1. THE INFORMATION USERWAY COLLECTS AND HOW IT IS USED
Personal Data and Usage Data shall be referred to together as the “Information”.
- Information Collected when browsing the Website (the “Personal Data”).
- While browsing the Website, Visitor may be requested to provide UserWay with certain information such as, Visitor’s name, phone number, IP address, email and other data which may be requested by UserWay.
- Additional information may also be collected by UserWay when a Visitor decides to contact UserWay’s customer support, sends UserWay other communications, signs up for UserWay’s newsletters or special offers (if applicable), or subscribes for and uses the service offered by UserWay (the “Service”).
- Information Collected via the Website (the “Usage Data”).
- Information is collected when Visitors contact UserWay’s support, send UserWay other communications, sign up for newsletters or special offers, or subscribe to UserWay’s Service.
- Cookies. Like many other websites, UserWay uses “cookies” to collect data relevant to Visitors’ activities on the Website. UserWay presents a banner to Visitors to facilitate their choices as to what cookies can collect. As a Privacy By Design company with data minimization practices, UserWay minimizes the information stored in cookies. Visitors can always disable cookies at their browser. If Visitors disable the cookies, some (or all) of the features and functionality of the Website may not be available to such Visitors.
- UserWay may also use other technologies (such as web beacons) to collect anonymous non-personally identifiable information. Such information may include Visitor’s IP address, browser type, referring website, site usage, and whether Visitors opened emails they received from UserWay.
- Web pages that Visitors visit; and
- Any other data normally stored in website logs such as pages on our website accessed and time of day.
2. WHAT USERWAY DOES WITH THE INFORMATION
UserWay is a Privacy By Design company, and gathers information with the aim of servicing its Customers best. UserWay does not sell the information it has on its Visitors’ and has no business model based on monetizing this data. For transparency, we are pleased to share how the Information will be used, in accordance with applicable laws for the following purposes:
- Improve the functionality, design and quality of the Website and Service.
- UserWay may occasionally inform Visitors (if such Visitor agrees to receive such notifications from UserWay) of new features, functionality, services and products, and other promotions from UserWay as well as send Visitors periodic updates, tips and newsletters.
- To respond to questions and comments from Visitors.
- To provide customer support, and in order to detect, prevent and address technical issues.
- To gather analysis or valuable information enabling UserWay to monitor the usage of the Website.
- UserWay may post Visitors’ testimonials on the Website which may contain personally identifiable information. By providing such testimonial to UserWay, the Visitors hereby agree and consent that UserWay will post Visitor’s name along with Visitor’s testimonial.
- UserWay will retain the Information until the Visitor requests to delete the Information.
3. SPECIFIC PROVISIONS FOR VISITORS FROM THE EUROPEAN ECONOMIC AREA (EEA)
- UserWay needs to perform a contract with such Visitor;
- The Visitors have given UserWay permission to do so;
- The processing is in UserWay’s legitimate interests and is not overridden by Visitors’ rights;
- To comply with the law.
- VISITORS’ DATA PROTECTION RIGHTS UNDER GENERAL DATA PROTECTION REGULATION (GDPR)
- If a Visitor is a resident of the European Economic Area (EEA), such Visitor have certain data protection rights. UserWay aims to take reasonable steps to allow any Visitor to correct, amend, delete, or limit the use of its Personal Data.
- If a Visitor wishes to be informed what Personal Data UserWay holds about them, or if a Visitor wishes that such Personal Data will be removed from UserWay’s systems, please contact UserWay via email email@example.com and write “GDPR Request ” as the subject of message. UserWay will send the applicable Visitor a reply e-mail within 30 days once it confirms the Visitor’s request.
- In certain circumstances, a Visitor may have the following data protection rights:
- The right to access, update or to delete the information UserWay has on such Visitor. If needed, assistance may be provided by contacting UserWay.
- The right of rectification. A Visitor has the right to have its information rectified if that information is inaccurate or incomplete.
- The right to object. A Visitor has the right to object to UserWay’s processing of their Personal Data.
- The right of restriction. A Visitor has the right to request that UserWay restrict the processing of their personal information.
- The right to data portability. A Visitor has the right to be provided with a copy of the information UserWay has on them in a structured, machine-readable and commonly used format.
- The right to withdraw consent. A Visitor also has the right to withdraw their consent at any time where UserWay relied on their consent to process their personal information.
- UserWay may ask a Visitor to verify their identity before responding to such requests.
- A Visitor has the right to complain to a Data Protection Authority about UserWay’s collection and use of their Personal Data. For more information, please contact a local data protection authority in the European Economic Area (EEA).
4. SPECIFIC PROVISIONS FOR VISITORS FROM CALIFORNIA, UNITED STATES UNDER CALIFORNIA DATA PROTECTION RIGHTS LAWS.
- If the Visitor is a California resident who provides personal data in obtaining products or services for personal, family or household use, California Civil Code Section 1798.83, permits the Visitor to request in writing and obtain from UserWay, twice per calendar year, information about the Information shared by UserWay, if any, with other third parties for their own direct marketing purposes.
- If applicable, such Information would include a list of the categories of the Visitor’s data and the names and addresses of those businesses with which UserWay have shared such Information during the preceding calendar year (i.e., requests for information made in 2021, will receive data regarding 2020 sharing activities).
- To make such a request, Visitors are kindly requested to contact UserWay at firstname.lastname@example.org and write “Request for California Privacy Data” as the subject of message. UserWay will send the applicable Visitor a reply e-mail within 30 days containing the requested data once it confirms the Visitor’s request.
- Please note that not all of the shared Information is covered by these requirements and therefore only data which is covered will be included in UserWay’s response.
5. STORING THE INFORMATION
- UserWay will retain any Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of UserWay’s Website, or in case UserWay is legally obligated to retain this data for longer time periods.
6. SHARING INFORMATION WITH THIRD PARTIES
UserWay will be entitled to share Information with third parties, as follows:
- UserWay may disclose general aggregate deanonymized information to potential business partners, investors, or the public, but UserWay will not, without Visitor’s specific permission, disclose any of Visitor’s Information to third parties.
- If UserWay becomes involved in a merger, acquisition, or any form of sale of some, or all, of its assets, UserWay may transfer all the Information in connection with such transaction.
- UserWay may use and share Information with certain third parties that assist UserWay to operate the Website (e.g. cloud providers, email distribution service providers, CRM providers, support ticketing providers and other similar service providers). Such third-party providers will have access to the Information as required to perform their functions but may not use it for other purposes.
- UserWay may share the Information with UserWay’s affiliates and subsidiaries.
- UserWay may share Information with third parties in order to comply with any applicable law, legal process, preventing fraud or imminent harm, ensuring the security of the Website, and when UserWay believes that disclosure is necessary to protect UserWay rights.
7. THIRD PARTY WEBSITES
8. INFORMATION SECURITY
- UserWay is a ISO 27001 certified and audited company, committed to ensuring that any information that is collected by UserWay remains secure. 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.
- Visitors can request additional information about our certification by writing to email@example.com, subject line, “Security Inquiry”.
9. CHILDREN’S PRIVACY
- Visitors must be at least thirteen (13) of age to access UserWay’s Website. UserWay’s Service must not be used by individuals who are under the age of eighteen (18) without parental consent (collectively, “Children”).
- UserWay does not knowingly collect personally identifiable information from anyone under the age of eighteen (18). If a parent or guardian is aware that their Children have provided UserWay with any Personal Data, they are requested to contact UserWay. If UserWay becomes aware that it has collected Personal Data from Children without verification of parental consent, UserWay will take steps to remove that information from its servers.
10. EMPLOYMENT CANDIDATES
When submitting your CV for employment opportunities UserWay will retain your personal information as it appears in your CV and/or as derived from your interview, for a period of 18 months (for job postings in the EU) or indefinitely (for job postings outside of the EU) from receipt of the information by our recruiting systems. Should you wish UserWay to remove your personal information before then, please contact us at firstname.lastname@example.org
- If you believe that we have not adhered to our Policy as outlined herein, please notify us by email to email@example.com. 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 may need to reasonably authenticate your identity , location, and may ask further questions to understand the nature and scope of your request.
Last modified: 19 January 2023