Who we are

Suggested text: Our website address is: https://wpveterans.com/agency.

Comments

Suggested text: When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.

An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

Media

Suggested text: If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

Cookies

Suggested text: If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Embedded content from other websites

Suggested text: Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Who we share your data with

Suggested text: If you request a password reset, your IP address will be included in the reset email.

How long we retain your data

Suggested text: If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

What rights you have over your data

Suggested text: If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Where we send your data

Suggested text: Visitor comments may be checked through an automated spam detection service.

You can also change your cookie settings via your browser. For further information, visit www.allaboutcookies.org.

The length of time a cookie will stay on your browsing device depends on whether it is a “persistent” or “session” cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your browsing device after you have finished browsing until they expire or are deleted.

3. USES MADE OF YOUR PERSONAL INFORMATION AND OUR LEGAL BASIS FOR PROCESSING

Providing personal information is optional; however, in order to provide you with access to our services and other resources such as whitepapers and demos, providing certain personal information (e.g., contact information and name, log-in details) may be necessary in order to receive these services and resources. You may choose whether or not to receive electronic marketing communications from us and we will only send you such communications where we have the appropriate consents to do so (to the extent required by applicable law). For more information on your choices, please see Section 5 below.

We process personal information through electronic and manual means for the following purposes:

Customers and Website Users

To fulfill a contract or to take steps linked to a contract. This includes:

  • to administer your access to your accounts;
  • to process orders, provide our products and services, and send you service related communications;
  • for customer support purposes including responding to your queries and investigating any complaints about the Sites.

As required to conduct our business and pursue our legitimate interests, in particular:

  • to improve and personalize your experience with us and our Sites and to tailor content, advertisements and offers to you;
  • to administer our Sites, conduct identity verification and other fraud detection activities;
  • to send you information you have requested;
  • to monitor, maintain and improve the performance of our Sites, analyze trends, usage and activities in connection with our services, validate users and ensure their technological compatibility with users, and optimize our marketing efforts and measure the effectiveness of our advertising campaigns;
  • for our own internal functions such as keeping our Sites secure, management and corporate reporting, internal research and analytics and to improve business efficacies;
  • to enforce compliance with our terms of use and other policies or otherwise in connection with legal claims, compliance, regulatory and investigatory purposes as necessary (including disclosure of such information in connection with legal process or litigation);
  • to create aggregate and statistical data (which cannot be used to identify you). For example, aggregate data may include data that describes the general demographics, usage or other characteristics of a Site’s users. We reserve the right to transfer and/or sell aggregate or group data about a Site’s users for lawful purposes.

Where you give us consent:

  • Where you ask us to send marketing information via a medium where we need your consent under applicable law (for example email marketing in some countries). For more information about how to modify your preferences about marketing communications, please see Section 5;
  • Where you give us consent to place cookies or similar technologies;
  • On other occasions where we ask for your consent, for the purpose we explain at the time.

As required by law:

  • In response to requests by government or law enforcement authorities conducting an investigation.

Partners, Publishers and other Service Providers

We use contact information about individuals within other organizations that we work with in order to fulfill our contractual obligations or as required to conduct our business and pursue our legitimate interests including for our own internal functions such management, corporate reporting, and record keeping.

4. DISCLOSURES OF YOUR PERSONAL INFORMATION

We will share your personal information with the third-parties listed below for the purposes that are described in this Privacy Policy or otherwise with your consent.

Service Providers. When we employ an affiliate or third-party to perform a function on our behalf, we provide it with the personal information that it needs to perform its specific function. These companies are authorized to use your personal information only as necessary to provide these services to us. We use service providers for the purposes of delivering our products and services, managing your accounts, hosting, IT, security, support, billing, marketing, and communications.

Affiliates. PHRUTOS is a global business, headquartered in the United States. Your personal information collected by us in accordance with this Privacy Policy may be used and shared amongst PHRUTOS, LLC. and the PHRUTOS affiliates for the purposes of delivering our products and services, managing your accounts, hosting, IT, security, support, billing, marketing, and communications. The list in Section 7 describes the management responsibility for respective data processing activities by the listed PHRUTOS affiliates. If your personal information is transferred from Japan (and subject to Japanese privacy laws), it will be considered to be jointly used between PHRUTOS, LLC. and the listed PHRUTOS affiliates in accordance with the joint use cases set forth in Section 7.

Legal Requirements. We disclose personal information to government authorities or other third-parties if required to do so by law or in the good faith belief that such action is necessary to (a) comply with a subpoena, court order or similar legal obligation, (b) protect and defend our rights or property, (c) act in urgent circumstances to protect the personal safety of users of any Site or the public, (d) protect against legal liability, (e) to investigate fraud or other unlawful activity or (f) or as otherwise required or permitted by law.

Business Transfers. As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, including in bankruptcy, your personal information may be part of the transferred assets. You will be notified via email and/or a prominent notice on our Sites of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Publishers. If you have requested us to do so, we may provide personal information to third-party publishers that we work with. For example, if you have provided your name or a biography to be published on a third-party publisher’s website.

Third-Party Partners.  We may share your personal information with selected third-party partners, including for their direct marketing purposes. We will obtain your prior consent for such a transfer where required by applicable law.

International Transfers of Personal Information. Your personal information is stored on servers in the US and is supported from the US. Where your personal information is transferred from Japan (and subject to Japanese privacy laws), you hereby agree to the transfer of your personal information to PHRUTOS, LLC.

5. WITHDRAWING CONSENT OR OTHERWISE OBJECTING TO PHRUTOS’ DIRECT MARKETING

Where we rely on consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above in Section 3. You have the absolute right to opt out of our direct marketing at any time, and EEA individuals can also opt out of profiling we carry out for direct marketing at any time. To stop receiving newsletters or marketing communications from us, you can use the unsubscribe mechanism in the relevant communication or you can send an email to [email protected] with information necessary to process your request. Please note that this will not stop you from receiving service related messages (i.e., non-marketing communications) such as email messages to let you know our service has been suspended for maintenance.

6. EEA DATA PROTECTION RIGHTS

If you are an individual located in the EEA, you have the right to ask us for a copy of your personal data, to correct, delete or restrict processing of your personal data, to obtain the personal data you provide to us in a structured, machine readable format, and to ask us to share (port) this data to another controller. In addition, you can object to the processing of your personal data in some circumstances (in particular, where we are not required to process such data in order to meet a contractual or other legal requirement).

We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests which we have described above. You can obtain information on any of our balancing tests by contacting us using the details below.

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are set out in applicable data protection laws. We will inform you of the relevant exemptions we rely upon when responding to any request you make.

To exercise any of these rights, please contact us here with the information necessary for us to process your request. If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.

If you deactivate your account, we will delete, block or anonymize your personal information so that it is no longer possible to identify you, subject to our retention policy below.

If you have provided a location review to one of our customers, please contact that customer directly if you have any questions about their privacy practices or wish to stop receiving communications from or exercise your rights in respect of personal data processed by that customer.

7. CALIFORNIA PRIVACY NOTICE

If you are a California resident, this section contains disclosures required by the California Consumer Privacy Act (“CCPA”) and applies only to “personal information” that is subject to the CCPA.  This section does not cover personal information about End Users of our customers, which we process solely on behalf of customers.

Currently, personal information about our current and former business customers is exempt from most CCPA obligations.  We do not and will not sell personal information about our business customers, former customers, or business (marketing) prospects.

We provide our business prospects with additional disclosures and rights under the CCPA. The remainder of this section provides additional information for our business prospects.

Accessibility.  Consumers with disabilities may access this notice by using a standard screen reader.

California Personal Information We Collect and Disclose.  We collect the categories of personal information listed in the below chart about California residents who are our business prospects.  As further set forth in the chart below, in the past 12 months, we have disclosed such California residents’ personal information to third parties for the listed business or commercial purposes.  We do not and will not sell such personal information.