(Updated: June 18, 2020.)

TRUSTe

WPEngine, Inc. (“WP Engine,” “we,” “us,” “our”) maintains this Privacy Policy to inform you of our practices with regard to personal data we collect from or about you in connection with our web site (the “Site”) or through the provision of our services (the “Services”). We may update this Privacy Policy from time to time. We will notify you of any material change by providing a notice on our web site or, if you are a customer, by whatever other means upon which we have mutually agreed. The current version of this Privacy Policy may be found at https://wpengine.com/legal/privacy/. By using the Site or the Services you acknowledge your consent to the practices described herein.

If you are a customer who is subject to the privacy laws of California or the European Union, the Data Privacy Addendum located at https://wpengine.com/legal/dpa/ as it may be updated from time to time governs the obligations between us with regard to personal data as defined by such laws.

  1. Personal data we collect
    1. Information you give us
      In order for you to use our Services and other features of our
      Site, we will ask you for some of your personal data (e.g. contact information, name, etc.). The
      amount and type of information that we gather depends on the nature of the interaction. For example,
      we ask visitors who would like to comment on our blog to provide a username. Those who purchase
      Services from us are asked to provide additional information including, as necessary, the personal
      and financial information required to process transactions. In each case, we collect such
      information only insofar as is necessary or appropriate to fulfill the purpose of your interaction
      with us. You can always refuse to supply personal data; however, doing so may prevent you from
      receiving our Services or engaging in other activities on the Site. In no event will we ever request
      sensitive personal data (e.g. health information, religious preferences, etc.) from you, and we
      expressly request that you not provide any such sensitive personal data to us.
    2. Web server logs
      As is true of most websites, we gather certain information automatically through your use
      of the Site. This information may include Internet protocol (IP) addresses, browser type, Internet
      service provider (ISP), referring or exit pages, the files viewed on the Site (e.g., HTML pages,
      graphics, etc.), operating system, date/time stamp, and clickstream data to analyze trends in the
      aggregate and administer the site. We use analytical software to help us understand this
      information. This software sends information to its licensor. Other sites and companies may also use
      this software. As a result, the licensor may collect information that, when aggregated by them,
      allows them to identify you individually. We have no responsibility for this collection and use.
    3. Cookies
      We and our partners use cookies and similar technologies to analyze trends,
      administer the Site, track users’ movements around the Site, and gather demographic information
      about our user base as a whole. You can control the use of cookies at the individual browser level.
      Ads appearing on our Site may be delivered to you by advertising partners who may set cookies. These
      cookies allow the ad server to recognize your computer each time they send you an online
      advertisement to compile information about you or others who use your computer. This information
      allows ad networks to, among other things, deliver targeted advertisements that they believe will be
      of most interest to you. This Privacy Policy covers our use of cookies and does not cover the use of
      cookies by any advertisers. However, data tracking files used by us may also be used by these
      advertisers and, when combined with other information held by them, be used to identify you
      personally. For more information on third party cookies and instructions on how to opt-out of those
      cookies set by members of the National Advertising Initiative, please click here.
      Or, if you are located in the European Union, please visit the European Interactive Digital Advertising Alliance here.
    4. Information collected by our customers.
      Our customers may collect personal data in connection with the Services we
      provide to them. WP Engine’s customers control the personal data they collect, and WP Engine will
      not use or disclose that personal data except as authorized or directed by the customer in the
      course of our provision of the Services and as governed by our agreement with that customer. If your
      personal data is controlled by one of our customers, and you have concerns about the way that data
      is managed or wish to exercise your rights with respect to such data (including your rights of
      access, amendment, or deletion), please contact that customer directly.
  2. How we use personal data
    WP Engine will only use the personal data we collect as reasonably
    necessary for the following purposes:

    1. to allow you to use and interact with the Site;
    2. to provide the Services to you as our customer;
    3. to inform our continued development of the Site and the Services;
    4. to communicate with you from time to time in response to your requests for information
      or as may be relevant to your account with us;
    5. to send marketing communications related to the services we provide;
    6. as required by applicable law or legal requirements pertaining to records retention or
      for internal administrative purposes; or
    7. as specifically authorized by you in writing.
  3. Disclosure to third parties
    We will not disclose your personal data to third parties except as
    follows:

    1. when we believe disclosure is reasonably required to comply with any law or legal request;
    2. to enforce our legal and contractual rights, or to protect the rights and safety of
      others;
    3. to third parties who help us provide any part of the Site or the Services, to the
      limited extent required for such help, and on condition that they may not further disclose your data
      or use it for any other purpose; or
    4. as part of a sale of our assets or a merger of our company.

    We remain responsible for compliance with this Privacy Policy by third parties to whom we disclose your
    personal data.

  4. Procedures to protect personal data
    We have put in place reasonable measures and appropriate procedures for implementing
    these policies and for safeguarding the personal data we collect. However, we cannot guarantee that personal
    data we collect will never be disclosed in a manner inconsistent with this Privacy Policy.We follow generally accepted standards to protect the personal data submitted to us, both
    during transmission and once it is received.
  5. Your rights over personal data that we control
    Upon request, we will provide you with details regarding your personal data that has
    been collected by us or which is under our control. If you would like to change information that we maintain
    about you, you may log into your account and change it or submit a support request for any information to
    which you don’t have access or the ability to change yourself. Information covered by this Privacy Policy
    may be deleted upon your request, provided that such deletion may impact our ability to provide you with the
    Services. You may also request that we update or correct your personal data by writing us at: WPEngine, Inc.
    Attn: Legal Department, 504 Lavaca St., Ste. 1000, Austin, Texas 78701, or by sending an email to
    [email protected] We will respond to your request within a reasonable timeframe.You may opt-out of receiving most e-mails from us by following the “unsubscribe” instructions
    provided in the e-mails. Alternatively, you may contact us as described herein. If you are our customer,
    you may not be able to opt out of all emails, including certain administrative or billing communications
    which are important to the ongoing maintenance of your account.We may keep your personal data for as long as reasonably required to meet the purposes
    described herein. Additionally, we will retain this information as required by law, as necessary to
    comply with our legal obligations, resolve disputes, and enforce our agreements.
  6. EU-US and Swiss-US Privacy Shield
    We participate in and have certified our compliance with the EU – U.S. Privacy Shield
    Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all personal data
    received from European Union (EU) member countries and Switzerland, respectively, in reliance on each
    Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield
    Frameworks, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov/list.Under the Privacy Shield Frameworks, we are responsible for the processing of personal data
    that we collect from you and subsequently transfer to a third party acting as an agent on our behalf. We
    comply with the Privacy Shield Principles for all onward transfers of personal data from the EU and
    Switzerland including the onward transfer liability provisions.With respect to personal data received or transferred pursuant to the Privacy Shield
    Frameworks, we are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In
    certain situations, we may be required to disclose personal data in response to lawful requests by
    public authorities, including requests made to meet national security or law enforcement requirements.If you have an unresolved privacy or data use concern that we have not addressed
    satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge)
    at https://feedback-form.truste.com/watchdog/request.

    Under certain conditions more fully described on the Privacy Shield website located at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint,
    you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

  7. California Residents
    If you are a resident of the State of California, this Section addresses your rights and our
    obligations under the California Consumer Privacy Act of 2018 (“CCPA”). Terms used in this Section have the
    same meaning as provided in the CCPA.Information We Collect
    Our Site collects information that identifies, relates to, describes, references, is capable of
    being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer
    or device (“personal information”). In particular, our Site has collected the following categories of
    personal information from visitors within the last 12 months:Category: Identifiers.
    Examples: A real name, IP address, email address, account name, or other similar identifiers.Category: Personal information categories listed in the California Customer Records statute
    (Cal. Civ. Code § 1798.80(e)).
    Examples: A name, address, telephone number, and (if you are applying for a job) your current employment
    and employment history.

    Category: Internet or other similar network activity.
    Examples: Browsing history, search history, information on a consumer’s interaction with a website,
    application, or advertisement.

    Category: Geolocation data.
    Examples: Physical location or movements.

    Personal information does not include:

    1. Publicly available information from government records.
    2. De-identified or aggregated consumer information.
    3. Information excluded from the CCPA’s scope.

    We obtain the categories of personal information listed above from the following categories of
    sources:

    1. Directly from you. For example, from forms you complete on our
      website.
    2. Indirectly from you. For example, from observing your actions on
      our website or interactions with our advertisers.

    Use of Personal Information
    We may use, or disclose the personal information we collect
    for one or more of the following business purposes:

    1. To fulfill or meet the reason you provided the
      information. For example, if you share your name and contact
      information to request a price quote or ask a question about our
      products or services, we will use that personal information to
      respond to your inquiry. If you provide your personal information to
      purchase a product or service, we will use that information to
      process your payment and facilitate delivery. We may also save your
      information to facilitate new product orders or process returns.
    2. To provide you with support and to respond to your
      inquiries, including to investigate and address your concerns and
      monitor and improve our responses.
    3. To respond to law enforcement requests and as required
      by applicable law, court order, or governmental regulations.
    4. As described to you when collecting your personal
      information or as otherwise set forth in the CCPA.
    5. We will not collect additional categories of personal
      information or use the personal information we collected for
      materially different, unrelated, or incompatible purposes without
      providing you notice.

    Sharing Personal Information
    We disclose all of the above categories of personal
    information to our third-party service providers subject, in each case,
    to a written contract that describes the business purpose of the
    disclosure and requires the recipient to both keep that personal
    information confidential and not use it for any purpose except
    performing the contract.

    Sales of Personal Information
    We do not and will not sell your personal information.

    Access to Specific Information and Data Portability
    Rights
    You have the right to request that we disclose certain
    information to you about our collection and use of your personal
    information over the past 12 months. Once we receive and confirm your
    verifiable consumer request, we will provide:

    1. The categories of personal information we collected
      about you.
    2. The categories of sources for the personal information
      we collected about you.
    3. Our business or commercial purpose for collecting or
      selling that personal information.
    4. The categories of third parties with whom we share that
      personal information.
    5. The specific pieces of personal information we collected
      about you (also called a data portability request).
    6. The categories of personal information we sold to a
      purchaser, and the categories of recipients.
    7. The categories of personal information we disclosed for
      a business purpose, and the categories of recipients.

    Deletion Request Rights
    You have the right to request that we delete any of your
    personal information that we collected from you and retained, subject to
    certain exceptions. Once we receive and confirm your verifiable consumer
    request, we will delete (and direct our service providers to delete)
    your personal information from our records, unless an exception applies.

    We may deny your deletion request if retaining the information
    is necessary for us or our service provider(s) to:

    1. Complete the transaction for which we collected the
      personal information, provide a good or service that you requested,
      take actions reasonably anticipated within the context of our
      ongoing business relationship with you, or otherwise perform our
      contract with you.
    2. Detect security incidents, protect against malicious,
      deceptive, fraudulent, or illegal activity, or prosecute those
      responsible for such activities.
    3. Debug products to identify and repair errors that impair
      existing intended functionality.
    4. Exercise free speech, ensure the right of another
      consumer to exercise their free speech rights, or exercise another
      right provided for by law.
    5. Comply with the California Electronic Communications
      Privacy Act (Cal. Penal Code § 1546 et. seq.).
    6. Engage in public or peer-reviewed scientific,
      historical, or statistical research in the public interest that
      adheres to all other applicable ethics and privacy laws, when the
      information’s deletion may likely render impossible or seriously
      impair the research’s achievement, if you previously provided
      informed consent.
    7. Enable solely internal uses that are reasonably aligned
      with consumer expectations based on your relationship with us.
    8. Comply with a legal obligation.
    9. Make other internal and lawful uses of that information
      that are compatible with the context in which you provided it.

    Exercising Access, Data Portability, and Deletion
    Rights
    To exercise the access, data portability, and deletion rights
    described above, you can contact us by email at [email protected] or by
    phone at (877) 973-6446. Only you, or a person registered with the
    California Secretary of State that you authorize to act on your behalf,
    may make a verifiable consumer request related to your personal
    information. You may also make a verifiable consumer request on behalf
    of your minor child.

    You may only make a verifiable consumer request for access or
    data portability twice within a 12-month period. The verifiable consumer
    request must:

    1. Provide sufficient information that allows us to
      reasonably verify you are the person about whom we collected
      personal information or an authorized representative.
    2. Describe your request with sufficient detail that allows
      us to properly understand, evaluate, and respond to it.

    We cannot respond to your request or provide you with personal
    information if we cannot verify your identity or authority to make the
    request and confirm the personal information relates to you. We will
    only use personal information provided in a verifiable consumer request
    to verify the requestor’s identity or authority to make the request.

    Response Timing and Format
    We endeavor to respond to a verifiable consumer request within
    45 days of its receipt. If we require more time, we will inform you of
    the reason and extension period in writing. We will deliver our written
    response by mail or electronically, at your option. Any disclosures we
    provide will only cover the 12-month period preceding our receipt of
    your request. The response we provide will also explain the reasons we
    cannot comply with a request, if applicable. For data portability
    requests, we will select a format to provide your personal information
    that is readily useable and should allow you to transmit the information
    from one entity to another entity without hindrance, specifically by
    electronic mail communication.

    We do not charge a fee to process or respond to your
    verifiable consumer request unless it is excessive, repetitive, or
    manifestly unfounded. If we determine that the request warrants a fee,
    we will tell you why we made that decision and provide you with a cost
    estimate before completing your request.

    Non-Discrimination
    We will not discriminate against you for exercising any of
    your CCPA rights. Unless permitted by the CCPA, we will not:

    1. Deny you goods or services.
    2. Charge you different prices or rates for goods or
      services, including through granting discounts or other benefits, or
      imposing penalties.
    3. Provide you a different level or quality of goods or
      services.
    4. Suggest that you may receive a different price or rate
      for goods or services or a different level or quality of goods or
      services.

    However, we may offer you certain financial incentives
    permitted by the CCPA that can result in different prices, rates, or
    quality levels. Any CCPA-permitted financial incentive we offer will
    reasonably relate to your personal information’s value and contain
    written terms that describe the program’s material aspects.
    Participation in a financial incentive program requires your prior opt
    in consent, which you may revoke at any time.

    California’s “Shine the Light” law (Civil Code Section §
    1798.83) permits users of our Website that are California residents to
    request certain information regarding our disclosure of personal
    information to third parties for their direct marketing purposes. To
    make such a request, please send us an electronic message through our
    website or write us at our address listed on our webpage.