marketing emails or by emailing privacy@loopdataservices.com. You may also unsubscribe from mailing lists via the applicable mailing list’s subscription website or, in some cases, by using the unsubscribe mechanisms included in such emails.

Retention of Your Personal Information
We generally keep personal information only for as long as required to fulfill the purposes for which it was collected. However, in some circumstances, we may retain personal information for other periods of time, for instance where we are required to do so in accordance with legal, tax and accounting requirements, or if required to do so by a legal process, legal authority, or other governmental entity having authority to make the request, for so long as required.  In specific circumstances, we may also retain your personal information for longer periods of time corresponding to a statute of limitation, so that we have an accurate record of your dealings with us in the event of any complaints or challenges.

International Transfers
If you are located within the European Economic Area, the United Kingdom or Switzerland, you should note that your personal information will be transferred to countries outside these jurisdictions, including the United States where Loop Data is located.  The U.S. is deemed by the European Union to provide inadequate data protection.  If you deem it necessary, contact us about applying European Commission approved Standard Contractual Clauses and other means to provide for adequate safeguards to protect personal information transferred outside these jurisdictions.  You have a right to obtain details of the mechanism under which your personal information is transferred outside of the EU by emailing privacy@loopdataservices.com.

Children’s Privacy
We do not knowingly collect or solicit personal information from anyone under the age of sixteen (16), or knowingly allow such persons to become Users.

Links to Third Party Sites and Services
Our web site and services may contain links to third party sites or online services. Please refer to the privacy policies of the relevant third party websites or services to find out more about how they process and handle personal information.

SECTION IV: Your Rights

Access and Amendment. You may contact our privacy coordinator at privacy@loopdataservices.com for help accessing or amending your personal information.

Additional Rights. We grant the following rights to all individuals regardless of location, although this grant is specifically intended to comply with GDPR and the privacy laws of the state of California:

• to obtain a copy of your personal information together with information about how and on what legal basis that personal information is processed;
• to rectify inaccurate personal information (including to have incomplete personal information completed);
• to erase your personal information (in limited circumstances, such as where it is no longer necessary in relation to the purposes for which it was collected or processed);
• to restrict processing of your personal information under certain circumstances;
• to export certain personal information in machine-readable format to a third party (or to you) when we justify our processing on the basis of your consent or the performance of a contract with you and the processing is carried out by automated means;
• to withdraw your consent to our processing of your personal information (where that processing is based on your consent, without affecting the lawfulness of processing based on consent before its withdrawal);
• to obtain, or see a copy of the appropriate safeguards under which your personal information is transferred to a third country or international organization; and
• to object to our use and processing of your personal information that is conducted on the basis of our legitimate interest. You also have the right to object at any time to any processing of your personal information for direct marketing purposes, including profiling for marketing purposes. Note that we do not ever use student data for marketing purposes of any kind, nor do we create, maintain or keep student profiles for any non-educational purposes.

Lodging a Complaint. You also have the right to lodge a complaint with your local supervisory authority for data protection, or privacy regulator. You may give that authority the email address of "privacy@loopdataservices.com" as our contact information.

Submitting a Request. To exercise the above rights or contact us with questions or complaints regarding our treatment of your personal information, contact us at privacy@loopdataservices.com. Please note that we may request proof of identity, and we reserve the right to charge a fee where permitted by law, especially if your request is manifestly unfounded or excessive. We will respond to your request within the applicable timeframes set out by law.

California Privacy Rights
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the types of personal information disclosed to those parties. If you are a California resident and would like to request this information, please submit your request in an email to privacy@loopdataservices.com. We may ask you to verify your California residency.

Contact Us
If you have any questions about our practices or this Privacy Policy, please contact us at privacy@loopdataservices.com, or write to us at: Loop Data, Attn: Legal Department, 535 N 250 West, Springville, UT 84663, USA.

Changes to the Privacy Policy
This Policy is current as of the effective date set forth above. If we make any changes to this Privacy Policy that materially change how we treat your personal information, we will place a prominent notice on our web site. Since we do not use cookies or other tracking technologies, we have no way of tracking your affirmative consent to Privacy Policy changes.