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Privacy Policy

Last Updated: 12/31/2020

Xariable, Inc. doing business as Loop Returns (“Loop,” “we,” “us,” and “our”) provides a platform to allow our customers to streamline and automate their workflows for returns. This Privacy Policy is designed to help you understand how we collect, use, and share your personal information and to help you understand and exercise your privacy rights.

1. Scope

This Privacy Policy applies to personal information processed by us, including on our websites, and otheronline or offline offerings. To make this Privacy Policy easier to read, our websites, mobile applications, and other offerings are collectively called “Services”.

An Important Note: This Privacy Policy does not apply to any of the personal information that our merchants may process using Loop’s products and services (“Merchant Data”). Our merchants’ respective privacy policies govern the collection and use of Merchant Data. Our processing of Merchant Data isgoverned by the contracts that we have in place with our merchants, not this Privacy Policy. Any questions or requests relating to Merchant Data should be directed to our merchants.

2. Personal Information We Collect

This Privacy Policy applies to personal information processed by us, including on our websites, and otheronline or offline offerings. To make this Privacy Policy easier to read, our websites, mobile applications, and other offerings are collectively called “Services”.

An Important Note: This Privacy Policy does not apply to any of the personal information that our merchants may process using Loop’s products and services (“Merchant Data”). Our merchants’ respective privacy policies govern the collection and use of Merchant Data. Our processing of Merchant Data isgoverned by the contracts that we have in place with our merchants, not this Privacy Policy. Any questions or requests relating to Merchant Data should be directed to our merchants.

A. Information You Provide to Us Directly

We may collect the following personal information that you provide to us.

• Merchant Account Creation. We may collect information when you create a merchant account, such as name, email address, telephone number, company name, and job title.

• Merchant Customers. When you initiate a return with one of our merchants, we may collect information such as your name, email address, mailing address, and telephone number.


• Purchases. If you are a merchant, we may collect personal information and details associated with your purchases, including payment information, such as name, credit card details, and billing information. Any payments made via our Services are processed by our third-party payment processor, Stripe. For more information about Stripe please see Stripe’s Privacy Policy.

• Your Communications with Us. We may collect personal information, such as name, email address, phone number, or mailing address when you request information about our Services, subscribe to our blog, book a demo, request customer or technical support, apply for a job orotherwise communicate with us.


3. HOW WE USE YOUR INFORMATION

We use your information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

A. Provide Our Services We use your information to fulfil our contract with you and provide you with our Services, such as:

Managing your information and accounts;

Providing access to certain areas, functionalities, and features of our Services;

Answering requests for customer or technical support;

Communicating with you about your account, activities on our Services, and policy changes;

Processing your financial information and other payment methods for products or Services purchased;

Processing applications if you apply for a job, we post on our Services; and

Allowing you to register for events.

B. Administrative Purposes

We use your information for various administrative purposes, such as:

• Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;

• Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;

Measuring interest and engagement in our Services;

Short-term, transient use, such as contextual customization of ads;

Improving, upgrading or enhancing our Services;

Developing new products and Services;

Ensuring internal quality control and safety;

Authenticating and verifying individual identities;

Debugging to identify and repair errors with our Services;

Auditing relating to interactions, transactions and other compliance activities;

Enforcing our agreements and policies; and

Complying with our legal obligations.

C. Marketing and Advertising our Products and Services

We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.

Some of the ways we market to you include email campaigns, custom audiences advertising, and “interest- based” or “personalized advertising,” including through cross-device tracking.

If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth below.

D. Other Purposes

We also use your information for other purposes as requested by you or as permitted by applicable law.

• Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

• De-identified and Aggregated Information. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create.

4. HOW WE DISCLOSE YOUR INFORMATION 

We disclose your information to third parties for a variety of business purposes, including to provide our  Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or  asset transfer, as described below.  

A. Disclosures to Provide our Services 

The categories of third parties with whom we may share your information are described below.  

Service Providers. We may share your personal information with our third-party service providers  who use that information to help us provide our Services. This includes service providers that provide  us with IT support, hosting, payment processing, customer service, and related services. 

Business Partners. We may share your personal information with business partners to provide you  with a product or service you have requested. We may also share your personal information to business  partners with whom we jointly offer products or services. 

Affiliates. We may share your personal information with our company affiliates.  

Advertising Partners. We may share your personal information with third-party advertising partners.  These third-party advertising partners may set Technologies and other tracking tools on our Services to  collect information regarding your activities and your device (e.g., your IP address, cookie identifiers,  page(s) visited, location, time of day). These advertising partners may use this information (and similar  information collected from other services) for purposes of delivering personalized advertisements to  you when you visit digital properties within their networks. This practice is commonly referred to as  “interest-based advertising” or “personalized advertising.”  

APIs/SDKs. We may use third-party Application Program Interfaces (“APIs”) and software  development kits (“SDKs”) as part of the functionality of our Services. For more information about our  use of APIs and SDKs, please contact us as set forth below. 

B. Disclosures to Protect Us or Others 

We may access, preserve, and disclose any information we store associated with you to external parties if  we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national  security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights,  property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an  investigation or prosecution of suspected or actual illegal activity. 

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers 

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy,  receivership, purchase or sale of assets, or transition of service to another provider, your information may  be sold or transferred as part of such a transaction, as permitted by law and/or contract.

5. YOUR PRIVACY CHOICES AND RIGHTS 

Your Privacy Choices. The privacy choices you may have about your personal information are determined  by applicable law and are described below.  

Email and Telephone Communications. If you receive an unwanted email from us, you can use  the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note  that you will continue to receive transaction-related emails regarding products or Services you have  requested. We may also send you certain non-promotional communications regarding us and our  Services, and you will not be able to opt out of those communications (e.g., communications  regarding our Services or updates to our Terms or this Privacy Policy).  

We process requests to be placed on do-not-mail, do-not-phone, and do-not-contact lists as required  by applicable law. 

Text Messages. You may opt out of receiving text messages from us by following the instructions  in the text message you have received from us or by otherwise contacting us. 

“Do Not Track.Do Not Track (“DNT”) is a privacy preference that users can set in certain web  browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms  transmitted by web browsers. 

Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies  on your device or remove them by adjusting your preferences as your browser or device permits.  However, if you adjust your preferences, our Services may not work properly. Please note that  cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of  personalized advertisements on some mobile applications by following the instructions for  Android, iOS and others. 

The online advertising industry also provides websites from which you may opt out of receiving  targeted ads from data partners and other advertising partners that participate in self-regulatory  programs. You can access these and learn more about targeted advertising and consumer choice  and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the  European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.  

Please note you must separately opt out in each browser and on each device.  

Your Privacy Rights. In accordance with applicable law, you may have the right to: 

Access Personal Information about you, including: (i) confirming whether we are processing your  personal information; (ii) obtaining access to or a copy of your personal information; and (iii)  receiving an electronic copy of personal information that you have provided to us, or asking us to  send that information to another company (the “right of data portability”); 

Request Correction of your personal information where it is inaccurate or incomplete. In some  cases, we may provide self-service tools that enable you to update your personal information; 

Request Deletion of your personal information;  

Request Restriction of or Object to our processing of your personal information; and 

Withdraw your Consent to our processing of your personal information.  

If you would like to exercise any of these rights, please contact us as set forth below. We will process such  requests in accordance with applicable laws Your Privacy Rights. In accordance with applicable law, you may have the right to: 

Access Personal Information about you, including: (i) confirming whether we are processing your  personal information; (ii) obtaining access to or a copy of your personal information; and (iii)  receiving an electronic copy of personal information that you have provided to us, or asking us to  send that information to another company (the “right of data portability”); 

Request Correction of your personal information where it is inaccurate or incomplete. In some  cases, we may provide self-service tools that enable you to update your personal information; 

Request Deletion of your personal information;  

Request Restriction of or Object to our processing of your personal information; and 

Withdraw your Consent to our processing of your personal information.  

If you would like to exercise any of these rights, please contact us as set forth below. We will process such  requests in accordance with applicable laws

6. SECURITY OF YOUR INFORMATION 

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy.  Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information  you provide to us. We have taken appropriate safeguards to require that your personal information will  remain protected and require our third-party service providers and partners to have appropriate safeguards  as well. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized  disclosure. 

By using our Services or providing personal information to us, you agree that we may communicate with  you electronically regarding security, privacy, and administrative issues relating to your use of our Services.  If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice  on our Services, by mail or by sending an email to you. 

7. INTERNATIONAL DATA TRANSFERS  

All information processed by us may be transferred, processed, and stored anywhere in the world, including,  but not limited to, the United States or other countries, which may have data protection laws that are  different from the laws where you live. We endeavor to safeguard your information consistent with the  requirements of applicable laws.

8. RETENTION OF PERSONAL INFORMATION

  We store the personal information we collect as described in this Privacy Policy for as long as you use our  Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve  disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our  agreements, and comply with applicable laws. 

9. Supplemental Notice To California Residents

This Supplemental California Privacy Notice only applies to our processing of personal information thatis subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Loop has collected about them and whether Loop disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:

Category of Personal Information

Collected by Loop

Category of Third Parties Information is Disclosed to for a Business Purpose

Identifiers

A real name, postal address, Internet Protocol address, email address, or other similar identifiers.

• Advertising partners

• Service providers

Personal information categories listed in the California Customer

Records statute (Cal. Civ. Code § 1798.80(e))

A name, address, telephone number, employment, credit card number, debit card number, or any other financial information.

• Advertising partners

10. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS 

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to  third parties who intend to license or sell that Personal Information. You can exercise this right by  contacting us at support@loopreturns.com with the subject line “Nevada Do Not Sell Request” and  providing us with your name and the email address associated with your account. Please note that we do 

not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter  603A.

11. CHILDREN’S INFORMATION 

The Services are not directed to children under 13 (or other age as required by local law), and we do not  knowingly collect personal information from children. 

If you are a parent or guardian and believe your child has provided personal information to us without your  consent, you may contact us as described below. If we become aware that a child has provided us with  personal information in violation of applicable law, we will delete any personal information we have  collected, unless we have a legal obligation to keep it.

12. OTHER PROVISIONS 

Third-Party Websites/Applications. The Services may contain links to other websites/applications and  other websites/applications may reference or link to our Services. These third-party services are not  controlled by us. We encourage our users to read the privacy policies of each website and application with  which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices  or content of such other websites or applications. Providing personal information to third-party websites or  applications is at your own risk.  

Supervisory Authority. If you are located in the European Economic Area, Switzerland, the United  Kingdom or Brazil, you have the right to lodge a complaint with a supervisory authority if you believe our  processing of your personal information violates applicable law. 

Changes to our Privacy Policy. We may revise this Privacy Policy from time to time in our sole discretion.  If there are any material changes to this Privacy Policy, we will notify you as required by applicable law.  You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you  continue to use our Services after the new Privacy Policy takes effect.

13. CONTACT US 

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as  detailed in this Privacy Policy, please contact us at: 

Xariable, Inc. d/b/a Loop Returns 

PO Box 16250 

Columbus, OH 43216 

dpo@loopreturns.com