Published 6 December 2025

Your Privacy Rights

Introduction and scope

Loop Works, LLC ("Loop Works", "Loop" or "Company" or "we") respects your privacy, each individual's right to personal privacy and is committed to protecting it through our compliance with this policy.

This Privacy Policy describes how Loop collects, uses, shares and safeguards the personal data you provide to us, and applies to customers and their employees, prospects, business partners, event attendees, employees, job applicants, messaging users and members of the general public visiting our websites.

It also describes your choices regarding use, access and correction of your personal data. The use of personal data collected through our service shall be limited to the purpose of providing the Loop service for which the Customer ("Client" or "Subscriber") has engaged Loop as set out in the License User Agreement, Terms of Service, and other agreements with the Customer and this Privacy Policy ("Loop Service").

By using www.loopworks.com, you agree to the data practices described in this statement and you expressly consent to the collection, use and disclosure of your personal information in accordance with this Privacy Policy.

Loop services

Loop operates and provides a platform for employers to market and communicate with applicants and employees. During the course of our operations Loop collects data for both our Customers, and for our business operations including employment applications.

Privacy policy

Loop is committed to protecting your privacy. We have created this Privacy Policy to protect your personally identifiable information and to inform you about how we protect that information. This Privacy Policy applies to transactions and activities of visitors to and users of our websites ("Sites"), our blogs, our mobile applications ("Mobile Apps" / "Apps"), and our online products and services (collectively, "Services") and how we collect, use, and share personal information both in the course of our business activities and in providing the Services that Loop performs on behalf of Loop customers. This Privacy Policy does not apply to any website not owned or operated by Loop or to any offline points of contact between Loop, or any other company, and consumers.

Access to and use of Loop web sites or portals (including all sites owned or operated by Loop, collectively called the "Site") and the Services provided by Loop (hereafter referred to as, the "Service") will be subject to Loop's Privacy Policy as set forth herein.

We will collect and use information we receive directly from you through our websites and services only in the ways disclosed in this Privacy Policy.

This policy will inform you of our use of that information, where that information is retained and shared in the delivery of the Services, and the choices you can make regarding our use of the information.

The use of information collected through our Service shall be limited to the purpose of providing the service for which the Customer has engaged Loop. As a matter of policy, we do not sell or rent any of your personal information to third parties for any marketing purposes.

Loop customers and subscribers

In providing Services to our Customers, we collect, store, process, and disclose personal information belonging to individuals who are involved in recruiting or employment activities (these include customers, their employees or subscribers, applicants to jobs, those registering their interest in jobs or referring individuals to jobs or their friends and contacts). In each of these cases, our software is integrated into a Customer System and we are processing personal information solely on behalf of the Customer, and in accordance with our agreements with the Customer. Loop is a data processor for our Customers, each of whom operate as controllers of personal data.

We are a service provider to our Customers and have no direct relationship with a Customer's candidates or any individual whose personal data a Customer processes. Information provided to Loop by our Customers is collected by those Customers under their own Privacy Policies. As a result this policy does not apply to practices that Loop does not own or control, or to individuals that Loop does not employ or manage.

If you are interacting in recruiting or employment contexts with one of our Customers, the Customer's Privacy Policy applies to the processing. Please review the Customer's Privacy Policy, terms of use or other notices to learn more about the Customer's information practices, including its use of service providers like Loop.

Loop employees and applicants for employment

If you are interacting as a Loop employee, or an applicant for employment at Loop then our Employment Privacy Policy applies. This Policy may be accessed upon request to hr@loopworks.com.

Your personally identifiable information

The registration or application process or form collects certain information you voluntarily choose to share with Loop, such as your name, social media account identifier, email address and mobile number ("personally identifiable information" or "PII"). You may always choose not to provide such personally identifiable information; however, this may limit Loop's ability to provide you with a specific service or particular content. Loop may also collect other data, which may include personally identifiable information.

Personally identifiable information as used by Loop customers

Loop is contracted by employers and other companies ("Customers") to provide the Loop Service. Information about your use of the Service and visits to the online or mobile sites may be used by Loop and its Customers. Your personally identifiable information is only shared with the specific Customer which you visited and to which you subscribed.

When you use these Services, in addition to data you consent to provide, we will automatically collect information on the type of device you use, including the operating system version.

We collect your location-based information for the purpose of matching your search or content-request criteria. If you no longer wish to allow us to track your location-based information within the browser or application, you may turn this off at the device level.

Information related to data collected for our Customers

Loop collects information under the direction of its Customers and has no direct relationship with the individuals whose personal data it processes. If you are a candidate, employee or customer of one of our Customers and:

• Would no longer like to be contacted by one of our Customers that uses our service, contact the Customer that you interact with directly. We may transfer personally identifiable information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Customers.
• Require access to review, correct, amend, or delete inaccurate data, contact the Customer that you interact with directly.
• Require access to a record of this data, contact the Customer that you interact with directly.

When the Customer requests Loop to action any such request(s) we will respond to their request(s) within 30 days.

We will retain personal data we process on behalf of our Customers as long as needed to provide services to our Customer. Loop will retain and use this personally identifiable information as necessary to comply with any legal obligations, resolve disputes, and enforce our agreements.

Collection of your personal information as an authorized Loop Customer

If you purchase products and services through www.loopworks.com or are granted access to the Loop Services by your employer, Loop may collect personally identifiable information, such as your name, email address, social media account identifier, mobile number and other personal and non-personal information.

If you purchase products and services through www.loopworks.com, we may request billing and credit card information. In this instance Loop is interacting with Customers as a data controller. This information is not stored by Loop, except where users explicitly require us to do so, and provide consent for such.

Information about your computer hardware and software may be automatically collected by Loop. This information can include: your IP address, browser type, domain names, access times and referring website addresses. This information is used for the operation of the Loop Service, to maintain and improve quality of the service, and to provide general statistics pertaining to the use of the Loop customer site(s).

Individuals in the EEA and UK

We process your personal data (as defined in the GDPR Regulation - EU 2016/679 - GDPR and UK General Data Protection Regulation (UK GDPR)) in order to provide Loop Sites or Services for your use or for such other purposes as set forth in this Policy and the Terms of Use. Your personal data may be transferred to the United States and other countries outside of the EU which may offer different levels of protection for personal data than may be available in your country. Loop ensures that all personal data is handled, processed, transferred and stored in accordance with the GDPR Regulation, and that adequate safeguards and procedures providing protection to users' personal data are in place. When you submit your registration or application, you agree to Loop's Privacy Policy and, in particular, you expressly agree to the transfer of your personal information for the purposes described in that policy.

Right to privacy

Certain jurisdictions may provide you with privacy rights under applicable data protection or privacy law regarding the information you provide to us. In particular:

1. If you are a resident of the EEA or UK whose personal data is subject to EU or UK data protection law, you have certain privacy rights which include: the right to be informed, to access your information, to correct any information that is inaccurate, to have your information erased, to restrict or suppress your information, to obtain and reuse your personal data, to object to the processing of your personal information, and to object to how your data is used in automated decision making, if applicable. If you wish to enact your rights, please contact us at privacy@loopworks.com or by using the contact details under the "Contact Us" heading below.
2. If you are a resident of California whose personal information is subject to the California Consumer Privacy Act ("CCPA") as amended by the California Privacy Rights Act or "CPRA", you may review further details about the personal information we have collected about you over the last 12 months, including the categories of sources by reviewing this policy. We collect this information for the business and commercial purposes described herein and we share this information only with Customers for whom it is collected, or as described for our business operations. We do not sell (as defined in the CCPA) your personal information (and will not sell it without providing a right to opt out). California law provides you with a number of rights regarding your personal information.
   • Access. You have the right to request a copy of certain information we hold about you, as well as a summary of the categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or sharing that information; and the categories of third parties with whom we shared that information.
   • Delete. You have the right to delete certain information we have about you.
   • Financial incentives. You have the right to receive information about the financial incentives that we offer to you (if any).
   • Consequences for exercising rights. You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights.
   • Shine the Light. You also have the right to request, once per year, that we disclose the identity of any third parties with whom we have shared personal information for the third parties' direct marketing purposes within the previous calendar year, along with the type of personal information disclosed.
   • Certain information may be exempt from these rights under applicable law. For example, we need certain types of information so that we can provide you with the Service. If you ask us to delete it, you may no longer be able to access or use the Service.
   • You can exercise any of these rights by emailing privacy@loopworks.com and requesting a personal data access request or by sending a written email request to us at: Loop Works ATTN: Personal Data Access at privacy@loopworks.com. You may need to give us enough information so that we can be confident of your identity before we can satisfy certain requests. To do that, you'll need to give us certain information about you and/or your use of the Services. You can also designate an authorized agent to make a request on your behalf. To do so, you have to give us written authorization for the agent to act on your behalf. If we need to verify your identity, you'll need to do that directly with us.
3. If you do not wish to receive our email or messaging marketing communications for promotional purposes, you may opt out by clicking on the "unsubscribe" or "opt out" link in the marketing e-mails or messaging we send you.
4. If we process your personal information in reliance upon your consent, you can contact us at any time to withdraw your consent, by email at privacy@loopworks.com.

• If your personally identifiable information changes or if you no longer wish to use our service, you may request we modify or delete your information by emailing us at privacy@loopworks.com.

We will respond to any such requests in accordance with the requirements of applicable data protection laws. Please note that in order to fulfil your request, we may need you to provide certain information to verify your identity. Depending upon applicable data protection and privacy law, individuals may also designate an authorized agent to exercise these rights on their behalf.

Storage and processing of personal data

Loop operates the Loop Platform and associated Services in the United States and EU, allowing personal data to be collected, stored and processed in the region in which it is collected or in certain cases, as specified by Loop Customers. Typically, the primary storage and processing location is in the Customer's region or in the United States. We have standard operating procedures to ensure that all data collected under this privacy statement is processed in accordance with this statement's provisions and the requirements of applicable laws and standards.

As a global organization, we may need to transfer your personal data to Loop affiliates, contractors, service providers, and to third parties in various countries and jurisdictions around the world. When we engage in such transfers, we use a variety of legal mechanisms, including contracts such as the Standard Contractual Clauses published by the European Commission under Commission Implementing Decision 2021/914, to help protect your rights and enable these protections to travel with your data (European Commission international transfers). To learn more about the European Commission's decisions on the adequacy of the protection of personal data in the countries where Loop processes personal data, see the European Commission website.

Loop Works complies with the EU-US Data Privacy Framework (EU-US DPF), and the UK Extension to the EU-US DPF as set forth by the US Department of Commerce. Loop has certified to the US Department of Commerce that it adheres to the EU-US Data Privacy Framework Principles (EU-US DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-US DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-US DPF. If there is any conflict between the terms in this privacy statement and the EU-US DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit dataprivacyframework.gov.

Loop adheres to the DPF principles for onward transfers of personal data to third parties and is responsible for ensuring that the third parties comply with applicable data protection principles, including ensuring that the third parties do not process such personal data in a manner inconsistent with the DPF Principles. Loop remains liable for damages caused by third parties under the DPF unless Loop did not cause the event giving rise to damage.

If you have a question or complaint related to participation by Loop in the DPF Frameworks, please contact us at privacy@loopworks.com. Loop commits to resolve complaints or enquiries within 30 days of receiving any such notice.

For any complaints related to the DPF Frameworks that Loop cannot resolve directly, we have chosen to cooperate with the relevant EU Data Protection Authority, or a panel established by the European data protection authorities EU Data Protection Authorities (DPAs), and the UK Information Commissioner's Office (ICO) ico.org.uk, for resolving disputes with UK individuals with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-US DPF and the UK Extension to the EU-US DPF in the context of the employment relationship. Please contact us if you'd like us to direct you to your data protection authority contacts, at privacy@loopworks.com.

If you have not received a timely or satisfactory response from Loop to your question or complaint, please contact our alternative dispute resolution provider the ICDR/AAA by visiting go.adr.org/dpf_irm.html to file a question or complaint. The services of the ICDR/AAA are provided at no cost to you.

As further explained in the DPF Principles, binding arbitration is available to address residual complaints not resolved by other means. Loop is subject to the investigatory and enforcement powers of the US Federal Trade Commission (FTC).

If you require further information about our international transfers of personal data, please contact us at privacy@loopworks.com or by using the contact details under the "Contact Us" heading below. In each case we will respond within 30 days of receipt of your request.

Our subsidiaries include

• Loop Operating Company Ltd

What we use personally identifiable information for

Loop uses the collected personally identifiable information to verify your identity and to contact you in connection with your use of the Service. If you opt in to a Service that generates communication to you from Loop, you will be given the opportunity to opt out of receiving further such communications from Loop. Except as provided in this Privacy Policy, Loop does not sell, share or otherwise provide any personally identifiable information you give to us with any third party other than Customers.

Disclosure - communications content/data and information

We will share your personally identifiable information with third parties only in the ways that are described in this privacy statement. Though we do not sell your personally identifiable information to third parties, we may provide your personally identifiable information to companies that provide services to help us with our business activities such as a live help feature or in offering customer service. These companies are authorized to use your personally identifiable information only as necessary to provide these services to us. In any case when we transfer your information to third party companies, we will ensure they maintain the same level of security as us.

We may provide your personally identifiable information:

• as required by law, such as to comply with a subpoena, or similar legal process.
• when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
• if Loop is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your personally identifiable information, as well as any choices you may have regarding your personally identifiable information, to any other third party with your prior consent to do so.
• Also, certain technical processing of messages and their content may be required to: (1) send and receive messages; (2) conform to connecting networks' technical requirements; (3) conform to the limitations of the Service; or (4) conform to other similar requirements.

How we protect and store personal information

Loop uses commercially reasonable physical, managerial, and technical safeguards to protect personal information. We cannot, however, ensure or warrant the security of any information you provide to Loop Sites or that is provided to us in connection with Loop Services to our Customers. We cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. Moreover, Loop is not responsible for the functionality or security measures of any third parties with whom Loop interacts, such as social networks and our Customers, in the course of providing our Services.

We also 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 mobile or email communications from Loop, at all times. In the provision of Services, access to individual (ie, subscriber, user and job applicant) accounts is controlled by the Customer. Loop does not control account access to its Customers' Customer Systems, and is not responsible for the security of those systems. Please review the Privacy Policy of our Customer(s) with whom you are interacting for more information about the Customer's data security.

Loop has implemented commercially reasonable and appropriate technical, physical, and organizational measures to protect Customer Data from misuse or accidental, unlawful, or unauthorized destruction, loss, alteration, disclosure, acquisition, or access during the Processing, which will meet the requirements of the GDPR Regulation, or any stricter requirements, as imposed under the Service Agreement.

Access to Customer Data will be authorized only to the extent necessary to serve the applicable Data Processing Purposes and requirements of the Service Agreements. Loop staff with access to Customer data will be subject to confidentiality obligations.

Loop shall notify the Customer of a data security breach without undue delay after becoming aware that such a breach has occurred, unless a law enforcement official or supervisory authority determines that notification would impede a criminal investigation, or cause damage to national security or a breach of trust.

Data storage and retention

Loop will retain personal information that we receive and process on behalf of our Customers for as long as needed to provide services to our Customer. Our data retention periods will vary per contractual agreement with each individual Customer. Loop will retain and use this personal information to comply with our legal obligations, resolve disputes, and enforce our agreements.

In some instances, Loop does not retain data beyond a single session. Once Loop has facilitated the transmission of personal information to a Customer's database that is not hosted by Loop, it is that Customer's responsibility to guard the user's personal information against unauthorized access or transmission. We may store personal information in locations outside the direct control of Loop (for instance, on servers or databases co-located with hosting providers). When a customer terminates or deactivates its Customer account, Loop may retain the personal information of the Customer for a commercially reasonable time for backup, archival, or audit purposes.

Data processing purposes

Loop shall Process Customer Data on behalf of the Customer, only in accordance with the Service Agreement, pursuant to any documented instructions received from the Customer, or as needed to comply with the GDPR Regulation or any other Applicable Law.

Loop processes personal data pertaining to Customer records as needed to provide Customer services, Customer support activities, as required by GDPR Regulation and for the following additional purposes:

• Hosting, storage, and other processing needed for business continuity and disaster recovery;
• System and network administration and security, including infrastructure monitoring, identity and credential management, verification and authentication, and access control;
• Monitoring and other controls needed to safeguard the security and integrity of transactions;
• Enforcing contracts and protecting Loop, its associates, Customers, Customer employees, and the public against theft, legal liability, fraud, or abuse; and
• Approved Loop internal business processes.

Upon termination of the Service Agreement, Loop shall fulfill its obligations to the Customer with regard to returning the data and securely destroying the data, subject to GDPR Regulation.

Transparency to Customer applicants and employees

Loop shall promptly notify the Customer of requests or complaints related to the Processing of personal data by Loop that are received directly from Customer employees without responding to such requests or complaints, unless otherwise provided in the Service Agreement or instructed by the Customer.

Sub-processors

Third Party Sub Processors may only Process Customer Data pursuant to a Sub Processor Contract. The Sub Processor Contract shall impose similar data protection-related Processing terms on the Third Party Sub Processor that will be not less protective than those imposed on the Loop Contracting Entity by the Service Agreement and the Loop Privacy Code for Customer Data Processing Services.

Loop shall maintain a record of accredited Sub Processors involved in the performance of the relevant Customer Services and Loop shall provide notice to the Customer of any new Sub Processors engaged by Loop for the delivery of the Customer Services. Customers have 30 days from notification date to object to the use of new Sub Processors engaged by Loop for the delivery of the Customer Services.

Data types and tracking technologies

The information we gather and store includes internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.

We use this information to analyze trends, to render an optimized user experience on our site, to track users' movements on the site and to gather demographic information about our user base as a whole.

In order to improve the end-user experience, we use a third-party tracking service called Google Analytics that uses cookies to track non-personally identifiable information about visitors to our site in the aggregate (browser version, geographic region, click path, and bounce rates).

Social media features and widgets

On occasion, our Service includes social media features and widgets which are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the relevant company or organization providing the widget and its associated functionality.

Connected mobile site or links to data

In the course of delivering the Services Loop creates and hosts links to other mobile sites and websites. Loop is not liable for the privacy practices or the content of such websites.

What are cookies and does Loop use them?

What is a cookie?

The vast majority of websites and web services use cookies to "make things work". A cookie is a small file comprised of letters and numbers that we place onto your device to enable key Loop features and functionalities. Cookies support the easy sharing of your information on Loop Sites, facilitate the delivery of tailored content to you from our Customers, and support a number of customized features through Loop plugins such as our registration forms and mobile links. Cookies also allow us to identify your device, secure your access to Loop and our sites in general, and even to identify if or when someone attempts to access your account from a different device.

When does Loop use cookies?

We use cookies on our websites (www.loopworks.com) and mobile sites or applications, and any browser loading these sites (ie, any time you access these sites) will receive cookies from us. For our CRM users, or those registering on Loop sites, we also place cookies in your browser when you visit third party (ie, non-Loop) sites that host our plugins, such as our Loop registration forms. You can opt out directly from the applicable Customer site(s), in which case we will not place cookies in your browser through these plugins.

What types of cookies does Loop use?

Loop utilizes several types of cookie to bring you an exceptional user experience:

• Necessary cookies - required for effective navigation around the Loop platform and websites. Without these cookies, key functions and user experience may be significantly impacted.
• Persistent cookies - help us recognize you as an existing user and remember your preferences so we can deliver enhanced functionality and a personally tailored service. For example, a persistent cookie stays in your browser and will be recognized by Loop when you return to the site, in order to identify you. Should you get interrupted for any reason (including browser shutdowns or loss of access to the Internet) while completing a job application, persistent cookies will allow you to continue where you left off (at a later time).
• Session cookies - only last for as long as the session (usually the current visit to a website or a browser session) and expire when you close the browser. These cookies are required for site functionality.
• Performance cookies - utilized by third party partners or service providers may be used in order to help us continuously improve site performance and provide reporting to our Customers. For example, Loop partners with Google Analytics to collect data on site usage. This information is collected through the use of performance cookies which aggregate and anonymize all data, and no personally identifiable data is involved.

You will also have the option to save details (that you enter about yourself) after you close your browser, so that you will not have to re-enter the same details the next time you need to fill in a form on one of our sites.

Managing cookies: You can opt out of the use of cookies at any time, however this may limit the functionality of our Loop services, and your overall user experience. As a result, your customized settings (including login information) may not be retained, and there may be some Loop features you are unable to access. Such features could include your ability to efficiently work through a job application, or to register for one of our Customer's Talent Networks to receive job alerts that may be of interest based on your stated preferences.

To opt out of cookie use, you can set your browser to reject cookies. Please visit the Help menu of your Internet browser for instructions.

To opt out of Google Analytics, please go to: Google Analytics Opt-out Browser Add-on.

Third party cookies and tracking tools are not under our control, are not covered by our cookie policy or privacy statement, and are therefore subject to their own policies. We do not share data (including cookie data) with third parties for advertising purposes, however we may permit the use of cookies or other tracking technology at the request of and/or on behalf of our Customers.

By using our websites (www.loopworks.com), mobile sites, Platform or applications, you agree to our use of cookies.

Privacy for children

Loop does not direct any of its products, services, sites or offerings to children under age 13. If we learn that any personal information has been collected from a child under age 13, we will delete the information as soon as possible. If you believe that we might have any information from or about a child under 13, please contact us at privacy@loopworks.com.

Site monitoring tools

Loop uses analytics software while providing the Service on your mobile device. This allows us to ensure our Mobile Software and Service functions properly on your device. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the application.

Loop subscriber user options to unsubscribe or opt out

If you wish to subscribe to the Service we will use the personally identifiable information to contact you. If at any time you wish to opt out of receiving these text messages or emails, you may follow the unsubscribe or opt out procedure provided in communication to you by text or email. In addition, if you are a registered user, you may also opt out and have your account permanently deleted by emailing your request to privacy@loopworks.com.

Updates and changes to this policy

Loop reserves the right to change this Privacy Policy from time to time. Loop will post the revised Privacy Policy on this site located at https://loopworks.com/privacy-policy/, and will either send a notice to the e-mail address that you specified in your registration and/or post notice of the change so it is visible when users log on for the first time prior to said changes taking effect so that you are always aware of what personal information Loop may collect and how Loop may use this information.

We encourage you to review this Privacy Policy regularly for any changes. Your continued use of the Services will be subject to the then-current Privacy Policy.

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