Privacy Policy – Mobile

WALKME MOBILE^™

Effective Date: January 09, 2019

This Section specifies the privacy and data retention practices in connection with WalkMe Mobile^™, a software development kit (SDK) that enables Users to develop interactive mobile guidance and engagement for native mobile applications (which may be referred to in this Section as the “Service”). For information regarding the WalkMe System^™ or the WalkMe Site please see the relevant Section(s). For a complete view of privacy practices relevant to you, please also read the General Section.

A.    WHAT INFORMATION MAY WE COLLECT ON USERS OF WALKME MOBILE™AND HOW?

WalkMe Mobile™ collects the following data:

1. Information Collected from Customer’s Application. If you are a Customer who wants to utilize WalkMe Mobile™ on a mobile application that you own, control, license, or use, we may collect the name of the application and version of the application.
2. Information Collected from End Users of the Application. When an End User uses an application with WalkMe Mobile™, we may collect a randomly generated identifier which by default does not contain Personal Information but which may link to Personal Information if Customer actively chooses for it to do so; timestamp; phone number; masked IP address; and general location information, based on algorithms, to guess if you are using the application from home or from work, however this information does not include your precise geolocation. In addition, we retain IP addresses in logs for security purposes.
3. Technical and Behavioral Information. We may also collect technical and behavioral information including: the interaction of the End User with the Service; device type (e.g. smartphone, tablet, etc.); operating system (e.g. iOS, Android); network provider; platform; timestamp; API key (identifier for application); model, manufacture and OS version of device; session start/stop time; country location; time zone; and the number of times you run an application and the time and place where you run it based on your IP. We also use (but do not store) information from the sensors in the End User’s device such as the accelerometer, gyroscope.
4. Information about In App Messaging. The Service may provide In App messaging, in which case we may collect some or all of the following: (i) the content type of the In App Messaging (what the Offering is about, e.g., games, finance, entertainment, news); (ii) the Offering type (e.g. whether the Offering is text, image, or video based); (ii) certain information about post-click/consumption activity in relation to the Offering.
5. Contact details for the Customer: WalkMe may also collect the email addresses of people who communicate with WalkMe via email or create accounts and receive login credential. In certain cases.
6. Although we do not use the information we collect to identify who you are, some of the information collected may be considered Personal Information in some jurisdictions. Some of the data and information we collect can indirectly be used to identify you, while other data and information (such as your location or how often you use a certain app) can only be used to identify you when combined with other information. We also use some of this data and information in an aggregate form that does not identify you personally.
7. Special Features. Customer may use certain features which may cause the system to collect and store additional Personal Information (“Special Features”). Those features are turned off by default. These Special Features may include.
   1. API Calls: WalkMe Mobile supports a set of API functions that allow the app to enrich the information regarding the End Users (“API Calls”), API Calls may require WalkMe Mobile to collect additional Personal Information namely information about the End User’s actions in the app (through API Goals) and information about the app’s End User (through the User Attributes API or End User Identifier API).To make use of the API functions, Customers have to embed the API to WalkMe Mobile.Customers are responsible for the lawful and fair collection of Personal Information through API calls in WalkMe Mobile, and to hold any consent, permit or license required by applicable to facilitate the collection, retention and use or processing or storage of any data.WalkMe is not aware of the nature of the information collected through the API calls. Such information may include Personal Information about an individual’s race or ethnic origin, political opinions, religious or similar beliefs, trade union physical or mental health or condition, criminal offences, or related proceedings or any other data considered as sensitive under applicable law (“Sensitive Information“).

B.  HOW DO WE COLLECT INFORMATION ON USERS OF THE WALKME MOBILE^™SERVICE?

We collect the information listed above through your use of the Service. In other words, when you are using the Service we are aware of it and may gather, collect and record the information relating to such usage. The system starts to collect data as soon as WalkMe Mobile^™ is integrated to the Customer’s application.

C.  WHAT ARE THE PURPOSES OF THE COLLECTION OF INFORMATION IN WALKME MOBILE^™?

1. Passively Collected Information is collected in order to:
   • Provide Customers and other Users with the Service
   • For customization and improvement of the Service.
2. Personal Information is collected in order to:
   • Operate the Service which includes:
     • Contacting Users for the purpose of providing them with technical assistance and other related information about the Service.
     • Replying to User’s queries.
     • Troubleshooting problems, detecting and protecting against error, fraud or other criminal activity.
   • For risk control, to comply with laws and regulations, and to comply with other legal processes and law enforcement requirements.
   • To enforce agreements executed with WalkMe and to enforce this Privacy Policy.

D.  SHARING INFORMATION GATHERED THROUGH THE WALKME MOBILE^™WITH THIRD PARTIES

We will never sell your information. WalkMe may disclose Personal Information collected through WalkMe Mobile^™ only in the following cases: (a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (b) to provide Customers with information gathered through the Service by WalkMe on Customer’s behalf; (c) to detect, prevent, or otherwise address fraud, breach of this policy, security or technical issues; (d) to respond to User’s support requests; (e) to respond to claims that any content available on the server violates the rights of third-parties; (f) to respond to claims that Personal Information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without consent or as a form of harassment; (g) to protect the rights, property, or personal safety of WalkMe, its Users, or the general public; (h) when WalkMe is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of its assets; (i) to collect, hold and/or manage your Personal Information through WalkMe’s authorized affiliates and third party service providers (for example, Amazon Web Services in the United States.),  solely in connection with the Service and subject to confidentiality agreement not less stringent than WalkMe’s obligations under this Privacy Policy. Such service provider may be located in a country that does not have the same data protection laws as your jurisdiction. When WalkMe transfers data to a service provider, we seek when practical to transfer data only upon executing an appropriate agreement and/or after the certification of the service provider under the E.U.-U.S. Privacy Shield and/or with service providers that are located in a country recognized by the E.U. Council as providing adequate protection; or (j) pursuant to your explicit approval prior to the disclosure.

For avoidance of doubt, WalkMe may transfer Personal Information to its affiliates which shall be obligated with the same restrictions as agreed with the Customer and as specified in this Privacy Policy.

E.    MODIFICATION OR DELETION OF PERSONAL INFORMATION GATHERED TROUGH WALKME MOBILE^™

Users may have a legal right under certain applicable laws (for instance if the User is residing in the E.U. citizen or  in California as applicable) or under Controller’s (as defined in the General Section) privacy policy to receive, rectify, erase, and restrict Personal Information about them that is held by us, to object to processing and, if processing occurs based on consent, to withdraw their consent. Users may also have the right to withdraw consent for processing for statistical and research purposes and in some cases (subject to applicable laws) to request cessation of any collection of Personal Information. WalkMe will never discriminate against any person based on his/hers exercising of their rights hereunder.

If for any reason a User wishes to modify, delete or retrieve his/her Personal Information, s/he may do so by contacting the applicable Controller (as defined in the General Section) (e.g. the provider of the platform on which the WalkMe System^™ is operating). The Controller shall perform the necessary process to identify the User as a User who has a the right to retrieve the specific information and then furnish to WalkMe the data required to be amended, deleted or retrieved together with a specific identification of the User and data (as shall be applicable for the specific Service provided and the requested data – for instance IP address and time of uploading the information to WalkMe’s servers (IP address is not enough for an identification of User or data)). WalkMe cannot retrieve data without a specific identification of User and data. WalkMe may not be able to delete, amend or retrieve User’s information without the Controller’s instructions and authorization.

Please note that Personal Information may be either deleted or retained in an anonymized manner (i.e. without being linked to any identifiers or Personal Information) depending on technical commercial capability. Such anonymized information may continue to be used by WalkMe for the purpose of operating the Service or for WalkMe’s legitimate interest without derogating from users’ rights..

For any request or question regarding deletion or amendment of User data, you can contact our Data Protection Officer at the contact details listed in the General Section and we shall make efforts to respond and support your request within 30 days.

F.    DATA RETENTION – WALKME MOBILE^™

Any Customer may request information regarding the storage and retention of data (“Audit”) by contacting us. WalkMe shall make reasonable efforts to respond to the Audit in reasonable time and subject to applicable law and to the protection of WalkMe’s trade secrets.

WalkMe will retain data it processes on behalf of its Customers only for as long as required to provide the Service to its Customers and as necessary to comply with its legal obligations, resolve disputes and enforce its agreements.

Unless otherwise agreed in writing with the Customer, after a request from the Customer to delete any data an automated process will begin that permanently deletes the data in accordance with the timelines set forth in the tables below. Once initiated, this process cannot be reversed and data will be permanently deleted.

However, some data will not be deleted and shall be kept in an anonymized manner. Some metadata and statistical information concerning the use of the Service are not subject to the deletion procedures in this policy and may be retained by WalkMe. Some data may also be retained on our third-party service providers’ servers until deleted in accordance with their privacy policy.

G.    COOKIES & PASSIVE COLLECTION WITH WALKME MOBILE^™

When you access or use the Service, WalkMe may use industry-wide technologies, which store certain information on your device (“Local Storage“) and which will allow the system to enable automatic return to a stage or page you visited and make your Service experience much more convenient and effortless. It is easy to prohibit the Local Storage. Most applications will allow you to erase such data from your device however, if you block or erase data from your device, your online experience may be limited. Our service providers may also use cookies – please see their privacy policy as detailed below.

H.    THIRD-PARTY SOFTWARE/SERVICE

We may use third-party software and/or services in order to collect and/or process the information detailed herein. Such software includes:

I.  QUESTIONS, CONTACT INFORMATION AND COMPLAINTS

If you have any questions (or comments) concerning this Privacy Policy, you are welcome to send us an email or otherwise contact us at the following address and we will make an effort to reply within a reasonable timeframe.
Please do not hesitate to contact us:
legal@walkme.com or 1-855-4WALKME (925563 – Toll Free Number).

WalkMe, Inc.
71 Stevenson Street, Floor 20
San Francisco, California, 94105
USA

Or contact WalkMe’s Data Protection Officer at:
Nir Nahum
legal@walkme.com
WalkMe, Inc.
71 Stevenson Street, Floor 20
San Francisco, California, 94105
USA

WalkMe previous Privacy Policy – Mobile