Gate2Way - Privacy Policy  

  

WOVEO LTD. hereby informs you about how the personal data collected from users accessing https://gate2way.com/ (“Platform”) and the rights granted by European data protection legislation. 

Please read carefully this privacy policy, before accessing the Platform. 

In this Policy: 

Services: means the services provided by WOVEO to the Users, which consist of providing a Report, detailing the Offers of the Providers which meet the selection criteria set by the User and, based on the User’s choice, reach out to the selected Providers and make reasonable efforts to them in contact with the User. 

Platform: the platform owned by WOVEO, available at https://gate2way.com/, including any subsequent updates, revisions, adaptations, enhancements, or new versions of the product, which Users can access, in order to identify payment solution providers suitable to their business needs.  

E-mail Address: the professional e-mail provided by the User, for the purpose of receiving the Report and for any further communication with WOVEO. 

Offer: the details of the Providers’ payment services, made available by the Providers featured on the Platform to WOVEO from time to time, upon which WOVEO makes no content change. 

Provider: companies offering payment solutions, which have provided WOVEO with an Offer. 

Report: means the list of Offers which meet the User’s selection criteria, requested by the User, which can be accessed through the link sent to the User’s E-mail Address. 

Personal Data: means any information concerning an identified or identifiable natural person - data subject; 

Data Subject: means any identified or identifiable natural person, directly or indirectly, in particular by reference to an identifying element, such as a name, an identification number, location data, an online identifier, or one or more factors specific identity of his physical, physiological, genetic, mental, economic, cultural or social, accessing and using the features of the Platform and its content, regardless of the means or duration of such interaction. 

1. Who we are 

The Platform, both through the website at https://gate2way.com/ and through any other mobile application, is owned and provided by WOVEO LTD, a limited liability company registered and functioning under the laws of Cyprus, registered address -  Kalymnou, 1 "Q  MERITO", 4th floor, Agios Nikolaos, Kamares,6037, Larnaca, Cyprus, Registration number: HE 409507, TIN number: 10409507202006292, E-mail sales@gate2way.com, Phone no. +357 96 300 233 (“WOVEO”), under the trademark Gate2Way. 

 

2. Personal Data we collect 

In order to make the Platform and our Services available to the Users, WOVEO collects the following data: 

a. as a result of accessing the Platform/Services/ Report - IP address, time and duration of accessing the Platform, device-specific information, such as operating system version, unique identifiers, name of the mobile network used, traffic reports recorded by servers hosting the Platform. 

The cookies needed to run Platform (Google Analytics) may possibly collect information about Users, including the websites from which the Platform was accessed, date and time of each visit, performed searches, accessed content and Services and their order, advertising banners, user interaction with advertising materials, and duration of the visit. 

This data is collected for the purpose of providing access to the Platform, Report, and / or Services and is processed anonymously, in the analytic reports on the traffic and use of the Platform. 

If the user's location data is requested, they will first be informed through a pop- up window, asking for their consent or refusal to allow access of the location data. If access to location services is denied, there is a chance that the Platform and Services be available, but with limited functionality. Location data permissions may always be changed on the dedicated section in the

Platform 

  1. as a result of the voluntary provision by the user: in order for the User to access the Services and receive the Report, the following data may be collected: e-mail address, date and time the Report was accessed. 
  2. through cookies: the Platform uses cookies necessary to provide the Services, or optional, to optimize the experience on the Platform. 

The policy on how cookies and similar technologies are used on the Platform is available here.   

1. Purposes of processing of Personal Data collected 

The Personal Data collected through the Platform will be used in accordance with the applicable legal provisions, for the purposes of providing the Services and in the legitimate interest of analyzing the functionality of the Platform and Services, as well as based on the consent of users, for the following purposes: 

  1. based on the agreement entered into with the User, for providing access to the

Platform, Services and Reports, as well as technical support, available here; 

  1. based on legitimate interest to keep Users informed in respect to the latest Offers and Services and to provide Users with updates on the latest relevant content – we use direct marketing as a part of this legitimate interest; 
  2. based on legitimate interest to analyze and improve the performance of the Platform,

Services or Reports; 

  1. in the event of a legal obligation in this regard; 
  2. in case of explicit user consent. 

Data such as the time and duration of access Platform, the source from which it was accessed, the device used, IP address, are collected anonymously, and analyzed to provide access to the platform, to improve the experience of users, adapting the platform version to the device used and prevent fraud. 

The name and surname of the users, as well as the e-mail address provided by the Users are used exclusively for the purposes of providing the Services and will only be shared with the Providers selected by the Users. 

The Platform uses external traffic analysis services - such as those provided by Google Analytics, in order to transmit anonymous standardized reports of the traffic on the Platform to clients of the advertising services featured on the Platform. 

The Personal Data collected will be stored only for the period necessary to fulfill the purposes. If an invoice is issued to the user, the data will be stored in accordance with the applicable legal provisions. 

The Personal Data collected will not be shared with any third party, except the Providers selected by the Users from the Report and indicated to WOVEO in writing, without the express consent of the Data Subject. 

1. The rights of the Data Subject 

Data Subjects – Users, whose personal data are collected and processed through the Platform have the following rights: 

  1. the right to be informed in respect to the collection and use of their personal data; 
  2. the right to request access to personal data, in order to obtain a copy of the personal data held by WOVEO; 
  3. the right to request the correction of any incomplete or inaccurate data ; 
  4. the right to request the deletion of personal data, depending on the specifics of the processing, insofar as the person can be identified and if: (i) the data have been processed unlawfully; (ii) the data are no longer necessary for the purpose for which they were collected; (iii) the period provided by law, regarding data retention, has expired; (iv) the Data Subject objects to the processing and there is no legitimate interest in the further processing of personal data; or (v) consent is withdrawn; 
  5. the right to request the restriction of the processing of personal data , depending on the specifics of the processing, insofar as the person can be identified and if: (i) a claim has been made regarding the accuracy of the personal data processed (for a period allowing verification the correctness of the data in question the correctness of the personal data); (ii) if the data are being processed illegally; or (iii) the processing of the data is no longer necessary, but the user wishes to keep it, in connection with any legal claims; 
  6. the right not to be subject to a decision based exclusively on automatic processing, including the creation of profiles, which produces legal effects concerning the data subject or similarly affects them to a significant extent , in which case the processing of personal data will be stopped , unless it is based on the consent of the data subject, is required for the performance of a contract or permit by law; 
  7. right to portability, i.e. the right to require the provision of personal data in a format that can be read by an electronic device (computer), portable format, depending on the specific processing, to the extent that the person can be identified; 
  8. the right to withdraw at any time the consent to the processing of the User's personal data, without affecting the legality of any processing on the basis of the consent previously expressed; 
  9. the right to file a complaint with the compentent data protection authorities. 

CYPRUS DATA PROTECTION AUTHORITY. 

WOVEO will make reasonable efforts to answer all legitimate Data Subject requests in respect to their personal data, within one month, but delays can be registered in case of complex or numerous requests. 

1. Communication and marketing 

WOVEO will communicate with Users via email, in order to confirm the User’s request on the Platform and to provide them access to the Report, as well as to carry on further communication with WOVEO and selected Providers in respect to the Services. Certain communications may be mandatory for the use of the Platform and Services. 

Users may receive marketing communications based on their express consent and can always withdraw such consent for any non-essential communications. 

Users can request to stop marketing communications at any time by accessing the deactivation link in the email provided by WOVEO. If you encounter problems in changing these settings, please contact privacy@gate2way.com. 

2. Personal Data transmission 

It is possible that WOVEO transmit personal data collected from the Data Subjects, for the purposes set out in section 3 above, to the Provides selected and indicated by the Users to WOVEO, located both within the European Economic Area ("EEA"), as well as outside its territory, based on the User’s request. 

Any sharing of Personal Data outside the EEA will always be subject to the safeguards provided for by the applicable legal provisions or a data transfer agreement that clearly defines the obligations of the parties and ensures the technical and organizational measures for protection of the data concerned. 

WOVEO uses third-party service providers to make certain aspects of our Services available, for example, cloud storage equipment. The service providers are currently located in the EEA. 

To improve the Platform and our Services, in some cases, data collected from Users will be distributed to service providers analysis (data analytics) to analyze the way in which Users interact/use the Platform, Services and Reports. We share data with them in an unidentifiable way to monitor and report the effectiveness of the functionality of the Platform and performance of our Services. 

This information will typically include cookie ID, IP address (abbreviated), reference URL, but also browser and device information. 

WOVEO may disclose User Personal Data to prosecutors, public or governmental authorities and other relevant third parties , in compliance with legal or regulatory requirements. 

3. Personal Data storage and duration 

The Personal Data collected through the Platform will be stored and processed both inside and outside the EEA, on secure servers, to provide users with the best possible experience. 

Personal Data will be stored for a period of 5 years or for the time necessary to fulfill the purposes for which it was collected, whichever is longer, including in order to meet any legal, accounting, or reporting requirements. 

4. Technical and organizational measures, processing security 

All information collected by WOVEO is stored on secure servers and presents appropriate and necessary technical and organizational measures to protect personal data. WOVEO continuously evaluates network security and the adequacy of its internal information security program, including through risk assessment and periodic testing. 

5. Links to third party websites 

The Platform may contain links to web pages or third party applications. Access to these links by Users will determine the application of privacy policies specific to each of these sites, for which WOVEO does not assume any responsibility. 

6. Contact details 

For any additional information or to exercise their rights, users can contact WOVEO, at privacy@gate2way.com.