Privacy Policy

About This Policy

This Privacy Policy (“Privacy Policy”) details our data collection processes, including the data we receive about you and how we process it, and your rights and obligations in relation to your personal data.

Unless we link to a different policy or state otherwise, this Privacy Policy applies when you visit or use the WireNxt services such as any WireNxt website or the website of a WireNxt owned and operated platform (the “Site”), community and customer service links or chat functionality, mobile applications, social media pages or handles, online and offline products and events, APIs or related services, and any accompanying services you are eligible to receive, such as teacher support services and tools (together, the “Services”). It also applies to prospective customers and enterprise products. By using or accessing the Services, you agree to the terms of this Privacy Policy. From time to time, we may develop new or offer additional services. They’ll also be subject to this Privacy Policy, unless stated otherwise when we introduce them.

Capitalized terms not defined here have the meanings set forth in the Terms of Service (the “Terms”). Your use of the Sites and Services is also subject to the Terms. You shouldn’t use the Services if you don’t agree with this Privacy Policy or any other agreement that governs your use of the Services, including the Governing Documents.

Personal Data We Collect About You

When you register with us, when you become a WireNxt Member or a member of any WireNxt owned or operated platform, when you choose to teach, attend, or host a class or Event (as defined in our Terms of Service), when you offer content or services for sale on WireNxt or a WireNxt owned or operated platform, or when you engage with WireNxt-sponsored webpages, including those involving surveys or quizzes, we may ask you for Personal Data. “Personal Data” refers to information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. In addition, we may collect data that is not identifiable to you or otherwise associated with you, such as aggregated data. This is not Personal Data. To the extent this data is stored or associated with Personal Data, it will be treated as Personal Data; otherwise, the data is not subject to this Privacy Policy.

These tables set out the categories of personal data we collect and use.

Category	Description
User Data & Identifiers	Personal data that we need to create your account and that enables you to use the Services. The specific types of information we collect will depend upon the Services you use, how you use them, and the information you choose to provide. The types of data we collect directly from you includes name, alias, email address, postal or billing address, zip code, account name, phone number, social media profiles, or other similar identifiers.
Payment Information	If you sign up for a membership, free trial, or other service, or make purchases, we collect certain data about your purchase (such as your name, billing address, and ZIP code) as necessary to process your order and which may be saved to process future orders. The exact personal data collected and used will vary depending on the payment method. You must provide certain payment and billing data directly to our payment service providers, including your name, credit card information, billing address, and ZIP code. We may also receive limited information, like the fact that you have a new credit card and the last four digits of that card, from payment service providers to facilitate payments. Wirenxt does not collect or store sensitive cardholder data, such as full credit card numbers or card authentication data.
Refund Information	At WireNxt, we strive to deliver high-quality digital marketing services to our clients. Our refund policy is designed to be fair and transparent. For ongoing service contracts, we do not offer refunds for services already rendered, but we will prorate the final bill if a client terminates services mid-month. Any unused portion of a prepaid retainer will be refunded within 30 days of contract termination. For project-based services, clients have 7 days from delivery to request revisions. If dissatisfaction persists after two rounds of revisions, a partial refund may be considered on a case-by-case basis. No refunds are issued 30 days after project completion. For workshops and training, full refunds are available for cancellations made more than 14 days before the event. We handle all refund requests promptly and professionally, aiming to maintain positive client relationships while protecting our business interests.
Other Information	Additional data you may choose to give us includes: demographic information such as your gender or other information; user-generated content you provide to us, such as when you upload a project, upload courses and other educational content, leave a class review, ask or answer a question, or otherwise participate in a public discussion forum; information you provide when you participate in a survey or research study, including testimonials; participation in promotions, sweepstakes or contests, or other marketing promotions; Information you provide when you communicate with our customer support team; and Information about others, including email address, for referral invitations.

Information automatically collected through your use of the Services

When you use our Services, we collect and analyze:

technical data such as your IP address, browser types, browser language, operating system, software and hardware attributes (including device IDs), online identifiers such as cookie data, referring and exit pages, and URLs;
Wirenxt app data such as mobile phone, tablet, or computer used to access the app, including device identifiers, IP address, operating system, version, internet service provider, browser type, domain name and other similar information, whether and when you update the app, date and time of use, error logs, and other similar information about how you use the app;
site usage patterns such as the number of clicks, mouse movements, scrolling, and time spent on a page;
navigation data such as pages viewed and the order of those pages, date and time of use, session duration, and error logs;
learning data such as content or classes watched, total minutes watched, and categories of classes you search for;
purchase data, such as the content or services you purchase or search for; and
other similar information.

When you use our Services, we collect and analyze:

technical data such as your IP address, browser types, browser language, operating system, software and hardware attributes (including device IDs), online identifiers such as cookie data, referring and exit pages, and URLs;
WireNxt app data such as mobile phone, tablet, or computer used to access the app, including device identifiers, IP address, operating system, version, internet service provider, browser type, domain name and other similar information, whether and when you update the app, date and time of use, error logs, and other similar information about how you use the app;
site usage patterns such as the number of clicks, mouse movements, scrolling, and time spent on a page;
navigation data such as pages viewed and the order of those pages, date and time of use, session duration, and error logs;
learning data such as content or classes watched, total minutes watched, and categories of classes you search for;
purchase data, such as the content or services you purchase or search for; and
other similar information.

We may use third-party providers such as Crazy Egg, Hot Jar, or Microsoft Clarity to log your activity. This provides us with a set of data and a session replay of your activity on WireNxt in the form of a video. Third-party providers like those mentioned here capture and analyze your usage data to help us make your WireNxt experience better. By agreeing to this Privacy Policy, you agree to our use of such third-party providers to log such activity and complete such analyses.

Category	Description
Usage Data
General (Non-Precise) Location	Your general location includes country, region, or state. We may learn this from technical data (e.g. your IP address, the language setting of your device) or payment currency.

Information collected from partners and other third parties

If you link, connect, or login to the Services with a third party service (e.g. Google, Facebook, Apple), you direct the service to send us information such as your registration and profile information as controlled by that service or as authorized by you via your privacy settings at that service.

Category	Description
Third-Party Services
Payment Partners and Merchants	If you choose to pay through third parties or by invoice, we may get data from our payment partners. This allows us to send you invoices or process your payments. If we direct you to a merchant, we receive data from the merchant that is related to your purchase. For example, we might direct you to one of our partner’s websites on a third party platform. Receiving this data allows us to analyze the effectiveness of our partnership with these merchant partners and understand your interests.
Information from Other Sources	We also obtain information from other sources. We protect this information according to the practices described in this Privacy Policy, plus any additional restrictions imposed by the source of the data. These sources vary over time, but could include: service providers that help us determine a location based on your IP address in order to customize our service and for other uses consistent with this Privacy Policy; security service providers who provide us with information to secure our systems, prevent fraud, and help us protect the security of WireNxt accounts; payment service providers who provide us with payment or balance information, or updates to that information, based on their relationship with you; online and offline data providers, from which we obtain aggregated demographic, interest-based, and online advertising related data; publicly-available sources such as publicly available posts on social media platforms and information available through public databases associating IP addresses with internet service providers; and advertising or marketing partners from whom we receive inferences (i.e., their understanding) of your interests and preferences. We may also receive additional information such as demographic and statistical information from third parties, including business partners, marketers, researchers, analysts, and other parties that we may attribute to you based on your assignment to certain statistical groups. We use this information to supplement the information that we collect directly from you in order to derive your possible interests, provide more relevant experiences for you, and improve our products, analytics, and advertising.

How We Use the Personal Data We Collect About You

At WireNxt, we are committed to transparency in our data practices. We collect and use your personal data for specific, legitimate purposes related to providing and improving our digital marketing services. Here’s how we use the information we collect:

Service Delivery and Improvement We use your personal data to deliver the digital marketing services you’ve requested. This includes tailoring our strategies, creating targeted campaigns, and optimizing your online presence. We also analyze this data to improve our services and develop new features that better meet our clients’ needs.
Communication Your contact information allows us to keep you informed about your campaigns, send important updates, and respond to your inquiries. We may also send you newsletters, marketing communications, or invitations to events that we believe may interest you, always with the option to opt out
Account Management We use your data to manage your account, process payments, and maintain accurate billing and administrative records.
Personalization By analyzing your data and interaction with our services, we can personalize your experience, offering more relevant recommendations and content tailored to your business needs.
Analytics and Reporting We use collected data to generate insights about the performance of your marketing campaigns. This helps us create detailed reports and make data-driven decisions to enhance your marketing strategies.
Legal Compliance Some data processing is necessary to comply with our legal obligations, including maintaining records for tax purposes and responding to legal requests from authorities when required.
Fraud Prevention and Security We use personal data to verify accounts, monitor for fraudulent activity, and maintain the security of our services and clients’ information.
Business Development Aggregated and anonymized data helps us understand market trends, allowing us to develop new services and improve existing ones to better serve our clients.
Client Support When you contact our support team, we use your information to assist you and resolve any issues you may be experiencing with our services.
Consent-Based Processing For certain types of data or specific uses, we may seek your explicit consent. In such cases, you have the right to withdraw your consent at any time.

Disclosing Your Personal Data

At WireNxt, we understand the importance of your privacy and handle your personal data with utmost care. We are committed to transparency regarding when and why we might disclose your information. Here’s a comprehensive overview of the circumstances under which we may share your personal data:

Service Providers and Subcontractors We may share your data with trusted third-party service providers who assist us in delivering our services. These may include:
Cloud storage providers
Analytics tools
Customer relationship management (CRM)
systems Email marketing platforms
Payment processors
Legal Requirements We may disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency). This could occur in response to:
Subpoenas
Court orders
Other legal processes
Business Transfers If WireNxt is involved in a merger, acquisition, or sale of all or a portion of its assets, your personal data might be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our website of any change in ownership or uses of your personal data.
Protection of Rights We reserve the right to disclose your personal data when we believe release is appropriate to:
Comply with the law
Enforce our policies
Protect our or others’ rights, property, or safety
With Your Consent We may share your personal data with third parties if you have given us explicit consent to do so. You can withdraw this consent at any time.
Anonymized or Aggregated Data We may share anonymized or aggregated data that cannot be used to identify you with third parties for various purposes, including industry analysis, academic research, or marketing.
Affiliates and Subsidiaries We may share your information with our affiliates or subsidiaries for business purposes. All such entities are governed by this privacy policy or are bound by appropriate confidentiality agreements.
Marketing Partners With your explicit consent, we may share your data with marketing partners to provide you with information about products or services that may interest you.
Social Media Platforms If you choose to connect your account to other social media platforms, we may disclose profile information to those platforms. We encourage you to review the privacy policies of these third-party services.
Public Forums If you post information in public areas of our website or services, this information may be viewed by any user of the website or services.

We assure you that:

We do not sell your personal data to third parties.
Any third parties we share data with are bound by strict confidentiality agreements and data protection requirements.
We only disclose the minimum amount of data necessary for the specific purpose.
We maintain records of all disclosures and can provide you with this information upon request.

If you have concerns about how your data is being shared, or if you wish to exercise your rights regarding your personal data, please contact our Data Protection Officer at [email protected]

Other Third Parties

We also share Personal Data with third parties when necessary to complete a transaction initiated or authorized by you, to provide you with a product or service you have requested, or to facilitate a sublicensing transaction or arrangement with such a third-party. In addition to those set forth above, these parties also include:

other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the Services), such as when users and Teachers interact through the Services;
social media services (if you interact with them through your use of the Services);
business partners that you access through the Services or that we engage to offer co-branded services, sell or distribute our products, or engage in sublicensing or joint marketing activities.

Aggregate/Anonymous Data

From time to time, we may share aggregated or anonymous information about use of the Services, such as by publishing a report on usage trends.

Protection of WireNxt and others

We also share Personal Data when we believe it is necessary to:

Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies;
Protect us, our business, our users, and others, for example to enforce our terms of service, prevent spam or other unwanted communications, and investigate or protect against fraud;
Maintain the security of our products and services.

Business Transfers

In connection with any reorganization, restructuring, merger or sale, or other transfer of assets, we will transfer information, including personal information, provided that the receiving party agrees to respect your personal information in a manner that is consistent with our Privacy Policy.

Legal Bases for use of Your Information

We process Personal Data for, or based on, one or more of the following legal bases:

Performance of a Contract

By using the Services, you have contracted with us through the Terms of Service, and we will process certain Personal Data to perform under that contract, including first and last name, email address, password, location information, and, if you are a Teacher, the content of your classes or other materials or services you publish or offer on the Services. When we process Personal Data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.

Legitimate Interests

We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties: first and last name, email address, location information, IP address, and your activity on the Services, including class usage information and community interaction data. Examples of these legitimate interests include: operation and improvement of our business, products, and services; personalization of web content on the Services; analyzing the use of the Services; marketing of our products and Services; provision of customer support; protection from fraud or security threats; compliance with legal obligations; and completion of corporate transactions.

In some cases, we process Personal Data based on the consent you expressly grant to us prior to the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you prior to the point and time of collection.

Other Processing Grounds

From time to time, we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

Retention of Your Information

We will retain your Personal Data for as long as your account is active or as needed to provide you services and to maintain a record of your transactions for financial reporting purposes. We will also retain and use your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Protection of Your Information

WireNxt takes technical and organizational security measures that are designed to safeguard Personal Data. However, no online activity is ever fully secure or error-free. While we strive to protect your information, we cannot guarantee that your Personal Data is absolutely secure. Please keep this in mind when disclosing any information to WireNxt.

Please recognize that protecting your Personal Data is also your responsibility. We urge you to take every precaution to protect your information when you are on the Internet, or when you communicate with us and with others through the Internet. Change your passwords often, use a combination of letters and numbers, and make sure you use a secure browser. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account might have been compromised), or if you suspect someone else is using your account, please let us know immediately by contacting us as indicated in the Contact Us section below.

Transfer to Other Countries

Because of the global nature of our business, WireNxt shares personal data internationally with its subsidiaries, subcontractors, and partners when carrying out the activities described in this Policy. They may process your data in countries whose data protection laws are not considered to be as strong as EU laws or the laws which apply where you live. For example, they may not give you the same rights over your data.

Whenever we transfer personal data internationally, we use tools and transfer agreements to:

make sure the data transfer complies with applicable law; and
help to give your data the same level of protection as it has in the EU and the laws which apply where you live.

Regardless of where you use our Services, the information collected as part of that use will be transferred to and maintained on servers located in the United States. By using our Services, you consent to this collection, transfer, storage, and processing of information to and in the United States.

Use of Cookies and Other Tracking Technologies

We and our service providers use cookies, web beacons, pixels, session replay/screen capture, and similar technologies on our Site to collect information and personalize your experience with our Services, to conduct analytics and marketing activities, and to provide you with targeted advertisements.

We use these technologies in order to offer you a more tailored experience in the future, by understanding and remembering your particular browsing preferences. Cookies are small text files that are placed on your computer or mobile device when you visit a site that enable us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Services you have visited; (iv) enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform searches and analytics; and (vi) assist with security and administrative functions.

As we adopt additional technologies, we may also gather information through other methods. Please note that you can change your settings to notify you when a cookie is being set or updated or to block cookies altogether. For more information, please consult the “Help” section of your browser (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). Please note that by blocking, disabling, or managing any or all cookies, you may not have access to certain features or offerings of the Services. For more information about our use of cookies, please see our Cookie Notice.

Children’s Information

The Services are not directed to children whose age:

is under the age of 13 years;
makes it illegal to process their personal data; or
requires parental consent to process their personal data.

We do not knowingly collect or use personal data from children who meet those criteria. If you’re under the age of 13 years, please do not use the Services, and do not provide any personal data to us. We may offer a specific service dedicated to children and your use of that service will be subject to the privacy policy governing that service.

We do not knowingly process data of EU residents under the age of 16 without parental consent. If we become aware that we have collected data from an EU resident under the age of 16 without parental consent, we will take reasonable steps to delete it as soon as possible. If you live in the EU and are under the age of 16 years, please do not use the Services, and do not provide any personal data to us.

We also comply with other age restrictions and requirements in accordance with applicable local laws.

If you’re a parent of a child under the age of 13 or 16, as applicable, and become aware that your child has provided personal data to WireNxt, please contact us. If we learn that we’ve collected the personal data of a child under the age of 13 or 16, as applicable, we’ll take reasonable steps to delete the personal data. This may require us to delete the WireNxt account associated with that personal data.

Your Rights

You have certain rights regarding the collection and processing of Personal Data. You may exercise these rights, to the extent they apply to you, by contacting us at the information provided at the end of this Privacy Policy, or by following instructions provided in this Privacy Policy or in communications sent to you.

Your rights vary depending on the laws that apply to you, but may include:

The right to know whether, and for what purposes, we process your Personal Data;
The right to be informed about the Personal Data we collect and/or process about you;
The right to learn the source of Personal Data about you we process;
The right to access, modify, correct, and delete Personal Data about you (see the “Accessing, Modifying, and Correcting Collected Personal Data” section below for more information);
The right to know with whom we have shared your Personal Data, for what purposes, and what Personal Data has been shared (including whether Personal Data was disclosed to third parties for their own direct marketing purposes);
The right to withdraw your consent, where processing of Personal Data is based on your consent; and
The right to file a complaint with a supervisory authority located in the jurisdiction of your habitual residence, place of work, or where an alleged violation of law occurred.

We may reject requests that are unreasonable or not required by law, including those that would be extremely impractical, could require disproportionate technical effort, or could expose us to operational risks such as free trial fraud. We may retain information as required or permitted by applicable laws and regulations, including to honor your choices, for our billing or records purposes, and to fulfill the purposes described in this Privacy Policy. We take reasonable measures to destroy or de-identify personal information in a secure manner when it is no longer required.

We currently do not collect household data. If all the members of a household make a request under this Policy, we will respond as if the requests are individual requests.

Please note, if you do not have a WireNxt account or other WireNxt owned or operated platform account, we will not have enough information about you to verify your requests under this Policy, as we do not keep sufficient information necessary to reidentify and link you to a prior visit to WireNxt where data may have been collected. As such, we will be unable to verify and honor your requests. You may make a verifiable consumer request related to your personal information twice per 12-month period.

If you are a California consumer, please see our California Consumer Privacy Act (CCPA) Privacy Notice by clicking here or simply scrolling down. See “Privacy Notice to Residents of Colorado, Connecticut, Oregon, Montana, Texas, Virginia, and Utah,” “Privacy Notice for Residents of Nevada,” and “Your European Union and UK Privacy Rights,” for more information about certain legal rights.

Accessing, Modifying, and Correcting Collected Personal Data

We strive to maintain the accuracy of any Personal Data collected from you, and will try to respond promptly to update our records when you tell us the information in our records is not correct. If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by making changes to your Profile. You can request that we correct or supplement such data by emailing [email protected].

Depending on the laws that apply to you, you may obtain from us certain Personal Data in our records. If you wish to access, review, or make any changes to Personal Data you have provided to us through the Services, please submit a request through our Online Form, or email us at [email protected] from the email address that you believe is associated with your WireNxt account.

Data Erasure

In some jurisdictions, you can request that your personal information be deleted. Please note that if you request deletion of your personal information, or if your account is suspended, terminated, or voluntarily closed:

We may retain your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend an account for fraud or safety reasons, we may retain information from that account to prevent that member from opening a new account in the future.
We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, we may keep information for tax, legal reporting, and auditing obligations.
Some copies of your information (e.g., log records) will remain in our database, but are disassociated from personal identifiers.
Because we take measures to protect data from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

Please see “Other Users” below for important information on how users on our platform may continue to have access to your data.

Requests Made Through Agents

You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.

Your European Union and UK Privacy Rights

In addition to the above-listed rights, European Union and United Kingdom privacy law provides individuals with enhanced rights with respect to their Personal Data. These rights may include, depending on the circumstances surrounding the processing of Personal Data:

The right to object to decisions based on profiling or automated decision-making that produce legal or similarly significant effects on you;
The right to request restriction of processing of Personal Data or object to processing of Personal Data carried out pursuant to (i) a legitimate interest (including, but not limited to, processing for direct marketing purposes) or (ii) performance of a task in the public interest;
In certain circumstances, the right to data portability, which means that you can request that we provide certain Personal Data we hold about you in a machine-readable format; and
In certain circumstances, the right to erasure and/or the right to be forgotten, which means that you can request deletion or removal of certain Personal Data we process about you.

To exercise any of these rights, please submit a request through our Online Form, or email us at [email protected] from the email address that you believe is associated with your WireNxt account. In the request, please specify which right you are seeking to exercise and the scope of the request.

Your Choices

You have choices about certain information we collect about you, how we communicate with you, and how we process certain Personal Data. When you are asked to provide information, you may decline to do so; but if you choose not to provide information that is necessary to provide some of our Services, you may not be able to use those Services. In addition, it is possible to change your browser settings to block the automatic collection of certain information.

Communications Opt-Out

We may send promotional emails from time to time. If you are located in the European Union, we will not send promotional emails without your consent. You can opt-out of receiving promotional emails from us at any time by clicking on the unsubscribe link in the emails. Please note that you cannot opt-out of non-promotional emails, such as those about your account, transactions, servicing, or our ongoing business relations. In addition, if you downloaded our app and opted-in to receive push notifications on your device, you can opt-out at any time by adjusting the permissions in your device or uninstalling our app.

Location Information

If you want to limit or prevent our ability to receive location information from you, you can deny or remove the permission for certain Services to access location information or deactivate location services on your device. Please refer to your device manufacturer or operating system instructions for instructions on how to do this.

Cookies and Web Tracking

Consult our Cookie Notice for more information about how to control and/or opt out of certain web tracking technologies.

Additional Information

Interpretation

Any version of this Privacy Policy in a language other than English is provided for convenience. If there is any conflict with a non-English version, you agree that the English language version will control.

Other Users

Other users of the Service or the public may have access to your Personal Data when you choose to make your profile or other personal information available to them through the Service, such as when you provide comments, reviews, survey responses, or other content. We do not control how other users or third parties use any personal information that you make available to such users or the public. Please be aware that any information you post publicly can be cached, copied, screen captured, or stored elsewhere by others (e.g., search engines) before you have a chance to edit or remove it.

California Consumer Privacy Act (“CCPA”) Privacy Notice

This Privacy Notice applies to California consumers and supplements the Privacy Policy.

Personal Information We Collect

We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“CCPA Personal Information”). We have collected the following categories of CCPA Personal Information from consumers within the last twelve (12) months:

Identifiers

Category	Personal Data Collected
First name, last name, postal address, unique personal identifier, online identifier, IP address, email address, alias, state, city, country, phone number, account name, social media profiles, or other similar identifiers
California Customer Records Personal Information Categories	Under the California Consumer Privacy Act (CCPA), California residents have the right to know what personal information businesses collect about them. At WireNxt, we are committed to transparency regarding the categories of personal information we collect. The following categories are as described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)):
Characteristics of Protected Classifications Under California or Federal Law	Age, race, national origin, physical or mental disability, sex (including gender, gender identity, gender expression), sexual orientation, veteran or military status of teachers only
Commercial Information	Records of services or content purchased
Internet or Other Similar Network Activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement
Geolocation Data	Our online services don’t collect precise geolocation data from GPS sensors. However, we do collect IP addresses from which we can determine your general location.
Sensory Data	Video recordings
Professional or Employment-Related Information	Employment History, Request for Leave
Sensitive Personal Information	Race and sexual orientation of teachers only

Uses of CCPA Personal Information

We use categories of CCPA Personal Information listed above for the purposes noted in the “How We Use the Personal Data We Collect About You” section of our Privacy Policy.

Categories of CCPA Personal Information disclosed for a business purpose

We disclose the categories of CCPA Personal Information listed below for business purposes. This table summarizes those categories and the third-party recipients of those categories, and also specifies where we are selling or sharing that information with those third-party recipients in certain instances. (Please see the “Disclosing Your Personal Data” section of our Privacy Policy for additional details that may be of interest to you.

Category	Category of Third-Party Recipients	Usage
Identifiers	payment processors, analytics service providers, ad networks and marketing tools	Sold to or shared with (as defined under California law) analytics service providers or ad networks and marketing tools in certain instances
California Customer Records Personal Information Categories	Clients, payment processors	Not sold to or shared with (as defined under California law) third-party recipients
Characteristics of Protected Classifications Under California or Federal Law; Sensitive Personal Information (applicable to teachers only)	Vetted collaboration partners, such as media partners	Not sold to or shared with (as defined under California law) third-party recipients
Internet or Other Similar Network Activity	Analytics service providers, ad networks and marketing tools, providers of advertising services	Sold to or shared with (as defined under California law) analytics service providers or ad networks and marketing tools in certain instances
Geolocation Data	Analytics service providers, ad networks and marketing tools, providers of advertising services	Sold to or shared with (as defined under California law) analytics service providers or ad networks and marketing tools in certain instances
Inferences Drawn From Other Personal Information	Analytics service providers	Sold to or shared with (as defined under California law) analytics service providers or ad networks and marketing tools in certain instances

Sources of CCPA Personal Information

We explain our sources of information in the “Personal Data We Collect About You” section of our Privacy Policy. For ease of reference, in regard to CCPA Personal Information these are:

Directly from you: For example, when you provide it to us to sign up for a Wirenxt account, interact with our customer service, or participate in surveys or marketing promotions, as well as information you provide when you choose to provide taste preferences or account settings (including preferences set in the “Account” section of our website).
Automatically or indirectly from you: For example, through and as a result of your use of and access to the Services, including through our mobile application.
Business and marketing partners or service providers: For example, online interactions you may have with our joint marketing partners and event co-sponsors, online identity and fraud verification services, social media sites, and analytics providers.

We use cookies and/or similar tracking technologies that enable certain advertising networks, social media companies, analytics services, and other third-party businesses to collect and use your personal information directly from your browser or device when you visit or interact with our Service or otherwise engage with our platform online. In some cases, we may upload CCPA Personal Information to certain of these partners for advertising or analytics purposes.

Under the CCPA, these activities may be deemed “sales” or “sharing” of CCPA Personal Information. To opt out of this use of your CCPA Personal Information, please complete the form at the following link: https://preferences.WireNxt.com/dont_sell. If you have enabled the Global Privacy Control signal on your browser, we will respond to it in accordance with the CCPA. Please note that we do not knowingly sell CCPA Personal Information of individuals under the age of 16.

Your California Privacy Rights

California’s “Shine the Light” law permits users of the Services who are California residents to request certain information regarding its disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please submit a request through our Online Form, email us at [email protected] from the email address that you believe is associated with your WireNxt account, or write to us at the address listed below.

The CCPA provides our users who are California residents the following rights with regard to CCPA Personal Information:

Right to Know: You have the right to request that we disclose certain information to you about the CCPA Personal Information we collected, used, disclosed, and sold about you in the past 12 months. Please note that you may only submit a request to know twice within a 12-month period. You may request to know any or all of the following:
- The categories of CCPA Personal Information we have collected about you;
- The categories of sources from which the Personal Data was collected;
- The categories of third parties to whom the CCPA Personal Information was disclosed;
- The business or commercial purpose for collecting, selling, or sharing the CCPA Personal Information; and
- The specific pieces of CCPA Personal Information we have collected about you.
Right to Deletion: You have the right to request that we delete the CCPA Personal Information we collected from you and maintained, subject to certain exceptions.
Right to Correct: You have the right to request that we correct inaccurate CCPA Personal Information that we maintain about you.
Right to Opt Out of Sales and Sharing: You have the right to opt out of our “sale” or “sharing” of your CCPA Personal Information. Please see above for how to exercise that right.
Right to Non-Discrimination: You have the right not to receive discriminatory treatment by us for the exercise of any of your rights.

The CCPA also allows you to limit the use or disclosure of your “sensitive personal information” (as defined in the CCPA and listed above) if your “sensitive personal information” is used for certain purposes. If we indicate above that we collect your “sensitive personal information,” you may opt out of our use or disclosure of that information by completing this form or by emailing us at [email protected].

You can exercise these rights by contacting us as specified in the “Contact Us” section at the end of this Policy. You can also designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and we may verify your identity directly. Please note that the rights listed above are subject to certain exceptions.

Retention

We retain CCPA Personal Information in accordance with the “Data Erasure” section above.

Privacy Notice to Residents of Colorado, Connecticut, Montana, Oregon, Texas, Utah, and Virginia

The disclosures in this section apply solely to individual residents of the states of Colorado, Connecticut, Montana, Oregon, Texas, Virginia, and Utah. Privacy laws in these states give residents certain rights with respect to their personal data, when they take effect. Those rights include:

Right to Request Access: You have the right to access and obtain a copy of your personal data that we hold about you.
Right to Request Deletion: You have the right to request that we delete personal data that we hold about you.
Right to Correct: You have the right to correct inaccuracies in your personal data.
Right to Opt Out of Sales and Use of Personal Data for Targeted Advertising Purposes: You may opt out of our “sale” of your personal data and our processing of your personal data for the purposes of “targeted advertising,” as such terms are defined in applicable privacy laws. To opt out of these uses of your personal data, please complete the form at: https://preferences.WireNxt.com/dont_sell.
Right to Portable Data: You have the right to request that we provide you a copy of personal data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another business, where our processing is carried out by automated means.

To submit a request to exercise your access, deletion, or correction privacy rights, please submit a request through our Online Form, or email us at [email protected] from the email address that you believe is associated with your WireNxt account. In the request, please specify which right you are seeking to exercise and the personal data with respect to which you want to exercise this right.

Please note that these rights are subject to certain exceptions. If you are a Colorado, Connecticut, Oregon, Montana, Texas, or Virginia resident and we deny your request to exercise any of the rights above, you may appeal our denial of your request by contacting us via one of the contact methods specified at the end of this Policy.

Privacy Notice for Residents of Nevada

For residents of the State of Nevada, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of sales of certain covered information that a website operator has collected or will collect about the resident. We do not currently sell covered information.

Changes to Our Privacy Policy

This Privacy Policy replaces all previous disclosures we may have provided to you about our information practices with respect to the Services. Our Services may change from time to time. As such, we reserve the right, at any time, to modify, alter, and/or update this Privacy Policy, and any such modifications, alterations, or updates will be effective upon our posting of the revised Privacy Policy. We will use reasonable efforts to notify you in the event material changes are made to our processing activities and/or this Privacy Policy, such as by posting a notice on the Services or sending you an email. The date this Privacy Policy was last updated is identified at the top of the page. Your continued use of the Services following our posting of any revised Privacy Policy will constitute your agreement of the amended Privacy Policy.

Contact Us

If you have any questions about this Privacy Policy or our data practices generally, please contact us using the following information:

Name:
WireNxt, Inc.

Email address for contact:
[email protected]

Mailing address:
215 Park Avenue South, 11th Floor, New York, New York 10003

Designated EU & UK representative and contact information:
DP-Dock, [email protected]

Please contact [email protected] if you need to access this Policy in an alternative format due to having a disability.