Information Use

We will only use your Personal Information when the law allows us to and as described below:

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Providing Looped’s Services and Services Communications. Users of Looped’s Services have a specific relationship with us. User registration information may be used to authenticate your access to the App, display customized content from your Clinic, track your progress through educational journeys, award and manage points, process rewards redemptions, facilitate purchases of Clinic services, and send notifications about your treatments and journeys.

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Data Management and Support. Looped stores and processes User content only on behalf of, and as instructed by, its Users or their Clinic. However, User content may be viewed or accessed by Looped for the purpose of resolving a problem or support issue. Users are responsible for maintaining the confidentiality and security of their user registration and password.

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Improvements. We also use User Personal Information to help deliver a better experience (for example, by displaying personalized content to you based on your interactions with the App), to diagnose technical problems, to support marketing activities, and so that we may better administer and improve the quality of the App and the Services.

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Marketing and Promotion. Looped uses the information listed in the section above to contact Users to further discuss their interest in the App and the Services, or to send Users information regarding Looped or its partners, such as information about new features, promotions and events. Any such communications will be sent in accordance with Users’ marketing preferences and consent choices. We may also notify Users with service-related information concerning the Services or the App to the extent allowed by law and in light of the commercial relationship between us. You may opt out of receiving marketing materials at any time by following the unsubscribe instructions included in each marketing communication.

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To Enforce Compliance with Our Policies. Looped may access User Data if necessary to investigate a suspected violation of the Terms of Use and/or Acceptable Use Policy for the Services.

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To Maintain Legal or Regulatory Compliance. Our Services are subject to certain laws and regulations which may require us to use your Personal Information. For example, we use your Personal Information to pay our taxes, to fulfill our business obligations, and as otherwise required by law. Without using your Personal Information for such purposes, we could not perform the Services in accordance with our legal and regulatory requirements.

How We Share Your Data

Sharing of Information

Looped will not copy, distribute, or otherwise share any User Personal Information except as set out in this Privacy Policy. Looped may share or communicate Users’ Personal Information in the following ways:

• Your Clinic: We share certain information with the Clinic that invited you to use the App, including journey completion data, points and rewards information, purchase orders for Clinic services, and consultation requests.

• Credit Card processing: Looped uses third-party service providers (Solidus, Stripe and Affirm) to manage credit card and payment processing. These service providers are not permitted to store, retain, or use billing information except for the sole purpose of payment processing on Looped’s behalf.

• Third party service providers: Looped may partner with other parties to provide Users with specific services such as authentication services (Stych), cloud hosting (Amazon Web Services), error monitoring, and application management (Vessel Partners). These service providers are subject to confidentiality and security agreements and are required to agree to use the Personal Information of Users for the purpose of providing services, under Looped’s instructions, to keep that information secure, and otherwise to handle Personal Information in the same manner as provided in this Privacy Policy, as required by applicable laws.  

• Potential acquirers of Looped’s business: If Looped is involved in a merger, acquisition or asset sale (each a “transaction”), some or all of Looped Users’ Personal Information may be disclosed or communicated for the purposes of evaluating or carrying out the transaction. In such a case, the other party will be instructed to handle the Personal Information in the same manner as provided in this Privacy Policy, and Users will be notified to the extent required by applicable laws.

• Law Enforcement. We may be required in certain circumstances to disclose or communicate Personal Information in response to a lawful request by public authorities, courts, law enforcement, or to comply with national security requirements, or as otherwise required by the applicable data protection law. To the extent allowed by law, we will notify you before a disclosure or communication is made.

• Consent: We may disclose or communicate Users’ Personal Information with third parties where we have consent to do so, except as otherwise prohibited by law.

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Data Location and Data Transfers

Users’ Personal Information may be transferred to and processed in countries outside of Canada. Our third-party service providers and partners may operate around the world. This means that when Looped collects Users’ Personal Information, such information may be processed in any of these countries, and accordingly, may be accessible to courts, law enforcement and national security authorities of those countries. 

Specifically, your phone number will be transferred to the United States and processed in the United States for the limited and narrow purpose of authentication through our service provider, Stytch. Payment information will be processed in the United States by Stripe and Affirm. Technical support may be provided by Vessel Partners from the United States. All other Canadian user data is stored in Amazon Web Services’ Canada Central data centre.

If you have any questions or wish to obtain further written information about Looped’s policies and practices with respect to the collection, use, disclosure or storage of your Personal Information by service providers or affiliates outside of Canada, you may contact our Privacy Officer at support@loopedapp.com.

How we Protect and Manage Your Data

Security

Looped uses appropriate administrative, technical, organizational, and physical security measures to protect our Users’ Personal Information against accidental or unlawful destruction, loss, and alteration, and against unauthorized disclosure, communication and access. We use standard industry practices to protect Users’ Personal Information, including firewalls, SSL encryption, limiting storage of financial information to PCI compliant third party providers, system redundancies, and co-location in a 24/7 secured, controlled environment. While we employ reasonable security measures, we cannot ensure or warrant the security of any information you transmit to us over the internet, and you do so at your own risk.

We have procedures in place to address any suspected personal data breach and will notify you and any applicable regulator of a breach as required by law.

Data Retention

We retain Personal Information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with the Services you have requested, to comply with applicable legal, contractual, tax or accounting requirements, or to defend ourselves from possible legal actions). When we have no ongoing legitimate business need to process your Personal Information, we will destroy it or anonymize it in accordance with applicable laws.

Your Choices to Control Your Data

Your Data Protection Rights

You can exercise any one of the following data protection rights as may be available to you under applicable law by contacting us at support@loopedapp.com or through one of the other methods set forth in the introduction to this Privacy Policy. In certain jurisdictions, we may need to verify your identity before responding to your request. Depending on your jurisdiction, you may have the following data protection rights:

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• The right to access, correct, update or request deletion of the Personal Information we collect about you. This is handled through a manual process internally, as there is no self-service account deletion feature in the App.

• The right to opt out of marketing communications, even if you have previously consented to receiving them. You may opt out at any time.

• The right to request a portable copy of your Personal Information.

• The right to de-indexation, re-indexation or cessation of dissemination of your Personal Information.

• If we have collected and process your Personal Information with your consent, then you may have the right to withdraw your consent by contacting us through one of the methods below – see the heading “Contact“.

Contact

In order to exercise your data protection rights or should you have any questions, concerns or complaints regarding our Privacy Policy or the collection or processing of your Personal Information, you may email our Privacy Officer at support@loopedapp.com.