Updated and effective as of: May 31, 2018
Choice and Opting Out: see “Choices” below for information about your choices regarding opting out of email marketing communications, opting out of MerchantWords’ cookies, opting out of interest-based advertising from third parties’ cookies, and opting out of the use of precise location.
Access and Rights: see “Access and Rights regarding Personal Information” below for information about how to be informed, the right to data portability, the right to object, your rights in relation to automated decision making and profiling, and the right to access, rectification, erasure, and restrict the processing of, the personal information that MerchantWords maintains about you.
International Transfers: see “International Information Transfers and Model Clauses” below for information on the transfer of your personal data.
COLLECTION OF INFORMATION
We and our third party service providers may collect personal information from you from the Services, including the following:
For example, we collect your personal information when you request information about the Services, you sign up to use the Services through our client login and user interfaces, or you request access to our resources. The decision to provide this information is optional, however, if you elect not to provide such information, you will not be able to access the information you had requested to access or use.
We also collect other information about you such as your MerchantWords account password, the creation date of your account, and payment information, such as your subscription type and the number of times we have charged your credit card for our Services.
We and our third party service providers may also collect other information that is linked or reasonably linked to a particular computer or device. This information includes the following:
We and our third party service providers may collect this information in a variety of ways, including through: your browser or device; your mobile device identifier; your use of our applications; the use of pixel tags and other similar technologies; your IP address; the aggregation of information; and cookies (see Cookies and Similar Technologies below).
USE OF INFORMATION
We and our third-party service providers may use personal information (such as email address and the last 4 digits of your credit card) collected from the Services:
We and our third party service providers may use other information from the Services that is linked or reasonably linked to a particular computer or device:
We may partner with certain third parties to collect other information to engage in analysis, research, and reporting, as well as to deliver advertising that we believe may interest you based on your activity on our website and other websites over time. These third parties may set and access cookies on your computer or other devices and may also use web logs or web beacons. See “Cookies and Similar Technologies.”
In some instances, we may combine information from the Services that is linked or reasonably linked to a particular computer or device with personal information. If we combine such information with personal information, the combined information will be treated by us as personal information as long as it is combined.
Your personal information (such as email address and last 4 digits of credit card number) collected from the Services may be shared:
We and our third party service providers may share other information from the Services that is linked or reasonably linked to a particular computer or device:
We may also share and disclose other information that we collect, including aggregate information, as we consider necessary to develop and provide our Services, including in the ways described above in this section “Information Sharing.”
We ask our service providers to confirm that their privacy and security practices are consistent with ours, we provide our service providers with only the information necessary for them to perform the services we request, and we ask our service providers not to use such information for any purpose other than as specified by MerchantWords.
MerchantWords may offer online resources that facilitate communications among the MerchantWords client community and others. Whenever you voluntarily post information to any public forum offered by MerchantWords, such information along with your user name can be accessed by other users of the forum, including members of the public if the forum is open to the public.
COOKIES AND SIMILAR TECHNOLOGIES
We and our service providers may also use "pixel tags," "web beacons", "clear GIFs" or similar means (individually or collectively "Pixel Tags") to analyze usage patterns of consumers. A Pixel Tag is an electronic image, often a single pixel, which is typically a transparent graphic image (usually 1 pixel x 1 pixel) that is placed on a web page or in a mobile application and may be associated with cookies on your hard drive. Some Pixel Tags are used to drop cookies on users’ devices. Pixel Tags allow us to count users who have visited our Services and pages within our Services, and to help determine the effectiveness of our Services.
To read about your choices with regard to MerchantWord’s and third parties’ uses of cookies in our Services, please see “Choices.”
We do not track users when they cross to third party websites, and we do not provide targeted advertising to them, and therefore we do not respond to Do Not Track (DNT) signals.
LEGAL BASIS RELIED ON FOR PROCESSING PERSONAL INFORMATION OF EUROPEAN ECONOMIC AREA INDIVIDUALS
MerchantWords is a data controller with respect to the personal data collected or received by us (such as email address and credit card numbers) through our Services. In this case, the data controller is Merchant Words, LLC. Depending on the data processed, we rely on various legal bases for the processing. We may process personal information (such as your email address and credit card number) with your consent or to fulfill our obligations under our contract with you, such as our obligation to give you access to our Services that you paid for and to process payment. On certain occasions, we may also rely on the consent of the individual to process personal information (for example, in some jurisdictions, when the user inputs personal information into the Services and consents to receive marketing communications). On other occasions we may rely on legitimate interest as a basis for processing, when it is in our legitimate interests to do so and when these interests are not overridden by the individual’s data protection rights. Those legitimate interests include performing our obligations with respect to providing the Services and improving our Services.
Opting Out of Marketing
We give you choices regarding our use and disclosure of your personal information for marketing purposes.
You may opt-out from receiving electronic communications from us. If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving these marketing related emails by contacting us at [email protected] or by clicking on the opt-out link within the email message that you receive from us.
Please also note that if you do opt-out of receiving marketing-related emails from us, we may still be required to send you administrative messages relating to the Services from time to time.
Opting Out of MerchantWords’ cookies
You may disable cookies, including MerchantWords cookies, by modifying the settings in your browser. However, please note that certain features of the Services may not work if you delete or disable cookies.
Opting Out of Interest-Based Advertising from Third Parties’ Cookies
If you go to optout.aboutads.info or www.aboutads.info/choices, you can learn how to exercise choice regarding the collection of information about your online activities over time and across multiple third-party websites, online services, devices, and applications for interest-based advertising purposes.
Opting Out of Use of Precise Location
To disable the collection of precise location information from your mobile device through mobile applications, you can access your mobile device settings and choose to limit that collection.
Android: For Android 6.0 and above: you can modify privacy settings in Settings > Applications > App Permissions > Location and tap the on/off toggle switch next to Location for each app which has permission to use your location data. For earlier versions of Android: you can modify privacy settings in Settings > More > Permission and tap the on/off toggle switch next to Location to turn location functions off for your device. Alternatively, you may uninstall the relevant program(s).
iOS: In iOS you can modify privacy settings in Settings > Privacy. You can select location data from this list to see which apps have asked for permission to use your location data.
ACCESS AND RIGHTS REGARDING PERSONAL INFORMATION
Any registered user of our Services can access and modify their profile information in their account settings in our Services. In addition, any registered user can also permanently delete their MerchantWords account by contacting us at [email protected].
If you reside outside the European Economic Area and Switzerland, you may also contact us at [email protected] if you would like to review, correct, update, suppress, or delete the personal information that MerchantWords maintains about you, or you would like to request a copy of your personal information held by us.
If you are a resident of the European Economic Area, including Switzerland, you are provided specific legal rights in regard to the handling of your information. You have the following rights with respect to your personal information:
• The right to be informed,
• The right of access,
• The right to rectification,
• The right to erasure,
• The right to restrict processing,
• The right to data portability,
• The right to object, and
• Rights in relation to automated decision making and profiling.
To exercise these rights as a resident of the European Economic Area, including Switzerland, email [email protected].
To opt out of receiving marketing communications from us, please see “Choices.”
To opt out of MerchantWords’ cookies, please see “Choices.”
To opt out of interest-based advertising from third parties’ cookies, please see “Choices.”
To opt out of the use of precise location, please see “Choices.”
Except as required by applicable law, we are also not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of our social media platform providers, operating system providers, wireless service providers or device manufacturers, including any personal information you disclose to other organizations through or in connection with the Services.
We ask that you not send us, and you not disclose to us, any sensitive information (e.g., social security numbers or other government identifiers, information related to racial or ethnic origin, political opinions, religion or other beliefs, medical or health conditions, criminal background, trade union membership, or sexual orientation) on or through the Services or otherwise to us, except where such information is legally required.
Information that we collect is stored using procedures and practices reasonably designed to help protect from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal information transmitted, stored or otherwise processed by us.
USE OF SERVICES BY MINORS
Our Services are not intended for, nor directed to, individuals under the age of 18, and we request that these individuals, and any other individual considered a minor under applicable law, not provide personal information through any of the Services.
INTERNATIONAL INFORMATION TRANSFERS AND MODEL CLAUSES
For residents in the European Economic Area, including Switzerland (“EEA”), we may also use service providers based outside the EEA to help us provide our Services to you. This means that we may transfer your information to service providers outside the EEA for the purpose of providing our Services to you. We take steps to ensure that where your information is transferred outside the EEA by our service providers, appropriate measures and controls are in place to protect that information in accordance with applicable data protection laws and regulations. In each case, we ask our service providers to transfer and process the personal information in accordance with the requirements of the EU General Data Protection Regulation (GDPR). In some instances, the transfer may be based on the use of the European Commission’s Standard Model Clauses for transfers of personal data outside the EEA.
Merchant Words, LLC
935 N La Brea Ave, 4th Floor
Los Angeles, CA 90038