We take your privacy very serious.

Privacy Policy

 

Welcome to Luep, the online and mobile service of Squirrel Technologies, LLC (“Luep,” “we,” or “us”). Our Privacy Policy explains how we collect, use, disclose, and protect information that applies to our Service, and your choices about the collection and use of your information.

If you have any questions about this Privacy Policy or the Service, please contact us at any time at dataprivacy@isquirrel.com.

For the purposes of EU data protection laws (“Data Protection Legislation”), Luep is the data controller (i.e. the company which is responsible for, and controls the processing of, your personal data).

What Information We Collect From You: Information you provide us directly: We ask for certain information such as your username, first and last name, phone number and email address when you register for a Luep account or if you correspond with us. We may also retain any messages you send through the Service, and may collect User Content you post to the Service. User Content can be made publicly available if you choose to do so.

Inviting a contact to use Luep from the “Add Contacts” feature: If you choose to use our invitation service to invite a third party to the Service through our “Invite friends” feature, we may access and collect information from your address book available on your mobile device and/or your email account, with your permission, in order to find your contacts on the Service. You understand that by inviting a contact to Luep through the “Invite friends” feature, you are directly sending a text or email from your personal accounts. In addition, you understand and agree that normal carrier charges apply to communications sent from your phone. Since this invitation is coming directly from your email or phone, we do not have access to or control this communication.

Adding Contacts on the Service: If you choose, you can find people you know with Luep accounts through our “Add Contacts” feature or by searching names and usernames on Luep. The “Add Contacts” feature may allow you to choose to find contacts either through your address book or through a search of names and usernames on Luep. If you choose to add your contacts through your address book, then you agree to provide Luep access to your address book such that we can regularly perform the search necessary to determine whether or not someone associated with the information you provide (including new contacts as you add them) is using Luep. If you choose to add your contacts through a search of names or usernames then simply type a name to search and see if that name or username appears on our Service.

Information we may receive from third parties: We may receive information about you from third parties. For example, by “following,” “liking,” adding the Luep application, linking your account to the Luep Service, etc., a third party may pass certain information about your use of its service to Luep. This information could include, but is not limited to, the user ID associated with your account (for example, your Facebook UID), an access token necessary to access that service, any information that you have permitted the third party to share with us, and any information you have made public in connection with that service. If you allow us access to your address book, your contacts’ user IDs, and your connection to those contacts, may be used and stored to make your experience more social, and to allow you to add your contacts on the Service as well as provide you with updates if and when your contacts join Luep. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to the Luep Service. You may also unlink your third party account from the Service by adjusting your settings on the third party service. If you unlink your third party account, we will remove the information collected about you in connection with that service.

How Do We Use the Information We Collect: We use this information to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages and push notifications, to allow you to find others and have others find you on the Service, and to permit you to share content with others on the Service. Where you have given consent for us to use your personal data to provide certain Services, you may withdraw your consent for some uses of the data at any time by contacting us at dataprivacy@isquirrel.com.

Legal basis for processing in the EU:

In the EU, the purposes for which we process your personal data are:

1. Where we need to perform the contract we are about to enter into or have entered into with you for the Service;

2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and

3. Where we need to comply with a legal or regulatory obligation in the EU.

We have set out in the table at Annex 1 and Annex 2 a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. Please contact us using the details above if you need information about the specific legal basis we are relying on to process your personal data where more than one legal basis has been set out.

Use of Cookies and Other Technology to Collect Information: We, and our third party partners, automatically collect certain types of usage information when you visit our website or use our Service, read our emails, or otherwise engage with us. When you visit the Service, we may send one or more cookies — a small text file containing a string of alphanumeric characters — to your computer that uniquely identifies your browser and lets us help you log in faster and enhance your navigation through the site. A cookie may also convey information to us about how you use the Service (e.g., the pages you view, the links you click, how frequently you access the Service, and other actions you take on the Service), and allow us to track your usage of the Service over time. We may collect log file information from your browser or mobile device each time you access the Service. Log file information may include anonymous information such as your web request, Internet Protocol (“IP”) address, browser type, information about your mobile device, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information. We may also collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Service. These tools collect information sent by your browser or mobile device, including the pages you visit, your use of third party applications, and other information that assists us in analyzing and improving the Service. When you access our Service by or through a mobile device, we may receive or collect and store a unique identification number associated with your device (“Device ID”), mobile carrier, device type and manufacturer, phone number, and location data (e.g., city and state) of your mobile device. We use or may use the data collected through cookies, log file, device identifiers, location data and clear gifs information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information; (c) provide and monitor the effectiveness of our Service; (d) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website and our Service; (e) diagnose or fix technology problems; (f) otherwise to plan for and enhance our Service; and (g) automatically update the Luep application on your mobile devices.

Sharing of Your Information: Remember, our Service allows you to connect with others and share information about yourself with other individuals. Your profile information, including your name, photo and other personal information you include in your bio, will be available publicly to other members of the Service by default. In addition, any User Content that you upload to the Service can be made publicly available if you choose to do so. Consider your own privacy and personal safety when logging in to our Service and sharing your information with anyone. Luep never shares your phone number and email address with other users on the Service without your consent.

We may also share your personal information with third parties who we require to operate, maintain and provide the features and functionalities of Service. Examples of these necessary third parties include:

• Other companies owned by or under common ownership as Luep, which also includes our subsidiaries (i.e., any organization we own or control).

• Third party vendors, consultants and other service providers that perform services on our behalf, in order to carry out their work for us which may include providing payment, mailing or email services, tax and accounting services, data enhancement services, fraud prevention services, web hosting, and/or analytic services, email server services (to send messages to users), product development services and identity verification services.

• The public and other members of the Service at your request. Any information or content that you voluntarily disclose for posting to the Service, such as User Content, becomes available to the public, as controlled by any applicable privacy settings. To change your privacy settings on the Service, please change your profile setting. Subject to your profile and privacy settings, any User Content that you make public is searchable by other Users. If you remove information that you posted to the Service, copies may remain viewable in cached and archived pages of the Service, or if other Users have copied or saved that information; and

• With other members of the Service so that you can be “found” on the Service. When other members of the Service attempt to “Add Contacts” on the Service using their address book or by name search or user ID, we will identify you as an existing member of the Service if your contact information is in your friend’s address book. Similarly, we will let you know which of your contacts in your address book are already members of the Service based on the contact information associated with the member’s account.

When we grant these necessary third parties access to your personal information, we require that they use your personal information solely in accordance with the rights granted to us and restrictions placed on us in this Privacy Policy.

We may also share your information with other parties in connection with any company transaction, such as a merger, sale of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party or in the event of bankruptcy or related or similar proceedings.

We may also share your information with third parties as required to (i) satisfy any applicable law, regulation, subpoena/court order, legal process or other government request (at the discretion of Luep), (ii) enforce our Terms of Use, including the investigation of potential violations thereof, (iii) investigate and defend ourselves against any third party claims or allegations, (iv) protect against harm to the rights, property or safety of Luep, its users or the public as required or permitted by law and (v) detect, prevent or otherwise address criminal (including fraud or stalking), security or technical issues.

How We Store and Process Your Information: Storage and Processing: Your information collected through the Service may be stored and processed in the United States, or any other country in which Luep or its subsidiaries, affiliates or service providers maintain facilities. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and we will take all steps reasonably necessary to ensure that any personal data are treated securely and in accordance with this Privacy Policy. Such transfers are made pursuant to appropriate safeguards.

How We Protect Your Information: Keeping your information safe: Luep cares about the security of your information, and uses commercially reasonable safeguards to preserve the integrity and security of all information collected through the Service. To protect your privacy and security, we take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from Luep, at all times. However, Luep cannot ensure or warrant the security of any information you transmit to Luep or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed. Luep is not responsible for the functionality or security measures of any third party.

Compromise of information: In the event that any information under our control is compromised as a result of a breach of security, Luep will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

Your Choices About Your Information: Commercial and marketing communications: We use the information we collect or receive to communicate directly with you. We may send you emails containing newsletters, promotions and special offers. If you do not want to receive such email messages, you will be given the option to opt out or change your preferences. We also use your information to send you Service-related emails (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, technical and security notices). You may not opt out of Service-related emails. You will also be able to be “found” on Luep based on information that you provide (see “Adding Contacts on the Service”) above.

You control your account information and settings: You may update your account information at any time by logging into your account and changing your settings. You can also stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. As noted above, you may not opt out of Service-related communications (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, technical and security notices). If you have any questions about reviewing or modifying your account information, you can contact us directly at dataprivacy@isquirrel.com.

Opting out: The only way to completely opt out of the collection of any information through cookies or other tracking technology is to actively manage the settings on your browser or mobile device. Please refer to your mobile device or browser’s technical information for instructions on how to delete and disable cookies, and other tracking/recording tools. (To learn more about cookies, clear gifs/web beacons and related technologies, you may wish to visit http://www.allaboutcookies.org and/or the Network Advertising Initiative’s online resources, located at http://www.networkadvertising.org ). Depending on your type of device, it may not be possible to delete or disable tracking mechanisms on your mobile device. Note that disabling cookies and/or other tracking tools prevents Luep or its business partners from tracking your browser’s activities in relation to the Service. However, doing so may disable many of the features available through the Service. If you have any questions about opting out of the collection of cookies and other tracking/recording tools, you can contact us directly at support@isquirrel.com.

Your rights in respect of your personal information if you are resident in the EU and Switzerland: If you are located in the EU or Switzerland, you have the following rights in respect of your personal data that we hold:

a) Right of access. The right to obtain access to your personal data.

b) Right to rectification. The right to obtain rectification of your personal data without undue delay where that personal data is inaccurate or incomplete.

c) Right to erasure. The right to obtain the erasure of your personal data without undue delay in certain circumstances, such as where the personal data is no longer necessary in relation to the purposes for which it was collected or processed.

d) Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal data in certain circumstances, such as where the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of that personal data.

e) Right to portability. The right to portability allows you to move, copy or transfer personal data easily from one organization to another.

f) Right to object. You have a right to object to processing based on legitimate interests and direct marketing.

g) Right to withdraw consent. You should be aware that you are entitled to withdraw your consent where that has been given, at any time. If you do this and we have no alternative lawful reason to process your personal data, this may affect our ability to provide you with rights to use the Service.

If you wish to exercise one of these rights, please contact us at dataprivacy@isquirrel.com.

You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm

How Long Does Luep Keep Information About Me: Following termination or deactivation of your User account, Luep may retain your profile information and User Content for a commercially reasonable time for backup, archival, or audit purposes.

For individuals based in the EU or Switzerland, we store personal data for as long as necessary to fulfill the purposes for which we collect the data (see above under “WHAT INFORMATION DO WE COLLECT FROM YOU?”), except if required otherwise by law.

“Do Not Track Signals”: Although we do our best to honor the privacy preferences of our customers, we are not able to respond to Do-Not-Track signals from your browser at this time. As discussed above, we track website usage information through the use of cookies for analytic and internal purposes only. Because we do not collect this information to track you across websites over time, your selection of the “Do Not Track” option provided by your browser will not have any effect on our collection of cookie information for analytics or internal purposes.

Links to Other Web Sites and Services: We are not responsible for the practices employed by websites or services linked to or from the Service, including the information or content contained therein. Please remember that when you use a link to go from the Service to another website, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party’s own rules and policies. In addition, you agree that we are not responsible for and we do not have any control over any third-parties that you authorize to access your User Content. If you are using a third-party website or service (like Facebook) and you allow such a third-party access to your User Content you do so at your own risk. This Privacy Policy does not apply to information we collect by other means (including offline) or from other sources other than through the Service.

Changes to our Privacy Policy: Luep may modify or update this Privacy Policy from time to time to reflect the changes in our business and practices, and so you should review this page periodically. When we change the policy in a material manner we will let you know and update the ‘last modified’ date at the bottom of this page.

This Privacy Policy was last modified on January 15, 2021 .

Annex 1

Personal information we may collect when you use the service.

Annex 2

Personal information collected automatically