Privacy policy
Last updated 10th August, 2023
This Privacy Policy is a part of Terms and Conditions and contains information about collecting users’ personal data and other information and the manner of its processing during use of 2WAY MESSAGE services as we respect your right to privacy and to be well informed. The acceptance of Terms and Conditions for the use of 2WAY MESSAGE services means accepting this Privacy Policy without any reservations. When we refer to “2WAY” or “2WAY MESSAGE”, we mean the 2WAY entity that acts as the controller or processor of your information.
This Privacy Policy applies to 2WAY’s tools and platform, including the 2WAY mobile and desktop applications (collectively, the “Services”), 2way.app and other 2WAY websites and other interactions (e.g. customer service inquiries, user conferences, etc.) you may have with 2WAY.
This Privacy Policy does not apply to any third party applications or software that integrate with the Services or any other third party products, services or businesses.
2WAY:
- takes reasonable and appropriate technical and operational measures to protect your personal data and hold your personal data from loss, misuse and unauthorized access, disclosure, alteration, and destruction
- takes into due account the risk involved in the processing and the nature of the personal data.
HOW DO WE COLLECT PERSONAL INFORMATION?
We collect information about users’ personal data when:
- you register on our website/to our Services or
- fill out a form or
- in connection with the correspondence between us and the user (used strictly to answer to your correspondence).
Some of the provided user’s information such as: your IP address, domain, browser type, operation system type etc. may be automatically acquired when a user visits our websites.
Please be aware that all personal information is collected and processed in accordance with principles and rules of GDPR (General Data Protection Regulation (EU) 2016/679).
WHAT CATEGORIES OF DATA DO WE COLLECT?
When ordering our Services or contacting 2WAY you may be asked to enter your name, surname, company business name, email address, credit/payment card information, industry, company size, phone number. Aforementioned data is necessary to complete user registration and at the same time to ensure access to 2WAY services. Those data are collected by 2WAY.
Please note that you as a user are fully responsible for lawfully obtaining data in accordance with the applicable law, as well as lawful entrusting of such data to us for processing as we collect and process data entered by you to 2WAY. Details of your liability for the aforementioned data you may find in Terms and Conditions in part “Limitation of liability”. To make it clear - you are the owner of such data and you are responsible for collecting personal data in compliance with all applicable law provisions.
Taking the above into account we may collect information regarding data subjects as follows: users of 2WAY and data collected by them in 2WAY, visitors of 2WAY websites and individuals who may contact us via our websites.
WHAT DO WE USE YOUR INFORMATION FOR?
2WAY’s main purpose of collecting users’ information (including personal data) and using it is to make our services available to you and to communicate with you if applicable.
We can also collect and use users’ information to upgrade and improve functionality of our services.
Your information helps us to better respond to your individual needs and understanding them. We use the information you provide us in order to:
- personalize user’s experience
- improve our services
- process transactions
- provide you with customer service
- prepare advanced statistics and analysis
- to send periodic e-mails.
We collect and process such data collectively and anonymously.
We may also partner with selected third-party vendors such as Google Analytics, Google Tag Manager, LiveChat, Amplitude, Hubspot, Albacross and others to allow tracking technologies and remarketing services on the website and 2Way Message applications through the use of first party cookies and third-party cookies to analyze and track user's use of the website. By accessing our website or 2Way Services you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their privacy policies. We do not transfer personal information to these third-party vendors.
And what about profiling personal data?
By using our services you give us consent to the profiling of personal data for the purpose of maintenance and providing Services to you. Thanks to this, we may provide you accurate content. We inform you that you have a right not to be profiled. If so please inform us about your request via email - such request is tantamount to the termination of the agreement for using our Services.
And what about geo-location?
2WAY may have access to your geo-location data (as we collect and process IP addresses) regarding devices you use while using our services.
And what about social media widgets?
As you can see our website contains social media widgets/features (Instagram, LinkedIn, Twitter).
Please be aware that those widgets/features:
- may collect your IP address
- may set a cookie to enable the features to function in the proper way
- are hosted by a third party or hosted on your site - they are governed by the third party privacy policy.
Through them, we provide up-to-date information about our activities, services, promotions, news and we create a platform for exchange views. Therefore, on the basis of 2WAY legitimate interest, personal data of people using our social media profiles (e.g. in reaching our customers, responding to comments) and the data that we access if you use a social media plugin within our website (in terms of statistics purposes of our website).
Please remember that the processing of personal data on social media is subject to the privacy rules of the respective social media provider. Therefore, we encourage you to read the rules of the social media providers we use to maintain our social media profiles:
- LinkedIn, provided by LinkedIn Corporation (1000 W. Maude Avenue, Sunnyvale, CA 94085, United States of America), and for users within European Union, European Economic Area and Switzerland LinkedIn Ireland Unlimited Company (Wilton Plaza, Wilton Place, Dublin 2, Ireland) Privacy policy
- Instagram, provided by Meta Inc. (1601 S. California Ave, Palo Alto, CA 94304, United States of America), and for users within European Union Meta Ireland Ltd. (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) Privacy policy
- Twitter, provided in the European Union, EFTA countries and the United Kingdom is Twitter International Company (One Cumberland Place, Fenian Street Dublin 2, D02 AX07 Ireland), and for other users Twitter Inc (1355 Market Street, Suite 900, San Francisco, CA 94103 United States of America) Privacy policy
Something about data integrity and purpose limitation
Personal data collected by the 2WAY is relevant to the purposes for which data is collected. We ensure that they will not be used by us for other purposes unless you authorize us to do so. We will make an effort to ensure data is reliable for its intended use, accurate, complete and current. Taking it into account we may contact you occasionally to check that your data is still accurate and current.
HOW DO WE PROCESS THIRD PARTY INFORMATION?
Users may process personal data and third party information by using 2WAY services. 2WAY shall treat personal data owned by the user and processed via 2WAY services as confidential. 2WAY shall not use the information for any other purpose than to provide you with high quality and secure services and shall comply with Privacy Policy. The content (including personal data) that You submit in 2WAY may be transmitted through technology providers and infrastructure systems.
HOW DO WE PROTECT YOUR DATA?
the security of your personal data is our main concern. We follow high industry standards to protect the personal data processed via our services and products, both during transmission and once we receive it.
We remind you however, that no method of internet transmission or electronic storage is 100% secure. 2WAY takes every possible step to keep the data protection system up to date and modern.
2WAY uses technical and organizational measures and the highest security to protect the provided data against loss, destruction, misuse, unauthorized access or disclosure. The used measures and technology ensure complete safety of the data provided by the user. We use a secure socket layer (SSL) during the registration process and to fulfill payments by credit card.
DO WE COLLECT CHILDREN PERSONAL DATA?
2WAY services are addressed to business companies. 2WAY does not collect personal information from anyone under the age of 18. If you notice we collect and process personal data of anyone under this age incorrectly, please contact us immediately.
As a responsible company we encourage parents/legal guardians to monitor their children’s behavior on the Internet.
DO WE SELL OR DISCLOSE YOUR PERSONAL DATA DO THIRD PARTIES?
We do not sell, trade or otherwise transfer to outside parties your personal identifiable information. In particular, we shall transfer no information or personal data to third parties for marketing purposes without your prior consent.
This does not include trusted third parties who assist us in operating our services, so long as those parties agree to keep this information confidential and use proper security measures.
Please be aware that we may also release your information when we believe in good faith that disclosure is appropriate to comply with the law such as to comply with a subpoena, or similar legal process and it is necessary to protect our rights, your safety or the safety of third parties, investigate fraud, respond to government request or if it is necessary for the 2WAY’s security and its rights protection.
2WAY reserves the right to disclose personal data and other information relating to the user to third parties affiliated with 2WAY connected with providing services and its current business activity, such as payment processing, providing customer support and sending emails out on our behalf.
Users’credit/payment card data shall be disclosed solely to service providers that conduct non-cash transactions strictly for purposes related to payments process.
We may share you personal data with:
- parent, subsidiary, affiliated or successor companies
- third party service providers e.g. hosting, credit card processing, e-mail, support services providers - if requested we can provide you the list of those providers. Be sure that those entities have minimum access to your personal data, only to those necessary to services to be provided
- entities into which our company is merged or in case of any transfer of the company (please be aware that those entities will comply with those Privacy Policy) - we will notify you promptly about such events by updating Privacy Policy and if possible via other means.
If we share data with third parties they will be required to use your data in a manner that is consistent with this Privacy Policy.
We will provide an individual opt-out choice before we share data with third parties other than mentioned above or before we use it for a purpose other than which it was originally collected or subsequently authorized.
To limit the use and disclosure of your personal data, please submit a request via email.
Please be aware of an exception to opt-out choice - it would be where we are required to disclose your personal data pursuant to governmental or judicial order, law or regulation to meet national security or law enforcement requirements.
Some information about accountability for onward transfer
All personal data is being processed by 2WAY within the European Economic Area (EEA).
2WAY may transfer personal data only to third parties that are obliged to provide at least the same level of privacy protection to you data as we and as required by the Principles of the EU-U.S. Privacy Shield Framework and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).
We will only transfer data to our third party providers (such as consultants, accountants, attorneys, and sub-processors) who need the information in order to provide services to or perform activities on our behalf and only for a purpose consistent with this Privacy Policy.
HOW DO WE USE COOKIES?
The so called ‘cookies’ may be used while using services or products rendered by 2WAY. These are pieces of information sent by the server, stored on a user’s computer for the purpose of automatic identification of a particular user when using our services.
‘Cookies’ enable us to quickly confirm your identity and owing to them the use of our services becomes much easier and more widely available. ‘Cookies’ are used by 2WAY solely with the purpose of personalizing a particular user. ‘Cookies’ can be used on condition that they are accepted by a browser and that they shall not be removed from the storage media.
Users who removed ‘cookies’ from their storage media or have not accepted them on their browser may not have access to products or services rendered by 2WAY. We do not link the information we store in cookies to any personal data you submit while on our site.
The use of third party cookies is not covered by our privacy policy. We do not have access or control over these cookies.
WHO IS THE DATA GATHERING ENTITY?
Conducting its activity, under the business name of 2Way Inc., with its registered seat at 382 NE 191st St #77112 Miami, FL 33179-3899, United States of America, registered in Delaware, file number: 4718018 shall be the entity gathering personal data and other information.
HOW TO CHANGE OR DELETE MY DATA?
If your personal data changes, or if you no longer desire our service, you may correct, update, delete inaccuracies or request deactivation of your account by emailing us at [email protected]
At any time you have the right to access your personal data - look into the part “How to contact us”.
Our websites contain links to other sites that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other sites.
Using offered products and services rendered by 2WAY, the user is obliged to comply with rules contained in the Terms and Conditions.
We will respond to your request within 30 days.
RECOURSE, ENFORCEMENT AND LIABILITY
Please be informed that in case:
- we are not in compliance with our Privacy Policy
- if you have any questions
- if you wish to take any other action concerning this Privacy Policy or your personal data
feel free to contact us and let us know about your concerns.
As the safety of your personal data means a lot for us, be sure that we will investigate your complaint, take appropriate action and report back to you within 30 days.
DO WE MODIFY THIS PRIVACY POLICY?
We may update this Privacy Policy to reflect changes to our information practices or requirements of law.
In case of any material changes you will be notified by email (sent to the e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective.
HOW TO CONTACT US?
In case of any questions regarding this Privacy Policy please feel free to contact us via
- the following email: hello@2way.app
- or text us at: +44 7520 642111 or +1 (650) 434-4000.