WordArrows® LLC — Privacy Policy

This Privacy Policy describes how we collect, use, and share your personal information and the choices you may have regarding our use of your personal information. We may update and make changes to this policy, so we encourage you to review it periodically.

1. Information We Collect. 

In the 12 months prior to the "last updated" date of this notice, we have collected the following categories of personal information:

• Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers;

• Personal information as defined in California Customer Records law such as name, signature, address, telephone number, education, employment, employment history, bank account number, credit or debit card number, and other financial information;

• Commercial information such as purchase or transaction history;

• Internet or other electronic network activity information such as browsing history, search history, and information regarding  consumer's interaction with an internet website application or advertisement;

• Geolocation data about the location of your device;

• Professional or employment-related information;

• Education information; and

• Sensitive personal information such as account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.

Personal information does not include publicly available information.

2. How Your Information is Collected. 

We collect your personal information from:

• You—in person, by telephone, text or email, and/or through our website and mobile apps during transactions, account creation, participation in our programs, contacts with customer service or help lines including chatbots;

• Publicly accessible sources, such as property records;

• Third parties such as affiliates, business partners, credit reporting agencies, customer due diligence providers, advertising networks, internet service providers, social networks, data analytics providers, government entities, and data brokers;

• Third parties with your consent (such as your bank);

• Automated means through your use of your mobile device or other technology, such as when you visit our websites or use our mobile applications or services, or click on advertisements or links in emails you receive from us; and

•Our IT systems, including automated monitoring of our websites and other technical systems, such as our computer networks and connections, email and messaging systems.

3. Why We Collect Your Information. 

We collect and use consumer personal information for the following business purposes:

• To perform services on behalf of the business, including delivering our services, processing registrations, sending confirmations, providing updates, improving our website and training offerings, maintaining or servicing accounts, providing customer service, processing or fulfilling

orders and transactions, verifying customer information, processing payments, providing wanalytic services, or providing similar services on behalf of the business or service provider;

• To send you educational content, offers, and marketing communications, but you can opt out at any time.

• To conduct Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;

• To ensure security and integrity and prevent fraud;

• To debugging and identify and repair errors that impair existing intended functionality;

• To providing advertising and marketing service;

• To undertake internal research for technological development and demonstration;

• To undertake activities to verify or maintain the quality or safety of a service or device and to improve, upgrade, or enhance the service or device;

• To comply with our legal and regulatory obligations;

• For the performance of our contract with you or to take steps at your request before entering into a contract;

• Operational reasons, such as improving efficiency, training, and quality control;

• Conducting checks to identify our customers and verify their identity;

• Gathering and providing information required by or relating to audits, inquiries, or investigations by regulatory bodies.

4. Categories of Information Sold to or Shared with Third Parties. 

In the preceding 12 months, we have not sold or shared any personal information with any third parties. We do not knowingly sell or share the personal information of consumers under 16 years of age.

5. Categories of Information Disclosed for a Business Purpose. 

In the preceding 12 months, we have not disclosed any personal information for a business purpose

with any third parties.

6. Use or Disclosure of Sensitive Personal Information. 

We do not use or disclose your sensitive personal information for purposes other than those listed below:

• To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services;

• To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information;

• To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to aprosecute those responsible for those actions;

• To ensure the physical safety of natural persons;

• For short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer's current interaction with the business, provided that the personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer's experience outside the current interaction with the business;

• To perform services on behalf of the business;

• To verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by

the business; and

• To collect or process sensitive personal information where the collection or processing is not for the purpose of inferring characteristics about a consumer. You have the right to limit the use and disclosure of your sensitive personal information. If you exercise your right to limit the use of your sensitive personal information, we will limit our use and disclosure of your sensitive personal information for the purposes listed above.

7. Your Rights. 

You have the following rights with respect to your personal information:

• Right to know what personal information the business has collected about you, including:

o The categories of personal information we have collected

o The categories of sources from which the personal information is collected

o The business or commercial purpose for collecting, selling, or sharing personal information

o The categories of third parties to whom we disclose personal information –and–

o The specific pieces of personal information we have collected about you.

• Right to delete personal information that we have collected from you with certain exceptions, including where the information is necessary to complete our transaction with you. Subject to the exceptions set out below, on receipt of a verifiable request from you, we will:

o Delete your personal information from our records;

o Direct any service providers or contractors to delete your personal information from their

records;

o Direct third parties to whom the business has sold or shared your personal information to

delete your personal information unless this proves impossible or involves disproportionate

effort.

Please note that we may not delete your personal information if it is reasonably necessary to:

• Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;

• Help to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for those purposes;

• Debug to identify and repair errors that impair existing intended functionality;

• Exercise free speech, ensure the right of another consumer to exercise their right of free speech, or exercise another right provided for by law;

• Comply with the California Electronic Communications Privacy Act, if applicable,

and any other applicable law;

• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;

• Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;

• Comply with an existing legal obligation; or

• Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

• Right to correct inaccurate personal information that we maintain about you. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.

• Right to opt-out of the sale or sharing of your personal information.

• Right to limit the use or disclosure of your sensitive personal information for reasons other than those set forth in Section 6.

• Right not to receive discriminatory treatment for exercising any of these rights. This means we cannot, among other things:

o Deny goods or services to you;

o Charge different prices or rates for goods or services, including through the use of

discounts or other benefits or imposing penalties;

o Provide a different level or quality of goods or services to you; or

o Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Please note that we may charge a different price or rate or provide a different level or quality of goods or services to you, if that difference is reasonably related to the value provided to our business by your personal information. We may also offer loyalty, rewards, premium features,

discounts, or club card programs consistent with these rights or payments as compensation, for the collection of personal information, the sale of personal information, or the retention of personal information.

8. How to Exercise Your Rights. 

You can submit a request to exercise your rights to access, correct, or delete your personal information by sending an email to [mikepierce@wordarrows.com] and providing us with your name, address, phone number, and email. Verification of Your Identify 

We will need your contact information, including your name, address, phone number, and email to verify your identity for access, correction, or deletion requests. Our verification process may also include asking you to log into your account and complete a one-time passcode validation,

asking you to answer a few questions about yourself to help us verify your identity, and/or using a third-party identification service to assist us. We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person

about whom we collected information or is someone authorized to act on such person's behalf.

Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

Authorized Agent Request 

If you are an authorized agent, then you will be required to submit your contact information and complete a certification form as well as provide information about the consumer for whom you are making a request.

9. Contact Us. 

For questions or concerns about our privacy policies and information practices, please contact us at mikepierce@wordarrows.com , wordarrows.com