# Privacy Policy

*Last Updated and Effective as of: June 16, 2023*


Your use of our Services is governed by our Terms of Use. OUR TERMS OF USE CONTAIN DISCLAIMERS OF WARRANTIES AND LIABILITY, A CHOICE OF LAW PROVISION AND A CLASS ACTION WAIVER. THESE PROVISIONS AFFECT YOUR RIGHTS ABOUT HOW TO RESOLVE ANY DISPUTE WITH MERRIAM-WEBSTER, INCORPORATED ("MERRIAM") INCLUDING UNDER THIS PRIVACY POLICY. PLEASE REVIEW. YOUR USE OF THE SERVICES IS ACCEPTANCE OF THIS PRIVACY POLICY AND OUR TERMS OF USE.

## Table of Contents

- Introduction
- Cookie Notice & Cookie Policy
- COPPA Compliance
- Links to Third-Party Websites or Apps
- How We Collect & Use Your Personal Information
- Use of Our Services - Information Collected Automatically & Other Information
- Your Rights & Choices
- How we respond to “Do Not Track” signals
- Children's Privacy
- The Puku Privacy Notice
- Security of Your Information
- Data Storage and Retention
- Consent to Processing and Transfer of Information about You
- Privacy Notice for California Residents
- EU Data Subject Rights
- EU Representative and Data Protection Officer
- Copyright
- Business Transfers
- Acceptance of Privacy Policy Terms and Conditions
- Questions, Comments or Complaints

## Introduction

Your privacy is important to us. We understand that you are aware of and care about your own personal privacy interests, and we take that seriously. This Privacy Policy sets forth your privacy rights and applies to personal information we may collect through our websites, mobile applications or online services that link to this Privacy Policy (our “Services”); how we will use, disclose and protect this information; and how you can opt out of some of our uses and disclosures of your information. This Privacy Policy does not apply to information that we collect in other ways, such as over the phone, by mail or in person, except where state otherwise or as required by law.

Your decision to use the Services and provide your personal data is voluntary. We indicate on our online, mobile, and other registration forms what types of personal data are requested. You may choose not to submit requested information online, or may choose to restrict the use of cookies (see our Cookie Policy and Your Rights & Choices below for more information), but that may limit the services Merriam-Webster is able to provide to you.

The Services are a network of general audience sites, and are not targeted to, and do not knowingly collect personal data from, minors under 16 years of age. We request that these individuals do not provide personal data through the Services. Please see COPPA Compliance below for more information.

We recognize that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Policy as we undertake new personal data practices or adopt new privacy policies.

## Cookie Notice & Cookie Policy

Our Services use cookies, which are small data files that are placed on the hard drive of your computer, tablet, smartphone, or other devices when you visit a website and other tracking tools on our website and digital platforms. When we refer to cookies, this includes other similar technologies such as pixel tags, or web beacons. For more information about these tools and your choices, please refer to our Cookie Policy, Use of Our Services - Information Collected Automatically & Other Information and Your Rights & Choices below.

## COPPA Compliance

In accordance with the Federal Children's Online Privacy Protection Act of 1998 (COPPA), we will never knowingly solicit, nor will we accept, personally identifiable information from users known to be under thirteen (13) years of age without the consent of their educational institution or the child's parent or guardian. We do, however, use COPPA-compliant, third party services that automatically collect or share certain information and usage data with us to support our internal operations as described under How we use your information and Puku third-party service providers below.

If an educational institution with students that are under thirteen (13) years of age uses our Merriam-Webster Unabridged Service, the educational institution also may provide us with personally identifiable information about its students. We use student information to provide this Service to the educational institution and its students, consistent with our Merriam-Webster Unabridged Privacy Notice.

If you believe that we have collected personal information from someone under the age of 13, please contact us at: privacy@m-w.com.

## How We Collect & Use Your Personal Information

Merriam-Webster protects the identity of visitors to the Services by limiting the collection of personally identifiable information. Personal information provided by you to us will not be posted or published by us for viewing by third parties. In most cases, the information you provide is limited to first name, last name, email address, city, state, age, and phone number. We use this information to provide you with goods and services, including subscription services, publications, and the like. We do not sell personal information to anyone and only share it with third parties who are facilitating the delivery of our Services as provided in this Privacy Policy. You can enjoy many of our Services and their unique features without giving us your personal information.

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#### Subscriptions, User Login Registrations, and Mobile App Services

When you subscribe to or register for a Service or download a mobile app service, we collect information about you that may include (but not be limited to) your name, email address, city, state, and age. We may also collect a personal mailing address and a phone number. Users may edit their information at any time to change, add or remove certain personal information. We process your personal information to administer and manage your subscription or other-like Service, deliver user benefits to you, inform you of prizes and other benefits or opportunities associated with your Service and respond to your information requests. We also may use this information for legitimate business purposes that help us analyze the demographics of our subscribers and understand our users' needs and interests to better tailor our products and services to meet users' needs and deliver additional services to our users. See also The Puku Privacy Notice below.

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#### Promotions, sweepstakes, contests, and other special features

For specific promotions, sweepstakes and contests sponsored or co-sponsored by us, and to access certain features, such as the ‘save your words' feature, we collect information voluntarily submitted by you to us to deliver the requested feature that may include (but not be limited to) your name, email address, city, state, and age. You may edit this information at any time to change, add or remove it from our Services.

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#### Newsletters

To register for or subscribe to receive a Merriam-Webster newsletter, you must provide us with your email address. We use Autopilot by Ortto and Salesforce, our third-party service providers, to deliver requested newsletters, such as Word of the Day, to you on our behalf. When you open an email that contains a newsletter, we gather certain statistics, such as number of emails opened and clicks within a newsletter, using industry-standard technologies, including clear gifs, helping us monitor and improve our newsletters. For more information, please see Autopilot's Privacy Policy and Salesforce's Privacy Statement. Except for Autopilot and Salesforce, we do not share your voluntarily provided email address with any third party.

You may manage your Merriam-Webster newsletter subscriptions by subscribing or unsubscribing at any time using the link included in the related email. Please note that if you have set your browser to block cookies, this may have an impact on your ability to unsubscribe. If you have any difficulties managing your email or other communication preferences with Merriam-Webster, please contact us at privacy@m-w.com.

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#### Communications from our approved, third-party partners and us

If you choose to provide us with your email address or other personal information, you also may receive the following types of emails from us:

- Emails related to subscription-maintenance activities;
- Emails highlighting new features, content, and usage tips for the Services; and
- Special offers and other marketing messages
- From us for additional Merriam-Webster and Encyclopædia Britannica (Merriam-Webster's parent company) products and services, and
- From our approved, third-party partners, if you "opt in" or give us your permission to send them.


When you provide us with your personal information, you can let us know that you do not wish to receive special offers from Merriam-Webster or its third-party partners. Also, each special offer will have information available to allow you to "opt out" if you no longer wish to receive special offers. We may use Autopilot or Salesforce to deliver emails to you on our behalf. When you open an email from us, we may gather certain statistics, such as number of emails opened and clicks within the email, using industry-standard technologies, including clear gifs, helping us monitor and improve our Services. For more information, please see Autopilot's Privacy Policy and Salesforce's Privacy Statement. Except for Autopilot and Salesforce, we do not share your voluntarily provided email address with any third party.

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#### Surveys

We may occasionally conduct online surveys. All surveys are voluntary, and you may decline to participate.

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#### Purposes for processing (using) personal data provided directly by you

As explained above, Merriam-Webster processes your data to provide you with the products and services you have requested or purchased from us, including special features, subscriptions, newsletters, and other content. Sometimes we use third-party providers or work with co-sponsors to facilitate the delivery of the services or special features described above, and these third-party providers may be supplied with or have access to your personal information for the sole purpose of providing services to you on our behalf, such as Word of the Day or delivering the special feature. Also, we may disclose your personal information in special legal circumstances. For instance, such information may be used where it is necessary to protect our copyright or intellectual property rights, or if the law requires us to do so.

To carry out these activities, Merriam-Webster may rely on many legal bases to process your personal data, including where:

- necessary to perform the contractual obligations in our Terms of Service and to provide the requested Services to you;
- necessary for a third party's, or our, legitimate interests;
- necessary to comply with a legal obligation or to defend legal claims;
- necessary to protect the public interest or vital interest of others;
- you have expressly made information public; or
- you have consented to the processing, which may be revoked at any time.

We also use your data for legitimate business purposes that enable us to refine our products and services to better tailor them to your needs, communicate with you about other products and services offered by Merriam-Webster, secure your personal data, or comply with regulatory and legal obligations.

You can update your personal information and change your marketing preferences at any time by sending an email to privacy@m-w.com.

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#### Payment card information

You may choose to purchase goods or services from Merriam-Webster using a payment card. Typically, payment card information is provided directly by users, via the Services, into the PCI/DSS-compliant payment processing service to which the Merriam-Webster subscribes, and Merriam-Webster does not, itself, process or store your card information. We strongly encourage you not to submit this information by email. When Merriam-Webster employees receive payment card information from users by email, fax, phone, or mail, it is entered as instructed and then deleted or destroyed.


## Links to Third-Party Websites or Apps

You may find advertising or other content on the Services that link to websites, apps, products, or services belonging to our third-party partners, suppliers, advertisers, sponsors, licensors and other third parties, or offer content, functionality, or apps developed and maintained by third parties not controlled by Merriam-Webster. These third-party linked websites, apps, products, services and advertisements may use automated means to collect information about you and your use of these features. Merriam-Webster provides these links solely as a convenience to you. Merriam-Webster does not control and is not responsible for the practices employed by websites, apps, products, services, or advertisements linked to or from the Services. Therefore, Merriam-Webster disclaims liability for any information, materials, products or services offered at any third-party website linked to or from the Services. Such third-party websites, apps, products, or services may have terms and conditions (as well as privacy policies) that are different from those set forth here.

This Privacy Policy does not apply to the activities of Merriam-Webster’s third-party sponsors, advertisers, and other partners that may collect your user information while you access or use such third party’s services in connection with your use of the Services (e.g., social media and sharing services). Merriam-Webster is not responsible for the privacy practices or content of these third-party linked services once you leave the Services, click an advertisement or sign up for a special offer. We encourage you to read and review the privacy statement of each third-party service that you may choose to use, and we urge all users of our Services to follow safe internet practices: *Once you leave the Merriam-Webster Services, do not supply personal data to these third-party linked services unless you have verified their security and privacy policies.*

## Use of Our Services - Information Collected Automatically & Other Information

Like other commercial websites, Merriam-Webster and our authorized partners use cookies (small files transferred from a website to its users' hard drives or browsers for record-keeping purposes), including strictly necessary, performance, functional, and personalization cookies, software logs, and other similar information gathering technologies throughout our Services to collect certain information automatically and store it in log files to monitor the use of the Services, gather non-personal informational about our users, and for a variety of other legitimate business interests and purposes. This information may include (but is not limited to) internet protocol (IP) addresses, mobile device identifiers, the region or general location where your computer or device is accessing the internet, browser type (for example, Firefox or Internet Explorer), operating system (for instance, Windows or Macintosh), your internet provider (for example, Comcast), and other usage information about your use of our Services, including a history of the pages you view.

We may work with DigiTrust to set a cookie (DigiTrust Cookie) in your browser to enable us to collect web-viewing data that includes visits to a Merriam-Webster service and other non-affiliated websites over time.

We also may work with third-party analytics providers, ad networks, and advertisers in order to track your online activities over time and across third party websites, apps and devices, by obtaining information through the automated means (including cookies) mentioned above. The information received by us through these automated methods may include (but is not limited to) information about your activities across unrelated websites and mobile applications, information about the possible relationships between different browsers and devices, information that we receive from our third-party service providers, demographic data, information from social media providers, and information about your interests. We may add this information to the data we have already collected through our Services.

Please refer to our Cookie Policy and Your Rights & Choices below for more information.

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#### Purposes for processing (using) information collected automatically & other information

We may use and disclose information collected automatically through our Services and other information for any purpose, except if it is considered personal data under applicable law. If we combine information collected automatically with the personal data provided by you, we treat the combined information as personal data and use it only in the manner described above. See Purposes for processing (using) personal data provided directly by you above.

On the basis of legitimate interests, we use this information (or combined information) to help us design our Services to better suit our users' needs, to provide and improve our Services, for identification verification, to provide support, for statistical and market research purposes to tailor content to usage patterns, for analytic purposes through tools such as Google Analytics, and to personalize your experience by presenting content, products, and offers tailored to you. This information, along with other information we gather when you login, also can be used to understand use across websites and devices to further improve our Services and show you advertisements on the Services or other third-party websites and apps that may be tailored to your individual interests and enable us to offer the Services to you free of charge. We also may use your IP address to help diagnose problems with our servers and to administer our Services, analyze trends, track user movements and gather broad demographic information that assists us in identifying user preferences.

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#### Relevant content and recommendations

We use Google Analytics Demographics and Interest reporting, which is a Google Analytics Advertiser feature that collects and stores standard internet log and user information on our behalf and gathers information about what pages you visit, how long you are on our sites, how you got here, and what you click on during your visit. This Google Analytics data is not tied to personal information, so this information cannot be used to identify who you are. For our legitimate business interests, we use the data provided by Google Analytics Demographics and Interest reports to develop our services and content around our user demographics, interests, and behavior on our Services.

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#### Advertising and interest-based, behavioral advertising

To provide you with premium content, free-of-charge, Merriam works with third-party service providers to display advertising, including interest-based or behavioral advertising, on the Services.

We participate in the IAB Transparency & Consent Framework and comply with its Specifications and Policies. Our Consent Management Platform (CMP) is OneTrust LLC with the CMP identification number 28.

In addition, some of the pages on the Services may be affiliated with CMI Marketing, Inc., d/b/a Raptive ("Raptive") for the purposes of placing advertising on the Services, and Raptive will collect and use certain data for advertising purposes. Raptive's CMP is LiveRamp with the CMP identification number 3. To learn more about Raptive's data usage and your related rights, click here: Raptive's Advertising Privacy Statement.

We also may rely on third-party service providers to do things like: take user-level information, anonymize it through hashing (a hashed email address might look something like this:

**e820bb4aba5ad74c5a6ff1aca16641f6**) and match it against other anonymized, people-based identifiers – doing this helps us serve you personalized, relevant advertisements. Specifically, when you use our ad-supported Services, we may share information that we may collect from you, including your email (in hashed form), IP address or information about your browser or operating system, with our third-party service providers, Index Exchange (IX) and LiveRamp Inc. and its group companies (‘LiveRamp’). IX and LiveRamp may use our first-party cookie on your browser to match your shared information to their marketing databases to provide back a pseudonymous privacy-centric identifier for our use in real time bidding in digital advertising. These third parties may in turn link further demographic or interest-based information to your browser. You have the choice to opt out of the use of your data by third-party service providers for this purpose at any time. Please find more information about opting out below.Since our Services are provided to you free of charge, we have a legitimate business interest in monetizing the delivery of our premium content to you on the Services through the display of advertising. To the extent required by applicable law or contractual obligations, we obtain your consent before using your information for interest-based, behavioral advertising – please see our Cookie Policy.

Merriam-Webster does not provide any personal information to third-party ad networks or advertisers about visitors to the Services, however these third parties may use automated means, such as cookies, to collect information, which may include your IP address, directly from you when you use our Services. Our Privacy Policy does not cover the use of information that they may have collected from you on the Services or other websites or the use of data that you provide directly to such third-party partners; that usage is governed by the third-party partner's privacy policy. For information about opting out of interest-based, behavioral advertising, please see our Cookie Policy and Your Rights and Choices below.

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#### Mobile device identifiers

When you use a mobile device like a tablet or cell phone to access our Services, we may access and monitor one or more "device identifiers," which are small data files associated with your mobile device that uniquely identify your mobile device. A device identifier may deliver information to a third-party partner or us about how you browse and use the Services. Some features of the services may not function properly if use or availability of device identifiers is impaired or disabled. For more information, please see our Cookie Policy and Your Rights and Choices below

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#### Anonymous aggregated data

We may provide anonymous aggregated data to other companies we do business with for statistical purposes.


## Your Rights & Choices

Please read our Cookie Policy, which more fully describes the cookies, pixel tags, web beacons and other similar technologies used on the Merriam-Webster Services and includes a “Cookie Settings” button that explains each cookie category and enables you to opt-out of certain cookies, such as personalization cookies, which are related to interest-based advertising.

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#### Browser controls

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Services. For more information about cookies, please visit http://www.allaboutcookies.org/. Please note that limiting third-party cookies via your browser controls does not prevent our first-party cookies from being set in this way.

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- To manage or delete browser cookies, please see your browser's privacy settings.
- To manage or delete Flash cookies, please use the Adobe Flash Player Settings Manager here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html


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#### Google Analytics Ad Settings

You can opt-out of this Google Analytics Advertiser feature using the Ads Settings located at https://www.google.com/settings/ads. You also can use the Google Analytics Opt-Out Browser Add-on to disable tracking by Google Analytics. To delete these cookies, please see your browser's privacy settings or follow the above instructions.


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#### IX & LiveRamp

You can control the use of your personal data by IX and LiveRamp as follows:

- IX's options for users to opt-out of personalized advertising can be found on the IX website at this link: https://www.indexexchange.com/privacy/. IX may continue to add opt-out options.
- To opt out of LiveRamp's use of your personal data, please head here: https://liveramp.com/opt_out/.


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#### Interest-based, behavioral advertising opt-out choices

You can exercise choice about the collection of data for interest-based, behavioral advertising, including by DigiTrust, by visiting the Digital Advertising Alliance's choice page and opting out from DigiTrust. Opting out from DigiTrust will stop DigiTrust Partners from using the DigiTrust identifier. Through the DAA choice page, you may make other choices for companies that participate in the DAA, some of which are DigiTrust Partners.

Some advertising networks require that we specifically list their opt-out links below. When you opt-out of a network, you may receive an "opt-out" cookie so that the network will know not to assign you new cookies in the future. Please know:

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**If you opt-out of interest-based, behavioral advertising you will continue to receive ads on our free, ad-supported Services, but not behaviorally targeted ads**. Also, if you opt out of Merriam-Webster's practices, you may continue to receive interest-based, behavioral advertising through other companies.- If you erase your browser's cookies, you may need to perform this process again.
- If you would like to learn more about interest-based, behavioral advertising or to opt-out of having this information used by companies that are part of the Network Advertising Initiative to deliver targeted ads, please visit http://www.networkadvertising.org. Many of the same companies are members of the Self-Regulatory Program for Online Behavioral Advertising. You can learn more and opt-out of receiving interest-based, behavioral ads from them at http://www.aboutads.info/choices.
- If you would like to avoid all advertisements on our Services, sign up for a paid-for subscription service or upgrade your mobile application.

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You also can opt-out of interest-based, behavioral advertisements on the Services by Merriam-Webster (and other companies employing online advertising) via the following options:


## How we respond to “Do Not Track” signals

When you visit a website in any browser, you automatically share information with that website, such as your IP address, and other standard PC information. If the website contains content provided by a third-party website (for example a web measurement tool such as a web beacon or scripts), some information about you may be automatically sent to the content provider. This type of arrangement has several benefits, such as allowing you to access third-party content from our Services conveniently. Some internet browsers or other tools include “Do Not Track” (DNT) features that, when turned on, send a signal to websites you visit indicating you do not wish to be tracked across websites over time. However, since no technology standard for DNT signals has been developed or adopted to date, Merriam-Webster does not currently respond to DNT signals.

## Children's Privacy

**A note to minors:** If you are under the age of 16, please get permission from your parent/legal guardian or school before using the Services, including Puku, or sending any email to us. If we discover that we have collected any personally identifiable information from a child under the age of 16 without parental consent, we will suspend the associated account and/or remove that information from our database as soon as possible.

Merriam-Webster does not knowingly collect or solicit personally identifiable information from or about children under 16, except as permitted by law or otherwise provided herein. If we discover we have received any information from a child under 16 in violation of this policy, we will delete that information immediately. If you believe Merriam-Webster has any information from or about anyone under 16, please email us at privacy@m-w.com.

## Puku Privacy Notice

Puku is owned and operated by Merriam-Webster, Incorporated. By accessing and using Puku, you confirm that you accept Puku's and our collection, use, and sharing of your data in the manner provided herein. We will not collect, use, or share your information with anyone except as described in this Puku Privacy Notice.

Puku can be downloaded, and the free content can be used without requiring a user to subscribe or provide any personal data beyond the usage and analytics data that is necessary to support our internal operations.

We may send alerts or notifications to your device as part of the usage and features of Puku. These may include prompts or reminders that notify you on your device of details about your child's use of Puku. Also, your child may use Puku to share word lists created by them with others, including friends and teachers, but this information is not collected or used by us. Puku requests that your child creates a unique username and provide their age, however, this information is stored locally in Puku on your device and is not used, collected, accessed, or stored by us.

#### Children's Online Privacy Protection

To respect your and your child's privacy, Puku collects the minimum amount of information necessary to operate and provide Puku's services to you and your child. In addition, we have taken steps to ensure that Puku complies with the Children's Online Privacy Protection Act (COPPA). For example, we do not use Puku to collect personal information (as broadly defined by COPPA) without a parent or guardian's consent or for purposes of online behavioral advertising. We do, however, use COPPA-compliant, third party services that automatically collect or share certain information and usage data with us to support our internal operations as described under How we use your information and Puku third-party service providers below.

If you believe that we have collected personal information from someone under the age of 13, please contact us at: privacy@m-w.com.

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#### Information collection and use

Any information you provide or we collect automatically through yours or your child's use of Puku is used to enable us to deliver Puku to you and your child as described, and as otherwise provided below. We never rent or sell yours or your child's information.

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#### Information you provide about yourself or your child.

We receive and store personal information a parent or guardian knowingly provides to us. This information may include a parent or guardian's email address and other personal information. You can choose not to provide us with certain personal information, but then you and your child may not be able to take advantage of some of Puku's subscription features.

*Parent or guardian email address and payment card information*. We may ask for and collect a parent or guardian's email address when you provide it to us. It is always your choice to provide us with this information, and this information will be retained by us and used as described in this Puku Privacy Notice and under Purposes for processing (using) personal data provided directly by you and Communications from our approved, third-party partners and us above and Security of Your Information below. If a parent or guardian has given their email address to us, they may receive information about their child's use of Puku or information from us about related Merriam-Webster products and services that we believe they might also enjoy. You can stop receiving emails from us anytime with just one click. At the bottom of every email we send we offer a link to unsubscribe. You can also contact us at privacy@m-w.com anytime so that we can help.If a parent or guardian chooses to unlock Puku's subscription features, you may be required to provide a credit card number, which will be processed as provided under Payment card information above.

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#### Information we collect automatically

When you open Puku, our servers (or those of our authorized, third-party service providers) automatically record certain information that your device sends. This information may include data such as your device's IP address and location, device name and version, operating system type and version, unique device identifier, word lists your child interacts with on Puku, access times and dates, and other statistics. See also Third-party service providers below.


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#### How we use your information

We use the personal and non-personal information we collect from you or automatically through yours or your child's use of Puku to improve both Puku and our internal operations, and we do not allow sharing of your personal information with third parties and their products or services, except as described herein. Specifically, we use this information to:

- store user profiles and provide wordlist recommendations;
- provide a leveling process in order to help direct your child to the best beginning word list;
- keep track of your child's activities on Puku; and
- alert you to new Merriam-Webster products or services, including new Puku features.

In addition, we use this information for internal operation purposes that include conversion tracking, frequency tracking, attribution, and improving Puku's services. For more information, see Puku third-party service providers below.

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#### Puku third-party service providers

To help us provide you with the best service, we work with the following authorized, third-party service providers to include their tracking tools, such as device identifiers, within Puku. See Mobile device identifiers above. Using tracking tools, these third-party service providers collect information automatically on our behalf from about yours and your child's use of Puku, store collected information on their servers, and provide us with both analytics and push notification services. You may opt out of certain activities performed by our third-party service providers through your mobile device settings, such as your device advertising settings for mobile phones, or as otherwise provided below.

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#### Google Inc. analytics services

*Google Analytics for Firebase*. Firebase is an analytics service provided by Google Inc. Firebase specifically collects these data: online identifiers, browser type and settings, operating system, mobile network information, crash reports, device identifiers as well as App-Instance Identifier (a randomly generated number that identifies a unique installation of an App for the first time). We use Firebase's own unique user ID (app.instance id), which does separate one mobile phone from another, but does not personally identify you or your child. All data collected by Firebase on our behalf is stored by Firebase on its own servers. For more information, including length of time this information is stored by Firebase, please see:- https://firebase.google.com/policies/analytics/
- https://support.google.com/analytics/answer/6004245?hl=en
- https://policies.google.com/technologies/partner-sites
- https://firebase.google.com/terms/

*Google Ads conversion tracking*. Google Ads conversion tracking is an analytics service provided by Google that connects data from the Google Ads advertising network with actions performed in connection with Puku. Personal data that may be collected by Google Ads conversion tracking includes usage data.All data collected by Google is processed by Google in the United States and Google is a Privacy Shield participant. You may opt-out of certain Google features by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy?hl=en. We encourage you to review Google's policy for safeguarding your data: https://support.google.com/analytics/answer/6004245. For more information on what type of information Google collects, please visit please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en.

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#### Facebook Ads conversion tracking (Facebook, Inc.)

Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed in connection with Puku. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram, and Audience Network. The Facebook Ads conversion tracking pixel collects usage data. Facebook processes this data in the United States and is a Privacy Shield participant. We encourage you to review Facebook's Privacy Policy.


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## Security of Your Information

Any personally identifiable information collected through this site is stored on limited-access servers. We maintain safeguards to protect these servers and the information they store. Also, to help protect the privacy of data and personally identifiable information you transmit through the use of our Services, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We strive to restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. In addition, we strive to educate all our employees about the importance of confidentiality and maintaining the privacy and security of your information.

## Data Storage and Retention

Your personal information is stored by us using Amazon Web Services (AWS) cloud storage solutions in the AWS Cloud – U.S. East (N. Virginia) Region, with backups in the AWS Cloud – Asia Pacific (Singapore) Region and Brazil (Sao Paulo) Region. We retain your information for the duration of your business relationship with us and as long as necessary to permit us to use it for the legitimate business purposes that we have communicated to you and comply with applicable law or regulations. For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact the Merriam-Webster's data protection officer at dpo@m-w.com.

## Consent to Processing and Transfer of Information about You

Merriam-Webster's headquarters are in the United States. Information we collect from you will be processed in the United States and may be stored, transferred to, and processed in any country where we have facilities or in which we engage service providers. These countries may be outside your country of residence, including the United States, and may have different data protection laws than your country.

If you are in the European Economic Area (EEA), Merriam collects and transfers personal information out of the EEA only: with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest of Merriam in a manner that does not outweigh your rights and freedoms. Merriam endeavors to apply suitable safeguards to protect the privacy and security of your personal information and to use it only consistent with your relationship with us and the practices described in this Privacy Policy.

## EU Data Subject Rights

The EU GDPR and other countries' privacy laws provide certain rights for data subjects. A good explanation of them (in English) is available on the website of the United Kingdom's Information Commissioner's Office.

If you wish to confirm that Merriam-Webster is processing your personal data, or have access to the personal data Merriam-Webster may have about you, please contact us at dpo@m-w.com and request a copy of our Merriam-Webster Subject Access Request Form. Before processing any such requests, we must first verify that it is a valid and lawful request and that you are in fact the data subject for such request. Please allow at least thirty (30) days for a response.

## EU Representative and Data Protection Officer

Merriam-Webster is headquartered in Springfield, Massachusetts USA. Merriam-Webster has appointed an EU representative and data protection officer for you to contact if you have any questions or concerns about Merriam-Webster's personal data policies or practices.

Our EU representative's contact information is:

Merriam-Webster EU Representative

Unity Wharf, 13 Mill Street

London SE1 2BH UNITED KINGDOM

GDPR_EURep@m-w.com

Our data protection officer's name and contact information are:

M.G. Kim

Merriam-Webster Data Protection Officer

325 N. LaSalle Street, Suite 200

Chicago, IL USA 60654

dpo@m-w.com

## Copyright

All of the content on the Services is copyrighted by Merriam-Webster, Incorporated, 47 Federal Street, P.O. Box 281, Springfield, MA 01102, or its licensors, and it cannot be redistributed or used for commercial purposes. More detailed information about Merriam-Webster's copyrights and trademarks is available on our Copyright Notice page.

## Business Transfers

As we continue to develop our business, we might sell or buy subsidiaries, or business units. In such transactions, customer information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Policy (unless, of course, the customer consents otherwise). Also, in the unlikely event that Merriam-Webster or substantially all of its assets are acquired, customer information will be one of the transferred assets and will remain subject to our Privacy Policy.

## Acceptance of Privacy Policy Terms and Conditions

By using the Services, you signify your agreement to the terms and conditions of this Merriam-Webster Privacy Policy. If you do not agree to these terms, please do not use this site. We reserve the right, at our sole discretion, to change, modify, add, or remove portions of this policy at any time. Please take a look at the Effective Date at the top of this page to see when this Privacy Policy was last revised. Amended terms that materially impact or modify your privacy rights take effect 30 days after they are initially posted on the site. Your continued use of any of the Services following the posting of any changes to these terms shall mean that you have accepted those changes.

## Questions, Comments or Complaints

If you have questions about Merriam-Webster or its products, visit our Contact Us page to find email addresses and other contact information for the appropriate department. To correct, update, or remove personally identifiable information, please email us at dpo@m-w.com. If you have any questions or concerns, please send an email to privacy@m-w.com or at dpo@m-w.com.