OOTech Privacy Notice
Effective as of September, 2022.
Our Mission at OOLoop is to improve experiences at a local and global scale focusing on toxic issues involving gender, race, age, sexuality, disability, abuse and more.
We know the data involved with emotional experiences are deeply personal so we wanted to provide an avenue to document and share those experiences without compromising your privacy.
When you use OOLoop, you are trusting us with personal information. We are committed to keeping that trust, which is why we endeavour to take steps to ensure that individual User’s data and privacy rights are protected and to be transparent about our practices.
The purpose of our Privacy Notice is to explain what data we collect, how it is used and shared, and how you can control it.
- The data that serves you
When you sign up for an account and use OOLoop we collect very little personal information for account management and contract fulfillment proposes. We may also use this information to improve the User’s experience, such as personalizing product offers, the insights you get, etc. However, no personal information that you share on the App as a looper is ever processed or shared in any way that can identify you. Any data that leaves your device or personal storage is encrypted, aggregated and de-identified. For insights and research activities, we use only statistics derived from de-identified or aggregated data.
If you do not wish to share any personal information when creating an account, you can use the App as a guest User. An account is only needed for Loopers that want to participate in insight studies or other specific features.
- You are in control
You may ask to access, modify, correct, erase, and update your personal information through our self-service portal or by writing to us at email@example.com. For iOS OOLoop Premium Users, the App also enables you to download a report containing some of your personal information from within the App. Please be aware that erasing or modifying some personal information you have provided could affect your ability to use certain features of the App that rely on historical data.
- Securing your data
We take reasonable and appropriate measures to protect your personal information from loss, theft, misuse or unauthorized access. We require similar standards of data protection from our partners, affiliates, service providers and others that may have access to your data to help us manage our relationship with you or fulfill the purpose for which the data was collected.
- We limit children’s access to the App
You must be at least 13 years old to use the App (16 for European Economic Area (“EEA”) residents). We do not knowingly collect information from children under 13 (16 for EEA residents), and we do not allow people to use the App if they are younger than 13 (16 for EEA residents). Moreover, some of the App functions are limited for Users that are younger than 18.
- You can freely talk to us
We believe in transparency and open dialogues, as such, if you have questions about this Privacy Notice, how we collect or process your personal information, or anything else related to our collection, use or disclosure of your personal information, we strongly encourage you to contact our Privacy Office at firstname.lastname@example.org.
This Privacy Notice applies to the use of our Services. It explains how OOTech Inc. (“OOTech” or “we” or “us”) collects, stores, uses, transfers and shares personal information from our Users (“you” or “Looper”) in connection with the OOLoop mobile application (the “App”) and the ooloop.me , ootech.me and ootech.ca websites (the “Websites”) (all collectively, the “Services”).
We reserve the right to and may change this Privacy Notice from time to time. If we make any material changes, we will notify you by email (sent to the email address provided when you register), through the App, or by presenting you with a new version of this Privacy Notice. If permitted by applicable law, your continued use of the Services after the effective date of an updated version of the Privacy Notice will indicate your acceptance of the Privacy Notice as modified. In some cases, you will be given a choice about whether to explicitly accept changes to the Privacy Notice.
If you do not accept the terms of the Privacy Notice, please do not use our Services.
Please check the Privacy Notice posted on our Websites and in the App for the latest updates on our data privacy practices.
TABLE OF CONTENTS
- How to contact us
- Personal information we collect
- How we use your personal information
- How we share your personal information
- Your privacy rights
- Other important information
- HOW TO CONTACT US
If you have questions or complaints regarding this Privacy Notice or our data collection or data processing practices, or if you want to report any data privacy concerns or data security issues, please contact our privacy office at email@example.com.
We take your privacy questions seriously. A dedicated team reviews your inquiry to determine how best to respond to your question(s) or concern(s). In most cases, all substantive contacts receive a response within seven days. In other cases, we may require additional information or let you know that we need more time to respond.
Where your complaint indicates that an improvement could be made in the way we address the handling of privacy issues, we will take steps to make such an update at the next reasonable opportunity.
If you are not satisfied with our response, you may refer your complaint to the applicable regulator. On your request, we can provide you with information about relevant complaint avenues which may apply to your circumstances.
- PERSONAL INFORMATION WE COLLECT
At OOTech we practice data minimization and only collect data that we need . We collect information relating to you and your use of our Services from a variety of sources. Some of this information is collected directly from you and some of this information is collected from your interaction with our Services, your company, other individuals at your company, or from third parties. How and what information we collect about you will depend on the way that you use or interact with our Services, for example, whether you are an anonymous User, Builder, Partner, Looper, etc. and based on the service type that you choose.
The types of information collected from you directly or that you may provide to us many include:
- Account Information. Your name, User ID and related account details, including email address, devices registered, account status, and age range.
If you choose to register or login using a third-party account (such as Apple), the authentication of your login details is handled by that third party and we only collect the information you expressly agree to share with us at the time you give permission to link your OOLoop account with the third-party account, like your email address. When you use your Apple Single Sign-On (SSO) account (or other supported SSO), we do not have access to your Apple (or other supported SSO) account information.
- Device Information. Data from which your device could be identified, such as device serial number, or about your device, such as browser type (for e.g., when you create a service ticket to report an issue with the App).
- Contact Information. Data such as name and email address.
- Payment Information. Data about your billing address and method of payment, such as bank details, credit, debit, or other payment card information.
- Transaction Information. Data about purchases of our products and services.
- Usage Data. Data about your activity on and use of our offerings, such as app launches within our services, including search history, product interaction, crash data, performance and other diagnostic data, and other usage data.
- Location Information. Location data is only collected when you record a Loop (journal entry of an emotional experience) to show where the experience occurred. No location tracking is done outside of this purpose, i.e., we do not allow location tracking for any other reason. Your precise location data is only store on your device and never used or shared, unless you chose to do so
- Other Information You Provide to Us. Details such as the content of your communications with OOTech, including interactions with customer support and contacts through social media channels or websites, information collected from your participation in insight studies, etc.
You are not required to provide the personal information that we have requested and when you do share any of the personal information needed to perform a Service, it is used only for that purpose.
Please note that, if you choose not to share personal information needed to perform the Service you are requesting from us, we may not be able to provide you with our Services or respond to requests you may have.
Sensitive Personal Information
- If you send or disclose any sensitive personal information (e.g., information related to demographics or physical or mental health condition) to us when using the Services, you consent to our processing and use of such sensitive personal information as necessary to provide the Services.
- If you do not consent to our processing and use of such sensitive personal information, you must not submit sensitive personal information to our Services.
- You may subsequently modify or withdraw your consent to the use and processing of sensitive personal information in accordance with applicable laws in certain jurisdictions and according to Section 5 of this Privacy Notice.
- If you do not want your Company to send us sensitive personal information about you, you must make such a request directly to your Company.
- HOW WE USE YOUR PERSONAL INFORMATION
We use your data to provide, support, personalize and develop our Services.
How we use your personal information will depend on which Services you use, how you use those Services and the choices you make in your settings. We use the data that we have about you to provide and personalize our Services, including with the help of automated systems and inferences we make so that our Services can be more relevant and useful to you and others.
OOTech uses your personal information only when we have a valid legal basis to do so.
Depending on the circumstance, OOTech may rely on your consent (where you have given consent) or the fact that the processing is necessary to fulfil a contract with you (e.g., to deliver the Services you have requested), protect your vital interests or those of other persons, or comply with the law. We may also process your personal information where we believe it is in our or others’ legitimate interests, taking into consideration your interests, rights, and expectations. The way in which we may use your personal information includes:
- Power Our Services. We collect personal information necessary to power our services, which may include the personal information collected to improve our offerings, for internal purposes such as auditing or data analysis, or troubleshooting.
- Process Your Transactions. To process transactions, OOTech must collect data such as your name, purchase, and payment information.
- Security And Fraud Prevention. To protect individuals, employees, and OOTech and for loss prevention and to prevent fraud.
- Personal Information Used For Personalization. If you choose to personalize your Services or communications where such options are available, OOTech will use information that we collect so that we can offer you those personalized Services or communications. You can learn more about how relevant Services use the information to personalize your experience by reviewing the privacy information presented when you use a Service that asks to use your personal information.
- Comply With The Law. To comply with applicable law — for example, to satisfy tax or reporting obligations, or to comply with a lawful governmental request.
- Generate Insights. When you choose to participate in insight studies, we use privacy enhancing technologies like differential privacy and federated learning to derive insights from your Loops. The data generated in this process that is used for the insight studies renders the Looper or individual completely anonymous and can never be linked back to anyone.
Where we rely on your consent to process personal information, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your personal information, please contact our Privacy Office at firstname.lastname@example.org.
OOTech does not use algorithms or profiling to make any decision that would significantly affect you without the opportunity for human review.
OOTech retains personal information only for so long as necessary to fulfill the purposes for which it was collected, including as described in this Privacy Notice or as required by law. We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Notice. When assessing retention periods, we first carefully examine whether it is necessary to retain the personal information collected and, if retention is required, work to retain the personal information for the shortest possible period permissible under law.
- HOW WE SHARE YOUR PERSONAL INFORMATION
OOTech may share personal information with OOTech-affiliated companies, service providers who act on our behalf, our partners, developers, publishers, and others at your direction. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations or Users, or in the event of a reorganization, merger, or sale.
Further, OOTech does not sell or share personal information with third parties for their own marketing purposes.
When using our App, you control what information goes into the App, where it is stored and who you share it with. When you do want to securely share your personal information from the App, it will be only accessible to those you share it with within the App. However, if you share your loop to another third-party platform (for e.g., Twitter or Apple) OOtech has no control over that and you should refer to those third parties’ privacy guidelines for more information.
Your Personal Information may be subject to transfer to another jurisdiction for processing and storage by a third-party performing service for OOTech, including but not limited to Canada, the United States, the United Kingdom, and the European Union. In such situations, the Personal Information may be accessible by courts, law enforcement and national security authorities of that jurisdiction. In addition, OOTech may use certain cloud-based services to process or store information.
Sharing of Personal Information with third party service providers is governed by contractual agreements which include appropriate privacy and security safeguards. Such contractual agreements require that any third party with whom we share your Personal Information must use the information solely for the purposes of providing the contracted services for OOtech, and that the third parties agree to handle Personal Information in a manner consistent with the relevant principles in this Policy and/or applicable laws.
Principles of processing
- Data minimization and purpose limitation.
We will not process personal information in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you or collect any personal information that is not needed for the mentioned purposes. For any new purpose of processing, we will ask your separate consent.
- No sale of personal information.
We will not sell or rent your personal information. We will not use or disclose your personal information except as otherwise described in this Privacy Notice. We may share your personal information with our service providers, partners and others solely as described in this Privacy Notice.
- PRIVACY RIGHTS
It does not matter what country or region you come from, we are committed to providing you vast privacy rights in relation to your personal information.
- Correction of your Personal Information
If you believe that your personal information is inaccurate, you have a right to contact us and ask us to correct such personal information.
- Restriction of Processing
You have a right to request that the processing of your personal information be restricted in some circumstances. For example, you have the right to request the restriction of your personal information if you contest the accuracy of your personal information and we need some time to verify its accuracy.
- Right to object to the processing of your Personal information
In some cases, you can object to the processing of your Personal information, for example, if we process it under the legitimate interest basis, by contacting us at email@example.com.
- Access to your Personal Information (including in portable form)
You have a right to request information about what personal information we process about you, to access all your Personal information, and receive a copy of it, including in a structured and portable form.
- Erasure of your Personal information
Where you believe that the processing of your personal information is unlawful or if you withdraw your consent for processing it, you may ask us to erase or delete your personal information. Please be aware that erasing some personal information may affect your experience while using certain features of our Services that rely on historical data.
For App users, if you wish to delete the account, please visit the platform authentication section of the APP to delete your account. This will permanently delete your account and all related data stored on our servers, if applicable. If you choose to delete your account, it will remain active for 30 days before everything is wiped clean, except as noted below.
- Information you have shared with others will remain visible after you close your account or delete the information from your profile. We do not control data that other Loopers have copied out of our Services. Group content and ratings or review content associated with closed accounts will show an unknown User as the source.
Once your account is deleted, a User can continue to use the App anonymously without signing in. This will allow the User access to the limited features available in that mode. However, if a user decides to re login to their account within the 30 days after they have activated a deletion request, that request will automatically be cancelled and the User will need to repeat the account deletion process if they still wish to delete their account.
You can stop all collection of information by the App by uninstalling it. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. Please note that uninstalling the App does not automatically delete the account and the data stored in it, Users must initiate a deletion request before uninstalling the APP for data to be deleted, where applicable.
How to exercise your privacy rights
Contact us at firstname.lastname@example.org to exercise your privacy rights.
We will respond to your request within 7 days after receipt. However, depending on the nature of your request, it may take us up to 90 days to fulfil that request, for example for full erasure of your personal information stored in our backup systems. We will let you know if we need more time and explain the reasons for the delay.
Please keep in mind that if we receive a vague request, we may contact you to better understand the request. We may also refuse to comply with a manifestly unfounded request and with excessive (repetitive) requests.
In some cases, we might also require you to prove your identity. Normally, we make sure to verify that the request is coming from the same email as you provided when registering. Where you have not registered your account, we may ask you to undergo additional verification measures to ensure we are appropriately responding to requests.
Subject to applicable laws, you may have a right to complain about your local data protection authority about any of our activities (related to your privacy rights, among others) that you think are not compliant with applicable law. If you have any concerns about our privacy practices, please let us know at email@example.com
- OTHER IMPORTANT INFORMATION
General security measures
We implement technical and organizational measures to protect personal information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the nature of the personal information that we process and risks associated with special categories of personal information we collect. These measures include:
- Using differential privacy to preserve anonymity when unlocking insights. Differential privacy transforms the personal information shared through the App before it ever leaves the User’s device so that no one can ever reproduce the true data to identify anyone.
- Applying federated learning systems to train models without having your data leave your device or where you chose for your data to be stored.
- Encryption of your personal data in transit using Secure Multi-Party Communication, and at rest.
- Systematic vulnerability scanning and penetration testing.
- Protection of data integrity.
- Organizational and legal measures. For example, our employees have different levels of access to your personal information and only those in charge of data management get access to your personal information and only for limited purposes required for the operation of the Services. We impose strict liability on our employees for any disclosures, unauthorized accesses, alterations, destructions, misuses of your personal information.
- Conducting periodical data protection impact assessments to ensure that the Services fully adhere to the principles of ‘privacy by design’, ‘privacy by default’ and others. We also commit to undertake a privacy audit in the event of OOTech merger or takeover.
No security system is perfect and, as such, we cannot guarantee the absolute security of the Services, or that your information will not be intercepted while being transmitted to us. Please understand that you can help keep your information secure by choosing and protecting your password appropriately, not sharing your password and preventing others from using your devices.
If we learn of a security systems breach that affects you, we may either post a notice or attempt to notify you by email (if you provided one) and will take reasonable steps to remedy the breach as specified in applicable law and this Privacy Notice. If we learn of a potential breach, together with other actions referred to in the Privacy Notice (such as notifying you in certain cases), we will also undertake particular actions to remedy the breach as appropriate under the circumstances, which may include, logging you out from all the devices, resetting a password (sending a temporary password for you to apply) and performing other reasonably necessary activities and actions.
If you want to report a security incident related to the Services please contact us at firstname.lastname@example.org.
Storage and Cross-Border Data Transfers
OOTechch is based in Canada and the Personal information we collect is transferred to and processed in Canada (where it is governed by Canadian law) and to other countries (where it is governed by the laws of those countries). The laws of Canada and the laws of other countries may not offer the same protections as the laws of your jurisdiction.
Personal information stored by the Looper through the App is stored according to the Looper’s preference and is only used or shared according to the Looper’s preference. The Looper has complete control of their personal information on the APP and the ability to choose where it can be stored. For example, on their device, on their iCloud account, on OOTech servers, etc.
The ability to explore relevant real-time insights on the mobile devices, computers, and local or cloud servers that hold the data you generate on our platform enables you to feel confident that your information is always stored at the locations you selected. This deeper level of privacy settings gives you unprecedented control over the data that you generate every day (messages, images, video & audio recordings, files, as well as structured and binary data).
Direct Marketing and Do Not Track Signals
We do not share personal information with third parties for their direct marketing purposes without your permission.
Cookies and tracking technologies
Social media widgets
Our Websites and App may include social media features or widgets, such as the Twitter or LinkedIn Like or Share buttons. Use of these features may collect your IP address, detect which page you are visiting on our Websites, and set a cookie to enable the feature to function properly. Your interactions with these features are governed by the privacy Notice of the third party providing these features.
Links to other websites
Our Websites and App may include links to other websites or Apps (for example, Slack channel). The privacy practices of those other websites may differ from OOTech privacy practices. If you submit personal information to any of those websites, your personal information is governed by their privacy Notice. We encourage you to carefully read the privacy Notice of any website you visit or App you use.
We display Customer or User testimonials and other endorsements on our Websites. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial or any other endorsement, please contact us at email@example.com.
Getting In Touch
If you have any questions, concerns or complaints about our Privacy Notice or our data collection or data processing practices, or if you want to report any data privacy concerns or data security issues, please contact us at firstname.lastname@example.org.