OwnWP.com is committed to safeguarding your privacy. Contact us at if you have any questions or problems regarding the use of your Personal Data and we will gladly assist you.
- Definitions Used in This Policy
- Data Protection Principles We Follow
- What Rights Do You Have Regarding Your Personal Data
- What Personal Data We Gather About You
- How We use Your Personal Data
- Who Else Has Access to Your Personal Data
- How Long We Store Your Data
- How We Secure Your Data
- Jurisdiction-Specific Rules
- Information About Cookies
- Contact Information
- Policy Effective Date
Personal Data – any information relating to an identified or identifiable natural person.
Processing – any operation or set of operations which is performed on Personal Data or on sets of Personal Data.
Data subject - a natural person whose Personal Data is being Processed.
Child - a natural person under 16 years of age.
We/us (either capitalized or not) – OwnWP.com, an Ultimate Solution, LLC production.
2. Data Protection Principles
We promise to follow the following data protection principles:
- Processing is lawful, fair, transparent. Our Processing activities have lawful grounds. We always consider your rights before Processing Personal Data. We will provide you information regarding Processing upon request.
- Processing is limited to the purpose. Our Processing activities fit the purpose for which Personal Data was gathered.
- Processing is done with minimal data. We only gather and Process the minimal amount of Personal Data required for any purpose.
- Processing is limited to a time period. We will not store your personal data for longer than needed.
- We will do our best to ensure the accuracy of data.
- We will do our best to ensure the integrity and confidentiality of data.
3. Data Subject's Rights
You have the following rights:
- Right to information – meaning you have to right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.
- Right to access – meaning you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered.
- Right to rectification – meaning you have the right to request rectification or erasure of your Personal Data that is inaccurate or incomplete.
- Right to erasure – meaning in certain circumstances you can request for your Personal Data to be erased from our records.
- Right to restrict processing – meaning where certain conditions apply, you have the right to restrict the Processing of your Personal Data.
- Right to object to processing – meaning in certain cases you have the right to object to Processing of your Personal Data, for example in the case of direct marketing.
- Right to object to automated Processing – meaning you have the right to object to automated Processing, including profiling; and not to be subject to a decision based solely on automated Processing. This right you can exercise whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you.
- Right to data portability – you have the right to obtain your Personal Data in a machine-readable format or if it is feasible, as a direct transfer from one Processor to another.
- Right to lodge a complaint – in the event that we refuse your request under the Rights of Access, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled please contact us.
- Right for the help of supervisory authority – meaning you have the right for the help of a supervisory authority and the right for other legal remedies such as claiming damages.
- Right to withdraw consent – you have the right withdraw any given consent for Processing of your Personal Data.
4. Data We Gather
4.1 Information that you have provided us with
This might be your e-mail address, name, billing address, home address etc – mainly information that is necessary for delivering you a product/service or to enhance your customer experience with us. We save the information you provide us with in order for you to comment or perform other activities on the website. This information includes, for example, your name and e-mail address.
4.2 Information automatically collected about you
This includes information that is automatically stored by cookies and other session tools. For example, your shopping cart information, your IP address, your shopping history (if there is any) etc. This information is used to improve your customer experience. When you use our services or look at the contents of our website, your activities may be logged.
4.3 Information from our partners
We gather information from our trusted partners with confirmation that they have legal grounds to share that information with us. This is either information you have provided them directly with or that they have gathered about you on other legal grounds. See the list of our partners here.
4.4 Publicly available information
We might gather information about you that is publicly available.
5. How We Use Your Personal Data
We use your data to do things like provide our Services, communicate with you, troubleshoot issues, secure against fraud and abuse, improve and update our Services, analyze how people use our Services, serve personalized advertising, and as required by law or necessary for safety and integrity.
5.1 Our Services
We use your Personal Data in order to:
- provide our service to you. This includes, for example, registering your account; providing you with other products and services that you have requested; providing you with promotional items at your request and communicating with you in relation to those products and services; communicating and interacting with you; and notifying you of changes to any services.
- enhance your customer experience;
- fulfill an obligation under law or contract;
We use your Personal Data on legitimate grounds and/or with your Consent.
On the grounds of entering into a contract or fulfilling contractual obligations, we Process your Personal Data for the following purposes:
- to identify you;
- to provide you a service or to send/offer you a product;
- to communicate either for sales or invoicing;
On the ground of legitimate interest, we Process your Personal Data for the following purposes:
- to send you personalized offers* (from us and/or our carefully selected partners);
- to administer and analyze our client base (purchasing behavior and history) in order to improve the quality, variety, and availability of products/ services offered/provided;
- to conduct questionnaires concerning client satisfaction;
As long as you have not informed us otherwise, we consider offering products/services to you that are similar or same to your purchasing history/browsing behavior our to be our legitimate interest.
With your consent we Process your Personal Data for the following purposes:
- to send you newsletters and campaign offers (from us and/or our carefully selected partners);
- for other purposes we have asked your consent for;
5.2 Third-Parties Through Website Functionality
Smush does not interact with end users on our website. Smush sends images to the WPMU DEV servers to optimize them for web use. This includes the transfer of EXIF data. The EXIF data will either be stripped or returned as it is. It is not stored on the WPMU DEV servers.
Per the functionality of this plugin, backups of your website files and/or database are created and stored locally on your server and/or remotely on 3rd party servers based on the settings of this plugin. Archives can include but are not limited to, file and database assets, including hashed passwords, 3rd party data, uploads and user information. These backups are stored to provide the critical functionality of this plugin.
Cookies are used to handle importing and restoring backups.
Some plugin settings ask for an email address or login credentials to 3rd party services. This is stored to provide functional features to the plugin.
This plugin tracks dates, times and actions of successful and unsuccessful backups and remote data transfers. This is stored to help make the plugin better and assist with troubleshooting problems.
This plugin logs some personal information such as email addresses, usernames, database, and server information. This is stored to help make the plugin better and assist with troubleshooting problems.
Minimally, backup retention is 10 weeks but in some cases may be indefinitely in order to retain the integrity of the website and its functionality.
Cookies used during the restore/import process expire after 24 hours.
Settings are retained indefinitely until they are changed or removed manually.
Backups are set to be automatically sent to at least one of the following remote third-party destination servers:
Backup zip files are stored with hashed file names to prevent filename guessing. Directory browsing is disabled.
The first time you visit this site, a browser cookie is generated to identify you as a new visitor. If you were referred to this site by another site, the referral URL is also tracked in a cookie. This allows us to create customized messaging and notices for each of our site visitors. This data is retained in your web browser until cleared by you or your browser.
Easy Digital Downloads
We collect information about you during the checkout process on our store. This information may include but is not limited to, your name, billing address, shipping address, email address, phone number, credit card/payment details and any other details that might be requested from you for the purpose of processing your orders.
Handling this data also allows us to:
- Send you important account/order/service information.
- Respond to your queries, refund requests, or complaints.
- Process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests.
- Set up and administer your account, provide technical and/or customer support, and to verify your identity.
Additionally, we may also collect the following information:
- Location and traffic data (including IP address and browser type) if you place an order, or if we need to estimate taxes and shipping costs based on your location.
- Product pages visited and content viewed while your session is active.
- Your comments and product reviews if you choose to leave them on our website.
- Account email/password to allow you to access your account if you have one.
- If you choose to create an account with us, your name, address, and email address, which will be used to populate the checkout for future orders.
The IP address of visitors, user ID's of logged in users, and username of login attempts are conditionally logged to check for malicious activity and to protect the site from specific kinds of attacks. Examples of conditions when logging occurs include login attempts, log out requests, requests for suspicious URLs, changes to site content, and password updates. This information is retained for 60 days.
In order to ensure file integrity, iThemes Security pulls data from wordpress.org, ithemes.com, and amazonaws.com. No personal data is sent to these sites.
Security logs are retained for 60 days.
We collect information about visitors who comment on Sites that use our Akismet anti-spam service. The information we collect depends on how the User sets up Akismet for the Site, but typically includes the commenter's IP address, user agent, referrer, and Site URL (along with other information directly provided by the commenter such as their name, username, email address, and the comment itself).
WP Courseware only collects first name, last name, e-mail address, and mailing address when a purchase is made. If a course is offered for free, then the user's registration information is only stored in the WordPress users table. WP Courseware does not collect any credit card data. WP Courseware only sends required data to the payment gateways.
Data collected from an order is used to process transactions and enroll users into courses. Your name and email address are used to send out email notifications for your purchases or course notifications.
5.3 Legal Obligation
We Process your Personal Data in order to fulfill obligation rising from the law and/or use your Personal Data for options provided by law. We reserve the right to anonymize Personal Data gathered and to use any such data. We will use data outside the scope of this Policy only when it is anonymized. We save your billing information and other information gathered about you for as long as needed for accounting purposes or other obligations deriving from the law, but not longer than 7 years.
We might process your Personal Data for additional purposes that are not mentioned here but are compatible with the original purpose for which the data was gathered. To do this, we will ensure that:
- the link between purposes, context, and nature of Personal Data is suitable for further Processing;
- the further Processing would not harm your interests and
- there would be an appropriate safeguard for Processing.
We will inform you of any further Processing and purposes.
6. Who Else Can Access Your Personal Data
We do not share your Personal Data with strangers. Personal Data about you is in some cases provided to our trusted partners in order to either make providing the service to you possible or to enhance your customer experience.
We share your data with:
- Processing partners - others who can access data we have gathered and may process your personal data on behalf of us and are required to use it solely as we direct, to provide our requested service.
- Business partners - other companies we do business with and share personal data.
- Connected third parties - others not in the above categories.
- With Service Providers, Contractors, and Agents: We share your data with third-party companies who perform services on our behalf, like payment processing, data analysis, marketing and advertising services (including retargeted advertising), email and hosting services, and customer services and support. These service providers may access your personal data and are required to use it solely as we direct, to provide our requested service.
- For Security and Legal Compliance: We may disclose your data to third parties if we (in our sole discretion) have a good faith belief that the disclosure is:
- Permitted or required by law;
- Requested as part of a judicial, governmental, or legal inquiry, order, or proceeding;
- Reasonably necessary as part of a valid subpoena, warrant, or other legally-valid requests;
- Required to detect, prevent, or address fraud, abuse, misuse, potential violations of law (or rule or regulation), or security or technical issues; or
- Reasonably necessary in our discretion to protect against imminent harm to the rights, property, or safety of OwnWP, our users, members of the public, or our Services.
- During a Change in Control: If OwnWP undergoes a business transaction like a merger, acquisition, corporate divestiture, or dissolution (including bankruptcy), or a sale of all or some of its assets, we may share, disclose, or transfer all of your data to the successor organization during such transition or in contemplation of a transition (including during due diligence).
- After Aggregation/De-identification: we can disclose or use aggregate or de-identified data for any purpose.
We only work with Processing partners who are able to ensure an adequate level of protection to your Personal Data. We disclose your Personal Data to third parties or public officials when we are legally obliged to do so. We might disclose your Personal Data to third parties if you have consented to it or if there are other legal grounds for it.
7. How Long We Store Your Data
If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators (which may include support from third-party developers as needed) can also see and edit that information. Inactive users are removed when specifically requested.
8. How We Secure Data
We do our best to keep your Personal Data safe. We use safe protocols for communication and transferring data (such as HTTPS). We use anonymizing and pseudonymizing where suitable. We monitor our systems for possible vulnerabilities and attacks. We have hardened our server and website security.
We do not intend to collect or knowingly collect information from children. We do not target children with our services.
We recognize the privacy interests of children and encourage parents and guardians to take an active role in their children’s online activities and interests. Children under 13 (or under 16 in the European Economic Area) should not use the Services. If we learn that we’ve collected personal data from a child under those ages, we will take reasonable steps to delete it.
Parents who believe that OwnWP may have collected personal data from a child under those ages can submit a request that it be removed to support@OwnWP.com.
8.2 How we Protect Data
OwnWP uses appropriate security based on the type and sensitivity of data being stored. We take appropriate security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal data that we collect and store. These measures vary based on the type and sensitivity of the data but include a mandatory strong password requirement, password encryption, two-factor authentication availability, and staff training in data protection.
As with any internet-enabled system, there is always a risk of unauthorized access. No system can be 100% secured, so we cannot guarantee that communications between you and OwnWP, the Services, or any information provided to us in connection with the data we collect through the Services will be free from unauthorized access by third parties.
Your best defense is to protect your password. You should not share your password with any third party, and if you believe your password or account has been compromised, you should change it immediately and contact us if you suspect any unauthorized access to your account.
8.3 Data Breach Procedure
The Support Manager will ascertain whose data was involved in the breach, the potential effect on the data subject and what further steps need to be taken to remedy the situation. The investigation will consider:
- The type of data;
- Data sensitivity;
- What protections are in place (e.g. encryption);
- What has happened to the data;
- Whether the data could be put to any illegal or inappropriate use;
- How many people are affected;
- What type of people have been affected (users, server developers, third-party services etc) and whether there are wider consequences to the breach.
A clear record will be made of the nature of the breach and the actions taken to mitigate it. The investigation will be completed as a matter of urgency and, wherever possible, within 24 hours of the breach being discovered/reported. A further review of the causes of the breach and recommendations for future improvements will be done once the matter has been resolved.
The Support Manager will notify anyone potentially affected by the breach.
Notifications shall include (if known):
- How and when the breach occurred and what data was involved. Details of what has already done to mitigate the risks posed by the breach.
- Specific and clear advice on what to do to protect yourself and what we are doing to help you.
9. Cookies and Other Technologies We Use
A cookie is a tiny text file stored on your computer. Cookies store information that is used to help make sites work. Only we can access the cookies created by our website. You can control your cookies at the browser level. Choosing to disable cookies may hinder your use of certain functions.
9.1 Cookie Use
- Necessary cookies – these cookies are required for you to be able to use some important features on our website, such as logging in. These cookies don't collect any personal information.
- Functionality cookies – these cookies provide functionality that makes using our service more convenient and makes providing more personalized features possible. For example, they might remember your name and e-mail in comment forms so you don't have to re-enter this information next time when commenting.
- Analytics cookies - these cookies are used to track the use and performance of our website and services
- Advertising cookies - these cookies are used to deliver advertisements that are relevant to you and to your interests. In addition, they are used to limit the number of times you see an advertisement. They are usually placed to the website by advertising networks with the website operator’s permission. These cookies remember that you have visited a website and this information is shared with other organizations such as advertisers. Often targeting or advertising cookies will be linked to site functionality provided by the other organization.
9.2 Cookie Removal
You can remove cookies stored on your computer via your browser settings. Alternatively, you can control some 3rd party cookies by using a privacy enhancement platform such as optout.aboutads.info or youronlinechoices.com. For more information about cookies, visit allaboutcookies.org.
10. Jurisdiction-Specific Rules
If you live in California, you have certain rights to request information. Users outside of the United States should note that we transfer data within the US and other areas outside of the European Economic Area.
10.1 Users in California
If you are a California resident, you have the right to request certain details about what personal information we share with third parties for those third parties’ direct marketing purposes. To submit your request, send an email to support@OwnWP.com with the phrase “California Shine the Light” and include your state of residence and your email address that is affiliated with your account.
Since the internet industry is still working on Do Not Track standards, solutions, and implementations, we do not currently recognize or respond to browser-initiated Do Not Track signals.
10.2 Users Outside of the U.S.
OwnWP, and its parent company, Ultimate Solution, LLC., is headquartered in Alamogordo, New Mexico, and in order to provide the Services to you we may transfer your data to the United States and process it there. By visiting or using our Services, you consent to the storage of your data on servers located in the United States. If you are using the Services from outside the United States, you consent to the transfer, storage, and processing of your data in and to the United States or other countries. Specifically, personal data collected in Switzerland and the European Economic Area (“EEA”) is transferred and stored outside those areas.
That data is also processed outside of Switzerland and the EEA by OwnWP, our parent company Ultimate Solution, LLC., or our service providers, including to process transactions, facilitate payments and provide support services as described in Section 4. We have entered into data processing agreements with our service providers that restrict and regulate their processing of your data on our behalf. By submitting your data or using our Services, you consent to this transfer, storage, and processing by OwnWP and its processors.
12. Contact Information
13. Policy Effective Date
Last modification was made on 6 June 2018.