Looper. GDPR Compliance

Overview

Looper has undertaken a review of its data collection, storage and security arrangements and has implemented various system changes to reflect the data security and privacy principles entrenched by GDPR, including individual’s right of access and right to be forgotten.

Looper understands the fundamental importance of data security and privacy to its customers and end users of its services, and will continue to review and update its systems and compliance policies and procedures following the commencement of the GDPR.

Looper as a processor

Looper provides a service for the sending and/or receiving of messages, principally by way of SMS. For the purposes of GDPR, when providing this service to customers, Looper acts as a processor.

Subject Matter of processing

The subject matter of Looper’s processing activities for GDPR purposes comprises the provision of a service for customers to send messages to, and/or receive messages from, end users.

Nature and purpose of processing

Messages are processed by Looper strictly in accordance with customer instructions and otherwise in accordance with the requirements of relevant laws, for the purposes determined by the customer.

Type of Personal Data processed

For the purposes of GDPR, Looper’s customer will be the “controller” in relation to personal data that is processed and will thus have control over the types of personal data processed. Looper processes only that data (which may include personal data) that is transmitted in the course of sending/receiving messages in accordance with the controller’s instructions. Personal data processed include source and destination telephone number and, depending on message content, may include other personal data.

Categories of Data Subjects

As the “controller” for GDPR purposes, Looper’s customer necessarily has sole control over the specific categories of data subjects that may be the subject of processing by Looper.

Level of Risk associated with processing

Typically, the personal data that Looper processes and the circumstances in which such data is processed, would be unlikely to result in significant harm to a data subject in the case of a data breach, however any assessment of risk associated with a potential data breach necessarily depends upon the types of personal data transmitted in the course of sending/receiving messages in accordance with the controller’s instructions and the context in which that data is processed.

Where is the Personal Data stored?

Personal data is encrypted and stored in data centres located in Australia and operated under contract by suitably qualified third parties.

Who has access to the Personal Data?

Access to personal data stored by Looper is restricted. Specified customer and technical support personnel have limited access for the sole purpose of performing the messaging services that Looper is contracted to perform and to address any customer queries arising out of the performance of those services.

Looper may provide personal data to aggregators to facilitate the provision of the messaging services. Aggregators (who constitute sub-processors for GDPR purposes) will be engaged by Looper pursuant to a GDPR compliant contract. Looper does not provide personal data to any other third parties.

How long do we store Personal Data?

Looper retains personal data processed by it in the course of providing messaging services to its customers for the period of time necessary to enable it to complete the processing it is contracted to provide or as otherwise required to comply with its legal obligations, including its requirements to retain certain metadata for 2 years under the Telecommunications (Interception and Access) Act 1979 (Cth).

Exercising of Rights afforded by GDPR

Looper recognises the rights that are granted to EU residents under the GDPR and will take appropriate action to ensure that those rights are actioned upon request. Any EU resident seeking to exercise a right in respect of their personal data should contact our support centre on 1300 971 083. Looper is committed to ensuring the security of personal data is maintained, and accordingly, any person making a request in respect of their personal data will be required to provide satisfactory evidence as to their right to do so (which may include, for example, their identity and EU residency).