Data & Messaging Policy

1. Two Kinds of Contact Data

Your Contacts area contains two kinds of records, and different rules apply to each:

• Platform-shared contacts — customers who interacted with your business through Loopearn (signed up on the mobile app, redeemed a reward or loyalty offer, or messaged you on a connected channel such as WhatsApp). Loopearn collected this data and shares a limited profile with you so you can serve that customer relationship.
• Merchant-uploaded contacts — contacts you import yourself (for example via CSV upload). You collected this data, and you are responsible for it.

2. Roles Under India's DPDP Act, 2023

• For merchant-uploaded contacts, you act as an independent data fiduciary under the Digital Personal Data Protection Act, 2023. Loopearn processes that data on your instructions to provide the Service (storage, segmentation, message delivery).
• For platform-shared contacts, Loopearn is the data fiduciary and shares limited data with you strictly for the purpose described in Section 3.
• You are responsible for complying with the obligations that attach to your role, including lawful grounds for processing, notice to the individuals concerned, and responding to their rights requests.

3. Purpose Limitation for Platform-Shared Contacts

Platform-shared contacts are provided to you for one purpose: serving customers who have chosen to interact with your business. You may not:

• Sell, rent, or share this data with any third party
• Export it for marketing unrelated to the customer's relationship with your business
• Contact these customers outside the platform in ways they have not consented to

4. Consent Requirements for Uploaded Contacts

When you upload contacts, you confirm that:

• The contacts belong to your business (customers, subscribers, or people who gave you their details directly) — purchased or scraped lists are not permitted
• Each person has consented to receive communications from your business
• You will honor opt-out and unsubscribe requests promptly
• You will delete a contact's data when they ask you to (see Section 6)

We record your confirmation of consent with each upload.

5. Messaging Rules

Two rules apply on every channel: only message contacts who have opted in to hear from your business, and message content must be accurate, must identify your business, and must comply with applicable law. In addition, each channel is governed by its own platform's policies, which you agree to comply with:

• WhatsApp — governed by Meta's WhatsApp Business messaging policies. Business-initiated messages outside the customer-service window require approved templates and prior opt-in. High block or report rates can cause Meta to restrict or ban your number.
• Instagram and Facebook Messenger — conversations are customer-initiated. You may reply within the messaging window Meta allows; outside it, only Meta-approved message types are permitted. These channels may not be used for cold outreach.
• Telegram — governed by Telegram's terms and bot policies. Your business can only message people who have started a conversation with it, and users who block or stop the conversation must not be contacted again through other means without consent.
• iMessage — governed by Apple's Messages for Business policies. Conversations are customer-initiated; unsolicited outbound messages are not permitted.
• Email — requires prior consent, a working unsubscribe mechanism, and accurate sender identity. High spam or complaint rates can cause mailbox providers to block your sender domain.

Loopearn is not responsible for restrictions the platforms impose as a result of your messaging practices. Where a channel is not yet available on Loopearn, these rules apply from the day it launches.

6. Erasure and Correction Requests

• If a person asks you to delete or correct their data, you must act on the request without undue delay, including removing them from your uploaded contacts and segments.
• When a Loopearn user deletes their account, we remove or de-identify their platform-shared profile. You must not retain copies of platform-shared data outside the Service.
• If you need help fulfilling a request, contact support@loopearn.com.

7. Your Responsibility for Uploaded Data

You agree to indemnify and hold Loopearn harmless from claims, penalties, and losses arising from contacts you uploaded without valid consent, or from messages you sent in breach of this policy or applicable law.

8. Enforcement

Violations of this policy may result in suspension of messaging features or of your Loopearn account, in line with our Terms of Service.

9. Contact Us

Questions about this policy? Contact us at support@loopearn.com.