We are Loop Now Technologies, Inc., based at 2 West 5th Ave., Suite 400, San Mateo, CA 94402, United States of America. All references in this policy to “Firework”, “our”, “us” or “we” refer to Loop Now Technologies, Inc.
California Consumer Notice of Collection.
CATEGORIES OF PERSONAL INFORMATION WE COLLECT
The categories of personal information we collect about you depends on how you interact with us. Depending on the Services you use, the following are the categories and specific types of personal information that we may collect, or have collected in the preceding 12 months:
- Account Information: including username, password, email address, postal address, phone number, username, business contact information, registration and login information, or other similar identifiers or account information.
- Information Specific to the Services: including, in certain instances, invoices, service interactions, business and commercial communications, order status, and history.
- Demographic Information: including age and gender, some of which may include characteristics of protected classifications under state or federal law.
- Device Information and Other Unique Identifiers: device identifier, internet protocol (IP) address, or similar unique identifiers.
- Internet or Other Network Activity: including metadata, browsing or search history, and information regarding your interactions with our websites, mobile applications, emails, or advertisements.
- Geolocation Data: including information that permits us to determine your location, such as if you manually provide location information or enable your mobile device to send us precise location information.
- Payment Information: including credit or debit card number, or other financial information.
- Inferences: inferences drawn from or created based on any of the information identified in this section.
- User Content: content that users contribute towards on our Sites, such as text, comments, images, video, profiles, and likes.
- Audio, electronic, visual, or similar information: We collect personal information including your image through certain applications using TrueDepth. Information from TrueDepth camera is used in real time. This information is not stored in our servers or disclosed to third parties. For more information about TrueDepth technologies, you may visit https://support.apple.com/en-us/HT208108.
- Sensitive Personal Information (where permitted and in accordance with applicable law): Some of the items of information listed above may be considered sensitive personal information, such as racial or ethnic origin, and health information.
Any sensitive personal information you provide for the Services is voluntary. For other personal information, in certain instances, we will not be able to process your request for our Services without the requested personal information.
HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
We collect your personal information in the following ways, pursuant to applicable law:
- Directly From You: such as when you create an account and profile with Firework; sign up with us to receive marketing communications; apply for a job through our careers page; or otherwise reach out to us.
PURPOSES OF PROCESSING AND HOW WE USE YOUR PERSONAL INFORMATION
- Help you efficiently access your information after you sign in to our Service;
- Remember information so you will not have to re-enter it during your visit or the next time you visit the Service;
- Communicate with you or third parties, or allow third parties to communicate with you to provide, improve, test, and monitor the effectiveness of our Service;
- Develop and test new products and features;
- Monitor metrics such as total number of visitors, traffic, and demographic patterns;
- In the case of business contact information, do business with partners, publishers and suppliers;
- Take the appropriate technical and organizational security measures to protect the Service or your personal information;
- Comply with legitimate requests or orders from competent public authorities and courts, including data protection authorities;
- Carry out internal corporate reporting, business administration, ensure adequate insurance coverage for our business, ensure the security of company facilities, research and development, and identify and implement business efficiencies (where it is in our legitimate interests to do so);
- Establish, exercise, or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so;
- Diagnose or fix technology problems;
- Make User Content available to third parties that are non-owned and non-operated by Firework, subject to your opting out by notifying our Support Team at firstname.lastname@example.org; or
- Automatically update the Firework application on your device.
Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. For example, we may collect your information to perform the Service with you, but we also collect your information so that we can quickly and easily respond to any questions about an order you place through our Services via our Sites or Apps or websites, applications, or devices of third-party publishers or distributors, provide you a confirmation or receipt for such order, or inform you that such order is incomplete. As a result, our collection and processing of your information is based on different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our general interest in conducting our business.
LEGAL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION
Firework relies on the following legal grounds for the collection, processing, and use of your Personal Information:
- As necessary to provide a service or perform a transaction (such as when we respond to your requests);
- Consent (where you have provided consent as appropriate under applicable law, such as for direct marketing or certain cookies);
- As necessary for legitimate interests (such as when we act to maintain our global business generally, including maintaining the safety and security of the Sites); and
- Compliance with legal obligations, particularly in the area of labor and employment law, social security and protection law, data protection law, tax law, and corporate compliance laws.
DISCLOSURE OF YOUR PERSONAL INFORMATION
In addition to the specific situations discussed elsewhere in this policy, we disclose, and may have disclosed in the preceding 12 months, information in the following situations:
- Service Providers/Suppliers. We may disclose User Content and your information (including but not limited to, information from cookies, log files, device identifiers, location data, and usage data) with other entities, including entities that we do not own or operate. Firework may use this information to help provide, understand, and improve the Service.
- Affiliates and Acquisitions. We may disclose information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires, or plans to acquire, our company, business, or our assets, we will also disclose information with that company, including at the negotiation stage.
- Compliance with Law or Other Legal Process. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also disclose your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third party intermediary.
- Where You Consent. We may also disclose your information for any other purposes disclosed to you with your consent.
- Anonymized and Aggregated Data. We may also disclose and use anonymized, aggregated reporting and statistics about users of our Service for the purpose of internal reporting or reporting to our corporate affiliate or other third parties (including clients), and for our marketing and promotion purposes.
We do not, and have not in the preceding 12 months, disclosed your sensitive personal information. We have no actual knowledge that we have sold or shared data (as those terms are defined under California law) of consumers under 16 years of age in the last 12 months.
HOW WE STORE, TRANSFER, AND SECURE YOUR PERSONAL INFORMATION
We also use commercially reasonable safeguards to help keep the information collected through the Service secure from loss, interference, misuse, unauthorized access, disclosure, alteration, or destruction. We also maintain reasonable procedures to help ensure that such data is reliable for its intended use and is accurate, complete, and current.
HOW LONG WE STORE YOUR PERSONAL INFORMATION
How long do we keep your User Content?
Following termination or deactivation of your account, Firework or its Service Providers may retain information (including your profile information) and User Content for a commercially reasonable time for backup, archival, and/or audit purposes, in accordance with applicable laws.
How long do we keep other Personal Information?
We keep your personal information for no longer than necessary for the purposes for which the personal information is processed. The length of time for which we retain personal information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise, or defend our legal rights.
CHOICES ABOUT YOUR INFORMATION AND YOUR RIGHTS
You may have certain rights regarding your personal information. The rights available to you depend on our reason for processing your personal information and the requirements of applicable law (i.e., your rights will vary depending on whether you are located in, for example, California, the European Union, or United Kingdom). Specifically, you may have the following rights:
- Access to Your Personal Information. You have the right to request access to the personal information we hold about you, along with other information such as the purposes of the processing, the recipients or categories of recipients to whom the personal information has been or will be disclosed, the sources of the personal information, retention, and transfers of personal information.
- Correction (Rectification). You have the right to request correction/rectification of inaccurate personal information we have about you. Depending on the purposes of the processing, you may have the right to have incomplete personal information completed, including by means of providing a supplementary statement. Note that we may keep historical information in our backup files as permitted by law, and you may not be able to change certain account information including your email address.
- Portability. Under certain circumstances, you have the right to receive the personal information about you that you have provided to us, in a structured, commonly used and machine-readable format.
- Deletion of Your Personal Information. You have the right to request that we delete your personal information.
- Objection to Processing. You may have the right to object to our processing of your personal information, under certain conditions, and we can be required to no longer process your personal information. Such right to object may especially apply if we collect and process your personal information for profiling purposes to better understand your interests in our products and services or for direct marketing purposes. If you have a right to object and you exercise this right, your personal information will no longer be processed by us for such purposes. Such a right to object may, in particular, not exist if the processing of your personal information is necessary to take steps prior to entering into a contract or to perform a contract already concluded.
- Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send reminders or notifications of upcoming events, free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in emails that you receive. If you decide not to receive promotional emails, we may still send you service-related communications.
- Promotional Mailings. If at any time you do not want to receive offers and/or circulars from us, you can remove yourself from our mailing lists by emailing us (our contact information is below) with “NO SNAIL MAIL” in the subject line along with your name, address, and zip code. Please note that our mailings are prepared in advance of their being sent. Although we will remove your name from our mailing list after receiving your request, you may still receive mailings from us that had been initiated prior to your name being removed or bulk mailings directed to ZIP codes or geographic areas.
- Promotional Text Messages. If you receive a text message from us (whether on our own behalf or on behalf of a third party) that contains promotional information, you can opt-out of receiving future text messages by replying, “STOP.”
- Opt out of the sale or sharing of Personal Information. We do not and have not in the preceding 12 months sold or shared (in this context, share means use of your personal information for cross-contextual behavioral advertising) your personal information. However, the use of technologies, such as cookies may constitute “sale” or “share” of personal information under California law. To opt out of the “sale” or “share” of your personal information as described in this section, visit DO NOT SELL OR SHARE MY PERSONAL INFORMATION.
– The following categories of personal information disclosed are considered “sale”/ “sharing” under California law: direct identifiers, device information, and geolocation data.
– The following categories of third parties to whom personal information was disclosed are considered “sale”/ “sharing” under California law: social media platforms and networks.
- Right to Opt Out of our Use of your Sensitive Personal Information (in certain instances and if permissible under applicable law). We do not disclose sensitive personal information for purposes other than those which cannot be limited under applicable law.
Please note that many of the above rights are subject to exceptions and limitations. Your rights and our responses will vary based on the circumstances of the request. If you choose to assert any of these rights under applicable law, we will respond within the time period prescribed by such law.
If you are located in the State of California in the United States, a person authorized to act on your behalf may make a verifiable request related to your personal information. If you designate an authorized person to submit requests to exercise certain privacy rights on your behalf, we will require verification that you provided the authorized agent permission to make a request on your behalf.
In any circumstances, your request must: (i) provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative of that person; and (ii) describe the request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
If you are a current or former Firework employee, please reference our Firework Employee Policy. If you are a California applicant, please reference our Firework Applicant Policy.
OPT-OUT PREFERENCE SIGNAL (DO NOT TRACK)
Firework generally recognizes commercially recognized opt-out preference signals (e.g., Global Privacy Controls). Recognition of this signal applies only to the specific device and/or browser that communicates the signal and does not cross over to all devices/browsers you use to access the Services.
OTHER IMPORTANT INFORMATION
The following additional information relates to our privacy practices:
- Third Party Applications/Websites. Our Service may include links to, or be accessible via, websites or applications that are owned or operated by third parties. Please note that any personal information that you provide to such third parties will be governed by their privacy policies, and we have no control over or responsibility for their privacy practices. We encourage you to review the privacy policies of any third-party website or application for details about what information is collected and how it is used and/or disclosed prior to providing any personal information.
- Accessibility. If you are visually impaired, you may access this notice through your browser’s audio reader.
- Children. Our Service is not directed to, and we do not knowingly collect personal information from, anyone under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us. We do not sell any information of children.
HOW TO CONTACT US
Last Updated Date: January 2023