3. Collection, Retention and Use of Information
3.1 Information Collected from You
Our primary goals in collecting information are to provide and improve our Services, to administer your use of the Services (including your Account, if you are an Account holder), to enable you to enjoy and easily navigate our Services, to monitor and secure the Service, to prevent unauthorized use of the Service and depending on your preference to deliver you advertising. The information that Lookback collects from you varies depending on your use of the Services as a Participant or as a Customer. We will process your information where there is a legitimate interest to do so. Those interests are described in this policy.
3.1.1 Information Obtained from Participants
If you are a Participant, you may access the Services to create Recordings by (i) receiving an invitation from a Customer or an authorized user of a Customer to test Customer’s application(s) by using the Services, or (ii) interacting directly with Customer’s application(s) that incorporate the Services. When you access the Services as a Participant, Lookback will collect the following information from you:
18.104.22.168 Information in Recordings. Depending on the settings on your device or on the application you are testing, when you create a Recording using the Services, Lookback will collect information regarding your device (such as device name, operating system and model), video content you create as a Participant (captured by the camera and the screen on your device), which may include your image or appearance, any audio captured by the microphone on your device, banners, and any other information that is displayed on your device screen as you create a Recording by interacting with a Customer application (collectively, the “Recording Information”).
22.214.171.124 Onboarding Information. After being invited to participate in a research session, we will collect certain information that can be used to identify you, such as your name and email address.
3.1.2 Information Obtained from Customers
If you are a Customer, you may use the Services to test your application(s) by (i) inviting Participants to use the Services with your application(s) to create Recordings, (ii) incorporating the Services into your application(s), or (iii) allowing your authorized users to act as Participants and create Recordings. As a Customer, Lookback will collect the following information from you and/or your authorized users:
126.96.36.199 Account Information. If you create an account to use the Services (the “Account”) and/or sign up for a paid subscription to the Services, we will collect certain information that can be used to identify you, such as your name and email address.
3.1.3 Information Obtained from All Lookback Users
Lookback will collect the following information from Customers, Participants or any other users of the Site or the Services:
188.8.131.52 Information Collected Using Cookies and other Web Technologies. Like many website owners and operators, we use automated data collection tools such as Cookies and Web Beacons to collect certain information.
“Web Beacons” (also known as Web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike Cookies, which are stored on the user’s device, Web Beacons are typically embedded invisibly on web pages (or in an e-mail).
184.108.40.206 Information Related to Use of the Services. Our servers automatically record certain information about how a person uses our Services (we refer to this information as “Log Data”), including both Account holders and non-Account holders (either, a “User”). Log Data may include information such as a User’s Internet Protocol (IP) address, browser type, operating system, the web page that a User was visiting before accessing our Services, the pages or features of our Services to which a User browsed and the time spent on those pages or features, search terms, the links on our Services that a User clicked on and other statistics. We use Log Data to administer the Services and we analyze (and may engage third parties to analyze) Log Data to improve, customize and enhance our Services by expanding their features and functionality and tailoring them to our Users’ needs and preferences. We may use a person’s IP address to generate aggregate, non-identifying information about how our Services are used.
220.127.116.11 Information Sent by Your Device. We collect certain information that your device sends when you use our Services, like a device identifier, user settings and the operating system of your device, as well as information about your use of our Services ("Device Information").
18.104.22.168 Location Information. When you use a Lookback Application on your mobile device, we may collect and store information about your location by converting your IP address into a rough geo-location or by accessing your mobile device’s GPS coordinates or coarse location if you enable location services on your device. We may use location information to improve and personalize our Services for you. If you do not want us to collect location information, you may disable that feature on your mobile device.
5. Information that We Share with Third Parties
We will not share any Personal Data that we have collected from or regarding you except as described below:
Information Shared with Parent Companies, Subsidiaries, or Affiliates. We may share your Personal Data and Recording Information with our parent companies, subsidiaries and affiliates.
Information Shared with Our Service Providers. We may engage third-party service providers to work with us to administer and provide the Services. These third-party service providers have access to your Personal Data only for the purpose of performing services on our behalf. We maintain a list of third-parties we engage and we will notify Customers in advance if we engage any additional third-parties.
Information Shared with Customers. If you, as a Participant, or an authorized user of a Customer, use or access the Services to create a Recording, you agree that we may share your Recording Information and Personal Data with the Customer(s) for whom you are providing testing services.
Information Shared with Third Parties. We may share aggregated information and non-identifying information with third parties for industry research and analysis, demographic profiling and other similar purposes.
Information Disclosed in Connection with Business Transactions. Information that we collect from our users, including Personal Data, is considered to be a business asset. Thus, if we are acquired by a third party as a result of a transaction such as a merger, acquisition or asset sale, or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your Personal Data, may be disclosed or transferred to a third party acquirer in connection with the transaction.
Information Disclosed for Our Protection and the Protection of Others. We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you 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 process (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 activity.
6. Your Choices
We offer you choices regarding the collection, use and sharing of your Personal Data and we will respect the choices you make. Please note that if you decide not to provide us with the Personal Data that we request, you may not be able to access all of the features of the Services.
Modifying Your Information. If you are a Customer or an authorized user of a Customer, you can access and modify the Personal Data associated with your Account by changing the settings in your Account. In addition, if you are an authorized user of a Customer, upon termination of Customer’s agreement with Lookback, the Personal Data associated with your Account will not be deleted and your Account will remain in existence, although you will no longer be able to access any content or Recordings associated with Customer. If you are a Participant you should contact the Customer to access, modify or delete your Personal Data or Recording Information, since the Customer is the controller of that data.
7. Responding to Do Not Track Signals
Our Site does not have the capability to respond to “Do Not Track” signals received from various web browsers.
8. The Security of Your Information
We take reasonable administrative, physical and electronic measures designed to protect the information that we collect from or about you (including your Personal Data) from unauthorized access, use or disclosure. When you enter sensitive information on our forms, we encrypt this data using TLS or other technologies. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.
9. Your Rights
Individuals located in certain countries, including the European Economic Area, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. You can usually do this using the settings and tools provided in your Services account. If you cannot use the settings and tools, contact Support at email@example.com for additional access and assistance.
10. Links to Other Sites
11. International Transfer and Privacy Shield
Whether you are a Customer, an authorized user of a Customer, or a Participant, your Personal Data may be transferred to, and maintained on, computers or servers, that are located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide your Personal Data to us, we may transfer your Personal Data to the United States and process it there. We work with our Customers, users and vendors with regard to legal compliance pertaining to data transfer.
For the avoidance of doubt, for information we collect from Participants or Customers’ authorized users, the Customer is responsible for obtaining any necessary consent from the Participants or such authorized users regarding the international transfer of any Personal Data included in their Recordings.
11.2 Privacy Shield
11.2.2 Questions or Complaints
In compliance with the Privacy Shield Principles, Lookback commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Lookback at:
11.2.3 U.S. Federal Trade Commission Enforcement
Our Privacy Shield compliance is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).
11.2.4 Third parties and data processed
If we receive personal data subject to our certification under the Privacy Shield and then transfer it to a third-party service provider acting as an agent on our behalf, we have certain liability under the Privacy Shield if both (i) the agent processes the personal data in a manner inconsistent with the Privacy Shield and (ii) we are responsible for the event giving rise to the damage.
11.2.5 Choices Regarding Your Data
11.2.6 Requirement to Disclose
We may disclose personal data when we have a good faith belief that such action is necessary to: conform to legal requirements or to respond to lawful requests by public authorities, including to meet national security or law enforcement requirements; or to enforce our contractual obligations.
11.2.7 Dispute Resolution
If you are a resident of a European country participating in the Privacy Shield and you have not received timely response to your concern, or we have not addressed your concern to your satisfaction, you may seek further assistance, at no cost to you, from the EU Data Protection Authorities, or the Swiss Federal Data Protection and Information Commissioner (FDPIC), depending on your location. European and Swiss users may, under specific conditions set forth in Annex I to the Principles, invoke binding arbitration through the Privacy Shield panel to resolve any complaints.
11.2.8 Right of Access
12. Processing of Personal Data
13. Our Policy Toward Children
Our Services are not directed to children under 16 and we do not knowingly collect Personal Data from children under 16. If we learn that we have collected Personal Data of a child under 16 we will take steps to delete such information from our files as soon as possible.
You can always reach out to us at firstname.lastname@example.org with questions or concerns.
To communicate with our Data Protection Officer, please email email@example.com.