LoopPhone Privacy Policy

1. Who we are, and what this Policy covers

   This Privacy Policy explains how LoopDesignLab PTE. LTD. (registration no. 202334183H), 83B Tanjong Pagar Rd, Singapore 088504 (“LoopDesignLab”, “we”), handles personal information on the LoopPhone, under the Protection of Personal Information Act, 2013 (POPIA).

   Important — your network provider handles most of the data. The LoopPhone is supplied with mobile service from your network provider. Most personal information relating to your SIM, subscriber account, network and location is collected to provide that connectivity service and is controlled by your network provider as the responsible party. LoopDesignLab processes it only on your network provider’s behalf (as its operator) and does not use it for its own purposes. For how that data is handled, and for any request about it, please refer to your network provider’s own privacy policy. This includes device and SIM identifiers, signal statistics and data-usage information sent by the LoopPhone app to LoopDesignLab’s servers, which LoopDesignLab processes on your network provider’s behalf to operate the connectivity service. Your network provider may in some cases be a member of the LoopDesignLab group (for example, for Travel eSIM services).

2. What LoopDesignLab handles for its own purposes

   For its own purposes, LoopDesignLab processes only a limited set of information:

   • App diagnostics and crash data, through Google Firebase, to keep the device software stable and secure.
   • Basic device and app settings, stored on the device.
   • A contact card built from the account you sign in with — this stays on the device and is not sent to us.
   • Cached weather for a location you choose.

   We rely on our legitimate interest in providing a stable, secure device. We do not sell your personal information and do not use it for advertising. Separately, and not for our own purposes, the device and SIM identifiers, signal statistics and data-usage information that the LoopPhone app sends to our servers are processed on your network provider’s behalf, as described in section 1 above.

   The personal information provided to us is provided voluntarily. However, if you do not provide certain information or disable relevant permissions, some device features (including connectivity, software stability or location based functionality) may not operate as intended.

3. Location

   Some features use your device’s location to provide the network service (for example, to connect you to the right network). Precise location is collected only when you turn on Troubleshoot Mode (off by default; described in the LoopPhone App Privacy Policy) and is handled as part of the connectivity service described in section 1. You can change this in the device’s settings.

4. Who we share with

   We share information with Google (Firebase), which processes diagnostics data on our behalf, and with your network provider for the connectivity service. We may disclose information where required by law.

5. Storage, transfers and retention

   Our own diagnostics data may be processed by Google outside South Africa under appropriate safeguards. We may transfer your personal information outside of South Africa to countries which provide an adequate level of data protection similar to that of POPIA or where we are satisfied that there is an appropriate justification under POPIA for the transfer such as a binding transfer agreement.

   Data handled for your network provider is stored and transferred by them (including outside South Africa) under their policy. We keep information only as long as necessary for the purpose, then delete or anonymise it.

6. Your rights

   Under POPIA you may ask to access, correct, rectify or delete your personal information, or object to the processing. For information your network provider controls — your SIM, account, network and location data — please contact your network provider. You may also complain to the Information Regulator (South Africa) whose contact details are as follows:

   Woodmead North Office Park
   54 Maxwell Drive
   Woodmead
   Johannesburg
   
   P.O Box 31533
   Braamfontein
   Johannesburg
   2017
   South Africa

   Email address: enquiries@inforegulator.org.za / POPIAComplaints@inforegulator.org.za

7. Children, changes and contact

   The LoopPhone is not intended for children under the age of 18, and we do not knowingly process their information without the required parental consent. We may update this Policy; the current version is on the device and at docs.loopdl.info/loopphone/device/privacy-policy. Legal: legal@loopdl.com.