(“WCCCC”, “we”, “us”, “our”) on our websites located at the domains wcccc.org, as well as such other websites or
mobile applications that we own or operate (individually and collectively, “Our Website” or the “WCCCC Website”).
As further discussed, below, data protection laws, regulations, and directives in
certain jurisdictions distinguish between the rights and responsibilities of “Controller(s)” of personal information
or data (“Information”), from those who are “Processor(s)” of such Information or data on the applicable controllers’ behalf.
WCCCC is generally the controller of Information that it collects from and about the persons and entities who are visiting
Information Collected from WCCCC Visitors
We also provide certain services to commercial persons and entities (each, a “Client” and collectively, “Clients”),
who, in turn, own and operate their own websites or mobile applications (“Client Site(s)”), and who wish
to utilize our code, software and services and reports (the “Service(s)”) to analyze how third party visitors
to their Client Sites (“Client Site Visitor(s)”) use, interact with, and engage their Client Sites.
The applicable Clients are the Controllers of Information collected from their Client Site Visitors,
whether or not such information is accessed, analyzed, or otherwise utilized by or on behalf of the Client
via the Service (“Client Visitor Information”); WCCCC is not the Controller of such Client Visitor Information.
to the Client Sites themselves, nor to any Client Visitor Information. For any questions regarding the privacy,
security, or other practices or policies on the Client Sites, please contact the applicable Client.
Device Information from WCCCC Visitors.
We may receive and collect certain Information furnished by the visitor's browser or otherwise by their access device (“Device Information”), such as:
• Browser Information
• Operating system Information
• Mobile device Information (e.g., device identifier, mobile operating system, etc.)
• IP address (stored in anonymized form)
• Pages accessed
• Geographic location
• Time of visit (by day, week, and duration)
• Whether the visitor is a new or return visitor
• Other such Information as may be delivered or shared by the applicable browser or access software or device.
We may also receive certain information regarding visitors from the prior
website visited by such visitors (“Referral Information”). For instance, If a WCCCC Visitor navigates
to the WCCCC Website from another website, WCCCC may receive certain information from the referring website
(i.e., the last website the visitor visited before visiting the WCCCC Website) as part of the
Hypertext Transfer Protocol ("HTTP") request. For example, if a WCCCC Visitor navigates to the
WCCCC Website from a search engine, WCCCC may receive information contained in the referring URL for
the applicable search query, such as the terms the WCCCC Visitor was searching for before visiting the WCCCC Website.
Registration Information from WCCCC Clients
When WCCCC Visitors register as Clients to use the WCCCC Service,
or request additional information about WCCCC, WCCCC may require Information, such as name,
email mailing address, phone number, and/or proposed Client Site to be tracked, to process
the registration or request ("Client Registration Information").
WCCCC’s Use of WCCCC Visitor Information
WCCCC may use Information of WCCCC Visitors,
including Device Information Referral Information of WCCCC Visitors and Client Registration Information, to:
• Authenticate Client’s access to the WCCCC Site, trial versions, or Service;
• Process and fulfill Client requests or purchases;
• Register for annual conference;
• Check the WCCCC Visitor’s qualifications for registration and/or to bill WCCCC Clients for the Services.
WCCCC may also use Client Information to:
• Provide WCCCC's products and Services, personalize and tailor your experience on the WCCCC Website;
• Operate our business;
• Understand how Clients are engaging with WCCCC Website and Service;
• Request additional information necessary to process or fulfill an order;
• Assess Client satisfaction with the WCCCC Service;
• Inform Clients that an upgrade is available; or to contact Clients with information about WCCCC,
including information about new or existing products and services or special offers.
For example, we may periodically send promotional materials or notifications related
to our products and Services to the email address associated with annual registration.
• Otherwise for our legitimate business interests.
If Information is aggregated or de-identified so it is no longer
reasonably associated with an identified or identifiable natural person, WCCCC may use it for any business purpose.
To the extent Information is associated with an identified or identifiable natural person and is protected as personal
(small text files that WCCCC stores locally on a Client Site Visitor’s device) on Client Sites for one or
more of the following purposes: to help identify whether a Client Site Visitor is a first time visitor,
or has visited previously (provided that we will not store identifiers that can be used to personally
identify such Client Site Visitors); assess usage patterns and perform traffic analysis;
identify preferences; diagnose problems with our Service; analyze trends; and otherwise administer
WCCCC products and services. Cookies placed by WCCCC on the computers of Client Site Visitors do not include
Personally Identifiable Information such as name, phone number, e-mail address or mailing address,
nor does WCCCC link cookies to such Personally Identifiable Information on our servers or databases.
Our Clients' Use of Client Visitor Information
Each Client hereby:
Our Processing of Client Visitor Information
• Directs WCCCC, only in accordance with applicable law to provide the Services
• Represents, warrants, and covenants that it will abide by all applicable laws, rules, and
regulations applicable to Client Site Visitors and Client Visitor Information, and ensure that
any instructions to WCCCC are consistent with, and do not and will not constitute a violation of same;
• Represents, warrants, and covenants that it has obtained all consents required
under applicable laws or regulations for the processing of Client Visitor Information under the
Service as described hereunder and in the Terms and as otherwise instructed by the Client; and
that provides each Client Visitor with notice of its practices regarding data collection, use,
and that otherwise complies with all applicable laws.
As the Processor of Client Visitor Information,
we will process Client Visitor Information only in compliance with the applicable Client’s instructions
regarding the processing of Client Visitor Information, including any applicable Terms,
but subject to applicable laws and regulations regarding such Client Visitor Information,
and as otherwise required by applicable law and regulations.
WCCCC Disclaimers Regarding Personally Identifying Information of Client Site Visitors
WCCCC's Service is not designed to knowingly collect or extract from
Client Visitor Information (including any Recorded Interactions or Device Information received
from Client Sites through the Service) information that could be used to personally
identify Client Site Visitors, such as a Client Site Visitor’s name, address or phone number
("Personally Identifiable Information") when a Client Site Visitor visits a
Client Site that uses the WCCCC Service. In particular, WCCCC does not attempt
to identify, decipher, access, or associate Personally Identifying Information regarding
a Client Site Visitor from any Recorded Interactions or Device Information, provided that WCCCC
may receive Referral Information, as noted above. WCCCC includes tools to enable Clients to
preempt the collection of or remove sensitive data from the WCCCC Service, to be set by
the applicable Clients as the Data Controllers.
WCCCC Does Not Collect Visitor Information Across Multiple Sites
WCCCC does not collect or aggregate information about visitor behavior on multiple, different websites.
Retention and Deletion of Client Visitor Information
WCCCC will retain Client Visitor Information in accordance with the applicable Client’s instructions,
including any applicable Terms and as required by applicable law. Client agrees and acknowledges that the deletion of Client Visitor Information
may affect the delivery or performance of the Service. WCCCC will comply with such instructions to delete
Client Visitor Information as soon as reasonably practicable and within a maximum period of 180 days,
unless applicable laws require retention. WCCCC may retain Client Registration Information as long as necessary
Client Registration Information after each year’s registration as needed for WCCCC to pursue
legitimate business interests, record keeping procedures, legal compliance, preservation of rights,
security purposes, and enforcement of legal and contractual rights.
WCCCC's Sharing and Disclosure of WCCCC Visitor Information and Client Visitor Information
Client agrees and acknowledges that it will be responsible for exporting any
Client Visitor Information or Client Registration Information that it wishes to
retain following the termination of the Terms.
This section describes the manner and extent to which WCCCC may share and disclose Information.
Notwithstanding anything to the contrary below or elsewhere herein, as between a Client and WCCCC, the Client is solely responsible
for its policies and practices for the sharing and disclosure of Client Visitor Information as the Controller of such Information.
WCCCC’s Default Policy Regarding Sharing of Client Visitor Information
WCCCC never sells or shares any Client Visitor Information with individuals or companies other than the specific Client from whose
Client Site WCCCC collected the Client Visitor Information. This Client Visitor Information is provided to Clients
in the form of aggregated reports and/or statistics that identify the collective behavior of Client Visitors to the Client's Site.
Clients will also have access to Recorded Interactions through the Service.
WCCCC’s Default Policy Regarding Sharing of Client’s Personally Identifiable Information
WCCCC does not provide Clients' Personally Identifiable Information to third parties for any purpose.
Disclosure Pursuant to the Client’s Instructions
WCCCC will share and disclose Client Visitor Data in accordance with the applicable Client’s instructions,
including any applicable Terms, and otherwise in compliance with but subject to applicable laws and regulations.
We may utilize affiliates or third parties as subprocessors of the Information,
to support the Services, and otherwise to support the conduct of our business, to provide, by way of example,
service such as computing and storage services. We will use subprocessors subject to contracts that are substantially
as protective of Personally Identifiable Information as those contained herein, and, to the extent applicable,
in compliance with Article 28(3) of the General Data Protection Regulation.
Change of Control
If WCCCC, or substantially all of its assets, is acquired by another company or successor entity,
the Information hereunder will be one of the assets transferred or acquired by the purchaser or successor.
You acknowledge that such transfers may occur, and that any purchaser of or successor to WCCCC or
its assets may continue to collect, use and disclose your Information as set forth in this policy.
Like many companies that accept payment by credit card,
WCCCC relies on third-party payment processors to process financial payments. When you make payments to WCCCC
to obtain or use WCCCC's products or services, WCCCC may share Personally Identifiable Information, such as your
name, address, and credit card information, with qualified third parties in order to process your order.
Law Enforcement/Legal Process
WCCCC reserves the right to disclose any Information (including Personally Identifiable Information):
Aggregated, Anonymized, Pseudonymized, or De-identified Information
(1) to comply with any law, regulation, or legal request, if and to the extent that we reasonably believe disclosure is in
accordance with or required by any applicable law, regulation or legal process;
(2) to enforce, apply, or investigate breaches of the Terms or other agreements; or
(3) protect the rights, property, user experience, or safety of WCCCC, our employees, our users, our Clients, or others.
We may disclose or use aggregated, anonymized, pseudonymized, or otherwise de-identified Information for any purpose.
Transfer of Data Abroad; International Users
If you are visiting the Our Website or a Client Site from a country other than
the United States of America the various communications will necessarily result in the transfer of information
across international boundaries. By visiting the Our Website or the Client Site, as applicable, you consent to the
as applicable, you consent to the collection, storage, processing, and transfer of your information in and to the United States,
or other countries and territories, pursuant to the laws of the United States.
Security and Protection of Visitor Information and Client Information
If we transfer Personally Identifying Information from a Client Site in the European Economic Area (“EEA”)
to other countries not deemed adequate under applicable data protection law, we will do so in compliance with either:
European Union Model Clauses. WCCCC will offer to enter into the European Union Model Clauses,
also known as Standard Contractual Clauses, with the Client. To enter into such clauses, please contact us at email@example.com;
E.U.-U.S. Privacy Shield and Swiss-U.S. Privacy Shield (“Privacy Shield”). WCCCC will transfer such Information in
compliance with the data protection requirements under the Privacy Shield. To learn more about the Privacy Shield Program,
please see http://www.privacyshield.gov/welcome.
WCCCC implements security mechanisms to protect Visitor Information and Client Information from loss,
misuse and unauthorized access, disclosure, alteration and destruction. Examples of these security mechanisms include
limited and password-protected access, firewalls, and SSL encryption to protect transmission of data, as further
please contact us at firstname.lastname@example.org.
Policy Concerning Children Under Age of 16
WCCCC does not knowingly or intentionally collect Personally Identifiable Information from
children under 16. If we learn that we have Personally Identifiable Information of a child under age 16,
we will remove it. If you believe we have Personally Identifiable Information about a child under the age of 16,
please notify us at email@example.com.
WCCCC retains the discretion to amend or modify this policy from time to time.
Use and disclosure of Information we obtain is subject to the later of:
For More Information / Your Information Rights
(1) the policy in effect at the time such visitor Information or Client Information is collected or
(2) any subsequent policy to which you agree or of which you have notice, if you elect to use WCCCC or a WCCCC Client Site
(including the WCCCC Website) following such acceptance or notice.
If we make material changes in the way we use or disclose Personally Identifiable Information, we will notify you through one or more of the following means:
a direct communication to your WCCCC registration, a communication to the email address associated with your registration,
or a clear and prominent announcement on the WCCCC Website. Your continued access to or use of WCCCC or websites that use
WCCCC welcomes any questions or comments about this
Any such comments or questions should be submitted via e-mail to: firstname.lastname@example.org.
Access to Personally Identifiable Information or other Information Stored at WCCCC
At any time, a WCCCC Client or WCCCC Visitor may access and/or modify their Personally
Identifiable Information or other Information stored by WCCCC on their behalf, to enable them to access,
rectify and restrict processing of their respective Information, and allow them to export their Information,
by accessing their WCCCC registration and contacting us at email@example.com.
California Information Rights
Under California Civil Code Section 1798.83 (the “Shine the Light” law), California residents
who provide personal information in obtaining products or services for personal, family or household use are entitled to request
and obtain from us once per calendar year certain disclosures about the personal information we shared, if any, with
other businesses for their own direct marketing uses. If applicable, this information would include the categories of
personal information, and the names and addresses of those businesses with which we shared personal information,
for the immediately prior calendar year (e.g. requests made in 2019 will receive information regarding 2019 sharing activities).
To make such a request, please send an email to firstname.lastname@example.org with a subject line of "Request for California Privacy Information."
Please be aware that not all information sharing is covered by the "Shine the Light" requirements and
only information on covered sharing will be included in our response.