Effective as of December 14th, 2020
- Personal Data We Collect
- How We Use Your Information
- Information We Share with Third Parties
- Your Privacy Choices and Rights
- Responding to Do Not Track Signals
- Security of Your Information
- International Transfers
- Our Policy Toward Children
- Supplemental Notice for California Residents
- Supplemental Notice for Nevada Residents
2. Personal Data We Collect
Lookback collects information directly from you and automatically, as described below.
Information We Collect from You
Lookback may collect the following information from Customers:
- Account Information. If you create an account to use the Services (the “Account”) and/or sign up for a paid subscription to the Services, we will collect certain information that can be used to identify you, such as your name and email address.
Information We Collect Automatically
Lookback may collect the following information from users of the Services:
- Information Collected Using Cookies and other Web Technologies. Like many website owners and operators, we may use automated data collection tools such as Cookies, pixel tags, and Web Beacons (“Technologies”) to automatically collect certain information through your use of our Services.
- “Web Beacons” (also known as Web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike Cookies, which are stored on the user’s device, Web Beacons are typically embedded invisibly on web pages (or in an e-mail).
Our uses of these Technologies fall into the following general categories:
- Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
- Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);
- Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
- Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party websites.
See Section 6 below to understand your choices regarding these Technologies.
- Information Related to Use of the Services. Our servers automatically record certain information about how a person uses our Services (we refer to this information as “Log Data”), including both Account holders and non-Account holders (either, a “User”). Log Data may include information such as a User’s Internet Protocol (IP) address, browser type, operating system, the web page that a User was visiting before accessing our Services, the pages or features of our Services to which a User browsed and the time spent on those pages or features, search terms, the links on our Services that a User clicked on and other statistics. We use Log Data to administer the Services and we analyze (and may engage third parties to analyze) Log Data to improve, customize and enhance our Services by expanding their features and functionality and tailoring them to our Users’ needs and preferences. We may use a person’s IP address to generate aggregate, non-identifying information about how our Services are used.
- Information Sent by Your Device. We collect certain information that your device sends when you use our Services, like a device identifier, user settings and the operating system of your device, as well as information about your use of our Services.
- Location Information. When you use a Lookback Application on your mobile device, we may collect and store information that can be used to infer your approximate location (e.g., IP address). We may use location information to improve and personalize our Services for you.
Information We Collect from Other Sources
3. How We Use Your Information
We use your information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.
A. Provide Our Services
We use your information to fulfil our contract with you and provide you with our Services, such as:
- Managing your information and accounts;
- Providing access to certain areas, functionalities, and features of our Services;
- Answering requests for customer or technical support;
- Improving our Services;
- Communicating with you about your account, activities on our Services, and policy changes;
- Processing your financial information and other payment methods for products or Services purchased;
- Processing applications if you apply for a job, we post on our Services; and
- Allowing you to register for events.
B. Administrative Purposes
We use your information for various administrative purposes, such as:
- Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
- Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
- Measuring interest and engagement in our Services;
- Short-term, transient use, such as contextual customization of ads;
- Improving, upgrading or enhancing our Services;
- Developing new products and Services;
- Ensuring internal quality control and safety;
- Authenticating and verifying individual identities;
- Debugging to identify and repair errors with our Services;
- Auditing relating to interactions, transactions and other compliance activities;
- Enforcing our agreements and policies; and
- Complying with our legal obligations.
C. Marketing and Advertising our Products and Services
We may use Personal Data to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.
Some of the ways we may market to you include email campaigns, custom audiences advertising, and “interest-based” or “personalized advertising,” including through cross-device tracking.
If you have any questions about our marketing practices or if you would like to opt out of the use of your Personal Data for marketing purposes, you may contact us at any time as set forth below.
D. Other Purposes
We also use your information for other purposes as requested by you or as permitted by applicable law.
- Consent. We may use Personal Data for other purposes that are clearly disclosed to you at the time you provide Personal Data or with your consent.
- De-identified and Aggregated Information. We may use Personal Data and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create.
- Share Content with Colleagues. Our Services may offer various tools and functionalities. For example, we may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a colleague, such as an email inviting your colleague to use our Services.
5. Information We Share with Third Parties
We will not share any Personal Data that we have collected from or regarding you except as described below:
- Parent Companies, Subsidiaries, or Affiliates. We may share your Personal Data and Recording Information with our parent companies, subsidiaries and affiliates for our administrative purpose including activities such as IT management, for them to provide services to you, or support and supplement the Services we provide.
- Our Service Providers. We may engage third-party service providers to work with us to administer and provide the Services. These third-party service providers have access to your Personal Data only for the purpose of performing services on our behalf. We maintain a list of third parties we engage and we will notify Customers in advance if we engage any additional third-parties, as required by applicable law or our Customer agreement.
- Third Parties. We may share aggregated or de-identified information with third parties for industry research and analysis, demographic profiling and other similar purposes.
- Business Transactions. Information that we collect from our users, including Personal Data, is considered to be a business asset. Thus, if we are acquired by a third party as a result of a transaction such as a merger, acquisition or asset sale, or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your Personal Data, may be disclosed or transferred to a third party acquirer in connection with the transaction.
- For Our Protection and the Protection of Others. We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims, legal process (including subpoenas); (ii) to protect our property, rights and safety and the property, rights and safety of a third party or the public in general; and (iii) to stop any activity that we consider illegal, unethical or legally actionable activity.
6. Your Privacy Choices and Rights
We offer you choices regarding the collection, use and sharing of your Personal Data and we will respect the choices you make. Please note that if you decide not to provide us with the Personal Data that we request, you may not be able to access all of the features of the Services.
Cookies. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others.
Individuals located in certain countries and jurisdictions, including the European Economic Area, California, and Brazil, have certain statutory rights in relation to their Personal Data. Subject to any exemptions provided by law, you may have the right to:
- Access Personal Data about you, including: (i) confirming whether we are processing your Personal Data; (ii) obtaining access to or a copy of your Personal Data;
- Request Correction of your Personal Data where it is inaccurate, incomplete or outdated. In some cases, we may provide self-service tools that enable you to update your Personal Data, such as through your Account;
- Request Deletion, Anonymization or Blocking of your Personal Data when processing is based on your consent or when processing is unnecessary, excessive or noncompliant;
- Request Restriction of or Object to our processing of your Personal Data when processing is noncompliant;
- Withdraw your Consent to our processing of your Personal Data. If you refrain from providing Personal Data or withdraw your consent to processing, some features of our Service may not be available;
- Request data portability and receive an electronic copy of Personal Data that you have provided to us; and
- Be informed about third parties with which your Personal Data has been shared.
If you are a user of our Customer, please contact our Customer to exercise your privacy rights.
If you are located in the European Economic Area, Switzerland, the United Kingdom or Brazil, you have the right to lodge a complaint with your local supervisory authority or the Swedish Data Protection Authority (Datainspektionen, email@example.com), which is our lead supervisory authority in the European Union, if you believe our processing of your Personal Data violates applicable law.
7. Responding to Do Not Track Signals
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
8. Security of Your Information
We take reasonable administrative, physical and electronic measures designed to protect the information that we collect from or about you (including your Personal Data) from unauthorized access, use or disclosure. When you enter sensitive information on our forms, we encrypt this data using TLS or other technologies. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.
By using our Services or providing personal data to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.
9. International Transfers
Your Personal Data may be transferred to, and maintained on, computers or servers, that are located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide your Personal Data to us, we may transfer your Personal Data to the United States and process it there. We work with our Customers, users and vendors with regard to legal compliance pertaining to international data transfers and endeavor to safeguard your information consistent with the requirements of applicable laws.
Questions or Complaints
In compliance with the Privacy Shield Principles, Lookback commits to resolve complaints about our collection or use of your Personal Data. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Lookback at firstname.lastname@example.org.
U.S. Federal Trade Commission Enforcement
Our Privacy Shield compliance is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).
Third Parties and Data Processed
If we receive personal data subject to our certification under the Privacy Shield and then transfer it to a third-party service provider acting as an agent on our behalf, we have certain liability under the Privacy Shield if both (i) the agent processes the personal data in a manner inconsistent with the Privacy Shield and (ii) we are responsible for the event giving rise to the damage.
Choices Regarding Your Data
Requirement to Disclose
We may disclose personal data when we have a good faith belief that such action is necessary to: conform to legal requirements or to respond to lawful requests by public authorities, including to meet national security or law enforcement requirements; or to enforce our contractual obligations.
If you are a resident of a European country participating in the Privacy Shield and you have not received timely response to your concern, or we have not addressed your concern to your satisfaction, you may seek further assistance, at no cost to you, from the EU Data Protection Authorities, or the Swiss Federal Data Protection and Information Commissioner (FDPIC), depending on your location. European and Swiss users may, under specific conditions set forth in Annex I to the Principles, invoke binding arbitration through the Privacy Shield panel to resolve any complaints.
10. Our Policy Toward Children
11. Supplemental Notice for California Residents
If you are a resident of California, please click here to view our Supplemental Notice for California residents.
12. Supplemental Notice for Nevada Residents
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A. For more information, please contact us as set forth below.
Lookback Group, Inc
877 Cedar Street
Santa Cruz, CA 95060