Xariable, Inc. doing business as Loop Returns (“Loop,” “we,” “us,” and “our”) provides a platform to allow our customers (each a “Merchant”) to streamline and automate their workflows for returns and exchanges. This Privacy Policy is designed to help you understand how we collect, use, and share your personal information and to help you understand and exercise your privacy rights.
This Privacy Policy applies to personal information processed by us, including on our websites, and other online or offline offerings. To make this Privacy Policy easier to read, our websites, and other offerings are collectively called “Services”.
This Privacy Policy does not apply to any of the personal information that Merchants may process about their own end customers using Loop’s products and services (“Merchant Data”). The Merchants’ respective privacy policies govern the Merchants’ collection and use of Merchant Data. Any questions or requests relating to a Merchant’s collection or use of Merchant Data should be directed to such Merchant.
The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.
A. Information You Provide to Us Directly
We may collect the following personal information that you provide to us.
B. Information Collected Automatically
We may collect personal information automatically when you use our Services:
Our uses of these Technologies fall into the following general categories:
See Section 5 below to understand your choices regarding these Technologies.
C. Information Collected from Other Sources
We may obtain information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as the Shopify app store, we may collect information about you from that third-party application that you have made available via your privacy settings. We may also obtain your email address from a third-party service if you have given that third-party service permission to share such information.
D. Employees, Independent Contractors And Employment Candidates
We collect personal information and other information relating to employees, independent contractors and employment candidates, which may include name, address, email address, telephone number, resume information, notes on meetings, reports, references, interviewer impressions and other industry standard data, as well as data made publicly available or available to us on social networks, and other information that is customary or necessary to administer the employment or engagement relationship.
If the candidate or employee resides in a jurisdiction in which we are required to provide a separate applicant, employee or independent contractor privacy notice, our collection and use of the personal information is also governed by such separately-provided privacy notice. In such case, such separately-provided privacy notice shall prevail in the event of any conflict between such the terms of such notice and the terms of this Privacy Policy.
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:
B. Administrative Purposes
We use your information for various administrative purposes, such as:
C. Marketing and Advertising our Products and Services
We may use personal information to provide you with content and advertisements and to tailor such content and advertisements to be more relevant to you. We may also use, and permit third parties to use, cookies and other tracking technologies (such as web beacons and pixels) with the aim of collecting certain information to analyze behavior and customize the content and advertising displayed to you on the Service, as well as to provide you with advertisements for our products and services tailored to you across the Web, as permitted by applicable law.
If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, please review Section 5 below to exercise your choices.
D. Other Purposes
We also use your information for other purposes as requested by you or as permitted by applicable law.
We disclose your information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.
A. Disclosures to Provide our Services
The categories of third parties with whom we may share your information are described below.
B. Disclosures to Protect Us or Others
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement, national security requests or legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.
Please note you must separately opt out in each browser and on each device.
Please also see the following sections of this Privacy Policy regarding the rights of European residents and residents of certain US states.
We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot guarantee or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.
By using our Services or providing personal information 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 breach of our systems, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.
We store the personal information we collect as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
Residents of the (“UK”) and European Economic Area (“EEA”) are provided certain privacy rights under the UK and EU General Data Protection Regulations (“GDPR”). If you are located in Switzerland, The Swiss Federal Data Protection Act applies to our processing of personal data.
Legal basis for processing
We process personal data in accordance with the General Data Protection Regulation (the “GDPR”) under the following legal bases:
Data subject rights
Subject to any exemptions provided by law, EEA Data Subjects have the right to request:
Some of these rights apply only in certain circumstances and depend on the legal basis relied upon to process the data. As an example, the right to object applies to processing which is carried out on the basis of our legitimate interests and only if we cannot demonstrate compelling legitimate grounds which outweigh your rights, interests and freedoms. The same right does not apply to processing which is necessary for us to comply with our legal obligations or to perform a contract with you. These rights may extend to the personal data we collect through cookies or similar tracking technologies. Where processing is based on your consent, you may withdraw that consent at any time, although any processing previously carried out will still be legal.
International data transfer
If you are located outside the United States and choose to provide your information to us, you consent to our transferring your information to the countries other than the country in which the data was originally collected, including the United States, in order for us to process it there. Those countries may not have equivalent data protection laws as the country in which you provided the data.
When we transfer your data to other countries, we will protect the data as described in this Privacy Policy and comply with applicable legal requirements providing adequate protection for the transfer of data to countries outside the EEA, UK, and Switzerland. For example, we may rely on Standard Contractual Clauses (“SCCs”) for the transfer of personal data to countries that have not received an applicable adequacy decision, as well as on the UK’s International Data Transfer Addendum to the SCCs.
For more information on cross-border transfers of your Personal Data or the appropriate safeguards in place, please contact us at dpo@loopreturns.com, or escalate your complaints to our DPO as described below.
Complaints
We encourage interested persons to raise any concerns by emailing us in the first instance so that we can investigate and attempt to resolve any complaints and concerns regarding use and disclosure of information.
European data subjects may lodge a complaint with Loop’s Data Protection Officer by emailing dpo@loopreturns.com. Alternatively, data subjects may wish to lodge a complaint with a European Data Protection Authority.
Introduction. In this section, we provide information for residents of California, Virginia, Colorado, Connecticut, Utah, Nevada, Texas, Oregon, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey and other U.S. states in which an applicable state privacy law is currently in effect, as may be required under applicable privacy laws of such states from time to time (“State Privacy Laws”). For instance, the California Consumer Privacy Act (“CCPA”), as amended by the California Consumer Privacy Rights Act (“CPRA”), and the Virginia Consumer Data Protection Act (“VCDPA”), require that we provide their respective residents certain specific information about how we handle their personal information. Because certain State Privacy Laws require that we disclose specific information about how we handle certain personal information collected about residents of their states, the scope of this section may be different than the scope of the rest of our privacy policy.
Definitions of key terms.
Under State Privacy Laws, subject to certain exceptions, “personal information” is generally any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular resident or household in the applicable state.
A “Sale” of personal information under State Privacy Laws such as CCPA and VCDPA may occur any time a business sells or makes available any personal information to a third party for monetary or other valuable consideration.
A “Share” of personal information under the CPRA generally means disclosing, making available or communicating personal information by a business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged.
“Cross-context behavioral advertising” or "Targeted Advertising" means the targeting of advertising to a consumer based on the consumer’s personal information obtained from the consumer’s activity across businesses, distinctly-branded websites, applications, or services, other than the business, distinctly-branded website, application, or service with which the consumer intentionally interacts.
“Sensitive information” under State Privacy Laws is generally defined as personal information that reveals sensitive information about a consumer, such as social security, driver’s license, state identification card or passport numbers, account log-in, financial account, debit card or credit card numbers in combination with any required security or access code, password or credentials allowing access to an account, precise geolocation, data revealing racial or ethnic origin, religious beliefs, physical or mental health diagnosis, sexual orientation, or citizen or immigrant status, as well as processing of genetic or biometric data for identification, and personal data collected from a known child.
Rights under applicable laws. Depending on where you reside, you may have additional legal rights with respect to your information under State Privacy Laws. These rights are described below. While some of these rights apply generally, certain rights apply in limited cases. Consistent with State Privacy Laws, this Supplemental Notice provides a way to exercise such rights for residents of the above states. This section does not apply to any matters exempted from State Privacy Laws during the period of exemption, nor to matters covered by an applicable law prior to the relevant portion of the applicable State Privacy Laws going into effect.
Right to Know/Confirm
You may have the right, depending on your jurisdiction, to request the following about the personal information we have collected about you:
Under some State Privacy Laws, the above right to know is limited to events that occurred in the preceding 12 months, while other State Privacy Laws may have a different time limitation or no time limitation.
Right of Deletion
You have the right to ask us to delete the personal information we have collected from you, subject to exceptions the law provides.
For example, to the extent permitted by State Privacy Laws, we may deny a deletion request if retaining the information is necessary for us or our service provider(s) to: (a) complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you; (b) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; (c) debug products to identify and repair errors that impair existing intended functionality; (d) protect our legal interests, to defend our rights in a case of potential, threatened, or actual litigation, and to enforce our rights; (e) comply with a legal obligation and/or (f) fulfill internal and lawful uses that are compatible with the context in which you provided the information.
Right of Non-Discrimination
You have the right to not be discriminated against if you exercise these privacy rights. We will not discriminate against you, deny, charge different prices for, or provide a different quality of goods or services if you choose to exercise these rights.
Right to Opt-Out of Sales and/or Sharing of Personal Information
Under certain State Privacy Laws, you have the right to opt of the Sales (and/or Sharing, if you reside in California) of your personal information to third parties.
Right to Limit Use & Disclosure of Sensitive Personal Information
Other than to the limited extent described above, we do not collect, use, or disclose information we believe to be sensitive under State Privacy Laws.
Right to Revoke Consent
Under certain State Privacy Laws, you have the right to revoke consent you previously provided to the processing of your personal information, subject to exceptions provided by applicable law.
Notice at Collection
At or before the point of collection, notice must be provided to the individual of the categories of personal information collected and the purposes for which such information is used.
Exceptions to These Rights
The law provides for certain exceptions to the rights described above. We reserve the right to avail ourselves of these exceptions where applicable.
Right to Appeal
You may appeal our decision with respect to a request you have submitted by emailing us at dpo@loopreturns.com.
Some U.S. states provide you with the right to further appeal our determination to a consumer protection agency located in that state. For example:
Colorado – The Colorado Attorney General’s Office
Maryland – Maryland Attorney General Consumer Protection Division
Nebraska – Nebraska Attorney General’s Office
New Hampshire – Data Privacy Unit of the Consumer Protection and Antitrust Bureau of the New Hampshire Attorney General’s Office
New Jersey - Division of Consumer Affairs in the Department of Law and Public Safety of New Jersey
Texas - For denied appeals, visit the Texas Attorney General’s Office, Consumer Protection Division
Virginia – For denied appeals, visit the Virginia Attorney General’s Office, Consumer Protection Division
How to Exercise Your Rights.
If you live in a relevant jurisdiction and would like to send us a request to exercise one of your above rights, you may do so by contacting us at dpo@loopreturns.com.
You may designate an authorized agent to make a request on your behalf as permitted under law, though before we process that request, we will require that you provide the authorized agent written permission to do so and verify your identity directly with us.
To help protect your privacy and maintain security, we may take steps where required to verify your identity before granting you access to your personal information or complying with your request. We may not be able to respond to your request if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Notice of Categories of Personal Information; Categories of third parties to whom we disclose Personal Information:
(1) We collect the following categories of personal information:
Category of Personal Information Collected by Loop
Category of Third Parties Information is Disclosed to for a Business Purpose
Identifiers
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
Commercial information
Internet or other electronic network activity
Professional or employment-related information
(2) The types of Personal Information listed in the previous sub-section may be disclosed to the categories of third parties listed above in this Privacy Policy.
Sources and Use of Personal Information. We collect Personal Information from the following sources:
We use Personal Information for the business and commercial purposes listed above in this Privacy Policy.
Notice of Financial Incentives. We may offer you a program, benefit or other offering related to the collection of Personal Information, which may be considered a financial incentive under applicable State Privacy Laws. If you wish to withdraw from the benefit, please contact us. We will not reduce the value of any incentive you previously received from us if you do so, or discriminate against you if you exercise such rights after signing up for the benefit. Each financial incentive related to submission and use of Personal Information is based upon our reasonable but sole determination of the estimated value of such information, which takes into consideration, without limitation, estimates regarding the anticipated revenue generated from such information, the anticipated expenses which might be incurred in the collection, storage, and use of such information in the operation of our business, and other relevant factors related to the estimated value of such information to our business, as permitted under applicable State Privacy Laws. You will be notified of the Personal Information you are required to submit at the time you sign up for the incentive. For example, we may offer a one-time discount code if you provide your email address and sign up to receive our newsletter. The use of the discount code is subject to terms and conditions displayed in our terms of use. You may unsubscribe from the newsletter for any reason by contacting us at the email or using the unsubscribe option at the bottom of the newsletter email. Even if you unsubscribe, you can still use the discount code (subject to its terms and conditions) and exercise your rights as described above.
CCPA Metrics for 2023
Pursuant to CCPA Regulation 999.317(g), Loop informs you of the following metrics with respect to the year 2023:
The Services are not directed to minors (or other age as required by local law), and we do not knowingly collect personal information from children.
If you are a parent or guardian and believe your child has provided personal information to us without your consent, you may contact us as described below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it.
Third-Party Websites/Applications. The Services may contain links to other services, websites and applications, and other services, websites or applications may reference or link to our Services. These third-party services, websites and applications are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other services, websites or applications. Providing personal information to third-party services, websites or applications is at your own risk.
Changes to our Privacy Policy. We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.
If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at:
Xariable, Inc. d/b/a Loop Returns
797 N Wall St., Suite 201
Columbus, OH 43215
dpo@loopreturns.com
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