Privacy Policy

 

C. Use of Information Collected Via the Sites

(1) Personal Information

We use your personal information that is collected on these Sites for the purposes set forth above. We primarily use information for the following purposes:

• For the purpose of operating our business, including to improve and develop our services for security and fraud prevention purposes, and to improve user experience.
• To alert you to updated information about WTN, or other third parties, or, with your prior consent, to forward promotional materials.
• To try to ensure the Sites are relevant to your needs.
• To help us create and publish content most relevant to you.
• To notify you about a material change to this Privacy Policy or the Terms of Use, if necessary.
• To manage your access to the Sites and handle other customer support inquiries.
• To generate web analytics and compile user information for marketing purposes, advertising, conducting marketing analysis, providing you with recommendations for products or services based on your profile, and promotional material planning and distribution. 
• To contact you in response to proposals or inquiries that you submit on the Sites.
• To use as otherwise disclosed in this Privacy Policy or at the time of collection of personal information.
• To comply with our legal obligations. For example, to enable us to meet our obligations in connection with legal claims, compliance, regulatory, investigative, and disciplinary purposes and informal requests from law enforcement or other governmental authorities; and
• For recruitment, evaluation, and selection of job candidates. 
• As otherwise in compliance with the law.

(2) Non-Personal Information

Non-personal information is used similarly as described above and in other ways as permitted by applicable laws, including combining non-personal information with personal information.

D. Legal Bases for Processing

We process personal information in accordance with applicable law and with transparency and fairness. Our processing activities are conducted:

• With your consent;
• In order to establish and fulfill our contractual obligations to you. For example, to provide the services and products you buy from us or to provide you information, products, and technical support that you request from us;
• For the legitimate purpose of operating our business, including to improve and develop our services (as far as the use of personal information is permitted for this purpose under applicable data protection law, including obtaining your consent where required under law), for fraud prevention purposes, and to improve user experience. When we process personal information to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms. You can obtain further information on legitimate interests balancing exercises we have carried out by contacting us at info@worldtrustnetwork.net;
• To protect your vital interests, like for health and safety reasons or to protect the public interest;
• To comply with our legal obligations. For example, to enable us to meet our obligations in connection with legal claims, compliance, regulatory, investigative, and disciplinary purposes and informal requests from law enforcement or other governmental authorities; and
• As otherwise in compliance with the law.

We will not use or otherwise process your personal information for any other purposes, unless we have legal grounds to do so (e.g., you provide us with your additional consent before such use). We do not use automated decision making tools to create a profile about you or to make decisions about you that produce a legal or similarly significant effect. For example, we do not use these tools to make determinations about your candidacy as a job applicant unless those results are reviewed by a WTN team member. 

E. Disclosure, Sharing, and Sale of Personal Information

(1) Personal Information

We may share or disclose your personal information to the following parties and in the following instances, in each case always only in accordance with applicable data protection laws:

• To vendors, affiliates, and other third parties to process your purchases. If you choose to make a purchase to the Sites, we may collect information from you such as your credit card number, billing address and other information related to such purchase, and we may use such collected information in order to process your payment. We may also provide such information, or other personal information provided by you, to unaffiliated third parties as necessary to complete your purchase (for example, to process your credit card).
• To vendors, affiliates, strategic partners, agents, third party marketers or other unaffiliated parties for advertising and marketing purposes, including generating web analytics and compiling user information for marketing purposes, advertising, conducting marketing analysis, providing you with recommendations for products or services based on your profile, and promotional material planning and distribution pursuant to your consent or otherwise in accordance with applicable law. If you do not want us to share your personal information in this manner, please do not provide us with this information, or please do not opt in to such activities or, as may be sufficient under applicable law, please inform us that you would like to opt out of this type of sharing by contacting us at the address provided at the bottom of the Privacy Policy.
• To affiliates, strategic partners, agents, third party marketers or other unaffiliated parties who are offering products or services that we believe may be of interest to you or who require your personal information for research, administrative and/or internal business purposes pursuant to your consent or otherwise in accordance with applicable law. These parties may use your personal information, such as your first and last name and email address, to contact you with an offer or advertisement related to a product or service, or they may use such information for their own research, administrative, or business purposes. If you do not want us to share your personal information in this manner, please do not opt in to such activities or, as may be sufficient under applicable law, please contact us below to change your preferences.
• To unaffiliated third-party service providers, agents or independent contractors who help us maintain our Sites and provide other administrative services to us (including, but not limited to, credit card processing services, providing customer service, maintaining and analyzing data, sending customer communications on WTN’s behalf, and entry collection, winner selection and prize fulfillment for contests, sweepstakes and other promotions if you decide to participate). We seek to ensure that these unaffiliated third parties will not use the personal information for any other purpose than to provide the administrative services for which they are responsible. Because such unaffiliated third-party service providers that help us administer our Sites will have access to users’ personal information, if you do not wish for our unaffiliated third-party service providers to have access to your information, please do not register or submit any personal information to us.
• To unaffiliated third-party service providers, agents or independent contractors to fulfill a request made by you. For example, if you email us a question or otherwise inquire about one of our services, we may use your email address to process your request and respond to your question. Also, if you are entering a sweepstakes or contest, we may use your personal information in order to fulfill the terms of that promotion. This means that we may share the information for prize fulfillment purposes or mail carriers. We also may share your information with the co-sponsor of that promotion pursuant to your consent or otherwise in accordance with applicable law.
• To government authorities or law enforcement officials as required by law or for administrative purposes and to the extent that applicable law allows and/or requires this: (i) to comply with the law, legal actions or lawful request of the authorities or (ii) in the good faith belief that such action is necessary in order to conform to the requirements of law or comply with legal process served on us, protect and defend our rights, property or safety, including the rights, property and safety of WTN and its family of Sites or act in urgent circumstances to protect the personal safety of our end users or others under the applicable laws, (iii) to fulfill our obligations under our agreement with you, or (iv) to check, prevent and investigate fraud, security or technical issues.
• To our advisers, any prospective purchaser’s advisers, and the new owner of the business as part of any corporate reorganization process including, but not limited to, mergers, acquisitions, and sales of all or substantially all of our assets.
• To protect against potential fraud, we may verify with third parties the information collected from these Sites. In the course of such verification, we may receive personal information about you from such services. In particular, if you use a credit card or debit card to make a purchase on the Sites, we may use card authorization and fraud screening services to verify that your card information and address matches the information that you supplied to us, and that the card has not been reported as lost or stolen. Except as described in this Privacy Policy or at the time we request the information, we do not otherwise use, share or otherwise disclose your personal information to any third parties.
• In the unlikely event of a direct or indirect reorganization process including, but not limited to, mergers, acquisitions, divestitures, bankruptcies, and sales of all or a part of our assets, WTN may disclose your personal information and non-personal information following completion of such transaction and/or during the assessment process pending transfer. If transferred in such a case, the purchaser will abide by the terms and conditions of this Privacy Policy.

• Job applicant information will be disclosed to individuals within our company that have a legitimate business need to access the information. We may also disclose your personal information to service providers, such as employment consultants or background search providers. 

• When you engage in a business relationship with us, we will collect and process your personal information as described in the “Personal Information Collected” section of this Policy. We use this information for business purposes such as to run our Sites and provide our services. This Privacy Policy does not override any specific contracts agreed to by the parties, and relationships may be governed by further privacy agreements. If you are engaging with us on behalf of others in your company or otherwise providing the personal information of others, by engaging with us, you acknowledge and agree that you have obtained any required consent from those individuals. 

(2) Non-Personal Information

We may share non-personal information collected on the Sites in the manner disclosed above and in other ways as permitted by law. For example, we may track and analyze non-personal information and aggregate usage and volume statistical information from our visitors and customers and provide such information to third parties.

(3) Sale or Sharing for Targeted Advertising Purposes

To personalize our ads and marketing experiences, and to provide tailored video content, we work with advertising and analytics partners, ad networks, and social media sites. These partnerships may be considered a “sale” or “sharing” under some U.S. laws, even when no money exchanges hands. For example, when you log in to your account on a web page where cookies are present, that may be considered a “sale” or “sharing” of your personal information.

The personal information we might “sell” or “share” includes your basic name and contact information, online activity information, customer records, and other personal information or sensitive personal information outlined in Section B, above. If you want to opt-out of this use, please contact us at info@worldtrustnetwork.net. WTN does not knowingly sell or share the personal information of children under the age of 16.

 

F. Collection and Use of Information from Children

WTN does not knowingly collect information from visitors under the age of 16, or 18 in the European Economic Area (“EEA”). In the event that we learn that a person under these ages has provided WTN with personal information, we will promptly delete such personal information from our systems.

G. Content on the Sites

The primary purpose of the Sites is to make available to consumers educational, informational, and entertainment video content, audiovisual content, audio content, power point and other print-only content, and content of a like nature (collectively, the “Content”).

As of the effective date of this Privacy Policy, WTN does not utilize Targeting Tools (defined below) on the Sites. WTN does, however, reserves the right to use Targeting Tools in the future, and in such event the following paragraphs will apply.

In connection with our provision of Content, the Sites may utilize online targeting technologies and code-based tools, including, but not limited to, social media pixels, Software Development Kits (“SDKs”), and cookies (i.e., advertising or analytics cookies) that track information about your activity and webpage-viewing history on the Sites (collectively, “Targeting Tools”) in order to recommend, both on the Sites and on third-party vendor sites, tailored Content and to gauge performance of Content, the Sites and WTN in general. Targeting Tools on the Sites may result in information about your activity on the Sites being transmitted from your browser to WTN and third parties, which, in turn, may result in the display of targeted advertisements on third-party websites and platforms, including advertisements for WTN content. In addition, whether Targeting Tools on the Sites result in your browser’s transmission of information to third parties depends on a number of factors that may be outside of WTN’s knowledge or control, including what third-party websites you use, what information you have provided to such third parties, and whether (and the extent to which) you have limited the use of cookies by the operators of those third-party websites. For more information about these targeting tools and how to control the personal information collected by these tools, please see Section N, below. 

H. International Transfer of Information

If you choose to provide WTN with personal information, and with your prior consent or otherwise in accordance with applicable law, WTN may transfer that information to its affiliates and subsidiaries or to other third parties, across borders, and from your country or jurisdiction to other countries or jurisdictions around the world. If you are visiting from the European Union (EU), the European Economic Area (EEA) or other regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring your personal information to the United States which does not have the same data protection laws as the EU/EEA and may provide more limited recourse mechanisms, including dissimilar or, at times, weaker data protection rights. In case of such transfer, appropriate safeguards (e.g., EU standard contractual clauses) will be used to ensure an adequate level of protection of your personal information.

With knowledge of these risks, you understand that:

• Your personal information may be used for the uses identified above in accordance with this Privacy Policy and the applicable data protection law; and
• Your personal information may be transferred to the United States as indicated above.

For further information on or to request a copy of the aforementioned safeguards, please email us at info@worldtrustnetwork.net.

 

I. Your Rights and Choices 

• Contact Us: Please contact WTN at the methods provided below at the end of the Privacy Policy if you have questions about your personal information or if you would like to otherwise make a change to such information or would like to opt out of marketing. 
• Your Account: You can also specifically update, change, or delete certain personal information (such as your email address, mailing address, and payment method) on the Sites by logging into your account and clicking “My Account” in the menu at the top of each page of the website.
• Email Opt-Out: We communicate with users who purchase Content on the Sites on a regular basis via email. For example, we may use your email address, in each case always only in accordance with applicable laws, to send you information about a service requested by you, to confirm a service requested by you, to send you notice of payments, to send you information about changes to our services, and to send notices and other disclosures as required by law. Generally, users cannot opt-out of these transactional communications, but they will be primarily informational in nature rather than promotional. However, we provide you the opportunity to exercise an opt-out choice with respect to promotional communications; if you do not want to receive other types of communication from us, such as emails or updates from us regarding new services and products offered on the Sites or if you do not want us to share your personal information with third parties. The opt-out choice may be exercised, as required by the applicable law, by ticking or un-ticking the appropriate box if such checkbox is available at the points where personal information is collected, or by contacting us at info@worldtrustnetwork.net. We will process your opt-out request as soon as possible and in accordance with applicable law, but please be aware that in some circumstances you may receive a few more messages until the opt-out request is processed. You also may opt-out of receiving such emails by clicking on the “unsubscribe” or “opt-out” link within the text of the email.
• Text or SMS Messaging: We do not currently, but may in the future may also offer text/SMS messaging to you. In some circumstances, we might require you to opt-in to receive text messages from us. At any time, you may opt-out of receiving particular text messages from us by texting STOP in response to any text message.  

Additionally, individuals located in the EEA, United Kingdom, and Switzerland have the right to:

• Obtain confirmation as to whether or not your personal information exists and to be informed of its content and source, verify its accuracy and request its completion, update, or amendment;
• Request the deletion, anonymization or restriction of the processing of your personal information;
• Object to the processing, in all cases, of your personal information for legitimate reasons;
• Withdraw consent at any time if we have asked for your consent to process your personal information. Your withdrawal does not affect the legality of the processing carried out based on your consent until the withdrawal.
• Receive an electronic copy of your personal information, if you would like such a copy for yourself or to port your personal information to a different provider;
• Lodge a complaint with a relevant data protection supervisory authority. The relevant data protection authority will be the supervisory authority in your country.

These rights might be limited in some situations – for example, where we can demonstrate that we have a legal requirement to process your data. In some instances, this may mean that we are able to retain data even if you withdraw your consent.

Where WTN requires personal information to comply with legal or contractual obligations, the provision of such information is mandatory. If such data is not provided WTN will not be able to provide its Services or meet obligations placed on it. In all other cases, provision of requested personal information is optional.

The following rights are available to residents of California, Colorado, Connecticut, Virginia, and Utah, but may be subject to some legal exceptions:

• the right to know or access. You may request information about the categories and specific pieces of personal information we have collected about you, as well as the categories of sources from which such information is collected, the purpose for collecting such information, and the sale or disclosure for business purposes of your personal information to third parties, and the categories of third parties with whom this information was shared. 
• the right to data portability, meaning you may also request a copy of the personal information we have collected, and upon request, we will provide this information to you in electronic form.
• the right to opt out of the sale of your personal information to third parties.
• the right to opt-out of the use or sharing of your personal information for targeted advertising purposes.  
• the right to request deletion of your personal information.
• the right to opt-out of profiling or automated decision-making. 
• the right to limit the use and disclosure of your sensitive personal information if we use such information to create inferences about you. At this time, WTN does not use your personal information to create inferences about you. 
• the right to not be discriminated against for exercising any of the rights mentioned above. This includes not being discriminated against in connection with financial incentives, which we may offer from time to time. 

If you would like to exercise one or more of the above rights, please contact us using the contact information provided below. Whenever feasible for verification, we will match the identifying information provided by you to the personal information already maintained by us. If, however, we cannot verify your identity from the information already maintained by us, we may request additional information. You may designate an authorized agent to make a request on your behalf. Such authorized agent must have permission to submit requests on your behalf. 

We may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf. You may have the right to appeal a denial of your request by contacting us as described in the notice of denial.

J. Financial Incentives and Bone Fide Loyalty Programs

We do not currently, but may in the future offer you financial incentive programs or bona fide loyalty programs like discounts and special offers in exchange for your personal information. The personal information requested in connection with the offer, as well as other terms, will be provided at the time you sign up. We may share your data with service providers and marketing partners to provide the program. We will provide the name of any program partners at the time you sign up.  In calculating these offers, we consider the expenses related to the offer and the value of your data.

You may withdraw from any of the programs at any time by following the instructions provided.  Please note that if you opt out or request to delete your data, we may no longer be able to provide you with the benefits. For offers involving your e-mail, you may unsubscribe/opt-out via the “unsubscribe” or “opt-out” link in any marketing email you have received.  For offers involving text messaging, you may text STOP.  For all other offers, you may follow the instructions provided with the offer. 

K. Forums, Chat Rooms, and Other Public Posting Areas

Please note that any information you include in a message you post to any chat room, forum or other public posting area is available to anyone with Internet access. If you don’t want people to know your e-mail address, for example, don’t include it in any message you post publicly. PLEASE BE EXTREMELY CAREFUL WHEN DISCLOSING ANY INFORMATION IN CHAT ROOMS, FORUMS AND OTHER PUBLIC POSTING AREAS. WE ARE NOT RESPONSIBLE FOR THE USE BY OTHERS OF THE INFORMATION THAT YOU DISCLOSE IN CHAT ROOMS, FORUMS AND OTHER PUBLIC POSTING AREAS.

L. Third Party Websites

This Privacy Policy applies solely to personal information collected on the Sites. The Sites may contain links to other websites, such as to relevant third-party online resources, our partners’ websites, and other third-party websites. Any access to and use of such linked websites is not governed by this Privacy Policy but instead is governed by the privacy policies of those third parties. We are not responsible for the privacy practices or the content of these other websites.

M. Chatbot Features and Session Replay Technology

We may use session replay technology to monitor how you interact with our Sites or services. The personal information collected by this technology may include which links you click on, pages and content you view, information that you type into our online forms, recordings of mouse clicks and movements, and information about your device or browser. 

Our Sites may also have chatbot features for customer support purposes. The third parties providing these features may collect the content of your communications and other personal information you provide while interacting with the chatbot and provide that information to us. Please discontinue use of the Sites if you do not consent to our collection of such information.

N. Cookies and Ads

(1) Cookies Used by WTN

We use, and may allow certain third parties to use (including advertisers, third party ad networks, and other ad companies), cookies, web beacons, social media pixels, and other similar online targeting technologies (together, “cookies”) to provide our services, serve advertisements on the Sites, and to improve the performance of WTN’s advertising across the Internet. A web beacon is an electronic image, also called a “gif,” that may be in the form of a “png” image, as well as iframe, script, input link, embed, object, and other tags to track usage. These web beacons may be used on our web pages to deliver cookies, count visits and compile statistics on usage and effectiveness of our Sites. 

Please be advised that these cookie providers, such as advertising companies, may gather personal information about your visit to the Sites or other sites to enable them to market products or services to you, to monitor which ads have been served to your browser and which webpages you were viewing when such ads were delivered. If you are based in the EEA or another country which requires express consent for the use of certain kinds of cookies and of similar technologies and/or of information obtained by the use of cookies or similar technologies, we will comply with such consent requirements.

Depending on the particular advertising services they provide, these third party advertising companies may employ first-party cookies or third-party cookies. Unlike third-party cookies, first-party cookies are hosted on WTN’s servers. If you would like more information about third-party cookies or to learn more about your opt-out choices, please click here ( https://www.networkadvertising.org/choices/). For the avoidance of doubt, the option to opt out of cookies does not mean that we or third-party advertising companies use cookies without your consent where such consent is required under applicable law. PLEASE NOTE THAT THIS POLICY DOES NOT COVER THE COLLECTION AND USE OF INFORMATION BY SUCH THIRD PARTY WEBSITES AND ADVERTISING COMPANIES.

The types of cookies used on the Sites can be categorized as follows:

• Essential or Strictly Necessary Cookies are essential to our Sites and allow you to navigate and use their features. They also help authenticate users and prevent fraudulent use of your account. 
• Performance and Analytics Cookies, which are sometimes called “analytics cookies,” enable us to improve our Sites and services by seeing which areas and features are most popular and to count the number of computers or mobile devices accessing our Sites.
• Functional Cookies allow us to personalize and improve your experience by recording your preferences, which allows you to visit our Sites without re-entering your username and/or password. 
• Targeting or Advertising Cookies are used by WTN and third parties to deliver ads we believe are more relevant to you and your interests, to improve the performance of our advertising across the Internet, and to limit the number of times that you see an ad on our Sites. 

If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies or be given the choice of declining or accepting the transfer to your computer of a particular cookie (or cookies) from a particular site.

You may also visit http://www.allaboutcookies.org/manage-cookies/index.html for more information. However, if you choose not to accept cookies, your ability to use our Sites may be hindered. 

The “Do Not Track” (“DNT”) privacy preference is an option that may be made in some web browsers allowing you to opt-out of targeting by websites and online services. At this time, global standard DNT technology is not yet finalized and not all browsers support DNT. We do not sell data in the traditional sense of a “sale” but we do utilize third party advertising vendors who may use information collected through our Sites to track users. We do not recognize all DNT signals but we do recognize the Global Privacy Control.

 

O. Changes to this Privacy Policy

We reserve the right to change this Privacy Policy from time to time. When we do, we will also revise the “last updated” date at the top of this Privacy Policy. When we make any material changes to this Privacy Policy, we will notify you either by sending a notice to the primary email address specified in your account or by placing a prominent notice on the Sites as required by applicable law so that you have the opportunity to exercise your rights.

P. Security and Retention

We implement reasonable security measures to protect against the loss, misuse, unauthorized access, disclosure, alteration or destruction of the information you provide us. We may use third party products and services to secure or store your information. Please understand that no data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to WTN is done at your own risk. We use firewalls to protect your information from unauthorized access, disclosure, alteration, or destruction. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software.

If we learn of a security systems breach we may attempt to notify you electronically so that you can take appropriate protective steps. By using these Sites or providing personal information to us you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of these Sites. We may post a notice on our Sites if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

The personal information record created through your registration with our Sites can only be accessed with the unique password associated with that record. To protect the integrity of the information contained in this record, you should not disclose or otherwise reveal your password to third parties. You agree that you are responsible for all acts or omissions that occur on your account while your password is being used. Please let us know immediately if you believe your password has been compromised.

Q. Retention

We will retain your personal information for as long as necessary to provide the products and services you have requested. Afterwards, we may retain data for an appropriate period to protect ourselves from legal claims, to administer our business, or to the extent permitted by applicable law, which may require us to hold your personal information for specific periods. We will delete your personal information when you withdraw your consent, if there is no other legal ground for further processing (e.g., a statutory obligation to retain your personal information), or when you object to the processing in accordance with Section I (see above) or when we are obligated to delete it in accordance with an obligation under applicable law.

R. Data Controller Information and Contacting Us

If you have any questions about this Privacy Policy or our privacy practices, please contact the data controller at info@worldtrustnetwork.net.