1. Scope
This Cookie Policy explains how Loop Your Spare Ltd uses cookies and similar technologies on https://loopyourspare.com/. It should be read together with our Privacy Statement.
2. What cookies are
Cookies are small files stored on your browser or device. Similar technologies include pixels, local storage, software development kits and identifiers that can recognise a browser or device, remember preferences, secure services or measure use.
3. Consent
We use strictly necessary cookies without consent where they are required to provide a service you have requested. We do not place or access analytics, advertising or other non-essential technologies on your device unless you have given consent. Our cookie banner gives you equally prominent options to accept or reject non-essential cookies, and you can change your preferences at any time.
4. Cookie categories
Strictly necessary
These support functions such as security, fraud prevention, authentication, load balancing, consent records and preferences you have requested. Disabling them may prevent the website or account area from working.
Analytics
These help us understand aggregate website usage and improve performance. We use Google Analytics, and only after you consent. Depending on configuration, Google may receive information such as page URLs, device and browser information, approximate location derived from your IP address, event data and cookie identifiers.
Functional and marketing
We do not currently use functional cookies that are not strictly necessary, or any marketing or advertising cookies. If we introduce them, we will ask for your consent first and update this Policy.
5. Cookies we use
| Cookie / technology | Provider | Purpose | Category | Duration |
|---|---|---|---|---|
| _ga | Google Analytics | Distinguishes users for analytics | Analytics | Up to 2 years |
| _ga_<container-id> | Google Analytics | Maintains session state | Analytics | Up to 2 years |
| Consent preference cookie | Loop Your Spare / consent management tool | Stores your cookie choices | Strictly necessary | Up to 12 months |
| Authentication / session cookies | Loop Your Spare | Security and account sessions | Strictly necessary | Session |
Cookie names and lifetimes can change with provider configuration. The current, detailed list is always available in the Cookie Settings panel on our website.
6. Google Analytics
Google Analytics is provided by Google Ireland Limited. It processes analytics data on our behalf and may process data outside the European Economic Area, relying on appropriate transfer safeguards. We have entered into Google’s data processing terms and configured the service with privacy controls. The analytics tag does not load until you consent. You can also read Google’s own privacy information.
7. Managing your preferences
You can accept, reject or customise non-essential cookies through the cookie banner. A permanent “Cookie Settings” link in the website footer lets you review or change your choices at any time. Browser controls can also delete or block cookies, but they do not replace your choices in Cookie Settings.
8. Withdrawing consent and consent records
You can withdraw consent at any time through Cookie Settings, as easily as you gave it. Withdrawal does not affect processing carried out before withdrawal. We keep a limited record of your consent choice to remember your preferences and to demonstrate compliance.
9. Updates and contact
We may update this Policy when technologies, providers or legal requirements change. Questions may be sent to contact@loopyourspare.com.
1. About these Terms
These Terms govern access to and use of the public website at https://loopyourspare.com/ (the “Website”). They do not govern access to the Loop Your Spare platform, whether free or paid, which is governed by the Subscription Terms and any order form or customer agreement.
2. Company information
| Legal entity | Loop Your Spare Ltd |
|---|---|
| Registered office | 51 Bracken Road, Sandyford, Dublin 18, Ireland |
| CRO number | 803649 |
| contact@loopyourspare.com | |
| Website | https://loopyourspare.com/ |
3. Acceptance
By accessing or using the Website, you agree to these Terms. If you do not agree, please do not use the Website. If you use the Website on behalf of an organisation, you confirm that you have authority to act for that organisation.
4. Website information
The Website provides general information about our business, technology and services. It is not legal, engineering, environmental, financial or other professional advice. You should obtain appropriate advice before relying on information for a project, regulatory submission or business decision.
5. Sustainability and performance claims
References on the Website to potential cost savings, landfill or recycling costs, waste reduction, carbon savings, environmental impact, regulatory support, commercial value or future performance are illustrative unless expressly stated otherwise. Results depend on project inputs, assumptions, geography, implementation and third-party data, and we do not guarantee any particular outcome. Where we publish figures, we aim to identify the source, date, territory and methodology where reasonably necessary to understand them.
6. Intellectual property
The Website and its content, including text, software, layouts, databases, graphics, photographs, trademarks and logos, are owned by or licensed to Loop Your Spare Ltd and protected by applicable intellectual property laws. You may view and print reasonable extracts for internal, non-commercial evaluation. You may not reproduce, modify, distribute, sell, scrape, frame or commercially exploit the Website or its content without our written permission.
7. Acceptable use
You must not:
- use the Website unlawfully or fraudulently, or to infringe anyone’s rights;
- introduce malware, probe for vulnerabilities, bypass security or gain unauthorised access;
- use automated extraction, scraping or indexing, except with our written permission or as permitted by law;
- interfere with the availability or performance of the Website or with other users; or
- submit content that is unlawful, misleading, defamatory, confidential without authority, or infringing.
8. Enquiries and submissions
Submitting an enquiry or registration request does not oblige us to offer an account, subscription or access to any Service. We may review applications before granting access. Personal data you submit is handled under our Privacy Statement.
9. Third-party services and links
The Website may link to third-party websites or services. Links do not imply endorsement. We are not responsible for third-party content, availability, security or privacy practices.
10. Availability and changes
We may change, suspend or withdraw Website content or functionality. We do not guarantee uninterrupted or error-free availability. We may update these Terms by publishing a revised version with a new date; continued use of the Website after that date means you accept the updated Terms.
11. Liability
Nothing in these Terms excludes or limits liability that cannot lawfully be excluded or limited, including liability for fraud or fraudulent misrepresentation, or for death or personal injury caused by negligence. Subject to that, and to the fullest extent permitted by law, the Website is provided on an “as available” basis and Loop Your Spare Ltd is not liable for indirect or consequential loss, or for loss of profit, revenue, opportunity, goodwill, anticipated savings or data arising from use of, or reliance on, the Website.
12. Governing law
These Terms are governed by Irish law. The Irish courts have exclusive jurisdiction, except that where mandatory law gives a consumer the right to bring proceedings elsewhere, that right is unaffected. The Website is intended primarily for business users.
13. Contact
Questions about these Terms may be sent to contact@loopyourspare.com.
These Subscription Terms are written for business customers. The Service is offered only to persons acting for the purposes of a trade, business, craft or profession. We do not knowingly contract with consumers. If a person is nevertheless a consumer, mandatory consumer rights apply and cannot be excluded.
1. Parties and contract documents
These Terms govern access to the Loop Your Spare software platform and related services (the “Service”) supplied by Loop Your Spare Ltd to the business or organisation identified during signup, checkout or in an order form (the “Customer”). The contract consists of: (a) the applicable order form or online checkout; (b) these Terms; (c) the Data Processing Agreement, which forms part of the contract (the “DPA”); and (d) any service description or plan limits expressly incorporated at purchase.
If these documents conflict: on data protection matters, the DPA prevails; otherwise, an individually signed order form prevails over these Terms. Our Privacy Statement is an information notice about how we handle personal data where we act as controller. It is not a term of the contract.
2. Eligibility and authority
The Customer must be legally capable of entering into a contract. The person creating an account or purchasing a plan confirms that (a) they are acting for a trade, business, craft or profession and not as a consumer, (b) they are authorised to bind the Customer, and (c) all signup and billing information is accurate. Submitting a registration or subscription request does not guarantee acceptance.
3. Plans
3.1 Free Plan
The Free Plan may provide limited users, storage, projects, functionality, support or usage. It is provided without subscription fees, but the Customer remains bound by these Terms. We may change or discontinue the Free Plan on at least 30 days’ notice, during which the Customer may export its data under clause 26. The Free Plan is not a free trial and does not become a paid plan unless the Customer actively selects a paid plan and authorises payment.
3.2 Pro and Enterprise Plans
Pro and Enterprise features, user limits, support, storage and pricing are shown at checkout or in an order form. Enterprise features may also be subject to a negotiated order form, implementation statement or service level agreement.
3.3 Monthly and annual billing
Paid plans may be purchased monthly or annually. The billing cycle selected at checkout applies until changed or cancelled. Annual subscriptions are billed for the full annual term unless an order form states otherwise.
4. Orders and activation
An online order is an offer to purchase the selected Service. The contract begins when we send an acceptance or activate the paid plan. We may refuse an order for legitimate reasons, including pricing error, suspected fraud, legal restrictions or resource limitations, and will refund any amount paid for an order we do not accept. We may review requests before creating an account and may request additional information before granting access. Access credentials may be issued separately following approval.
5. Prices, taxes and payment
Prices and currency are displayed before purchase. Prices exclude applicable taxes unless stated otherwise, and any taxes payable will be charged as required by law. The Customer must provide accurate billing and tax information and pay charges when due.
We may change subscription prices. A price change applies only from the next renewal and only after we have given the Customer at least 30 days’ written notice before that renewal. If the Customer does not accept the change, it may cancel before the renewal date and the new price will not apply.
Payments are processed by Stripe Payments Europe, Limited (“Stripe”), which collects and processes card and payment details under its own terms and privacy notice. We do not store full card numbers or security codes. The Customer authorises recurring charges for each renewal until cancellation.
6. Automatic renewal
Unless cancelled before the renewal date, a paid subscription renews automatically for a further period equal to the current billing cycle, and the Customer’s payment method is charged the then-current price. The renewal frequency, the price (or how it is calculated) and the cancellation method are shown at checkout before purchase. For annual subscriptions, we will send a reminder at least 14 days before renewal.
7. Cancellation and refunds
The Customer may cancel through its account settings, where available, or by emailing contact@loopyourspare.com. Cancellation takes effect at the end of the current paid billing period unless we state otherwise, and access normally continues until then.
Except where required by law or expressly stated in an order form, fees already paid are non-refundable and unused time is not credited. If we materially breach the contract and do not remedy the breach within a reasonable period after written notice, the Customer may terminate and receive a pro-rata refund for prepaid, unused Service after the effective termination date. If we discontinue a paid Service without offering a substantially equivalent replacement, we will give a pro-rata refund for prepaid, unused time. The Customer’s rights to switch provider and to export data are set out in clause 26.
8. Payment failure
If payment fails or becomes overdue, we may retry the payment, contact the billing administrator, restrict paid functionality, or suspend access after reasonable notice. The Customer remains liable for amounts due. We may charge interest and recover reasonable costs on overdue business debts as permitted by the European Communities (Late Payment in Commercial Transactions) Regulations 2012.
9. Customer accounts and administrators
The Customer is responsible for its authorised users, account configuration, user permissions and credential security. Users must not share individual credentials. The Customer must promptly disable access for departed or unauthorised users and notify us of suspected compromise.
10. Licence and permitted use
During the subscription term, we grant the Customer a limited, non-exclusive, non-transferable, revocable right for its authorised users to access and use the Service for the Customer’s internal business operations, subject to the selected plan and these Terms. No ownership rights are transferred.
11. Restrictions
The Customer must not, and must not allow others to:
- resell, sublicense or make the Service available to third parties other than authorised users;
- copy, modify, reverse engineer, decompile or attempt to discover the source code, except to the extent this restriction is prohibited by law;
- bypass limits, security or access controls;
- upload malware, unlawful content, or data without appropriate rights and notices;
- use the Service to develop or benchmark a competing product for publication without our written permission; or
- use automated means that materially burden the Service.
12. Customer Data
As between the parties, the Customer retains all rights in the data, content, images and records it submits to the Service (“Customer Data”). The Customer grants Loop Your Spare a non-exclusive right to host, copy, process, transmit and display Customer Data only as necessary to provide, secure and support the Service and to comply with law. We do not use Customer Data that contains personal data to train AI models for other customers or for general-purpose use. We may improve the Service using usage and diagnostic data and aggregated or anonymised information as described in clause 14.
The Customer is responsible for the legality, accuracy and quality of Customer Data, for obtaining necessary notices and permissions, and for avoiding unnecessary personal or confidential information. The Customer must not upload special-category personal data or highly sensitive information unless expressly agreed and appropriately protected.
13. Listings and platform content
The Customer is responsible for the material listings, descriptions, images and other content it publishes through the Service, including their accuracy, its right to offer the materials, and compliance with applicable law (including waste, health and safety and environmental requirements). Listings must not offer unlawful, hazardous or misdescribed materials.
Unless an order form says otherwise, Loop Your Spare provides the technology that lets Customers list, find and manage materials. We are not a party to any arrangement between Customers for the transfer or reuse of materials, and we do not verify listings or guarantee their quality, availability or legality.
We may remove or restrict content or access where we reasonably believe content is unlawful or breaches these Terms. Where we do so, we will tell the affected Customer the reasons, unless the law prevents us, and the Customer may contest the decision by emailing contact@loopyourspare.com. Anyone who believes content on the Service is illegal can report it to contact@loopyourspare.com, explaining why, identifying the content (including its location on the Service), and giving their name and email address. We will review reports promptly and diligently.
14. Aggregated and anonymised data
We may generate statistics and insights from use of the Service that do not identify the Customer or any individual. We may use and disclose genuinely aggregated or anonymised information for analytics, benchmarking, sustainability reporting, product development and industry insights. We will not present identifiable Customer information as community reporting without permission or another lawful basis.
15. Data protection
Each party will comply with applicable data protection law. Where we act as controller (for example, for account, billing and usage data), our Privacy Statement applies. Where we process personal data contained in Customer Data on the Customer’s behalf, the DPA applies, the Customer is the controller (or, where it acts on behalf of another, a processor) and we are its processor. The Customer must ensure that it has a lawful basis for the personal data it submits, that it gives all required notices, and that it responds to individuals where it acts as controller.
16. Security and incidents
We maintain technical and organisational security measures appropriate to the risk, as described in the DPA. The Customer acknowledges that no online service is completely secure. We will notify the Customer without undue delay after becoming aware of a personal data breach affecting Customer Data, as set out in the DPA.
17. Third-party services and integrations
The Customer may choose to use integrations or third-party services, and their use is governed by the third party’s terms. We are not responsible for third-party services outside our control. We may replace sub-processors or infrastructure providers, subject to the DPA.
18. AI-assisted functionality
The Service may include automated or AI-assisted features. Outputs may be incomplete, inaccurate or unsuitable for a particular use. The Customer must apply appropriate human review and remains responsible for project, safety, environmental, financial, procurement and compliance decisions. AI features do not constitute professional advice or a guarantee of compliance or savings.
19. Support, maintenance and changes
Support for each plan is described at purchase. We may perform maintenance and update or improve the Service. We may change features where reasonably necessary for security, law, technology or product development. We will use reasonable efforts to avoid materially reducing core paid functionality during a current paid term without notice or an appropriate remedy.
20. Intellectual property and feedback
Loop Your Spare and its licensors own the Service, software, documentation, designs, trademarks, models, methods and improvements, excluding Customer Data. If the Customer provides feedback, the Customer grants us a worldwide, perpetual, irrevocable, royalty-free right to use it without identifying the Customer.
21. Confidentiality
Each party may receive non-public information that a reasonable person would understand to be confidential. The receiving party will use it only for the purposes of the contract, protect it with reasonable care, and disclose it only to personnel and advisers who need to know it and are bound by confidentiality. This does not apply to information that is public without breach, already lawfully known, independently developed or lawfully received from another source. Disclosures required by law may be made, after notice to the other party where lawful.
22. Warranties
We warrant that we will provide paid Services with reasonable care and skill. If we breach this warranty, the Customer must notify us with sufficient detail, and our primary obligation is to re-perform or correct the affected Service within a reasonable period. Except as expressly stated, and to the fullest extent permitted by law, the Service is provided “as is” and we do not warrant uninterrupted availability, error-free operation, or that estimates, matches, forecasts or reports will achieve a particular result.
23. Liability
Nothing in the contract excludes or limits liability for fraud, fraudulent misrepresentation, death or personal injury caused by negligence, or any other liability that cannot lawfully be excluded or limited. Subject to that:
- neither party is liable for indirect or consequential loss, or for loss of profit, revenue, savings, opportunity, goodwill or anticipated benefit;
- Loop Your Spare is not liable for decisions made from Customer Data, estimates, third-party information or AI-assisted output, or for use contrary to the documentation;
- for paid Services, Loop Your Spare’s aggregate liability arising in any 12-month period will not exceed the fees paid or payable by the Customer for the affected Service in that period; and
- for the Free Plan, Loop Your Spare’s aggregate liability will not exceed EUR 100.
These limits also apply to liability under the DPA. They do not limit the Customer’s obligation to pay fees, and they do not reduce rights that cannot lawfully be limited. Nothing in this clause is intended to prevent a data subject from exercising their rights directly against either party.
24. Suspension
We may suspend access where reasonably necessary to address a security threat, unlawful use, material breach, non-payment, a legal requirement, or a risk to the Service or other users. Where practicable, we will give notice and an opportunity to remedy, and we will limit suspension to what is reasonably necessary.
25. Termination
Either party may terminate the contract for material breach not remedied within 30 days after written notice, or immediately where the breach cannot be remedied, the other party becomes insolvent, or law requires termination. We may terminate a Free Plan on notice under clause 3.1. On termination, access ends (subject to clause 26) and outstanding fees become due.
26. Switching, data export and deletion
Right to switch. The Customer may at any time ask to switch to another provider of data processing services or to its own systems, by giving us written notice of up to two months. That is the maximum notice we require to start switching. The Customer’s paid-term and fee commitments under clauses 5 to 7 continue to apply for the term it has purchased.
Transition. From the date of the switching notice, we will continue to provide the Service for a transitional period of up to 30 days (or longer, if technically unfeasible within 30 days and we tell the Customer why), and we will give reasonable assistance, information and support to help the Customer complete the switch securely.
What can be exported. The Customer may export all Customer Data (listings, project, site and organisation records, images, notes, and impact and reporting data) together with associated metadata, in a structured, commonly used and machine-readable format such as CSV or JSON, using the export functions in the Service or on request to contact@loopyourspare.com. We do not charge switching or data-export charges.
Retrieval period and deletion. After the transitional period ends, or after termination or expiry for any other reason, the Customer may retrieve its data for at least 30 days. After that period we will delete Customer Data, subject to backup rotation, retention required by law, and security records, in line with the DPA. Account deletion requests from individual users are handled under the Account Deletion Policy and the Privacy Statement.
27. Notices
Operational notices may be sent in the Service or by email. Legal notices to Loop Your Spare must be sent to contact@loopyourspare.com and should identify the Customer and the nature of the notice. Notices to the Customer may be sent to the account or billing email and are deemed received when sent, unless delivery fails.
28. Changes to these Terms
We may update these Terms for legal, security, technical or business reasons. We will give advance notice of material changes that affect a current paid term. If a change materially disadvantages the Customer, the Customer may cancel before the change takes effect. Changes required by law or by urgent security needs may take effect sooner.
29. General
Neither party may assign the contract without the other’s consent, except that Loop Your Spare may assign it as part of a merger, reorganisation, sale of business or group restructuring. Neither party is liable for delay caused by events beyond its reasonable control, except for payment obligations. A failure to enforce a right is not a waiver. If a provision is unenforceable, the rest continues. The contract is the entire agreement about its subject matter. No third party has rights under it unless expressly stated.
30. Governing law and disputes
The contract is governed by Irish law, and the Irish courts have exclusive jurisdiction. Before starting formal proceedings, the parties will try in good faith to resolve the dispute through authorised representatives. Mandatory consumer rights, if applicable, remain unaffected.
31. Contact
Loop Your Spare Ltd, 51 Bracken Road, Sandyford, Dublin 18, Ireland. CRO 803649. Email: contact@loopyourspare.com.
This Data Processing Agreement (“DPA”) forms part of the contract between Loop Your Spare Ltd (“Processor”, “LYS”, “we”) and the Customer (“Controller”) under the Subscription Terms. It takes effect when the Customer accepts the Subscription Terms, and no separate signature is needed unless the Customer asks for a signed copy. It applies where we process personal data on the Customer’s behalf in providing the Service, as required by Article 28 of the General Data Protection Regulation (EU) 2016/679 (“GDPR”).
1. Definitions
“Customer Personal Data” means personal data contained in Customer Data that we process on the Customer’s behalf. “Data Protection Law” means the GDPR, the Irish Data Protection Act 2018 and any other applicable data protection law. “Sub-processor” means a third party we engage to process Customer Personal Data. Terms such as “controller”, “processor”, “personal data”, “personal data breach”, “processing” and “data subject” have the meanings given in the GDPR.
2. Roles and scope
2.1 For Customer Personal Data, the Customer is the controller (or, where it acts on behalf of another controller, a processor) and Loop Your Spare is the processor (or sub-processor). Annex 1 sets out the subject matter, duration, nature and purpose of the processing, the types of personal data and the categories of data subjects.
2.2 Where we act as a controller of personal data (for example, account administration, billing, security and service usage data), this DPA does not apply and our Privacy Statement does.
3. Processing on instructions
3.1 We will process Customer Personal Data only on the Customer’s documented instructions, including with regard to transfers to a third country. The Subscription Terms, this DPA and the Customer’s use of the Service’s features are the Customer’s complete instructions at the start of the contract. Further instructions must be reasonable and given in writing.
3.2 We may process Customer Personal Data where required by EU or Irish law. In that case we will tell the Customer before the processing, unless the law prohibits us from doing so.
3.3 We will tell the Customer if, in our opinion, an instruction infringes Data Protection Law.
3.4 The Customer is responsible for ensuring that it has a lawful basis for its instructions and for the personal data it submits, and that it has given all necessary notices.
4. Confidentiality
We will ensure that everyone we authorise to process Customer Personal Data is bound by an appropriate duty of confidentiality and processes it only as needed to provide the Service.
5. Security
We will implement technical and organisational measures appropriate to the risk, as required by Article 32 GDPR. Our current measures are summarised in Annex 2. We may update them, provided the overall level of security is not reduced.
6. Sub-processors
6.1 The Customer gives us general written authorisation to engage Sub-processors. We will provide a list of current Sub-processors on request at contact@loopyourspare.com.
6.2 We will give the Customer at least 30 days’ notice (by email or in the Service) before adding or replacing a Sub-processor. The Customer may object on reasonable data protection grounds within that period. If we cannot resolve the objection, the Customer may terminate the affected Service and receive a pro-rata refund of prepaid, unused fees.
6.3 We will impose on each Sub-processor data protection obligations no less protective than those in this DPA, and we remain responsible for their performance.
7. International transfers
We will transfer Customer Personal Data outside the European Economic Area only where a lawful transfer mechanism under Chapter V GDPR is in place, such as an adequacy decision or the European Commission’s Standard Contractual Clauses, with supplementary measures where required.
8. Assistance
8.1 Taking into account the nature of the processing, we will help the Customer, by appropriate technical and organisational measures, to respond to requests from data subjects. If a data subject contacts us directly about Customer Personal Data, we will redirect them to the Customer where we can identify the Customer, and we will not respond ourselves except to acknowledge the request.
8.2 We will help the Customer to comply with its obligations under Articles 32 to 36 GDPR (security, breach notification, data protection impact assessments and prior consultation), taking into account the nature of the processing and the information available to us.
9. Personal data breaches
We will notify the Customer without undue delay after becoming aware of a personal data breach affecting Customer Personal Data. The notice will describe, as far as we know, the nature of the breach, the categories and approximate number of data subjects and records, the likely consequences and the measures taken or proposed, and we will provide further information as it becomes available. We will cooperate with the Customer to investigate and mitigate the breach.
10. Audits and information
We will make available to the Customer the information necessary to demonstrate compliance with this DPA and Article 28 GDPR. We will allow and contribute to audits, including inspections, conducted by the Customer or an auditor it appoints, no more than once in any 12 months (unless required by a regulator or following a personal data breach), on at least 30 days’ written notice, during business hours, subject to reasonable confidentiality terms and without unreasonable disruption to our business. The Customer bears the cost of any audit.
11. Return and deletion
At the end of the Service, or earlier on the Customer’s written request, we will make Customer Personal Data available for export under clause 26 of the Subscription Terms and then delete it, unless EU or Irish law requires us to keep it. Copies in backups are deleted in the normal backup rotation and are isolated from ordinary use until then.
12. Liability
Each party’s liability under this DPA is subject to the limits and exclusions in clause 23 of the Subscription Terms, except where the law does not allow it, and without affecting the rights of data subjects.
13. Term, order of precedence and governing law
This DPA lasts for as long as we process Customer Personal Data. On data protection matters it prevails over the Subscription Terms and any order form. It is governed by Irish law, and the Irish courts have exclusive jurisdiction.
Annex 1: Details of processing
| Item | Description |
|---|---|
| Subject matter | Provision of the Loop Your Spare software platform and related services to the Customer. |
| Duration | The term of the contract and any retrieval period under clause 26 of the Subscription Terms, until deletion. |
| Nature of processing | Hosting, storage, retrieval, display, transmission, backup, deletion and support of Customer Data. |
| Purpose | To provide, secure and support the Service, and to carry out the Customer’s instructions. |
| Types of personal data | Names, business contact details and roles of the Customer’s users and contacts; account identifiers; images, notes, locations and records in listings and projects that identify or relate to individuals; user activity records. |
| Categories of data subjects | The Customer’s employees, contractors and authorised users; individuals who appear in or are named in content the Customer uploads; contacts at the Customer’s counterparties. |
| Special categories of data | None. The Customer must not upload special-category personal data unless agreed in writing. |
Annex 2: Technical and organisational measures
- Access control: role-based access, least-privilege principles, and access limited to personnel who need it.
- Authentication: strong password policy, hashed password storage and multi-factor authentication for the platform and internal systems.
- Encryption: encryption in transit (TLS) and encryption at rest where appropriate.
- Logging and monitoring: logging of security-relevant events and significant user actions, and monitoring for misuse.
- Backups and resilience: regular backups and recovery procedures.
- Vulnerability management: timely patching and vulnerability management.
- Personnel: confidentiality obligations and security awareness for staff.
- Sub-processors: data protection terms with every Sub-processor and due diligence before engagement.
- Incident response: procedures for identifying, escalating and responding to security incidents and personal data breaches.
- Deletion: secure deletion or anonymisation of data when no longer needed.
Annex 3: Sub-processors
We use Sub-processors in the following categories: cloud hosting and storage; database and authentication services; email and communications services; and customer support tools. A current list, with names and processing locations, is available on request at contact@loopyourspare.com.