Chatway, Inc. (in this Policy: “us“, “we” and “our“) respects your privacy.
This Policy (the “Policy”) explains our privacy practices for our Services at www.chatway.com and any related domain names as well as through our “Chatway” mobile application (collectively – the “Service” or the “Services”). It describes the ways your personal information and data is collected and used and the rights and options available to you with respect to your information.
You are not legally obligated to provide us Personal Data and may do so at your own free will. If you do not agree to provide us with such data or have it processed by us or any of our service providers, please contact us or not enter our Sites or use our Service.
PERSONAL INFORMATION WE COLLECT
Device and traffic information – information identifying and relating to your computer and mobile device and communication and transmission data that your computer and mobile device generates when you use the Service;
Personal information – information that you provide us when you register to the Service or when you communicate with us or other users of the Service, including any personal information that becomes available to us when you register to the Service through a social network account, such as your basic profile information, your contacts, email addresses, photos/videos and any other content available therein (in accordance with your privacy settings on any such social network).
We collect data related to your use of the Service, such as information about your geographic location, the frequency of your use of the Service and content that you viewed, created or uploaded when using the Service. We may collect communication and transmission data that your computer and mobile device generates or stores to help us provide the Service. For example, we may collect and receive the operating system version you use once you register to the Service.
We collect Device Information using the following technologies:
– “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
– “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
– “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.
Use of the Service and the creation of an account are available to registered users only. When you register with the Service we may ask you to provide us with certain contact information and personal details, such as your full name and an active e-mail address and to enter a username and password or provide other details or attributes that define you as a user (such as your profile picture). We may collect additional information, as required, when we exchange communications with you.
Registration may also be available through social networks accounts, such as Facebook, Google and LinkedIn. When registering through your social network account, you are allowing us access to your basic profile information (such as your name, age, email address). We can only access the information that your social network operator makes available to us, according to your privacy settings on such social network.
Please bear in mind that false, incorrect, or outdated, abusive or unlawful information may prevent you from registering and may impair our ability to provide you the full scope of the Service, or to contact you.
When you register with the Service, you may be required to provide a username and set a unique password that will identify you each time you enter the Service. We may require other or additional means or methods of identification, from time to time.
Additionally, when you subscribe to the service, we collect certain information from you, including your name, billing address and payment information (including credit card numbers and PayPal ID). We refer to this information as “Billing Information.”
The following information is collected from you without receiving your definitive consent:
The last time you entered the app, Registration date, First seen date, Browser name, Browser version, Browser language, Operating system, App version, Number of total sessions, Twitter profile URL, LinkedIn account URL, Initial IP Address, Initial Location, Session times, Actions performed.
This information is being collected only in order to give you the best possible service and support. You’ll be able to see more information on the reasons we collect and use this data in the following section “How we use your personal information”.
INFORMATION RECEIVED BY INTEGRATION OF SERVICES BY THIRD PARTY PROVIDERS
In order to facilitate the usage of the application and enhance its features and capabilities, the Service enables users to integrate a selection of services offered by third-party providers. We handle data transferred, acquired, processed or shared from/to these services in the same manner we do for data originating from Chatway and are subject to this Policy.
As required by some of these service providers, we disclose further specific information regarding the manner of access, usage, storing and sharing of data originating from third-party providers/services:
- The Service allows users to register using their Google account, obtaining basic profile information such as name, email and image.
- The Service allows users to integrate Google Drive cloud storage using their Google account in order to view, manage and share folders/files from their Google Drive storage directly through the Service. Files are not stored by us, but only referred to, unless users actively share them, which may require further processing (e.g. for conversion).
- The Service allows users to integrate Google Calendar using their Google account in order to view, manage and share scheduled events from their Google Calendar directly through the Service.
- The Service allows users to integrate Microsoft Calendar using their Microsoft 365 or Outlook-Exchange account in order to view, manage and share scheduled events from their Calendar directly through the Service.
HOW WE USE YOUR PERSONAL INFORMATION
We use Personally identifiable information to:
- Provide you with the Service, its features and functionalities.
- Send you notices and updates, to conduct surveys related to the Service and to provide you with information related to the Service – through the Service interface or through e-mail, as available.
- Respond to messages that you send us, and to allow us to provide support and assistance.
- Improve and customize your and other users’ experience with the Service.
- Enhance existing features of the Service and to develop new features and services.
- Prevent fraud, misappropriation, infringements, identity thefts and any other misuse of the Service.
- Facilitate our internal managerial, archival, administrative and audit activities.
- Contact you as and when we believe it to be necessary.
- Enforce the Terms and this Policy and prevent misuse of the Service;
- Comply with any applicable law and assist law enforcement agencies or competent authorities under any applicable law, when we have a good faith belief that our cooperation with such entities is legally mandated or meets the applicable legal standards.
- Take any action in any case of dispute, or legal proceeding of any kind between you and us, or between you and other users or third parties with respect to, or in relation with the Service.
We use the Device Information that we collect to:
- Improve and optimize the Service (for example, by generating analytics about how our customers browse and interact with the website or Service, and to assess the success of our marketing and advertising campaigns).
- Provide you with better customer support in case of any difficulty using the Service.
- Curating the interface according to your browser and operating system.
SHARING YOUR PERSONAL INFORMATION
We share your Personal Information with third parties to help us use it as described above.
We mainly do this in the following instances:
- To operate, maintain and enhance the Service;
- To execute purchase transactions, which involve or relate to third parties such as payment providers and clearance services.
- If you have breached the Terms, abused your rights to use the Service, or violated any applicable law. Your information may be shared with competent authorities and with any third party, as may be required;
- If we reasonably believe that we are required by law to share or disclose your information;
- In any case of dispute, or legal proceeding of any kind involving you with respect to the Service;
- If the operation of the Service is organized within a different framework, or through another legal structure or entity (such as due to a merger or acquisition), provided that those entities agree to be bound by the provisions of this Policy, with reasonably necessary changes taken into consideration; and
- Personally identifiable information may be shared with our subsidiaries, sister-companies and parent companies, but their use of such information must comply with the Policy.
These are the third party subprocessors we share your information with on a regular basis:
We specifically use Google Adwords for remarketing. This means we will continue to show ads to you across the internet, specifically on the Google Content Network (GCN).
You can also opt-out of Google Analytics here https://tools.google.com/dlpage/gaoptout
We specifically use Facebook’s Custom Audience Pixel for retargeting. This allows user behavior to be tracked after redirected to our website by seeing or clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, i.e. we do not see the personal data of individual users. However, this data is stored and processed by Facebook. Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook’s Data Usage Policy https://www.facebook.com/about/privacy/. You can allow Facebook and its partners to place ads on and off Facebook. A cookie may also be stored on your computer for these purposes. You can object to the collection of your data by Facebook pixel, or to the use of your data for the purpose of displaying Facebook ads by contacting the following address: https://www.facebook.com/settings?tab=ads.
Subprocessor Obligations – Where Chatway authorizes a subprocessor to process your Personal Data, we entered into a written agreement with each such subprocessor that contains provisions that are consistent with those contained in this policy.
In any case other than the above, your personally identifiable information will be shared with others only if you provide your explicit prior consent.
DE-IDENTIFIED OR AGGREGATED INFORMATION
We may use de-identified, statistical or aggregated information, including information that we process according to this policy, to properly operate the Service, to develop and improve the quality and functionality of the Service, to enhance your experience, to create new services, including customized services, to change or cancel existing features and for other research, development and statistical purposes. We may share, publish, post, disseminate, transmit or otherwise communicate or make available such information to suppliers, business partners, sponsors, developers, affiliates and any other third party, at our sole discretion, provided however, that we will not knowingly, or intentionally share information that can be reasonably used to reveal your identity without your consent.
SECURING YOUR PERSONAL INFORMATION
We and third parties on our behalf implement security measures to secure the information we store and process. While such security measures reduce the risk of security breaches, they do not provide absolute security. Therefore, while we take reasonable measures to secure the information, we cannot guarantee that it will be immune from any wrongdoings, malfunctions, unlawful interceptions or unauthorized access.
We retain different types of personally identifiable information for different periods, depending on the purposes for processing the information and our legitimate business purposes. When we no longer need to process the information that identifies you, we may take measures to de-identify the information.
Generally, as long as you are a user of the Service, we do not delete information related to you, unless there are technical reasons that require us to retain only portions of the data, or if we are required by law to delete it. This was decided for restoring purposes in case of crashes.
Please note that we will retain and disclose information when we deem it necessary to satisfy orders issued by courts and government authorities. We will notify you about the disclosure, only if we are explicitly permitted to do so. In any case, we may keep any aggregated or anonymous information for statistical, development, marketing and other purposes, indefinitely.
Some of the Cookies may expire when the session ends and you exit your browser. Other cookies are saved on your computer’s hard drive. If you wish to block our cookies, you may do so by clicking the “options” button on your browser’s menu and follow the necessary instructions. You can read your browser’s Help file of for further information. However, bear in mind that disabling cookies may complicate or even prevent the use of the Services, or certain features thereof.
You have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us at firstname.lastname@example.org
Before allowing you to exercise your right, we will need to verify your identity. We will make the information available to you, subject to any legitimate constraints and pursuant to the applicable law. We may refuse your request, for example, if we are unable to identify you, or if we believe that removal of certain information may jeopardize activities or features of the Service, harm other users, or compromise our legal rights.
We may provide you additional options to delete your personal information through the settings and preferences features of the Service. You may access your account and edit or amend the personal details that you provided during registration at any time, through your account settings or by updating the information of your social network account that you provided to register with the Service. If you find that the information on your account is not accurate, complete or updated, then you may make all necessary changes to correct it.
Additionally, we note that we are processing your information in order to fulfill contracts we might have with you, or otherwise to pursue our legitimate business interests listed above.
Please note that your information will be transferred (mainly through cloud services) outside of Europe, including to Canada and the United States. If you disagree with such transfer, please contact us by the e-mail mentioned above.
REPRESENTATIVE IN THE EU
Chatway Inc. is a company located outside of the European Union. In order to comply with Art 27 EU GDPR, “GDPR-Rep.eu” has been nominated as our representative in the European Union. If you want to make use of your data privacy rights, please visit our public Privacy dashboard at https://gdpr-rep.eu/q/18343006
You may also contact GDPR-Rep.eu by mailing this address:
Maetzler Rechtsanwalts GmbH & Co KG
Attorneys at Law
c/o Chatway Inc.
Schellinggasse 3/10, 1010 Vienna, Austria
Please add the following subject to all correspondence:
GDPR-REP ID: 18343006
We do not allow children under the age of 13 to use the Service. If you are not yet 13 years of age, then you may not use the Service and must not provide any personal details to us.
We do not intentionally collect personal information about children who are under 13 years of age. If we learn that a child under the age of 13 provided personally identifiable information to us without verifiable parental consent, we will use commercially reasonable efforts to delete such information from our databases.
We strongly encourage parents to monitor their children’s use of online and mobile applications. We will delete a child’s personally identifiable information if a parent so requests by contacting us at email@example.com.
SECURITY AND PRIVACY RECOMMENDATIONS
We ask you to keep your username and password in absolute confidentiality and refrain from disclosing them to others. Make sure that you change your password frequently and at least once every six months.
Bear in mind that when you upload your content to the Service, depending on the target destination, it may be displayed to other users of the Service. As soon as your content is displayed publicly, it will not be considered private or confidential and you should not have any expectation of privacy with respect to it.
PLEASE USE CAUTION AND COMMON SENSE WHEN YOU UPLOAD ANY PERSONALLY IDENTIFIABLE INFORMATION. YOU ARE SOLELY RESPONSIBLE FOR ANY CONTENT AND INFORMATION THAT YOU UPLOAD.
We may also amend this Policy to comply with any legal requirements. In these cases, the amendments will become effective as required or ordered and we will send you a notice of such change.
We are doing our utmost to comply with this Policy. If you have any questions, concerns or complaints regarding this policy, please refer them to firstname.lastname@example.org. After receiving your request, we may contact you to better understand your concerns and will make all efforts to promptly answer your question, or resolve your complaint.