Privacy Policy

Our activity is to provide smart personal branding and enhanced online presence for individuals by using innovative back-end technologies.

You have chosen to benefit from our Services pursuant to an Agreement.

As we are committed to respect your privacy, such Services will always be provided with your Consent.

In this document, we provide clear information of how your data is processed when You visit our website and when You use our Services.

At any time, please refer to the following definitions:

“Agreement” means a project proposal we made to You to benefit from the Services, a service contract we entered into with your company in relation with the Services; or a purchase or adherence to a selected plan on our website.

“Personal Data” means any information relating to You, as an identified person, directly or indirectly, such as your name, address, marital status, date of birth, gender, office location, position, company name, spoken languages, photos, your identification number, your location data, or factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity, your networks and connections made available to us, or obtained on your behalf and any personal information You would provide us with;

“Consent” means any freely given, specific, informed and unambiguous indication of your wishes by which You, by a statement or by a clear affirmative action, signifies agreement to the Processing of Personal Data relating to You;

“Content” means the information on You, that You will provide us with, so we can implement it on Your Website, such information shall include your Personal Data;

“Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

“Performance of our Services” means the actions necessary for us to provide our Services;

“Service Proposal” means the proposal we made You, describing our Services tailored for your personal situation;

“Services” means all the steps for creating and publishing Your Website online;

“Your Website” means a collection of pages accessible on the World Wide Web or through blockchain technology for which we will obtain and hold an Internet Protocol address and corresponding domain name on your behalf and take such further acts as are necessary to establish the address of the website and on which we will display the adapted, reformated, and otherwise modified Content provided by You, from time to time.

  • 1.1 When signing up and registering

    By signing up to our website, You will be asked to register, so we can identify You. At this stage, we receive and store any information You enter on our website or that You provide us with in any other way. The types of Personal Data collected may include (but is not limited to) your name, address, telephone number, mobile number, e-mail address, birthday, company name, office location, title department, spoken languages, usage information regarding your use of our Services, and browser information.

    The Personal Data You provide is used for purposes such as allowing You to set up a user account and profile that can be used to interact with us. We may also draw upon this Personal Data in order to adapt the Services to your needs and to develop new tools.

    When You use our website, we automatically receive and record information on our server logs from your browser or mobile Platform, including your location, IP address, cookie information, and the page You requested. We treat this data as non-Personal Data, except where we are required to do otherwise under applicable law. We only use this data in aggregate form. We may provide this information to our partners about how our customers, collectively, use our site, so that our partners may also understand how often people use our website.

    We also collect and Process your Personal Data to create Your Website.

    1.2 When accepting to benefit from our Services

    If You fail to provide your Personal Data, we may not be able to perform the Services pursuant to the Agreement. In this case, we may have to cancel the Service, provided that we will notify You if this is the case at the time.

    You give your Consent to the Processing of your Personal Data for the following specific purposes: Processing is necessary for the performance of the Agreement.

    You understand that the Personal Data You provide us with is meant to be accessible by anyone on the World Wide Web.

  • We use different methods to collect Personal Data from and about You, including through:

    a. From the information You provide to us when You meet us (if applicable);

    b. From the Content You provide to us via your personal account on our website (www.usway.co);

    c. When You communicate with us in writing, by telephone, fax, website registration, email or other forms of electronic communication. In this respect, we may monitor, record and store any such communication;

    d. When You complete (or we complete on your behalf) on-boarding or application or other forms;

    e. From publicly available sources or from third parties, most commonly where we need to conduct background checks about You online;

    f. Direct interactions. You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, and email or otherwise. This includes Personal Data You provide when You:

    i. register on our website;
    ii. enter a promotion or survey;

    iii. enter data for installing or using any powered application and/or installing or using mobile application we may launch

    iv. correspond with us (online or offline including via email addresses and phone numbers), if You contact us;

    v. give us some feedback;

    g. Automated technologies or interactions. As You interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. We may also receive technical data about You if You visit other websites employing our cookies; and

    h. Third parties or publicly available sources. We may receive Personal Data about You from various third parties and public sources as set out below technical data from the following parties:

    i. analytics providers such as Google;
    ii. advertising networks/agencies and
    iii. search information providers

  • We Process your Personal Data because it is necessary:

    a. For the Performance of our Services;
    b. To provide You with a confirmation regarding the Agreement;
    c. To deal with any complaint or request You may have;

    d. For any other purpose for which You provide us with your Personal Data; and
    e. For the administration and management of our business

    In this respect, we may share your Personal Data with or transfer your Personal Data to:

    a. Third parties whom we engage to assist in delivering the Services to You;

    b. Our professional advisers where it is necessary for us to obtain their advice or assistance including lawyers, accountant, IT or public relations advisers; and

    c. Our data storage providers

    Your Website, as a final product, will not be published online without your explicit Consent. Once online, Your Website will be accessible by anyone on the World Wide Web.

  • We may send You marketing about services we provide which may be of interest to You, as well as other information in the form of alerts, newsletters and invitations to events or functions which we believe might be of interest to You or in order to update You with information (such as legal or commercial news) which we believe may be relevant to You. We may communicate this to You in a number of ways including by post, telephone, email or other digital channels.

  • We will get your express opt-in consent before we share your Personal Data with any company outside Usway for marketing purposes.

    You can ask us or third parties to stop sending You marketing messages at any time by logging into our website, or third parties websites and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to You.

  • You can set your browser to refuse all or some browser cookies or to alert You when websites set or access cookies. If You disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.

  • We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If You wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your Personal Data for an unrelated purpose, we will notify You and we will explain the legal basis which allows us to do so. Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  • We will never ask You to provide us with Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning sex life or sexual orientation. If You willingly decide to provide us with such sensitive information, You understand that You make such sensitive information public. We reserve the right, however, not to implement such sensitive information on Your Website.

  • This Privacy Policy is issued on behalf of Usway so when we mention “we” or “us”, in this Privacy Policy, we are referring to Usway.

    We have appointed a Controller, within our team, who is responsible for overseeing questions in relation to this Privacy Policy. If You have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the Controller using the details set out below.

    Contact details
    Full name of legal entity: Usway
    Full name of Controller: Bruno Hon

    Email address: [email protected]
    Address: IN5 TECH – DUBAI INTERNET CITY – DUBAI, UAE

    Phone: +971 525639131

  • At any time during the period You benefit from our Services, You have the right to access your Personal Data. This enables You to receive a copy of the Personal Data we hold about You and to check that we are lawfully Processing it.

  • We will only retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

    To determine the appropriate retention period for Personal Data, we consider the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

  • Our website and Your Website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about You. We do not control these third-party websites and are not responsible for their privacy statements. We encourage You to read the Privacy Policy of every website that can be accessed through our website or Your Website.

  • You have the right to obtain from the Controller without undue delay the rectification of inaccurate Personal Data concerning You.

    This enables You to have any incomplete or inaccurate data we hold about You corrected, though we may need to verify the accuracy of the new data You provide to us.

  • This enables You to ask our Controller to suspend the processing of your Personal Data in the following scenarios: (a) if You want us to establish the Personal Data’s accuracy; (b) where our Processing of the Personal Data is unlawful and You do not want us to erase it and request us to suspend the Processing instead; (c) where You need us to hold the Data to establish, exercise or defend legal claims; or (d) You have objected to our Processing of your Personal Data and we need to verify whether we have overriding legitimate grounds to use it.

  • We are committed to make it as easy to withdraw as to give consent.

    You have the right to withdraw your Consent at any time. The withdrawal of Consent shall not affect the lawfulness of Processing of your Personal Data based on consent before its withdrawal.

    If You withdraw your Consent, we will not be able to provide anymore of our Services to You and we will take reasonable steps, taking into account available technology and means to remove Your Website from the World Wide Web in a timely manner. We will also delete the Personal Data we have collected on You for internal use.

    In the eventuality You withdraw your Consent, we are not responsible for Content that would still be hosted on third party websites.

  • You have the right to obtain from the Controller the erasure of Personal Data concerning You without undue delay and the Controller undertakes to erase Personal Data without undue delay.

    This enables You to ask us to delete or remove Personal Data where there is no good reason for us continuing to Process it. You also have the right to ask us to delete or remove your Personal Data where You have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to You, if applicable, at the time of your request.

    Please object to the Processing of your Personal Data immediately if You feel that such Processing impacts your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

  • We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or You have made a number of requests. In this case, we will notify You and keep You updated.

  • Except from the Personal Data that will be contained in Your Website, and that You will be able to approve before it is made accessible to anyone on the World Wide Web, we have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know.

    We have put in place procedures to deal with any suspected Personal Data breach and will notify You and any applicable regulator of a breach where we are legally required to do so.

  • We may revise this Privacy Policy from time to time. Therefore, we may undertake a few changes to it. This version of the Privacy Policy will govern our use of your information. If we make any material changes in the way we use your Personal Data, we shall notify You by posting sending You an email in order to obtain your approval. By continuing to access or use the Services after those changes become effective, You agree to be bound by the revised Privacy Policy.

    Please note that it is substantial that the Personal Data we hold about You is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

Please keep a copy of this document at all time and feel free to ask us any question or address us any concern You would have regarding our Privacy Policy.

Privacy Policy

Our activity is to provide smart personal branding and enhanced online presence for individuals by using innovative back-end technologies.

You have chosen to benefit from our Services pursuant to an Agreement.

As we are committed to respect your privacy, such Services will always be provided with your Consent.

In this document, we provide clear information of how your data is processed when You visit our website and when You use our Services.

At any time, please refer to the following definitions:

“Agreement” means a project proposal we made to You to benefit from the Services, a service contract we entered into with your company in relation with the Services; or a purchase or adherence to a selected plan on our website.

“Personal Data” means any information relating to You, as an identified person, directly or indirectly, such as your name, address, marital status, date of birth, gender, office location, position, company name, spoken languages, photos, your identification number, your location data, or factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity, your networks and connections made available to us, or obtained on your behalf and any personal information You would provide us with;

“Consent” means any freely given, specific, informed and unambiguous indication of your wishes by which You, by a statement or by a clear affirmative action, signifies agreement to the Processing of Personal Data relating to You;

“Content” means the information on You, that You will provide us with, so we can implement it on Your Website, such information shall include your Personal Data;

“Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

“Performance of our Services” means the actions necessary for us to provide our Services;

“Service Proposal” means the proposal we made You, describing our Services tailored for your personal situation;

“Services” means all the steps for creating and publishing Your Website online;

“Your Website” means a collection of pages accessible on the World Wide Web or through blockchain technology for which we will obtain and hold an Internet Protocol address and corresponding domain name on your behalf and take such further acts as are necessary to establish the address of the website and on which we will display the adapted, reformated, and otherwise modified Content provided by You, from time to time.

  • 1.1 When signing up and registering

    By signing up to our website, You will be asked to register, so we can identify You. At this stage, we receive and store any information You enter on our website or that You provide us with in any other way. The types of Personal Data collected may include (but is not limited to) your name, address, telephone number, mobile number, e-mail address, birthday, company name, office location, title department, spoken languages, usage information regarding your use of our Services, and browser information.

    The Personal Data You provide is used for purposes such as allowing You to set up a user account and profile that can be used to interact with us. We may also draw upon this Personal Data in order to adapt the Services to your needs and to develop new tools.

    When You use our website, we automatically receive and record information on our server logs from your browser or mobile Platform, including your location, IP address, cookie information, and the page You requested. We treat this data as non-Personal Data, except where we are required to do otherwise under applicable law. We only use this data in aggregate form. We may provide this information to our partners about how our customers, collectively, use our site, so that our partners may also understand how often people use our website.

    We also collect and Process your Personal Data to create Your Website.

    1.2 When accepting to benefit from our Services

    If You fail to provide your Personal Data, we may not be able to perform the Services pursuant to the Agreement. In this case, we may have to cancel the Service, provided that we will notify You if this is the case at the time.

    You give your Consent to the Processing of your Personal Data for the following specific purposes: Processing is necessary for the performance of the Agreement.

    You understand that the Personal Data You provide us with is meant to be accessible by anyone on the World Wide Web.

  • We use different methods to collect Personal Data from and about You, including through:

    a. From the information You provide to us when You meet us (if applicable);

    b. From the Content You provide to us via your personal account on our website (www.usway.co);

    c. When You communicate with us in writing, by telephone, fax, website registration, email or other forms of electronic communication. In this respect, we may monitor, record and store any such communication;

    d. When You complete (or we complete on your behalf) on-boarding or application or other forms;

    e. From publicly available sources or from third parties, most commonly where we need to conduct background checks about You online;

    f. Direct interactions. You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, and email or otherwise. This includes Personal Data You provide when You:

    i. register on our website;
    ii. enter a promotion or survey;

    iii. enter data for installing or using any powered application and/or installing or using mobile application we may launch

    iv. correspond with us (online or offline including via email addresses and phone numbers), if You contact us;

    v. give us some feedback;

    g. Automated technologies or interactions. As You interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies. We may also receive technical data about You if You visit other websites employing our cookies; and

    h. Third parties or publicly available sources. We may receive Personal Data about You from various third parties and public sources as set out below technical data from the following parties:

    i. analytics providers such as Google;
    ii. advertising networks/agencies and
    iii. search information providers

  • We Process your Personal Data because it is necessary:

    a. For the Performance of our Services;
    b. To provide You with a confirmation regarding the Agreement;
    c. To deal with any complaint or request You may have;

    d. For any other purpose for which You provide us with your Personal Data; and
    e. For the administration and management of our business

    In this respect, we may share your Personal Data with or transfer your Personal Data to:

    a. Third parties whom we engage to assist in delivering the Services to You;

    b. Our professional advisers where it is necessary for us to obtain their advice or assistance including lawyers, accountant, IT or public relations advisers; and

    c. Our data storage providers

    Your Website, as a final product, will not be published online without your explicit Consent. Once online, Your Website will be accessible by anyone on the World Wide Web.

  • We may send You marketing about services we provide which may be of interest to You, as well as other information in the form of alerts, newsletters and invitations to events or functions which we believe might be of interest to You or in order to update You with information (such as legal or commercial news) which we believe may be relevant to You. We may communicate this to You in a number of ways including by post, telephone, email or other digital channels.

  • We will get your express opt-in consent before we share your Personal Data with any company outside Usway for marketing purposes.

    You can ask us or third parties to stop sending You marketing messages at any time by logging into our website, or third parties websites and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to You.

  • You can set your browser to refuse all or some browser cookies or to alert You when websites set or access cookies. If You disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.

  • We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If You wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your Personal Data for an unrelated purpose, we will notify You and we will explain the legal basis which allows us to do so. Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  • We will never ask You to provide us with Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning sex life or sexual orientation. If You willingly decide to provide us with such sensitive information, You understand that You make such sensitive information public. We reserve the right, however, not to implement such sensitive information on Your Website.

  • This Privacy Policy is issued on behalf of Usway so when we mention “we” or “us”, in this Privacy Policy, we are referring to Usway.

    We have appointed a Controller, within our team, who is responsible for overseeing questions in relation to this Privacy Policy. If You have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the Controller using the details set out below.

    Contact details
    Full name of legal entity: Usway
    Full name of Controller: Bruno Hon

    Email address: [email protected]
    Address: IN5 TECH – DUBAI INTERNET CITY – DUBAI, UAE

    Phone: +971 525639131

  • At any time during the period You benefit from our Services, You have the right to access your Personal Data. This enables You to receive a copy of the Personal Data we hold about You and to check that we are lawfully Processing it.

  • We will only retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

    To determine the appropriate retention period for Personal Data, we consider the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal requirements.

  • Our website and Your Website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about You. We do not control these third-party websites and are not responsible for their privacy statements. We encourage You to read the Privacy Policy of every website that can be accessed through our website or Your Website.

  • You have the right to obtain from the Controller without undue delay the rectification of inaccurate Personal Data concerning You.

    This enables You to have any incomplete or inaccurate data we hold about You corrected, though we may need to verify the accuracy of the new data You provide to us.

  • This enables You to ask our Controller to suspend the processing of your Personal Data in the following scenarios: (a) if You want us to establish the Personal Data’s accuracy; (b) where our Processing of the Personal Data is unlawful and You do not want us to erase it and request us to suspend the Processing instead; (c) where You need us to hold the Data to establish, exercise or defend legal claims; or (d) You have objected to our Processing of your Personal Data and we need to verify whether we have overriding legitimate grounds to use it.

  • We are committed to make it as easy to withdraw as to give consent.

    You have the right to withdraw your Consent at any time. The withdrawal of Consent shall not affect the lawfulness of Processing of your Personal Data based on consent before its withdrawal.

    If You withdraw your Consent, we will not be able to provide anymore of our Services to You and we will take reasonable steps, taking into account available technology and means to remove Your Website from the World Wide Web in a timely manner. We will also delete the Personal Data we have collected on You for internal use.

    In the eventuality You withdraw your Consent, we are not responsible for Content that would still be hosted on third party websites.

  • You have the right to obtain from the Controller the erasure of Personal Data concerning You without undue delay and the Controller undertakes to erase Personal Data without undue delay.

    This enables You to ask us to delete or remove Personal Data where there is no good reason for us continuing to Process it. You also have the right to ask us to delete or remove your Personal Data where You have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to You, if applicable, at the time of your request.

    Please object to the Processing of your Personal Data immediately if You feel that such Processing impacts your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

  • We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or You have made a number of requests. In this case, we will notify You and keep You updated.

  • Except from the Personal Data that will be contained in Your Website, and that You will be able to approve before it is made accessible to anyone on the World Wide Web, we have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know.

    We have put in place procedures to deal with any suspected Personal Data breach and will notify You and any applicable regulator of a breach where we are legally required to do so.

  • We may revise this Privacy Policy from time to time. Therefore, we may undertake a few changes to it. This version of the Privacy Policy will govern our use of your information. If we make any material changes in the way we use your Personal Data, we shall notify You by posting sending You an email in order to obtain your approval. By continuing to access or use the Services after those changes become effective, You agree to be bound by the revised Privacy Policy.

    Please note that it is substantial that the Personal Data we hold about You is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

Please keep a copy of this document at all time and feel free to ask us any question or address us any concern You would have regarding our Privacy Policy.