Update Notice (November 15, 2023)
We will continue keeping the personal information of all our users safe and secure. If you have any questions or concerns regarding these revisions, you can contact us a firstname.lastname@example.org.
1. About This Policy
This policy also provides information based on laws related to the processing of your personal data. Further, this policy sets out the basis by which we will process any personal data that you provide to us or that we obtain from other sources.
2. Information About Us
For the purpose of data protection law, California Labs, Inc. ("we", "us", and "our") is the data controller with respect to your personal data. Our product name is the “Loop” digital picture frame and the “Loop” photo sharing App.
Our main office address:
1540 Market St. Suite 100, San Francisco, CA 94102
Our email address:
In this policy:
- Your “personal data” means any data which relates to you and from which you can be identified. It may include contact details, other personal information, photographs, and videos.
- “Processing” means any activity or operation that is carried out in respect of your personal data, including collecting, storing, using, transferring, and deleting.
- “App” refers to the family photograph/video-sharing mobile and web applications collectively named “Loop”.
- “Child” means any individual under the age of 13 registered as a “child” in the Loop app.
4. How We Collect Your Personal Data and What Personal Data We Collect
Information you provide while using the app. This may include your first and last name, email address, and payment information (including credit card details and shipping information). Other personal data may also be contained in photographs and video clips you upload to the app.
In order to use the app, you are required to provide your first name, last name, email and password. Other personal data is not required. Any additional personal data will only be obtained if and when you choose to provide it to us.
Information we collect. This may include your device information (such as operating system/version, hardware model, browser type/version), IP address, Loop login information, usage log for the app, device IDs (such as Apple IDFA or Google AAID), and cookies and similar technologies.
- Information we collect from other sources. This may include:
- Information about ad clicks and app installs from marketing platforms
- Purchase information/history from Apple, Google, and other payment platforms for products and services ordered through the app
- Loop usage activity from analytics platforms
- When uploading to Loop via Google Photos: Photos/videos selected for upload and profile information registered to Google Photos (If you choose to use this feature, your name, email address, and profile picture are accessed to display in the app while using the feature. This information is not saved to our servers.)
5. Purpose and Legal Basis of Processing Personal Data
We use your personal data for the following purposes based on our legitimate interests and/or with your consent:
- To provide you with our services. Our services include the app,, payment processing for products and services purchased within the app, and improvements to the app.
- To provide user support. This includes handling inquiries and complaints, troubleshooting and solving technical issues, and making necessary changes to our services.
- For marketing analytics. This includes collecting and analyzing data to research usage of the app.
- To protect against cyberattacks. This includes maintaining the privacy of our users and investigating and deterring unauthorized or illegal activity.
- For marketing. This includes operating promotional campaigns, measuring the performance of these campaigns, and sending information about our services, products, and features. We do not sell your data to any third parties. We also do not share your data to any third parties for advertising purposes.
6. Disclosure of Personal Data to Recipients
Your personal data may be shared with the following recipients in the situations described below:
- Authorized employees or affiliates. When necessary, these authorized individuals will access the minimum amount of data required to provide customer support, operate our system and services, or investigate fraud or security issues.
- Our own servers at https://api.joinloop.com
- Payment service providers. Payments for products/services ordered through the app are processed by secure and trusted payment processors, such as Apple, Google, Stripe, and GMO. We do not store payment information.
- Infrastructure vendors and other service providers. We store all data on servers provided by secure infrastructure services. We also provide data to service providers who support our business, such as by analyzing how our app is used, providing customer service, conducting surveys, measuring promotional campaigns, and/or sending emails and push notifications to users, for the purpose of processing the data described in the above.
- Law enforcement bodies. In response to legal requests, we will share the minimum amount of data necessary with law enforcement bodies.
- Other users who are invited to an album. The only information accessible by other album members is information that you have provided when using the app, the first name and last name and album name.
- In order to process personal data as described in “5. Purpose and Legal Basis of Processing Personal Data” above, we retain third-party service providers including the following:
- Amazon Web Services and Heroku (to store data, provide our service, etc.)
- Google Firebase (for analytics, to send push notifications, etc.)
- Twilio (for phone number validation for SMS/Text photo feature)
- Apple In-App Purchase, Google Play Billing, Stripe, GMO-PG (to process payments)
- Gorgias and Zendesk (to provide customer support)
- Facebook, Twitter (for advertising and analytics)
- Instabug (for crash reporting and app analytics)
In all cases, we apply strict measures to keep your data safe and your privacy protected. We share your personal data only for the purposes described in “5. Purpose and Legal Basis of Processing Personal Data” above. We do not sell your personal data to any third parties, even in the form of anonymized statistical data.
7. Cross-Border Transfer of Personal Data
Whenever we transfer, store, or process your personal data, we take reasonable steps to safeguard the privacy of your data. When using or disclosing personal data transferred from the European Economic Area, we adhere to the standard contractual clauses approved by the European Commission, adopt other means under European Union law to ensure adequate safeguards, or obtain your consent.
8. Storage Limit of Personal Data
We retain your personal data for the periods listed below, except when required by law to retain it for a longer period of time. In that case, we retain your data for the period required by law.
- We retain your personal data until we receive a request from you to delete your account.
- Photos and videos deleted from the app are removed from our servers automatically within 30 days.
- Your personal data will be deleted from our servers within 30 days of receiving a request to delete your account.
To delete your account and all data, email email@example.com with your request.
We utilize cookies and similar technologies within the app in order to collect certain information, including the following:
- Tracking IDs.Tracking IDs are used by various third-party service providers to associate multiple sessions (and any activity within those sessions) with a unique ID. Your device sends this unique ID with related engagement data, allowing third-party service providers to attribute all relevant activities to one user.
- IP addresses.Our third-party service providers collect IP addresses in services relating to the app.
We use the following first-party cookies based on your consent or without your consent only where permitted by applicable laws.
To keep you logged in while using the Loop Premium Computer Upload Site
10 minutes from last access
To connect you to the right album after clicking an invitation link
14 days from last access
To keep you logged in while using the browser version of the app
14 days from last access
We may change the expiration time frames listed above in order to optimize the app’s usability.
It is possible to disable cookies and other tracking IDs on your device. To learn more, visit the appropriate link below:
10. Your Rights
We acknowledge that you have the right to access and correct your personal data, discontinue our usage of your personal data, and other rights stipulated in each applicable jurisdictional law. You also have the right to lodge a complaint with a data protection authority in the jurisdiction where you reside, where you work, or where the alleged infringement of your rights took place. We will comply with any such request in full accordance with the applicable laws and regulations.
11. Required Personal Data
The following personal data is required to use the app:
- First Name and Last Name
- Email Address
Please note that you cannot use the app if we cannot obtain the personal data listed above.
12. Privacy of Children
We do not knowingly collect or solicit information from anyone under the age of 13 without parental consent. The app is not directed at children under the age of 13 who register themselves without parental consent, and we do not knowingly allow such persons to register. In the event that we learn that we have collected personal information from a child under age 13 without parental consent, we will delete that information as quickly as possible. If you believe that we might have obtained any information from a child under 13 without parental consent, please contact us.
- Secure data handling procedures for personal and sensitive user data
All information we send to our servers or our partners is encrypted before sending.
Should you have any questions or concerns regarding this Privacy Notice, please do not hesitate to contact us.
Loop at California Labs, Inc.
1540 Market St.
San Francisco, CA 94102