Privacy Policy

Effective Date: January 1, 2025
Revision Date: May 21, 2025

This Privacy Policy ("Policy") describes the collection, use, disclosure, and protection of Personal Information by Word Smithey (“Company,” “we,” “us,” or “our”) in connection with your access to and use of the website located at wordsmithey.com, and any related services, content, features, or functionality (collectively, the “Services”). This Policy applies to all users of the Services and is intended to comply with applicable privacy laws, including but not limited to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”), and any applicable data protection laws governing the collection and use of personal data of individuals located in the European Economic Area (“EEA”) or the United Kingdom (“UK”).

I. Categories of Personal Information Collected
We collect the following categories of Personal Information:
(A) Identifiers, including but not limited to name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, and user credentials.
(B) Commercial information, including records of products or services purchased, obtained, or considered, and other purchasing histories or tendencies.
(C) Internet or other electronic network activity information, including browsing history, search history, interaction with the Services, and metadata.
(D) Geolocation data derived from IP address or device settings.
(E) Audio, electronic, visual, or similar information provided through customer communications.
(F) Professional or employment-related information voluntarily submitted.
(G) Inferences drawn from any of the above information to create a profile reflecting user preferences or behavior.
(H) Sensitive Personal Information, which may include account login information in combination with access credentials, and precise geolocation, as applicable.

II. Sources of Personal Information
We collect Personal Information from the following sources:
(A) Directly from you when you interact with our Services, including when you register for an account, sign up for newsletters, make purchases, or contact us.
(B) Automatically through cookies, pixels, and similar tracking technologies.
(C) From service providers, contractors, and third parties that assist in delivering the Services, including but not limited to payment processors, marketing platforms, analytics vendors, and hosting providers.
(D) From publicly available sources and data append services.

III. Use of Personal Information
The Personal Information described above is used for the following business purposes:
(A) To provide, operate, and maintain the Services, including account registration, authentication, and customer support.
(B) To process transactions and fulfill orders.
(C) To analyze usage, improve content, and develop new features.
(D) To personalize user experiences and deliver tailored content and communications.
(E) To send administrative messages, including updates to our Terms of Use or this Policy.
(F) To comply with legal obligations and defend legal claims.
(G) To detect, investigate, and prevent fraudulent or malicious activity.
(H) To facilitate marketing and promotional communications, including targeted advertising.
(I) To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets.
(J) To facilitate participation in programs, events, ARC opportunities, or other benefits.
(K) To offer financial incentives, where applicable, in exchange for voluntary provision of Personal Information.

IV. Disclosure of Personal Information
We may disclose Personal Information as follows:
(A) To service providers or contractors that process data on our behalf under binding contractual obligations.
(B) To third-party partners for marketing and advertising purposes, including cross-context behavioral advertising, where permitted.
(C) To analytics and platform providers to measure performance and derive insights.
(D) To government agencies or other third parties when required by law, court order, subpoena, or similar legal process.
(E) In connection with the sale, merger, reorganization, or transfer of all or part of our business.
(F) To enforce our Terms of Use or protect the rights, safety, or property of the Company or others.
(G) As otherwise disclosed at the time of collection or with your consent.

V. Sale or Sharing of Personal Information
The Company may engage in the “sale” or “sharing” (as defined under CCPA) of Personal Information, including through the use of cookies and other tracking technologies by advertising and analytics partners. You may opt out of the sale or sharing of Personal Information by submitting a request as described in Section VIII below.

VI. Data Retention
We retain Personal Information for as long as necessary to fulfill the purposes for which it was collected, including for the duration of any active account or relationship, and thereafter as required or permitted by applicable law. If no specific legal requirement applies, we retain Personal Information until a verifiable deletion request is received.

VII. Rights of Individuals
Depending on your jurisdiction, you may have the following rights regarding your Personal Information:
(A) Right to Know: to request information regarding the categories and specific pieces of Personal Information collected, disclosed, sold, or shared.
(B) Right to Delete: to request deletion of Personal Information subject to certain exceptions.
(C) Right to Correct: to request correction of inaccurate Personal Information.
(D) Right to Opt-Out: to opt out of the sale or sharing of Personal Information.
(E) Right to Limit Use of Sensitive Personal Information, where applicable.
(F) Right to Non-Discrimination for exercising your rights under this Policy.
(G) Right to Data Portability: to receive a copy of your Personal Information in a portable format.
To exercise any of the rights described herein, please contact us using the methods described in Section XI.

VIII. Authorized Agents
Authorized agents may act on behalf of a consumer to submit a privacy rights request, provided that:
(A) The agent is registered with the Secretary of State in the relevant jurisdiction.
(B) The agent provides signed written authorization from the consumer, or holds valid power of attorney under applicable law.
(C) The consumer’s identity is verified directly by the Company, or the Company confirms with the consumer that the agent has been authorized to act on their behalf.

IX. Financial Incentives
We may offer discounts, early access, exclusive content, or other benefits in exchange for the voluntary provision of Personal Information, such as an email address for marketing purposes. The value of the Personal Information is reasonably related to the benefit offered, as determined in good faith. Participation is voluntary and subject to opt-out at any time.

X. Children’s Data
Our Services are intended for use by adults. We do not knowingly collect Personal Information from children under the age of thirteen (13). If we become aware that a child has submitted Personal Information without verifiable parental consent, we will delete such information promptly.

XI. Security
We implement reasonable technical and organizational safeguards to protect Personal Information against unauthorized access, use, or disclosure. However, no method of transmission over the internet or method of electronic storage is 100% secure.

XII. International Data Transfers
If you access the Services from outside the United States, you acknowledge and agree that your Personal Information may be transferred to, processed, and stored in the United States and other jurisdictions where our service providers are located. By using the Services, you consent to such transfer.

XIII. Do Not Track and Global Privacy Control
Our Services do not currently respond to browser-based “Do Not Track” signals. However, we recognize and, where required, honor Global Privacy Control (GPC) signals as a valid request to opt out of the sale or sharing of Personal Information.

XIV. Updates to This Policy
We may update this Privacy Policy from time to time. The date of the most recent revision is listed at the top. Your continued use of the Services after any modifications constitutes acceptance of the updated terms.

XV. Contact Information
To exercise your rights, submit a data request, or ask questions regarding this Policy or our data practices, please contact us at:
Email: legal@wordsmithey.com