This Privacy Policy (this "Policy") explains how Zarubia Holdings Inc. ("Zarubia Holdings", "we", "us", or "our") collects, uses, discloses, and protects your information when you use the Looper mobile application and the related features and services we provide through it (together, "Looper" or "the Services"). Capitalised terms have the meanings given to them in this Policy.
We are the company responsible for your Personal Information — your "controller" for the purposes of applicable data-protection law. You can reach us at [email protected].
This Policy primarily governs the Looper mobile app. Our marketing website at looperai.golf offers a separate, optional email waitlist; where this Policy applies to that website, it is noted in context.
In this Policy, "Personal Information" (referred to as "Personal Data" where required by the GDPR or UK GDPR) means information that identifies, relates to, or could reasonably be linked with you. "You" and "your" mean the individual using the Services.
Contents
1. Who we are and how to contact us
Looper is operated by Zarubia Holdings Inc., the company accountable for the Personal Information we hold. For any privacy question, request, or complaint, email [email protected]. A postal address is available on request.
2. Scope of this Policy
This Policy applies to Personal Information we process through the Looper mobile app and the features delivered within it. It does not apply to third-party products or services we do not control, including the providers described in this Policy, who handle data under their own terms.
We use a cloud backend for storage, sync, sign-in, analytics, and diagnostics, and we use an external artificial-intelligence provider to generate certain features. This Policy describes those uses below.
3. Information we collect
Information you provide
- Profile and preferences — profile, gameplay, and preference information you enter, such as your name, avatar, and Home Course selection. Names are checked automatically when you set or change them, and avatar photos pass an automated image-safety scan before they are shown to other members.
- Content you generate — data generated as you use the app, including location recorded during a round (described below), and notes you add.
- Feedback and support — messages you send us, together with basic device information to help us respond.
- AI assistant messages — messages you send to the in-app AI assistant. Messages are checked automatically for safety, and your name is not included in what we send to the artificial-intelligence provider. They are stored on our servers and automatically deleted after up to 90 days (see Section 11).
- Optional photos — photos you choose to share are processed to generate a response and are not stored by us.
- Optional voice input — if you choose to speak instead of type, your device converts your speech to text and the app receives only the resulting text. No audio recording is captured, stored, or uploaded by us.
- Account credentials (optional) — if you sign in to make your account portable, we receive your email address. For Google sign-in, we also receive your name and profile photo. For Apple sign-in (available on iOS), we receive your name and email address, and you can choose to hide your email using Apple's private email relay, in which case we receive a relay address rather than your personal email.
- Community features — Looper includes community features, such as friends, shared live rounds, live sharing of a round while you play it, and the Looper League — our own competition among users who have set the same Home Course, the course you select in the app as your primary course — which we may introduce or expand over time. When you use them, your name, avatar, the rounds and scores you post or share, and reactions to other members' scores are visible to other members, such as the members of the League at your Home Course. The two bullets below explain what other members can see.
- Rounds you share with other members — when you post a round to the Looper League, every member of that course's League can see the full scorecard: your score on each hole, each hole's par and difficulty ranking, your putts, and the handicap figures used to work out your net score. You can post more than one round in a week, and we keep up to 30 of a week's rounds. When someone becomes your friend, they can open one of your rounds in full — the same per-hole detail, plus your tee and when you started and finished — and, where you played as a group, the same per-hole detail for the people you played with. Rounds you do not post or share stay private to you.
- Live sharing (Broadcast Round) — you can choose to share a round while you are playing it. It is off unless you turn it on, and you choose again for each round. While it is on, your friends — and, when you are playing your Home Course, the members of that course's League — can watch a live scorecard: your score and putts on each hole, each hole's par and difficulty ranking, how many holes you have played, your score against par, your tee, and the type of round. They can see the name of the course you are playing and that you are playing it now, and they can send you a clap. Your friends are told when you start. We do not share where you are on the course, your position or coordinates, your shot data, or anything from the AI assistant. If you are playing with others who are also sharing, everyone who can watch any of you can see all of you; anyone in your group who has not chosen to share is not shown at all. You can stop sharing at any point during the round, and it stops by itself when the round ends. We keep the live record for 7 days after that, then delete it (see Section 11).
- Abuse reports — if you report content or another member, we collect the report: the reason you select, any note you add, and a reference to the reported content. Reports made about your account are also linked to it. Reports are kept as long as needed to review and act on them, including, in limited cases, after an account is deleted (see Section 11).
- Blocking and account standing — if you block another member, we store your block list so that their content and requests no longer reach you; only you can see it. If an account is suspended for breaking our terms, we keep a record of that suspension, including after the account is deleted.
Information collected automatically
- Location — collected only while you have an active round in progress, to provide location-based features. Location collection is tied to the round: it starts when you begin a round and stops when the round ends, pauses, or is closed. We do not track your location when you are not in an active round. Separately, if you choose to share a round live, other members are shown the name of the course you selected while you play — never your position on it (see the live sharing bullet above).
- Score integrity — when you record a round, we derive limited information from your device's location — such as the window of time you were at the course, never your coordinates — and use it to confirm the integrity of scores posted to community features and to detect and prevent fraud or misuse. Where you play in a group, this information may be processed together with your playing partners' round records to confirm a round took place. It is deleted after 90 days and is never visible to other members.
- Device information — basic technical information such as device type, operating-system version, and app version, used for diagnostics.
- Diagnostics — crash and performance data collected through a third-party service if the app encounters a problem, to help us fix it.
- Usage analytics — basic events about how the app is used, collected through a third-party service.
- Account identifier — a device or account identifier created so your data can be stored and synced. It does not contain any personal information.
4. How we use your information
We use the information described above to:
- provide and operate the app's features;
- generate the AI-assisted features based on your inputs;
- create and maintain your account and sync your data across devices when you sign in;
- diagnose problems, monitor performance, and improve the app;
- respond to feedback and support requests;
- maintain the security and integrity of the Services;
- screen content for safety, review abuse reports, and enforce our community terms;
- confirm rounds posted to community features; and
- comply with our legal obligations and enforce our terms.
5. Legal bases for processing (EEA / UK)
Where the GDPR or UK GDPR applies to you, we process your Personal Data on the following legal bases:
- Performance of a contract — to provide the features you request, maintain your account, and sync your data.
- Your consent — for location collection during a round, optional photos, optional voice input, optional sign-in, and live sharing of a round. You can withdraw consent at any time, for example through your device permission settings, by stopping live sharing, or by not using the optional feature.
- Our legitimate interests — to diagnose problems, understand usage, improve and secure the app, and respond to feedback, balanced against your rights.
- Legal obligation — where we are required to retain or disclose information by law.
6. How we share your information
We share your information only with the service providers that help us operate the Services, and only as needed to deliver their features. We require these providers to protect your information and to use it only to provide their services to us. We do not sell your Personal Information, and we do not share it with advertisers (see Section 9). The categories of service providers we use are:
- Cloud hosting and database providers — securely store your account information and the content you provide so it syncs across your devices.
- Analytics and crash-reporting providers — help us understand how the app is used and diagnose technical problems.
- Artificial-intelligence providers — process the inputs you submit to the AI features, including any photo you choose to send, to generate a response and to screen those inputs for safety. Your name is not included in what we send. This information is handled under the provider's own privacy and security terms.
- Weather-data providers — receive only the coordinates of the course you select, never any personal information, to return current conditions.
- Sign-in providers — if you choose to sign in with a third-party account (such as Google or Apple), that provider verifies your identity and shares basic profile information (such as email and name) with us.
- App-store billing — the Apple App Store and Google Play process any subscription billing. We do not receive or store your payment-card details.
- Email-delivery providers (website) — if you join the waitlist on our marketing website, your email address is passed to an email-delivery provider so we can send you the updates you asked for.
We can provide the identity of the specific provider in any category on request — just email us at the address below.
We may also disclose your information where we reasonably believe it is necessary to comply with the law or a lawful request, to enforce our terms, to protect the rights, safety, or property of our users or others, or in connection with a corporate transaction such as a merger, acquisition, or sale of assets, in which case we will require the recipient to honour this Policy.
7. Advertising and analytics
Advertising. We do not currently use advertising identifiers, we do not serve third-party advertising in the app, and we do not work with advertising networks, ad SDKs, or data brokers. If we introduce advertising in the future, we will update this Policy, describe the identifiers and partners involved, and provide any opt-out or consent choices required by law before doing so.
Analytics. We use third-party analytics and crash-reporting tools to understand basic app usage and to diagnose crashes, and we warehouse aggregated usage events. These tools rely on device and installation identifiers rather than advertising identifiers, and we use them to operate and improve the Services, not for advertising.
8. Cookies and similar technologies
The Looper mobile app does not use cookies. Cookies are a web-browser technology and are not used inside the app. The app does use mobile analytics and diagnostics software development kits (SDKs) — the tools described in Section 7 — which rely on device and installation identifiers to function.
Our marketing website (looperai.golf) may use a minimal set of strictly necessary cookies or similar technologies to operate the site and its email waitlist. We do not currently use cookies for advertising or cross-site tracking on the website. If that changes, we will update this section and provide the consent choices required by law.
9. Sale or sharing of Personal Information
We do not sell your Personal Information, and we do not "share" it for cross-context behavioural advertising, as those terms are defined under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA). We have not sold or shared Personal Information in the preceding twelve months, and we do not sell or share the Personal Information of minors.
Because we do not sell or share Personal Information, there is currently no "Do Not Sell or Share My Personal Information" action you need to take. If we ever decide to sell or share Personal Information in the future, we will update this Policy, provide a clear opt-out mechanism, and honour any opt-out preference signals required by law before any such sale or sharing begins.
10. International data transfers
Your information is primarily processed and stored in data centres located in Canada. Because of the infrastructure our service providers use, some information may also be processed in other countries where those providers operate. Where information is transferred across borders, we rely on the safeguards offered by our providers, which may include contractual protections and other recognised transfer mechanisms.
For users in Australia: by using Looper you acknowledge that your information may be stored and processed in Canada and in other countries where our service providers operate. We take reasonable steps to ensure your information is handled consistently with the Australian Privacy Principles.
11. How long we keep your information
We keep your information for as long as your account is active or as needed to provide the Services, and you can delete it at any time (see Section 12). In particular:
- Account and round data — retained while your account is active or as needed to provide the app, and deleted when you delete your account.
- AI assistant messages — retained for up to 90 days, then automatically deleted by a scheduled process.
- Technical and diagnostic logs — retained for a limited period for security and diagnostics.
- Safety records — abuse reports, block lists, and suspension records are kept for as long as needed to review reports and enforce our terms. A limited record may be kept after an account is deleted to enforce a ban, resolve abuse reports, or meet legal obligations.
- Score-integrity records — deleted after 90 days.
- Live round records — the record behind a shared live round is deleted 7 days after the round ends.
- Legal holds — where the law requires us to keep certain information longer, we do.
12. Your privacy rights and choices
Rights available to everyone
Regardless of where you live, you can:
- Access your data — it is visible within the app at any time.
- Update your profile and the content you have entered from within the app at any time.
- Delete your account from within the app's account settings. This starts a process that removes your profile, rounds, avatar, AI assistant messages, block list, posted scores, live round records, score-integrity records, and reports you have filed from our servers and deletes your account — except limited records we must retain to enforce a ban, resolve abuse reports, or meet legal obligations.
- Export your data — email us at the address below and we will provide your data in a portable, machine-readable format.
- Withdraw consent — for example by turning off location permission for the app, which disables the features that depend on it.
To exercise any right, email [email protected]. We will not discriminate against you for exercising your rights.
California residents (CCPA / CPRA)
If you are a California resident, you have the right to know the categories and specific pieces of Personal Information we collect, to delete it, to correct it, and to opt out of any sale or sharing. As explained in Section 9, we do not sell or share Personal Information. In the preceding twelve months, the categories of Personal Information we collected map to the CCPA categories as follows:
- Identifiers — for example email address, name, and account identifiers.
- Internet or other electronic network activity — basic app-usage events.
- Geolocation data — precise GPS location collected only during an active round. Precise geolocation is treated as Sensitive Personal Information under the CPRA; we use it only to provide the location-based features you request and not to infer characteristics about you.
- Audio or visual information — an optional avatar photo you add to your profile, and an optional photo you choose to send to the AI features, which is not stored by us.
- Inferences — outputs the app generates from your inputs.
We collect this information from you and from your device, and we use and disclose it for the purposes in Section 4 and only with the providers in Section 6. You may make a request by emailing [email protected]. You may use an authorised agent, and we will take steps to verify your identity before acting. Because we operate online and interact with you directly, email is the contact method for these requests.
Canadian residents (PIPEDA)
If you are in Canada, you may access and correct your Personal Information and ask questions about how we handle it. We are accountable for the Personal Information we hold and can be reached at [email protected]. If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada.
Australian residents (Australian Privacy Principles)
If you are in Australia, you may request access to and correction of your Personal Information, and you may complain about how we handle it. Please contact us first at [email protected]. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC). Information about overseas disclosure is in Section 10.
EEA and UK residents (GDPR / UK GDPR)
If you are in the European Economic Area or the United Kingdom, you have the right to access, correct, delete, restrict, and port your Personal Data, to object to certain processing, and to withdraw consent. You can exercise your rights by emailing [email protected], and you have the right to lodge a complaint with your local supervisory authority.
13. Children's privacy
Looper is not directed at children under 13, and we do not knowingly collect Personal Information from anyone under 13. If you believe a child under 13 has provided us with Personal Information, contact us at [email protected] and we will delete it.
14. Security
We use established security practices to protect your information. Data is encrypted in transit and at rest, and we restrict access to it. No system is perfectly secure, and we cannot guarantee absolute protection, but we follow recognised best practices and work to keep your information safe.
15. Third-party services and links
The Services rely on the third-party providers described in this Policy, and the app may link to third-party content. We do not control those third parties, and their handling of your information is governed by their own privacy policies and terms. We encourage you to review them.
16. Changes to this Policy
We may update this Policy from time to time. If we make material changes, we will update the "Last updated" date above and notify you within the app. Your continued use of the Services after an update means you accept the revised Policy.
For questions about this Policy or your data, email [email protected].
Looper is operated by Zarubia Holdings Inc. A postal address is available on request.
