Wordly Privacy Policy

Introduction

This privacy policy (“Privacy Policy”) applies to the personal information that Wordly processes in connection with Wordly apps, websites, software, and related services (the “Services”), that link to or reference this Privacy Policy. The Services enable you to get real-time captions and/or translations for spoken conversations (audio input).

Data Controller: The Services are provided and controlled by Wordly, Inc., with its registered address in the USA (“we” or “us”). If you have any questions about how we use your personal data, please contact privacy@wordly.ai or click the “Contact” link on the website.

Please be informed that the processing rules for personal information collected from end users when accessing downstream systems or applications developed by developers using our Application Programming Interfaces (APIs) are not covered by this privacy policy. The developer operating the application, as the controller of the personal information processing activity, should disclose the relevant personal information protection policies to the end users.

Wordly adheres to the EU-U.S. DPF Principles with regard to personal data transferred from the European Union and the United Kingdom and the Swiss-U.S. DPF Principles with regard to personal data transferred from Switzerland.

What Information We Collect

We collect your personal information in three ways: Information You Provide, Automatically Collected Information, and Information From Other Sources. More detail is provided below.

Information You Provide

When you create an account, input content, contact us directly, or otherwise use the Services, you may provide some or all of the following information:

• Account information. We collect information that you provide when you set up an account, such as your name (where applicable), email address, and password.
• User Input. When you subscribe to our services, we collect your name, email address, mailing address, and other contact information so we can keep you informed about updates to our product.
• Information When You Contact Us. When you contact us, we collect the information you send us, such as contact details, feedback or inquiries about your use of the Services or information.

Automatically Collected Information

We automatically collect certain information from you when you use the Services, including internet or other network activity information such as your IP address, unique device identifiers, and cookies.

• Device and Network Information. We collect certain device and network connection information when you access the Services. This information includes your device model, operating system, IP address, device identifiers and system language. We also collect service-related, diagnostic, and performance information, including crash reports and performance logs. We automatically assign you a device ID and user ID. Where you log in from multiple devices, we use information such as your device ID and user ID to identify your activity across devices to give you a seamless login experience and for security purposes.
• Log Information. We collect information regarding your use of the Services, such as the features you use and the actions you take.
• Location Information. We automatically collect information about your approximate location based on IP address.
• Cookies & Similar Technologies. We use cookies and similar tracking technologies to operate and provide the Service. For example, we use cookies to remember your language preferences, and for security purposes. We will obtain your consent to our use of cookies where required by law. To learn more about our use of cookies, please see our Cookie Policy.

Information from Other Sources

We may receive the information described in this Privacy Policy from other sources, such as:

• Login, Signup, or Linked Services. Where available, if you choose to sign up for or log into the Services using a third-party service such as Zoom, Apple, or Google, or link your account to a third-party service, we may collect information from the service, such as an access token.
• Security Information. We receive information from our trusted partners, such as security partners, to protect against fraud, abuse, and other security threats to our Services.

How We Use Your Information

We use your information to administer, operate, and provide the Services, including for the following purposes.

• To provide, administer and maintain the Services, and to enforce our terms, conditions, and policies. This includes creating the accounts, delivering a fast and convenient login experience, enabling you to communicate with Wordly and provide user support.
• To communicate with you, including to notify you about changes to the Platform, provide customer support to you and send you other service-related messages.
• To promote the safety, security, and stability of the Platform, such as by preventing and detecting abuse, fraud, and illegal activity on the Platform and by conducting troubleshooting, data analysis, testing, and research.
• To comply with our legal obligations, or as necessary to perform tasks in the public interest, or to protect the vital interests of our users and other people. This could include providing law enforcement agencies or emergency services with information in urgent situations to protect health or life.

If you refuse to allow us to process the data in the manner described above, you may provide feedback through privacy@wordly.ai.

How We Share Your Information

Wordly does not share data with third parties.

The Security of Your Information

The security of your information is important to us. We maintain commercially reasonable technical, administrative, and physical security measures that are designed to protect your information from unauthorized access, theft, disclosure, modification, or loss. We regularly review our security measures to consider available new technology and methods. 

How Long Do We Keep Your Information

We retain your account information for as long as the account is active as it is necessary to provide our Services and for the other purposes set out in this Privacy Policy. We also retain information when necessary to comply with contractual and legal obligations.

Your personal data will be deleted upon request when you choose to no longer use the Services. Usage data and/or transaction data will remain in our system for accounting reasons.

Where We Store Your Information

The personal information we collect from you is stored on a server located in the United States.

How to Access Your Personal Data

You can view your activity in the Wordly Portal under Activity. Personal information, such as name, email address, and your preferences and settings can be found under your Profile in the Wordly Portal. 

Privacy Policy Updates

We may update this Privacy Policy from time to time as required by law. When we update the Privacy Policy, we will notify you by updating the “Last Updated” date at the top of the new Privacy Policy, posting the new Privacy Policy, or by providing any other notice required by applicable law. We recommend that you review the Privacy Policy each time you access our Services to stay informed of our privacy practices.

Contact Us

Questions, comments and requests regarding this policy should be addressed to privacy@wordly.ai or click the “Contact” link on the website.

Supplemental Terms - Jurisdiction-Specific

The Federal Trade Commission has jurisdiction over Wordly’s compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF).

European Economic Area (“EEA”), Switzerland, and UK

If you are using the Services in the EEA, Switzerland or the UK (the “European Region”), the following additional terms apply:

Legal bases for processing.

We use your personal data only as permitted by law. Our legal bases for processing your personal data described in this Policy are described in the table below.

Please be aware that we collect your personal data for the purposes set out in the table below. You may choose not to provide some of the personal data fields, but this may affect the services you are able to use from us.

 

Commitment to comply with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF

Wordly complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.  Wordly has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Wordly has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Wordly commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF in the context of the employment relationship.

Data Subject rights

The European Union’s General Data Protection Regulation (GDPR) and other countries’ privacy laws provide certain rights for data subjects. Data Subject rights under GDPR include the following:

• Right to be informed
• Right of access
• Right to rectification
• Right to erasure
• Right to restrict processing
• Right of data portability
• Right to object
• Rights related to automated decision making including profiling

This Privacy Notice is intended to provide you with information about what personal data Wordly Inc. collects about you and how it is used. 

If you wish to confirm that Wordly Inc. is processing your personal data, or to have access to the personal data Wordly Inc. may have about you, please contact us.

You may also request information about: the purpose of the processing; the categories of personal data concerned; who else outside Wordly Inc. might have received the data from Wordly Inc.; what the source of the information was (if you didn’t provide it directly to Wordly Inc.); and how long it will be stored. You have a right to correct (rectify) the record of your personal data maintained by Wordly Inc. if it is inaccurate. You may request that Wordly Inc. erase that data or cease processing it, subject to certain exceptions. You may also request that Wordly Inc. cease using your data for direct marketing purposes. In many countries, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how Wordly Inc. processes your personal data. When technically feasible, Wordly Inc. will—at your request—provide your personal data to you.

Reasonable access to your personal data will be provided at no cost. If access cannot be provided within a reasonable time frame, Wordly Inc. will provide you with a date when the information will be provided. If for some reason access is denied, Wordly Inc. will provide an explanation as to why access has been denied.

Wordly will arbitrate claims and follow the terms as set forth in Annex I of the DPF Principles, provided that an individual has invoked binding arbitration by delivering notice to your organization and following the procedures and subject to conditions set forth in Annex I of Principles.

If in the future Wordly does transfer personal information to a third party acting as an agent on Wordly’s behalf, Wordly shall remain liable under the DPF Principles if its agent processes such personal information in a manner inconsistent with the DPF Principles, unless Wordly proves that it is not responsible for the event giving rise to the damage.

For questions or complaints concerning the processing of your personal data, you can email us at privacy@wordly.ai. Alternatively, if you are located in the European Union, you can also have recourse to the European Data Protection Supervisor or with your nation’s data protection authority.