Privacy Policy

1. Who we are

dualoop SRL, Rue des Champs Elysées 18A, box 2, 1050 Ixelles, Belgium (enterprise and VAT number BE 0773.979.430), is responsible for the personal data described in this policy. Contact: info@dualoop.com.

2. What this policy covers

This policy covers dualoop Coach: the App at coach.dualoop.com and the website www.dualoop.coach.

When you or your organisation put personal data about other people into the Service, for example in interview notes, we process it on your organisation's behalf under our Data Processing Agreement, and your organisation is responsible for it. dualoop's consulting engagements have their own agreements.

3. What we collect

• Account: name, business email address and sign-in details.
• Profile: role, company, industry and focus, if you provide them.
• Your content: messages, files, documents, presentations, the coach's outputs and the facts it remembers for you.
• Usage: how much of your plan you use, and usage events recorded on our servers under an internal account ID, without your content.
• Analytics and marketing: if you consent, how you use the website and the App (PostHog, and Google Analytics on the website). On the website, also data to measure our LinkedIn ads (LinkedIn Insight Tag) and to show our sales team which companies visit (lemlist). See our Cookie Policy.
• Cookie choices: a record of each choice you make about cookies: a random ID, your choices and the date, without your name or IP address.
• Payment: subscription and billing details, handled by our payment provider. We do not receive full card numbers.
• Technical: IP address, device and browser information, and security logs.
• Communications: emails you send us and our replies.

Please do not share health or other sensitive information about yourself or others.

4. Why we use it

You can object at any time to processing based on legitimate interests (section 10), and withdraw your consent to analytics and marketing at any time with the "Cookie settings" link.

5. AI and web search

• We use third-party AI models to process your requests. The providers act on our behalf and may not use your data to train their models.
• When the coach searches the web, it sends a search query written from your conversation to our web search provider. Please leave out personal data the search does not need.
• When you paste a link, our servers retrieve that page.
• We do not make decisions about you based solely on automated processing that have legal or similarly significant effects.

6. Who we share it with

We share personal data only with:

• service providers that help us run the Service: hosting and databases in the EU, AI model providers, payment, email, analytics, marketing tools used with your consent, and web search. Our Subprocessors page lists them;
• tools or AI assistants you connect, at your request;
• authorities or courts, when the law requires it;
• a company that takes over the Service, after telling you.

If you consent to marketing on the website, LinkedIn collects data through its Insight Tag. We and LinkedIn are jointly responsible for that collection. LinkedIn is responsible for its own use of the data, under its privacy policy.

We do not sell personal data.

7. International transfers

Some of our providers are in the United States or other countries outside the European Economic Area. We transfer personal data only with a safeguard recognised by the GDPR, such as the EU-U.S. Data Privacy Framework or the European Commission's standard contractual clauses. You can ask us which safeguard applies and for a copy.

8. How long we keep it

• We keep your account data and content while your account is open. You can delete items, or your whole account, at any time in the App. Deletion is immediate.
• After you delete your account, we keep only invoices and accounting records for as long as the law requires, security logs that are no longer linked to you, backups until they expire, and analytics records, which carry only an internal ID, until they expire.
• We keep emails you send us, and internal alerts that mention you, until the matter is closed and related claims are time-barred. We keep technical logs only as long as needed for security, records of your cookie choices for as long as we may need to show that we asked, and analytics data for up to 7 years.

9. Security

We host the App and its database in the EU, in Paris and the Netherlands. We encrypt data in transit and at rest, encrypt most of your content with a key specific to your account, and restrict access to it. No system is completely secure. We will tell you about a personal data breach where the law requires.

10. Your rights

You can ask to access, correct or delete your personal data, restrict or object to its use, or receive it in a portable format, and you can withdraw any consent you gave. Write to info@dualoop.com. We answer within one month.

You can also complain to the Belgian Data Protection Authority (Autorité de protection des données / Gegevensbeschermingsautoriteit), Rue de la Presse 35, 1000 Brussels, www.autoriteprotectiondonnees.be.

11. Cookies

We use strictly necessary cookies and, only with your consent, analytics and marketing cookies. You can change your choice at any time with the "Cookie settings" link. Our Cookie Policy gives the details.

12. Changes

We may update this policy. We will tell you about material changes by email or in the App.