Last updated [05-25-2018]
The following terms shall have the following definitions: “ Location Data ” shall mean data with respect to the country from which you are accessing or using the Services. “ Personal Data ” shall mean information that can be used to identify you, directly or indirectly, alone or together with other information. This includes information such as your full name, email address, phone number, device IDs, and certain cookie and network identifiers.
How WordTree LLC Collects and Uses Personal Data.
(a) When you register for an account or interact with the Services . WordTree LLC collects Personal Data when you use or interact with our Services, including when you register for a Company account, browse our Services online, and, possibly, to make payments (including the possibility of processing of such payments). Personal Data may include name, address, phone number, username and password, email address, date of birth, and payment information. WordTree LLC uses Personal Data to create your Company account, enable your activity within our Services, and to provide the Services generally, including to develop, enhance, and improve our Services and your experience in using such Services. WordTree LLC also uses this data for internal purposes related to certain, analytics, innovation, testing, monitoring, customer communication, risk management, and administrative purposes.
(b) When WordTree LLC Collects Location Data . WordTree LLC may collect Location Data as part of the functionality of our Services. We may collect Location Data in several ways, such as through your wireless carrier, based on WiFi access point location, via Bluetooth beacons, through a connected device, or directly from the device on which you use the Services.
(d) When you participate in special activities, offers or programs . WordTree LLC may request or otherwise collect Personal Data when you participate in Promotions, when you participate in surveys, or when you participate in research activities or initiatives (“ Research ”). This includes Personal Data, such as name, address, email address, telephone number and other information that may be appropriate in order to participate. We may also launch surveys that ask you to answer questions about a range of topics from Personal Data to brand and product preferences. Promotions or surveys may be run by a WordTree LLC service provider. In such instances, Personal Data may be collected directly by and/or shared with WordTree LLC, the service provider, and/or business partner, including for marketing purposes.
(e) When you engage with our online communities or advertising . WordTree LLC may collect your Personal Data when you engage with any online communities, to the extent that WordTree LLC has created the same. This includes when you click on advertisements, interact with our social media pages, submit content, leave reviews, or otherwise enter information into comment fields, blogs, message boards, events, and other community forums sponsored by or affiliated with WordTree LLC.
(f) When you access third party products and services . We may allow you to (i) register and pay for third-party products and services, (ii) pay for the Services, or (iii) otherwise interact with another website, mobile application, or Internet location (collectively “ Third Party Sites ”) through our Services, and we may collect Personal Data that you share with Third Party Sites through our Services.
(h) When WordTree LLC collects data from third parties or publicly-available sources . WordTree LLC may obtain certain data about you from third party sources to help us provide and improve the Services and for marketing and advertising. We may combine your Personal Data with data we obtain from our Services, other users, or third parties to enhance your experience and improve the Services, such as providing you with a single point of sign on for our Services and/or building an account dashboard letting you understand how to access and control all the Services you use from a single location.
(i) When we collect cookies, device ID’s, location, and other tracking technologies. We may collect certain Personal Data using cookies and other technologies such as web beacons, device ID’s, advertising ID’s, HTML5 local storage, Flash cookies, and IP addresses. We specifically use browser cookies for different purposes, including cookies that are strictly necessary for functionality and cookies that are used for personalization, performance/analytics, and advertising.
(j) When we aggregate or centralize data . WordTree LLC may aggregate and centralize Personal Data for purposes of analytics, innovation, and to provide enhanced services to our customers and end-users.
How WordTree LLC Discloses Personal Data.
WordTree LLC may disclose your Personal Data for the purposes as described in Section 2 and in the following ways:
(a) Affiliates . With companies, ventures or projects that are owned or controlled by WordTree LLC, and internally within WordTree LLC, in order to provide and improve Services, for marketing purposes, and for advertising.
(b) Service Providers and Vendors . With business partners, marketing partners, vendors and contractors to provide, improve, and personalize the Services.
(c) SNS Providers . With SNS providers when we use social network widgets, buttons, or plug-ins in our Services.
(d) Advertising and Marketing Purposes . With advertising and marketing partners for advertising and marketing purposes on WordTree LLC’s behalf and on behalf of third parties. With companies involved in interest-based advertising, including web, mobile app and other advertising. This advertising consists of WordTree LLC and third-party advertisements that are personalized and displayed on our sites and apps and through other channels.
(e) Analytics . With certain companies for purposes of analytics and improvement of the Services.
(g) Sale . With prospective or actual purchasers, investors, or successor entities in connection with a contemplated reorganization or an actual reorganization of our business, in connection with financing, a sale, or other transaction involving the disposal of all or part of our business or assets, including for the purpose of permitting the due diligence required to decide whether to proceed with a transaction, pursuant to assurances of sufficient data handling practices and safeguards.
Legal Basis for Processing.
(a) No Requirement to Participate . You may choose not to provide WordTree LLC with your Personal Data; however, if you choose not to provide your Personal Data, you may not be able to enjoy the full range of Services.
(b) Rights with Respect to Personal Data . You have the following rights:
(i) Right of access to your Personal Data (Art. 15 GDPR). You have the right to ask WordTree LLC for confirmation on whether WordTree LLC is processing your Personal Data, and access to the Personal Data and related information on that processing (e.g., the purposes of the processing, or the categories of Personal Data involved).
(ii) Right to rectification (Art. 16 GDPR). You have the right to have your Personal Data corrected, as permitted by law.
(iii) Right to erasure (Art. 17 GDPR). You have the right to ask WordTree LLC to delete your Personal Data, as permitted by law. This right may be exercised among other things: (A) when your Personal Data is no longer necessary for the purposes for which it was collected or otherwise processed, (B) when you withdraw consent on which processing is based according to Art. 6(1)(a) or Art. 9(2)(a) GDPR and where there is no other legal ground for processing, (C) when you object to processing pursuant to Art. 21(1) GDPR and there are no overriding legitimate grounds for the processing, or when you object to the processing pursuant to Art. 21(2) GDPR, or (D) when your Personal Data has been unlawfully processed.
(iv) Right to restriction of processing (Art. 18 GDPR). You have the right to request the limiting of our processing under limited circumstances, including: when the accuracy of your Personal Data is contested, when the processing is unlawful and you oppose the erasure of your Personal Data and request the restriction of the use of your Personal Data instead, or when you have objected to processing pursuant to Art. 21(1) GDPR pending the verification whether the legitimate grounds of WordTree LLC override your grounds.
(v) Right to data portability (Art. 20 GDPR). You have the right to receive the Personal Data that you have provided to WordTree LLC, in a structured, commonly used and machine-readable format, and you have the right to transmit that information to another controller, including to have it transmitted directly, where technically feasible.
(vi) Right to object (Art. 21 GDPR). You have the right to object to WordTree LLC’s processing of your Personal Data, as permitted by law. This right is limited to processing based on Art. 6 (1)(e) or (f) GDPR, and includes profiling based on those provisions, and processing for direct marketing purposes. After which, we will no longer process your Personal Data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.
(c) Disclosure . WordTree LLC may disclose your Personal Data in the following ways:
(ii) Marketing . Where WordTree LLC is legally required to do so, we ask you for your prior consent before providing you with promotional materials or information. You may revoke your consent at any time (this will not affect the processing of your Personal Data undertaken until the revocation). If you want to stop receiving promotional materials, etc., you can do by contacting WordTree LLC.
(d) Legal Basis for Processing under the GDPR . In this section, WordTree LLC hereby provides information on the legal basis for processing of your Personal Data as required by Art. 13 and 14 of the GDPR:
(i) When you register for a Company account or interact with our Services, such processing is necessary for the performance of our Services. Art. 6(1)(b) GDPR.
(ii) When we collect Location Data following your prior consent, we process such data on the basis of your prior consent. Art. 6(1)(a) GDPR. In other cases, where we process your Location Data without consent, for example in order to provide our Services, such processing is necessary for the performance of our Services. Art. 6(1)(b) GDPR.
(iii) When you communicate with us or sign up for promotional materials, we process such data on the basis of our legitimate interest (Art. 6(1)(f) GDPR) and our legitimate interest is to provide you with our promotional messages. Where we are required under applicable local law to obtain your consent for sending you marketing information, the legal basis is your consent. Art. 6(1)(a) GDPR.
(iv) When you participate in special activities, offers, or programs. For non-sensitive Personal Data, we process such data on the basis of our legitimate interest (Art. 6(1)(f) GDPR) and our legitimate interest is to provide you with our promotional messages or to allow you to participate in our special activities, offers or programs.
(v) When you engage with our advertising and we actively collect your Personal Data in this context, we process such data on the basis of our legitimate interest (Art. 6(1)(f) GDPR), and our legitimate interest is to provide you with our promotional messages.
(vi) When you access third party products and services and we obtain Personal Data about you from such third party sources. For Personal Data that we need in order to perform the Services (e.g. if you pay for third party products through our Services), such processing is necessary for the performance of our Services. Art. 6(1)(b) GDPR.
(vii) When we collect data from third parties or publicly-available sources, for Personal Data which we need in order to perform the Services (e.g., for email verification purposes), such processing is necessary for the performance of our Services. Art. 6(1)(b) GDPR. Regarding other Personal Data, we process such data on the basis of our legitimate interest (Art. 6(1)(f) GDPR) and our legitimate interest is providing you with better Services and to enable you to use our Services more efficiently.
(ix) When we leverage and/or collect cookies, device IDs, Location Data, data from the environment, and other tracking technologies, we process such data on the basis of your consent (Art. 6(1)(a) GDPR), and based on our legitimate interest (Art. 6(1)(f) GDPR), where we do not obtain your consent and our legitimate interest is to provide you with better Services or marketing.
(x) When we aggregate or centralize data, such processing is either necessary for the performance of our Services (Art. 6(1)(b) GDPR) or we process such data on the basis of our legitimate interest (Art. 6(1)(f) GDPR) and our legitimate interest is to provide you with better or customized Services and marketing.
(xi) When you sign up for our services that consist of social sharing and communication with others, where we collect your consent in such case, we process such data on the basis of your prior consent (Art. 6(1)(a) GDPR) and where we do not collect your consent in such case, such processing is necessary for the performance of our Services (Art. 6(1)(b) GDPR).
(xii) When we disclose Personal Data to our affiliates and partners, and to our service providers and vendors, where we collect your consent in such case, we process such data on the basis of your prior consent. Art. 6(1)(a) GDPR. Where we do not collect your consent in such case, such processing is necessary for the performance of our Services (Art. 6(1)(b) GDPR), or we process such data on the basis of our legitimate interest (Art. 6(1)(f) GDPR), and our legitimate interest is to provide you with better Services and marketing.
(xiii) When we process or share Personal Data in the event of an actual or contemplated sale, we process such data for our legitimate interest in offering, maintaining, providing, and improving our Services. Art. 6(1)(f) GDPR.
(xiv) When we conduct analytics, we process such data on the basis of our legitimate interest (Art. 6(1)(f) GDPR), and our legitimate interest is to enhance your experience and to develop and improve our Services.
(xv) When we investigate suspected illegal or wrongful activity, we process such data on the basis of our legitimate interest (Art. 6(1)(f) GDPR), and our legitimate interest is to ensure compliance with legal requirements and law enforcement requests and for public safety purposes.
(e) Right to lodge a complaint before the Data Protection Authority . WordTree LLC encourages you to contact us directly and allow us to work with you to address your concerns. Regardless, you have the right to communicate a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or the place of the alleged infringement. You have the right to do so if you consider that the processing of Personal Data relating to you infringes applicable data protection laws.
(g) How to contact us or our Privacy Office . In case of questions about the processing of your Personal Data please contact us at firstname.lastname@example.org . If we are required under applicable law to appoint a data protection officer (DPO), you can contact the DPO that is responsible for your country/region at email@example.com
Consent as a Basis for Processing
In some cases, WordTree LLC will ask for your consent to process your Personal Data. You may indicate your consent in a number of ways, including, as permitted by law, checking or ticking a box (or some sort of equivalent action) to indicate your consent when (i) providing us with your Personal Data through our Services or a form; or (ii) registering or creating a Company account. We may request your consent for a number of activities including:
(a) Marketing and Communication . We may ask for your consent to contact you by telephone, text message, and/or email about other offers, products, events, or Services that we think may be of interest to you and for other marketing purposes.
(b) Sharing with Third Party Services . We may also ask for your consent to share your Personal Data with certain third party business partners in order to offer certain services or programs. To withdraw consent, please go to the preferences of the specific third party service.
(c) Third Party Marketing . We may ask for your consent to provide Personal Data to allow third parties to contact you regarding their products, services, or offers. To withdraw consent, please go to the preferences of the specific third party.
(d) Research . WordTree LLC may request your consent to use your Personal Data for Research purposes. WordTree LLC may also request your consent to contact you to determine your interest to participate in certain Research initiatives and to share identifying results. For market Research, we may ask questions on behalf of business partners and share your response with business partners.
(f) Transfer of Data . WordTree LLC transfers data to the United States for processing. We may request your consent for this transfer or the transfer, in other cases, may be justified by a legal basis other than consent.
(g) Automated Processing . WordTree LLC may use some automated processing to provide our Services and to make recommendations in the context of specific Services. This processing is strictly necessary for providing certain Services (and, in some cases, is the service itself) and is not covered by consent. Other automated processing is not significant either due to the nature of the data or the decisions being made or recommended, and so consent is not required. However, for automated processing that is significant and related to sensitive Personal Data, prior to sharing or using such data, WordTree LLC will first seek your consent. For the subset of automated processing included in ad profiling for ad targeting, you can change your consent status (for Website Services) by disabling advertising cookies.
(h) To Enable Social Sharing and Connect with Us on Social Media . Some of the Services consist of social sharing and communication with others. If you sign up for such Services, WordTree LLC may ask for your consent to use your information to enable sharing as described in the Service. WordTree LLC may also ask for your consent when you connect with us through a SNS.
(i) Promotions . WordTree LLC may ask you for permission to use your Personal Data for special offers, events, sweepstakes, and other promotions. We may use the Personal Data we collect during promotions, to administer the promotion, verify identity and age, and to communicate with you about the promotion.
Managing Preferences and Withdrawing Consent
You may, at any time, withdraw your consent with future effect and without affecting the lawfulness of processing of your Personal Data based on the consent you provided before you withdrew it, and exercise other controls regarding Website and online data collection, interest-based advertising, your communication settings, and device preferences. Depending on the Services, collection and use of Personal Data may be required for the Services to work. WordTree LLC provides you with several ways to manage your preferences:
(a) Cookie Use and Controls . Cookies are pieces of data stored in your web browser that are transmitted to websites to remember your browser over time and distinguish it from other users. Cookies are used to remember you and personalize your web experience and for security, analytics, marketing, and interest-based advertising. WordTree LLC’s cookies are placed and read by our web servers, while other cookies are placed and read by other companies’ web servers. You can block and control cookies using the information noted in this section. If you block all cookies, certain functionality on our website and Services will not work.
(b) IP Address Use . An IP address is an identifier assigned by a network to a computer, mobile device, or routing device. WordTree LLC’s advertising and analytics partners may use IP addresses to group or correlate devices for purposes of analytics, security and anti-fraud purposes, interest-based advertising, ad targeting, ad attribution, and limiting ad frequency.
(c) Web Pixels or Beacons . Pixels are extremely small image files that, when loaded by your web browser, cause the browser to make a network request to the party corresponding to the pixel. If that party’s cookies are currently stored in your browser, those cookies will be transmitted with the request. Beacons can be used on web pages for advertising or to confirm the opening of a marketing email. When used in conjunction with cookies for interest-based-advertising, the cookie controls above can be used to control the purpose for which they are used.
(d) HTML5 Local Storage . HTML5 local storage in the browser is different from cookies, but can be used for the same purpose (i.e., to pair a tracking ID to a particular web server with your web browser so that the web server can identify your web browser over time). You can control the purpose for which HTML5 local storage is used by using the cookie controls outlined above and in our browser settings.
(e) Flash Cookie Use . Flash cookies are “local shared objects” used by Flash player to store data, similar to cookies. If you have Flash installed, and wish to delete, block, or manage Flash cookies, please use the Flash settings panel made available by Adobe.
(f) Social Networks . Social network widgets, buttons, and plug-ins on our Websites passively transmit data regarding a social network’s members to that social network, even when a button is not clicked. These technologies may allow a social network (e.g., Facebook, Twitter or YouTube) to personally identify its members and to know the web pages its members have visited. This is the case where social network buttons are embedded, regardless of whether a button is “clicked”, “pressed” or “selected”. If you belong to a social network or use these categories of web services, you should review the privacy policies of those services to understand the nature of the data that they collect and what, if any, options the service offers to control how data is collected and used. If you disable advertising cookies, the passive tracking associated with these buttons will be blocked on our sites.
(g) Mobile Device Advertising ID’s, Location and other Data Use . WordTree LLC’s Services may transmit Device ID’s, Location Data, and data from sensors to us and our partners, including our advertising partners. Device IDs include IDs associated with your mobile device carrier, platform-specific IDs such as Android ID, Google AID, and Apple's IDFA, and IDs that are part of your device hardware, such as WiFi address and serial number. Exactly which Device IDs are transmitted can depend on your mobile device platform and the version of your operating system. WordTree LLC’s Services may also collect Device IDs and network addresses (including IP addresses, MAC addresses, and SSIDs) from other, in-range or networked devices and WiFi access points. WordTree LLC may use Device IDs, coarse location and Location Data, and data from sensors, including the local network, for strictly necessary purposes; improving our Services and analytics; personalization and preferences; and cross-app, cross-device, interest-based advertising.
(h) Withdrawing Consent for Use of Mobile Device ID’s, and for Analytics and Advertising . Activating the “Limit Ad Tracking”, “Opt out of Ads Personalization”, or equivalent setting from your mobile device will transmit a signal to WordTree LLC and any third parties that we use and when that signal is received by WordTree LLC or third parties, it communicates your choice to not have Device IDs used for purposes of advertising or analytics. WordTree LLC honors the signal and requires that our third party advertising and analytics partners do the same.
(i) Consent Settings for Communication . After signing up for email communications, you can choose to unsubscribe using the unsubscribe link in any commercial email we send. If you use more than one of WordTree LLC’s Services, then unsubscribing from the emails relating to that Service may not stop you from receiving emails from other Services. Please note that if you unsubscribe from all emails, then this means that you have unsubscribed from all emails other than strictly necessary emails. You will still receive email communications from us if they are strictly necessary to provide the Services or to confirm or validate a transaction, recover accounts, etc.
Transfers of Personal Data to Other Countries
WordTree LLC does not knowingly collect Personal Data online from children under the age of 13 (note that the minimum age may vary based on country/region, and on local law). If you become aware that a child has provided us with Personal Data without parental consent, please contact us at firstname.lastname@example.org . If WordTree LLC becomes aware that a child under the age of 13 has provided us with Personal Data without parental consent, then the Company will take steps to remove the data and cancel the child’s account.
If you have any questions, comments, or concerns about how we handle your Personal Data, then you may contact us through our support team or write to us at:
5868 E. 71st Street
Indianapolis, IN 46220
Fax (317) 576-8027