Privacy Notice

Last updated – February 2019

​

Welcome to EasyWay Ltd. (“EasyWay”, or “we”). We care about your privacy and are committed to protecting our users' right to privacy.

This Privacy Notice (“Privacy Notice”) governs the manner in which we collect, use, process, maintain and disclose information collected from users (each, a “User”, or “you”) via our website, available at: www.easyway.ai (“Site”) our dashboard platform for massaging communication for our Customers (as defined below) (“Platform”) and/or through services provided through the Site or otherwise by EasyWay (together, the “Services”).

If you choose to use the Services, interact with the Site, or otherwise provide data to us, you explicitly agree to the use of such data in accordance with this Privacy Notice. You may not use the Site and Services, or submit any data through them if you do not agree to any of the terms hereunder. This Privacy Notice shall not be construed in any manner to derogate from our terms and conditions of EasyWay in connection with the Site and Services or any other agreement or understanding between EasyWay and you (“Terms”).

Please note, that the Site and the Services may contain links to other websites, products or services offered by third parties, which are not governed by this Privacy Notice. This Privacy Notice does not apply to the practices of entities which are not controlled by EasyWay.

 

THE HIGHLIGHTS:

• You are not required by law to provide us with any Personal Data (as defined below). Sharing Personal Data with us is entirely voluntary.

• Certain of our Services, such the Platform, are designed for our Customers (i.e. hotels). As a Guest (defined below) you may be offered by the hotel that you are staying to communicate with the hotel via the Platform, which includes communication through various massaging services (e.g. Facebook Messenger, WhatsApp Messenger, SMS, etc.). Please note that in such case we are processing Personal Data on behalf of the Customers, and your use of the Platform, including any services offered by the hotel, shall be subject to the hotel's policies. The privacy and security practices of our Customers are not covered by this Privacy Notice.

• By engaging with us to receive the Services, You expressly agree and unequivocally consent to the processing of Personal Data in accordance with this Privacy Notice.

If you have any questions regarding the processing of your Personal Data or would otherwise like to contact us in connection with this Privacy Notice, please send us an email to: [office@easyway.ai].
 

• Our Services are intended for Users over the age of 16 or equivalent minimum age for providing consent to processing of Personal Data in the relevant jurisdiction. Children under such age are not permitted to use the Services. If you are under such age you should cease to use the Services immediately.

• EasyWay does not knowingly collect or process any sensitive Personal Data, defined under the GDPR as “Special Categories of Personal Data”.

• You may request to review, amend, erase or restrict the processing of your Personal Data retained by EasyWay in accordance with applicable law. Please note that in case you request to erase or restrict the processing of your Personal Data, we may not be able to provide you with some or all of the Services.

• We may transfer your Personal Data outside the geographical region through which collection or access to the Services is made. By using EasyWay's Services, You expressly agree to such transfer. If the level of privacy protection in a country does not comply with recognized international standards, we will ensure that data transferred to our databases in that country is adequately protected and that the transfer of data to third parties in such countries is made pursuant to a contract or other measures providing adequate protection.

• We do not sell, trade, or rent Users Personal Data to third parties. We share Personal Data with third parties in connection with the provision of the Services to our Users and as otherwise stated in this Privacy Notice.

1. What is Personal Data, and what data is collected about me by EasyWay?

“Personal Data”, means any information which identifies or can be used to identify a natural person, including, but not limited to, first and last name, phone number, email address, IP address, credit card information, etc.

Non-Personal Data.

We collect non-Personal Data regarding Users concerning their use of the Website and/or Services, such as the scope, frequency, latency, pages accessed, what and when a User views or interacts with content and materials displayed through our Site and the Services, device identifiers, and other technical information regarding the device used to access the Site and Services, such as model, operating system, etc.

Personal Data.

1. 1. Site. We collect Personal Data you submit to us actively via the Site, for example when you choose to fill details in the “Contact Us” feature on our Site, you will be requested to provide certain Personal Data, such as your name, e-mail address and the content of your massage.

   2. We log users Internet protocol (IP) address and collect certain data regarding your use of the Site, such as the frequency and the extent of your use.

   3. Platform. We process Personal Data, on behalf of the hotels that use our Platform and Services, regarding the hotels' guests (“Guests”), such data includes phone number and the content of the massages. These hotels constitute our customers (“Customers”) and the Controllers of the Guests' Personal Data and we process Personal Data on their behalf. The privacy and security practices of our Customers are not covered by this Privacy Notice.

   4. We do not knowingly collect or process any Personal Data included in Special Categories of Personal Data (as defined in the GDPR). In the event you become aware that such data has been posted to the Website or collected by us, please inform us immediately.

2. What will EasyWay do with my data?

   1. Non-Personal Data. Non-Personal Data is used mainly for click stream analysis in order to constantly improve and maintain our Site and Services, including among others, in order to measure and understand the level of engagement to our Services, for general business analytics and in order to provide a more personalized experience and tailored content, for ensuring the technical functioning of our network, to help prevent fraudulent use of our Services and for developing new services and features.

We may use information in the aggregate to understand how our Users as a group use the Services and resources provided on our Site. This information is statistical in nature.

1. 1. Personal Data. Personal Data is used only for the following limited purposes:

      1. To provide our Customers the Services, including the Platform and its operation and maintenance.

      2. To resolve any disputes, communicate with Users regarding customer service and support issues, and to respond to questions or comments and help resolve any problems.

      3. To prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts and any other misuse of the Site or the Service and to enforce our Terms.

      4. To protect the security or integrity of our databases and the Services, and to take precautions against legal liability.

      5. To improve the Services, and to develop new features, products and services.

      6. To improve your experience on the Site and customize our Services to your interests, including by way of targeted advertising.

      7. For the purposes of our legitimate interests, to the extent not overridden by the rights and freedoms of natural persons, as permitted under applicable law.

      8. To provide updates with respect to material changes to this Privacy Notice.
          

2. Does EasyWay use cookies?  

No.

1. How We Protect Your Data?

We adopt appropriate and generally accepted data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your Personal Data. However, these measures are unable to provide absolute information security. Therefore, although efforts are made to secure your personal information, it is not guaranteed and you cannot reasonably expect that the Site and its related databases will be immune from any wrongdoings, malfunctions, unauthorized interceptions or access, or other kinds of abuse and misuse

1. How Can I Control My Personal Data?

   1. Reviewing and amending your Personal Data. You are entitled to review your Personal Data, and may exercise such right by sending us a request to: [office@easyway.ai]. In the event any Personal Data is incorrect or outdated, you may update and correct such data by providing us with appropriate notification.

   2. Right of erasure and restriction. You may also request the deletion or the restriction of your Personal Data, and EasyWay will comply with such requests, to the extent required under applicable law.

   3. Portability of Personal Data. To the extent relevant to you and to the Services, You may be entitled to request the portability of your Personal Data, and we will comply with such requests, to the extent required under applicable law.

   4. Retention of Data. We reserve the right to retain any Personal Data for as long as reasonably necessary in order to: (i) fulfill the purposes described herein; (ii) in the defense or assertion of legal claims and liability; (iii) for the analysis and development of the Services; and (iv) to comply with applicable law. Non-Personal Data and statistical anonymized data may be retained by us without limitation.

2. Will EasyWay Share My Personal Data With Others?

   1. Non-Personal Data, aggregate and statistical or otherwise anonymized data may be shared without limitation with third parties at our discretion. This information does not contain Personal Data and is used to develop content and services for our Users and clients.

   2. We share Personal Data only under the following limited circumstances:

      1. With trusted partners and third parties who assist us in operating and providing the Services and conducting our business, such as data storage services. For example: we use AWS as our cloud storage service provider.

      2. With third party suppliers who are helping us to deliver the Services. For example, we share Personal Data with a company that provides us with services related to the operation of the Platform.

      3. For personalizing your experience of the Services.

      4. As necessary to help detect and prevent potentially illegal acts and fraud, and to guide decisions about products, services and communications.

      5. With our affiliates and connected companies, such as subsidiaries, sister-companies and parent companies.

      6. To comply with a legal requirement, for the administration of justice, to protect your vital interests or the vital interests of others, to protect the security or integrity of our databases or the Services, to take precautions against legal liability, or in the event of a corporate sale, merger, reorganization, dissolution or similar event.

      7. Other third parties with your consent or direction to do so.

3. What is the lawful basis under which EasyWay processes Personal Data?

   1. Certain processing activities conducted by us are based on the necessity of such activities for the performance of our Services between us and our Users and Customers. For example, we need to process your phone-number, for connecting you to the Platform.

   2. Other processing activities are based on the grounds that they are necessary for the purposes of our legitimate interests or the legitimate interests of a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of natural persons which require protection of Personal Data.

   3. There may be certain processing activities based on your consent to this Privacy Notice. In connection with such activities, you may rescind your consent, by sending us an email to: [office@easyway.ai] Please note that in the event you rescind your consent to the processing of Personal Data, we may not be able to provide you with some or all of the Services.

4. Will EasyWay transfer my Personal Data internationally?

   1. Our databases are currently located in Germany. EasyWay may transfer your Personal Data internationally for the purpose of providing you with the services, if necessary.

   2. Some of our processing activities are made in Israel. The European Commission has decided that the State of Israel ensures an adequate level of privacy and data protection, therefore, in accordance with the GDPR, the transfer of Personal Data from the EU to Israel is lawful and does not require any specific authorization.

   3. Any transfer of Personal Data originating from the EU to a third country shall be made in accordance with applicable law, including by providing adequate protections, or otherwise implementing appropriate safeguards to ensure the protection of our Users' rights.

5. Will I receive promotional materials from EasyWay?

We currently do not send marketing material to Users. Please note that our Customers may use the Platform to send you marketing materials. Such marketing materials are governed by their privacy policies. We recommend you to review the hotels' policies in connection with your right regarding marketing materials.  

1. Persons under 16

Our Site and the Services provided through it is a general audience Site, which is not directed to persons under 16 years old. If a parent or guardian becomes aware that his or her child has provided us with Personal Data without their consent, he or she should contact us immediately. We do not knowingly collect or solicit Personal Data from people under 16 years old. If we become aware that a person under 16 years old has provided us with Personal Data, we will delete such data from our databases.

1. Changes to this Privacy Notice

EasyWay may update this Privacy Notice at any time. We encourage Users to frequently check this page for any changes. You acknowledge and agree that it is your responsibility to review this Privacy Notice periodically and become aware of any modifications.

1. Applicable Laws

The provisions included in this Notice relating to matters regulated under the GDPR will apply only to the processing of Personal Data which is subject to the GDPR in accordance with the applicability provisions contained therein. If the GDPR does not apply to the processing of your Personal Data, some of the provisions above may not apply to you. Otherwise, this notice shall be governed by the laws of Israel.

1. Questions or concerns regarding privacy

If you have any questions about this Privacy Notice, the practices of this Site or the Services, or your dealings with this Site or the Services, please contact us at:[office@easyway.ai], and we will make every effort to resolve your concerns without delay.

You are also entitled to file a complaint with the appropriate supervisory authority in connection with concerns you may have with regards to your privacy and Personal Data.