Effective: June 12, 2018
EU-US and Swiss-US Privacy Shields
POP is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. POP complies with the Privacy Shield Principles for all onward transfers of personal data from the EU or Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, POP is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, POP may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described at www.privacyshield.gov/welcome, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Types of information we gather and how we use it
Information provided to us
We collect information from Clients directly when you register as a new user of WordFly or email customer support, such as email address, first and last name, job title, and phone number. We may also collect information from Clients when you: (1) sign up to receive email newsletters from us; (2) request additional information, customer service, or other assistance; and (3) participate on social media accounts involving WordFly properties.
POP collects information under the direction of its Clients; in these circumstances, POP has no direct relationship with the individuals whose personal data it processes. We work with our Clients to help them provide notice to their Subscribers concerning the purpose for which personal information is collected.
Information we collect when you interact with WordFly
When you interact with the WordFly website or open communications you receive from Clients, our servers may keep an activity log that does not identify you individually. Generally, we collect the following categories of Information:
- We, and third parties acting on our behalf, collect and store certain information about your computer, or other device that you use to access the WordFly website by storing strings of code called “Cookies” on your computer or using similar tracking tags such as beacons, tags, and scripts. This information may include IP address, browser type, browser language, and other transactional information. We and third parties may use this information to analyze trends, administer the site, track users movements around the site, gather demographic information about our user base. We may receive reports based on the use of these technologies on an individual as well as aggregated basis.
- We gather certain other information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, reading history of the pages you view and/or clickstream data. We use this information to provide you a more customized experience.
We may combine this automatically collected log information with other information we collect or receive about you. We do this to improve the Services we offer, including analytics and site functionality.
Information related to campaigns
Any email addresses, mobile phone numbers, and supplemental Subscriber data that is imported by Clients into WordFly for use in a campaign is stored in WordFly. Any data collected from published surveys, forms, landing pages, RSVPs, or other data collection techniques are stored in WordFly. We also store all information that is used in campaigns that Clients have sent or are going to send. After the campaign is sent, we store who opened, clicked, bounced, and shared the campaign. POP stores all the data Clients collect when publishing surveys, forms, landing pages, and RSVPs through WordFly. WordFly has no control over the content or data requested in survey or other form building tools. POP uses the information it collects to provide its Services to Clients.
Benchmark reporting for Clients
If a Client chooses to opt in to the Benchmark Reporting datashare program, we will take data created through the Client's use of WordFly, remove all identifiable information about such use, and then combine that data with anonymous data from other organizations in comparable industries and offer benchmark reports in an aggregate form. This data includes the Client's industry, industry category, region, open rates, click rates, and bounce rates from the Client's campaigns.
Information used to communicate with Client Users
- Account Maintenance. We use your email address to uniquely identify you when you log in and to communicate with you about your account. You will receive an email from us when you are added as a new user. If you forget your password, we will email you instructions for how to reset your password.
- System Alerts. You may be sent brief system alerts to let you know about planned updates to the system that may affect your account.
- WordFly User News. We send a monthly email announcing new features, learning opportunities, and information about how to use WordFly. From time to time we will also promote other POP product offerings. You can unsubscribe at any time by clicking the unsubscribe link in the email.
- Client Support. We use the email address you provide to us to communicate with you about support issues and feedback about WordFly.
- Billing. If you are the billing contact for your organization, we will send you invoices, receipts, and notices of delinquency related to your account via email.
To service providers
We may provide your personal information to companies that provide services to help us with our business activities such as customer support. These companies are authorized to use your personal information only as necessary to provide these services to us.
We may transfer personal information to companies that help us provide WordFly and the Services.
We partner with third parties to either display advertising on our Website or to manage our advertising on other sites and in WordFly communications. Our third party partners may use tracking technologies such as cookies to gather information about activities within WordFly and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here). Please note this does not opt you out of being served ads. You will continue to receive generic ads.
The third party tracking technologies on our Website include:
- Google Analytics: https://www.google.com/policies/privacy/partners/
- Facebook: https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen
- Twitter: https://help.twitter.com/en/rules-and-policies/twitter-cookies
Please follow these links for more information about those parties’ data practices and their opt-out options.
Social Media (Features) and Widgets
Client's Subscriber Data and Lists
Except as disclosed below, we won't ever contact, share, or sell our Client's Subscriber data and lists. Client's Subscriber data and lists belong to the Client. They can be exported at any time from WordFly. We will only contact a Subscriber on a Client's list:
- In response to a complaint;
- If a subscriber has contacted us directly;
- With the Client’s prior consent to do so.
We may use Subscriber Data and Lists to support and improve the Services
Including adding features and providing benchmarking and other comparison information based on aggregating and analyzing data.
Information from other sources
For reporting purposes, we may use a Subscriber's email address to obtain additional information that appears to be related to the email address, such as a name and whether the Subscriber participates in social media websites. This information may be obtained by searching the Internet directly or through one or more services.
How we secure your data
What we do
- WordFly requires an account name, username, and password to log in.
- Your password and security question answer are encrypted and known only to you. We cannot see your passwords. We can only reset them. If you forget your password, you will need to reset it in WordFly by answering your security question correctly.
- Any data that WordFly sends or receives is electronically encrypted using secure socket layer technology (SSL) when sending over network resources.
- In addition, we follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it.
- No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.
Client security responsibilities as a user
- Click the Sign Out link in the upper-right corner of WordFly when you are finished using WordFly to prevent unauthorized access from your computer.
- Clients must remove users when they no longer work for the Client.
- Maintain the confidentiality of any account name and password provided to you. You are solely responsible for uses of any account provided to you, whether or not authorized by you.
- Immediately notify us of any unauthorized use of your account.
- Immediately notify us if you believe a survey or form is being used maliciously
- Use the Secure Upload link provided inside WordFly if you need to send sensitive data, such as Subscriber lists, for troubleshooting purposes.
- Do not use surveys or other form tools to request highly sensitive personal identifying information like social security number, credit card numbers, drivers license, bank account information, or other.
- If you as a Client have any questions about the security of personal information in WordFly, you can contact us at firstname.lastname@example.org.
To meet legal requirements
In certain situations, WordFly may be required to disclose information collected from or about you or Subscriber data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; if required to provide such information by a court, administrative or governmental order, or subpoena or other legal process; or if required to provide information to people helping us comply with legal and other requirements such as attorneys and accountants.
To detect, investigate, and prevent activities that may be illegal or violate the WordFly Acceptable Use Policy
From time to time we look at the content of email campaigns sent through WordFly in order to ensure that the Acceptable Use Policy is followed. This is necessary to help prevent spam, ensure compliance with data privacy and anti-spam legislation, and ensure higher deliverability for all campaigns sent through WordFly.
To transfer information in the event that we change our ownership or corporate organization while providing WordFly
Links to Other Web Sites
Publicity and Testimonials
Our Web site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us as described below under “Questions + Comments”. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
Opt-out of Communications
POP has no direct relationship with the individuals whose personal data it processes. If you are a subscriber of one of our Clients and would no longer like to be contacted by the Client, please contact the Client that you interacted with directly.
If you are a Client and would like to stop receiving our newsletter or marketing emails, please follow the unsubscribe instructions included in these emails or you can contact us at email@example.com.
Notice of changes
Information for users in Europe and elsewhere outside of the United States
If you use WordFly outside of the United States, you understand that we may collect, process, and store your personal data in the United States and other countries. The laws in the U.S. regarding personal information may be different from the laws of your state or country. Any such transfers will comply with safeguards as required by relevant law. If applicable, you may have a right to claim compensation for damages caused by a breach of relevant data protection laws.
Users in the European Economic Area (“EEA”) and Switzerland
If you are a resident of the EEA or Switzerland, the following information applies with respect to personal data collected through your use of WordFly.
Purposes of processing and legal bases for processing
Right to lodge a complaint
Users that reside in the EEA or Switzerland have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for data protection authorities are available here.
Personal information we collect may be transferred to, and stored and processed in, the United States or any other country in which we or our affiliates or subcontractors maintain facilities. WordFly will ensure that transfers of personal information to a non-EEA country or an international organization are subject to appropriate safeguards.
You are entitled to the rights under Chapter III of the EU General Data Protection Regulation or Section 2 of the Swiss Federal Act on Data Protection with respect to the processing of your personal data, which include the right to access and rectify your personal data and to request erasure of your personal data. To exercise these rights, contact via our contact form or at the address below.
If you are a Data Protection Authority in the EEA with questions about this policy or WordFly, please contact us directly as described under Questions + Comments below. Alternatively, you can contact our EEA Representative at the following address, who will forward your correspondence to us:
EEA GDPR Representative
Condé Nast International
The Adelphi, 1-11 John Adam Street
London, WC2N 6HT
Note: If you do not represent a Data Protection Authority in the EEA, please do not use the address above, but instead direct your question(s) to us as described directly below.
Questions + Comments
Attention: WordFly Privacy Department
1326 5th Ave
Seattle, WA 98101