Last updated: 2021-10-08
The privacy of your data — and it is your data, not ours — is a big deal to us. In this policy, we lay out what data we collect and why, how your data is handled, and your rights to your data.
We promise we never sell your data or use it for advertising purposes.
This policy applies to all services built and maintained by Loomio Limited.
Our guiding principle is to collect only what we need. Here’s what that means in practice.
When you sign up for a Loomio product, we typically ask for identifying information such as your name, email address, and maybe a company or group name. That’s just so you can personalize your new account, and we can send you notices, invoices, updates, or other essential information. We also give you the option to add a profile picture that displays in our products, but we do not normally look at or access that picture. We’ll never sell your personal info to third parties, and we won’t use your name or company in marketing statements without your permission either.
When you pay for a Loomio product, we ask for your credit card and billing address. That’s so we can charge you for service, calculate taxes due, and send you invoices. Your name, billing address, organization name and billing information are handled directly by our subscription management service, and credit card information is handle by our payment processor.
We log all access to all accounts by full IP address so that we can always verify no unauthorized access has happened. We keep this login data for as long as your product account is active.
We also log full IP addresses used to sign up a product account. We keep this record forever because they are used to mitigate spammy signups.
Web analytics data — described further in the Website Interactions section — are also tied temporarily to IP addresses to assist with troubleshooting cases.
When you browse our marketing pages or applications, your browser automatically shares certain information such as which operating system and browser version you are using. We track that information, along with the pages you are visiting, page load timing, and which website referred you for statistical purposes like conversion rates and to test new designs. We sometimes track specific link clicks to help inform some design decisions. These web analytics data are tied to your IP address and user account if applicable and you are signed into our Services.
We use CAPTCHA services across our applications to mitigate brute force logins and in Loomio as a means of spam protection. We have a legitimate interest in protecting our apps and the broader Internet community from credential stuffing attacks and spam. When you log into your accounts and fill specific forms in Loomio, the CAPTCHA service evaluates various information (e.g IP address, how long the visitor has been on the app, mouse movements) to check whether the data is possibly filled out by an automated program instead of a human.
We do use persistent first-party cookies to store certain preferences, make it easier for you to use our applications, and support some in-house analytics. A cookie is a piece of text stored by your browser to help it remember your login information, site preferences, and more. You can adjust cookie retention settings in your own browser. To learn more about cookies, including how to view which cookies have been set and how to manage and delete them, please visit: www.allaboutcookies.org.
At this time, our sites and applications do not respond to Do Not Track beacons sent by browser plugins.
When you write Loomio with a question or to ask for help, we keep that correspondence, including the email address, so that we have a history of past correspondences to reference if you reach out in the future.
We also store any information you volunteer like surveys. Sometimes when we do customer interviews, we may ask for your permission to record the conversation for future reference or use. We only do so if you give your express consent.
We don’t collect any characteristics of protected classifications including age, race, gender, religion, sexual orientation, gender identity, gender expression, or physical and mental abilities or disabilities. You may provide these data voluntarily, such as if you include a pronoun preference in your email signature when writing into our Support team.
We also do not collect any biometric data. You are given the option to add a picture to your user profile, which could be a real picture of you or a picture of something else that represents you best. We do not extract any information from profile pictures: they are for your use alone.
Our default practice is to not access your information. The only times we’ll ever access or share your info are:
To provide products or services you've requested. We do use some third-party services to run our applications and only to the extent necessary process some or all of your personal information via these third parties. You can view the list of third-party services we use here. Having subprocessors means we are using technology to access your data. No Loomio human looks at your data for these purposes unless an error occurs that stops an automated process from working and requires manual intervention to fix. These are rare cases and when they happen, we look for root cause solutions as much as possible to avoid them from reoccurring. We also use some other processors for other business functions, which you can view: Company processors.
To help you troubleshoot or squash a software bug or support request. We may need to access your account when you contact us asking for support to resolve a software bug or adminsitative issue.
To investigate, prevent, or take action regarding restricted uses. Accessing a customer’s account when investigating potential abuse is a measure of last resort. We have an obligation to protect the privacy and safety of both our customers and the people reporting issues to us. We do our best to balance those responsibilities throughout the process. If we do discover you are using our products for a restricted purpose, we will report the incident to the appropriate authorities.
When required under applicable law.
Loomio Limited, is a New Zealand registered company, however our data infrastructure are located in the United States, European Union, Australia and New Zealand.
- If law enforcement authorities have the necessary warrant, criminal subpoena, or court order requiring we share or preserve data, we have to comply. Otherwise, we reject requests from local and federal law enforcement when they seek data. And unless we’re legally prevented from it, we’ll always inform you when such requests are made. In the event a government authority outside New Zealand approaches Loomio with a request, our default stance is to refuse unless the New Zealand government compels us to comply through procedures outlined in a mutual legal assistance treaty or agreement.
- If we get an informal request from any person, organization, or entity, we do not assist. If you are an account owner who wants to export data from their accounts, you can do so directly by following these instructions.
- If we are audited by a tax authority, we may be required to share billing-related information. If that happens, we only share the bare minimum needed such as billing addresses and tax exemption information.
As a discussion and decision-making platform, Loomio stores and processes user generated Content; including discussions, comments, proposals, files and images.
We also store and process your “user profile”; including your name, email address, profile photo. This information can make a user personally identifiable, although you can use a pseudonym and anonymous email address to prevent this.
As a member of a Loomio group, your user profile and the content you create or upload to Loomio will be shared with the members of that group. Your email address will only be available to administrators of the group.
Content including your user profile will be public on the internet if you participate in a public discussion or join a public group.
You may view or correct your personal information at any time via the "edit profile" page within Loomio.
You may delete your user account. This will permanently delete your profile information including:
- Your user account including your name, email address, user id and other personally identifying data will be deleted from our systems.
- Comments, proposals and discussions you’ve made will remain but your name will be removed from them.
- You will no longer be listed as a member of any groups.
At Loomio, we apply the same data rights to all customers, regardless of their location. Currently some of the most privacy-forward regulations in place are the European Union’s General Data Protection Regulation (“GDPR”) and California Consumer Privacy Act (“CCPA”) in the US. Loomio recognizes all of the rights granted in these regulations, except as limited by applicable law. These rights include:
- Right of Access. This includes your right to access the personal information we gather about you, and your right to obtain information about the sharing, storage, security and processing of that information.
- Right to Correction. You have the right to request correction of your personal information.
- Right to Erasure / “To be Forgotten”. This is your right to request, subject to certain limitations under applicable law, that your personal information be erased from our possession and, by extension, all of our service providers. Fulfillment of some data deletion requests may prevent you from using Loomio services because our applications may then no longer work. In such cases, a data deletion request may result in closing your account.
- Right to Complain. You have the right to make a complaint regarding our handling of your personal information with the appropriate supervisory authority. To identify your specific authority or find out more about this right, EU individuals should go to https://edpb.europa.eu/about-edpb/board/members_en.
- Right to Restrict Processing. This is your right to request restriction of how and why your personal information is used or processed, including opting out of sale of personal information. (Again: we never have and never will sell your personal data.)
- Right to Object. You have the right, in certain situations, to object to how or why your personal information is processed.
- Right to Portability. You have the right to receive the personal information we have about you and the right to transmit it to another party.
- Right to not be subject to Automated Decision-Making. You have the right to object and prevent any decision that could have a legal, or similarly significant, effect on you from being made solely based on automated processes. This right is limited, however, if the decision is necessary for performance of any contract between you and us, is allowed by applicable law, or is based on your explicit consent.
- Right to Non-Discrimination. This right stems from the CCPA. We do not and will not charge you a different amount to use our products, offer you different discounts, or give you a lower level of customer service because you have exercised your data privacy rights. However, the exercise of certain rights (such as the right “to be forgotten”) may, by virtue of your exercising those rights, prevent you from using our Services.
Many of these rights can be exercised by signing in and directly updating your account information.
If you have questions about exercising these rights or need assistance, please contact us at firstname.lastname@example.org. For requests to delete personal information or know what personal information has been collected, we will first verify your identity using a combination of at least two pieces of information already collected including your user email address. If an authorized agent is corresponding on your behalf, we will first need written consent with a signature from the account holder before proceeding.
If you are in the EU, you can identify your specific authority to file a complaint or find out more about GDPR, at https://edpb.europa.eu/about-edpb/board/members_en.
All data is encrypted via SSL/TLS when transmitted from our servers to your browser. The database backups are also encrypted.
In Loomio most data are not encrypted while they live in our database (since it needs to be ready to send to you when you need it), but we go to great lengths to secure your data at rest. For more information about how we keep your information secure, please review our security overview.
We've designed our deletion policy and the features within Loomio based on our experience of supporting a variety of organizations with differing levels of technical competency and trust.
Our design strives to provide:
- Flexibility. If you write something then want to change or remove it, you can.
- Accountability. If you write something then change it, there is a record of the changes.
- Recovery from mistakes and malicious actions. As an admin you can restore accidentally discarded records, and prevent group members from deleting records they should not delete.
- Safety and confidence. If you need something permanently deleted, you can do that.
When it comes to discussions, comments, polls, votes, files and other records that are not user accounts, we have three functions available:
- Discard will remove the record from view. Discarded records are automatically deleted 90 days after they were discarded.
- Restore can be used to reverse the discard action before the 90 day period has ended, bringing a record back to its normal state.
- Delete will immediately and irreversibly delete a record. When a record is deleted, it cannot be restored.
Our application database has 4 day point-in-time recovery, meaning that 4 days after you delete a record it has been completely removed from our systems and backups.
If you accidentally delete a record, we do not offer recovery from these backups.
If you choose to delete your Loomio user account, we will remove your user profile including your user ID, name, email address, profile photo and other known personally identifying information. However, communication history (such as comments and votes) will be kept to preserve the integrity of discussions and decisions within your groups.
If you wish to have comments or other data deleted from a group that you are not an administrator of, you should contact the group administrator and request deletion of that data.
Data deletion requests may be made to the data protection officer via email (email@example.com). Loomio may delete user data at the request of law enforcement or if personal safety is at risk.
Our products and other web properties are operated in the United States, European Union, Australia and New Zealand. If you are using one of our services located outside of the country you reside, please be aware that any information you provide to us will be transferred to and stored in the location of the regional service. By using our service, participating in any of our services and/or providing us with your information, you consent to this transfer.
The GDPR requires that any data transferred out of the EU must be treated with the same level of protection that the EU privacy laws grant. Loomio has offered a data processing addendum.
We have incorporated a Data Processing Addendum to our Terms of Service that is in effect when the GDPR applies to your use of Loomio Services to process Customer Data as defined in the DPA. The DPA includes the European Commission’s Standard Contractual Clauses (both controller-processor and controller-controller) to extend GDPR privacy principles, rights, and obligations everywhere personal data is processed. The DPA is extensive so to aid our customers, we have provided both a summary of what they mean and how Loomio Limited upholds our responsibilities in our Privacy Regulation Reference. If you prefer to have an executed copy of the Data Processing Addendum, contact us to request a signed DPA with your organization name, and name and email address of the person with authority to sign on behalf of your organization. Regardless of whether you execute or not, we protect and secure your data to the high standards set out in the addendum.
There are also a few ad-hoc cases where EU personal data may be transferred to the US related to Loomio Limited operations. Such transfers are only occasional and transferred under the Article 49(1)(b) derogation under GDPR.
We may update this policy as needed to comply with relevant regulations and reflect any new practices. Whenever we make a significant change to our policies, we will also announce them on our company blog.