Effective: November 18, 2021
Types of information we gather and how we use it
Information provided to us
We collect information from you 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 you when you: (1) sign up to receive email newsletters from us through the Website or elsewhere; (2) request additional information, customer service, or other assistance; and (3) participate on social media accounts involving our 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 Website or open communications you receive through WordFly from Clients, our servers may keep an activity log that does not identify you individually. Generally, we collect the following categories of Information through the Service:
- 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 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 Website, and gather demographic information about our user base. We may receive reports based on the use of these technologies on an individual and 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 Service, including with respect to analytics and Website 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. Pop 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 Service 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 the 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 the Service. These companies include providers of the following services:
- Payment processing
- Customer service
- Fulfilling subscription services
- Cloud computing infrastructure
Social Media Features and Widgets
The Website includes social media features and widgets, such as the Facebook Like button. These features may collect your IP address, which page you are visiting on our Website, and may set a cookie to enable the feature to function properly. In addition, we may receive personal information about you and your contacts that has been made available to us by the company that provides the social features. You should make sure you are comfortable with your personal information the third party social networking services may make available to us by visiting those services' privacy policies and/or modifying your privacy settings directly with those services. We treat personal information that we receive through third party social networking services in the same ways as all of your personal information we receive through our Service.
Client's Subscriber Data and Lists
- In response to a complaint;
- If a subscriber has contacted us directly;
- If required by law;
- With the Client’s prior consent to do so.
We may use Subscriber Data and Lists to support and improve the Service, including adding features and providing benchmarking and other comparison information by analyzing aggregated and non-personally identifiable 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 in WordFly
What we do
- WordFly requires an account name, username, and password to log in.
- Your password and security question answer are encrypted. We cannot see your passwords. We can only enable a process for you to 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 sensitive personal identifying information like social security number, credit card numbers, drivers license, bank account information, or similar information.
- 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, we 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 may look at the content of email campaigns sent through WordFly to gauge compliance with our Acceptable Use Policy. Nevertheless, we do not make any representations, warranties, covenants or guarantees that: (1) the Website or WordFly, or any portion thereof, will be monitored for accuracy, legality or unacceptable use, (2) apparent statements of fact will be authenticated, or (3) we will take any specific action (or any action at all) in the event of a challenge or dispute regarding compliance or non-compliance with applicable law or the Acceptable Use Policy. We generally do not pre-screen content sent by our Clients using WordFly, so you may be exposed to content you do not agree with or that violates our Acceptable Use Policy.
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 Website 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 “Contact Us”. 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 (WordFly) Client Subscribers
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.
Subscribers in certain jurisdictions have the right to opt-out of (a) disclosures of their personal data to third parties not identified at the time of collection or subsequently authorized, and (b) uses of personal data for purposes materially different from those disclosed at the time of collection or subsequently authorized. If you are a Subscriber with such rights and you are unable to contact our Client directly, you can contact us for assistance in processing your opt-out and/or personal data usage request at email@example.com
Pop (WordFly) Clients
If you are a Client and would like to stop receiving our newsletter or marketing emails, follow the unsubscribe instructions included in these emails or you can contact us at firstname.lastname@example.org. If you would like to inquire about personal data usage, you can also contact us at email@example.com
Notice of changes
The California Consumer Privacy Act (“CCPA”) provides consumers with specific rights regarding their personal information. You have the right to request that businesses subject to the CCPA (which may include our Clients with whom you have a relationship) disclose certain information to you about their collection and use of your personal information over the past 12 months. In addition, you have the right to ask such businesses to delete personal information collected from you, subject to certain exceptions. If the business sells personal information, you have a right to opt-out of that sale. Finally, a business cannot discriminate against you for exercising a CCPA right.
When offering WordFly services to our Clients, Pop acts as a “service provider” under the CCPA and our receipt and collection of any consumer personal information is completed on behalf of our Clients in order for us to provide the Service. Please direct any requests for access or deletion of your personal information under the CCPA to the Client with whom you have a direct relationship.
When using our Website separate from WordFly, you may come directly to us to exercise your rights under CCPA as described in this section. Note that this may require us to confirm your identity by asking you to verify certain information you previously provided, or other methods as practicable.
Right to Know and Access Information: You may access information we maintain about you from your use of our Website by contacting us as described below. If we grant your request, we will provide you with a copy of the personal information we maintain about you in the ordinary course of business. This may include what personal information we collect, use, or disclose about you. We may not fulfill some or all of your request to access as permitted by applicable law.
Deletion of Information: You may request that we delete your personal information collected via the Website. Depending on the scope of your request, we may refrain from granting your request, as permitted by applicable law. For example, we may be legally required to retain your information in our business records. You may submit a deletion request by contacting us as described below.
Authorized Agent: California residents may use an authorized agent on their behalf to exercise a privacy right discussed immediately above. If you are an authorized agent acting on behalf of a California resident to communicate with us or to exercise a privacy right discussed immediately above, you must be able to demonstrate that you have the requisite authorization to act on behalf of the resident and have sufficient access to their laptop, desktop, or mobile device to exercise these rights digitally. If you are an authorized agent trying to exercise rights on behalf of a Pop user, please contact us as described below with supporting verification information, which includes a valid Power of Attorney in the State of California, proof that you have access to the consumer’s interface, and proof of your own identify.
To Exercise Your Rights
Attention: WordFly Privacy Department
1326 5th Ave, Suite 800
Seattle, WA 98101, USA
Please note that your exercise of the above rights is subject to certain exemptions to safeguard the public interest (e.g., the prevention or detection of crime) and our interests (e.g., the maintenance of legal privilege). We will try to comply with your request as soon as reasonably practicable. Requests to exercise these rights may be granted in whole, in part, or not at all, depending on the scope and nature of the request and applicable law. Where required by applicable law, we will notify you if we reject your request and notify you of any reasons we are unable to honor your request.
|Categories of personal information we collect||
|Categories of sources from which the personal information is collected||We collect the personal information directly from you.|
|Business or commercial purpose for collecting or selling personal information||
We collect your personal information to operate the website, respond to your requests and for the following business purposes:
|Categories of third parties with whom we share personal information||We may share your personal information – specifically your IP address, device ID or similar online identifier, with certain third parties, such as social networks and service providers.|
|Specific pieces of personal information we have collected||
Internet Protocol address, device ID
Information for users in Europe and elsewhere outside of the United States
Pop operates its Service in the United States. If you use our Service from outside of the United States, you understand and agree that we may collect, process, and store your personal data in the United States.
While the data protection, privacy, and other laws of the United States might not be as comprehensive as those in your country, this does not change our commitment to safeguard your privacy. Where required, we will implement Standard Contractual Clauses with third parties or rely on such other transfer mechanism to ensure that the transfer of your personal information is lawful. We offer our Clients a Data Processing Addendum available here.
Purposes of processing and legal bases for processing
Although Pop no longer relies on the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks to legitimize transfers of Personal Information from the EU/Switzerland to the U.S., Pop remains registered with the U.S. Department of Commerce, and we adhere to the principles underlying the Privacy Shield (the “Principles”). The United States Federal Trade Commission (FTC) has jurisdiction over our compliance with the Privacy Shield and we are subject to the FTC’s investigatory and enforcement powers. Information regarding the Privacy Shield program and evidence of our certification can be found at Privacy Shield Home. This site also provides Pop Clients the option to invoke binding arbitration through the Privacy Shield Panel if we are not able to resolve your complaint through our existing Data Protection Agreements or with the Federal Data Protection and Information Commissioner. Additional information on the arbitration process is available on the Privacy Shield website at Privacy Shield Home.
Right to lodge a complaint
Users that reside in the UK, 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. UK contact details can be found here.
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.
Please note that for personal information about you that we have obtained or received for processing on behalf our Clients, which determined the means and purposes of processing, all such requests should be made to that Client. We will honor and support any instructions they provide us with respect to your personal information.
Attention: WordFly Privacy Department
1326 5th Ave, Suite 800
Seattle, WA 98101, USA