Privacy Policy

COMMITMENT TO PRIVACY
Updated and Effective Date: August 14, 2018

WOORLY, LLC dba Woorly (“Woorly”) is committed to protecting your privacy and will make reasonable efforts to provide you a safe and secure user experience. We aim to make our Privacy Policy easy to read so you that you understand our online data collection practices and usage policies for www.woorly.com (the “Site” and any “Services”). Please note that your use of the Site and any of our Services is subject to our Terms of Service which you may access at the bottom of our homepage. Our Privacy Policy and Terms of Service are integral to your use of our Site. Your continued use of the Site will constitute your agreement of and acceptance of the Terms of Service and this Privacy Policy. This Privacy Policy and Woorly’s obligations under the General Data Protection Regulation (EU) 2016/679 (“GDPR”) to data subjects residing in the European Union will supercede inconsistent terms in the Terms of Service.

SCOPE OF THE PRIVACY POLICY
The Privacy Policy applies to all information you provide to Woorly through the Site. If you have submitted information to any third parties through our Site and Service, as provided below, the privacy policies of those third parties will govern how your data will be used. Please check the privacy policies of any third party we link to before providing it with your personal information.

WHAT INFORMATION WE COLLECT
We generally collect two types of information—personally identifiable information (“PII”) and non-personally identifiable information (“Non-PII”). PII is any information that can be used to specifically identify you as an individual. For example, you may submit and we may collect your name, email address, address, phone number, or similar information through the Site. Non-PII consists of information that does not specifically identify you. The following sections describe how we collect and use your PII and Non-PII.

HOW WE COLLECT YOUR INFORMATION
Cookies and Beacons
Like all websites, we use cookies and other technologies, including web beacons, so that we can enhance your user experience. Web beacons and cookies collect information such as URLs you came from and go to, your browser and OS information, your IP address, your mobile provider, your mobile device, and your ISP. None of the information collected by our cookies or web beacons is PII.
Cookies are bits of data placed on your hard drive when you visit websites. A cookie file contains information that can identify you anonymously and maintain your account’s privacy. We use cookies to maintain your identity between sessions so that the Site can be personalized based on your preferences or history. We may also use cookies to track information about which pages you visit within the Site to help us gauge the effectiveness of the Site or our content. We may also store other information such as recent searches in your session. We use cookies to tell us, for example, whether you have visited us before or if you are a new visitor, and to help us understand what areas of the Site are of greatest interest to you. Cookies also may enhance your online experience by saving your preferences and password so you do not have to re-enter this information each time you visit the Site. Please be aware that some or all of the cookies may be placed by or be accessible by third parties.
Most web browsers automatically accept cookies, but you can configure your browser to stop accepting new cookies, to notify you when you a new cookie is received, and to disable existing cookies. If you choose to disable cookies in your browser, however, you may be unable to take full advantage of some or all of the Site’s features.

Third-party services and tools we use may also send you cookies to collect certain information from users, which includes:
Google AdWords Conversion, Google Dynamic Remarketing, Google AdWords User Lists, GA Audiences and Google Analytics (collectively referred to as “Google”): Google collects anonymous data (ad views, analytics, browser information, cookie data, date/time, demographic data, hardware/software type, internet service provider, interaction data, page views, and serving domains), pseudonymous data (IP Address (EU PII), Device ID (EU PII), PII (name, address, phone number, email address, login, EU- IP address, EU-unique device ID ), sensitive (financial information). Aggregate data, anonymous data, PII data and sensitive data is shared by Google with third-party parties. We use the information we get from Google only to improve this website and for marketing purposes. Google collects only the IP address assigned to you on the date you visit this website, rather than your name or other identifying information. You can review Google’s privacy policy at https://www.google.com/policies/privacy/. Although Google plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this website, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google about your visits to this website is restricted by the Google Terms of Use and the Google Privacy Policy. You can prevent Google from recognizing you on return visits to the website by disabling cookies on your browser (see below).
DoubleClick: Google operates DoubleClick, which collects anonymous data (ad views, analytics, browser information, cookie data, date/time, demographic data, hardware/software type, internet service provider, interaction data, page views, and serving domains), pseudonymous data (IP Address (EU PII), search history, location based data, and Device ID (EU PII)), and PII (name, address, phone number, email address, login, EU- IP address, and EU-unique device ID). DoubleClick’s privacy policy can be found at: http://www.google.com/intl/en/policies/privacy/. DoubleClick shares aggregate data, anonymous data, PII data and sensitive data with third-party parties. We do not combine the information collected through DoubleClick with personally identifiable information.

Facebook Custom Audience: Facebook Custom Audience is operated by Facebook Business (formerly Facebook Custom Audience), collects: anonymous data (ad views, analytics, browser information, cookie data, date/time, demographic data, hardware/software type, internet service provider, interaction data, page views, and serving domains), pseudonymous data (IP Address (EU PII), search history, location based data, Clickstream Data, PII (name , address, phone number, email address, login, EU- IP address, EU-unique device ID ), sensitive (financial information). Facebook Custom Audience’s privacy policy can be found at: https://www.facebook.com/full_data_use_policy.
Facebook for Developers (formerly Facebook Connect): Facebook for Developers collects: anonymous data (ad views, analytics, browser information, cookie data, date/time, demographic data, hardware/software type, internet service provider, interaction data, page views, and serving domains), pseudonymous data (IP Address (EU PII), search history, location based data, Clickstream Data, PII (name , address, phone number, email address, login, EU- IP address, EU-unique device ID ), sensitive (financial information). Facebook for Developers’ privacy policy can be found at: https://www.facebook.com/about/privacy/.

HubSpot and HubSpot Forms (collectively referred to as “HubSpot”): HubSpot collects: anonymous data (browser information, cookie data, date/time, demographic data, hardware/software type, page views and serving domains) and pseudonymous data (IP Address (EU PII), location based data, Clickstream Data), PII (name, address, phone number, email address, login), and sensitive (financial information). HubSpot’s privacy policy can be found at: https://legal.hubspot.com/privacy-policy. We do not know if HubSpot shares the data it collects with third-party parties. We do not combine the information collected through HubSpot with personally identifiable information.
Segment: Segment operates Segment. Segement’s privacy policy can be found at: https://segment.com/docs/legal/privacy/.
Wistia: Wistia collects: anonymous data (browser information, cookie data, and page views) and pseudonymous data (IP Address (EU PII), PII (name, address, phone number, email address), and sensitive (financial information). Wistia collects aggregate data and shares that data with third-parties. Wistia’s privacy policy can be found at: http://wistia.com/privacy.
Each of the above-listed services and tools listed is governed by the privacy policy established by the respective third-party provider. We encourage you to refer to such policies, which are linked to above in the description of each service.

Links
At times, we may present links in a format that allows us to discern whether these links have been followed.

Log Files
When you are using the Site, we automatically gather basic information from your browser, such as IP address, browser type, ISP, OS, and date/time stamps to analyze trends, administer the site, analyze bugs, and gather broad demographic information. Except as otherwise provided in this Privacy Policy, we will not share log files externally.

Information About You That You Provide
When you register with Woorly, we may collect your name, company information and payment information. Some of this information may be viewed by registered users of the Site.

Email/Telephone
When you register for our services we require an email address and phone number that may be used for communications. Email messages may contain code that helps our systems track your usage of these emails. We reserve the right to send you email regarding service announcements, administrative messages, and Privacy Policy or Terms of Use changes. We may also contact you by telephone solely in connection with Woorly services. If you would rather not receive phone calls from us, please remove your phone number from your account.

Do Not Track Notice.
Your browser may provide you with the option to send a “Do Not Track” signal to websites you visit. This signal is used to request that websites not send the requesting device cookies, but websites have no obligation to respond to such signal or to modify their operation. At the current time, the Site is not programmed to recognize Do Not Track signals, so this Site will not treat you differently if we receive such signals from your browser and we may not comply with Do Not Track settings on your browser.

HOW WE USE YOUR INFORMATION
We will never sell, share, or transfer your information to third parties without your permission. However, you agree that we may use your information: to enhance or improve our users’ experiences; to understand how you use our Service; to process transactions; to send you email newsletters and respond to inquiries; to provide the Service; to register your account and allow you to use our Service; to promote our products or services and other marketing efforts; to develop and improve our Service and associated technology; to develop new products; to maintain and ensure the viability and integrity of our network; to protect the rights or property of you, Woorly, our users or our partners; and to share with other users.
Data Retention Policies: Length of Time Personal Information is Retained
Woorly retains personal information for as long as necessary to fulfill the business purpose for which you provided it to us and any other legitimate business purpose, including without limitation, for the purposes of satisfying any legal, accounting, or reporting requirements. We may also retain offline archival copies of data for the applicable statutory periods. If you would like more details about our data retention policies, please contact us.
Woorly periodically reviews its collection, storage and processing procedures and policies to ensure that it is in compliance with applicable law.

THIRD PARTY CONTRACTORS
We employ third party suppliers, contractors and service providers to facilitate our services and may need to share your information with them to provide information, products or services to you. Examples may include processing credit card payments, hosting, supplementing the information you provide us to provide you a better service, or analyzing data. In all cases where we share your information with such agents, we require the agent to acknowledge and adhere to our privacy and customer data handling policies.

REQUIRED DISCLOSURES
We make every reasonable effort to preserve your privacy, but may need to disclose your PII when required by law or if we have a belief that such action is necessary to:
Enforce the Privacy Policy or the Terms of Use; comply with a judicial proceeding, court order, or legal process; or protect the rights, property, or personal safety of Woorly, its members, you or others.
We may be required to disclose personal data in response to lawful requests by public authorities including to meet national security and law enforcement requirements.
You authorize us to disclose any information about you to law enforcement or government officials as we, in our sole discretion, believe is necessary or appropriate.

Choices Relating to Use of Personal Information
Woorly will give you choices about the ways we use and share your personal information, and we’ll respect the choices you make. Although signing up for some or all of our services may require you to submit personal information, we will ask for your consent if we intend to use that information for any purpose other than providing you with the services requested or as provided for in this document. You may object, restrict or withdraw consent for us to use your personal information at any time.
In the case of Woorly seeking to use your personal information for any purpose not specified upon registration or for the purpose of providing you with the services requested or as provided for in this privacy policy, we will request your consent to use your personal information and will only use it if you affirmatively give us consent to do so through an opt in process.
You may choose to decline to submit any personal information for any of our products or services. Please note that this may result in our being unable to provide said service, including, without limitation, subscription services, even if time remains for your subscription.

YOUR RIGHT TO ACCESS, REVIEW, CHANGE AND OTHERWISE CONTROL YOUR PERSONAL DATA
We acknowledge the EU individual’s right to access their personal data that is stored by Woorly and to ensure that such personal data is accurate and relevant for the purposes for which Woorly collected it. You may control the information you provide to us in various ways. If you would like to change any of your information in our database, you can do so by logging onto your account and following the directions.
If you would like to review your personal data, but you do not have an account or no longer have access to your account, you may contact us at info@woorly.com. However, where such access is unreasonable, requires a disproportionate effort, jeopardizes the privacy of other Woorly users, or contravenes the law, our policies, or reasonable business practice, requests to access data may be declined. User identification is required to access data for these reasons, and the process and procedures for various types of access may differ. Please contact us for further information at info@woorly.com.
To cancel your account, send an email request to info@woorly.com from the email address you provided us in your registration. We will generally endeavor to remove your user information once we have received a cancellation request, but we cannot guarantee that your information has been or will be removed immediately. After cancellation of your account, you agree that we may retain non-accessible archival copies of your information for a commercially reasonable amount of time for internal and legal purposes.

AGE RESTRICTIONS
Any person who provides information through the Site represents that they are 18 years of age or older. We do not knowingly collect PII from anyone under the age of 18. Our Site and Service are not designed for users under 18.

CHILDREN’S PRIVACY PROTECTION
Woorly takes special care to protect the privacy needs of children under the age of 13 and Woorly encourages parents to be an active participant in their child’s online activities. Woorly abides by the Children’s Online Privacy Protection Act (COPPA) and other relevant laws. The website does not target and is not intended for children under the age of 13 and, in fact, is not intended for children under the age of 18. Woorly will not knowingly collect personal information from children. If Woorly discovers personal data from a child under the age of 13 gathered through the website, without parental consent, Woorly will eliminate that data.

CAN-SPAM COMPLIANCE NOTICE
Woorly complies with the Federal CAN-SPAM Act. You may use your account features on the Site to opt-out of notifications, promotional emails and newsletters. You will also have the ability to opt-in in the event that we share your information with other third-party organizations for their marketing or promotional uses or various other programs or features. If you wish to be removed from any communications simply respond to the link provided in the email or email us at info@woorly.com.

Data Portability
Woorly will comply with your request to obtain a copy of the information you have shared through our services. You have rights to obtain a copy of some of the personal information that we hold on you and reuse or share it for your own purposes (“right to data portability”).
The right to data portability only applies:
to personal information you have provided to us (i.e. not any other information);
where we are processing your personal information because you have provided your consent for us to do so, or under a contract with you; and
when processing is carried out by automated means.
Woorly can refuse your data portability request if the processing does not satisfy the above criteria. Also, if the personal information concerns more than one individual, we may not be able to transfer the information to you if doing so would prejudice the other person’s rights.

LINKS TO THIRD PARTY WEBSITES
Woorly or others may post links to third party websites on our Site or Service, which may include information that we have no control over. When accessing a third party site through our Site or Service, you acknowledge that you are aware that these third party websites are not screened for privacy or security issues by us, and you release us from any liability for the conduct of these third party websites.
Please be aware that this Privacy Policy, and any other policies in place, in addition to any amendments, does not create rights enforceable by third parties. Woorly bears no responsibility for the information collected or used by any advertiser or third party website. You must review their terms of service and privacy policy to understand how their information collection practices work.

PRIVACY POLICY CHANGES
We reserve the right to change or update the Privacy Policy at any time, and will notify users of the Site by posting such changed or updated Privacy Policy on this page. Under certain circumstances, we may also elect to notify you of changes or updates to the Privacy Policy by additional means, such as by posting a notice on the homepage of the Site or by sending you an email. Any changes or updates will be effective immediately upon posting to the Site and will be reflected by the Effective Date above and below. Continued use of the Site following any changes shall indicate your acknowledgement of such changes and agreement to the Privacy Policy and any future revisions.

SECURITY
To protect your privacy and security, we take reasonable steps to verify your identity before granting profile access. You are responsible for maintaining the secrecy of your unique password and account information at all times.
The Site uses SSL certificates to help secure your information. However, as this is the internet we make no assurances or guarantees that your information will be safe. For this reason, we recommend you take appropriate measures such as protecting your passwords, using firewalls or downloading anti-virus software. If we learn of a security systems breach, then we may attempt to notify you electronically through our Site or by email so that you can take appropriate protective steps. By using the Site or providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site.

EU-U.S. PRIVACY SHIELD
Woorly complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member’s countries. Woorly has certified that it adheres to the Privacy Shield Principles. If there is any conflict between the policies in this privacy policy, the General Data Protection Regulation and the Privacy Shield Principles, the General Data Protection Regulation shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.
Woorly is responsible for the processing of personal data it receives under the Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. Woorly complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Woorly is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Woorly may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
In compliance with the Privacy Shield Principles, Woorly commits to resolve complaints about your privacy and our collection or use of your personal information. European Union individuals with inquiries or complaints regarding this privacy policy should first contact Woorly at info@woorly.com.
Woorly has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.
Finally, as a last resort and in limited circumstances, EU individuals with unresolved complaints may invoke a binding arbitration option before a Privacy Shield Panel.

COMMITMENT TO GDPR
Woorly is committed to complying with the requirements of the GDPR.

NOTICE TO INTERNATIONAL USERS: CROSS-BORDER TRANSFERS OF PERSONAL INFORMATION AND PROCESSING OF INFORMATION IN THE UNITED STATES OF AMERICA
The Site is hosted in the United States. All information that is submitted by you is stored and processed within the US, which may not have the same data protection and privacy laws as your country. For your personal information, you agree to:
The use of your personal data for the uses identified above in accordance with the Privacy Policy; and the transfer of your personal data to the United States as indicated above.
Please be aware that your information may also be processed by us in the country where it was collected as well as other countries where laws regarding processing of information may be less stringent than the laws in your country.

ACQUISITION OR CHANGE OF CONTROL
If Woorly is involved in any merger, acquisition or any other form of sale. We will endeavor to protect the privacy of personal information, and notify you before such sale or acquisition, and the transfer to a new privacy policy, if applicable. In the event of a change of control of Woorly from, for example, a sale to of stock, membership or assets, or merger with, another entity, or upon Woorly’s filing for a bankruptcy, information Woorly receives from you is a Woorly asset that may be transferred.

CALIFORNIA PRIVACY RIGHTS
Woorly permits residents of the State of California to use its Service, and complies with the California Business and Professions Code §§ 22575-22579.
Under §1798.83 of the California Civil Code, residents of California can obtain certain information from companies with whom they have an established business relationship. That information is about the personal information those companies have shared with third parties for direct marketing purposes during the preceding calendar year. The law requires companies to inform consumers about the categories of personally information shared with third parties, the names and addresses of those third parties, and examples of the services or products marketed by those third parties. To request a copy of the information disclosure provided by Woorly under Section 1798.83 of the California Civil Code, please contact us.
Various provisions throughout this Privacy Policy address requirements of the Californian privacy statutes. Although we do not disseminate your information to third parties without permission, you must presume that we collect electronic information from all visitors. You may contact us at info@woorly.com with any questions.
Contacting Woorly or the Appropriate Supervisory Authority
Enforcement and Independent Dispute Resolution

For EU residents:
To access your information, ask questions about our privacy practices, or issue a complaint, contact us at:
Woorly
1428 Williams Street, Suite Q
Chattanooga, TN 37405
info@woorly.com
You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. The following is the contact information for the supervisory authorities in each member state: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.
As further explained in the Privacy Shield Principles, a binding arbitration option will also be made available to you in order to address complaints not resolved by any other means. To learn more about our privacy practices, see our Privacy Policy details.

For non-EU residents:
To access your information, ask questions about our privacy practices, or issue a complaint, contact us at:
Woorly
1428 Williams Street, Suite Q
Chattanooga, TN 37405
info@woorly.com
If your inquiry is not satisfactorily addressed, contact the Federal Trade Commission (FTC) directly (https://ftccomplaintassistant.gov), and afford the FTC time to attempt to resolve the issue. To learn more about our privacy practices, see our Privacy Policy details.
Our Commitment to Compliance with Applicable Law and Updates to Our Privacy Policy

Compliance Verification and Privacy Policy Updates
Woorly regularly reviews, self-assesses, and verifies that the attestations and assertions made about our Privacy Shield privacy practices are true and these privacy practices have been implemented as represented and in accordance with the GDPR and/or Privacy Shield Principles. As part of the annual compliance verification process, Woorly will follow the steps below in an independent manner:
Review this Privacy Policy to ensure that it accurately and comprehensively describes the practices in place around collection of personal information received from the EU.
Ensure that the publicly posted privacy policy indicates Woorly’s adherence to the GDPR and Privacy Shield Principles.
Confirm that Woorly’s published privacy policy regarding personal information received from the EU is prominently displayed, completely implemented, and accessible to individuals.
Ensure that individuals are informed of any in-house arrangements for handling complaints and of the independent mechanisms through which they may pursue complaints.
Ensure that Woorly has implemented processes and procedures for training our employees in the execution of Privacy Shield policies and the GDPR, including appropriate disciplinary action for failure to follow it.

We undertake not to reduce your rights to privacy as set out in this policy without your consent. If you have any complaints or queries, please do not hesitate to contact us.

CONTACT US
How to Contact Us
If you have any questions or complaints about this Privacy Policy or how we collect or process your personal information, please contact us at info@woorly.com. You may also contact us by mail at 1428 Williams Street, Suite Q, Chattanooga, TN 37405.

Last updated: August 14, 2018. Effective date: August 14, 2018.