Loop Callout — Privacy & Data Retention Policy

Loop Callout operates a technology-enabled referral marketplace that helps customers connect with independent trade and service providers.

In providing the platform, Loop may collect and process information relating to:

• customers;
• service requests;
• service locations;
• providers;
• marketplace activity;
• communications; and
• platform usage.

This Policy should be read together with Loop Callout's Terms of Service and Tradesperson Service Agreement, where applicable.

The information Loop collects depends on how you use the platform.

Loop may collect personal information:

• directly from you;
• when you submit a service request;
• when you create or maintain a provider account;
• when you upload photographs or other information;
• when you contact Loop;
• when you accept a marketplace opportunity;
• when you make a payment to Loop as a provider;
• when you provide feedback or submit a complaint;
• automatically when you use the website or platform;
• from publicly available business or licensing registers;
• from identity, licence or insurance verification sources;
• from a customer or provider where information is reasonably necessary to operate the marketplace; and
• from service providers that assist Loop with platform operation.

Where reasonable and practicable, Loop will collect personal information directly from the individual concerned.

Loop may collect, hold, use and disclose personal information for purposes including:

• providing and operating the Loop marketplace;
• processing customer service requests;
• qualifying and categorising requests;
• identifying potentially suitable providers;
• facilitating customer-provider introductions;
• communicating about requests;
• managing provider accounts;
• verifying provider information;
• processing provider opportunity fees;
• maintaining marketplace security;
• detecting fraud or misuse;
• managing complaints and disputes;
• monitoring marketplace quality;
• improving matching and platform functionality;
• analysing demand and service availability;
• providing customer or provider support;
• sending operational notifications;
• maintaining business and legal records;
• complying with legal and regulatory obligations;
• enforcing Loop's Terms and provider agreements; and
• protecting the rights, safety and security of Loop, its users and others.

Loop may also use de-identified or aggregated information for:

• analytics;
• marketplace planning;
• product development;
• research;
• performance measurement; and
• business strategy,

provided the information is no longer reasonably identifiable as relating to a particular individual.

Loop may use artificial intelligence and other automated tools to assist with platform functions.

These systems may use information provided by customers or providers to:

• categorise requests;
• identify the likely trade required;
• summarise service descriptions;
• identify missing information;
• suggest urgency;
• identify potentially suitable providers;
• assist marketplace matching;
• detect unusual activity; and
• assist internal marketplace administration.

AI-assisted outputs are used to support platform operations.

They are not a substitute for professional trade or safety assessment.

Where appropriate, Loop may allow automated outputs to be reviewed or overridden by a person.

Loop will aim to collect and use only the information reasonably necessary for the relevant automated process.

To facilitate a service request, Loop may share relevant information with providers.

Depending on the stage of the request, this may include:

• general job description;
• trade category;
• suburb or service area;
• urgency;
• preferred availability;
• photographs;
• relevant access information; and
• customer contact details.

Loop may limit the amount of identifying information disclosed before a provider accepts an opportunity.

Once an appropriate provider accepts a request, Loop may disclose information reasonably necessary for the provider and customer to communicate and arrange the service.

Providers must use customer information only for legitimate purposes connected with the relevant service and in accordance with their agreement with Loop and applicable law.

Loop may display or disclose information about participating providers, including:

• name or trading name;
• profile information;
• trade category;
• service area;
• verification status;
• relevant licence or registration information;
• marketplace information; and
• contact information where appropriate.

Loop will not knowingly publish information that is unnecessary for operation of the marketplace.

Loop may disclose personal information to service providers that assist with functions such as:

• cloud hosting;
• database infrastructure;
• authentication;
• email;
• SMS or other communications;
• artificial intelligence;
• analytics;
• payments;
• fraud prevention;
• customer support;
• identity verification;
• licence or business verification;
• cybersecurity; and
• professional advisers.

Loop may also disclose information where:

• required or authorised by law;
• required by a court, tribunal or regulator;
• reasonably necessary to investigate fraud or serious misuse;
• reasonably necessary to protect a person's safety;
• necessary to establish, exercise or defend legal rights; or
• connected with a business restructure, acquisition or sale, subject to applicable privacy requirements.

Some technology providers used by Loop may process or store information outside Australia.

This may include cloud, communications, AI, analytics or other technology providers.

Where personal information may be disclosed overseas, Loop will take steps required by applicable Australian privacy law.

Loop does not intend to retain identifiable personal information indefinitely.

Personal information will generally be retained only for as long as it is reasonably required for:

• operating the marketplace;
• providing services;
• managing customer or provider relationships;
• resolving complaints or disputes;
• maintaining marketplace integrity;
• detecting fraud or abuse;
• meeting tax, accounting, insurance or legal obligations;
• defending or pursuing legal claims; or
• another purpose permitted by law.

Where Loop no longer needs identifiable personal information for a permitted purpose, and is not legally required to retain it, Loop will take reasonable steps to:

• securely destroy it; or
• de-identify it.

The following periods are proposed operational rules and should be confirmed by legal counsel before launch.

Normal deletion schedules may be paused where information is reasonably required for:

• a customer complaint;
• a provider dispute;
• litigation or threatened litigation;
• regulatory investigation;
• insurance claim;
• fraud investigation;
• law-enforcement request; or
• another legal obligation.

Once the reason for the hold ends, the information should return to the normal retention and deletion process.

Information scheduled for deletion may temporarily remain in secure backup systems.

Loop will take reasonable steps to ensure that deleted information is not restored into ordinary operational use except where required for disaster recovery or another legitimate purpose.

Backup copies should be overwritten or deleted according to Loop's ordinary backup lifecycle.

Instead of deleting information, Loop may de-identify it where appropriate.

De-identification may be used for:

• analytics;
• demand forecasting;
• service-area analysis;
• marketplace-performance analysis;
• product development; and
• research.

Loop should take reasonable steps to ensure that de-identified information is not reasonably capable of identifying the individual concerned.

Loop will take reasonable technical and organisational steps to protect personal information from:

• misuse;
• interference;
• loss;
• unauthorised access;
• unauthorised modification; and
• unauthorised disclosure.

Security measures may include:

• access controls;
• authentication;
• encryption where appropriate;
• role-based access;
• logging;
• backups;
• security monitoring;
• restricted administrative access;
• vendor controls; and
• internal policies and procedures.

No internet-connected system can be guaranteed to be completely secure.

If Loop becomes aware of a suspected personal-information breach, it may:

• investigate the incident;
• contain the breach;
• assess the likely consequences;
• take remedial action;
• notify affected individuals where appropriate; and
• notify regulators where required by law.

Loop will comply with applicable data-breach notification requirements.

You may request access to personal information Loop holds about you.

Requests may be sent to:

privacy@loopcallout.com.au or another privacy contact published by Loop.

Loop may need to verify your identity before providing access.

Access may be refused or limited in circumstances permitted by law.

Where access cannot be provided, Loop will explain the reason where required.

If you believe personal information Loop holds about you is inaccurate, incomplete, out of date, irrelevant or misleading, you may ask Loop to correct it.

Loop will take reasonable steps to correct information where required by applicable privacy law.

Providers are also responsible for keeping their marketplace profile, licensing and insurance information current.

You may ask Loop to delete personal information associated with you.

Loop will assess the request having regard to:

• whether the information remains necessary for an active service;
• legal record-keeping requirements;
• fraud-prevention requirements;
• disputes or complaints;
• regulatory obligations; and
• other lawful reasons for retention.

Where Loop is not legally or operationally required to retain identifiable information, it may delete or de-identify it.

A deletion request does not necessarily require Loop to erase information that it is legally entitled or required to retain.

If you believe Loop has mishandled your personal information, you may submit a privacy complaint.

Contact:

Please include enough information for Loop to understand and investigate the complaint.

Loop will:

• acknowledge the complaint where appropriate;
• investigate the matter;
• request further information if required; and
• respond within a reasonable period.

If you are not satisfied with Loop's response, you may have the right to complain to the Office of the Australian Information Commissioner or another relevant regulator.

Loop may use cookies and similar technologies for purposes including:

• essential website functionality;
• authentication;
• security;
• analytics;
• remembering preferences; and
• measuring website performance.

Where consent is legally required for particular technologies, Loop will obtain that consent.

Further information may be provided through a separate cookie notice or consent interface.

Loop may send marketing communications where permitted by law.

You may unsubscribe from marketing communications at any time using:

• the unsubscribe link in an email;
• account settings where available; or
• a request sent to Loop.

Operational messages relating to active service requests, security or marketplace administration may still be sent where necessary.

Loop is intended for people legally capable of requesting or providing the relevant services.

Loop does not knowingly seek to collect personal information from children for independent use of the marketplace.

If Loop becomes aware that information has been collected from a child inappropriately, it may take steps to delete or otherwise appropriately handle that information.

Loop may update this Privacy & Data Retention Policy from time to time.

Where changes are material, Loop may provide notice through:

• the website;
• the platform;
• email; or
• another appropriate method.

The current version will identify the date on which it was last updated.

Privacy or data-retention questions may be sent to: