diff --git a/Grammarly/Privacy Policy.md b/Grammarly/Privacy Policy.md index ee4d561d6ba..93e85ae56c4 100644 --- a/Grammarly/Privacy Policy.md +++ b/Grammarly/Privacy Policy.md @@ -89,9 +89,9 @@ Privacy Policy ============== -Effective as of September 18, 2020 +Effective as of March 1, 2021 -The previous version is [here](https://www.grammarly.com/privacy-policy-June-24-2020). +The previous version is [here](https://www.grammarly.com/privacy-policy-Sept-18-2020). At Grammarly, we care about the privacy of your data and are committed to protecting it. This Privacy Policy explains what information we collect about you and why. We hope you will read it carefully. @@ -145,7 +145,7 @@ We collect this information as you use the Site, Software, and/or Services: * User Content. This consists of all text, documents, or other content or information uploaded, entered, or otherwise transmitted by you in connection with your use of the Services and/or Software. -* Names of user contacts (if you are using the Grammarly Keyboard). The Grammarly Keyboard may request or obtain access to the names of your contacts on your device. This access helps the Grammarly Keyboard recognize when you are typing names so it can make appropriate suggestions (for example, if you misspell a name). +* Names of user contacts in Grammarly Keyboard (on-device storage only). To make appropriate spelling suggestions, the Grammarly Keyboard may request or obtain access to your contacts' names on your device. For instance, Grammarly will not try to autocorrect names that are in your contacts. These names will be stored solely on your device within the Grammarly Keyboard app and are never sent to Grammarly servers. #### Automatically collected Information @@ -175,7 +175,7 @@ We use, process, and store your Information as necessary to perform our contrac * To communicate with you about your use of our Site, Software, and/or Services, product announcements, and software updates, as well as respond to your requests for assistance, including providing account verification support if you’re having difficulty accessing your account. -* To send you direct marketing emails and special offers about Grammarly, from which you can unsubscribe at any time. For more information, please see the section titled, “[Will Grammarly send me emails?](#will-grammarly-send-me-emails)” If you are located in the European Economic Area (EEA), we will only send you marketing information if you consent to us doing so at the time you create your account or any point thereafter. +* To send you direct marketing emails and special offers about Grammarly, from which you can unsubscribe at any time. For more information, please see the section titled, “[Will Grammarly send me emails?](#will-grammarly-send-me-emails)” If you are located in the European Economic Area (EEA), Switzerland, or the UK, we will only send you marketing information if you consent to us doing so at the time you create your account or any point thereafter. * To display User Content associated with your account and make sure it is available to you when you use our Services. @@ -232,7 +232,7 @@ Data collected by third parties through these apps and plugins is subject to eac From time to time, we may want to contact you with information about product announcements, software updates, and special offers. We also may want to contact you with information about products and services from our business partners. You may opt out of such communications at any time by clicking the “unsubscribe” link found within Grammarly emails and changing your contact preferences. All Grammarly account holders will continue to receive transactional messages related to our Services, even if you unsubscribe from promotional emails. -For EEA users: We only send marketing communications to users located in the EEA with your prior consent. Please see the section “[For EEA users](#for-eea-users)” below. +For EEA, Swiss, and UK users: We only send marketing communications to you with your prior consent. Please see the section “[For EEA, Swiss, and UK users](#for-eea-users)” below. ### Does Grammarly ever make any of my Personal Data or User Content public? @@ -242,12 +242,14 @@ No, we do not share Personal Data or User Content except in the limited circumst Unless your Grammarly account is part of a Grammarly for Education (also known as Grammarly@edu) license, Grammarly does not knowingly collect personal information from children under the age of 13. If we determine we have collected personal information from a child younger than 13 years of age, we will take reasonable measures to remove that information from our systems. If you are under the age of 13, please do not submit any personal information through the Site, Service, and/or Software. We encourage parents and legal guardians to monitor their children’s internet usage and to help enforce this Policy by instructing their children never to provide personal information through the Site, Service, and/or Software without their permission. +Please note that in some countries the age of digital consent is older than 13. If you are in one of those countries, you must be at least that age to use the Site, Software, and/or Services. + Data storage, transfer, retention, and deletion ----------------------------------------------- ### Where is my Information stored? -Information submitted to Grammarly will be transferred to, processed, and stored in the United States. When you use the Software on your computing device, User Content you save will be stored locally on that device and synced with our servers. If you post or transfer any Information to or through our Site, Software, and/or Services, you are agreeing to such Information, including Personal Data and User Content, being hosted and accessed in the United States. Please note that the laws of the United States may be different from the privacy  laws applicable to the place where you are resident. +Information submitted to Grammarly will be transferred to, processed, and stored in the United States. When you use the Software on your computing device, User Content you save will be stored locally on that device and synced with our servers. If you post or transfer any Information to or through our Site, Software, and/or Services, you are agreeing to such Information, including Personal Data and User Content, being hosted and accessed in the United States. Please note that the laws of the United States may be different from the privacy laws applicable to the place where you are resident. ### How secure is my Information? @@ -255,7 +257,7 @@ Grammarly is committed to protecting the security of your Information and tak We use industry-standard encryption to protect your data in transit and at rest. -Once we receive your data, we protect it on our servers using a combination of technical, physical, and logical security safeguards. The security of the data stored locally in any of our Software installed on your computing device requires that you make use of the security features of your device. We recommend that you take the appropriate steps to secure all computing devices that you use in connection with our Site, Software, and Services. +Once we receive your data, we protect it on our servers using a combination of technical, physical, and logical security safeguards. The security of the data stored locally in any of our Software installed on your computing device requires that you make use of the security features of your device. We recommend that you take the appropriate steps to secure all computing devices that you use in connection with our Site, Software, and/or Services. If Grammarly learns of a security system breach, we may attempt to notify you and provide information on protective steps, if available, through the email address that you have provided to us or by posting a notice on the Site. Depending on where you live, you may have a legal right to receive such notices in writing. @@ -279,19 +281,15 @@ As Grammarly evolves, we may need to update this Policy to keep pace with ch EU-U.S. & Swiss-U.S. Privacy Shield ----------------------------------- -Grammarly 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. Grammarly 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 [http://www.privacyshield.gov](http://www.privacyshield.gov/). - -In compliance with the Privacy Shield Principles, Grammarly 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 Grammarly at the contact address below. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, dispute resolution is available through a third-party arbitrator by contacting our designated Privacy Shield independent recourse mechanism, [JAMS](https://www.jamsadr.com/eu-us-privacy-shield). In certain circumstances, the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework provide the right to invoke binding arbitration to resolve complaints not resolved by other means, as described in [Annex I](https://www.privacyshield.gov/article?id=ANNEX-I-introduction) to the Privacy Shield Principles. - -The Privacy Shield Principles describe Grammarly’s accountability for personal data that it subsequently transfers to a third-party agent. Under the Principles, Grammarly shall remain liable if third-party agents process the personal information in a manner inconsistent with the Principles, unless Grammarly proves it is not responsible for the event giving rise to the damage. - -The Federal Trade Commission has jurisdiction over Grammarly’s compliance with the Privacy Shield. +Grammarly, Inc. participates in the EU-US and Swiss-US Privacy Shield frameworks but does not rely on it. [Learn more.](https://support.grammarly.com/hc/en-us/articles/360021115751-Does-Grammarly-participate-in-Privacy-Shield-) For EEA, Swiss, and UK users![](https://static.grammarly.com/assets/files/b86f6188f2d8b41348b078c4ceea0153/accordion_arrow.svg) ------------------------------------------------------------------------------------------------------------------------------- Grammarly uses, processes, and stores Personal Data, including what is listed in the “[What Information does Grammarly collect about me?](#what-information-does-grammarly-collect-about-me)” section, as necessary to perform our contract with you, and based on our legitimate interests in order to provide the Services. We rely on your consent to process Personal Data to send promotional emails and to place cookies on your devices. In some cases, Grammarly may process Personal Data pursuant to legal obligation or to protect your vital interests or those of another person. +When Grammarly transfers the personal data of EEA, Swiss, and UK residents outside of those regions it does so via appropriate safeguards of user privacy, such as standard contractual clauses. + ### What rights do I have, and how can I exercise them? Individuals located in the European Economic Area (EEA), Switzerland, and the UK have certain rights in respect to their personal information, including the right to access, correct, or delete Personal Data we process through your use of the Site, Software, and/or Services. If you’re a user based in the EEA, Switzerland, or the UK, you can: @@ -300,24 +298,29 @@ Individuals located in the European Economic Area (EEA), Switzerland, and the UK * Have your Personal Data corrected or deleted. Some Personal Data can be updated by you: You can update your name and email address, as well as language preference, through your Grammarly account settings. If you registered for Grammarly using Google or Facebook, or if you otherwise have problems updating this information, please [submit a support ticket](https://support.grammarly.com/hc/en-us/requests/new?showForm). You can remove your Personal Data from Grammarly by [deleting your account](https://support.grammarly.com/hc/en-us/articles/115000090052-Delete-your-Grammarly-account). -* Object to us processing your Personal Data. You can ask us to stop using your Personal Data, including when we use your Personal Data to send you marketing emails. We only send marketing communications to users located in the EEA with your prior consent, and you may withdraw your consent at any time by clicking the “unsubscribe” link found within Grammarly emails and changing your contact preferences. Please note you will continue to receive transactional messages related to our Services, even if you unsubscribe from marketing emails. +* Object to us processing your Personal Data. You can ask us to stop using your Personal Data, including when we use your Personal Data to send you marketing emails. We only send marketing communications to users located in the EEA, Switzerland, and the UK with your prior consent, and you may withdraw your consent at any time by clicking the “unsubscribe” link found within Grammarly emails and changing your contact preferences. Please note that you will continue to receive transactional messages related to our Services, even if you unsubscribe from marketing emails. -* Complain to a regulator. If you’re based in the EEA and think that we haven’t complied with data protection laws, you have a right to lodge a complaint with your local supervisory authority. +* Complain to a regulator. If you’re based in the EEA, Switzerland, or the UK and think that we haven’t complied with data protection laws, you have a right to lodge a complaint with your local supervisory authority. If you have other questions or do not have a Grammarly account, contact us by [submitting a support ticket](https://support.grammarly.com/hc/en-us/requests/new?showForm). -### Who is Grammarly's EEA Representative? +### Who is Grammarly’s EEA Representative? -VeraSafe has been appointed as Grammarly’s representative in the EEA for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. VeraSafe can be contacted in matters related to the processing of Personal Data. To make such an inquiry, please contact VeraSafe using this contact form: [https://www.verasafe.com/privacy-services/contact-article-27-representative](https://www.verasafe.com/privacy-services/contact-article-27-representative). +VeraSafe has been appointed Grammarly’s representative in the EEA and the UK for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union and the UK General Data Protection Regulation, respectively. VeraSafe can be contacted in matters related to the processing of Personal Data. To make such an inquiry, please contact VeraSafe using this contact form: [https://www.verasafe.com/privacy-services/contact-article-27-representative](https://www.verasafe.com/privacy-services/contact-article-27-representative). Alternatively, VeraSafe can be contacted at: -VeraSafe Ireland Ltd -Unit 3D North Point House -North Point Business Park -New Mallow Road -Cork T23AT2P -Ireland +For the EU: VeraSafe Ireland Ltd, +Unit 3D North Point House, +North Point Business Park, +New Mallow Road, +Cork T23AT2P, +Ireland + +For the UK: VeraSafe United Kingdom Ltd., +37 Albert Embankment, +London SE1 7TL, +United Kingdom ### Data transfers @@ -336,7 +339,7 @@ This Supplemental Privacy Notice supplements the information in our Privacy Poli If you’re a California resident, California law requires us to provide you with some additional information about how we collect, use, and disclose your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)). -Throughout this Privacy Policy, we discuss in detail the specific pieces of personal information we collect from and about users, the sources of that information, and how we share it. Under the CCPA, we’re also required to provide you with the “categories” of personal information we collect and disclose for business purposes (as defined by applicable law). Those categories are: identifiers (such as name, email address, or social network account and profile data); commercial information (such as transaction data for a paid account); financial data (such as payment method or financial account information); internet or other network or device activity (such as IP address and usage information); location information (e.g., the general location where you use your device when interacting with the Site, Software or Services); sensory information (such as audio recordings if you call our customer service); inference data about you; and other information that identifies or can be reasonably associated with you. We collect these categories of personal information from different sources, as described in the section titled, “[What Information does Grammarly collect about me?](#what-information-does-grammarly-collect-about-me)” above. +Throughout this Privacy Policy, we discuss in detail the specific pieces of personal information we collect from and about users, the sources of that information, and how we share it. Under the CCPA, we’re also required to provide you with the “categories” of personal information we collect and disclose for business purposes (as defined by applicable law). Those categories are: identifiers (such as name, email address, or social network account and profile data); commercial information (such as transaction data for a paid account); financial data (such as payment method or financial account information); internet or other network or device activity (such as IP address and usage information); location information (e.g., the general location where you use your device when interacting with the Site, Software, and/or Services); sensory information (such as audio recordings if you call our customer service); inference data about you; and other information that identifies or can be reasonably associated with you. We collect these categories of personal information from different sources, as described in the section titled, “[What Information does Grammarly collect about me?](#what-information-does-grammarly-collect-about-me)” above. We and our service providers may use the categories of personal information we collect from and about you consistent with the various business and commercial purposes we discuss throughout this Privacy Policy. Please see the section titled “[How does Grammarly use my Information?](#how-does-grammarly-use-my-information)” above for more information. We share this information with the categories of third parties described in the section titled, “[Does Grammarly share my Information?](#does-grammarly-share-my-information)” @@ -374,8 +377,6 @@ The CCPA sets forth certain obligations for businesses that “sell” personal If you’re a California resident, you can ask for a list of third parties (if any) that have received your information for their direct marketing purposes during the previous calendar year. This list also contains the types of information shared. We provide this list at no cost. To make such a request, contact us at [support@grammarly.com](mailto:support%40grammarly.com). -Updated: September 18, 2020 - For Nevada users![](https://static.grammarly.com/assets/files/b86f6188f2d8b41348b078c4ceea0153/accordion_arrow.svg) ------------------------------------------------------------------------------------------------------------------- @@ -388,23 +389,23 @@ This Brazil Privacy Notice (“Notice”) applies to personal data processing ac If you’re a resident of Brazil, you may have certain rights. Brazilian law may permit you to request that we: -* confirm whether we process your data; +* Confirm whether we process your data. -* provide access to and/or a copy of certain information we hold about you; +* Provide access to and/or a copy of certain information we hold about you. -* correct incomplete, inaccurate, and outdated data; +* Correct incomplete, inaccurate, and outdated data. -* anonymize, block, or delete data that is unnecessary, excessive, or not being processed in accordance with Brazilian data protection law; +* Anonymize, block, or delete data that is unnecessary, excessive, or not being processed in accordance with Brazilian data protection law. -* port your personal data to another service or product vendor; +* Port your personal data to another service or product vendor. -* delete personal data processed with your consent, when applicable; +* Delete personal data processed with your consent, when applicable. -* provide you with information regarding the public and private entities with which we share data; +* Provide you with information regarding the public and private entities with which we share data. -* provide you with information about the possibility of withdrawing consent and the consequences of such withdrawal, where applicable; and +* Provide you with information about the possibility of withdrawing consent and the consequences of such withdrawal, where applicable. -* withdraw your consent. +* Withdraw your consent. You can exercise some of these rights by logging in and visiting the My Account page. For example, you can download a copy of your Personal Data, delete your Personal Data by deleting your account, or correct your Personal Data in your Grammarly account settings. You can also submit requests by submitting a [support ticket](https://support.grammarly.com/hc/en-us/requests/new?showForm) or emailing [support@grammarly.com](mailto:support%40grammarly.com). You will be required to verify your identity before we fulfill your request. To do so, you’ll need to log into your account or provide us with certain information regarding yourself and/or your usage of the Site, Software, and Services.