Explore Loop Privacy Policy
LAST UPDATED: June 29, 2023
LOOP (together with our affiliates, “LOOP”, “Company” “we”, or “us”) respect your privacy.
LOOP offers a service distribution solution, that facilitates the sale, purchase, and delivery of
consumer product goods (“Goods”) that are packaged in durable and refillable packaging
and the return and processing of the durable and refillable packaging, once used, for re-use
with additional purchases of the same Goods, which includes the tracking required to ensure
the quality assurance of such cleaned and refilled packaging (together with the LOOP
Platform, the “Services”).
In connection with our Services, this Privacy Policy describes the types of personal
information we collect on www.exploreloop.com (the “Site”), (the “Personal Information”) the
purposes for which we collect that Personal Information, the other parties with whom we may
share it and the measures we take to protect the security of your Personal Information. It also
tells you about your rights and choices with respect to your Personal Information, and how
you can contact us about our privacy practices.
Our privacy practices may vary among the countries and regions in which we operate toreflect local practices and legal requirements as described below. Please refer to Section 12
below for more information regarding any specificities applicable to your Personal Information
and rights regarding your Personal Information in these countries or regions.

1. Personal Information We Collect
Information you give us
Personal information that you may provide through the Site or otherwise communicate with
us includes:
Account information, we collect information from you when you sign up to register for an
account subsequently (“Account”) via Loop, such as your first name, last name, email
address, postcode, city, state and/or country of residence ;Marketing information, such your preferences for receiving marketing communications anddetails about how you engage with them;2. How We Use Your Personal
Information
To provide our Services
If you use our Services, we use your personal information to inform you in regions not yet
serviced by Loop to be informed once a Loop service is launched in your region.

To communicate with you
If you request information from us, register online, or participate in our surveys, promotions or
events, we may send you Loop-related marketing communications as permitted by law. You
will have the ability to opt out of such communications as described below.

To comply with law
We use your personal information as we believe necessary or appropriate to comply withapplicable laws, lawful requests and legal process, such as to respond to subpoenas orrequests from government authorities.

With your consent
We
may
requestyour
support@loopmobileapp.com

consent

to

use

your

personal

informationtoTo create anonymous data
We may create anonymous data from your personal information and other individuals whose
personal information we collect. We make personal information into anonymous data by
excluding information that makes the data personally identifiable to you, and use thatanonymous data for our lawful business purposes.

For compliance, fraud prevention and safety
We use your personal information as we believe necessary or appropriate toa) enforce the terms and conditions that govern the Service;b) protect our rights, privacy, safety or property, and/or that of you or others; andc) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal
activity.

3. Cookies and Similar Technologies
What are cookies?
We may collect information using “cookies” or similar technologies (altogether, “Cookies”).
Cookies are small data files stored on the hard drive of your computer or mobile device by a
website. We may use bothsession Cookies (which expire once you close your web browser) and persistent Cookies(which stay on your computer or mobile device until you delete them) to provide you with amore personal and interactive experience on our Site.
We use two broad categories of Cookies:(1) first party Cookies, served directly by us to your computer or mobile device, which we use
to recognise your computer or mobile device when it revisits our Site; and(2) third party Cookies, which are served by service providers on our Site, and can be usedby such service providers to recognise your computer or mobile device when it visits otherwebsites.

Cookies we use
Our Site uses the following types of Cookies for the purposes set out below:● Local Storage: This technology allows our Site to remember choices you make when
you use our Site. The purpose of this is to provide you with a more personal
experience and to avoid you having to re-select your preferences every time you visit
our Site.
● Analytics and Performance Cookies: These cookies are used to collect information
about traffic to our Site and how users use our Site. The information gathered may
include the number of visitors to our Site, the websites that referred them to our Site,
the pages they visited on our Site, what time of day they visited our Site, whether they
have visited our Site before, and other similar information. We use this information to
help operate our Site more efficiently, to gather broad demographic information,
monitor the level of activity on our Site, and improve the Site.

Disabling Cookies
You can typically remove or reject Cookies via your browser settings. In order to do this,follow the instructions provided by your browser (usually located within the “settings,” “help”“tools” or “edit” facility). Many browsers are set to accept Cookies until you change yoursettings.
Further information about Cookies, including how to see what cookies have been set on yourcomputer or mobile device and how to manage and delete them, visit
www.allaboutcookies.org.
If you do not accept our Cookies, you may experience some inconvenience in your use of ourSite. For example, we may not be able to recognize your computer or mobile device and you
may need to log in every time you visit our Site.

4. How We Share Your Personal
Information
Service Providers
We may employ third party companies and individuals to administer and provide the Services
on our behalf (such as customer support, hosting and storage, analytics, email delivery,
marketing/advertising and database management services). These third parties may use yourinformation only as directed by the Company and in a manner consistent with this Privacy
Policy, and are prohibited from using or disclosing your information for any other purpose.

Compliance with Laws and Law Enforcement; Protectionand Safety
Company may disclose information about you to government or law enforcement officials or
private parties as required by law, and disclose and use such information as we believe
necessary or appropriate toa) comply with applicable laws and lawful requests and legal process, such as to respond to
subpoenas or requests from government authorities;b) enforce the terms and conditions that govern the Service; c) protect our rights, privacy,
safety or property, and/or that of you or others; andd) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal
activity.

Business Transfers
Company may sell, transfer or otherwise share some or all of its business or assets, including
your personal information, in connection with a business deal (or potential business deal)
such as a merger, consolidation, acquisition, reorganization or sale of assets or in the eventof bankruptcy, in which case we will make reasonable efforts to require the recipient to honor
this Privacy Policy.

Social Networking Services (SNSs)The Services may enable you to post content to SNSs. If you choose to do this, we will
provide information to such SNSs in accordance with your elections. You acknowledge andagree that you are solely responsible for your use of those websites, such as Facebook orApp, such as WhatsApp and that it is your responsibility to review the terms of use andprivacy policy of the applicable website or service. We will not be responsible or liable for:1) the availability or accuracy of such website, App or service;2) the content, products or services on or availability of such website, App or service;3) the data shared by other users of the websites, App or service; or (iv) your use of any
such website, App or service.

5. Your Choices
Access, update, correct or delete your information
You may review, update, correct or delete the personal information by contacting us at
support@loopmobileapp.com or if you have additional requests or questions.

Choosing not to share your personal information
Where we are required by law to collect your personal information, or where we need yourpersonal information in order to provide the Services to you, if you do not provide thisinformation when requested (or you later ask to delete it), we may not be able to provide youwith the Services. We will tell you what information you must provide to receive the Services
by designating it as required in the Services or through other appropriate means.

Additional information for certain jurisdictions
Loop is committed to respecting the privacy rights of individuals under all privacy laws
applicable to us. Some privacy laws require that we provide specific information about
individual rights, which we have set forth at the end of this Privacy Policy:● California: if you are a California resident, you have certain rights under California
privacy laws regarding your personal information as set forth below in Section 12
Additional Information for Residents in Certain Jurisdictions.
● EU/EEA/UK: if you are in the European Union / European Economic Area/United
Kingdom, please go to Section 12 Additional Information for Residents in Certain
Jurisdictions below for details about your rights under the GDPR.
● Brazil/LGPD: if you are in Brazil and subject to the Brazilian General Data Protection
Law (LGPD), please go to Section 12 Additional Information for Residents in Certain
Jurisdictions below for details about your rights under the LGPD.

6. Security
We take a number of organizational, technical and physical measures designed to protect the
Personal Information we collect, both during transmission and once received. These include
but are not limited to:● Forcing APIs (REST and Pub/Sub) to operate over encrypted ports (HTTPS and
TLS).
● Data encryption between services within the cloud based systems used by Loop.
● File encryption over file servers.
● Highly restricted access to Production Environments.
However, no security safeguards are 100% secure and we cannot guarantee the security ofyour Personal Information. We will comply with applicable laws and regulations requiring that

we notify you in the event your Personal Information is compromised as a result of a breachof our security measures.

7. Children
Our Services are not directed to children under 16. If a parent or guardian becomes awarethat his or her child has provided us with information without their consent, he or she should
contact us. If we learn that we have collected personal information from a child under age 16,
will delete such information from our files as soon as reasonably practicable.

8. Sensitive personal
category data)

data(Special

We ask that you not send us, and you not disclose, any sensitive personal data (e.g.,
information related to racial or ethnic origin, political opinions, religion or other beliefs, health,biometrics or genetic characteristics, criminal background or trade union membership) on or
through the Site or otherwise to us.
If you send or disclose any sensitive personal data to us when you use the Site, you must
consent to our processing and use of such sensitive personal data in accordance with thisPrivacy Policy. If you do not consent to our processing and use of such sensitive personaldata, you must not submit such sensitive personal data to our Site.

9. Other Important Privacy Information
Third party websites sites, Apps and services
The Services may contain links to other websites and services. These links are not anendorsement, authorisation or representation that we are affiliated with that third party. We do
not exercise control over third party
websites or services, and are not responsible for their actions. Other websites and services
follow different rules regarding the use or disclosure of the personal information you submit tothem. We encourage you to read the privacy policies of the other websites you visit andservices you use.

User generated content
We may make available on our Site, or link to, features that allow you to share information
online (e.g., on message boards, in chat areas, in file uploads, through events, etc.). Please
be aware that whenever you voluntarily disclose personal information online, that information
becomes public and can be collected and used by others. We have no control over, and takeno responsibility for, the use, storage or dissemination of such publicly-disclosed personal
information.

Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. We encourage you toperiodically review this page for the latest information on our privacy practices. If we makechanges to this Privacy Policy we will post them on the Site and update the Last Updated
date above. If we make material changes to this Privacy Policy you will be notified via email(if you have an Account where we have your contact information) or another manner throughthe Services that we believe reasonably likely to reach you. We will obtain your consent toany material Privacy Policy changes if and where this is required by applicable dataprotection laws.
Any modifications to this Privacy Policy will be effective upon our posting of the new terms
and/or upon implementation of the new changes on the Service (or as otherwise indicated at
the time of posting). In all cases, your continued use of the Service after the posting of any
modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

10. Legal basis for processing
We only use your personal information as permitted by law. We are required to inform you ofthe legal bases of our processing of your personal information, which are described in thetable below. If you have questions about the legal basis of how we process your personal
information, contact us at support@loopmobileapp.com● Contract: Processing is necessary to take steps that you request prior to signing up
for the Services or to perform the Services.
● Consent: We rely on your consent to provide you with advertising and to send out
marketing communications. If we want to send you marketing communication, you willneed to first provide an expressed interest in “opting in” to communications. For
example when you are filling out a contact or other form, if you click on the option to
Sign up for newsletters & participate in research, you are opting in to marketing
communications emails. You can later opt in or out by contacting us. Where we rely
on your consent you have the right to withdraw it anytime in the manner indicated in
the Service or by contacting us.
● Legitimate Interest: We rely on our Legitimate Interest to carry out the following:○ To communicate service and support related information with you especiallywhen LOOP launches in your region○ To carry out analytical reports using anonymised data
○ For compliance, fraud prevention and safety○ Records of communications sent to you or that we receive from you in relation
to an event you will attend/have attended.
○ Records of events, including photography and video recordings of events○ To send out service related communications that we believe will be of benefit
to you because of a product or service that you have expressed interest in (notrequiring consent).
We make sure we consider and balance any potential impact on you (both positive andnegative) and your rights before we process your personal information for our legitimate
interests. We do not use your personal information for activities where our interests areoverridden by the impact on you (unless we have your consent or are otherwise required or
permitted to by law).
Where we rely on legitimate interest for marketing you have the right to object.
● Legal obligation: We rely on this basis when the processing is necessary for you tocomply with the law (not including contractual obligations). For example, forprocessing financial data.
● Use for new purposes: We may use your personal information for reasons notdescribed in this Privacy Policy where permitted by law and the reason is compatible
with the purpose for which we collected it. If we need to use your personal information
for an unrelated purpose, we will notify you and explain the applicable legal basis.

11. Retention
We will only retain your personal information for as long as necessary to fulfill the purposes
we collected it for, including for the purposes of satisfying any legal, accounting, or reporting
requirements.
To determine the appropriate retention period for personal information, we consider theamount, nature, and sensitivity of the personal information, the potential risk of harm fromunauthorized use or disclosure of your personal information, the purposes for which we
process your personal information and whether we can achieve those purposes through othermeans, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity,
Financial and Transaction Information) for legal or regulatory requirements, this can include
but is not limited to tax and audit purposes.
In some circumstances we may anonymise your personal information (so that it can no longer
be associated with you) in which case we may use this information indefinitely without further
notice to you.

12. Additional Information for Residents
in Certain Jurisdictions
In this section, we set forth additional information as required under applicable privacy laws incertain jurisdictions.

A. European Union / European Economic Area / United
Kingdom
Loop is headquartered in the United States and has affiliates and service providers in othercountries, and your personal information may be transferred to the United States or otherlocations outside of your state, province, country or other governmental jurisdiction where
privacy laws may not be as protective as those in your jurisdiction.

Whenever we transfer your personal information out of the EEA to countries not deemed by
the European Commission to provide an adequate level of personal information protection,
the transfer will be based on one of the following safeguards recognized by the European
Commission as providing adequate protection for personal information, where required by EU
data protection legislation:● the country to which we send the Personal Information may be approved by theEuropean Commission or● the recipient may have signed a contract based on “standard contractual clauses”
approved by the European Commission, obliging them to protect your Personal
Information,● there is the lawful use of an appropriate cross-border transfer safeguard or applicable
derogations.
As a resident of the European Union (EU) and the European Economic Area (EEA), you havethe following rights, under the GDPR, regarding your Personal Information:
Right to access: You have the right to obtain from us confirmation as to whether or not
personal data concerning you are processed, and, where that is the case, you have the rightto request and get access to that personal data.
Right to withdraw consent: Where we have asked for your consent to process your
Personal Information, you can withdraw this consent at any time by contacting us at
support@loopmobileapp.com. If you wish to opt out of receiving our commercial messages,
you can also do so by at any time using the "unsubscribe" link at the bottom of such e-mail.
Withdrawing a consent may lead to fewer possibilities to use our Services.
Right to rectification: You have the right to obtain from us the rectification of inaccurate
personal data and you have the right to provide additional personal data to complete any
incomplete personal data.
Right to object: In certain cases, you have the right to object to processing of your personaldata, including data relating to profiling. You have the right to object at further processing ofyour personal data insofar as such data have been collected for direct marketing purposes.
We shall then no longer process your personal data unless we demonstrate other compelling
legitimate grounds for our processing that override your interests, rights and freedoms or for
legal claims.
Right to restriction of processing: You have the right to request from us restriction ofprocessing, applicable for a certain period and/or for certain situations e.g. to allow ourverification of accuracy of personal data after your contesting of accuracy or to prevent us
from erasing personal data when personal data are no longer necessary for the purposes but
still required for your legal claims or when our processing is unlawful. Restriction ofprocessing may lead to fewer possibilities to use our Services.
Right to data portability: You have the right to receive from us in a structured format yourpersonal data and you have the right to (let) transmit such personal data to another controller.
Right to erasure: You have the right to have personal data we process about you erased
from our systems if the personal data are no longer necessary for the related purposes, if wehave unlawfully processed thepersonal data or if you object to processing for direct marketing. Furthermore, you have theright to erase if you withdraw consent or object to our processing as meant above, unless wehave a legitimate ground to not erase the data. We may not immediately be able to erase allresidual copies from our servers and backup systems after the active data have been erased.
Such copies shall be erased as soon as reasonably possible.
Right to be Not Subject to Automated Individual Decision-Making: You have the right tonot be subject to a decision based solely on automated processing.
Right to Filing Complaints: We hope that we can satisfy queries you may have about theway we process your data. If you have any concerns about how we process your data, you
can get in touch with us, using the details below. In the event you have unresolved concerns,
you also have the right to contact your local data protection authority. We hope this will not benecessary and would like to assure you we will do our best to resolve any dissatisfaction you
may have.

B. California
In this section, we provide information for California residents as required under California
privacy laws, including the California Consumer Privacy Act (CCPA) and the California
Privacy Rights Act (CPRA), which requires that we provide California residents certain
specific information about how to handle their personal information. This section does notaddress or apply to ourhandling of:● publicly available information made lawfully available by state or federal governments● personal information that is subject to an exemption under Section 1798.145(c) – (f) of
the CCPA (such as protected health information that is subject to HIPAA or the
California Medical Information Act, and non-public information subject to theGramm-Leach Bliley Act or the California Financial Information Privacy Act)● personal information we collect about job applicants, independent contractors, orcurrent or former full-time, part-time and temporary employees and staff, officers,
directors or owners of Willis Towers Watson● personal information about individuals acting for or on behalf of another company, tothe extent the information relates to our transactions with such company, products orservices that we receive from or provide to such company, or associatedcommunications or transactions (except that such individuals have the right to opt-out
of any sale of their personal information and to not be subject to any discrimination forexercising such right)

Rights of California residents
California law grants California residents certain rights and imposes restrictions on particularbusiness practices as set forth below.
● Do-Not-Sell or Share: California residents have the right to opt-out of our sale or
sharing of their personal information. Such can be exercised by filling out the following
form at: https://exploreloop.com/dsar/
We do not sell personal information about residents who we know are younger than
16 years old without opt-in consent.
● Initial Notice: We are required to notify California residents, at or before the point ofcollection of their personal information, the categories of personal informationcollected and the purposes for which such information is used.

●

Request to Delete: California residents have the right to request deletion of theirpersonal information that we have collected about them and to have such personal
information deleted, except where an exemption applies. We will respond to verifiable
requests received from California residents as required by law.
● Request to Correct: California residents have the right to request that we rectify
inaccurate information about them. We will respond to verifiable requests received
from California residents as required by law.
● Request to Know: California residents have the right to request and, subject tocertain exemptions, receive a copy of the specific pieces of personal information that
we have collected, used, disclosed and sold about them in the prior 12 months and tohave this delivered, free of charge, either (a) by mail or (b) electronically in a portable
and, to the extent technically feasible, readily useable format that allows the individual
to transmit this information to another entity without hindrance. California residents
also have the right to request that we provide them certain information about how wehave handled their personal information in the prior 12 months, including the:○ categories of personal information collected;○ categories of sources of personal information;○ business and/or commercial purposes for collecting and selling their personal
information;○ categories of third parties with whom we have shared their personal
information;○ categories of personal information that we have sold in the preceding 12months, and for each category identified, the categories of third parties towhich we sold that particular category of information; and○ categories of personal information disclosed for a business purpose in thepreceding 12 months, and for each category identified, the categories of third
parties to which we disclosed that particular category of personal information.
California residents may make a request to know up to twice every 12 months. We will
respond to verifiable requests received from California residents as required by law.
● How to submit requests: Requests to know, and requests to delete may besubmitted by contacting us at support@loopmobileapp.com. An authorized agent canmake a request on a California residents’ behalf by providing a power of attorney valid
under California law, or providing:(1) proof that the consumer authorized the agent to do so;(2) verification of their own identity with respect to a right to know categories, right toknow specific pieces of personal information, or requests to delete which are outlined
above; and(3) direct confirmation that the consumer provided the authorized agent permission tosubmit the request.
We will respond to requests received from California residents as required by law.
● Right to non- discrimination: The CCPA and CPRA prohibits discrimination against
California residents for exercising their rights under the CCPA and CPRA.
Discrimination may exist where a business denies or provides a different level orquality of goods or services, or charges (or suggests that it will charge) different
prices, rates, or penalties on residents who exercise their CCPA and CPRA rights,

●unless doing so is reasonably related to the value provided to the business by theresidents’ data.
Financial incentives: A business may offer financial incentives for the collection, saleor deletion of California residents’ personal information, where the incentive is notunjust, unreasonable, coercive or usurious, and is made available in compliance withapplicable transparency, informed consent, and opt-out requirements. California
residents have the right to be notified of any financial incentives offered and theirmaterial terms, the right to opt-out of such incentives at any time, and may not be
included in such incentives without their prior informed opt-in consent. We do not offer
any such incentives at this time.

C. Brazil/LGPD
The following information applies to personal data which we process from any individuals thatis related to Brazil’s territory under the National Data Protection Law (LGPD):● Scope: In addition to the circumstances set forth above, the LGPD applies when we
process personal data subject to protect your fundamental rights of freedom, privacy
and the free development of your personality.
● Sensitive Personal Data under the LGPD: Sensitive personal data under the LGPD
includes Personal Information (as defined above) about racial or ethnic origin,religious belief, political opinion, union membership or organization of a religious,
philosophical or political nature, data relating to health or sexual life, genetic orbiometric data, when linked to a natural person. Please see the sections above formore information on how we treat sensitive personal data.
● Individual rights: Under the LGPD, you have certain rights related to your Personal
Information, subject to other limitations in this law, as follows:○ Confirmation of the existence of data processing;○ Access to your Personal Information;○ Correction of incomplete, inaccurate, or out-of-date Personal Information;○ Anonymization, blocking, or deletion of unnecessary or excessive Personal
Information, or data processed in non compliance with LGPD;○ Portability of Personal Information to another service or product provider,subject to the LGPD;○ Deletion of Personal Information, to the extent permitted by the LGPD;○ Information about the entities with whom we have shared Personal
Information;○ Information about the possibility of denying consent and consequences ofsuch denial;○ Revocation of consent.
● Contacting Us in Brazil: If you have any questions or comments about this Privacy
Policy as it relates to the LGPD or our processing activities in Brazil, please
support@loopmobileapp.com

13. Contact Us
If you have any questions or concerns at all about our Privacy Policy, please feel free tocontact us at support@loopmobileapp.com