Wx Router

Last updated: July 18, 2023

This Privacy Policy describes the ways we collect, store, use and manage the information you provide to us or we collect in connection with our Services and the Website.

If you are a user of a service provided to you by our Business Customer, the “Personal Information Processed on behalf of Business Customers” section of this Privacy Policy applies to you.

1. Definitions

• “Policy” means this Privacy Policy.
• “We”, “our” or “us” means Wx Router LLC, a company located at 1501 Lincoln Blvd #1006 Venice, CA 90291, and any of our affiliates.
• “You”, “your” means you as an individual user of our Services and/or Website.
• “Website” means our website on which this Policy appears.
• “Services” means our services provided to you according to the Terms.
• “Terms” means our Terms of Service.
• “Personal Information” means, if not otherwise defined in the applicable law, 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. If you cannot be identified (e.g., when Personal Information has been aggregated and anonymized), then this Policy does not apply.
• “Business Customer” means an entity using our API or ‘Employee Benefits’ solution.

2. What Data We Collect and How We Do That

First of all, we would like to assure you that we have not sold and do not sell your Personal Information.

When you visit our Website, use our Services or contact us directly we collect and process your Personal Information. The ways we collect it can be broadly categorized into the following:

Information you provide to us directly

When you use some parts of our Services we might ask you to provide Personal Information to us. For example, you will provide your email address, home address and your name when you create an account with us. We may collect information from you when you contact us or provide feedback. In order to use our removal Services you will need to provide to us your name, alias, email address, phone number and date of birth.

Information we collect automatically

As is true of most online services, we may automatically collect certain information about the devices you use to access the Services and Website. As described further below, we may collect and analyze (i) device information such as IP addresses, unique device identifiers, screen resolution, time zone, browser types, browser version, browser language, operating system, device make and model, and (ii) information related to the ways in which you interact with the Website and Services, such as referring and exit web pages and URLs, platform type, number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, statistical information about the use of the Website and Services, the amount of time spent on particular pages, the date and time you used the Website or Services, the frequency of your use of the Website and Services, error logs, and other similar information. We may use third-party analytics, advertising and marketing services and technologies (such as Google Analytics, Facebook Ads, Google Ads, Microsoft Ads, Sendgrid, Hotjar, etc.) to assist in collecting this information. Information collected by various technologies, including cookies and similar tools, will be collected directly by these service providers, who use the information to evaluate your use of the Services and Website, including by analyzing usage trends.

Cookies and similar tracking technologies

A cookie is a small piece of text sent to your browser by a website you visit.

We use only strictly necessary cookies that let you use the Website and its essential features, including:

• to recognize you when you visit the Website,
• to remember your preferences,
• to perform security measures.

We also use ‘local storage’ and ‘session storage,’ which are used to store data in your web browser. Local storage supports persistent data storage, similar to cookies but with an enhanced capacity and no information stored in the HTTP request header. Session storage is purged when you close the browser.

As mentioned earlier, third parties whose tools and services we use can serve their cookies when you use the Website and Services (third-party cookies).

Third-party services may use the following types of cookies:

Performance and Analytics Cookies. These cookies are used, for example, to count how many visitors we receive to a page, to understand from what sources users come to the Website or to help us analyze how the Website and Services are used. For more information on Google Analytics cookies, visit https://policies.google.com. To opt-out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.

Targeting Cookies and Other Tools. Such cookies, tags or pixels are set by third-party advertising services. These cookies can be used to create a user profile and display relevant ads on other sites (remarketing tags). These cookies identify the browser and the device.

Functional Cookies. These cookies are used to remember your preferences and settings, for example, to keep a chat with customer support after a page reload.

Social Media Cookies. These cookies relate to services provided by third parties, such as "Like" and "Share" buttons. They are used to provide you with services or to remember your sharing preferences for social networks. Social networks that provide the button may use it to identify you, even if you have not used the button when browsing our Website.

Most web browsers allow some control of most cookies through the browser settings.

You may be able to reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the Website and Services may not function properly if the ability to accept cookies is disabled.

Information we get from third parties

We might receive Personal Information about you from third parties. For example, Stripe, a payment provider, makes available to us information about the payer’s zip code, IP address, card network type (Visa, MasterCard, American Express, etc.), last 4 digits of your card and its expiration date. Please note that we do not receive any other payment details from payment providers.

3. How We Use Personal Information

Our processing of your Personal Information is necessary for us to provide you with the Services and Website. If we do not process your Personal Information, we may be unable to provide you with all or some features of the Services.

We use your Personal Information for a number of purposes, which may include the following:

• To operate our Services and Website, ensure they work as intended and deliver the Services you have requested.
• To support you, including assisting with the resolution of technical or other issues relating to the Services and Website.
• To enhance our services and websites, test and develop new features and carry out analysis of our Services and Website so that we can optimize your user experience and provide you and other users with more efficient tools and features.
• To analyze and aggregate data, to prepare statistics, in particular, to produce aggregated analytics and reports, which we may use internally.
• To display advertisements to you.
• To manage our relationship and communicate with you. This may include (a) operational and transactional communications, like information about changes to our Services, information about new features, security updates or assistance with using our Services; (b) survey requests, feedback collection and follow-up communication if the Terms or the use of Services has been terminated or suspended; or (c) providing you with the information you have requested from us or information we are required to send to you. These communications are part of the Services we provide to you and in most cases you will not be able to opt out of them. If an opt-out is available, you will find that option within the communication itself or in your profile settings.
• To promote and drive engagement with the Services and Website.
• To send marketing communications that may be of specific interest to you. These communications are aimed at driving engagement and maximizing what you get out of the Services, including information about new services, newsletters, product offers, and promotions we think may be of interest to you. You may opt out of receiving marketing communications from us at any time by clicking an ‘unsubscribe’ link at the bottom of the email or contacting our support team at support@facely.co.
• To prevent, detect and report crime, protect you, other users and us, for example, by ensuring network and information security, mitigating security risks, detecting and preventing any fraudulent or malicious activity, and make sure that everyone is using our Services and Website fairly and in accordance with the Terms and applicable regulations.
• To perform legal duties, responsibilities, and obligations; and to comply with laws and regulations that apply to us.
• To exercise our rights set out in the Terms or other agreements with you.
• To disclose information to our contractors on a need-to-know basis or our successors following a restructure.

We may aggregate and/or de-identify information collected through the Services and Website. We may use de-identified and/or aggregated data for any purpose, including without limitation for research and marketing purposes.

4. To Whom We May Disclose Your Personal Information

There will be times when we may need to disclose your Personal Information to third parties. We may disclose your Personal Information to:

• Data broker and people-search sites: in order to provide you with the Services we have to disclose your information to data brokers and people search sites, which allows us to find your records on these sites and request their removal on your behalf;
• Third-party service providers and partners who assist us in the provision of the Services and Website, for example, (a) those who support delivery of or provide certain features in connection with the Services and Website (e.g. Stripe, a payment services provider; Sendgrid, an email delivery service; HubSpot, a CRM platform, and Sentry, a crash reporting platform); (b) providers of analytics and measurement services (e.g. Google Analytics, ProfitWell etc.); (c) providers of technical infrastructure services (e.g. Microsoft Azure, Google Cloud, and Amazon AWS); (d) providers of customer support services (e.g. Zendesk); (e) those who facilitate conduct of surveys (e.g. Hotjar); (f) those who help to advertise, market or promote our Services and Website (e.g. Mautic, Facebook Ads, Google Ads, Linkedin Ads, Reddit Ads, and Microsoft Ads);
• Law enforcement agencies, government bodies, courts or other third parties, when required by law;
• Professional advisors, such as lawyers, auditors, etc. where necessary in the course of the professional services that they render to us;
• Our contractors who have entered into binding obligations of privacy and confidentiality that are at least as protective as those in this Privacy Policy and as required by the applicable law; and/or
• Other persons where we have your consent.

5. Data Retention

Some information you can delete whenever you like, some data is deleted automatically, and some information we retain for longer periods of time when necessary. When the information is being deleted, we make sure that your information is safely and completely removed from our servers or retained only in anonymized form.

Sometimes business and legal requirements oblige us to retain certain information, for specific purposes, for an extended period of time. Reasons we might retain some data for longer periods of time include:

• To ensure that the Services and Website are available to you and other users.
• To protect you, other persons, and us from fraud, abuse, illegal activity and unauthorized access, for example, when we suspect someone is committing fraud.
• To comply with tax, anti-money laundering and other financial regulations, or for accounting purposes..
• To facilitate dispute resolution.
• To meet and comply with applicable law, regulation, legal process or enforceable governmental request, or when we are required to enforce the Terms, including investigation of potential violations.
• If you have directly communicated with us, for example, through a customer support channel or provided feedback or a bug report.

6. Security Measures

We have implemented technical, physical, and organizational security measures to protect against the loss, misuse, and/or alteration of your information. These safeguards vary based on the sensitivity of the information that we collect and store.

Security and privacy third party risk assessment is established as a part of our vendor management process.

7. Information Concerning Children

The Website and Services are not intended for children aged 16 or under. We do not seek to collect Personal Information about children aged 16 or under. If you have any concerns about your child’s privacy in relation to our Services, or if you believe that your child under the age of 16 may have entered Personal Information onto our Website, please contact us at support@facely.co. We will delete such Personal Information from our records or seek verifiable parental or legal guardian consent to retain such information within a reasonable time..

8. Third Party Links and Services

The Services and Website may contain links to third party websites, apps, plug-ins and other services. If you choose to use these sites or features, you may disclose your information not just to those third parties, but also to their users and the public more generally depending on how their services function. We are not responsible for the content or privacy practices of such third party websites or services. The collection, use and disclosure of your information will be subject to the privacy policies of the third party websites or services, and not this Privacy Policy. We encourage you to read the privacy statements of each and every site you visit.

9. Modifications

We reserve the right, at our sole discretion to modify or revise this Policy at any time by posting the amended Policy on the Website. Please check the most current Policy.

Your continued use of the Website or Services after a change or update has been made will constitute your acceptance to the revised Privacy Policy. If you do not agree with the modifications, please discontinue use of the Website and Services.

10. Privacy Related Inquiries

If, for any reason, you are concerned with the way that we may be using your Personal Information, you have questions about the privacy aspects of the Services or Website, please, contact us at support@facely.co.

11. Personal Information Processed on behalf of Business Customers

In connection with performing services for our Business Customers, we may also collect, process and store Personal Information owned and controlled by our Business Customers at their direction.

This Privacy Policy does not apply to our security and privacy practices in connection with (i) your access to and use of our Business Customers’ products and services which use our API, and (ii) your data handled by your employer when administering its Employee Benefits program with us.

Business Customers are responsible for establishing policies for, and ensuring compliance with, all applicable laws and regulations, as well as any and all privacy policies, agreements or other obligations, relating to the collection of Personal Information in connection with the use of our products and services by their end users or employees.

We collect information under the direction of our Business Customers, and have no direct relationship with individuals whose Personal Information we process in connection with our Business Customers’ use of our services and products.

If you are an individual who is an end user or an employee of our Business Customer, you will be directed to contact the Business Customer you have relations with for assistance with any requests or questions relating to your Personal Information.

12. California Privacy Notice

Notwithstanding the fact that Wx Router does not qualify as a business to which the California Consumer Privacy Act (CCPA) applies, we strive to voluntarily comply with the CCPA’s key principles.

This Privacy Notice for California residents supplements the information contained in this Privacy Policy.

This section applies solely to visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

Personal Information that we may collect, or may have collected from you in the preceding twelve months, fall into the following categories established by the California Consumer Privacy Act (CCPA):

• identifiers, such as your name, alias, address, phone numbers, email address, or IP address;
• characteristics of protected classifications under California or US federal law, such as age (40 years or older);
• commercial information, such as your subscription purchase history;
• Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.
• geolocation data, such as the location of your device or computer;
• audio, visual, electronic or other similar information, including when you communicate with us by phone or otherwise;
• inference data, such as information about your preferences; and
• Sensitive Personal Information, such as driver’s license or state identification card number and your credentials, including password, allowing access to your account with us.

We use and disclose sensitive personal information for the limited purposes permitted under the CCPA and not for the purposes of inferring characteristics about a consumer. For example, we may process your Sensitive Personal Information in order to perform the services you request from us or to verify information. The CCPA does not afford you rights to limit the use or disclosure of your Sensitive Personal Information for these purposes.

Categories of Sources of Personal Information

In the past twelve months, we have collected Personal Information relating to California residents from the sources described above in section “What Data We Collect and How We Do That”.

Categories of Third Parties to Whom We Disclose Personal Information

We disclose Personal Information to the categories of third parties described above in section “To Whom We May Disclose Your Personal Information”.

Categories of Personal Information Disclosed for a Business Purpose

Personal Information that we may have disclosed about consumers for a business purpose in the preceding twelve months fall into the following categories established by the CCPA:

• identifiers, such as your name, email address, or phone numbers, for example if we use a third-party customer support services;
• identifiers, such as your name, home address, or, in exceptional cases, ID card or driver’s license information, for example when we remove your information from people search websites;
• your age or other protected classifications under California or US federal law, for example if we conduct user surveys or analysis using a third-party service provider;
• commercial information, such as the details of a product or service you have purchased if a third party service provider is assisting to provide that product or service to you;
• geolocation data and Internet or other electronic network activity information, if we use a third-party service provider to help us with analytics, marketing or advertising; and
• audio, visual, electronic or other similar information, for example if a third-party provider of customer support services reviews recordings of customer support phone calls for quality assurance purposes.

For more information about Personal Information we may disclose to third parties for a business purpose, please visit section “How We Share Your Personal Information” above.

Business and Commercial Purposes for Collecting Personal Information

We use Personal Information we collect for business and commercial purposes described above in section “How We Use Personal Information”. We may also use Personal Information relating to California residents for one or more of the specific “business purposes” listed in the CCPA.

Categories of Personal Information Shared

As described in this Policy, we use online advertising services from third parties on the Website. When you interact with the Services or Website, the following categories of Personal Data may be shared, and have been shared in the preceding twelve months, with certain of these third-party providers who may use it for online or “cross-context” behavioral advertising, which meets the definition of “share” under the CCPA:

• Identifiers;
• commercial information;
• internet network activity information.

Your Rights

You have the following right under the CCPA:

• To request that we disclose to you Personal Information we have collected about you.
• To request further information about our collection, use, disclosure, or sale of your Personal Information such as a list of the categories of personal information collected about you, and other related information such as the source of the information, categories of information shared or sold to third parties, and the purpose for such sharing.
• To request correction of inaccurate Personal Information.
• To request to delete your Personal Information, in some circumstances.
• To opt out of selling or sharing for cross-context behavioral advertising certain Personal Information.
• To the extent we have collected Sensitive Personal Information about you, to direct us to limit our use of your Sensitive Personal Information to that use which is necessary to perform our services and to perform other services as set forth in the CCPA.
• To designate an authorized agent to exercise some of your rights.

If you wish to do any of these things, please contact us at +1 424 216 9253 or at support@facely.co. Please be aware that we do not accept or process requests through other means (e.g., via fax, social media, etc.).

We will review the information provided and may request additional information to ensure we are interacting with the correct individual. Please also be aware that making any such request does not ensure complete or comprehensive removal or deletion of Personal Information, and there may be circumstances in which the law does not require or allow us to fulfill your request.

To the extent we receive requests directly from end users or employees of our Business Customers regarding their Personal Information, we will work with such Business Customers to comply with its obligations under the CCPA.

No Sale of Personal Information

In the preceding twelve months we have not sold any Personal Information of consumers, as those terms are defined under the CCPA.

No Discrimination

We will not discriminate against you for exercising your rights under the CCPA.

13. Virginia Privacy Notice

Notwithstanding the fact that the Virginia Consumer Data Protection Act (VCDPA) does not currently apply to Wx Router due to its scope limitation, we strive to voluntarily comply with the VCDPA’s key principles.

This Privacy Notice for Virginia residents supplements the information contained in this Privacy Policy.

This section applies solely to visitors, users, and others who reside in the Commonwealth of Virginia.

The VCDPA requires us to give you the following information:

• The categories of personal data processed by us. This can be found above in section “California Privacy Rights Notice” under “Categories of Personal Information Collected”, excluding Sensitive Personal Information, since the VCDPA does not treat driver’s license numbers or account credentials as such.
• The purpose for processing Personal Information. This is described above in section “How We Use Personal Information”.
• We process Personal Information for targeted advertising.
• We do not sell Personal Information.
• We do not process Personal Information for the purpose of profiling in furtherance of decisions that produce legal or similarly significant effects concerning consumers.
• We do not share Personal Information with third parties (as defined in the VCDPA). We disclose Personal Information to our service providers, contractors and other processors as described above in section “To Whom We May Disclose Your Personal Information”.

Subject to the exclusions and limitations set forth in the VCDPA, you have the following rights concerning your Personal Information:

• To request that we delete your Personal Information, and we will do so unless it is reasonably necessary for us to maintain your Personal Information in compliance with the VCDPA.
• To request that we correct inaccurate Personal Information, taking into account the nature and purpose of its processing.
• To confirm whether or not we are processing your Personal Information and to access it.
• To obtain a copy of Personal Information that you previously provided to us in a portable format.
• To opt out of the processing of your Personal Information for purposes of targeted advertising. Your choice will not affect marketing that is not based on your Personal Information. For example, you may still receive advertising based on the content and predicted audience of the website you are browsing. This is known as “contextual advertising” and it will not stop in response to your requests.

You can reach us at +1 424 213 9494 or at support@facely.co to submit a request to exercise your consumer rights under the VCDPA or if you wish to appeal our decision with respect to your request.

We will not discriminate against you for exercising any of your consumer rights contained in the VCDPA.

14. Nevada Privacy Notice

We do not sell “covered information” as defined under Chapter 603A of the Nevada Revised Statutes.