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PRIVACY POLICY

PRIVACY POLICY

We have the utmost respect for your privacy, and understand that your personal information is important to you

Migota Ltd. and its subsidiaries and affiliates (the “Company” and all references, as the context requires, to “we”, “us” or “our”) are committed to protecting and respecting your rights to privacy. The basis on which any personal data we collect from you, or that you provide to us, will be processed by us on a lawful basis is set forth in this privacy policy, in our Terms of Use (https://worddio.com/terms) and the GDPR webpage (https://worddio.com/eu-gdpr)

IMPORTANT: BY USING THE SERVICES (AS DEFINED BELOW), YOU GIVE YOUR CONSENT THAT ALL PERSONALLY IDENTIFIABLE INFORMATION ("PII") THAT YOU SUBMIT OR THAT IS COLLECTED THROUGH THE SERVICES, INCLUDING ANY PII RELATING TO YOUR CHILDREN, MAY BE PROCESSED BY THE COMPANY (AS DEFINED BELOW) IN THE MANNER AND FOR THE PURPOSES DESCRIBED IN THE FOLLOWING PRIVACY POLICY. IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS SET FORTH HEREIN, PLEASE DO NOT USE THE SERVICES.

Migota Ltd., as owner of the website Worddio.com and the mobile application Worddio. At Migota Ltd. (the "Company", "we" or Worddio), we recognize that privacy is important. This policy applies to all of the software, services, information, tools, features and functionality offered by the Company and/or its subsidiaries and/or affiliated companies on our proprietary application known as "Worddio" and its website available at: Worddio.com (collectively, the "Services") and covers how PII that the Company collects and receives, including in respect of any use of the Services, is treated. If you have any questions about this policy, please feel free to contact us at support@worddio.com

Information We Collect and How We Use It

Unless stated otherwise in this policy, the Company will not share, sell, auction off or give away your PII to any third-party or other organization without first obtaining your prior written consent. In order to provide our Services, we may collect the following types of information:

  • Information you provide. For some features of the Services we ask you for PII, including, but not limited to: nick name and email address.
  • Third Parties. We sometimes supplement the information that you provide with information that is received from third parties. If you interact with Facebook and/or Instagram, Twitter, Google plus and/or any other social media network or other social media plug-in in the Services (such as a Facebook “Like” button) (“App Platforms“) in connection with the Services (such as by sharing a scanned photo on Facebook or Instagram, Twitter, Google plus via the Services), we may receive information from your respective App Platform account, including your name, photo, email address, friends list and any information defined as public pursuant to the policies of such App Platforms. You are responsible for your decision to share your photos and any other information with others, including on the App Platforms. You should check your App Platforms privacy settings to understand and change the information sent to us through the App Platforms. The Company is not responsible for the privacy practices of such third parties and/or App Platforms. We recommend you to carefully read the terms of use and privacy policies of such third parties and/or App Platforms before using their services and connecting to the Services. This privacy statement applies solely to PII collected by us.
  • Personal information. We process your PII only for specific and limited purposes, including the provision of the Services. We ask only for PII that is adequate, relevant and not excessive for those purposes. Some of these purposes may include to inform you of new services and features we will be providing, to send you requested information and additional materials in respect of the Services, for promotional purposes, and internally to help us improve our Services and to help resolve any problems.
  • User information. When you use the Services, we may automatically receive and record information from your device about operating system. Our systems may automatically record and store technical information regarding the method and nature of your use of the Services, including, without limitation, the date on which you registered to the Services, which pages or widgets of the Services our visitors view and the dates and times on which they viewed such pages or widgets, impressions, the number of views they get and any actions they make in the Services (such as when a pass the test, download, or deleted, personal word list, in-app purchase).
  • Traffic data collected through the Services. In addition to the information we collect as described above, we may use technology to collect information about the use of the Services. For example, our systems may automatically record and store browser information, search history, exit point, use time, platform type, operating system information, number of clicks and cookies. This technology does not identify you personally, it simply enables us to compile statistics about our visitors and their use of the Services. The Services contain hyperlinks to other pages, widgets and features on the Services. We may use technology to track how often these links are used and which pages, widgets and features of the Services our visitors choose to view. Again this technology does not identify you personally it simply enables us to compile statistics about the use of these hyperlinks.
  • Cookies. In order to personalize your experience and collect and analyze the anonymous data described herein, we may use temporary cookies that remain on your device for a limited period of time. We may also use persistent cookies that remain on your device until the application is removed, in order to record any content you may have gained access to by using Services. Cookies by themselves cannot be used to discover the identity of the user. A cookie is a small piece of information which is sent to and stored on your device. Cookies do not damage your device. Most browsers or devices may allow you to block cookies but you may not be able to use some features on the Services if you block them. You may set most browsers to notify you if you receive a cookie (this enables you to decide if you want to accept it or not).
  • User communications. When you send email or other communication to the Company, we may retain those communications in order to process your inquiries, respond to your requests and improve our Services. We may send you push notifications to send you special updates in respect of the Services. You should be able to opt-out of these notifications at the device level. We may also send you newsletters and promotional communications if you joined our mailing list, you may opt-out of this service at any time by submitting a request to support@worddio.com
  • Links. Links to other sites and applications may be provided by the Company as a convenience to our users. The Company is not responsible for the privacy practices or the content of other sites and applications and you visit them at your own risk. We recommend you to carefully read the terms of use and privacy policies of such sites and applications. This privacy statement applies solely to PII collected by us.
  • Children. We care about the safety of children. Because the Services are not directed towards children under 18, they are not allowed to register with or use the Services, or provide PII. If you are under the age of 18 or the age of legal majority where you reside if that jurisdiction has an older age of majority, you must obtain parental consent (or consent from your legal guardian) prior to using our Services. We do not knowingly contact or engage with children under the age of 18 (or the age of legal majority where you reside if that jurisdiction has an older age of majority) without said parental consent (or consent from your legal guardian). If you have reason to believe that a child under the said age has provided us with their PII, please contact us at the address given above and we will endeavor to delete that PII from our databases.
  • Maintenance. The Company uses the PII that you provide or that we collect to operate, maintain, enhance, and provide the Services.
  • Analysis. The Company uses all of the PII that we collect to understand the usage trends and preferences of our users, to improve the way the Services work and look, and to create new features and functionality.
  • Choices for personal information. We will not collect or use PII for purposes other than those described in this policy and/or in any other legal instrument in effect between us. If we intend to use your PII for any purposes other than those described in this policy and/or in the Worddio Terms of Use, then we will ask for your consent prior to such use. You can decline to submit PII, in which case the Company may not be able to provide you with Services.

Information sharing

The Company only shares PII with other companies or individuals in the following limited circumstances:


  • As required for the provision of the Services, including, without limitation, sharing information with payment service providers and other service providers (including for analysis and statistics), and with App Platforms. The Worddio servers that are used to store your PII are owned and hosted by Coolicehost LLC, authorized retailer of good and services provided by CooliceHost.com (their privacy policies and practices may be found athttps://coolicehost.com/privacy-policy.html ).
  • We have your consent.
  • We require opt-in consent for the sharing of any sensitive PII.
  • We have a good faith belief that access, use, preservation or disclosure of such PII is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable agreements and/or their terms, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against imminent harm to the rights, property or safety of the Company, its users or the public as required or permitted by law.
  • If we become involved in a merger, acquisition, or any form of sale of some or all of our assets. In the event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how PII is treated, transferred, or used. In any of the circumstances described in this paragraph, the information will be subject to the privacy policy of the      purchaser or assignee.
  • If we obtain assurances from our agents that they will safeguard PII through measures consistent with this policy. Where we have knowledge that an agent is using or disclosing PII in a manner contrary to this policy, we take commercially reasonable steps to prevent or stop the unauthorized use or disclosure.

Information security

We follow generally accepted industry standards to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of PII. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your PII, we cannot guarantee its absolute security.

  • We strive to maintain the reliability, accuracy, completeness and currency of PII that we collect and to protect the privacy and security of our users. We keep your PII only for as long as reasonably necessary for the purposes for which it was collected or to comply with any applicable legal or ethical reporting or document retention requirements.
  • We limit access to PII about you to employees, contractors and agents who we believe reasonably need to come into contact with that PII. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.
  • Personal information. We process your PII only for specific and limited purposes, including the provision of the Services. We ask only for PII that is adequate, relevant and not excessive for those purposes. Some of these purposes may include to inform you of new services and features we will be providing, to send you requested information and additional materials in respect of the Services, for promotional purposes, and internally to help us improve our Services and to help resolve any problems.
  • We have physical, electronic, and procedural security measures and safeguards to reasonably protect PII. Our servers and our databases are protected by industry standard security technology, such as industry standard firewalls and password protection.
  • Although we cannot guarantee against any loss, misuse, unauthorized disclosure, alteration or destruction of data, we try to prevent such unfortunate occurrences.

Data integrity, accessing and updating personal information

The Company processes PII only for the purposes for which it was collected and in accordance with this Policy or any applicable service agreements. We review our data collection, storage and processing practices to ensure that we only collect, store and process the PII needed to provide or improve our Services. We take reasonable steps to ensure that the PII we process is accurate, complete, and current, but we depend on our users to update or correct their PII whenever necessary. Nothing in this policy is interpreted as an obligation to store information, and we may, at our own discretion, delete or avoid from recording and storing any and all information.

  • Upon receipt of your written request and enough information to permit us to identify your PII, we will disclose to you the PII we hold about you. Upon your request, we will also correct, amend or delete any PII that is inaccurate and notify any third party who received this PII from us of the necessary changes.
  • We do not charge for complying with a correction request, however, for all other requests, we may charge a small fee to cover its costs. Requests to delete PII are subject to any applicable legal and ethical reporting or document retention obligations imposed on the Company.
  • We ask individual users to identify themselves and the PII requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical, or for which access is not otherwise required.

Enforcement

The Company regularly reviews its compliance with this policy. Please feel free to direct any questions or concerns regarding this policy or our treatment of PII by contacting us as provided above. When we receive formal written complaints it is the Company’s policy to contact the complaining user regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of PII that cannot be resolved between the Company and an individual.

Changes to this Privacy Policy

The Company may update this policy. We will notify you about significant changes in the way we treat PII by sending a notice to the primary email address specified in your account or by placing a prominent notice on the Services. We encourage you to periodically review this policy for the latest information about our privacy practices.

Consent To Processing

By providing any PII to us pursuant to this policy, all users, including, without limitation, fully understand and unambiguously consent to this policy and to the collection and processing of such PII abroad. The server on which the Services are hosted and/or through which the Services are processed may be outside the country from which you access the same and may be outside your country of residence. Some of the uses and disclosures mentioned in this policy may involve the transfer of your PII to various countries around the world that may have different levels of privacy protection than your country. By submitting your PII through the Services, you consent, acknowledge, and agree that we may collect, use, transfer, and disclose your PII as described in this policy. If you do not consent to the terms of this policy, please do not use the Services.

Questions

If you have any questions about this policy, concerns about the way we process your PII, or if you wish to delete all information regarding your use of the Services, please contact us at support@worddio.com



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