CMDPress

Privacy Policy

This Privacy Policy ("Policy") describes how the operator of this platform ("Company", "we", "us", or "our") collects, uses, discloses, retains, and safeguards information when you access or use the web-based dashboard, WordPress agent plugin, application programming interfaces (APIs), command-line tools, mobile applications (if any), documentation, websites, and all related software, features, and functionality (collectively, the "Services"). This Policy applies to all users of the Services, including account holders, team members, and visitors to our public-facing pages. By accessing or using the Services, you acknowledge that you have read, understood, and consent to the practices described in this Policy. If you do not agree with any part of this Policy, you must immediately cease all use of the Services.

1. Definitions

"Personal Data" means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an identified or identifiable natural person or household. "Controller" means the entity that determines the purposes and means of processing Personal Data. "Processor" means an entity that processes Personal Data on behalf of a Controller. "Account Data" means information associated with your user account, workspace, team, and subscription. "Site Data" means technical, configuration, and operational data collected from or about your Connected Sites through the agent plugin or API. "Connected Site" means any WordPress website or application connected to the Services through the agent plugin or API. "Usage Data" means information about how you interact with and use the Services. "Aggregate Data" means data that has been combined, de-identified, or anonymized such that it can no longer reasonably be used to identify a specific individual. "Processing" means any operation performed on Personal Data, including collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure, dissemination, alignment, combination, restriction, erasure, or destruction.

2. Our Role as Controller and Processor

With respect to Account Data, Usage Data, and data we collect directly from you, we act as the Controller. With respect to data stored on or transmitted from your Connected Sites (including data about your end users, customers, or visitors), you are the Controller and we act as a Processor, processing such data solely on your behalf and in accordance with your instructions as expressed through your use of the Services. You are solely responsible for ensuring that you have all necessary legal bases, consents, and authorizations to transmit data from your Connected Sites to the Services, and for the lawfulness of all processing you direct us to perform. We shall not be liable for any failure by you to obtain required consents or comply with applicable data protection laws with respect to your Connected Sites.

3. Information We Collect

We collect the following categories of information:

4. Sources of Data Collection

We collect data from the following sources: (a) directly from you when you register an account, configure your profile, set up a team, manage your subscription, contact support, or otherwise interact with the Services; (b) automatically from your Connected Sites through the WordPress agent plugin, which periodically transmits site configuration, health, and status data to the Services via authenticated, signed REST API requests; (c) automatically through cookies, session identifiers, web beacons, pixels, and similar tracking technologies embedded in the Services; (d) automatically from server logs and application monitoring systems that record requests, errors, performance metrics, and security events; (e) from third-party service providers that support payment processing, email delivery, hosting, infrastructure, analytics, error tracking, and security monitoring; and (f) from publicly available sources where such information supplements or verifies data you have provided.

5. How We Use Your Data

We use collected data for the following purposes:

6. Legal Bases for Processing (EEA, UK, and Similar Jurisdictions)

Where applicable data protection law requires a legal basis for processing Personal Data, we rely on one or more of the following grounds: (a) Consent: Where you have given clear, informed, and unambiguous consent to the processing of your Personal Data for one or more specific purposes. You may withdraw consent at any time, though withdrawal does not affect the lawfulness of processing performed prior to withdrawal. (b) Contractual Necessity: Where processing is necessary for the performance of a contract to which you are a party (including our Terms of Service) or to take steps at your request prior to entering into a contract. (c) Legal Obligation: Where processing is necessary for compliance with a legal obligation to which we are subject, including tax, accounting, anti-money laundering, and regulatory reporting obligations. (d) Legitimate Interests: Where processing is necessary for our legitimate interests or those of a third party, provided that such interests are not overridden by your fundamental rights and freedoms. Our legitimate interests include operating and improving the Services, ensuring security, preventing fraud, and conducting analytics. (e) Vital Interests: Where processing is necessary to protect the vital interests of any natural person. (f) Public Interest: Where processing is necessary for the performance of a task carried out in the public interest, to the extent applicable.

7. Cookies, Tracking Technologies, and Automated Data Collection

We use the following types of cookies and similar technologies:

You may manage cookie preferences through your browser settings. Most browsers allow you to block or delete cookies, but doing so may impair your ability to use certain features of the Services, particularly authentication and session management. We honor Do Not Track (DNT) signals where technically feasible, but note that there is no universally accepted standard for DNT signal interpretation. The Services do not use cookies or tracking technologies for third-party advertising purposes.

8. Disclosure of Data

We do not sell, rent, or trade your Personal Data to third parties for their marketing purposes. We may disclose your data in the following circumstances:

9. Data Retention

We retain Personal Data for as long as your account is active or as reasonably necessary to fulfill the purposes for which it was collected. Specific retention periods include:

We may retain Aggregate Data and fully anonymized data indefinitely for analytical, research, and operational purposes. Upon expiration of the applicable retention period, Personal Data is securely deleted or irreversibly anonymized using commercially reasonable methods.

10. Data Security

We implement and maintain a comprehensive information security program that includes the following administrative, technical, and physical safeguards:

NOTWITHSTANDING THE ABOVE, NO METHOD OF ELECTRONIC TRANSMISSION, STORAGE, OR PROCESSING IS COMPLETELY SECURE, AND WE CANNOT AND DO NOT GUARANTEE ABSOLUTE SECURITY. You acknowledge that you transmit data to and through the Services at your own risk. You are solely responsible for maintaining the security of your own account credentials, devices, Connected Sites, and hosting environments. We shall not be liable for any unauthorized access, data breach, data loss, or data corruption except to the extent directly and proximately caused by our gross negligence or willful misconduct.

11. International Data Transfers

The Services are operated from, and data is primarily stored in, infrastructure located in the United States (or other jurisdictions where our hosting providers maintain data centers). If you are located outside the United States, your Personal Data will be transferred to, stored, and processed in the United States or other countries that may have data protection laws that differ from those in your jurisdiction. By using the Services, you explicitly consent to such transfers. Where required by applicable law (including the GDPR, UK GDPR, or similar frameworks), we implement appropriate safeguards for cross-border data transfers, including: (a) Standard Contractual Clauses (SCCs) approved by the European Commission; (b) the UK International Data Transfer Addendum; (c) adequacy decisions where applicable; or (d) other legally recognized transfer mechanisms. You may request a copy of the applicable transfer safeguards by contacting us through the channels described in this Policy.

12. Your Privacy Rights

Subject to applicable law, you may have the following rights regarding your Personal Data:

To exercise any of these rights, please contact us through the support channels provided within the Services or at the contact information listed in this Policy. We will verify your identity before processing your request and will respond within the timeframe required by applicable law (typically 30 days, extendable by an additional 60 days for complex requests). We will not discriminate against you for exercising your privacy rights.

13. California Privacy Rights (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act and California Privacy Rights Act ("CCPA/CPRA") provide you with additional rights regarding your Personal Information (as defined under California law). In the preceding 12 months, we have collected the categories of Personal Information described in Section 3 of this Policy. We do not sell or share (as those terms are defined under the CCPA/CPRA) your Personal Information for cross-context behavioral advertising purposes. California residents have the right to: (a) know what Personal Information we collect, use, and disclose; (b) request deletion of Personal Information; (c) request correction of inaccurate Personal Information; (d) opt out of the sale or sharing of Personal Information (though we do not engage in such activities); and (e) not be discriminated against for exercising their CCPA/CPRA rights. To exercise these rights, contact us through the channels described in this Policy. We will verify your identity using information associated with your account.

14. Additional State Privacy Rights

Residents of Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), and other states with comprehensive privacy legislation may have rights similar to those described in Sections 12 and 13, including rights of access, correction, deletion, data portability, and the right to opt out of targeted advertising, profiling, and the sale of personal data. We do not engage in the sale of personal data or targeted advertising. To exercise rights under your state's privacy law, please contact us through the channels described in this Policy.

15. European Economic Area, United Kingdom, and Swiss Data Subjects

If you are located in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, you have the rights described in Section 12 under the General Data Protection Regulation (GDPR), UK GDPR, or Swiss Federal Act on Data Protection (FADP), as applicable. You may also contact your local supervisory authority to lodge a complaint. The data protection supervisory authority for the UK is the Information Commissioner's Office (ICO). For EEA residents, the competent supervisory authority depends on your country of residence. Where we rely on legitimate interests as a legal basis, you may request details of the balancing test we have conducted.

16. Agent Plugin Data Collection

The WordPress agent plugin installed on your Connected Sites collects and transmits data to the Services as necessary to provide the site management, monitoring, and maintenance features you have enabled. The types of data collected by the agent plugin include, but are not limited to: WordPress core version and update status; PHP version and configuration; web server information; database version and size; installed plugin names, versions, slugs, active/inactive status, and update availability; installed theme names, versions, active/inactive status, and update availability; site health metrics; cron job schedules; user account data (usernames, email addresses, roles, last login dates) as needed for user management features; debug log contents when debug log viewing is enabled; file integrity checksums for core file verification; backup file metadata; and site configuration toggles. Data is transmitted via authenticated, cryptographically signed REST API requests over HTTPS. You are responsible for informing your end users, visitors, and any other individuals whose data may be present on your Connected Sites about the data collection and transmission performed by the agent plugin, and for obtaining any consents required by applicable law.

17. Cookies and Tracking Technologies (Detailed)

The following table describes the primary cookies and tracking technologies we use:

We do not use third-party advertising cookies. You may manage cookie preferences through your browser settings. Blocking strictly necessary cookies will prevent you from using the Services.

18. Do Not Track and Global Privacy Control

Some browsers transmit "Do Not Track" (DNT) or "Global Privacy Control" (GPC) signals. We honor GPC signals as legally required in applicable jurisdictions. For DNT signals, there is no universally accepted standard, and our response to DNT may vary. We do not engage in cross-site tracking or targeted advertising.

19. Data About Children

The Services are not directed to individuals under the age of 18 (or the age of majority in the applicable jurisdiction). We do not knowingly collect Personal Data from children under the age of 13 (or the applicable age under local law, such as 16 under the GDPR). If we become aware that we have inadvertently collected Personal Data from a child without appropriate parental or guardian consent, we will take reasonable steps to promptly delete that data. If you believe we have collected data from a child, please contact us immediately through the channels described in this Policy.

20. Third-Party Websites and Services

The Services may contain links to, or integrations with, third-party websites, applications, or services that are not owned or controlled by us, including but not limited to the WordPress.org plugin and theme directory, payment processor portals, and documentation sites. This Privacy Policy does not apply to any third-party websites or services. We are not responsible for the privacy practices, content, security, or data collection activities of any third party. We strongly encourage you to review the privacy policies and terms of service of any third-party websites or services before providing them with any Personal Data or granting them access to your information.

21. Data Processing Agreement

If you require a Data Processing Agreement (DPA) for compliance with the GDPR, UK GDPR, or other applicable data protection legislation, please contact us through the channels described in this Policy. We will provide a DPA that addresses the requirements of Article 28 of the GDPR, including provisions regarding the subject matter and duration of processing, the nature and purpose of processing, the types of Personal Data processed, the categories of data subjects, and the obligations and rights of the Controller.

22. Data Breach Notification

In the event of a security breach that results in unauthorized access to, or disclosure of, Personal Data that is likely to result in a risk to your rights and freedoms, we will notify affected users and applicable supervisory authorities in accordance with the timeframes and procedures required by applicable law (including, where applicable, the 72-hour notification requirement under Article 33 of the GDPR). Notification may be provided via email to the address associated with your account, through in-app notifications, or by posting a notice on the Services. We shall not be liable for any delays in notification caused by law enforcement requests, forensic investigation requirements, or the need to implement containment measures.

23. Automated Decision-Making and Profiling

The Services may use automated systems for purposes such as fraud detection, abuse prevention, rate limiting, and security threat assessment. These systems may analyze usage patterns, IP addresses, request frequencies, and behavioral signals to identify and block suspicious activity. We do not use automated decision-making that produces legal effects or similarly significant effects on individuals without human review. If you believe you have been adversely affected by an automated decision, you may contact us to request human review.

24. Data Minimization and Purpose Limitation

We collect and process only the Personal Data that is reasonably necessary for the purposes described in this Policy. We do not collect excessive data or use Personal Data for purposes materially different from those for which it was collected, unless we have obtained your consent or have another valid legal basis. We periodically review the data we hold to ensure compliance with this principle.

25. Changes to This Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time at our sole discretion. When we make material changes, we will update the "Last Updated" date at the top of this page and may provide additional notice through email, in-app notifications, or a prominent notice on the Services. We are not obligated to provide individual notice of non-material changes. Your continued use of the Services after any changes are posted constitutes your acceptance of the updated Policy. If you do not agree with any changes, you must stop using the Services and may request deletion of your account and data. We recommend reviewing this Policy periodically to stay informed about our data practices.

26. Contact Information

For questions, concerns, or requests regarding this Privacy Policy, your Personal Data, or our privacy practices, please contact us through the support channels provided within the Services or at the contact information posted on our website. If you are located in the EEA or UK and wish to raise a concern about our data processing practices, you have the right to lodge a complaint with your local data protection supervisory authority.