Privacy Policy

Who We Are

Incsub, LLC provides WordPress and web hosting services via WPMU DEV, CampusPress, and Edublogs.

This privacy policy applies to all visitors and customers using or accessing any of the websites that we produced and maintain for the services that we provide, including wpmudev.org, campuspress.com, edublogs.org, incsub.com, and theedublogger.com. It also applies to the WordPress services that we provide as part of WPMU DEV memberships that use APIs to interact with our servers or the WPMU DEV site and to human resources data of our employees and contractors.

This policy DOES NOT cover websites that we host for our customers as part of WPMU DEV or CampusPress. For these sites, the site owner/customer is responsible for publishing its own privacy policy.

Incsub, LLC is a registered corporation in Alabama, USA. Our mailing address is:

Incsub, LLC
7700 Northcross Dr #10291
Austin, TX 78766
USA

For any privacy-related questions, you can reach us at admin@incsub.com.

Who We Share Your Data With

We use third-party services (data processors) across our sites. The extent to which your data is shared with these providers depends on your use of our services, and we list the specific third-parties in use (with links to their privacy policies) in the sections below.

Each third-party provider has been vetted by our security team to ensure that privacy policies and practices meet or exceed the same levels of compliance and standards that we follow. Where appropriate and available, we hold additional signed Data Privacy Agreements with these companies as an additional layer of accountability in order to help ensure your data is safe and secure.

We disclose potentially personally-identifying and personally-identifying information only to our employees, contractors and affiliated organizations that (i) need to know that information in order to process it on our behalf or to provide services, and (ii) that have agreed, in writing, not to disclose it to others. Some of those employees, contractors and affiliated organizations may be located outside of your home country; by using our websites and services, you consent to the transfer of such information to them. We will not rent or sell potentially personally-identifying and personally-identifying information to anyone.

We may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

If we ever were to engage in any onward transfers of your data with third parties for a purpose other than which it was originally collected or subsequently authorized, we would provide you with an opt-out choice to limit the use and disclosure of your personal data.

Cookies

A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. We use cookies across our sites to help identify and track visitors, their usage of our services, and their website access preferences. We describe the specific cookies used in the sections below. Visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using our websites, with the drawback that certain features may not function properly without the aid of cookies.

What Personal Data We Collect And Why We Collect It

Registered Users

  • If you create an account on one of our sites, you will be prompted to select a Username and provide your Email Address.
  • When choosing a Username, we strongly advise you not use or include your real name. Usernames cannot be changed.
  • Your Username and Email Address are stored in the website’s database. Your Email Address is used to send you an email with a link to set your password or to send you an email with a link to reset your password in the event you forget your password.
  • Once an account is created, you must contact us to have it deleted.
  • Accounts have a numeric User ID assigned to them when they are created. The User ID cannot be changed.
  • An anonymized string created from your email address (also called a hash) is provided to the Gravatar service to see if a Profile picture of you is available for display. The Gravatar service privacy policy is available here.
  • You may optionally complete your Profile by providing your First Name, Last Name, Website (URL) and/or Biographical info. These additional details are also saved in the website’s database. You may edit these details, and your Email Address, in your Profile at any time.
  • You may also choose how your name is displayed (your Display Name) to visitors to the site (e.g. in comments you create) in your Profile.
  • Your Username, First Name, Last Name and Email Address are accessible by employees on the site.
  • If you attempt to log in to our site, we will set a temporary cookie to determine if your browser accepts cookies at all. This cookie contains no personal data and is discarded when you close your browser.
  • If you have an account and you log in to a site, we will set up several cookies to save your login information and some of your screen options. The logged-in cookies last for two days, and the screen options cookies last for a year.
  • If you select “Remember Me” these cookies will persist for two weeks. If you log out of your account, the login cookies will be removed. It is important that you log out if you are using a public computer.
  • For users that register on one of our sites, we also store the data they provide in their profile indefinitely. All registered users can see, change or delete most of that data at any time except their login name/nickname.

 

Publishing Content (Comments, Pages, Posts, Forums)

  • Your Profile Picture (Gravatar), Display Name, Website (URL) (if any) and Biographical Info (if any) may be visible to visitors to the website (e.g. if you leave a comment, forum post, or contribute an article/post).
  • If you author an article/post, your Username, User ID, Profile Picture (Gravatar), Display Name, Website (URL) (if any) and Biographical Info (if any) are provided to any visitor using the website’s REST API interface.
  • If you upload media (e.g. images) to the website (in forums, posts, or comments), you should avoid uploading images with EXIF GPS location data included. Visitors to the website can download and extract any location data included in images on the website.
  • Visitors using the website’s REST API interface can correlate uploaded media to a particular user. This may allow such visitors to map a user to a particular time and location if EXIF GPS location data was included in the uploaded media.
  • If you edit or publish an article/post, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.
  • When visitors leave comments on one of our sites we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
  • Comments may require manual approval by one of our employees or site owners.
  • If you leave a comment on a site you may opt-in to saving your name, email address and website in cookies so we can recognise you as a commenter. These cookies will persist for one year.
  • Additional spam detection is provided by Automattic/Akismet. The Automattic privacy policy is available here.
  • Published content and comments are stored indefinitely unless deletion/removal is requested by the original author.

 

Email/Chat/Contact Forms

  • We use Google/G Suite to process all internal email and communication with our customers. Google’s privacy policy is available here.
  • Customers that email us, or use any of the contact forms on our websites, will have their email address, IP address, and any data provided in the contact form or body of the email stored in G Suite archives and in our help desk third-party service provider, HelpScout. The HelpScout privacy policy is found here.
  • We use LiveChatInc to provide live chat and live support services. Any data provided during a live chat session with one of our team members will be recorded and logged in an email that is sent to our HelpScout help desk. This includes your name, email address, and IP address. The LiveChatInc privacy policy is found here.
  • LiveChatInc uses cookies to tailor chat sessions to the individual. No personal information is stored in these cookies (only visit history). Cookies expire in 3 years.
  • We keep all email and chat communication indefinitely to help us provide support and improve our services. Individuals can request copies of any previous correspondence with us at any time.

 

Embedded Content From Other Websites

Embeds are pieces from other websites that are shown from time to time on our websites. They behave in the exact same way as if the visitor has visited the other website and may use cookies or capture information. Typically embedded content is from websites that share videos, images, or other content. These services may collect your IP Address, your User Agent, store and retrieve cookies on your browser, embed additional third-party tracking, and monitor your interaction with that embedded content, including correlating your interaction with the content with your account with that service, if you are logged in to that service.

Links to the privacy policies of the most common services have been included below. Where a general privacy policy is not available, the applicable country is indicated.

 

Analytics

  • We use Google Analytics for tracking visitors and aggregating information about the traffic to our websites. The Google Analytics privacy policy can be found here:  https://policies.google.com/privacy. You can learn more about how to opt-out of tracking in Google Analytics here.
  • We use Mixpanel to track the logged-in activity of users of WPMU DEV. This includes profile information provided during signup. Mixpanel’s privacy policy is found here.
  • Mixpanel uses cookies to track activity on the WPMU DEV site. Cookies include a unique identifier tied to your WPMU DEV account but does not include personally identifying information. Cookies expire within 1 year.

 

Marketing Campaigns

  • We use email marketing to communicate with customers and potential customers from time to time. All email lists and campaigns are “opt-in” meaning we will not send you these sorts of emails unless you indicated that you wish to receive them during signup or other interactions on our website.
  • We may send you “system” emails, such as password reset requests or payment notifications/receipts even if you have not opted-in to email marketing lists.
  • All marketing emails sent by us will include an unsubscribe link in the footer of the email. Emails sent to you may also include standard tracking, including open and click activities.
  • We use two different services for email marketing, MailChimp and Mixpanel. Mailchimp’s privacy policy is found here. Mixpanel’s privacy policy is found here.
  • With the exception of visitors to Edublogs.org, we may utilize social media and web advertising campaigns. These service providers use cookies on our sites and/or pixel tracking to serve ads across the different platforms.

 

Paying Customers

  • For business analytics and payment subscription records for WPMU DEV, we use Chartmogul. Charmogul’s privacy policy can be found here.
  • For business analytics, CRM, and subscription records of Enterprise and CampusPress customers, we use Hubspot. Hubspot’s privacy policy can be found here.
  • For payment transactions for WPMU DEV and Edublogs, we use PayPal and Stripe. PayPal’s privacy policy can be found here. Stripe’s privacy policy can be found here.
  • For payment transactions and invoice records of Enterprise and CampusPress customers, we use Zoho. Zoho’s privacy policy can be found here.
  • To comply with accounting and legal requirements, we keep data on financial transactions in the systems above for up to 10 years.

 

Hosting and API Services

  • All web servers and hosting are managed by our team on the Amazon Web Services platform located in different regions around the world. This includes website hosting, backups, web database, file storage, APIs, and log files. Hosting, Enterprise, and CampusPress customers may choose which region/country their website is hosted in, and in that case, all WordPress and database files for that site will be stored in that region only. Amazon’s privacy policy can be found here.
  • Our ‘Hummingbird’ and ‘Smush’ products and our hosting services use the Stackpath Content Delivery Network (CDN). Stackpath may store web log information of site visitors, including IPs, UA, referrer, Location and ISP info of site visitors for 7 days. Files and images served by the CDN may be stored and served from countries other than your own. Stackpath’s privacy policy can be found here.

 

What Rights You Have Over Your Data

If you are a registered user or have left comments on our site you can request to see or download the data we have about you.

Typically for visitors that have left comments, the data will be their email address, any IP addresses assigned to them at the time of leaving the comments and the user agent strings of the browsers they used. The rest of the data is public as published by the visitors.

For registered users or paying customers, this will also include profile information and download, payment, and support ticket histories.

You can also request “to be forgotten” and we will erase any personally identifiable data we have about you. Of course, this excludes data we need for administrative or security purposes or if we are required by law to retain some of the data.

An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct his/her query to admin@incsub.com. We will respond within a reasonable timeframe, not to exceed one week.

 

 

How We Protect Your Data

The security and reliability of our service is our number one priority. We invest heavily in the training of our staff and our infrastructure to ensure that best practices are followed in everything that we do.

See wordpress.org/about/security for details on the security of the WordPress core itself.

  • Prevention is best when it comes to security, and as a first step, we follow all WordPress Code Standards in the plugins that we build and use.
  • In addition, we have an extensive internal review and Quality Assurance process in place specifically to prevent potential security vulnerabilities in our plugins and services.
  • Every Incsub employee and contractor goes through background checks and an onboarding process that includes a trial period where access to customer data is provided only when working directly under the supervision of another staff member.
  • All staff only have access to systems that are directly required to complete the functions of their job. We use dual factor authentication for all critical systems and communications services, and automatically log all staff activity using an internal logging tool, Google ‘G’ Suite features, and Amazon Cloud Trail.
  • All staff (including any contractors) undergo initial training to ensure proper understanding of all security-related processes. Staff regularly attend industry conferences and otherwise stay informed of best practices and relevant trends. Staff review and agree, in writing, to all policies and procedures annually.
  • We only use third-party services, such as Amazon Web Services, that are fully vetted and adhere to the highest levels of privacy and security practices.

What Data Breach Procedures We Have In Place

Should any event occur where customer data has been lost, stolen, or potentially compromised, our policy is to alert our customers via email no later than 48 hours of our team becoming aware of the event. We will also report such incident to any required data protection authority. We will work closely with any customers affected to determine next steps such as any end-user notifications, needed patches, and how to avoid any similar event in the future.

Privacy Shield Frameworks

Incsub, LLC complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Incsub, LLC has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit privacyshield.gov.

In compliance with the Privacy Shield Principles, Incsub, LLC commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Incsub at admin@incsub.com or by mail at the address at the top of this policy.

If we do not resolve your complaint, you may contact JAMS, our designated independent dispute resolution provider for Privacy Shield inquiries. You can contact JAMS, which is based in the United States, through its website at the following link: https://www.jamsadr.com/eu-us-privacy-shield

If neither Incsub, LLC nor JAMS resolves your complaint, you may, in certain circumstances, be able to seek binding arbitration through the Privacy Shield Panel. You can read more about binding arbitration in Annex I to the Privacy Shield Principles.

Incsub, LLC commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship.

Our commitments under the Privacy Shield are subject to the investigatory and enforcement powers of the United States Federal Trade Commission.

Privacy Policy Changes

Although most changes are likely to be minor, Incsub may change its Privacy Policy from time to time, and in Incsub’s sole discretion. Incsub will notify clients by email when making changes.

Changelog

  • July 6, 2018 – Add claused for Privacy Shield Frameworks
  • May 25, 2018 – Updated language of the policy to be more user-friendly, specifically outlining requirements in preparation for meeting the GDPR.
  • September 28, 2016 – Removed clauses for EU/Swiss Safe Harbor Program
  • June 11, 2013 – Added in clauses for EU/Swiss Safe Harbor Program