Privacy Policy

Last Updated: November 2, 2021

Welcome!

WordSong utilizes Stripe to collect and process payment information. Stripe provides economic infrastructure for the internet. WordSong obtains Personal Data about you when you process a WordSong transaction via Stripe. WordSong and Stripe care about the security and privacy of the personal data that is entrusted to us.

This policy describes the Personal Data that we collect, how we use and share it, your rights and choices, and how you can contact us about our privacy practices.

We may collect and use personal data when we do business with you.

This Privacy Policy includes important information about your Personal Data and we encourage you to read it carefully.

1. Personal Data We Collect

a. Personal Data that we collect about you

Personal Data is any information that relates to an identified or identifiable individual, and can include information about how you engage with our Services (e.g. device information, IP Address). In many cases, the Personal Data that you provide directly to us through our Services will be apparent from the context in which you provide the data:

  • When you register for a WordSong account we collect your full name, email address, and account log-in credentials.
  • When you authorize us to store information about you in connection with Stripe Checkout, we collect your name and contact information and information about your stored payment methods (e.g. payment card number, CVC code and expiration date). Learn More.
  • When you respond to Stripe emails or surveys, we collect your email address, name and any other information you choose to include in the body of your email or responses. If you contact us by phone, we will collect the phone number you use to contact WordSong, as well as other information you may provide during the call. If you are a WordSong User or Customer, when you contact us, we may collect additional information in order to verify your identity.
  • If you are a WordSong User, you will provide some of your contact details, such as name, postal address, telephone number, and email address. You may also choose to provide bank account information.
  • If you are a Customer, when you make payments to, or transact with a User through Stripe’s Services or a Stripe provided device, we will receive your transaction information. The information that we collect will include payment method information (such as credit or debit card number, or bank account information), purchase amount, date of purchase, and in some cases, some information about your purchases. Different payment methods may require the collection of different categories of information. The payment method information that we collect will depend upon the payment method that you choose to use from the list of available payment methods that are offered to you at the time of check-out. We may also receive your name, email, billing or shipping address and in some cases, your transaction history to authenticate you.

In connection with fraud monitoring, prevention, detection, and compliance activities for Stripe and its Users, we receive identity related from the following sources:

  • From Customers (including through their devices (e.g. IP Addresses)) related to Customers.
  • From our business partners, financial service providers, identity verification services, and publicly available sources.

This Personal Data (e.g., name, address, phone number, country) helps us to confirm identities and prevent fraud. We may also use technology to assess the fraud risk associated with an attempted transaction by a Customer with a Stripe User.

You may also choose to submit information to us via other methods, including: (i) in response to marketing or other communications, (ii) through social media or online forums, or (iii) through participation in an offer, program or promotion.

b. Information that we collect automatically on our Sites and through marketing of our products

Our Sites may use cookies and other technologies. These technologies record information about you, including:

  • Browser and device data, such as IP Address, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and the language version of the Sites you are visiting.
  • Usage data, such as time spent on the Sites, pages visited, links clicked, language preferences, and the pages that led or referred you to our Sites.
  • Online activities. We collect information about your online activities on websites and connected devices over time and across third-party websites, devices, apps and other online services.
  • We collect information when you engage with our marketing messages and when you click on links included in ads for our products. We use Google Analytics on our Sites to help us analyze your use of our Sites and diagnose technical issues.

2. How We Use Personal Data

a. Our Services

We rely upon a number of legal grounds to enable our use of your Personal Data. We use Personal Data to facilitate the business relationships we have with our Users, to comply with our financial regulatory and other legal obligations, and to pursue our legitimate business interests. We also use Personal Data to complete transactions and to provide payment-related services.

Legal compliance

We use Personal Data to verify the identity of our Users in order to comply with fraud monitoring, prevention and detection obligations, laws associated with the identification and reporting of illegal and illicit activity, such as AML (Anti-Money Laundering) and KYC (Know-Your-Customer) obligations, and financial reporting obligations. For example, we may be required to record and verify a User’s identity for the purpose of compliance with legislation intended to prevent money laundering and financial crimes. These obligations are imposed on us by the operation of law, industry standards, and by our financial partners, and may require us to report our compliance to third parties, and to submit to third party verification audits.

Legitimate business interests

Where allowed under applicable law, we rely on our legitimate business interests to process Personal Data about you. When we do so, we balance our legitimate interests against the interests and rights of the individuals whose Personal Data we process. The following list sets out the business purposes that we have identified as legitimate:

  • Detect, monitor and prevent fraud and unauthorized payment transactions;
  • Mitigate financial loss, claims, liabilities or other harm to Customers, Users, Stripe, and WordSong;
  • Determine eligibility for and offer new WordSong products and services;
  • Respond to inquiries, send Service notices and provide customer support;
  • Promote, analyze, modify and improve our Services, systems, and tools, and develop new products and services, including reliability of the Services;
  • Manage, operate and improve the performance of our Sites and Services by understanding their effectiveness and optimizing our digital assets;
  • Analyze and advertise our Services;
  • Conduct aggregate analysis and develop business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of, our business;
  • Share Personal Data with third party service providers that provide services on our behalf and business partners which help us operate and improve our business;
  • Enable network and information security throughout Stripe and our Services; and
  • Share Personal Data among our affiliates for administrative purposes.

3. How We Disclose Personal Data

WordSong does not sell or rent Personal Data to marketers or unaffiliated third parties. We share your Personal Data with trusted entities, as outlined below.

a. Stripe

We share Personal Data with other Stripe affiliated entities in order to provide our Services and for our administration purposes.

b. Service providers

We share Personal Data with certain of our service providers subject to contract terms that limit their use of Personal Data. We have service providers that provide services on our behalf, such as identity verification services, website hosting, data analysis, marketing service, information technology and related infrastructure, customer service, email delivery, and auditing services. These service providers may need to access Personal Data to perform their services. We authorize such service providers to use or disclose the Personal Data only to perform services on our behalf or comply with legal requirements. We require such service providers to contractually commit to protect the security and confidentiality of Personal Data they process on our behalf. Our service providers are predominantly located in the European Union and the United States of America. Learn More.

c. Business partners

We share Personal Data with third party business partners in connection with our Services to our Users. Examples of third parties to whom we may disclose Personal Data for this purpose are banks and payment method providers (such as credit card networks) when we provide payment processing services, and the professional services firms that we partner with to deliver our services.

d. Corporate transactions

In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share Personal Data with third parties in connection with such transaction. Any other entity which buys us or part of our business will have the right to continue to use your Personal Data, but subject to the terms of this Privacy Policy.

e. Compliance and harm prevention

We share Personal Data as we believe necessary: (i) to comply with applicable law, or rules imposed by payment method in connection with use of that payment method; (ii) to enforce our contractual rights; (iii) to protect the Services, rights, privacy, safety and property of WordSong, you or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.

4. Your Rights and Choices

You may have choices regarding our collection, use and disclosure of your Personal Data:

a. Opting out of receiving electronic communications from us

If you no longer want to receive marketing-related emails from us, you may opt-out via email to [email protected]. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you other messages in connection with providing our Services.

b. How you can see or change your account Personal Data

If you would like to review, correct, or update Personal Data that you have previously disclosed to us, you may do so by contacting us.

c. Your data protection rights

Depending on your location and subject to applicable law, you may have the following rights with regard to the Personal Data we control about you:

  • The right to request confirmation of whether WordSong processes Personal Data relating to you, and if so, to request a copy of that Personal Data;
  • The right to request that WordSong rectifies or updates your Personal Data that is inaccurate, incomplete or outdated;
  • The right to request that WordSong erase your Personal Data in certain circumstances provided by law;
  • The right to request that WordSong restrict the use of your Personal Data in certain circumstances, such as while WordSong considers another request that you have submitted (including a request that WordSong make an update to your Personal Data);
  • The right to request that we export your Personal Data that we hold to another company, where technically feasible;
  • Where the processing of your Personal Data is based on your previously given consent, you have the right to withdraw your consent at any time; and/or
  • In some cases, you may also have the right to object to the processing of your Personal Data.

d. Process for exercising data protection rights

To exercise your data protection rights please do so by contacting us. We will comply with your request to the extent required by applicable law. We will not be able to respond to a request if we no longer hold your Personal Data. If you feel that you have not received a satisfactory response from us, you may have the right under applicable laws to consult with the data protection authority in your country.

For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file. If we no longer need to process Personal Data about you in order to provide our Services or our Sites, we will not maintain, acquire or process additional information in order to identify you for the purpose of responding to your request.

5. Security and Retention

We make reasonable efforts to provide a level of security appropriate to the risk associated with the processing of Personal Data. We maintain organizational, technical and administrative measures designed to protect Personal Data covered by this Privacy Policy against unauthorized access, destruction, loss, alteration or misuse. Your Personal Data is only accessed by a limited number of personnel who need access to the information to perform their duties. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (e.g., you feel that the security of your account has been compromised), please contact us immediately.

We retain your Personal Data as long as we are providing the Services to you. Even after we stop providing Services directly or indirectly to you, and even if you close your WordSong account or complete a transaction with WordSong, we keep your Personal Data in order to comply with our legal and regulatory obligations. We may also keep it to assist with our fraud monitoring, detection and prevention activities. We also keep Personal Data to comply with our tax, accounting, and financial reporting obligations, where we are required to retain the data by our contractual commitments to our financial partners, and where data retention is mandated by the payment methods you used. In all cases where we keep data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.

6. Use by Minors

Financial transaction services are not directed to minors, including children under the age of 13, and we request that they not provide Personal Data through the Stripe. In some countries, we may impose higher age limits as required by applicable law. We do not sell any Personal Data of Customers, Visitors or Users, including those aged between 13 to 16.

7. Updates To this Privacy Policy and Notifications

We may change this Privacy Policy from time to time to reflect new services, changes in our Personal Data practices or relevant laws. The “Last updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes are effective when we post the revised Privacy Policy on the Services.

We may provide you with disclosures and alerts regarding the Privacy Policy or Personal Data collected by posting them on our website or sending app push notifications, and by contacting you through your email address and/or the physical address listed in your Stripe account.

If applicable law requires that we obtain your consent or provide notice in a specified manner prior to making any changes to this Privacy Policy applicable to you, we will provide such required notice and will obtain your required consent.

8. Links To Other Online Services

The Services may provide the ability to connect to other online services. These online services may operate independently from us and/or may have their own privacy notices or policies, which we strongly suggest you review. If any online service linked to our Services is not owned or controlled by us, or does not claim to be covered by this Privacy Policy, we are not responsible for it and/or it is not covered by this Privacy Policy. Please refer to the privacy policy associated with that online service.

9. Contact Us

If you have any questions or complaints about this Privacy Policy, please contact us.

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