Privacy Policy
Look DS LLC
This Privacy Policy explains how Look DS LLC ("Look DS", "we", "our", "us") collects, uses, shares and protects personal data in connection with:
- www.lookdigitalsignage.com (our website)
- app.lookdigitalsignage.com (our web application)
- shop.lookdigitalsignage.com (our online store)
It also explains your rights in relation to your personal data and how to contact us or a supervisory authority.
We are subject to the Delaware Personal Data Privacy Act (DPDPA), to the EU General Data Protection Regulation (EU GDPR) in relation to goods and services we offer to individuals in the European Economic Area, and to the UK GDPR and the Data Protection Act 2018 in relation to individuals in the United Kingdom.
This policy is written for adults. If you are under 18, the Service is not intended for you and you must not create an account.
1Our two roles: controller and processor
This distinction matters, because different rules apply to each.
We are a controller for personal data we collect about you when you visit our websites, create an account, purchase a Subscription or Look Coins, contact support, or receive our marketing. For this data, we decide the purposes and means of processing, and this Privacy Policy applies.
We are a processor for personal data that our customers upload to, store in, or display through the Look platform, and for prompts and reference material submitted to content generation features. For this data, our customer is the controller and decides why and how it is processed. We process it only on the customer's documented instructions, under a separate data processing agreement, a copy of which is available on request from info@lookdigitalsignage.com.
If you are an employee, visitor or other individual whose data appears in a customer's Look account, please contact that customer. We will refer any request we receive to them.
2Personal data we collect
The personal data we collect depends on how you use our services. As controller, we collect:
| Category | Examples |
|---|---|
| Identity and contact | Name, company name, email address, telephone number, postal address |
| Account | Username, login details, account settings, role and permissions |
| Billing and tax | Billing address, VAT identification number, tax status, invoices, transaction history, payment method details (held by our payment providers, not by us) |
| Delivery | Delivery addresses specified for an order |
| Usage | Pages visited, features used, Screens paired, Coin balance and consumption, device and browser information, IP address |
| Support and communications | Correspondence by email, chat, phone or social media, support tickets, feedback |
| Marketing | Marketing preferences, responses to campaigns, surveys and promotions |
You must provide identity, contact and billing data to use our paid services. Where a field is optional, we will tell you, and we will explain the effect of not providing it.
We do not ask for and do not need your gender or date of birth.
3How we collect personal data
We collect personal data:
- directly, when you register, place an order, contact us, send feedback, complete a survey or enter a promotion;
- indirectly, from your use of our websites and application, usually through the technologies described in section 8;
- from third parties, including our payment providers, our resellers and partners, and publicly available sources such as company registries.
4Why we use personal data and on what legal basis
| Purpose | Legal basis (EU GDPR / UK GDPR) |
|---|---|
| Creating and administering your account, providing the Service, providing support | Performance of a contract (Art. 6(1)(b)) |
| Taking payment, issuing invoices, managing Coin balances | Performance of a contract (Art. 6(1)(b)) |
| Determining your place of supply, validating VAT identification numbers, calculating and reporting VAT | Compliance with a legal obligation (Art. 6(1)(c)) |
| Keeping accounting, tax and transaction records | Compliance with a legal obligation (Art. 6(1)(c)) |
| Service messages about changes to the Service, these terms or our policies, and security notices | Compliance with a legal obligation (Art. 6(1)(c)) and our legitimate interest in operating the Service (Art. 6(1)(f)) |
| Notifying you of a personal data breach | Compliance with a legal obligation (Art. 6(1)(c)) |
| Securing the Service, preventing fraud and abuse, enforcing our terms | Our legitimate interest in protecting the Service and our customers (Art. 6(1)(f)) |
| Improving the Service and developing new features, using aggregated and usage data | Our legitimate interest in improving our products (Art. 6(1)(f)) |
| Marketing to existing customers about similar products and services | Our legitimate interest in promoting our business (Art. 6(1)(f)), subject to section 5 |
| Marketing to prospective customers by email or SMS | Your consent (Art. 6(1)(a)), where required by the ePrivacy Directive or PECR |
| Non-essential cookies and similar technologies | Your consent (Art. 6(1)(a)) |
| Establishing, exercising or defending legal claims | Our legitimate interest in protecting our legal position (Art. 6(1)(f)) |
Where we rely on legitimate interests, we have assessed that our interests are not overridden by your rights and freedoms. You may ask us for details of that assessment.
We do not make decisions producing legal or similarly significant effects based solely on automated processing.
5Marketing
5.1We may send you updates about our products and services, including offers, promotions and new features.
5.2Where you are an existing customer and the message relates to products or services similar to those you have purchased, we rely on our legitimate interests, and you were given the opportunity to object when your data was collected.
5.3Where required by law, including for prospective customers in the European Economic Area and the United Kingdom, we ask for your consent before sending marketing by email or SMS.
5.4You may withdraw consent or object to marketing at any time, free of charge:
- by emailing info@lookdigitalsignage.com;
- by using the unsubscribe link in any marketing email;
- by replying STOP to any marketing SMS.
5.5Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal. We will still send you service messages relating to your account.
5.6We do not sell personal data, and we do not share it with third parties for their own marketing purposes.
7International transfers
7.1We are established in the United States. Personal data we collect is transferred to the United States and, where our service providers are located elsewhere, to other countries.
7.2Where personal data is transferred out of the European Economic Area or the United Kingdom, we rely on one of the following:
- an adequacy decision of the European Commission, or UK adequacy regulations, in respect of the destination country;
- the European Commission's Standard Contractual Clauses, and the UK International Data Transfer Addendum, together with a transfer impact assessment;
- a derogation permitted by applicable law.
7.3Where generation features are used and the model provider is located in a country without an adequacy decision, the transfer is made under Standard Contractual Clauses and is described in the sub-processor list.
7.4You may request a copy of the safeguards we rely on by contacting us using the details in section 13.
7.5Any change to the destinations to which we transfer personal data, or to the transfer mechanisms we rely on, will be notified in accordance with section 12.
8Cookies and similar technologies
8.1We use cookies, web beacons, pixels and similar technologies to recognise your device, remember your preferences, secure your session and understand how the Service is used.
8.2We ask for your consent before placing any non-essential cookie or similar technology. Strictly necessary cookies, which are required to provide a service you have requested, are set without consent.
8.3You may change or withdraw your cookie preferences at any time through the cookie settings on our websites, or through your browser settings.
8.4The cookies we use, grouped by category, with their purpose and duration, are listed in the cookie settings panel available on every page of our websites. You can review them there before giving or withdrawing consent.
8.5We use Google Analytics, provided by Google LLC, to understand how our websites are used. Google Analytics cookies are set only after you consent. You can opt out at any time through our cookie settings or by installing the Google Analytics opt-out browser add-on.
9How long we keep personal data
We keep personal data only for as long as we need it. Our standard retention periods are:
| Data | Retention period |
|---|---|
| Account data, while the account is active | For the duration of the account |
| Account data, after the account is closed | 24 months, then deleted or anonymised |
| Invoices, tax records, VAT evidence and place-of-supply evidence | 10 years from the end of the relevant tax year, as required by EU OSS and UK VAT rules |
| Records of VAT identification number validation | 10 years |
| Support correspondence | 36 months from the last contact |
| Marketing preferences and consent records | Until you withdraw consent, plus 24 months to evidence the withdrawal |
| Cookie consent records | 12 months |
| Server and security logs | 12 months |
| Prompts and generated output in generation features | As instructed by the customer under the DPA; by default, for the duration of the account |
Where a longer period is required by law, or where data is needed to establish, exercise or defend a legal claim, we retain it for that longer period. At the end of the applicable period we delete or irreversibly anonymise the data.
10Your rights
Subject to the conditions in applicable law, you have the right to:
| Right | What it means |
|---|---|
| Access | Obtain confirmation that we process your data, and a copy of it |
| Rectification | Have inaccurate data corrected and incomplete data completed |
| Erasure | Have your data deleted, in certain circumstances |
| Restriction | Have our use of your data restricted, in certain circumstances |
| Portability | Receive data you provided in a structured, commonly used, machine-readable format, and have it transmitted to another controller, in certain circumstances |
| Object to processing | Object at any time to direct marketing, and object in certain other circumstances to processing based on our legitimate interests |
| Withdraw consent | Withdraw consent at any time, where we rely on it |
| Not be subject to automated decisions | Not be subject to a decision based solely on automated processing producing legal or similarly significant effects. We do not make such decisions |
To exercise any right, email info@lookdigitalsignage.com or write to us at the address in section 13. Please tell us which right you wish to exercise and give us enough information to identify you. We may ask for additional information to verify your identity.
We respond without undue delay and in any event within one month of receiving your request. Where a request is complex or where we have received a number of requests, we may extend that period by up to two further months, and we will tell you within the first month if we do.
Exercising your rights is free of charge. Where a request is manifestly unfounded or excessive, we may charge a reasonable fee or refuse to act, and we will explain why.
Downloading your data
You may request a copy of your data by contacting us using any of the methods in section 13. We will send an archive to the email address on your account within the time limits above.
Deleting your account
You may request deletion of your account and associated data by contacting us using any of the methods in section 13. We will confirm by email when the deletion is complete. Data we are required to retain for tax, accounting or legal purposes will be retained for the periods in section 9 and will not be used for any other purpose.
11Keeping personal data secure
11.1We maintain appropriate technical and organisational measures to protect personal data against accidental loss and unauthorised access, use, alteration or disclosure. These include encryption in transit and at rest, access controls on a need-to-know basis, logging, and regular review of our security practices.
11.2We have procedures for handling suspected personal data breaches. We will notify you and any applicable regulator where we are legally required to do so.
11.3No system is completely secure. You are responsible for keeping your login details confidential and for notifying us without delay of any suspected unauthorised access.
12Changes to this Privacy Policy
12.1We may update this Privacy Policy from time to time.
12.2Where a change is material, we will notify you by email to the address on your account, and publish the updated policy here, at least 30 days before it takes effect.
12.3The date at the top of this policy shows when it was last updated. Previous versions are available on request.
13How to contact us and how to complain
Contact us
Post: Look DS LLC, 1201 N Orange Street, Suite 7003, Wilmington, DE 19801, United States
Email: info@lookdigitalsignage.com
Telephone: +1 302 313 1342
Individuals in the European Economic Area and the United Kingdom may contact us using the details above on any matter relating to the processing of their personal data. We respond in English.
Complaints
Please contact us first if you have a concern about how we use your personal data. We will do our best to resolve it.
You also have the right to lodge a complaint with:
- in the European Economic Area: the supervisory authority of the Member State of your habitual residence, place of work or of the alleged infringement. A list is available at edpb.europa.eu/about-edpb/about-edpb/members_en
- in the United Kingdom: the Information Commissioner's Office, ico.org.uk, telephone 0303 123 1113
- in Delaware: the Delaware Department of Justice, Consumer Protection Unit, attorneygeneral.delaware.gov/fraud/cpu/, telephone (302) 577-8600
14Accessible formats
If you would like this policy in another format, for example large print, audio or braille, contact us using the details in section 13.