Types of Personal Data
Depending on the customer relation cyway may collect the following personal data:
- Access data from our website. Any access to our web services including data submitted by your web browser such as timestamp, IP address, hostname, request language, user agent, operating system and requested resource
- Communication data, any records of phone calls with customers and partners including date/time, phone number, company and name. This might also include recordings of voice communication for educational and legal purposes. Such a recording would be announced beforehand
- Account and admin data, where applicable, professional information about customers and partners such as name, associated company, job title and contact information
User identifying mechanisms like cookies are used if their purpose is to guarantee the basic functionality of a service (e.g. authentication and session management).
Purposes for Processing Personal Data
cyway is processing personal data only for a specific purpose in the interest of the client relationship. In particular for:
- Client on-boarding processes to verify your identity
- Managing our relationship with existing clients
- Process payments
- Providing services requested by clients
- Meeting our on-going legal, regulatory, and compliance obligations
- Ensuring security and safety for clients, employees and partners
- Following up on legal requests for abuse reports and fraud investigations
Access to Personal Data
cyway applies the highest security standards and undertakes appropriate technical and organizational measures to protect your personal data against loss or other forms of unlawful processing. Data located at cyway is accessible to internal employees only. We follow the least privilege principle where access is minimized to employees only if and as long as they are assigned to a project or process.
Under some circumstances, cyway may embed videos from external sources if it helps to enrich the user experience (e.g. YouTube, Vimeo). Such embedded objects always enable all available privacy features (e.g. encryption, disabling third-party cookies, HTTP security header) to limit disclosure of personal data to outside entities.
Payment handling might be done by an external service provider. Such extended data processing would be indicated at the beginning of the exchange.
Employees of cyway are subject to extensive secrecy obligations. We make sure that personal data is only accessible by those employees who need access to do their job.
Retention time of Personal Data
cyway will only retain personal data as long as necessary to fulfil the purpose for which it was collected. This retention time will comply with legal, regulatory and internal policy requirements. After that retention period the data will be deleted irreversibly.
You have various rights with regard to the processing of your personal data by cyway.
Rights to information: You may at any time be informed by cyway within one month as to whether or not personal data concerning you is being processed, and, where that is the case, be informed about the purpose of the data processing. Furthermore, you are entitled to a copy of your personal data undergoing processing.
Right to rectification: You may ask us to rectify any inaccurate personal data concerning you.
Right to erasure: You have the right to ask for erasure of personal data concerning you. Such request will not affect the lawfulness of the previous processing of your personal data.
Right to restrict the data processing: You have the right to ask that your personal data shall not be processed in a certain manner or for a certain purpose or ask that cyway shall not continue to process your personal data in general. After you provide your consent to us to process your personal data, you can withdraw your consent at any time. If you withdraw your consent, we will no longer process your personal data. Such a request or withdrawal of consent will not affect the lawfulness of the previous processing of your personal data.
Depending on the applicable data protection law, you may have the right to data portability.
Please note that the restriction of data processing or the erasure of your personal data may have the consequence that you cannot, or not properly, use the website and/or the services and/or products of cyway and/or that cyway is not able to provide you the services that have been offered or agreed upon with you.
Please also note that your rights mentioned above may be limited under certain circumstances.
If you have any questions about this Privacy Statement or about the practices of this site or other issues concerning the data processing by cyway, you can contact:
Data Protection Officer