Privacy policy

Loom.AI Privacy Policy

Last Updated:  June 28, 2019

 

Welcome to Loom.ai!

Loom.ai offers an end-to-end real-time platform for creating, customizing and animating 3D avatars for enterprise applications.

Your privacy is important to us.

Protecting your privacy is really important to us.

Toward meeting that goal, we strive to comply with all applicable privacy laws.

We pledge to respect your privacy, to be transparent about our data practices, to keep your data safe and to only collect data that helps us provide and improve our products and services. With this in mind, we’re providing this Privacy Policy to explain our practices regarding the collection, use and disclosure of information that we receive through our Services. This Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Services. Our Data Protection Officer is Mahesh Ramasubramanian.

 


In this Privacy Policy:

We’ll refer to Loom.ai as “Loom” or “we” or “us”.
We’ll refer to our website as the “Site”.
We’ll refer to all the products and services we provide individually and collectively, as the “Services”.
We’ll refer to you, the person or entity accessing our Site or using our Services, as “you” or “your” or (if you are a purchaser of our Services) our “customer”.

Some other definitions we’ll be using in this Privacy Policy

What is a Data Controller? For general data protection regulation purposes, the “Data Controller” means the organization who decides the purposes for which, and the way in which, any Personal Information is processed. Our customers are the Data Controllers. 

What is a Data Processor? A “Data Processor” is an organization which processes Personal Information for a Data Controller. We are the Data Processor for our customers. As a Data Processor, we are bound by the requirements of the General Data Protection Regulations (the “GDPR”).

What is Data Processing? Data processing is any operation or set of operations (whether automated or not) performed upon Personal Information. Examples of data processing explicitly listed in the text of the GDPR are: collection, recording, organizing, structuring, storing, adapting, altering, retrieving, consulting, using, disclosing by transmission, disseminating or making available, aligning or combining, restricting, erasure or destruction.

What is Personal Information? Personal information is any information which is about you, from which you can be identified. Personal Information includes information such as an individual's name, address, telephone number, e-mail address or photograph. Personal Information also includes information about an individual's activities, such as information about his or her activity on Site or our Services, and demographic information, such as date of birth, gender, geographic area, and preferences, when any of this information is linked to personal information that identifies that individual. Personal Information does not include "aggregate" or other non-personally identifiable information. Aggregate information is information that we collect about a group or category of products, services, or users that is not personally identifiable or from which individual identities are removed.

 

How do we collect Personal Information?

In our service as a Data Processor, we collect Personal Information from Data Controllers in several ways:

Information you provide to us directly (for example, information you may provide in connection with accessing or purchasing our products or services)
Information you provide us when you contact us for help
If you contact us for help, we may collect your name and email address along with additional information you provide in your request so that we can provide you with assistance and improve the Service.
Information we may receive from third parties
We may receive information about you, including Personal information, from third parties, and may combine this information with other personal information we maintain about you. If we do so, this Privacy Policy governs any combined information that we maintain in a personally identifiable format.

 

What information do we collect?

We may collect the following types of personal information from you:

Your first and last name, username and email address
Your company’s name
Your (and/or your company’s) physical address
Information you choose to provide us through our Services (including, for example, your birthdate, gender, photograph, and/or phone number)
Information related to your camera and photos. Many of our services require us to collect images and other information from your device’s camera and photos. For example, you won’t be able to upload photos from your camera unless we can access your camera or photos.
We may also collect and aggregate information about the use of our Site and our Services. That information could include information such as your Internet Protocol (IP) address, browser type, operating system, the web page that you were visiting before accessing our Site, the pages or features of our Site which you browsed and the time spent on those pages or features, search terms, the links on our Site that you clicked on, and other statistics.
An IP or Internet Protocol Address is a unique numerical address assigned to a computer as it logs on to the internet.
If you access our Site using a mobile device, we may collect information such as a device identifier, user settings and the operating system of your device, as well as information about your use of our Services.

 

What do we use your Personal Information for?

We will use your Personal Information in compliance with this Privacy Policy to provide you with the best experience possible, and to improve and protect the Services. Any of the information we collect from you may be used in any of the following ways:

To operate, maintain, and provide to you the features and functionality of the Services (for example, data and logs are used in research to understand and improve the Services; to troubleshoot the Services; to detect and protect against error, fraud or other criminal activity; and to enforce this Privacy Policy and the Loom Terms of Use).
To compile statistics and analysis about your and other customers’ use of our Site and our Services.
To improve our Site and our Services — we continually strive to improve our Site offerings based on the information and feedback we receive from you.
To improve customer service — your Personal Information helps us to more effectively respond to your customer service requests and support needs.
To send periodic emails — the email address you provide may be used to send you information, notifications that you request about changes to our Services, to alert you of updates, and to send periodic emails containing information relevant to your account.
If you purchase anything through the use of our Services, then to enable you to purchase products or services from our Site.
We may also use Personal Information you provide to contact you regarding products, services, and offers that we believe you may find of interest. We allow you to opt-out from receiving marketing communications from us as described in the "Your Choices" section below.
In addition, anonymized data that does not identify you may be used for marketing and promotional use. Please see the section of this Policy titled “Do We Disclose any Personal Information to Outside Parties?” to learn more.

We may also use your Personal Information where necessary for us to comply with a legal obligation, including to share information with government and regulatory authorities when required by law or in response to legal process, obligation, or request.

We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose your Personal Information 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 processes (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.

We will request your consent before we use or disclose your Personal Information for a materially different purpose than those set forth in this Policy. Consent may be obtained by any legally sufficient method. For example, depending on the circumstances and applicable laws, consent may be obtained by providing you with notice and the opportunity to opt out.

 

Your Choices About Your Personal Information

We may use the information we collect or receive to communicate directly with you. We may send you emails containing newsletters, promotions and special offers. If you do not want to receive such email messages, you will be given the option to opt out. If you receive commercial email from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt out from receiving commercial email from us by sending us an email or by writing to us at the address given at the end of this Privacy Policy. Additionally, if we offer user account functionality on any of our Services, we may allow you to view and modify settings relating to the nature and frequency of promotional communications that you receive from us. Please be aware that if you opt out of receiving commercial e-mail from us, it may take up to ten business days for us to process your opt-out request, and you may receive commercial e-mail from us during that period. Additionally, even after you opt out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding our Services (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, and technical and security notices).

You may modify Personal Information that you provide to us from your Loom account preferences. If you remove data from your Loom account, it will no longer appear to you or others who use the Loom Service. Backups of that data will remain associated with your Loom account and in our archive servers.

Your Rights to Opt Out. You can opt out of receiving contests, giveaways, surveys and promotional emails by changing the notification preferences in your account settings or by unsubscribing via the “Unsubscribe” link in any Loom email. Opting out of these emails will not end transmission of important service-related emails that are necessary to your use of the Services. In addition, you may opt out of allowing third-party online advertising networks to collect information from our Site by adjusting the browser “settings” on your computer or mobile device. Please refer to your mobile device or browser’s technical information for instructions on how to delete and disable cookies, and other tracking/recording tools. Depending on your type of device, it may not be possible to delete or disable tracking mechanisms on your mobile device. Note that disabling cookies and/or other tracking tools prevents us or our business partners from tracking your browser’s activities in relation to the Service, and for use in targeted advertising activities by third parties. However, doing so may disable many of the features available through the Services. If you have any questions about opting out of the collection of cookies and other tracking/recording tools, you can contact us directly.

 

How do we protect your Personal Information?

We care about the security of your Personal Information. To help protect your privacy and security, we take reasonable steps (such as requesting a unique password to verify your identity before granting you access to your account), and we use commercially reasonable safeguards designed to preserve the integrity and security of all information collected through the Services, and to prevent accidental loss and from unauthorized access, use, alteration, and disclosure. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure We cannot ensure or warrant the security of any information you transmit to us or guarantee that information on the Services may not be accessed, disclosed, altered, or destroyed.

You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from us. We are not responsible for any unauthorized disclosure of Personal Information or other information caused by any person to whom you provide access to your account, or caused by any other third party that gains access to your account by circumventing our security measures or by using your password. You agree to indemnify and hold harmless Loom from and against any and all liability arising in any way from the access to the Site by persons to whom you have provided your online ID and/or online password. Your privacy settings may also be affected by changes to the functionality of third-party websites and services that you add to the Loom Service, such as social networks. We are not responsible for the functionality or security measures of any third party.

Upon becoming aware of a breach of your Personal Information, we will notify you as quickly as we can and will provide timely information relating to the breach as it becomes known in accordance with any applicable laws and regulations or as is reasonably requested by you. Despite the foregoing, you acknowledge and agree that this clause constitutes notice by Loom to you of the ongoing existence and occurrence or attempts of Unsuccessful Security Incidents for which no additional notice to Client shall be required. “Unsuccessful Security Incidents” means, without limitation, pings and other broadcast attacks on Loom’s firewall, port scans, unsuccessful log-on attempts, denial of service attacks, and any combination of the above, so long as no such incident results in unauthorized access, use or disclosure of Your Information. If you have any concerns over the security of your Personal Information, please contact us at support@loomai.com.

 

Do we use cookies?

Yes. Cookies are small files that a website or its service provider transfers to your computer’s hard drive through your Web browser (if you allow). These cookies enable the Site to recognize your browser and, if you have a registered account, associate it with your registered account. We may use both session Cookies and persistent Cookies to identify that you’ve logged in to the Services and to tell us how and when you interact with our Site. We use cookies to remember information so that you will not have to re-enter it during your visit or the next time you visit the Site, and to understand and save your preferences for future visits and compile aggregate data about Site traffic and Site interaction so that we can offer better Site experiences and tools in the future. They tell us which parts of the Loom Service you’ve visited so we can figure out which promotions you may like to see or to alert you to software compatibility issues. We may also use Cookies to monitor aggregate usage and web traffic routing on our Services and to customize and improve our Services, to provide custom, personalized content and information, including advertising, and to diagnose or fix technology problems.

In addition, we may use Cookies to automatically update your Loom application. Unlike persistent Cookies, session Cookies are deleted when you log off from the Services and close your browser. Although most browsers automatically accept Cookies, you can change your browser options to stop automatically accepting Cookies or to prompt you before accepting Cookies. Please note, however, that if you don’t accept Cookies, you may not be able to access all portions or features of the Site or the Services.

We may also collect information via standard server logs or clear GIFs (also known as “Web beacons”). Web beacons and pixel tags are images embedded in a webpage or email for the purpose of measuring and analyzing usage and activity. Loom, or third-party service providers acting on our behalf, may use web beacons and pixel tags to help us analyze usage and improve our functionality. Social media tools, like widgets and plug-ins, may be offered so you can share information from Loom on other sites such Facebook and Twitter. These interactive mini-programs collect your IP address, record the pages you visit on our Site, and set cookies that will enable the widget to function properly. Your interactions with these widgets are governed by the privacy policy of the company providing them, not by this Privacy Policy. We may also use the Facebook and Twitter pixel tags to help us understand how effective our marketing is on those sites. If we link or associate any information gathered through passive means with Personal Information, we treat the combined information as Personal Information under this Privacy Policy. Otherwise, we use information collected by passive means in non-personally identifiable form only.

We use the following third-party advertising cookies to present you with opportunities to access Services on our Site: We use Google Analytics cookies to allow us to see how you use our Services so that we can improve your experience. We encourage you to read the Google Privacy Policy. If you prefer to not have data reported by Google Analytics, you can install the Google Analytics Opt-out Browser Add-on. Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Personal Information collected to track and examine the use of our Services, to prepare reports on its activities and share them with other Google services. Google may use the Personal Information collected to contextualize and personalize the ads of its own advertising network. Personal Information collected: Cookies and Usage Data. Place of processing: United States.

“Do Not Track” options will not affect how we use your Personal Information

Although we do our best to honor the privacy preferences of our customers, we are not able to respond to Do-Not-Track signals from your browser at this time. As discussed above, we track websites and app usage information through the use of cookies for analytic and internal purposes only. Because we do not collect this information to track you across websites or apps over time, your selection of the “Do Not Track” option provided by your browser will not have any effect on our collection of cookie information for analytics or internal purposes.

 

Who at Loom may access your Personal Information?

Designated members of our staff may access Personal Information to help our customers with any questions they have, including help using our Services, investigating security issues, or following up on bug fixes with a customer. This activity is logged in our system for compliance, and we maintain different levels of access for its employees depending on their role in our company. For certain payment processors, only the Data Protection Officer has the ability to access additional business metrics from the payment processor (for purposes of investigating potential security breaches and fraud, or otherwise with the permission of the customer). In some cases, Personal Information may be accessible to certain persons involved with the operation of the Services (administration, sales, marketing, legal, system administration).

 

Do we disclose any Personal Information to outside parties?

Except as set out below, we do not sell, trade, or otherwise transfer to outside parties your Personal Information. Non-personally identifiable visitor information, however, may be provided to other parties for marketing, advertising, or other uses.

We may share your Personal Information with other companies owned by or under common ownership as Loom, which also includes our subsidiaries (i.e., any organization we own or control).
These companies will use your Personal Information in the same way as we can under this Privacy Policy.

We may disclose your Personal Information to third-party service providers (for example, payment processing, data storage and processing facilities, and email management, or identifying and serving targeted advertisements, content or service fulfillment, or providing analytics services) that assist us in our work. These companies are obligated by contract to safeguard any Personal Information they receive from us.
We limit the Personal Information provided to these service providers to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such Personal Information.

We may contract with third-party service providers to assist us in better understanding our Site’s visitors.
These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business.

We may also release your Personal Information when we believe release is appropriate to comply with the law, enforce our Site policies, or protect our or others’ rights, property, or safety.
In particular, we may release your Personal Information to third parties as required to (i) satisfy any applicable law, regulation, subpoena/court order, legal process or other government request, (ii) enforce our Terms of Use Agreement, including the investigation of potential violations thereof, (iii) investigate and defend ourselves against any third party claims or allegations, (iv) protect against harm to the rights, property or safety of Loom, its users or the public as required or permitted by law and (v) detect, prevent or otherwise address criminal (including fraud or stalking), security or technical issues.

If you ask us to do so, we may share your Personal Information with the public and other users of the Services. Any information or content that you voluntarily disclose for public posting to the Service, such as user-generated content, becomes available to the public. If you remove information that you posted to the Services, copies may remain viewable in cached and archived pages of the Service, or if other users of the Services have copied or saved that information.

We may share or sell aggregated, de-identified data that does not identify you, with partners and the public in a variety of ways. When we provide this information, we perform appropriate procedures so that the data does not identify you and we contractually prohibit recipients of the data from re-identifying it back to you. For example, in certain situations, businesses or third party websites we’re affiliated with may sell or provide products or services to you through or in connection with the Services (either alone or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Information with that affiliated business only to the extent that it is related to such transaction or service. We have no control over the policies and practices of third party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all such business’ or websites’ policies

You can direct us to share data with third parties. For example, you might authorize us to link your Loom account with a third-party app. Once you direct us to share your data with a third party, that data is governed by the third-party’s privacy policy.

Please remember that any content you upload to your public user profile, along with any Personal Information or content that you voluntarily disclose online in a manner other users can view (on discussion boards, in messages and chat areas, etc.) becomes publicly available, and can be collected and used by anyone. Your user name may also be displayed to other users if and when you send messages or comments or upload images or videos through the Services and other users can contact you through messages and comments.

Your Personal Information may also be transferred to another company in the event of a transfer, change of ownership, reorganization or assignment of all or part of our businesses or assets.
This will occur if the parties have entered into an agreement under which the collection, use and disclosure of the information is limited to those purposes of the business transaction, including a determination whether or not to proceed with the business transaction. You will be notified via email or prominent notice on our websites for thirty (30) days of any such change in ownership or control of your personal information or as otherwise may be required or permitted by law.

How do we handle global transfers and processing of your Personal Information?

Although we welcome people from all over the world, keep in mind that no matter where you live or where you happen to use our services, your Personal Information may be shared. This means that we may collect your Personal Information from, transfer it to, and store and process it in the United States and other countries outside of where you live. For example, some of our third-party providers may be located in different countries. Where this is the case, we will take steps to make sure the right security measures are taken so that your privacy rights continue to be protected as outlined in this Privacy Policy. By submitting your Personal Information, you’re agreeing to this transfer, storing or processing. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including Personal Information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction. If we transfer your Personal Information from the European Union. and process it in the United States, we do so in accordance with applicable law. In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

 

Retention of your Personal Information

We retain your Personal Information for as long as we need to fulfill our Services (for example, for as long as you maintain an account with us). Generally, if you deactivate your account with us, data that can identify you will be removed from the Loom Service. Backup copies of this data will be removed from our server based upon an automated schedule, which means it may persist in our archive for a short period. Loom may continue to use your de-identified data after you deactivate your account. In addition:

We may keep data linked to cookies and other online identifiers up to three years.
If we are involved in litigation or a governmental or regulatory investigation, then we keep data throughout the period of litigation or investigation and for 5 years after that. If a settlement means that we have to keep data for longer, then we keep data for the period required to administer the settlement. If we provide data to law enforcement agencies, then we keep a record of this for one year beyond the end of the investigation.
We may retain Personal Information from closed accounts to comply with applicable laws, detect or prevent fraud, collect any fees owed, resolve disputes, assist with or process claims, troubleshoot problems, assist with any investigation, comply with audits and investigation, to enforce our Terms of Use, and take other actions reasonably necessary, permitted, or required by applicable law.

 

Third-party Links

This Privacy Policy only applies to our Site, so when you link to other websites you should read those separate and independent privacy policies. Your browsing and interaction on any third-party websites, app, or service, including those that have a link or advertisement on our Site, are subject to that third party’s own rules and policies. We are not responsible for the practices employed by websites, mobile apps, or services linked to or from the Service, including the information or content contained therein. In addition, you agree that we are not responsible for and we do not have any control over any third parties that you authorize to access your Personal Information. However, we seek to protect the integrity of our Site and welcome any feedback about these websites.

 

Children’s Online Privacy Protection Act Compliance

Our Site, products and services are all directed to people who are at least 13 years old or older. We strive to comply with the requirements of COPPA (Children’s Online Privacy Protection Act). If this server is in the United States, and you are under the age of 13, do not use this Site. We do not knowingly collect personal information from children under the age of 13 or your country’s age of minority. If you nevertheless believe that your child has provided us with their personal information, please contact us at support@loomai.com.com and we will delete it.

 

Online Privacy Policy Only

This Privacy Policy applies only to information collected through our Site and not to information collected offline.

 

Your Consent

By accessing or using our Site, you consent to this Privacy Policy. You agree that we may use Your Personal Information (including store, record, transmit, maintain, use, reproduce, modify, adapt, and distribute it) to the extent necessary to carry out our obligations in providing the Site and the Services, and to help us improve the Site and the Services and make them better for all users of our Site and our Services.

 

Your Rights

Other rights you have include the rights to:

Withdraw your consent for us to process your Personal Information.
You have the right to withdraw consent where you have previously given your consent to the processing of their Personal Information.
Object to the processing of your Personal Information.
You have the right to object to the processing of your Personal Information if the processing is carried out on a legal basis other than consent.
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Information to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at support@loomai.com.
Ask for a copy of your Personal Information.
This is known as a Subject Access Request. If you would like a copy of some or all your Personal Information, please email support@loomai.com.
Ask us to correct your Personal Information.
It is your right to lodge an objection to the processing of your Personal Information if you believe that the legal ground “relating to your particular situation” applies. The only reasons we will be able to deny your request is if we can show compelling legitimate grounds for the processing, which override your interest, rights and freedoms, or the processing is for the establishment, exercise or defense of a legal claims.
Ask us to transfer your Personal Information to other organizations.
Ask us to erase certain categories or types of information.
If you choose to remove your Personal Information, you acknowledge that we may retain archived copies of your Personal Information in order to satisfy our legal obligations, or where we reasonably believe that we have a legitimate reason to do so.
Ask us to restrict certain processing.
You have the right to object to processing of Personal Information. Where we have asked for your consent to process information, you have the right to withdraw this consent at any time.
“Opt out” of certain sharing of Personal Information.
You may limit or "opt out" of our sharing your Personal Information with third parties.
For further information on opting out, please see the “Your Choices” section of this Privacy Policy.
Lodge a complaint.
You have the right to bring a claim before a competent data protection authority.

We are committed to resolving any complaints about our collection or use of your Personal Information. Individuals with inquiries or complaints regarding this Policy should contact our Privacy Officer as follows: LoomAI, Inc., Attn: Privacy Officer, 525 Brannan Street, Suite 206, San Francisco, CA 94107; or support@loomai.com.

 

Changes to our Privacy Policy

If we decide to change our privacy policy, we will post those changes on this page: but any future changes will not affect data that was collected under a previous version of this Policy. If we are going to use Personal Data collected through the Site in a manner materially different from that stated at the time of collection, then we will notify users via email and/or by posting a notice on our Site for 30 days prior to such use or by other means as required by law.

 

Contacting Us

If you have any questions, comments, or concerns about this privacy policy, please contact us using the following contact information:

LoomAI, Inc.
Attn: Privacy Issues

525 Brannan Street, Suite 206

San Francisco, CA 94107

support@loomai.com