Privacy Policy for UserWay Services

Welcome to UserWay’s Privacy Policy. First things first: UserWay is a Privacy by Design company. Privacy is baked into everything we do. And remember, if you have any questions along the way, you can always reach out to us at support@userway.org. We’re here to help!

So what exactly does this Privacy Policy apply to?

This Services Privacy Policy applies to the UserWay software, code, Widget, plugin, and/or associated services ("Services") offered by UserWay ("UserWay") and that are the property of UserWay or its parent company. If you're looking for our website privacy policy, click here

What does Privacy By Design Mean?

UserWay is a Privacy by Design company, with Privacy by Design Services. This means we take great care to avoid collecting, processing and/or storing information on our users, as privacy is our priority. UserWay does not have a business model based on any collection of personally identifiable information or monetization of that information. In parallel, we are proud to be GDPR and CCPA compliant. Our security, Privacy by Design approach and privacy compliance ensures that every industry, including government & public sector, education, hospitality, banking & financial, healthcare, consumer & retail, IT & security and more, can benefit from providing their users with the most powerful accessibility tools available.

So what information is UserWay collecting when we use the Services?

1. WHAT INFORMATION WE COLLECT

First of all, its really important to us that you know that UserWay does not collect any personally identifiable information about end-users. This applies to the end users visiting websites that host our services, such as the UserWay AI_Powered Accessibility Pro Widget. Such information is invisible to UserWay and therefore is not collected, and cannot be shared by UserWay with any third parties, even under duress.

UserWay does collect the minimum information about the website owner it requires to provide the service and may, under certain situations and very selectively, disclose such information to third parties, when absolutely necessary, and as described below.

This Privacy Policy addresses two kinds of information: (1) Personal Information (as such term is defined below); and (2) Anonymous Information (as such term is defined below).

Personal Information.

Limited personal information (contact information) is or may be collected by UserWay during the website owner’s signup process for our Services such as purchasing the Widget, applying for access to UserWay APIs or when paying (the “Owner’s Personal Information”). It may identify a website owner as an individual or a company, and may include first name, last name, email address and telephone number.

Anonymous Information.

UserWay collects data in order to monitor and ensure correct operation. This data is designed to not include personal information, and is not correlated with other web browsing information that could lead to revealing personal information. This includes metrics on the number of times the widget or its individual features were activated on a website. For website Owners that customize widget color, language, size, position, icon type, etc., on behalf of their end users, UserWay stores those widget UI preferences too (the “Anonymous Information”).

2. HOW DO WE COLLECT INFORMATION

  1. UserWay may collect Personal Information of website owners that engage UserWay’s Service in the process of registering to the Service.
  2. UserWay collects billing and account information from website owners such as credit cards, payment cards or other payment methods from website owners, and shares this information with the billing and payment processors. UserWay does not store credit card or payment card numbers after they have been forwarded to our billing and payment processors.

3. HOW WE USE YOUR INFORMATION

UserWay uses Personal Information and Anonymous Information, internally, to understand its users’ needs and improve its Service and support, and in particular:

  1. Internal record keeping: to establish and update user accounts.
  2. Answering questions: to respond to queries sent to us.
  3. Improving or expanding UserWay's accessibility content and offerings, including software and services.
  4. Promotion: should you choose to accept, we may periodically send promotional emails about UserWay's new products or features, special offers or other information.
  5. UserWay analyzes data about widget loads and usage to improve the UserWay accessibility product in order to better tailor it to end users' needs.

4. WHO WE DISCLOSE YOUR INFORMATION TO

UserWay discloses Owner Personal Information and Anonymous Information as follows:

  1. UserWay securely discloses transaction information to a third party payment provider for the purpose of processing payments and for fraud prevention purposes.
  2. To respond to inquiries from law enforcement or to defend our rights or the rights of others.

5. THIRD PARTY SOFTWARE AND SERVICES

Use of UserWay may involve third party software and services.

  1. Sharing your information with third parties
    1. UserWay may use and share Owner Personal Information and Anonymous Information related to the Service with certain third parties that help UserWay to operate its Service, such as cloud providers, scanning service providers and other similar service providers. When we use such third parties, we contract with them under strict confidentiality and security guidelines, and restrict them from using or disclosing the information, except as required to perform the services on our behalf or to comply with legal requirements.
    2. UserWay may also share Owner Personal Information and Anonymous Information with:
      1. governmental bodies, regulators, law enforcement agencies, courts/tribunals and insurers where we are required to do so (a) to comply with our legal obligations; (b) to exercise our legal rights (for example in court cases); (c) for the prevention, detection, investigation of crime or prosecution of offenders; and (d) for the protection of our employees and customers.
      2. If UserWay becomes involved in a merger, acquisition, or any form of sale of some, or all, of its assets, it may transfer all the Information that was collected from users in connection with such a transaction.
  2. International transfer of information
    1. UserWay Inc. is a US-based company and together with its affiliates provide the UserWay Service. To deliver our Services to you, it may sometimes be necessary for UserWay to share your data outside of the United States with its parent company: UserWay Ltd. which is located in the State of Israel. These transfers are subject to special rules under data protection laws.
  3. Advertising and Analytics Services.
    1. UserWay may use standard analytics tools such as Google Analytics, Facebook Business, Chartbeat, etc. to learn more about how the website Owner(s) uses our Service, and how we should improve our user experience. UserWay and its third-party partners and vendors may use tracking technologies or methods of web and mobile analysis (such as pixels, beacons, etc.) to collect, track and store certain information about you when you use or interact with our Services, communications, content or third party’s websites links, to provide you with targeted advertising based on your interests and browsing activities on our Website, personalize the advertising content, and to serve you advertisements that are relevant to your regional location.
    2. The Owner’s IP address or mobile device identifier may be automatically shared with such third parties when you access the Services or the third party’s websites.
    3. These tools maintain their own privacy practices in accordance with their own privacy policies to provide their service. Further information about how Google uses data when you use our Service, can be found here.
    4. If you (the Owner) do not want us to share your Personal Information for marketing and advertising purposes, you mayopt-out in accordance with provisions below section below or contact us using the details provided below. Please note that even if you unsubscribe, we may still use and share your Personal Information with third parties for non-marketing purposes (for example to fulfill your requests and orders, communicate with you and respond to your inquiries, etc.). In such cases, the companies with whom we share your Personal Information are authorized to use your Personal Information only as necessary to provide these non-marketing services.
    5. How Can I Opt-Out?
      1. Emails. If you no longer wish to receive emails from us, you may opt out of receiving them at any time, by clicking ‘unsubscribe’ on any e-mail communication, or sending an email with your request to support@userway.org.
      2. Please note that even if you opt out of receiving marketing communications by postal mail, we may continue to send you transactional communications about your subscription or orders by postal mail.
      3. Turning Off Tracking Technologies. You can choose to have your computer warn you each time a persistent or session cookie is being sent, or you can choose to turn off such cookies through your browser settings. Each browser is a little different, so look at your browser’s Help menu to learn the correct way to modify your cookies as described in Section 2.3 above.
      4. You have the ability to control the use of cookies on our website through the cookie banner that appears when you first visit our site. The cookie banner allows you to opt-out of certain categories of cookies, or all cookies altogether. Please note that if you choose to opt-out of certain cookies, certain features of our website may not function properly.
  4. Our cloud service providers. The server(s) on which our Website and the Service are hosted and/or through which any of the Service are processed are managed by third parties, including, Amazon Web Service (AWS) technology, whose mailing address is Amazon Web Services, Inc., 410 Terry Avenue North, Seattle, WA 98109-5210, ATTN: AWS Legal. You can find more details on AWS' Privacy Policy here. We have configured our data to be stored in the State of Oregon, USA.
  5. We reserve the right to disclose your information as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, or court order. Also, please note that we may disclose general, aggregated, non-personal and non-identifiable information about our users to potential business partners, investors, or the public.

6. SECURITY

UserWay is committed to ensuring that any information that is collected by UserWay remains secure, as reflected by UserWay’s being ISO27001 certified and audited. In order to preventing unauthorized access or disclosure UserWay has put in place suitable physical, electronic and managerial procedures to safeguard and secure the information collected online. UserWay uses industry standard SSL (secure socket layer) encryption to transfer private personal information.
UserWay cannot guarantee a perfect and absolute security measure, as no method of transmission over the Internet and or electronic storage is perfectly secure or invulnerable. Should we become aware of a security breach, we will notify any affected user, so that they can take appropriate protective steps. Such notification shall be issued by UserWay in accordance with the applicable (local) laws and regulations, as well as UserWay’s internal policies.

7. WHAT RIGHTS YOU HAVE IN CONNECTION WITH YOUR INFORMATION?

You may exercise any of your applicable legal rights in connection with your Personal Information collected by UserWay as detailed in this Privacy statement. In order to do so, kindly contact us at support@userway.org

  1. The consent you provided to UserWay in connection with the collection, use and processing of your personal information may be withdrawn at any time.
  2. Request to receive confirmation of whether your Personal Data is being processed.
  3. Request to receive a copy of your Personal information that you provided to UserWay
  4. Request that UserWay correct the specific Personal information that UserWay is holding
  5. Request that UserWay erase Its Personal information
  6. You have the right to complain to a Data Protection Authority if you believe that your rights have been violated

8. COMPLIANCE

If you believe that we have not adhered to our Policy as outlined herein, please notify us by email to support@userway.org. UserWay will examine any query and make commercially reasonable efforts to resolve any existing or potential dispute. Note that when you send us a request to exercise your rights, we will need to reasonably authenticate your identity , location, and may ask further questions to understand the nature and scope of your request.

9. UPDATES

UserWay reserves the right, at its sole discretion, to change or modify or to add or remove portions of the Privacy Policy at any time ("Updates"). You will be deemed to have accepted any Update by continuing to use UserWay.

10. GOVERNING LAW

This Privacy Policy shall be construed in accordance with and governed for all purposes by the substantive laws of Delaware US without regard to conflicts of law provisions. You agree that any claim or dispute you may have against UserWay and its affiliates, directors, officers, employees, and representatives must be resolved by a court located in Delaware US, and waive any jurisdictional, venue or inconvenient forum objections to such courts.

11. CONTACT US

If you have questions or comments about the Privacy Policy or UserWay's data collection in general, please send us an email at support@userway.org or contact us by mail: UserWay Inc. 1007 N. Orange St., 10th Floor Wilmington, DE 19801 USA.

By using the Service and/or accepting our Service Terms and Conditions, you hereby agree to the collection and use of your information as we have outlined in this Privacy Policy.

Capitalized terms used and not otherwise defined herein, shall have the respective meanings ascribed to them under our Service Terms of Use.

Last modified: 18 January 2023