About & Plans

Privacy Policy

Last updated: 7th August 2023.

Introduction

Here at Words.Tel Ltd, we are committed to putting your privacy first, always. We firmly believe in the right to privacy, and that upholding your rights is also good for our business.

This website is not intended for children and we do not knowingly collect data relating to children.

This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

It is important that you read this privacy policy together with our Terms and Conditions so that you are fully aware of how and why we are using your data.

Our Privacy Principles

Data Minimisation

  1. We restrict the collection and processing of personal data to the minimum amount necessary, and only collect personal data which we actually need for our specified purposes.
  2. We do not duplicate or aggregate data by default.
  3. We preiodically review the data we hold, and delete anything we do not need.

Data Integrity And Confidentiality

  1. We ensure that the data collected and processed is correct, relevant, and kept up-to date.
  2. We restrict access to data to the minimum amount of people and systems necessary.
  3. We take adequate information security measures to protect the data from misuse, and its subjects from harm.
  4. These measures are both technical (systems, software, and code) as well as human (staff training, guidelines, and supervision).
  5. We do not share data with others at any point without a justified reason and user consent.

Purpose Limitation

  1. We only collect and process personal data for the purpose that it was intended for.
  2. We tell you in advance what we will use your personal data for.
  3. We do not use personal data for other purposes, either active or potential.
  4. If we plan to use personal data for a new purpose other than a legal obligation or function set out in law, we get specific consent for the new purpose.

Storage Limitation

  1. We delete data which is no longer needed, both in active use and in archives under our control.
  2. We delete unnecessary data on a regular basis.

Lawfulness, Fairness, Transparency and Notice

  1. We identify an appropriate lawful basis for our processing.
  2. We inform you about how your data is being collected, processed, and shared.
  3. We inform you what rights and choices you have over those uses.
  4. We make our privacy standards public and accountable.

Accountability, Enforcement and Redress

  1. We document our collection and processing of data.
  2. We protect data in transit to and from third parties.
  3. We prevent misuse and breaches as much as is possible.
  4. We fix problems when things go wrong.
  5. We provide redress when data is misused, leaked, or breached.
  6. We work within the relevant legal & regulatory systems.
  1. We give users and visitors choices and options over how we use your data.
  2. We require clear, specific, and informed opt-in.
  3. We inform users of changes in uses and processing.
  4. We give you access to your options and rights at any time through the Account Dashboard.
  5. We give you the right to access your data, download your data, and correct errors.
  6. We give you the ability to tell us to stop using your data, and to delete your account.

Special Categories Of Data

  1. We take extra technical and human security measures to safeguard any sensitive data which could result in the people it is about being hurt.
  2. Special category data includes information about a person's race or ethnicity, religious or philosophical beliefs, health, sex life, sexual orientation, political opinions, trade union membership, location, genetic data, and biometric data.
  1. We ensure that everything we do meets the privacy regulations of where you are.
  2. As we rollout worldwide, we will ensure that we operate to the highest common denominator privacy standards across all the legal territories we operate in.
  3. We will work co-operatively and productively with regulations, laws, and supervisory bodies.

Controller

Words.Tel Ltd is the controller, and is responsible for your personal data.

We are a company registered in England and Wales. Our company number is 14313628. Our registered address is: Forma House, 40 Bowling Green Lane, London, United Kingdom, EC1R 0NE.

We have appointed a data protection officer (DPO), who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO at this email address: dpo@words.tel.

When We Are A Data Processor

You are the controller of any personal data that you publish via the Words.tel memorable phrases service (ie phrase content and phrase contact data). Any such personal data will be held by us as your data processor.

You are the data controller in respect of any such personal data.

Why Do We Collect Personal Data?

We collect personal data so that we can operate the Word.Tel memorable phrases service (this website), our mobile apps and our Alexa smart-speaker integration.

What Data Do We Collect?

Finding and Viewing Memorable Phrases

When you use our site as an anonymous visitor, to find and visit memorable phrases, we may collect the following personal information:

  • Technical information (such as your IP address, browser type and version) will get stored in our server logs.

We do not use any tracking cookies of any kind.

Buying Subscriptions and Reserving Phrases

When you use our site to buy subscriptions, reserve and manage memorable phrases and related services, you are required to create an account with us. When you create an account with us, we will collect the following personal information:

  • Your email address is used to log into your account.
  • Your mobile phone number is used to verify your identity, as part of our anti-spam / anti-scam measures. This information will be shared with our SMS provider for your company. We use it to send you one-time passcodes (OTPs) that are used to verify your identity.
  • Your credit/debit card payment information is used to pay for your account. This information is gathered by and stored by Stripe, our billing provider. We do not store or directly process your payment data. See Stripe's privacy policy for more details.
  • Technical information (such as your IP address, browser type and version) will get stored in our server logs.

We only use cookies to enable the technical operation of our site; to allow you to login and access your Account Dashboard.

We do not use any tracking cookies of any kind.

Content Published On Reserved Phrase Landing Pages

Each memorable phrase is associated with contact data (a.k.a. 'vcard' data). This data is entered by the person who has reserved the phrase, and is stored in our datastores. That person has a contract with us, and under the terms of that contract, that person is responsible for ensuring they have the legal right to enter any personal information that they include in that contact data.

Mobile App

Our application does not collect or store personal data. If you install our application from Google Play (Android-based mobile phones), then Google Play does collect some personal data. Please see the privacy policy for Google Play Services here.

Amazon Alexa Skill

When you use our skill you have to talk to Alexa. This voice input is sent to Amazon and us where we use it to understand what our skill should do for you. This is absolutely necessary for our service to give you an appropriate answer. We never collect or share personal data with our skills. To improve our services we analyze automatically how often utterances are spoken and other analytics. This is done automatically by Amazon in the Amazon Developer Portal.

Where Do We Store Collected Data?

Your personal data is stored on our servers, which are currently hosted in the European Union. As part of the terms and conditions for using our site, you agree to this.

How We Share And Use Collected Personal Data

Service Delivery & Improvement

We may share your personal data with authorised Words.tel staff for the purposes of securing and improving our services, and to prevent fraud, loss and other harms.

All authorised Words.tel staff will be required to complete our in-house privacy training before they are granted access to your personal data.

Payments

For payment transactions, your personal data is shared with Stripe (our payment provider).

Marketing

We will get your express opt-in via the Account Dashboard before we contact you for any marketing or promotional purposes.

You may opt-out of any marketing or promotional contacts at any time via the Account Dashboard.

We do not share collected data with any third parties for marketing or advertising purposes.

How Long Will We Keep Your Personal Data For?

By law, we are required to keep basic information about our customers (including contact, identity and transaction data) for six years after they cease being customers.

Lawful Basis

By using our services, you enter into a contractual arrangement to allow us to collect the personal data that we require to operate our services.

We do not rely on legitimate interest to collect or process your personal data.

Changes To This Privacy Policy

We keep our privacy policy under regular review, and are committed to revising it to improve clarity and to strengthen your rights wherever possible.

We may change this privacy policy from time to time. When we do, all registered users will be informed by email to the email address registered to their account.

Your Duty To Inform Us Of Changes

From time to time, we will ask you to re-verify your personal details. We need to do this to ensure that the personal data we have remains correct.

Failure to do so could result in us terminating the services that we provide you.