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Privacy Policy

Last updated: August 21, 2023

Who We Are

We have developed a user-friendly app that provides users with coupons, promo codes, cash back, and contributes to environmental sustainability.

This Privacy Policy and the Terms of Use apply to your access and use of our Services.

1. Changes to this Privacy Policy

We use our Privacy Policy to tell you how we manage and protect your personal information. When we make big changes to our Policy, we will notify you via the email address we have on file or other methods you have provided us. Sometimes we may use popups or other “just-in-time” notices to provide you with information about our privacy practices.

We may modify this Policy at any time, without prior notice, and changes may apply to any personal information we already hold about you, as well as any new personal information collected after the Policy is modified. If we make changes, we will notify you by revising the date at the top of this Policy. We will provide you with advanced notice if we make any material changes to how we collect, use or disclose your personal information or that impact your rights under this Policy by posting a new notice on our Services page or by sending you an email (if you have provided us with your contact information). If you continue to access or use our Services after receiving the notice of changes, you acknowledge your acceptance of the updated Policy.

In addition, we may provide you with real time disclosures or additional information about the data handling practices of specific parts of our Services. Such notices may supplement this Policy or provide you with additional choices about how we process your personal information.

2. Information You Provide Us

Personal information is any information that can be used to identify you, and we describe how we protect your personal information in the rest of this Policy. Anonymized information, or information stripped of your identifiable information, is not personal information.

Any information that is anonymized or aggregated is no longer personal information. In connection with the Services, we may ask you to provide these categories of personal information:

 

  • Account Information: Information you provide about yourself to access our Services, including name, email, phone number, address, and password, so that we may communicate with you and provide you with the Services.

 

  • Self – Reported Information: Information you provide about yourself, including your survey answers, demographics, interests or more.

 

  • Voluntary Information: Information you provide to us voluntarily by completing web forms, participating in polls, or contributing to blogs, postings, and other mediums constitutes Voluntary Information.

3. Information We Collect Through Your Use of the Services

We monitor information about your use and interaction with our Services automatically, using methods like cookies and logs. We do this in order to keep your account safe, ensure security and privacy, improve our Services and market our Services.

 

When you use the Services, we automatically collect information about the Services you use and how you use them (“Passive Information”), as described below.

 

  • Usage Information: We collect information about your interactions with the Services, such as the pages or other content you view, and other actions you perform while using the Services.

 

  • Log Data: We automatically collect log information when you use the Services. This might include your IP address, access times, hardware and software information, device information, device event information(e.g. crashes, unsuccessful logins, browser type), the web page you’ve viewed or engaged with before or after using the Services, and other relevant information. We collect and monitor this data in order to keep track of the security and privacy of your account.

 

  • Cookies, Pixel Tags and Similar Tracking Technologies: We may use various tracking technologies to collect and store information about your use of our Services. We use these tools to ensure that you receive a personalized experience, to provide you with certain functions on our Services, to keep your account safe, to improve and optimize our Services, and to market our Services. Please refer to the “Cookies and Similar Tracking Technologies” section below for more information.

4. Third-Party Sources of Information

With your permission, we collect some personal information about you from third parties. We do this in order to make it easier for you to access this data and to improve the quality of the Services.

5. How We Use Your Information

We require certain personal information to provide you with our Services. Generally, your personal information is used to provide, support, personalize, and improve our Services. We also use Passive Information for compliance and security purposes.

 

Your personal information can be used for various purposes, including:

 

  • To Provide Our Services. When you access or use our Services, we collect certain personal information about you to be able to provide you with our Services. We cannot provide you with our Services without such processing of your personal information.

 

Your personal information is used to ensure that our Services are appropriately used according to our policies, so that we can maintain a trusted environment for you. We use your personal information to ensure our Services are used as intended and permitted under our agreement(s) and policies with you.

 

  • To Enforce our Terms, Agreements, or Policies. To maintain a safe, secure, and trusted environment for you when you use the Services, we use your personal information to make sure our terms, policies, and agreements with you and any third-parties are enforced. We actively monitor, investigate, prevent, and mitigate any suspected or actual prohibited activities on our Services. We are required to process your personal information for this purpose in order to provide our Services.

 

We may use your personal information to maintain, monitor, and improve the security of our Services.

 

  • To Provide Secure Services. We recognize and acknowledge the trust you are placing in us to keep your personal information safe. We are committed to ensuring your personal information is processed securely on our Services. To maintain the security of our Services, we may process your personal information to investigate, detect, prevent, or report fraud, misrepresentation, security incidents or breaches, spam, malware, malicious activities, or other prohibited or illegal activities. In addition, we process your personal information to improve the security of our Services. We cannot provide the Services securely without such processing.

 

We may use your personal information to improve, optimize, or expand our Services.

 

  • To Conduct Product Research and Development. We want to ensure our Services are continually improving and expanding so that we meet and exceed your needs and expectations. To do so, we may process your personal information to improve, optimize, or expand our Services or features of our Services. We do so by processing information about your use of the Services, any information you provide to us, and by measuring, tracking, and analyzing trends and usage in connection to your use or the performance of our Services. We take additional security measures when processing your personal information for such purposes, such as by de-identifying (or “pseudonymizing”) your personal information and limiting access to such data. Without processing your information for such purposes, we may not be able to ensure your continued satisfaction when using our Services.

 

We may use your personal information to comply with applicable laws and regulations.

 

  • To Maintain Legal and Regulatory Compliance. We may be required to process your personal information under certain laws and regulations, such as tax laws, medical research obligations, or as otherwise required by applicable law. We cannot provide the Services to you without such processing.

 

We may use your personal information to market our Services.

 

  • To Engage in Marketing Activities. We may use your personal information to promote our Services. For example, we may conduct targeted advertising campaigns. For more information about these activities and instructions on how to opt out, please see the “Cookies and Similar Tracking Technologies” section.

 

We will notify you if we plan to use your personal information for any other reason not listed in this Policy. If necessary, we will seek your consent for such processing in advance.

 

We will disclose any other use of your personal information in connection with our Services prior to processing your personal information for such purposes. You may choose not to allow us to process your personal information for any purposes that are not compatible with the purposes for which we originally collected your personal information or subsequently obtained your consent. However, you should be aware that if you choose to limit how we use your personal information, some or all of our Services may not be available to you.

6. How We Share Your Information

We respect your privacy and limit how we share your personal information. We may share your personal information with external parties that you authorize, and external parties that we vet to help us provide you the Services, to improve your experience on the Services, to ensure continuation of the Services, and to comply with legal obligations and keep people safe.

 

The third parties we work with do not have permission to use the information we share with them beyond what is necessary to assist us. We execute agreements with third parties to ensure they use adequate safeguards when processing your personal information in accordance with this Policy.

 

  • Affiliated Businesses. We may share your personal information with affiliated businesses to provide you with the Services, promote or market the Services, or to assist or improve our Services. As required by law, we will ask for your prior consent before sharing your personal information with affiliates we do not control, business partners, or others for marketing purposes (like products, services, or clinical trials that may be of interest to you).

 

  • Merger, Bankruptcy, or Corporate Reorganization. We may disclose and transfer your personal information to a subsequent owner, co-owner, or operator of Cloopp or the Services, or in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets (i.e., a bankruptcy proceeding), or other corporate change. We will notify you with any choices you may have regarding your personal information when we are engaged in a merger, bankruptcy, or corporate reorganization.

 

  • Legal Obligations and Safety. We may share your personal information if it is reasonably necessary to: 
    • – Comply with a valid legal process (e.g., subpoenas, warrants, court orders, etc.);
    • – Comply with requests or investigations by public authorities;
    • – Comply with applicable laws or regulations;
    • – Enforce or apply the Cloopp policies or policies of our research or business partners;
    • – Protect the security or integrity of the Services; or
    • – Protect the rights, property, or safety of Cloopp, our employees or users, partners and affiliates, or other natural persons.

 

We will, at our discretion, provide you with advance notice if we are compelled to disclose your personal information to law enforcement, unless we are prohibited from doing so by public authorities or the law.

7. Cookies and Similar Tracking Technologies

We use cookies, pixel tags, web beacons and similar tracking technologies to provide our Services to you, increase security, make your browsing experience more convenient and market our Services.

 

Cloopp uses cookies and similar tracking technologies to collect Passive Information about your use of our Services. Cookies are small files, typically comprised of letters and numbers, that your computer or mobile device saves when you visit certain websites. When you return to the websites that save cookies on your device—or visit other websites that use the same cookies—the websites recognize such cookies and your browsing device.

 

  • How We Use Cookies. Generally, we use first-party and third-party cookies for the following purposes:
    • To make our Services function properly;
    • To provide a secure browsing experience during your use of our Services;
    • To collect Passive Information about your use of our Services to help us improve and optimize our Services;
    • To remember your preferences for your convenience; and
    • To market our Services, including by showing ads or content on our Services or on third- party sites.

 

The types of cookies and tracking technologies used in our Services have different functions, such as allowing you to access secure areas of our Services, remember your choices, and improve and optimize our services.

 

  • Types of Cookies on Our Services. We use the following types of cookies on our Services:
    • Strictly Necessary Cookies: These cookies are essential because they enable you to move around and use our Services. For example, strictly necessary cookies allow you to access secure areas on our Services. Without these cookies, some services cannot be provided. This category of cookies is essential for our Services to work and they cannot be disabled.
    • Functional Cookies. We use functional cookies to remember your choices so we can tailor our Services to provide you with enhanced features and personalized content. For example, these cookies can be used to remember your name or preferences on our Services. While these cookies can be disabled, this may result in less functionality during your use of our Services.
    • Performance or Analytic Cookies. These cookies collect anonymous Passive Information about how you use our Services. For example, the cookies will collect information about the pages you view or click on while using our Services or if you get an error message from certain pages. We use the information collected by such cookies to improve and optimize our Services. You can disable these cookies.
    • Advertising or Targeting Related Cookies. We may use first-party or third-party cookies and web beacons to deliver ads or similar content on our Services or third-party sites, such as Google and Facebook. For example, we use Google Ads and Facebook to serve targeted ads on websites across the Internet to people who have previously visited or interacted with our Services. These third parties may use cookies or similar tracking technologies to collect information about your activity on our Services or other websites across the Internet in order to do so. We may also use cookies and tracking technologies to track your interaction with ads or our Services, such as whether you have clicked on an ad, which helps us monitor the effectiveness of an advertising campaign.
    • Third-Party Cookies. These are cookies that are provided by a third-party service provider and belong in one of the cookie categories described above. The only third-party cookies we use are Google Analytics cookies, used for improving and optimizing our Services. If you would like more information on how Google uses cookie information, please visit their website to find out more.

 

You can see and manage the cookies and similar tracking technologies we use in your browser settings and by visiting a third-party cookie service provider’s website directly.

 

  • How to Manage Cookies. Depending on whether you would like to manage a first-party or third-party cookie, you will need to take the following steps:
    • First-Party (or Cloopp’s) Cookies: You can enable, disable, or delete cookies through the browser you are using to access our Services. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable cookies, you may not be able to access secure areas of our Services, and/or parts of the Services may not work properly for you. You can find more information about how to change your browser cookie settings at https://www.allaboutcookies.org.
    • Third-Party Cookies: You can disable cookies from third parties by using your browser settings or, if available, directly opting-out of cookie collection with the third-party cookie service provider via their website. The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at the following websites:
      • Network Advertising Initiative
      • Your Online Choices EU
      • Ad Choices
      • Facebook
      • Google Ads
      • Google Analytics

8. Your Choices

You can adjust information about your account, information you provide to us, and communication preferences. You can also terminate your account at any time. However, we may still retain some information required by law or that has already been processed for Cloopp Inc.

 

  • Your Account: You may access your Cloopp Account Information by going to the “Your Account” page. You can edit your Account Information as necessary, such as your email address, name, phone number, and more. When you update your Account Information, we may keep a copy of your previous account details for our records and to prevent fraud or other activities that violate our terms, policies and agreements. However, if you do not provide us with some of your personal information, such as your name or email, we will no longer be able to provide you with access to our Services.
  • Self-Reported and Voluntary Information: You may choose not to provide us with some of your personal information. For example, you are not required to submit an intake form to us or complete any survey we send to you. In some instances, you may be able to edit your answers to forms, surveys or features you submit to us in your account. If you cannot find the information you are looking for in your account, please contact us at info@Cloopp.com with your request.
  • Communication Preferences: If you do not want to receive emails from us, please adjust your communication preferences or click the unsubscribe link within the email you received from us. You will not be able to unsubscribe from Service-related communications as they are necessary for us to continue offering you the Services.
  • Sharing Settings: Cloopp allows you to share your personal information with third parties, such as healthcare providers, external research organizations, friends or family members, or other individuals outside of our Services. You should only share your personal information with individuals or entities you trust. Once you share your personal information with anyone, Cloopp does not have control of the data you have shared and is no longer liable or responsible for the shared personal information. If you would like to change how you share your Account Information with third parties, you may update your preferences in your settings or contact us at info@Cloopp.com.
  • Account Deletion: At any time, you can delete information you have uploaded to your account, such as medical records and survey answers. If you wish to delete your account completely, please email us at info@Cloopp.com. Please note that Cloopp’s deletion of your personal information is subject to limitations, including any information that has already been processed for Cloopp Inc and any applicable legal retention requirements.

 

If you are located in the European Economic Area or Switzerland, please refer to the section below entitled, “Notice to Individuals in the European Economic Area and Switzerland” for information about additional choices and rights to your personal information.

9. How We Protect Your Information

Protecting your personal information is our highest priority and we implement physical, administrative, and technical measures to protect it.

 

One of the Cloopp’s top priorities is protecting your personal information. Cloopp employs commercially reasonable physical, administrative, and technical safeguards to help protect and secure your personal information, including encryption of your personal information while it is at rest and in transit.

 

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All personal information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL or other encryption technology, or will use our third-party payment processors which use appropriate security procedures.

 

You should be aware that, unfortunately, no system can be 100% secure. Although the security of your personal information is our highest priority, there will always be a risk that your personal information gets compromised. We also depend on you to keep your Account Information secure by keeping your password confidential and taking precautions to keep others from accessing your account.

 

Multi-profile account holders (such as family member accounts or accounts handled by a healthcare provider or some other entity) should be aware of their responsibility to protect the security and privacy of each individual on their account.

 

Please notify us immediately at info@Cloopp.com. if you become aware of any unauthorized access to or use of your account.

10. Transfers of Your Information

We may process your personal information outside of your country, such as when you decide to share access to your account with a doctor from another country.

 

When you access or use our Services, your personal information may be processed in the United States or any other country in which Cloopp, its affiliates, or service providers maintain facilities. Such countries or jurisdictions may have data protection laws that are less protective than the laws of the jurisdiction in which you reside. If you do not want your information transferred to, processed, or maintained outside of the country or jurisdiction where you are located, you should immediately stop accessing or using the Services.

 

If you are located in the European Economic Area or Switzerland, please refer to the section below entitled, “Notice to Individuals in the European Economic Area and Switzerland.”

11. Retention

In general, we keep your information for as long as necessary to deliver our Services or to comply with applicable law.

 

We generally retain your personal information as long as necessary to fulfill the purposes of collection or to comply with applicable law. Otherwise, we will try to delete your personal information upon your request or when we no longer need it for the purposes it was originally collected. We will not delete any personal information that also relates to other individuals, unless such other individuals also wish to delete their personal information at the same time.

 

We recognize that retention requirements can vary between jurisdictions, but we generally apply the retention periods described below.

 

  • Passive Information. We collect information about your interactions with our Services and we may store such information for the establishment or defense of legal claims, audit, or fraud and/or crime prevention purposes. Any information collected via cookies is retained up to one year from expiry of the cookie or the date of collection.

 

  • Cloopp Inc. We will retain any personal information involved in completed or pending Cloopp Inc indefinitely. Deletion of your personal information that has been used for Cloopp Inc will compromise the integrity of any research projects or conclusions.

 

  • Marketing Data. Any contact information you provide to us for marketing purposes (such as subscribing to our newsletter), like your name, email address, and phone number, is retained on an ongoing basis until you unsubscribe from our marketing communications. Thereafter we will add your contact information to our do-not-contact list to respect your unsubscribe request.

12. California Privacy Rights

If you live in California, you can ask us for a list of third parties we share your personal information with for marketing purposes.

 

California law permits California residents to ask us for a notice that identifies the categories of personal information that we share with our affiliates and/or third parties for marketing purposes, and that provides contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to us at the address provided under the “Contact Information” section.

13. Third Party Links On Our Services

You may find links to other websites on our Services. We do not control the content on these websites. You may find links to other websites, third party applications, and widgets on our Services that we do not own or control (“Third Party Links”). Cloopp is not responsible for the content on Third Party Links, nor do we endorse or review the privacy practices of such websites. Please read the privacy policies of such Third-Party Links to understand how your personal information will be handled before using their websites or services.

14. Do - Not - Track Signals

We do not respond to Do-Not-Track Signals. We use information about your online activity for security purposes and improving our Services.

 

Currently, we do not monitor or take any action with respect to Do Not Track signals or other mechanisms, which means that we collect information about your online activity both while you are using the Services and after you leave our Services.

15. Children’s personal information

Without parent or guardian consent, we do not allow children under 18 years old to use our Services.

 

We do not knowingly or intentionally collect personal information from minors. If you are under 18, you may use our Services only with your parent or guardian’s consent. Please contact us if you believe we have collected personal information about a child without consent from their parent or guardian so we can take action to prevent such access and to delete their information from our Services.

16. Notice to Individuals in the European Economic Area and Switzerland

This section only applies to individuals using or accessing our Service while located in the European Economic Area, the United Kingdom, or Switzerland (collectively, the “Designated Countries”) at the time of data collection.

We may ask you to identify which country you are located in when you use or access some of the Services, or we may rely on your IP address to identify which country you are located in. When we rely on your IP address, we cannot apply the terms of this section to any individual that masks or otherwise hides their location information from us so as not to appear located in the Designated Countries. If any terms in this section conflict with other terms contained in this Policy, the terms in this section shall apply to individuals in the Designated Countries.

  • Our Relationship to You. Cloopp is a data controller with regard to any personal information collected from individuals accessing or using its Services. A “data controller” is an entity that determines the purposes for which and the manner in which any personal information is processed. We use your personal information under certain legal bases permitted under the law, including:
    • With your consent
    • With your consent
    • To satisfy legal obligations
    • If we need to, to fulfill a contract with you, or to enter into a contract with you
    • In the public interest
    • In your vital interests
    • Based on our legitimate interests
    • For archiving purposes in the public interest, scientific or historical research purposes
  • Legal Bases for Processing Your personal information. We rely on the following Legal Bases under the EU General Data Protection Regulation in processing your personal information.
SectionPurpose of ProcessingLegal Basis for Processing
5(a)To Provide the ServicesWe are required to process your information to provide our Services to you. Our processing is based on our contract obligations or to take steps at the request of the individual prior to entering into a contract.
5(c)To Provide You with Service-Related Communications
5(e)To Enforce our Terms, Agreements or Policies
5(f)To Provide You with Customer Support
5(g)To Provide Secure Services
5(b)Third Party Service Providers
5(d)Affiliated Businesses, Business Partners or Others
5(b)To Conduct ClooppProcessing is based on our legitimate interest to better understand you, to develop treatments or cures for diseases, to maintain and improve the accuracy of the information we store about you, and to better promote or optimize our Services. In relation to the processing of special categories of personal data, processing is necessary for scientific or historical research purposes. As described in Sec. 5(b), above, ViuHealth takes specific measures to safeguard to protect your fundamental rights and privacy interests. In relation to incapacitated data subjects, processing is based on the vital interest of the individual, where the individual is physically or legally incapable of giving consent.
5(d)To Provide You with Research Communications
5(g)To Conduct Research and Product Development
5(i)To Maintain Legal and Regulatory Compliances
5(f)Legal Obligations and Safety

 

We will use your personal information for marketing purposes based on legitimate interest or consent, subject to the applicable law.

 

  • Marketing. We will only contact you if you are located in the Designated Countries by electronic means (including email or SMS) based on our legitimate interests, as permitted by applicable law or your consent. If you do not want us to use your personal information in this way, please click the unsubscribe link at the bottom of any of our email messages to you or contact us at info@Cloopp.com. You can object to direct marketing at any time and free of charge. You have certain rights to your personal information, including the right to:
    • Withdraw consent
    • Access and correct
    • Request deletion
    • Enjoy data portability
    • Restrict processing
    • Have us notify relevant third parties of erasure, rectification, and restriction
    • Object to processing
    • Opt out of automated individual decision – making, including profiling

 

Each of these rights has conditions and limitations, which are further described in the Policy below.

 

  • Individual Rights. We provide you with the rights described below when you use our Services. We may limit your individual rights requests: (a) where denial of access is required or authorized by law; (b) when granting access would have a negative impact on other’s privacy; (c) to protect our rights and properties; or (d) where the request is frivolous or unrealistic. If you would like to exercise your rights under applicable law, please contact us at info@Cloopp.com.
    • You can request access or deletion of your personal information.
    • You can correct or update your personal information, object to processing or your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
    • If we 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 the 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.
    • You have the right to complain to your local data protection authority about our collection and use of your personal information.

 

If you believe we have infringed or violated your privacy rights, please contact us at info@Cloopp.com so that we may resolve your dispute directly.

 

You also have the right to lodge a complaint with a competent supervisory authority. When we transfer your personal information to a business not located in the EU, we comply with the conditions laid down in Chapter 5 of the General Data Protection Regulation (“GDPR”).

 

  • Transfer of Your personal information. We transfer your personal information subject to the appropriate safeguards required under the applicable law. Depending on the circumstances the transfer of your personal information out of the Designated Countries, or an onward transfer of such information, is necessary for the performance of our contract with you, the performance of a contract between us and another party that we entered into for your interest, or for important reasons of public interest. Whenever we share your personal information with another party, we contractually require the recipients to comply with the GDPR and all other applicable data protection laws in processing your personal information and/or use the EU e rely on Standard Contractual Clauses in relation to such transfers.

17. Contact Information

If you have any questions, complaints, or feedback about this Privacy Policy or our treatment of your personal information, please feel free to contact us at info@Cloopp.com or by mail to:

Cloopp

Attn: Privacy Officer

1460 Broadway  Suite 1600

New York, NY 10013