This privacy notice for OnTheGoSystems Limited ("we", "us", or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:
- Visit our websites, use your WPML customer account, or use WPML and any related products, services, or features
- Interact with us through support, documentation, sales, marketing, or events, or use any other OnTheGoSystems service that links to this privacy notice
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at hello@wpml.org.
Summary of key points
This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.
Who is responsible for your data? OnTheGoSystems Limited is the controller of the personal data we collect to run your account, bill you and support you. When you use WPML to process the personal data of your own visitors or clients, you are the controller and we are your processor, under our Data Processing Annex (DPA). Learn more about the legal bases we rely on.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.
Do we process any sensitive personal information? We do not process sensitive personal information.
Do we receive any information from third parties? Yes, a little. Our payment processors tell us whether a payment succeeded, the EU VAT register (VIES) tells us whether a VAT number is valid and the company name it is registered to, and for business clients we read public information about the company. Learn more about information from other sources.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.
In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.
How long do we keep your information? Each kind of data has its own period, from 24 hours to as long as your account exists, and invoices longer. Learn more about how long we keep your information.
How do we keep your information safe? We protect personal data with the technical and organisational measures set out in our Data Processing Annex (DPA). Learn more about how we keep your information safe.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.
How do you exercise your rights? The easiest way to exercise your rights is by visiting https://app.wpml.org/home/contact-us/personal-data-request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.
Where is our Data Processing Annex (DPA)? Our Data Processing Annex (DPA), with the Standard Contractual Clauses and the UK and Swiss addenda, is Annex 1 of our Terms and Conditions and forms part of them. There is nothing to sign or send back. You can also read and print the DPA at https://app.wpml.org/account/dpa.
Want to learn more about what we do with any information we collect? Review the privacy notice in full.
Table of contents
- What information do we collect?
- How do we process your information?
- Who is responsible for your data, and what legal bases do we rely on?
- When and with whom do we share your personal information?
- Do we use cookies and other tracking technologies?
- How do we handle your social logins?
- How long do we keep your information?
- How do we keep your information safe?
- Do we collect information from minors?
- What are your privacy rights?
- Controls for Do-Not-Track features
- Do United States residents have specific privacy rights?
- Do we make updates to this notice?
- How can you contact us about this notice?
- How can you review, update, or delete the data we collect from you?
1. What information do we collect?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
- names
- email addresses
- usernames
- passwords
- contact preferences
- billing addresses
- company name, VAT number and tax ID, when you give them for your invoices
- the questions, messages and files you send to our support, including your conversations with Maiya, our AI support assistant
Sensitive Information. We do not process sensitive information.
Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is stored by PayPal and Stripe. You may find their privacy notice link(s) here: https://www.paypal.com/us/legalhub/privacy-full#personalData (opens in a new tab) and https://stripe.com/en-hr/privacy (opens in a new tab).
Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter, or other social media account. If you choose to register in this way, we will collect the information described in the section called "How do we handle your social logins?" below.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
- Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings, information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take, including which features you use), and device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings). Where applicable, we may also collect information about your interactions with designated WPML administration interfaces, including navigation paths, configuration actions, and feature usage patterns through session replay technology for product improvement, troubleshooting, and usability analysis.
- Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
- Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.
- Download and update data. When a WPML site downloads or updates our plugins, we record the account and site key, the site's address, the IP address of the request and the versions involved.
Information from other sources
We receive a small amount of information about you from others:
- Payment processors (Stripe and PayPal) tell us whether a payment succeeded, was refunded or was disputed.
- The EU VAT register (VIES), run by the European Commission, tells us whether the VAT number you enter is valid, and the company name it is registered to.
- Public sources, for business clients. After a purchase, we read public information about the buyer's company (its website and web search results for the company name) to record the company's name, industry, size band and whether it is an agency. We use this profile to understand who our clients are, so our support and offers fit them.
2. How do we process your information?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
- To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
- To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service. We may share the content you submit for translation with third-party infrastructure and/or translation providers, solely for the purpose of generating translations. We do not use your content to train artificial intelligence models, nor permit its use for training on our behalf.
- To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service. This may include reviewing interactions recorded within designated WPML administration interfaces when necessary to investigate and troubleshoot technical issues.
- To improve the usability, performance, and effectiveness of our Services. We may process usage information, including interactions within designated WPML administration interfaces, to understand how users interact with plugin features, identify usability issues, troubleshoot technical problems, and improve the overall user experience.
- To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
- To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see "What are your privacy rights?" below.
- To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.
- To request feedback or reviews regarding our Services. We may process your information to contact you after you have used our Services to request feedback or a review, based on our legitimate interests in improving our Services and user experience and in accordance with applicable laws. You can opt out of receiving such communications at any time.
3. Who is responsible for your data, and what legal bases do we rely on?
In Short: We are the controller of the data we need to run your account, bill you and support you, and we process it only when we have a valid legal reason (i.e., legal basis) to do so under applicable law: to provide you with services to enter into or fulfill our contractual obligations, to comply with laws, with your consent, or to fulfill our legitimate business interests. When you use WPML to process your own visitors' or clients' data, you are the controller and we are your processor.
If you are located in the EU or UK, this section applies to you.
Our role as controller. OnTheGoSystems Limited, 22/F 3 Lockhart Road, Wanchai, Hong Kong (company registration 1683657), is the controller of the personal data described in this notice: your account, your orders and invoices, your support questions, and the use of our websites. Our Data Protection Officer is Mercedes Barreda, hello@wpml.org.
The table shows each purpose and the legal basis under the GDPR (and, where it applies, the UK GDPR) that we rely on for it:
| Purpose | Data | Legal basis |
|---|---|---|
| Creating your account, signing you in and keeping your account in working order | Name, email address, username, password, language, team members you invite | Performance of our contract with you (Art. 6(1)(b)) |
| Selling and renewing your plan: orders, payments, renewals, renewal and expiry reminders, card-expiry notices, refunds | Name, email and billing address, company, order and payment history | Performance of our contract with you (Art. 6(1)(b)) |
| Issuing invoices and keeping our tax and accounting records, including the EU VAT (OSS) return | Billing details, VAT number, tax ID, amounts and VAT charged | Compliance with our legal obligations (Art. 6(1)(c)) |
| Checking your VAT number with the EU VAT register (VIES) so the right VAT is charged | VAT number and country | Compliance with our legal obligations (Art. 6(1)(c)) |
| Delivering plugin downloads and updates to your registered sites | Account, site keys, site address, IP address, plugin versions | Performance of our contract with you (Art. 6(1)(b)) |
| Answering your support questions, including through Maiya, and translating them for the supporter who answers | Your questions, messages, files and the site details you share | Performance of our contract with you (Art. 6(1)(b)) |
| Reviewing support conversations to improve our answers | Support questions and replies | Our legitimate interest in giving correct and consistent support (Art. 6(1)(f)) |
| Building a company profile of business clients from public information | Company name, website, industry, size band, whether it is an agency | Our legitimate interest in understanding our clients (Art. 6(1)(f)) |
| Sending product news and newsletters | Name, email address, newsletter topic preferences | For clients: our legitimate interest in telling them about the products they use (Art. 6(1)(f)). For people who are not clients: your consent when you sign up (Art. 6(1)(a)). Every email carries an unsubscribe link |
| Asking for feedback and reviews (for example a rating survey, or an invitation to review us) | Name, email address, your rating and comments | Our legitimate interest in improving our Services (Art. 6(1)(f)) |
| Measuring how our websites are used with a first-party analytics cookie | Pages visited, referrer, device and browser type, country, a random visitor ID | Your consent (Art. 6(1)(a)), given in the cookie banner |
| Counting visits without a cookie when you decline or do not answer | Anonymous, cookie-free page counts | Our legitimate interest in knowing how our websites are used (Art. 6(1)(f)) |
| Measuring which Google Ads lead to a first purchase | The Google Ads click ID, the order number, its value and currency | Your consent (Art. 6(1)(a)); the click is kept only after you accept analytics |
| Keeping our Services secure: firewall, rate limits, fraud prevention and request logs | IP address, request details | Our legitimate interest in keeping our Services and our clients safe (Art. 6(1)(f)) |
Where we rely on your consent, you can withdraw it at any time (see "What are your privacy rights?"). Where we rely on our contract with you, we need the data to provide the Services; without it we cannot open your account, sell you a plan or answer your question.
Our role as processor. When you use WPML to process personal data of your own (for example, content of your site that you send for automatic translation), you are the controller of that data and we process it for you as your processor, under our Data Processing Annex (DPA), Annex 1 of our Terms and Conditions, which forms part of the Terms without a separate signature. The DPA complies with Article 28 of the GDPR and, where applicable, the UK GDPR and the Swiss Federal Act on Data Protection.
We may also process certain personal information based on our legitimate interests where those interests are not overridden by your rights and freedoms. These legitimate interests include maintaining and improving the functionality, security, reliability, and usability of our Services, providing technical support, preventing fraud and abuse, performing internal analytics, and understanding how users interact with our Services to improve their overall experience.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
- For investigations and fraud detection and prevention
- For business transactions provided certain conditions are met
- If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
- For identifying injured, ill, or deceased persons and communicating with next of kin
- If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
- If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
- If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
- If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
- If the collection is solely for journalistic, artistic, or literary purposes
- If the information is publicly available and is specified by the regulations
4. When and with whom do we share your personal information?
In Short: We may share information in specific situations described in this section and/or with the following third parties.
We may need to share your personal information in the following situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- When we use service providers. We may share your information with third-party service providers to support the operation of the services, including providers of hosting, translation services, processing and infrastructure, payment processing, customer communications (such as newsletters), feedback collection, and analytics. These providers process your information on our behalf and only as necessary to provide these services to us.
- Payment processors. Stripe and PayPal receive your payment details and the amount of each order in order to take your payment. They also process payment data under their own privacy notices (linked in section 1).
- The EU VAT register. When you enter a VAT number, we send the number and its country to the European Commission's VIES service to check it.
- Tax authorities. Our quarterly EU VAT (OSS) return reports totals per member state, without client names. We keep invoices so that we can produce them to a tax authority when the law requires it.
- Google Ads. If you accepted analytics cookies and arrived from a Google ad, we send Google the ad click ID, the order number, its value without tax and its currency when you complete your first order, so we can measure which ads lead to purchases. We send no name or email address.
Our websites and services may contain links to third-party review platforms. If you choose to visit or submit a review on such platforms, any information you provide will be collected and processed by the third party in accordance with their own privacy notices and terms.
Service providers and subprocessors
The service providers that process personal data for us, each with its registered seat, its processing location and what it does, are listed with a dated record of changes on our sub-processor page; the Data Processing Annex (DPA) sets out the terms under which they process the data you entrust to us.
Transfers outside the EEA and the UK
OnTheGoSystems Limited is seated in Hong Kong, and our servers and most of our service providers are in the United States: our database and application run in Amazon Web Services' us-east-1 region (Virginia), with a backup copy in us-west-2 (Oregon). Personal data you give us is therefore processed in Hong Kong and in the United States. Where personal data is transferred from the EEA, the UK or Switzerland to a country without an adequacy decision, we use the European Commission's standard contractual clauses, with the UK and Swiss addenda, set out with our Terms and Conditions and described in clause 7 of the Data Processing Annex (DPA). You can ask us for a copy at hello@wpml.org.
5. Do we use cookies and other tracking technologies?
In Short: We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. We do not have a separate cookie notice: this section is our cookie notice. It lists the cookies we set and how you can refuse them.
We measure how our site is used with our own, self-hosted analytics — we never use third-party analytics or share this data. If you accept analytics cookies, we set one first-party cookie (_otgs_vid, 13 months) to recognize your browser across visits. If you decline (or don't answer), we only keep anonymous, cookie-free page counts that cannot identify you or follow you across days — based on a daily-rotating code derived from a truncated network address, deleted every 24 hours. You can change your choice at any time via "Cookie Settings" in the footer.
Where the law requires consent, our cookie banner asks for it before any analytics cookie is set. We decide whether to show the banner from the country of your IP address, which we look up in a geolocation database we keep on our own servers. The cookies we set on wpml.org and app.wpml.org are:
| Cookie | What it does | How long it lasts | Set when |
|---|---|---|---|
| klaro | Remembers your cookie choice | 365 days | You make a choice in the cookie banner |
| _otgs_vid | Recognizes your browser across visits for our analytics | 13 months | Only if you accept analytics |
| _otgs_gclick | Remembers the Google ad you arrived from, so a first purchase can be counted for that ad | 90 days | Only if you accept analytics; deleted when you withdraw consent |
| wpml_account, wpml_uid | Tell the pages of wpml.org that you are signed in, so they can show your account menu | Until you close the browser or sign out; wpml_uid at most 14 days | You sign in |
| wpml_visitor | Remembers that you confirmed your email address in our support chat | 30 days | You confirm your email address in the support chat |
| The sign-in session cookie of app.wpml.org | Keeps you signed in | Until you sign out or close the browser | You sign in |
6. How do we handle your social logins?
In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.
Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.
We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.
7. How long do we keep your information?
In Short: Each kind of data has its own retention period. Most of your account data is kept while your account exists; invoices are kept after that, because tax and accounting law requires it.
| Data | How long we keep it |
|---|---|
| Your account: name, email address, username, password, billing address, company, VAT number, tax ID, language and settings, and the accounts of team members you invited | While your account exists. When you delete your account, we delete it, together with your sign-in identity. |
| Orders and invoices, with the billing name, email and address on them | Kept after your account is deleted, because tax and accounting law requires it. |
| Your subscriptions, plugin licences and registered sites | While your account exists. When you delete your account, we cancel the subscriptions, end the licences and deactivate the site keys; the records of them stay with your orders. |
| Your support questions, replies, chat and Maiya conversations, and the files you sent with them | Kept, also after you delete your account, so we can answer a question about an earlier case. |
| Passwords and other access details you share with a supporter in a private reply | Deleted when the question is closed. |
| Files you attach to a reply and never send | Deleted after 24 hours. |
| Records of the emails we send you (address, subject, date, whether it was delivered) | 24 months from sending. |
| The list of addresses we must not email (after an unsubscribe, a bounce or a complaint) | Kept for as long as the block applies, so we never email that address by mistake; deleted 24 months after the block is lifted. |
| Links we send to confirm that an address may receive our emails again | Valid for 7 days, deleted 30 days after they expire. |
| Website visit records (pages, referrer, country, device, the analytics visitor ID, and your account if you were signed in) | 25 months. Daily totals that identify no one are kept. |
| Plugin download and update records (account, site key, site address, IP address, versions) | 25 months. Daily totals that identify no one are kept. |
| Per-site records of whether WPML may send usage statistics from a site | 90 days. |
| Reports that WPML sites send when they check for updates | 7 days after we process them. |
| Translation and content statistics that WPML sites send us | 13 months; daily site check-ins 395 days. |
| Company profile of business clients | While your account exists. |
| Your ratings and comments in our feedback surveys | Kept. |
| Security logs of requests to app.wpml.org and api.wpml.org (IP address, request) | Firewall logs 365 days; load-balancer logs 30 days. |
| Database backups | Daily backups 14 days; a weekly copy 90 days. Data deleted from our database is gone from our backups after that. |
| Records of our background jobs, which can name the email address a message went to | 7 days after the job finished; 90 days for a failed job. |
You can delete your account yourself from your account page. If you hold a lifetime licence, our support team deletes it for you on request.
For personal data we process for you as your processor, the Data Processing Annex (DPA) (clause 3.2) says how we return or delete it.
8. How do we keep your information safe?
In Short: We protect personal data, both what we hold as a controller and what we process for you, with the technical and organisational measures set out in Appendix 2 of our Data Processing Annex (DPA).
9. Do we collect information from minors?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at hello@wpml.org.
10. What are your privacy rights?
In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "How can you contact us about this notice?" below.
We will consider and act upon any request in accordance with applicable data protection laws.
If we process your personal data for one of our clients as their processor (for example, your data on a client's WordPress site), please send your request to that client; the Data Processing Annex (DPA) (clause 5.3) says how we help them answer it.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority (opens in a new tab) or UK data protection authority (opens in a new tab).
If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner (opens in a new tab).
Withdrawing your consent: {#withdrawconsent} If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "How can you contact us about this notice?" below or updating your preferences (for example, where session replay recordings are available within WPML, you may disable this functionality at any time through the WPML settings interface.)
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section "How can you contact us about this notice?" below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
Account information
If you would at any time like to review or change the information in your account or terminate your account, you can:
- Log in to your account settings and update your user account.
- Contact us using the contact information provided.
Upon your request to terminate your account, we delete your account and its sign-in identity from our active databases. We keep your orders and invoices, which the law requires, and your support questions, as section 7 sets out. Deleted data leaves our backups within 90 days.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.
If you have questions or comments about your privacy rights, you may email us at hello@wpml.org.
11. Controls for Do-Not-Track features
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
12. Do United States residents have specific privacy rights?
In Short: If you are a resident of the United States, you are granted specific rights regarding access to your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers | Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name | YES |
| B. Protected classification characteristics under state or federal law | Gender and date of birth | NO |
| C. Commercial information | Transaction information, purchase history, financial details, and payment information | NO |
| D. Biometric information | Fingerprints and voiceprints | NO |
| E. Internet or other similar network activity | Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements | NO |
| F. Geolocation data | Device location | NO |
| G. Audio, electronic, visual, thermal, olfactory, or similar information | Images and audio, video or call recordings created in connection with our business activities | NO |
| H. Professional or employment-related information | Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us | NO |
| I. Education Information | Student records and directory information | NO |
| J. Inferences drawn from collected personal information | Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual's preferences and characteristics | NO |
| K. Sensitive personal Information | NO |
We will use and retain the collected personal information as needed to provide the Services or for:
- Category A – As long as the user has an account with us
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
- Receiving help through our customer support channels;
- Participation in customer surveys or contests; and
- Facilitation in the delivery of our Services and to respond to your inquiries.
How do we use and share your personal information?
Learn about how we use your personal information in the section, "How do we process your information?"
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, "When and with whom do we share your personal information?"
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.
We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.
13. Do we make updates to this notice?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated "Last updated" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
14. How can you contact us about this notice?
If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO), Mercedes Barreda, by email at hello@wpml.org, by phone at +17029973025 (Skype), or contact us by post at:
OnTheGoSystems Limited Mercedes Barreda 22/F 3 Lockhart Road Wanchai, Hong Kong
The same address answers questions about the Data Processing Annex (DPA), as its clause 13.2 says.
15. How can you review, update, or delete the data we collect from you?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please visit: https://app.wpml.org/home/contact-us/personal-data-request.
Last updated on: 27 October 2026