These definitions should help you understand this policy. When we say “we,” “us,” “our,” and “VIRAL LOOPS,” we are referring to Viral Loops Limited. We provide online platforms that you may use to market to or stay in contact with others, including creating, and managing viral and referral campaigns and other information related to your Participants (the “Services”). When we say “User,” we are referring to the person or entity that is registered with us to use the Services. When we say “you,” we are referring either to a User or to some other person who visits any of our Websites. A “Participant” is a person you contact through our Services, or a person who you might choose to contact at some point in the future through the use of our Services. In other words, a Participant is anyone on your Participant List or about whom you have given us information. “Personal Information” means any information that identifies or can be used to identify you or a Participant, directly or indirectly, including, but not limited to, first and last name, date of birth, email address, gender, occupation or other demographic information. A “Participant List” is a list of Participants and all associated information related to those Participants (for example, email addresses).
We collect the following information:
2. The information we collect may be "personally identifiable" (meaning it can be used to specifically identify you as a unique person) or "non‐personally identifiable" (meaning it can't be used to specifically identify you). We use both types of information, and combinations of both types, as described below. We may use or store information wherever VIRAL LOOPS does business, including countries outside your own.
3. Whenever you use our web application there's certain information that gets created and recorded in an automated way. This information we collect includes:
b. Information on the leads participating in your campaigns including information such as: a) name, b) email, c) social profile.
c. Device Information. In addition to log data, we may also collect information about the device you're using VIRAL LOOPS app on, including what type of device it is, what operating system you're using, device settings, unique device identifiers, and crash data. Whether we collect some or all of this information often depends on what type of device you're using and its settings.
d. Social Profile. In addition to the core data, we also collect information about the social profile of the user, such as FacebookID or TwitterID. We utilize that data to uniquely identify leads and avoid duplications in our Database. Users have the absolute right to delete all their leads throughout our Web App.
4. List and email information: When you add a participant list or create an email with VIRAL LOOPS, we have and may access the data on your list and the information in your email. If a Participant chooses to use the ‘invite a friend through email’, it will allow the participant to share your email content with individuals not on your participant list. When a participant invites a friend through email, we do not store their friend’s email address, and they are not added to any participant list as a result of the ‘invite a friend through email’. The user who created the email campaign only sees an aggregate number of times their campaign was forwarded by a participant and does not have access to the email addresses used to share or receive that content.
6. Web beacons: We use web beacons on our Websites, emails and widgets. When we send emails to our users, we may track behavior such as who opened the emails and who clicked the links. This allows us to measure the performance of our email campaigns and to improve our features for specific segments of Users. To do this, we include single pixel gifs, also called web beacons, in emails we send. Web beacons allow us to collect information about when you open the email, your IP address, your browser or email client type, and other similar details. We also include Web Beacons in the emails we deliver for you. We use the data from those Web Beacons to create reports about how your email campaign performed and what actions your Participants took. Reports are also available to us when we send email to you, so we may collect and review that information.
7. Information from other sources: From time to time we may obtain information about you or your Participants from third party sources, such as public databases, social media platforms, third party data providers and our joint marketing partners. We take steps to ensure that such third parties are legally permitted or required to disclose such information to us. Examples of the information we may receive from other sources include: demographic information, device information (such as IP addresses), location, and online behavioral data (such as information about your use of social media websites, page view information and search results and links). We use this information, alone or in combination with other information (including Personal Information) we collect, to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant products features, and services.
8. Third-party websites with Viral Loops widgets and snippets: When our widgets and snippets are installed on third party websites, we apply rate-limit tactics based only on the IP address of the visitor, in order to prevent our public API from being abused. These IP addresses are saved in temporary storage that expires after 1 minute. In case our public API is being abused, we reserve the right to collect and process the offending IP address(es) to protect our customers and systems. Otherwise, Viral Loops does not collect, retain or share any personally identifiable information gathered on sites or apps not owned by Viral Loops. This includes both unique user identifiers and IP addresses. Viral Loops does not use the domain viral-loops.com for fingerprinting.
We may use Personal Information for a range of reasons, including:
1. To promote use of our services to you and others. If you use any of our services and we think you might benefit from using another service we offer, we may send you an email about that. You can stop receiving our promotional emails by following the unsubscribe instructions included in every email we send. In addition, we may use information we collect in order to advertise our services to you or suggest additional features of our services that you might consider using. In addition, we may use your personal information to advertise our services to potential or other users like you.
2. To send you informational and promotional content in accordance with your marketing preferences. You can stop receiving our promotional emails or Messenger notifications by following the unsubscribe instructions.
3. To bill and collect money owed to us by our users. This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different credit card number. We use third parties for secure credit card transaction processing, and we send billing information to those third parties to process your orders and credit card payments.
4. To send you system alert messages. For example, we may inform you of temporary or permanent changes to our services, such as planned outages, new features, version updates, releases, abuse warnings, and changes to our terms and policies.
5. To communicate with our users about their account and provide customer support.
6. To enforce compliance with our Terms and applicable law. This may include developing tools and algorithms that help us prevent violations.
7. To protect the rights and safety of our users and third parties, as well as our own.
8. To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.
9. To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.
10. To prosecute and defend a court, arbitration, or similar legal proceeding.
11. To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
12. To provide, support, and improve the services we offer. This includes our use of the data that our users provide us in order to enable our users to use the services to communicate with their participants. This also includes, for example, aggregating information from your use of the services or visit to our websites and sharing this information with third parties to improve our services. This might also include sharing your information or the information you provide us about your campaign participants with third parties in order to provide and support our services or to make certain features of the services available to you, always in accordance with your marketing preferences.
13. To provide suggestions to you. This may include adding features that compare users’ viral and referral campaigns, or using data to suggest products or services that you may be interested in or that may be relevant to you or your campaign participants.
14. To transfer your information in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition. In that event, any acquirer will be subject to our obligations under these Terms, including your rights to access and choice. We will notify you of the change either by sending you an email or posting a notice on our website.
15. For recruitment purposes if you have applied for a role with Viral Loops.
16. To compile aggregated statistics about site usage and to better understand the preferences of our Visitors.
17. To customize content and layout of the Websites.
Combined Information: We may combine personal information with other information we collect or obtain about you (such as information we source from our third party partners), to serve you specifically, such as to deliver a product or service according to your preferences or restrictions, or for advertising or targeting purposes. When we combine personal information with other information in this way, we treat it as, and apply all of the safeguards in these Terms applicable to, personal information.
Data Collected for and by our Users
If you are a Participant and no longer want to be contacted by one of our Users, please unsubscribe directly from that User’s campaign or contact the User directly to update or delete your data. If you contact us, we may remove or update your information within a reasonable time and after providing notice to the User of your request.
We will retain Personal Information we process on behalf of our Users for as long as needed to provide our Services or to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our agreements.
Public Information and Third Party Websites
a. Blog. We have public blogs on our Websites. Any information you include in a comment on our blog may be read, collected, and used by anyone. If your Personal Information appears on our blogs and you want it removed, contact us here. If we are unable to remove your information, we will tell you why.
b. Social media platforms and widgets. Our Websites include social media features, such as the Facebook Like button. These features may collect information about your IP address and which page you are visiting on our Website, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. We also maintain presences on social media platforms including Facebook, Twitter, and Instagram. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
We may disclose Personal Information to the following types of third parties for the purposes described in this policy:
a. Service Providers. Sometimes, we share your information with our third party Service Providers, who help us provide and support our Services. Examples of Service Providers include payment processors, hosting services and content delivery services.
Contests and Sweepstakes
We may, from time to time, offer surveys, contests, sweepstakes, or other promotions on our Websites or through social media (collectively “Our Promotions”). Participation in our Promotions is completely voluntary. Information requested for entry may include personal contact information such as your name, address, date of birth, phone number, email address, username, and similar details. We use the information you provide to administer Our Promotions. We may also, unless prohibited by the Promotion’s rules or law, use the information provided to communicate with you, or other people you select, about our Services. We may share this information with our affiliates and other organizations or Service Providers in line with this policy and the rules posted for the Promotion.
How do we protect your information?
We are committed to protecting your personal information against unauthorized use or disclosure. We implement a variety of security measures to maintain the safety of your personal information when you access your personal information. We do not sell, trade or otherwise transfer to outside parties your personally identifiable information. This does not include trusted third parties who assist us in operating our Website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, regulation or legal request; enforce our site policies or protect ours or others rights, property or safety or to detect, prevent, or otherwise address fraud, security or technical issues. However non‐personally identifiable visitor information may be provided to other parties for marketing or other uses. We may engage in a merger, acquisition, bankruptcy, dissolution, reorganization, or similar transaction or proceeding that involves the transfer of the information described in this Policy.
Other Data Protection Rights
You have the following data protection rights:
1. To access, correct, update, or request deletion of your Personal Information. Viral Loops takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete, and up to date. You may contact us directly at any time about accessing, correcting, updating, or deleting your Personal Information, or altering your data or marketing preferences by emailing us at email@example.com. We will consider your request in accordance with applicable laws.
In addition, if you are a resident of the EEA, you can object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information. Again, you can exercise these rights by emailing us at firstname.lastname@example.org
2. Similarly, if we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
3. You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA are available here.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.
How We Share Information
1. Our service providers: Sometimes, we share your information with our third-party service providers, who help us provide and support our Services and other business-related functions. Examples include analyzing data, hosting data, engaging technical support for our Services, processing payments, and delivering content.
3. Any competent law enforcement body, regulatory body, government agency, court or other third party where we believe disclosure is necessary (a) as a matter of applicable law or regulation, (b) to exercise, establish, or defend our legal rights, or (c) to protect your vital interests or those of any other person.
5. Any other person with your consent.
Legal Basis for Processing Personal Information (EEA Persons Only)
If you are from the European Economic Area, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.
However, we will normally collect and use Personal Information from you where the processing is in our legitimate interests and not overridden by your data-protection interests or fundamental rights and freedoms. Typically, our legitimate interests include improving, maintaining, providing, and enhancing our technology, products, and services; ensuring the security of the Services and our Websites; and for our marketing activities.
If you are a User, we may need the Personal Information to perform a contract with you. In some limited cases, we may also have a legal obligation to collect Personal Information from you. If we ask you to provide Personal Information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not, as well as of the possible consequences if you do not provide your Personal Information.
Where required by law, we will collect Personal Information only where we have your consent to do so.
Your Choices and Opt-Outs
Users and Website visitors who have opted in to our marketing emails or Facebook Messenger notifications can opt out of receiving marketing emails or Messenger notifications from us at any time by clicking the "unsubscribe" link at the bottom of our marketing messages or writing “Unsubscribe” or “Stop” on Messenger.
Also, all opt-out requests can be made by emailing us at email@example.com. Please note that some communications (such as service messages, account notifications, billing information) are considered transactional and necessary for account management, and Users cannot opt out of these messages unless you cancel your Viral Loops account.
We take appropriate and reasonable technical and organizational measures to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. If you have any questions about the security of your Personal Information, you may contact us at firstname.lastname@example.org.
Viral Loops accounts require a username and password to log in. Users must keep their username and password secure, and never disclose it to a third party. Because the information in a User’s Viral Loops account is so sensitive, account passwords are hashed, which means we cannot see a Viral Loops’ password. We cannot resend forgotten passwords either. We will only provide Users with instructions on how to reset them.
What choices do you have about your information?
If you have a VIRAL LOOPS account, many of the choices you have about your information are built directly into the product or your account settings. For example, you can:
1. Access and change information in your profile page at any time, and choose whether your profile page is available to search engines;
2. Link or unlink your VIRAL LOOPS account from an account on another service (e.g., Facebook or Twitter). For some services (like Facebook), you can also choose whether or not to publish your activity on VIRAL LOOPS to that service.
3. Close your account at any time. When you close your account, we'll deactivate it and remove your content from our Web Application. We may retain archived copies of your information as required by law or for legitimate business purposes (including to help address fraud and spam).
4. You may have choices available to you through the device or software you use to access our Web application. For example: The browser you use may provide you with the ability to control cookies or other types of local data storage; To learn more about these choices, please see the information provided by the device or software provider.
Retention of Data
We retain Personal Information where we have an ongoing legitimate business or legal need to do so. Our retention periods will vary depending on the type of data involved, but, generally, we'll refer to these criteria in order to determine retention period:
1. Whether we have a legal or contractual need to retain the data.
2. Whether the data is necessary to provide our Services.
3. Whether our Users have the ability to access and delete the data within their Viral Loops accounts.
4. Whether our Users would reasonably expect that we would retain the data until they remove it or until their Viral Loops accounts are closed or terminated.
When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.
Questions & Concerns
If you have any questions or comments, or if you have a concern about the way in which we have handled any privacy matter, please email us at email@example.com. You may also contact us by postal mail or email at:
Viral Loops Limited
21 Aylmer Parade Aylmer Road, N2 0AT
Updated September 17, 2020