Privacy Policy

Introduction

Good-Loop Ltd ("Good-Loop", "we", "our", "us") is a private limited company registered in the UK under registration number SC548356.

Doing 'what is right' is at the heart of everything Good-Loop stands for, and how we treat individuals privacy is no exception. We are committed to respecting your privacy, and this privacy policy sets out the basis on which the personal data collected from you, or that you provide to us, will be processed by us. Please read the following carefully to understand how we will use your personal data.

The policy applies to visitors of the Good-Loop website and viewers (end users of our digital adverts), plus people who sign up to My.Good-Loop or other apps we provide.

1. Personal Information

  • When you interact with us, particularly when you use our website, or the My.Good-Loop App, or view our adverts, ("our services") you may provide us with personal information. Some of this personal information may be required so that we can provide our service to you, or respond to your queries. We may also ask you for additional personal information which is optional for you to provide, which will allow us to improve the service that we provide to you.

  • We will always aim to make it clear which personal information is necessary for you to provide and which personal information is optional. However, if you are unsure as to whether you are required to provide any particular piece of personal information please ask.

  • Typical personal information we may collect for interactions on our website or App is as follows:

    • your name;

    • your mobile number and email address;

    • your internet protocol (IP) address;

    • the content of any messages that you send via the App or website; and

    • your cv if applying for a position with us.

  • When viewing our adverts we may collect the following information:

    • the type of device you are using and the way in which it is configured;

    • your internet protocol (IP) address;

    • your approximate location (via IP address, which usually gives information on which country and city you are in);

    • your activity when viewing our adverts or using our website, including events you sign up for, purchases you make and promotions you are interested in; and

    • statistical data to identify trends.

2. Uses Made Of The Information

  • We are committed to protecting your privacy, and will only use your personal information in accordance with applicable data protection legislation, including the General Data Protection Regulation (GDPR) and the Data Protection Act 2018.

  • In accordance with our ethical criteria, we will:

    1. Never support manipulation, e.g. through political dark-ads.

    2. Never support exploiting vulnerable groups.

    3. Never use dark patterns to trick users into giving more consent than they wish.

When you use our website or App, or view our adverts, you may provide us with the following personal data, which we process accordance with this Privacy Policy and for the following purposes:

2.a. Legitimate Interests

We collect and process some data on the legal basis of legitimate interests.

We have designed our data collection and handling to minimise the use of individual data.

We have assessed the potential impact on a data subjects' interests and fundamental rights, and concluded that it is very low, and does not override the legitimate interests.

The details are described below.

2.b. Adverts

What personal data do we process?

Why do we process this personal data?

What is our lawful basis for processing?

Approximate Location Data: this is collected via the web connection you use (IP address). This is only accurate to the level of country and city/region.

We may temporarily store your IP address during this processing. This is never shared even in aggregate and is not retained beyond a maximum of one month.

To comply with country specific laws and to select adverts by country.

To identify trends in service usage and address any location-specific issues.

To calculate the carbon footprint of an advertiser.

To comply with a legal obligation or our legitimate interest to analyse user data.

Usage Data: We may process data regarding viewing adverts, including average time spent in the advert, any problems reported, clicks, device type, and number and frequency of views.

We may temporarily store the browser user-agent string during processing for device type. This is never shared even in aggregate and is not retained beyond a maximum of one month.

To identify any fraudulent use of the adverts.

To measure advert views and interactions in order to correctly bill advertisers and credit publishers and charities.

To identify any problems, defects or issues with the adverts.

To optimise the performance of the adverts and improve future versions.

To satisfy our legitimate interest

 

(to enable use of the services, prevent fraud, improve the usability of the services, and make modifications and updates).

Segment Markers: Cookies which mark segments for targeted advertising.

To find viewers that match an advert, or select adverts that better match the viewer.

To monitor trends.

With your consent to the use of Cookies.

Advertising Data: we may receive aggregated personal data from third parties with whom we place adverts. This data will include statistics about who has interacted with our services, but we will not be able to personally identify you.

We may also track your interaction with our services through the use of cookies and log files.

To allow us to track views, clicks, downloads and user behaviour trends.

To satisfy our legitimate interests

 

(identify trends in user behaviour to improve and develop our services).

2.c. Website and App

The following data uses do not apply to adverts, but may apply when you use our website or App.

What personal data do we process?

Why do we process this personal data?

What is our lawful basis for processing?

Data as described in 2.a. above.

As described in 2.a. above.

As described in 2.a. above.

Identity Data: this includes your title, first name and surname.

To set up your account and enable you to use the Website and App.

To fulfil our contract with you.

To satisfy our legitimate interests (to run and operate Good-Loop and our business, to maintain our records, to prevent fraud, to keep you safe, to answer any queries or propose solutions to any problems you are having with the Website or App).

Contact Data: this includes your email address and any other contact details you may choose to provide to us.

To set up an App account and enable you to use the Website/App.

To contact you if there are any problems with the Website/App.

To inform you of any changes we make to the Website/App, its terms, or this Privacy Policy.

To let you know of any new sessions or general updates about Good-Loop.

If relevant, to contact you about and allow your participation in beta testing of any new versions of the Website, App or new functionality.

Providing you with the types of news and updates that you have asked to receive by the types of communication that you have asked us to use.

Where you have chosen to receive marketing communications from our partners through electronic communications such as push notifications or emails, sending you those marketing communications.

To fulfil our contract with you.

To satisfy our legitimate interests (to keep our records up to date).

Your consent (if we use your contact details for marketing purposes we will only do so with your express consent. You can withdraw your consent at any time by emailing support@good-loop.com or clicking on the "unsubscribe" link in the email).

Where it is necessary for compliance with legal obligations, including for record keeping and regulatory compliance purposes.

Survey Data: this includes any additional information you may choose to give us as part of a survey we conduct.

To analyse user data and identify user trends.

To identify new user needs and develop appropriate new content.

Your consent - it is completely up to you whether you share this data with us, and you can choose to remove it at any time and we will stop processing it. You can withdraw your consent by emailing us (see Our Details below).

Marketing Data: We may send you adverts that we feel are of interest to you.

To ensure that you receive marketing which is most relevant to you and to enable us to best promote our partner's products.

With your consent to the use of your personal details, and your consent to Cookies.

Where you have given us your consent to use your personal information in a particular manner, you have the right to withdraw this consent at any time, which you may do by contacting us as described in paragraph 10. Please note however that the withdrawal of your consent will not affect any use of your personal information made before you withdrew your consent.

3. Circumstances In Which We May Share Your Personal Information

  • First and foremost, we will never sell your personal data unless you explicitly authorise that.

  • Your personal information may however be made available to our partners, with your consent, when:

    • you sign up for our newsletter;

    • you otherwise connect with a partner, including sending messages through Good-Loop; or

    • We may also share your personal information with third parties if we are under a duty to share your personal information in order to comply with any legal obligation, or in order to enforce or apply such other terms as apply to our relationship, or to protect the rights, property, for the purposes of any legal dispute, or safety of our customers, ourselves or others (including exchanging information with other companies and organisations for the purposes of fraud protection).

  • We may share anonymised and aggregated information about our customers/users to third parties, such as our clients, to allow them to reach the kind of audience they want to target. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users viewing a specific advertising campaign.

  • We may publish this anonymised or aggregate data in statistical form for Good-Loop promotional purposes, or to assist charities in understanding the pattern of donations.

4. Transferring Your Personal Information Internationally

  • In certain cases the sharing of your personal information to a third party as described above may involve your personal information being transferred outside of the United Kingdom. For example, our servers are located in Germany, a country in the EEA and therefore subject to the GDPR, therefore offering the same safeguards in respect of your personal data.

  • Where personal data is transferred to a country which is not considered to have the same standards of protection for personal data as those in the United Kingdom, we will take all steps required by law to ensure sufficient protections are in place to safeguard your personal information, including where appropriate putting in place contractual terms approved by the relevant regulatory authorities.

5. Retention, Updating And Removal Of Your Personal Information

  • Data Retention

The duration for which we retain your personal information will differ depending on the type of information and the reason why we collected it from you. For example, when we monitor our advertising activity via your IP address, your IP address will automatically be deleted after one month. However, if you register for an account with us we will need to retain your personal information for longer, for example until you close the account, or for example for at least six years in accordance with usual commercial practice, potential legal disputes and regulatory requirements.

  • Accuracy

When you register for an account it is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, including if you change your contact details. You can update some of the personal information we hold about you on our website. Alternatively, you can contact us using the details in paragraph 10.

  • Removal

If you want to stop receiving any information from us, such as news and updates, please let us know by updating your preferences through our website or contacting us using the details in paragraph 10. It may take up to one month to unsubscribe you from marketing.

Your decision to stop receiving information from us or to delete your account may result in the deletion of some of the personal information that we hold about you, but we may still retain personal information required for other purposes, including where we are legally required to do so.

  • Erasure

You may request the erasure of personal information that we hold about you. To make a deletion request, please contact us, providing full details of the personal information you want to be erased. We will consider all requests upon receipt. We may ask for additional information, for example to verify your identity. You have the right to delete most data, though some data has to be kept for legal reasons.

6. Cookies And Log Files

  • When you browse our website, use our App, or view our adverts, we may use "cookies" to keep track of your visit and give you a better browsing experience.

  • IAs with most websites, these cookies allow us to log various information about visitors, including IP addresses, browser type, internet service provider (ISP) information, referring / exit pages and date / time stamp. We may use this information to analyse advertising trends, administer our website, track your movement around the website, App and adverts, and gather broad demographic information.

  • Please see our Cookie Policy for more information on the cookies we use.

7. Security

  • The protection of your personal information is very important to us and we have in place various security measures to ensure that your personal information is kept secure.

  • However, you should be aware that the method you use to get in contact with us, such as email or blog, may not be entirely secure and your personal information may be susceptible to being intercepted in transit. Equally, your personal information is at risk if a malicious third party gains access to your Good-Loop account or to any other place where your personal information is stored, such as your email account.

  • You should therefore take all reasonable steps to keep your personal information secure, including choosing a secure password for Good-Loop account and your email account and not disclosing your passwords to anybody else. You should use a unique password for every account.

8. Enquiries, Issues And Complaints

  • You are entitled by law to ask for a copy of your personal information at any time. Please contact us using the details in paragraph 10.

  • In the unlikely event that you have any concerns about how we use your personal information, please contact us as described in paragraph 10. This includes situations where you want to request the rectification or erasure of your personal information, restrictions to be placed around how we use your personal information, or to object to a particular use.

  • We will respond to any enquiries or complaints within one month of receipt, and usually a lot sooner.

  • If we are unable to resolve your complaint, you may make a complaint to the Information Commissioner's Office. Please see https://ico.org.uk/make-a-complaint/ for more information.

9. Changes To This Privacy Policy

  • We reserve the right to alter this privacy policy at any time. Such alterations will be posted on our website. You can also obtain an up-to-date copy of our privacy policy by contacting us as described in paragraph 10. Should you object to any alteration, please contact us.

10. Our Details

  • If you need to contact us about this notice or any matters relating to the personal information we hold on you, you can email our Data Protection Officer (DPO) via dpo@good-loop.com.

  • Good-Loop Ltd is company SC548356, registered in the UK. Our registered address is 27 McDonald Road, Edinburgh, EH7 4LX.

  • We are registered with the UK Information Commissioner's Office (ICO). Our registration number is: ZA275147

  • The International Advertising Bureau (IAB) operates a framework for managing consent, called the Transparency Consent Framework (TCF). Good-Loop complies with the policies of the TCF, and is on the Global Vendor List (GVL) as vendor #749.

  • We are applying to join the Trustworthy Accountability Group (TAG). Our TAG ID is aa835747e2deb43f

11. Links To Other Websites

  • Our website or App may contain links to external third party websites and apps. If you follow a link to a third party website or app, please note that this privacy policy does not apply to that website or app. We are not responsible or liable for the privacy policies or practices of any third party websites or apps, so check their policies before you submit any personal data to those websites.

12. GDPR Notes

  • The Company is both a Controller and a Processor of data.

  • The Company does not handle special category data.

  • The Company is not required to keep records of Processing Activities (see GDPR Article 30, clause 5).

13. CCPA Notes

  • CCPA Not Applicable: The Company does not match any of the three thresholds for the CCPA, which are: (a) annual gross revenues below the $25 million threshold, (b) receive or disclose the personal information of 50,000 or more California residents, households, or devices each year, and (c) make 50 percent or greater annual revenue from selling California residents' personal information.

  • The Company voluntarily follows CCPA rules as if it were a Service Provider as a matter of good practice.

14. Further Information

  • We hope that the contents of this privacy policy address any queries that you may have about the personal information we may hold about you and what we may do with it. However, if you do have any further queries, comments or requests, please contact us as described in paragraph 10 above.

  • Whilst this privacy policy sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner's Website at https://ico.org.uk/your-data-matters/.

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