Your privacy is critically important to us. At Nrlyze, we have a few fundamental principles:
• We are thoughtful about the personal information we ask you to provide and the personal information that we collect about you through the operation of our services.
• We store personal information for only as long as we have a reason to keep it.
• We aim to make it as simple as possible for you to control what information on your website is shared publicly (or kept private), indexed by search engines, and permanently deleted.
• We help protect you from overreaching government demands for your personal information.
• We aim for full transparency on how we gather, use, and share your personal information.
• Our mobile applications (including the WordPress mobile app for Android and iOS)
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:
• Basic account information: We ask for basic information from you in order to set up your account. For example, we require individuals who sign up for an email address and password, along with a username or name
• Content information: You might provide us with information about you in draft and published content (a blog post or comment that includes biographic information about you, or any media or files you upload).
• Credentials: Depending on the Services you use, you may provide us with credentials.
• Communications with us (hi there!): You may also provide us with information when you respond to surveys, communicate with our Happiness Engineers about a support question, post a question in our public forums, or sign up for a newsletter.
• Job applicant information: If you apply for a job with us — awesome! You may provide us with information like your name, contact information, resume or CV, and work authorization verification as part of the application process.
Information We Collect Automatically
We also collect some information automatically:
• Log information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, including the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Services — for example, when you create or make changes to your website on WordPress.com.
• Usage information: We collect information about your usage of our Services. For example, we collect information about the actions that site administrators and users perform on a site 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. We may also collect information about your precise location via our mobile apps (like when you post a photograph with location information) if you allow us to do so through your mobile device operating system’s permissions.
• Stored information: We may access information stored on your mobile device via our mobile apps. We access this stored information through your device operating system’s permissions. For example, if you give us permission to access the photographs on your mobile device’s camera roll, our Services may access the photos stored on your device when you upload a really amazing photograph of the sunrise to your website.
• Interactions with other users’ sites: We collect some information about your interactions with other users’ sites while you are logged in to your account with us, such as your “Likes” and the fact that you commented on a particular post, so that we can, for example, recommend posts we think may interest you. As another example, we collect information about the comments IntenseDebate users make while logged in and use that information to, for example, tally up statistics about your comments (check them out in your dashboard!) and display information about your comments in your IntenseDebate public profile.
Information We Collect from Other Sources
Third-party services may also give us information, like mailing addresses for individuals who are not yet our users (but we hope will be!). We use this information for marketing purposes like postcards and other mailers advertising our Services.
How and Why We Use InformationPurposes for Using Information
We use information about you for the purposes listed below:
• To provide our Services. For example, to set up and maintain your account, host your website, backup and restore your website, provide customer service, process payments and orders, and verify user information.
• 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 and that will help them create and manage websites more efficiently or make our Services easier to use.
• To protect our Services, our users, and the public. For example, by detecting security incidents; detecting and protecting against malicious, deceptive, fraudulent, or illegal activity; fighting spam; complying with our legal obligations; and protecting the rights and property of Nrlyze and others, which may result in us, for example, declining a transaction or terminating Services.
• To fix problems with our Services. For example, by monitoring, debugging, repairing, and preventing issues.
• To customize the user experience. For example, to personalize your experience by serving you relevant notifications and advertisements for our Services, recommending content through our Reader post suggestions, and providing new essays and stories through Longreads for your reading pleasure.
• To communicate with you. For example, by emailing you to ask for your feedback, share tips for getting the most out of our products, or keep you up to date on Nrlyze; texting you to verify your payment; or calling you to share offers and promotions that we think will be of interest to you. If you don’t want to hear from us, you can opt out of marketing communications at any time. (If you opt out, we’ll still send you important updates relating to your account.)
• To recruit and hire new Nrlyzeians. For example, by evaluating job applicants and communicating with them.
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 charge you for a paid plan; 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
Sharing InformationHow 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:
• Legal and regulatory requirements: We may disclose information about you in response to a subpoena, court order, or other governmental request. For more information on how we respond to requests for information about WordPress.com users, please see our Legal Guidelines. Additionally, if you have a domain registered with WordPress.com, we may share your information to comply with the Internet Corporation for Assigned Names and Numbers’ (ICANN) regulations, rules, or policies. For example, your information relating to your domain registration may be available in the WHOIS database, or we may be required to share your information with ICANN-approved Dispute Resolution Service Providers. Please see our Domain Registrations and Privacy support document for more details.
• 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 Nrlyze, third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay.
• With your consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties when you authorize us to do so, like when you connected your site to a social media service through our Publicize feature.
• 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, or share a hashed version of your email address to facilitate customized ad campaigns on other platforms.
• Site owners: If you have a WordPress.com account and interact with another site using our Services, your information may be shared with the administrators of the site. For example, if you leave a comment on a site created on WordPress.com or running Jetpack, your IP address and the email address associated with your WordPress.com account may be shared with the administrator(s) of the site where you left the comment. Or if you make a payment (like via the Payments feature) to a site, your public display name, user name, and email address may be shared with the administrator(s) of the site.
• 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.
We have a long-standing policy that we do not sell our users’ data. We aren’t a data broker, we don’t sell your personal information to data brokers, and we don’t sell your information to other companies that want to spam you with marketing emails.
We show ads on some of our users’ sites as well as some of our own, and the revenue they generate lets us offer free access to some of our Services so that money doesn’t become an obstacle to having a voice.
Under a new California law, the California Consumer Privacy Act (“CCPA”), some personalized advertising you see online and on our services might be considered a “sale” even though we don’t share information that identifies you personally, like your name or email address, as part of our advertising program.
You have choices about these ads, learn more about them and our ads program.
Information Shared Publicly
Information that you choose to make public is — you guessed it — disclosed publicly.
That means information like your public profile, posts, other content that you make public on your website, and your “Likes” and comments on other websites are all available to others — and we hope they get a lot of views!
For example, the photo that you upload to your public profile, or a default image if you haven’t uploaded one, is your Globally Recognized Avatar, or Gravatar — get it? Your Gravatar, along with other public profile information, displays alongside the comments and “Likes” that you make on other users’ websites while logged in to your WordPress.com account. Your Gravatar and public profile information may also display with your comments, “Likes,” and other interactions on websites that use our Gravatar service, if the email address associated with your account is the same email address you use on the other website.
We also provide a “Firehose” stream of public data (like posts and comments) from some sites that use our Services to provide that data to Firehose subscribers, who may view and analyze the content (all subject to our Terms of Service), but do not have rights to re-publish it publicly. Find out more about opting out of the Firehose for WordPress.com and Jetpack sites. Public information may also be indexed by search engines or used by third parties.
Please keep all of 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 the web server logs that record information about a visitor to one of Nrlyze’s websites, like the visitor’s IP address, browser type, and operating system, for approximately 30 days. We retain the logs for this period of time in order to, among other things, analyze traffic to Nrlyze’s websites and investigate issues if something goes wrong on one of our websites.
As another example, when you delete a post, page, or comment from your WordPress.com site, it stays in your Trash folder for thirty days in case you change your mind and would like to restore that content, because starting from scratch is no fun. After the thirty days are up, the deleted content may remain on our backups and caches until purged.
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.
To enhance the security of your account, we encourage you to enable our advanced security settings, like Two Step Authentication.
You have several choices available when it comes to information about you:
• Limit the information that you provide: If you have an account with us, you can choose not to provide the optional account information, profile information, and transaction and billing information. Please keep in mind that if you do not provide this information, certain features of our Services — for example, premium themes that carry an additional charge — may not be accessible.
• Limit access to information on your mobile device: Your mobile device operating system should provide you with the option to discontinue our ability to collect stored information or location information via our mobile apps. If you choose to limit this, you may not be able to use certain features, like geotagging for photographs.
• Opt out of marketing communications: You may opt out of receiving promotional communications from us. Just follow the instructions in those communications or let us know. If you opt out of promotional communications, we may still send you other communications, like those about your account and legal notices.
• Set your browser to reject cookies: At this time, Nrlyze does not respond to “do not track” signals across all of our Services. However, you can usually choose to set your browser to remove or reject browser cookies before using Nrlyze’s websites, with the drawback that certain features of Nrlyze’s websites may not function properly without the aid of cookies.
• Close your account: While we’d be very sad to see you go, you can close your account if you no longer want to use our Services. (Here are account closure instructions for WordPress.com accounts.) Please keep in mind that we may continue to retain your information after closing your account, as described in How Long We Keep Information above — for example, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests, or reasonably needed for our legitimate business interests.
If you are located in certain parts of the world, including California 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.
California Consumer Privacy Act (CCPA)
The California Consumer Privacy Act (“CCPA”) requires us to provide California residents with some 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.
The CCPA also requires us to provide a list of the “categories” of personal information we collect, as that term is defined in the law, so, here it is. In the last 12 months, we collected the following categories of personal information from California residents, 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);
• Characteristics protected by law (for example, you might provide your gender as part of a research survey for us);
• Internet or other electronic network activity information (such as your usage of our Services, like the actions you take as an administrator of a WordPress.com site);
• Geolocation data (such as your location based on your IP address);
• Audio, electronic, visual or similar information (such as your profile picture, if you uploaded one);
• Professional or employment-related information (for example, your company and team information if you are a Happy Tools user, or information you provide in a job application); and
• 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.
If you are a California resident, you have additional rights under the CCPA, subject to any exemptions provided by the law, including the right to:
• Request 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, the categories of third parties we share it with, and the specific pieces of information we collect about you;
• Request deletion of personal information we collect or maintain;
• Opt out of any sale of personal information; and
• Not receive discriminatory treatment for exercising your rights under the CCPA.
Contacting Us About These Rights
You can usually access, correct, or delete your personal data using your account settings and tools that we offer, but if you aren’t able to or you’d like to contact us about one of the other rights, scroll down to “How to Reach Us” to, well, find out how to reach us.
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. For example, if you are a user, we will need you to contact us from the email address associated with your account. 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.
Controllers and Responsible Companies
Nrlyze’s Services are worldwide. Different Nrlyze companies are the controller (or co-controller) of personal information, which means that they are the company responsible for processing that information, based on the particular service and the location of the individual using our Services.
Depending on the Services you use, more than one company may be the controller of your personal data. Generally, the “controller” is the Nrlyze company that entered into the contract with you under the Terms of Service for the product or service you use. In addition, Nrlyze Inc., our US-based company, is the controller for some of the processing activities across all of our Services worldwide.
How to Reach Us
Other Things You Should Know (Keep Reading!)Transferring Information
• In the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield; or
• In the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them.
You can ask us for more information about the steps we take to protect your personal information when transferring it from the EU.
Visitors to Our Users’ Websites
Users control the content posted on their sites, so any disputes regarding content on a user’s site should be made directly to the site owner, through their “contact us” page, at an email address they provide, or by leaving a comment on the site.
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