Privacy Policy

Date: 23rd September 2017
Version number: 1.0

Introduction

We will never share with or sell your data to anyone.

Witness.ly commits to strong, secure and transparent privacy practices. Witness.ly never sells personal data. All processing operations in strict compliance with European privacy laws. You are in control of Your personal information at all times.

Inetis Ltd. (“Inetis”, “Witness.ly”, “we”, “us”, “our”) provides this “Privacy Policy” to inform our users of our policies and procedures regarding the collection, use and disclosure of personally identifiable information that we receive when they visit and use the www.witness.ly site and any websites owned by Witness.ly (collectively, the “Sites”), and when they use any of Witness.ly’s services. For ease of reading in this Privacy Policy, the Sites and our services are collectively referred to as the “Service(s).” This Privacy Policy applies only to information that you provide to us when you use the Sites or Service.

Who is Inetis

Inetis Ltd. is a European company headquartered in Slovenia, EU. It was founded in 1999. It provides services mostly to financial industry. Inetis complies with all the relevant European Union directives relating to data protection.

How do we collect user information?

Witness.ly is a service that analyzes the behaviour of website users. We do this recording website user's mouse/finger movements and the frequency of keypresses by user. No user input data is collected or stored on Our servers.

Witness.ly Enabled Sites insert a tracking code onto their respective website which is transmitted to Our servers based in Germany (EU). This tracking code contacts Witness.ly's servers and provides a script to Your computer or device accessing the Witness.ly Enabled Site. The script will capture data (specified in the following Section) related to the user's interaction with Witness.ly Enabled Site. This information is then sent to Witness.ly's servers for processing.

Our tools assist the owners of Witness.ly Enabled Sites by providing information needed to improve End User experience.

Information processed by Witness.ly

If you are a visitor of a website which is running the Witness.ly Service, this section applies to you.

Through the Witness.ly code embedded on a Witness.ly Enabled Site, the information collected and processed includes:

  • device screen width and height;

  • site URL;

  • mouse events;

  • touch events;

  • keypresses, excluding actual value of user input;

  • date nad time of webpage access.

You may opt-out from having Witness.ly collect Your information when at any time by visiting our Opt-out page and clicking 'Disable Witness.ly' button.

Our Privacy Policy should always be read in conjunction with the privacy policy of the Witness.ly Enabled Site which will contain further details regarding the processing of Your personal data by the Witness.ly Enabled Site.

Cookies

An HTTP cookie (also called web cookie, Internet cookie, browser cookie, or simply cookie) is a small piece of data sent from a website and stored on the user's computer by the user's web browser while the user is browsing.

Cookies may be used by Witness.ly Enabled Sites. For more information on on the use of cookies on Witness.ly Enabled site please refer to the Witness.ly Enabled Site cookie information pages.

Complete list of cookies used by Witness.ly site is available at Cookie information page.

Most browsers allow You to block accepting cookies. If You do not wish to have cookies placed on Your computer, please use cookies setting of Your to reject all cookies, before accessing this site. Please note that by doing so, some features of of the Site may become unavailable.

To find out more about cookies, including how how to manage and delete them, visit www.allaboutcookies.org.

Collection of Personally Identifying Information

In the course of your use of the Services, you may provide us with certain personally identifying information that can be used to provide you the Service, to identify and contact you, and to set up and administer your account (“Personally Identifying Information” or “PII”). PII may include, but is not limited to, your name, phone number, credit card or other billing information, email address, and postal addresses. You may at any time refuse to provide the PII that we request; however, this may limit our ability to provide the Services to you.

How We Use Personally Identifying Information

PII is used for the following purposes: (i) to provide, administer and improve our Services, (ii) to better understand your needs and interests, (iii) to fulfill requests you may make, (iv) to personalize your experience, (v) to provide Service announcements, (vi) to provide you with further information and offers from Segment or our affiliates, and (vii) protect, investigate and deter against fraudulent, harmful, unauthorized or illegal activity.

Behavioral Targeting / Re-targeting

Witness.ly does NOT use any targeted cookies or Web beacons to collect information about your activities on our Site or User Enabled Sites.

Purchase Information

If you purchase subscriptions to our Service from our Site, we request that you provide your name, email address, billing address, credit card information, telephone number and other information necessary to open your account and complete the transaction. We do not collect or store your full credit card information (although we may store the last four digits for verification purposes). Our credit card processing service provider will collect and store full payment card information from you to pay for your Service.

Children

Because the nature of our Service does not appeal to children under the age of 13, Witness.ly does not knowingly acquire or receive PII from children under 13. If we later learn that any user of our Service is under the age of 13, we will take appropriate steps to remove that user’s information from our account database and will restrict that individual from future access to the Service.

Testimonials

We display personal testimonials of satisfied customers on our Site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, please contact us. If you provide us with comments or feedback we may collect your name and e-mail address, as well as any other content included in the e-mail to send you a reply and improve our Service.

Social Media Widgets

Our Site may include social media features, such as the Facebook “like” button and widgets, such as the “share this” button. These features may collect your PII and track your use of the Site. These social media features are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing such functionality.

Mailing List Information

You may choose to submit your email address or other contact information via our Site. We may use this information to send you news about Witness.ly-related services, products or promotions. We may use one or more service providers to administer these messages, but we do not share your email address with spammers or any other third parties without your permission. We will give you the ability to opt out of marketing-related e-mails by logging in and changing your account settings or by clicking on a link at the bottom of each such e-mail. In some of our communications, we use tracking means, such as a “click-through URL” linked to content on the Site. We track this data to help us measure the effectiveness of our customer communications.

Aggregate Information

Witness.ly may collect and analyze non-PII information about the performance of its Service. From time to time, Witness.ly may release non-personally-identifying information in the aggregate, e.g., by publishing a report on trends in the usage of its Service.

Disclosure to Third Parties

We do not share or sell the Personally Identifying Information that you provide us with other organizations without your express consent. Under this Privacy Policy you hereby consent to sharing under the following circumstances:

Service Providers. We may employ third party companies and individuals to administer and provide the Service on our behalf, (including, without limitation, bill and credit card payment processing, maintenance, administration, support, hosting and database management services). These third parties may have access to your PII only to perform these tasks on our behalf in accordance with this Privacy Policy and are obligated not to disclose or use it for any other purpose.

Compliance with Laws and Law Enforcement; Protection and Safety. Witness.ly may disclose information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe reasonably necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, unauthorized or harmful.

Business Transfers. Witness.ly may sell, transfer or otherwise share some or all of its business or assets, including your personal information, in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy, in which case we will require the recipient to honor this Privacy Policy. You acknowledge that such transfers may occur and that any acquirer or successor of Witness.ly or its assets may continue to use your personal information as set forth in this Privacy Policy. You will be notified via email and/or a prominent notice on our Site or Service of any change in ownership or resulting change in uses of your personal information, as well as any choices you may have regarding your personal information.

Changing or Deleting Your Information

All Witness.ly account holders may review, update, correct or delete the PII in their registration profile by logging into their account. Removing your information may limit our ability to provide the Service to you. If you completely delete all such information, your account will be deactivated and you will lose access to the Service. You may also contact us directly at to accomplish the foregoing or if you have additional requests or questions. We’ll take reasonable steps to provide, modify or delete your information as soon as is practicable, but some information may remain in archived/backup copies for our records or as otherwise required by law. We may limit or reject your request in certain cases, including without limitation where the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question, where the rights of other persons would be violated, or as required by law. We will respond to all requests within 30 days or less.

Access to Data Controlled by our Clients

Witness.ly has no direct relationship with the individuals whose personal data is contained within the Client User Data processed by our Service. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate personal data provided by our Clients should direct their query to Witness.ly’s Client. If the Client requests Witness.lt to remove or modify the data, we will respond to their request within 30 days (or less!). You may also contact us s directly at if you have additional questions or concerns.

Changes to Privacy Policy

We reserve the right to modify this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Policy you will be notified via e-mail (if you have an account where we have your contact information) or otherwise in some manner through the Service that we deem reasonably likely to reach you (which may include posting a new privacy policy on our Site – or a specific announcement on this page or on our blog).

Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes on the Service (or as otherwise indicated at the time of posting). In all cases, your continued use of the Service or Site after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

Security

The security of your PII is important to us. We follow generally accepted industry standards to protect the PII submitted to us, both during transmission and once we receive it (including encrypted storage, firewalls and password protection). Each of our employees is aware of our security policies, and your information is only available to those employees who need it to perform their jobs. No method of transmission over the Internet using industry standard technology is 100% secure. Therefore, we cannot guarantee the absolute security of your information. Witness.ly shall not be held liable by any Third Party, including You, in any event of unauthorized access, use and/or disclosure of information provided that such is not due to Gross Negligence, willful misconduct, fraud or bad faith by Witness.ly.

Security measures adopted by Witness.ly include:

  • access to the information stored within Witness.ly's servers is restricted to a limited number of Witness.ly employees and to users designated on our Customer's accounts and Third Parties who can access the information only in specific and limited circumstances and are bound by confidentiality;

  • Witness.ly's servers are protected by a) firewalls establishing a barrier between Our trusted, secure internal network and the Internet and b) IP restrictions, limiting access to whitelisted IPs;

  • each Client may only access information pertaining to its Client Website that it is tracking and to the specific End Users visiting such Client Website;

  • we use HTTPS for for all Our Services providing secure transfer of data to prevent wiretapping and man-in-the-middle attacks.

International Transfer

Your information is transferred to, and maintained on, computers located in EU. Your data PII data is protected in compliance with European privacy laws.

Links to Other Sites and Services

The Service may contain links to other websites and services. The fact that we link to a website or service is not an endorsement, authorization or representation that we are affiliated with that third party. We do not exercise control over third party websites or services, and are not responsible for their actions. Other websites and services follow different rules regarding the use or disclosure of the PII you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit and services you use.

Voluntary Public Disclosure of Personal Information

We may make available on our Site, or link to, certain opportunities for our members and other users to share information online (e.g., on message boards, in chat areas, in file uploads, through events, etc.). Please be aware that whenever you voluntarily disclose personal information online, that information becomes public and can be collected and used by others. We have no control over, and take no responsibility for, the use, storage or dissemination of such publicly-disclosed personal information. By posting personal information online in public forums, you may receive unsolicited messages from other parties.

Governing Law and Dispute Resolution

This Privacy Policy forms an integral part of Our Terms of Service. The Governing Law and Dispute Resolution mechanism found in Our Terms of Service shall also apply to Our Privacy Policy.


If you have any questions or concerns at all about our Privacy Policy, please feel free to contact us:

Inetis Ltd.
Kidriceva ulica 25
SI-3000 Celje
Slovenia
+386 3 426 00 00