Who We Are and What This Policy Covers

This Privacy Policy applies to information that we collect about you when you use our website.

Throughout this Privacy Policy we’ll refer to our websites, mobile applications, and other products and services collectively as “Services.” 

Please note that this Privacy Policy does not apply to any of our products or services, that have a separate privacy policy.

Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.

Information We Collect

We only collect information about you if we have a reason to do so — for example, to provide our Services, to communicate with you, or to make our Services better.

We collect this information from three sources: if and when you provide information to us, automatically through operating our Services, and from outside sources. Let’s go over the information that we collect.

Information You Provide to Us

It’s probably no surprise that we collect information that you provide to us directly. Here are some examples:

• Payment and contact information: There are various ways in which you may provide us payment information and associated contact information. For example, if you buy something from us  we’ll collect information to process those payments and contact you.  We also keep a record of the purchases you’ve made. You may also provide us with financial details to set up a payments integration, like the email address for your Stripe or PayPal account or your bank account information. 
• Communications with us: You may also provide us with information when you respond to surveys, communicate with us about a support question, or sign up for a newsletter. When you communicate with us via form, email, phone, or otherwise, we store a copy of our communications (including any call recordings as permitted by applicable law).

Information We Collect Automatically

We also collect some information automatically:

• Transactional information: When you make a purchase through our Services, we collect information about the transaction, such as product details, purchase price, and the date and location of the transaction. This includes when you purchase something we sell or when you use our Services  to buy something from a third party.
• Usage information: We collect information about your usage of our Services. We also collect information about what happens when you use our Services (e.g., page views, support document searches and other parts of our Services) along with information about your device (e.g., screen size, name of cellular network, and mobile device manufacturer). We use this information to, for example, provide our Services to you, get insights on how people use our Services so we can make our Services better, and understand and make predictions about user retention.
• Location information: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our Services from certain geographic regions.
• Information from cookies & other technologies: A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Pixel tags (also called web beacons) are small blocks of code placed on websites and emails. Positive Increment uses cookies and other technologies like pixel tags to help us identify and track visitors, usage, and access preferences for our Services, as well as track and understand email campaign effectiveness. For more information about our use of cookies and other technologies for tracking, including how you can control the use of cookies, please see our Cookie Policy.

Information We Collect from Other Sources

We may also get information about you from other sources.

The information we receive depends on which services you use or authorize and what options are available.

How and Why We Use Information

Purposes for Using Information

We use information about you for the purposes listed below:

• To provide our Services. 
• To ensure quality, maintain safety, and improve our Services. For example, by providing automatic upgrades and new versions of our Services. Or, for example, by monitoring and analyzing how users interact with our Services so we can create new features that we think our users will enjoy.
• To protect our Services, our users, and the public.
• To fix problems with our Services. For example, by monitoring, debugging, repairing, and preventing issues.
• To customize the user experience. 
• To communicate with you. For example, by emailing you to ask for your feedback, texting you to verify your payment. If you don’t want to hear from us, you can opt out of communications at any time. 

Legal Bases for Collecting and Using Information

A note here for those in the European Union about our legal grounds for processing information about you under EU data protection laws, which is that our use of your information is based on the grounds that:

(1) The use is necessary in order to fulfill our commitments to you under the applicable terms of service or other agreements with you or is necessary to administer your account — for example, in order to enable access to our website on your device; or

(2) The use is necessary for compliance with a legal obligation; or

(3) The use is necessary in order to protect your vital interests or those of another person; or

(4) We have a legitimate interest in using your information — for example, to provide and update our Services; to improve our Services so that we can offer you an even better user experience; to safeguard our Services; to communicate with you; to measure, gauge, and improve the effectiveness of our advertising; and to understand our user retention and attrition; to monitor and prevent any problems with our Services; and to personalize your experience; or

(5) You have given us your consent — for example before we place certain cookies on your device and access and analyze them later on, as described in our Cookie Policy.

Sharing Information

How We Share Information

We share information about you in limited circumstances, and with appropriate safeguards on your privacy. These are spelled out below, as well as in the section called Ads and Analytics Services Provided by Others:

• Subsidiaries and independent contractors: We may disclose information about you to our subsidiaries and independent contractors who need the information to help us provide our Services or process the information on our behalf. We require our subsidiaries and independent contractors to follow this Privacy Policy for any personal information that we share with them.
• Third-party vendors: We may share information about you with third-party vendors who need the information in order to provide their services to us, or to provide their services to you or your site. This includes payment providers that process your credit and debit card information, payment providers you use for your own ecommerce operations, fraud prevention services that allow us to analyze fraudulent payment transactions, cloud storage services, postal and email delivery services that help us stay in touch with you,  email support services that help us communicate with you, those that help us understand and enhance our Services (like analytics providers); those that make tools to help us run our operations (like programs that help us with task management, scheduling, word processing, email and other communications, and collaboration among our teams); other third-party tools that help us manage operations; and companies that make products available on our websites, who may need information about you in order to, for example, provide technical or other support services to you. We require vendors to agree to privacy commitments in order to share information with them. Other vendors are listed in our more specific policies (e.g., our Cookie Policy).
• Legal and regulatory requirements: We may disclose information about you in response to a subpoena, court order, or other governmental request.
• To protect rights, property, and others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of Positive Increment, third parties, or the public at large.
• Business transfers: In connection with any merger, sale of company assets, or acquisition of all or a portion of our business by another company, or in the unlikely event that Positive Increment goes out of business or enters bankruptcy, user information would likely be one of the assets that is transferred or acquired by a third party. If any of these events were to happen, this Privacy Policy would continue to apply to your information and the party receiving your information may continue to use your information, but only consistent with this Privacy Policy.
• With your consent: We may share and disclose information with your consent or at your direction. 
• Aggregated or de-identified information: We may share information that has been aggregated or de-identified, so that it can no longer reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services.
  
• Published support requests: If you send us a request for assistance (for example, via a support email or one of our other feedback mechanisms), we reserve the right to publish that request in order to clarify or respond to your request, or to help us support other users.

Information Shared Publicly

Information that you choose to make public is disclosed publicly.

Please keep this in mind when deciding what you would like to share publicly.

How Long We Keep Information

We generally discard information about you when it’s no longer needed for the purposes for which we collect and use it — described in the section above on How and Why We Use Information — and we’re not legally required to keep it.

For example, we keep web server logs that record information about a visitor to our websites, like the visitor’s IP address, browser type, and operating system, for approximately 30 days. 

Security

While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so. We monitor our Services for potential vulnerabilities and attacks.

Choices

You have several choices available when it comes to information about you:

• Set your browser to reject cookies: You can usually choose to set your browser to remove or reject browser cookies before using this website, with the drawback that certain features  may not function properly without the aid of cookies.

Your Rights

If you are located in certain parts of the world, including some US states and countries that fall under the scope of the European General Data Protection Regulation (aka the “GDPR”), you may have certain rights regarding your personal information, like the right to request access to or deletion of your data.

European General Data Protection Regulation (GDPR)

If you are located in a country that falls under the scope of the GDPR, data protection laws give you certain rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:

• Request access to your personal data;
• Request correction or deletion of your personal data;
• Object to our use and processing of your personal data;
• Request that we limit our use and processing of your personal data; and
• Request portability of your personal data.

You also have the right to make a complaint to a government supervisory authority.

US Privacy Laws

Laws in some US states require us to provide residents with additional information about the categories of personal information we collect and share, where we get that personal information, and how and why we use it. You’ll find that information in this section (if you are a California resident, please note that this is the Notice at Collection we are required to provide you under California law).

In the last 12 months, we collected the following categories of personal information, depending on the Services used:

• Identifiers (like your name, contact information, and device and online identifiers);
• Commercial information (your billing information and purchase history, for example);
• Internet or other electronic network activity information (such as your usage of our Services.)
• Geolocation data (such as your location based on your IP address);
• Inferences we make (such as likelihood of retention or attrition).

You can find more information about what we collect and sources of that information in the Information We Collect section above.

We collect personal information for the business and commercial purposes described in the How and Why We Use Information section. And we share this information with the categories of third parties described in the Sharing Information section. We retain this information for the length of time described in our How Long We Keep Information section.

In some US states you have additional rights subject to any exemptions provided by your state’s respective law, including the right to:

• Request a copy of the specific pieces of information we collect about you and, if you’re in California, to know the categories of personal information we collect, the categories of business or commercial purpose for collecting and using it, the categories of sources from which the information came, and the categories of third parties we share it with;
• Request deletion of personal information we collect or maintain;
• Request correction of personal information we collect or maintain;
• Opt out of the sale or sharing of personal information;
• Receive a copy of your information in a readily portable format; and
• Not receive discriminatory treatment for exercising your rights.

You can find detailed metrics about Automattic’s compliance with these rights in our Privacy Report.

Right to Opt Out

We never directly sell your personal information in the conventional sense (i.e., for money).

We may share your information as necessary with our third-party service providers to provide our services to you. To the extent that we share your information with certain advertising, marketing, or analytics vendors, this can be considered a “sale” or “share” in certain U.S. States, which you may have the right to opt out of.

You can learn more about this sharing and how to opt out by clicking conctacting [email protected]

Our opt-out is managed through cookies, so if you delete cookies, your browser is set to delete cookies automatically after a certain length of time, or if you visit sites in a different browser, you’ll need to make this selection again.

We also respect the GPC browser signal and will treat it as a valid means of communicating your desire to opt out.

We do not collect or process your sensitive (and potentially sensitive) personal information except where it is strictly necessary to provide you with our service, where the processing is not for the purpose of inferring characteristics about you, or for other purposes that do not require an option to limit under California law. We don’t knowingly sell or share personal information of those under 16.

Your Information & Personalized Advertising

We and our users do use cookies to share certain device identifiers and information about your browsing activities with our advertising partners, and those advertising partners may use that information to show you personalized ads on some of our users’ sites and some of our own.

The personal information we share includes online identifiers; internet or other network or device activity (such as cookie information, other device identifiers, and IP address); and geolocation data (approximate location information from your IP address). These disclosures may be considered a “sale” or “share” of information under some US state privacy laws. We do not sell (or share) information through our ads program that identifies you personally, like your name or contact information. Learn how you can opt out by conctacting [email protected]

Contacting Us About These Rights

You can to contact us about any of these rights, at [email protected]

When you contact us about one of your rights under this section, we’ll need to verify that you are the right person before we disclose or delete anything. You can also designate an authorized agent to make a request on your behalf by giving us written authorization. We may still require you to verify your identity with us.

Appeals Process for Rights Requests Denials

In some circumstances we may deny your request to exercise one of these rights. For example, if we cannot verify that you are the owner we may deny your request to access the personal information . As another example, if we are legally required to maintain a copy of your personal information we may deny your request to delete your personal information.

In the event that we deny your request, we will communicate this fact to you in writing. You may appeal our decision by responding in writing to our denial email and stating that you would like to appeal. All appeals will be reviewed by an internal expert who was not involved in your original request. In the event that your appeal is also denied this information will be communicated to you in writing. 

If your appeal is denied, in some US states you may refer the denied appeal to the state attorney general if you believe the denial is in conflict with your legal rights. The process for how to do this will be communicated to you in writing at the same time we send you our decision about your appeal.

Other Things You Should Know

Transferring Information

Because our Services are offered worldwide, the information about you that we process when you use the Services in the EU may be used, stored, and/or accessed by individuals operating outside the European Economic Area (EEA) who work for us, other members of our group of companies, or third-party data processors. This is required for the purposes listed in the How and Why We Use Information section above.

When providing information about you to entities outside the EEA, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this Privacy Policy as required by applicable law. These measures include entering into European Commission approved standard contractual arrangements with entities based in countries outside the EEA.

You can ask us for more information about the steps we take to protect your personal information when transferring it from the EU.

Ads and Analytics Services Provided by Others

Other parties may provide analytics services via our Services. These analytics providers may set tracking technologies (like cookies) to collect information about your use of our Services and across other websites and online services. These technologies allow these third parties to recognize your device to compile information about you or others who use your device. This information allows us and other companies to, among other things, analyze and track usage, determine the popularity of certain content, and deliver ads that may be more targeted to your interests. Please note this Privacy Policy  does not cover the collection of information by any third-party advertisers or analytics providers.

Privacy Policy Changes

Although most changes are likely to be minor, we might change our Privacy Policy from time to time. We encourage visitors to frequently check this page for any changes to its Privacy Policy. If we make changes, we may provide additional notice (like adding a statement to our homepage or sending you a notification through email.) Your further use of the Services after a change to our Privacy Policy will be subject to the updated policy.