SECTION 1 – WHAT INFORMATION LOOPABLE COLLECTS AND HOW LOOPABLE COLLECTS IT

Loopable collects various types of information, including information that identifies you or may identify you, in order to provide and improve the Services and to operate its business generally. What information Loopable collects about you and how Loopable collects that information is described below.

1. Information Provided by You.

   When you use the Services, Loopable collects the below information if and when you submit it:

   • Contact Information (e.g., name, email address, postal address, phone number).
   • Profile Information (e.g., username, password, preferences).
   • Communications (e.g., responses to surveys, correspondences with customer service or other users).
   • Marketing Information (e.g., preferences for receiving marketing communications, details about how you engage with marketing communications).
   • Other Information voluntarily provided by you (e.g., other information that you voluntarily submit to the Services, such as Assessments or videos or information submitted in connection with Assessments).

   Loopable collects this information when you create an account, fill out a form, send Loopable an email, subscribe to a newsletter, or otherwise submit information to Loopable.

2. Information Collected Automatically.

   In addition, Loopable (and its service providers and business partners) may automatically log the following information about you, your computer, your mobile device, and your activity on the Services:

   • Device Data (e.g., information about your computer or mobile device and operating system, including type and version number, manufacturer, and model, browser type, screen resolution, IP address, unique identifiers, and general location information).
   • Usage and Performance Data (e.g., pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, duration of access, crash rates, launch times, hang rates).

   Loopable (and its service providers and business partners) facilitate the collection of this information by using the following technologies:

   • Cookies Loopable uses, or allows to be used, cookies throughout the Services. Cookies are data files containing small amounts of information that are placed on your computer or device when you visit a website. Cookies are widely used by website owners to uniquely identify your browser and to store information or settings for a variety of purposes, such as to keep you logged into your account as you navigate between secure pages, to remember your preferences between sessions, to facilitate online advertising, and so on. You can prevent cookies from being set on your computer or device by adjusting the settings of your browser (see your browser “Help” for how to do this). However, be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of the Services. Therefore, it is recommended that you do not disable cookies.
   • Javascript libraries. These are snippets of code within the Services that execute when certain actions take place.
   • Web beacons Also known as pixel tags or clear GIFs, these are tiny graphics embedded invisibly on webpages and emails and are about the size of the period at the end of this sentence. This technology is used to demonstrate that a webpage or email was accessed or opened or that certain content within it was viewed or clicked.

SECTION 2 – LOOPABLE'S USE OF YOUR INFORMATION

Loopable does not use your personal information, except as described in this Privacy Policy. Loopable may use the information it collects for the following purposes:

• Delivery of the Services. Loopable may use such information to provide the Services. For example, Loopable may use such information to: set up your account; fulfill your requests for products and services; provide, operate, and maintain the Services; understand your needs and interests; provide you with a customized experience; provide customer service and support; respond to your inquiries; send communications, including confirmations, receipts, technical notices, updates, security alerts, and administrative messages; prevent fraudulent activity; comply with legal obligations and regulations applicable to the Services; and for any other purpose based on Loopable's legitimate interest in connection with providing the Services to you.
• General Operation of Services. Loopable may use such information to: operate, improve, and administer the Services generally. For example, Loopable may use such information to provide, maintain, and improve Loopable's website, develop new features of the Services, and to diagnose and fix technical problems.
• Research & Development. Loopable may use such information for research and development purposes, including to analyze and improve the Services and Loopable's business and to develop other products and services. As part of these activities, Loopable may create aggregated, de-identified, or other anonymous data from personal information. Loopable makes personal information into anonymous data by removing information that makes the data personally identifiable to you. Loopable may use this anonymous data and share it with third parties for lawful business purposes.
• Analytics. Loopable may use such information, in an aggregated form, to understand general information and trends related to its Services, such as how many users have visited its website during a given period of time, the types of devices these visitors are using, customer demographics, and so on. The information is not used to identify any individual and is used by Loopable to help improve the Services and promote its business.
• Promotional Communications. Loopable may use such information to contact you with newsletters, marketing or promotional materials, and other information that may be of interest to you. You may opt-out of receiving any or all of these communications by following the instructions provided in any email sent to you or by following the unsubscribe link in those emails.
• Compliance & Protection. Loopable may use such information to: protect its, yours, or others' rights, privacy, safety, or property; audit its internal processes for compliance with legal or contractual requirements or internal policies; enforce its Terms of Services or other contracts; protect against, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft; and comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
• Other Purposes with Your Consent. Loopable may use such information for some other purpose, provided you specifically consent to that other purpose.

SECTION 3 – LOOPABLE'S DISCLOSURE OF YOUR INFORMATION

Loopable takes your privacy seriously and does not share your personal information with third parties, except as described in this Privacy Policy. Loopable will never sell your personal information to marketers. Loopable, however, may share your information with third parties in the following circumstances:

• Your consent. Loopable may share your information with your consent, such as when you submit a video or other information in connection with an Assessment to be viewed by other users or if you send a message via the Services directly to another user.
• Everyday Business Purposes. Loopable may share your information with third parties in connection with providing the Services, such as sharing your information with a Service Provider when you submit an Assessment.
• Service Providers. Loopable may share your information with third parties that provide services on its behalf, including services related to web-hosting, analytics, promotion management, and ad serving. Unless otherwise stated in this policy, these service providers will be given access to your information only as is reasonably necessary to provide their services.
• Advertising Partners. Loopable works with third-party advertising companies that collect, or may receive from Loopable, information about your activity on the Services and other online services to help Loopable advertise the Services.
• Affiliates. Loopable may disclose your information to its subsidiaries and corporate affiliates for use consistent with this Privacy Policy.
• Compliance & Protection. Loopable may preserve or disclose to third parties your information if it believes that doing so is reasonably necessary to: protect its, yours, or others' rights, privacy, safety, or property; audit its internal processes for compliance with legal or contractual requirements or internal policies; enforce its Terms of Services or other contracts; protect against, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft; and comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
• Business Transfers. In the event that Loopable is involved in a merger, acquisition, reorganization, sale of assets, or bankruptcy, your information may be sold or transferred as part of related transactions, and your information may be disclosed as part of the diligence process leading up to such transactions. However, the promises in this Privacy Policy will apply to your information as transferred to any new entity.
• Professional Advisors. Loopable may disclose your information to professional advisors, such as lawyers, accountants, and insurers, where such disclosure is reasonably necessary in the course of the professional services such advisors are providing to Loopable.
• Non-Private or Non-Personal Information. Loopable may share your non-private, aggregated, or non-personal information with advertisers, publishers, business partners, sponsors, and other third parties.

SECTION 4 – OTHER WEBSITES AND SERVICES

Certain links throughout the Services may direct you away from the Services. Loopable is not responsible for, and cannot control, the privacy practices of other sites and third parties. Once you leave Loopable's Services, information subsequently collected is no longer governed by this Privacy Policy.

SECTION 5 – COMMITMENT TO DATA SECURITY

Loopable takes reasonable measures to protect your information from unauthorized access and against loss, misuse, and alteration by third parties. Although Loopable makes reasonable, good faith efforts to store the information collected through the Services in a private, secure operating environment, Loopable cannot guarantee its absolute security during its transmission or its storage. Further, while Loopable attempts to ensure the integrity and security of its network and systems, it cannot guarantee that its security measures will prevent third parties (e.g., “hackers”) from illegally accessing this information. As a result, Loopable does not warrant that your information will be protected against loss, misuse, or alteration by third parties.

SECTION 6 – COMMITMENT TO CHILDREN'S PRIVACY

Loopable does not knowingly collect or solicit personal information from anyone under 13 or knowingly allow children under 13 to use, access, or register for the Services. If you are under 13, please do not send any information about yourself to Loopable. No one under the age of 13 may provide to Loopable any personal information. In the event that Loopable learns that it has collected personal information from a child under 13, Loopable will delete that information as quickly as reasonably possible. If you believe that Loopable might have any information from a child under 13, please contact Loopable at support@loopable.co.

SECTION 7 – DO NOT TRACK SIGNALS

Some web browsers offer a “Do No Track” (“DNT”) signal. A DNT signal is an HTTP header field indicating your preference regarding tracking or cross-site user tracking. Loopable does not respond to DNT signals.

SECTION 8 – UPDATING THIS POLICY

Loopable may revise this Privacy Policy to reflect changes to its information practices. The most current version will always be located here. If the revision, in Loopable's discretion, is material, Loopable will attempt to notify you via email to the email address associated with your account or by posting notice on its website. As partial consideration for accessing or using the Services, you agree to check back here from time to time to determine if the Privacy Policy has been revised. By continuing to access or use the Services after the revisions have become effective, you agree to be bound by the revised Privacy Policy.

SECTION 9 – MODIFYING YOUR PERSONAL INFORMATION

You are responsible for maintaining the accuracy of any information you submit to Loopable. If your personal information changes or if you no longer desire to use the Services, you may change or delete certain information by editing your account settings or by contacting support@loopable.co Loopable will respond to your request within 45 days. However, even after you cancel your account or request that your personal information be deleted, some information from your account may remain stored or viewable or used, but only in compliance with this Privacy Policy.

SECTION 10 – OPTING OUT OF MARKETING EMAILS

You may opt-out of receiving promotional emails from Loopable by following the instructions in those emails or by emailing support@loopable.co with your request. If you opt-out, Loopable may still send you non-promotional emails, such as emails regarding your account or providing information that you have specifically requested.

SECTION 11 – DATA RETENTION

Loopable will retain your information for as long as needed to provide the Services and as otherwise set forth in this Privacy Policy. If you wish to cancel your account or request that Loopable no longer use your information to provide you services, contact support@loopable.co. Loopable will retain and use your information as necessary to comply with its legal obligations, resolve disputes, and enforce its agreements.

SECTION 12 – INTERNATIONAL VISITORS

Like many websites, the Services are accessible by an international audience, including visitors from the European Economic Area and other non-U.S. territories. By using the Services, you expressly agree that your personal information, and any information or materials that you submit to the Services, may be used for the purposes identified in this policy and the Terms of Service. In addition, such data may be stored on servers located outside your jurisdiction and in jurisdictions that may have less stringent privacy practices than your own. By using the Services, you expressly consent to the transfer of your data from your country or jurisdiction to other countries or jurisdictions around the world, including to the United States, for use by Loopable and its affiliates for the purposes described herein, subject only to any additional requirements that may be set forth in a separate, written agreement between you and Loopable.

SECTION 13 – CALIFORNIA PRIVACY RIGHTS

The California Consumer Privacy Act of 2018 (“CCPA”) provides California consumers with certain rights regarding their personal information. Those rights are described in Appendix A below.

SECTION 14 – CONTACT INFORMATION

If you have questions or comments regarding this Privacy Policy, please contact:

Effective Date: 05/27/2024

APPENDIX A – CALIFORNIA RESIDENTS

This appendix (the “Appendix”) applies only to California residents. This Appendix describes (1) how Loopable collects, uses, and shares Personal Information of California residents in operating its business and (2) the rights of California residents with respect to that Personal Information. For purposes of this Appendix, “Personal Information” has the meaning given to it in the CCPA (without including any exempted information).

Your California Privacy Rights.

You have the rights listed below. However, these rights are not absolute, and in certain cases, Loopable may decline your request as permitted by law.

• Right to know about Personal Information collected, used, disclosed, or sold. You have the right to request that Loopable discloses to you the categories of Personal Information that Loopable collects or discloses (or has collected or disclosed in the past 12 months) about you, the categories of sources of such information, the business or commercial purpose for collecting your Personal Information, and the categories of third parties with whom Loopable shares or discloses your Personal Information.
• Right to request deletion of Personal Information. You have the right to request the deletion of your Personal Information that Loopable has collected from you, subject to certain conditions and limitations under the law.
• Right to opt-out of the sale of Personal Information. You have the right to opt-out of the sale of your Personal Information. As described in more detail below, Loopable does not sell Personal Information to third parties for their commercial purposes as defined under the CCPA.
• Right to non-discrimination for exercising a consumer privacy right. You are entitled to exercise the rights described above free from discrimination. This means that Loopable will not penalize you for exercising your rights by taking actions such as: denying you services; increasing the price/rate of services; or decreasing service quality.

Your to exercise your California Privacy Rights.

You may submit a request to exercise your above-described rights by emailing support@loopable.co. You will need to verify your identity before Loopable will be able to process your request, and Loopable reserves the right to confirm your California residency. Government identification may be required. You can designate an authorized agent to make a request on your behalf, but Loopable will need to verify both your and your agent's identities and your agent must provide valid power of attorney or other proof of authority acceptable to Loopable. Loopable cannot process your request if you do not provide sufficient detail to allow Loopable to understand and respond to it. Loopable will work to respond to your verifiable request within 45 days of receiving it. In certain cases, Loopable may be required or permitted by law to deny your request.

Loopable does not sell your Personal Information

Based on Loopable's current understanding of the CCPA, Loopable does not “sell” your Personal Information as defined in the CCPA. However, like many companies online, Loopable uses services provided by Google, Facebook, and other advertising companies that track website visitor activity to help deliver interest-based ads to those visitors. Loopable describes this in more detail in the above Privacy Policy.

Personal Information Loopable collects, uses, and discloses.

The specific details of the categories of Personal Information that Loopable collects from you is described in Section 1 (What Information Loopable Collects and How Loopable Collects It) of the above Privacy Policy.

The specific details of how Loopable uses the categories of Personal Information that it collects from you is described in Section 2 (Loopable's Use of Your Information) of the above Privacy Policy.

The specific details of how Loopable discloses the categories of Personal Information that it collects from you is described in Section 3 (Loopable's Disclosure of Your Information) of the above Privacy Policy.