1. Introduction

This Privacy Policy (“Privacy Policy”) describes how Gigloop, LLC and its affiliates (“Gigloop”) will collect, use, retain, disclose, and delete your Personal Information on the Gigloop Platform (“Platform”). It will also explain your legal rights with respect to that information. By using the Platform, you confirm that you have read and understood this Privacy Policy, and the applicable Terms of Service (together referred to herein as the “Agreement”). The Agreement governs the use of the Platform. Gigloop will collect, use, retain, disclose, and delete the Personal Information consistent with the Agreement.

If you are a California resident or data subject in Europe, please see the “Additional Disclosure for California Residents” and “Additional Disclosures for Data Subjects in the European Economic Area (EEA), Switzerland, and the UK” sections below. If you have any questions or wish to exercise your rights and choices, please contact us at support@gigloop.co.

2. General Terms

In this Privacy Policy:

• Gigloop, LLC may be referred to “Gigloop”, “we”, “our”, “us”.
• We call a user of the Platform “User”, “Users”, “you”, “your,” or “Client” and “Looper,” as appropriate.
• The community platform that we offer at our website (including at least www.gigloop.co) is referred to as the “Site(s)”.
• The mobile applications (whether on iOS or Android) are referred to as the “Apps”.
• Gigloop’s Sites, Apps and related services, information and communications are collectively referred to as the “Gigloop Platform.”
• “Terms of Service” refers to the Platform’s Terms of Service, which is located at  www.gigloop.co/terms . This Privacy Policy is incorporated into, and considered a part of, the Terms of Service.
• “Personal Information” is information that can directly or indirectly identify, or can reasonably identify, an individual, to the extent regulated under applicable privacy laws.

3. Collection of Personal Information

We collect personal information directly from you when you provide it to us or from your use of the Platform. Some examples of Personal Information we collect includes the following:

• Contact Information, such as your first and last name, email address, physical address, and phone number which is needed to set up an account.
• Billing Information, such as your credit or debit card number, expiration date, security code, and zip code.
• Identity Information, such as your date of birth, and depending on where you reside, your social security, tax ID number, VAT ID number, or social insurance number, and photo of your ID document such as your passport, local ID, or driver’s license.
• Promotional Information, such as the information you provide when you participate in surveys, contests, or similar offerings.
• User Generated Content Information, such as information submitted via email or chat messages between you and us or between you and other users. This can include photos shared between users or by a Looper via chat related to the performance of a Gig.
• Booking Information, such as information about the gig or job you are seeking e.g., the time, date, and location. If you are a Looper, we also collect information about your gigs, rates, and skills.
• Data from Cookies and Similar Technologies as described in our Cookie Policy in Section 10, which sets out the different categories of cookies and similar technologies that the Platform uses and why we use them.
• Device Data, including data about the type of device or browser you use, your device’s operating system, internet service provider, device’s regional and language settings, and device identifiers such as IP address and AD ID.
• Location Data, including location data such as those derived from an IP address or data that indicates a city or postal code level or latitude/longitude data.
• Service Use Data, including your activities on the Platform’s features and webpages, the time of day you browse, and emails and advertisements that you view and may interact with.

4. Use of Personal Information

We use your Personal Information for business and commercial purposes, which includes the following purposes:

• To operate and make available the Platform.
• To connect you with other users to fulfill a Gig;
• To personalize your experience on the Platform;
• For billing and fraud prevention to ensure a safe and secure environment to facilitate financial transactions;
• To conduct identification and criminal background checks, as permitted by applicable laws;
• To ensure the safety of our users both online and offline;
• To maintain the integrity of the Platform;
• For analysis to improve the Platform;
• To contact you with transactional and promotional communications;
• To provide you with customer support, and to assist in the resolution of your, or a third party’s, complaints;
• To advertise our Platform’s or a partner’s products or services that we think might interest you. For more information and to understand your choices regarding third-party ads, please see our Cookie Policy in Section 10;
• To enforce the relevant Terms of Service; and
• As otherwise set forth in other terms of the Agreement or as otherwise permitted under applicable laws.

5. Disclosure of Personal Information

We share your Personal Information with third parties for the following purposes:

• Subsidiaries. To promote and improve each other’s products and services.
• Service Providers. To operate the Platform and process Personal Information in accordance with Gigloop’s instructions and on its behalf, such as the following business and commercial purposes:
  • Email origination.
  •  Identity and criminal background checks as permitted under applicable laws;
  • Fraud prevention and detection;
  • Receipt, invoice, or support services;
  • Customer relationship management services;
  • Data analytics;
  • Marketing and advertising;
  • Website hosting;
  • Communications services;
  • Technical support;
  • Financial transaction fulfillment and related chargeback and collection services;
  • For registrant processing to onboard you on the Platform; and
  • As otherwise set forth in other terms of the Agreement or as otherwise permitted under applicable laws.
• Promotions or Offers. When you voluntarily enter a sweepstakes, prize draw, contest, promotion, or offering, we may share your Personal Information with the partner to provide you with the product or service requested.
• Advertising. We may share your Personal Information with third parties for advertising purposes.
• Other users. We may share your contact information with another user, or their legal or other authorized representative, to resolve an investigation or dispute related to, or arising from, an interaction between you and another user of the Platform, or between us and a third party related to the Platform.
• Legal Obligations. We may disclose your Personal Information to comply with applicable laws, or as requested by courts, law enforcement, governmental or public authorities, tax authorities, or authorized third parties, to the extent permitted under applicable laws, or where disclosure is reasonably necessary to address any activity that may expose us or a third party to legal or regulatory liability. We may also disclose your Personal Information to a relevant third party in our sole discretion, and to the extent permitted by applicable law, if we have reason to believe there has been an injury or an actual or possible interference with the rights of users, Gigloop and its parents, partners, or the general public.
• Merger or Acquisition. We may also share your Personal Information with interested
  parties in connection with, or during negotiations of, any proposed or actual merger,
  purchase, or sale of all or any portion of our assets to another business.

6. Retention of Personal Information

We retain your Personal Information for as long as necessary to provide you with our products or services and fulfill the purposes described in this Privacy Policy. When we no longer need to use your information and there is no need for us to keep it to comply with our legal obligations or to the extent permitted under applicable laws, we’ll either delete it from our systems or deidentify it so that we can’t use it to reidentify you.

7. Your Rights and Choices

Depending on where you live, you may have certain privacy rights under regional or local law. If you live in the EEA, UK, or Switzerland, please see “Additional Disclosures for Data Subjects in the European Economic Area (EEA), Switzerland, and the UK” section below.

Opt-Out of Promotional Communications. You may opt-out of receiving or promotional updates via email, SMS, or push notifications, on web and app, by visiting the “Notifications” page in your Account Settings and setting your preferences. Other opt-out mechanisms include:

• Opt out of promotional email marketing by clicking on the unsubscribe link in the email;
• Opt out of promotional text messages by following the instructions provided in those messages to text the word “STOP”

We may still continue to send you transactional communications, such as those about your account, Gigs, transactions, servicing, or ongoing business relationship with you.

Right to Access and Data Portability. You have the right to access the Personal Information we have about you. In particular, you have the right to request the following from us:

• The categories of Personal Information we have collected about you;
• The categories of sources from which the Personal Information was collected;
• The categories of Personal Information about you we disclosed for a business purpose or sold;
• The categories of third parties to whom the Personal Information was disclosed for a business purpose or sold;
• The business or commercial purpose for collecting or selling the Personal Information; and
• The specific pieces of Personal Information we have collected about you.

Right to Correct. You have the right to update and correct inaccuracies in your account at any time by logging in and clicking on the “Account” tab. There, you can view, update, and correct your account information.

Right to Delete. You have the right to delete the Personal Information we have about you. Please note we may retain certain Personal Information to comply with our legal obligations or to the extent permitted under applicable laws.

Right to Non-Discrimination. You have the right to non-discriminatory treatment by us should you exercise any of these rights. To exercise any of these rights, please submit a request at  support@gigloop.co. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your request.

8. Contacting Us

If you have any questions about our this policy or our privacy practices us, you may contact us at  support@gigloop.co or by sending us a letter to:

Attn: Legal Department – DMCA Notice
Gigloop, LLC
17870 Newhope Street, Suite 104-499
Fountain Valley, California 92708
United States of America

9. Jurisdiction-Specific Provisions

Residents of the United States

Right to Opt-Out of Sale. Gigloop does not generally sell information as the term “sell” is traditionally understood. However, to the extent “sale” under the CCPA is interpreted to include advertising technology activities such as those disclosed in Section 5, Gigloop’s Use of Information, as a “sale,” you have the right to opt-out of the sale of your Personal Information by us to third parties at any time. You may request to opt-out by clicking “Do Not Sell My Personal Information” and making your choice.

California Residents. California residents may request: a list of the categories of Personal Information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes, and a list of the categories of third parties to whom we have disclosed such information. To exercise a request, please submit a request at  support@gigloop.co. Note we may request additional information to verify your identity and confirm your California residence.

Residents of Canada

Transfer Of Data. We and our affiliates primarily store your Personal Information on servers located and operated within the United States to provide and operate the Platform. By accepting the terms of this Privacy Policy, you acknowledge the transfer to and processing of your Personal Information on servers located in the U.S.

Residents of the European Economic Area (EEA), Switzerland, and the United Kingdom

Controller. Gigloop, LLC is the data controller for your Personal Information.

Legal Bases for Using Your Personal Information

In accordance with the General Data Protection Regulation (“GDPR”) and the United Kingdom General Data Protection Regulation (“UK GDPR”), we rely on the following legal basis for processing your Personal Information:

Performance of a Contract 

We process the following information where it is necessary for us to carry out a contract to which you are party to or take steps before you enter into a contract with us or another user of the Platform:

• Contact Information
• Billing Information
• Booking Information
• User-Generated Content Information
• Driver’s License and Vehicle Information
• Third Party Information

For the following purposes:

• To operate and make available the Platform;
• To connect you with other users to fulfill a Gig;
• To process payments;
• To provide you with customer support, and to assist in the resolution of your, or a third party’s, complaints; or
• To enforce the relevant Terms of Service.

Consent 

We process the following information where you have given your consent:

• Contact Information
• Promotional Information
• Data from Cookies or Similar Technologies

For the following purposes:

• To contact you with transactional and promotional communications.
• To advertise our Platform’s or a partner’s products or services that we think might interest you. For more information and to understand your choices regarding third-party ads, please see our Cookie Policy in Section 10.

You have the right to withdraw your consent for the processing at any time. If you would like to withdraw your consent please submit a request at support@gigloop.co. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your request.

To comply with our legal obligations

We rely on this legal basis where the processing is necessary to comply with legal or regulatory obligations. The categories of information we process will depend on the factual circumstances and could include any of the categories listed in this Privacy Policy.

For the following purposes:

• For billing and fraud prevention to ensure a safe and secure environment to facilitate financial transactions;
• As otherwise set forth in the Terms of Service or as otherwise permitted under applicable laws;
• To conduct identification and criminal background checks, as permitted by laws;
• To ensure the safety of our users both online and offline; or
• To maintain the integrity of the Platform.

Legitimate Interests

We rely on our legitimate interests or those of a third party where they are not outweighed by your interests and fundamental rights, to process the following information:

• Contact Information
• Identity Information
• User-Generated Content Information
• Booking Information
• Device Data
• Location Data
• Service Use Data
• Data from Cookies and Similar Technologies

For the following purposes:

• To operate and make available the Platform;
• To connect you with other users to fulfill a Gig;
• For billing and fraud prevention to ensure a safe and secure environment to facilitate financial transactions;
• To ensure the safety of our users both online and offline;
• To maintain the integrity of the Platform;
• For analysis to improve the Platform; or
• To provide you with customer support, and to assist in the resolution of your, or a third party’s, complaints.

It is in our legitimate interest to process the information for the above purposes so that we can provide you with an innovative product and keep it secure. You have the right to object to processing based on legitimate interests. If you would like to object to the processing please submit a request at support@gigloop.co.

Your Rights

Right to Object to Processing. You may object to our processing of your personal information where we rely on legitimate interests as the legal basis. We will stop processing your information unless we can demonstrate compelling legitimate grounds for the processing, or if it is required for legal claims.

Right to Withdraw Consent. Where we rely on your consent to process your personal data, you have the right to withdraw your consent at any time. This will not affect the lawfulness of any processing carried out before you withdraw your consent.

Right to Lodge a Complaint. You have the right to lodge a complaint with your local supervisory authority. If you are located in the EEA, UK or Switzerland, you can contact the data protection authority in your country of residence.

How to Exercise Your Rights

To exercise any of these rights, please submit a request at  support@gigloop.co. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your request.

How We Transfer Your Personal Information

EU-US Data Privacy Framework (DPF) and the UK Extension to the EU-US DPF

Gigloop is a participant in the EU-US Data Privacy Framework (DPF) and its UK extension as set forth by the US Department of Commerce. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about DPF and to view our self-certification, please visit www.dataprivacyframework.gov.

As a participant of DPF, Gigloop is committed to transferring the personal information of all EU and UK residents in compliance with DPF Principles.

As explained in this Privacy Policy, Gigloop may disclose your personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If we transfer personal information about an EU or UK resident to a third party, the third party’s use, retention, or disclosure must also follow our DPF obligations. Gigloop recognizes our potential liability under the DPF for the third party’s failure to adhere to DPF principles concerning your personal information.

Gigloop is committed to resolving inquiries and complaints about our privacy program’s adherence to DPF. If you have any inquiries or complaints regarding our privacy program, you may contact us at  support@gigloop.co.

If we are unable to resolve your inquiry or complaint, you may contact an independent dispute resolution body, free of charge to you. You may contact our US-based third-party dispute resolution organization, JAMS, at https://www.jamsadr.com/DPF-Dispute-Resolution. If neither Gigloop nor JAMs is unable to resolve your complaint, you may, under certain circumstances, pursue binding arbitration.

Additional recourse mechanisms include contacting the following independent dispute resolution bodies: for EU residents, you may contact EU Data Protection Authorities at
https://www.edpb.europa.eu/about-edpb/about-edpb/members_en. For UK residents, you may contact the UK Information Commissioner’s Office at https://ico.org.uk/make-a-complaint/uk-
extension-to-the-eu-us-data-privacy-framework-complaints-tool/. In the US, Gigloop is subject to the investigatory and regulatory enforcement of the Federal Trade Commission.

10. Cookie Policy

Gigloop uses cookies, unique identifiers and other similar technologies, like pixels, to distinguish you from other users of our platform, provide our services to you, help collect data and to improve our platform. This Cookie Policy explains how and why we use cookies and other similar technologies.

When you visit our website, your browser may automatically transmit information to the site throughout the visit. In a similar way, when you use our mobile applications, we will access and use mobile device IDs to recognize your device. We use “cookies” and equivalent technologies to collect information through our website and Apps.

Most browsers accept cookies by default. You can instruct your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations. Exhibit A sets out the different categories of cookies that the Gigloop Platform uses and why we use them.

Cookies

Cookies are small data files stored on your device that act as a unique tag to identify your browser.

Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Additionally, persistent cookies allow us to bring you advertising both on and off the Gigloop Platform. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings. We utilize persistent cookies that only Gigloop can read and use, and access mobile device IDs to:

• save your login information for future logins to the Gigloop Platform
• assist in processing items during checkout;
• hold session information; and
• track user preferences.

Session cookies make it easier for you to navigate our website and expire when you close your browser. We utilize session ID cookies and similar technologies to:

• enable certain features of the Gigloop Platform;
• better understand how you interact with the website and the Gigloop Platform;
• monitor usage by our Users and web traffic routing on the Gigloop Platform; and
• identify visited areas of the Gigloop Platform.

Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Gigloop Platform and then close your browser.

Flash Cookies

We may use flash cookies (or Local Shared Objects) to personalize and enhance your visit. Via flash cookies we may store your preferences or display content based upon what you view on the Sites to personalize your visit.

Pixel Tags

We and our Third-Party Agents may use “pixel tags” (sometimes referred to as “web beacons” or “clear GIFs”). These or similar technologies are tiny graphic images and/or blocks of code with a unique identifier that are used to understand browsing activity and/or determine whether a specific action was performed.

These may be used by Gigloop or our Third-Party Agents in connection the Gigloop Platform and HTML-formatted email messages to, among other things, track the actions of Users and email recipients, determine the success of marketing campaigns, and compile statistics about Site usage and response rates.

Your Choices and Managing Cookies

You can adjust your browser settings to enable you to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. Depending on what browser you use, you may manage your settings here: Internet Explorer, Safari, Chrome, Firefox, and Opera. If you do not accept cookies, however, you will not be able to use all portions or all functionalities of the Gigloop Platform.

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is currently no industry consensus as to what site and app operations should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit https://www.allaboutdnt.com.

Contacting Us

If you have any questions about this Cookie Policy or the manner in which we or our Third-Party Agents treat your Personal Information, the practices of the Site, your dealings with the Gigloop Platform, or if you have technical problems, you may contact us
at support@gigloop.co.