Who We Are and What This Policy Covers

This Privacy Policy applies to information that we collect about you when you use sutra.co or the Sutra mobile application.

Information We Collect

We only collect information about you if we have a reason to do so — for example, to provide our Services, to communicate with you, or to make our Services better. We collect this information from three sources: if and when you provide information to us, automatically through operating our Services, and from outside sources. Let’s go over the information that we collect.

Information You Provide to Us

It’s probably no surprise that we collect information that you provide to us directly. Here are some examples:

• Basic account information: We ask for basic information from you in order to set up your account. For example, we require individuals who sign up for a Sutra.co account to provide an email address and password, along with a username and name — and that’s it. You may provide us with more information — like your address and other information you want to share — but we don’t require that information to create a Sutra.co account.
• Public profile information: If you have an account with us, we collect the information that you provide for your public profile. For example, if you have a Sutra.co account, your username is part of that public profile, along with any other information you put into your public profile, like a photo or an “About Me” description. Your public profile information is just that — public — so please keep that in mind when deciding what information you would like to include.
• Payment and contact information: If you buy something from us or earn revenue through our platform, we’ll collect information to process those payments and contact you. If you buy something from us — such as a subscription to a Sutra.co plan — or if you pay fees to a person or business through their Sutra.co offering, you’ll provide additional personal and payment information like your name, credit card information, and contact information. We also keep a record of the purchases you’ve made. If you use our e-commerce services, you’ll have to create a Sutra.co account. You may also provide us with financial details to set up a payments integration, like the email address for your Stripe or PayPal account.
• Content information: You might provide us with information about you in draft and published content (a blog post or comment that includes biographic information about you, or any media or files you upload).
• Communications with us (hi there!): You may also provide us with information when you respond to surveys, communicate with our support team about a support question, post a question in our public forums, or sign up for our newsletter. When you communicate with us via form, email, phone, Sutra.co comment, or otherwise, we store a copy of our communications (including any call recordings as permitted by applicable law).
• Job applicant information: If you apply for a job with us — awesome! You may provide us with information like your name, contact information, resume or CV, and work authorization verification as part of the application process.

Information We Collect Automatically

We also collect some information automatically:

• Log information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, including the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Services — for example, when you create or make changes to your website on Sutra.co.
• Usage information: We collect information about your usage of our Services. For example, we collect information about the actions that circle managers and users perform on Sutra — in other words, who did what and when (e.g., [Sutra.co username] deleted “[title of post]” at [time/date]). We also collect information about what happens when you use our Services (e.g., page views, support document searches, features enabled for your Sutra offerings, along with information about your device (e.g., screen size, name of cellular network, and mobile device manufacturer). We use this information to, for example, provide our Services to you, get insights on how people use our Services so we can make our Services better, and understand and make predictions about user retention.
• Location information: We may determine the approximate location of your device from your IP address. We collect and use this information to, for example, calculate how many people visit our Services from certain geographic regions. We may also collect information about your precise location via our mobile apps (like when you post a photograph with location information) if you allow us to do so through your mobile device operating system’s permissions.
• Stored information: We may access information stored on your mobile device via our mobile apps. We access this stored information through your device operating system’s permissions. For example, if you give us permission to access the photographs on your mobile device’s camera roll, our Services may access the photos stored on your device when you upload a really amazing photograph of the sunrise to your website.
• Information from cookies & other technologies: 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. Pixel tags (also called web beacons) are small blocks of code placed on websites and emails. Sutra uses cookies and other technologies like pixel tags to help us identify and track visitors, usage, and access preferences for our Services, as well as track and understand email campaign effectiveness and to deliver targeted ads related to our service and offerings to you on third party websites such as Facebook and LinkedIn.

How and Why We Use Information

Purposes for Using Information

We use information about you for the purposes listed below:

• To provide our Services. For example, to set up and maintain your account, host your website, backup and restore your website, provide customer service, process payments and orders, and verify user information.
• To ensure quality, maintain safety, and improve our Services. For example, by providing automatic upgrades and new versions of our Services. Or, for example, by monitoring and analyzing how users interact with our Services so we can create new features that we think our users will enjoy and that will help them create and manage websites more efficiently or make our Services easier to use.
• To market our Services and measure, gauge, and improve the effectiveness of our marketing. For example, by targeting our marketing messages to groups of our users (like those who have a particular plan with us or have been users for a certain length of time), advertising our Services, analyzing the results of our marketing campaigns (like how many people purchased a paid plan after receiving a marketing message), and understanding and forecasting user retention.
• To protect our Services, our users, and the public. For example, by detecting security incidents; detecting and protecting against malicious, deceptive, fraudulent, or illegal activity; fighting spam; complying with our legal obligations; and protecting the rights and property of Sutra and others, which may result in us, for example, declining a transaction or terminating Services.
• To fix problems with our Services. For example, by monitoring, debugging, repairing, and preventing issues.
• To customize the user experience. For example, to personalize your experience by serving you relevant notifications and advertisements for our Services.
• To communicate with you. For example, by emailing you to ask for your feedback, share tips for getting the most out of our products, or keep you up to date on Sutra; or emailing you to share offers and promotions that we think will be of interest to you. If you don’t want to hear from us, you can opt out of marketing communications at any time. (If you opt out, we’ll still send you important updates relating to your account.)
• To recruit and hire new people for the Sutra team. For example, by evaluating job applicants and communicating with them.

Legal Bases for Collecting and Using Information

A note here for those in the European Union about our legal grounds for processing information about you under EU data protection laws, which is that our use of your information is based on the grounds that: (1) The use is necessary in order to fulfill our commitments to you under the applicable terms of service or other agreements with you or is necessary to administer your account — for example, in order to enable access to our website on your device or charge you for a paid plan; or (2) The use is necessary for compliance with a legal obligation; or (3) The use is necessary in order to protect your vital interests or those of another person; or (4) We have a legitimate interest in using your information — for example, to provide and update our Services; to improve our Services so that we can offer you an even better user experience; to safeguard our Services; to communicate with you; to measure, gauge, and improve the effectiveness of our advertising; and to understand our user retention and attrition; to monitor and prevent any problems with our Services; and to personalize your experience; or (5) You have given us your consent — for example before we place certain cookies on your device and access and analyze them later on, as described in our Cookies Policy.

Sharing Information

How We Share Information

We share information about you in limited circumstances, and with appropriate safeguards on your privacy. These are spelled out below, as well as in the section called Ads and Analytics Services Provided by Others:

• Subsidiaries and independent contractors: We may disclose information about you to our subsidiaries and independent contractors who need the information to help us provide our Services or process the information on our behalf. We require our subsidiaries and independent contractors to follow this Privacy Policy for any personal information that we share with them.
• Third-party vendors: We may share information about you with third-party vendors who need the information in order to provide their services to us, or to provide their services to you or your site. This includes vendors that help us provide our Services to you (like Stripe, which powers Sutra payments, payment providers that process your credit and debit card information, payment providers you use for your own ecommerce operations, fraud prevention services that allow us to analyze fraudulent payment transactions, cloud storage services, postal and email delivery services that help us stay in touch with you, customer chat and email support services that help us communicate with you, registrars, registries, data escrow services that allow us to provide domain registration services, and your hosting provider if your site is not hosted by Sutra); those that assist us with our marketing efforts (e.g., by providing tools for identifying a specific marketing target group or improving our marketing campaigns, and by placing ads to market our services); those that help us understand and enhance our Services (like analytics providers); those that make tools to help us run our operations (like programs that help us with task management, scheduling, word processing, email and other communications, and collaboration among our teams); other third-party tools that help us manage operations; and companies that make products available on our websites (like third party integrations), who may need information about you in order to, for example, provide technical or other support services to you. We require vendors to agree to privacy commitments in order to share information with them.
• Legal and regulatory requirements: We may disclose information about you in response to a subpoena, court order, or other governmental request. Additionally, if you have a domain registered with Sutra.co, we may share your information to comply with the Internet Corporation for Assigned Names and Numbers' (ICANN) regulations, rules, or policies. For example, your information relating to your domain registration may be available in the WHOIS database, or we may be required to share your information with ICANN-approved Dispute Resolution Service Providers.
• To protect rights, property, and others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of Sutra, third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay.
• With your consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties when you authorize us to do so.
• Aggregated or de-identified information: We may share information that has been aggregated or de-identified, so that it can no longer reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services, or share a hashed version of your email address to facilitate customized ad campaigns on other platforms.
• Published support requests: If you send us a request for assistance (for example, via a support email or one of our other feedback mechanisms), we reserve the right to publish that request in order to clarify or respond to your request, or to help us support other users.

We have a long-standing policy that we do not sell our users' data. We aren't a data broker, we don't sell your personal information to data brokers, and we don't sell your information to other companies that want to spam you with marketing emails.

Information Shared Publicly

Information that you choose to make public is — you guessed it — disclosed publicly. That means information like your public profile, posts, and other content that you make public on your circles are all available to others! For example, the photo that you upload to your public profile, or a default image if you haven’t uploaded one, is your profile picture. Your profile picture, along with other public profile information, displays alongside the public circles that you are a part of on Sutra.co. Your profile picture and public profile information may also display with your comments on public circles. Public information may also be indexed by search engines or used by third parties. Please keep all of this in mind when deciding what you would like to share publicly.

How Long We Keep Information

We generally discard information about you when it’s no longer needed for the purposes for which we collect and use it — described in the section above on How and Why We Use Information — and we’re not legally required to keep it. For example, we keep web server logs that record information about a visitor to one of Sutra’s websites, like the visitor’s IP address, browser type, and operating system, for approximately 30 days. We retain the logs for this period of time in order to, among other things, analyze traffic to Sutra’s websites and investigate issues if something goes wrong on one of our websites. As another example, when you delete a circle on Sutra, it stays in your Trash folder for thirty days in case you change your mind and would like to restore that content, because starting from scratch is no fun. After the thirty days are up, the deleted content may remain on our backups and caches until purged.

Security

While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so. We monitor our Services for potential vulnerabilities and attacks.

Choices

You have several choices available when it comes to information about you:

• Limit the information that you provide: If you have an account with us, you can choose not to provide the optional account information, profile information, and transaction and billing information. Please keep in mind that if you do not provide this information, certain features of our Services may not be accessible.
• Limit access to information on your mobile device: Your mobile device operating system should provide you with the option to discontinue our ability to collect stored information or location information via our mobile apps. If you choose to limit this, you may not be able to use certain features, like geotagging for photographs.
• Opt out of marketing communications: You may opt out of receiving promotional communications from us. Just follow the instructions in those communications or let us know. If you opt out of promotional communications, we may still send you other communications, like those about your account and legal notices.
• Set your browser to reject cookies: At this time, Sutra does not respond to “do not track” signals across all of our Services. However, you can usually choose to set your browser to remove or reject browser cookies before using Sutra’s websites, with the drawback that certain features of Sutra’s websites may not function properly without the aid of cookies.
• Close your account: While we’d be very sad to see you go, you can close your account if you no longer want to use our Services. Please keep in mind that we may continue to retain your information after closing your account, as described in How Long We Keep Information above — for example, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests, or reasonably needed for our legitimate business interests.

Your Rights

If you are located in certain parts of the world, including California and countries that fall under the scope of the European General Data Protection Regulation (aka the “GDPR”), you may have certain rights regarding your personal information, like the right to request access to or deletion of your data.

European General Data Protection Regulation (GDPR)

If you are located in a country that falls under the scope of the GDPR, data protection laws give you certain rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:

• Request access to your personal data;
• Request correction or deletion of your personal data;
• Object to our use and processing of your personal data;
• Request that we limit our use and processing of your personal data; and
• Request portability of your personal data.

You also have the right to make a complaint to a government supervisory authority.

California Consumer Privacy Act (CCPA)

The California Consumer Privacy Act (“CCPA”) requires us to provide California residents with some additional information about the categories of personal information we collect and share, where we get that personal information, and how and why we use it. The CCPA also requires us to provide a list of the “categories” of personal information we collect, as that term is defined in the law, so, here it is. In the last 12 months, we collected the following categories of personal information from California residents, depending on the Services used:

• Identifiers (like your name, contact information, and device and online identifiers);
• Commercial information (your billing information and purchase history, for example);
• Characteristics protected by law (for example, you might provide your gender as part of a research survey for us);
• Internet or other electronic network activity information (such as your usage of our Services, like the actions you take as an administrator of a Sutra.co circle);
• Geolocation data (such as your location based on your IP address);
• Audio, electronic, visual or similar information (such as your profile picture, if you uploaded one);
• Professional or employment-related information (for example, information you provide in a job application); and
• Inferences we make (such as likelihood of retention or attrition).

You can find more information about what we collect and sources of that information in the Information We Collect section above. We collect personal information for the business and commercial purposes described in the How and Why We Use Information section. And we share this information with the categories of third parties described in the Sharing Information section. If you are a California resident, you have additional rights under the CCPA, subject to any exemptions provided by the law, including the right to:

• Request to know the categories of personal information we collect, the categories of business or commercial purpose for collecting and using it, the categories of sources from which the information came, the categories of third parties we share it with, and the specific pieces of information we collect about you;
• Request deletion of personal information we collect or maintain;
• Opt out of any sale of personal information; and
• Not receive discriminatory treatment for exercising your rights under the CCPA.

Contacting Us About These Rights

You can usually access, correct, or delete your personal data using your account settings and tools that we offer, but if you aren’t able to or you’d like to contact us about one of the other rights, scroll down to How to Reach Us to, well, find out how to reach us. When you contact us about one of your rights under this section, we’ll need to verify that you are the right person before we disclose or delete anything. For example, if you are a user, we will need you to contact us from the email address associated with your account. You can also designate an authorized agent to make a request on your behalf by giving us written authorization. We may still require you to verify your identity with us.

How to Reach Us

If you have a question about this Privacy Policy, or you would like to contact us about any of the rights mentioned in the Your Rights section above, please contact us via email.

Other Things You Should Know (Keep Reading!)

Transferring Information

Because Sutra’s Services are offered worldwide, the information about you that we process when you use the Services in the EU may be used, stored, and/or accessed by individuals operating outside the European Economic Area (EEA) who work for us, or third-party data processors. This is required for the purposes listed in the How and Why We Use Information section above. When providing information about you to entities outside the EEA, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this Privacy Policy as required by applicable law. These measures include entering into European Commission approved standard contractual arrangements with entities based in countries outside the EEA.

Privacy Policy Changes

Although most changes are likely to be minor, Sutra may change its Privacy Policy from time to time. Sutra encourages visitors to frequently check this page for any changes to its Privacy Policy. If we make changes, we may, in some cases, provide additional notice (like adding a statement to our homepage or the Sutra Blog or sending you a notification through email or your Sutra homepage. Your further use of the Services after a change to our Privacy Policy will be subject to the updated policy.

This privacy policy has been adapted from the Privacy Policy of Automattic, which is available under a Creative Commons Attribution-ShareAlike license.

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