Effective Date: June 8, 2021
A. PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT
DATA WE PROCESS ON BEHALF OF OUR CUSTOMERS
In order to provide the Services to our Customers, we collect and process certain information (which may include personal information) about our Customer’s Authorized Representatives and End Users. To the extent the GDPR applies to such processing activities, WalkMe is the Processor of such data.
The information collected, depends on the Service used as follows:
- Where you are an Authorized Representative accessing and using WalkMe System™ (i.e. WalkMe for web/desktop), we will collect your name, email address and WalkMe log-in credentials. Where you are an Authorized Representative accessing WalkMe Mobile™ (a software development kit that enables interactive mobile guidance and engagement for mobile applications either owned, controlled, licensed or used by a Customer), we will collect the name of the application and the version of the application along with any other information requested by our Customer, and your name, email address and WalkMe-log-in credentials.
- Where you are an End User using WalkMe System™, we will collect your IP address, web application data (page title/URL) and geolocation (only country and city). Where you are an End User of WalkMe Mobile™ we retain IP addresses in logs for security purposes.
- Whether you are using WalkMe System™ or WalkMe Mobile™, we collect a randomly generated identifier which, by default, does not contain personal information unless the customer chooses to use a custom user identifier. For more information about this, please refer to the Special Features section below
Where our Customer has opted for support from WalkMe in relation to the use of the Services, we will also collect WalkMe credentials such as username and account information from Authorized Representatives.
Our Customers may enable certain additional features (“Special Features”) to be added to the Services, which can be viewed here. These Special Features may require further personal information to be collected about End Users. Please contact the Customer for more information about which Special Feature they have enabled when using the Services.
Please note, for Small and Medium Businesses (“SMB”) Digital Analytics Experience and Adaptive Element Recognition are enabled by default.
To the extent the GDPR applies to the processing activities noted above (including the Special Features), we process such information as a Processor on behalf of our Customer acting as a Controller. In these circumstances, we have entered into a data processing agreement, which can be found here (“DPA”) with the Customer, to ensure compliance with applicable data protection laws (including the GDPR). Our Customers must ensure appropriate notice is provided and adequate consent (where required) is obtained from Authorized Representatives and End Users (unless there is another basis for the processing of personal information under applicable law).
DATA WE PROCESS FOR OUR OWN PURPOSES
In addition to the other categories of Personal Information identified below, WalkMe uses WalkMe Session Playback and other features on the editor and insights component of the Services to collect and use personal information about our Customers’ Authorized Representatives and End Users for the purposes set out below. To the extent the GDPR applies to such processing activities, WalkMe Ltd. and WalkMe, Inc. are Controllers of such data.
|Categories of personal information||How we collect it||Purposes for Processing||Legal Basis (where the GDPR applies)|
|Technical information when using the Services:
We collect personal information through cookies within our Services, from Authorized Representatives and End Users including:
|Automatically through cookies when Authorized Users and End Users use the Services.||Enable the operation and provision of the Services.
Personalise our Services.
Analyse, develop and improve our products and Services.
|Legitimate interests (to run a successful business).|
|Technical and behavioural information when using the Services:
We collect certain personal information about Authorized Representatives and End Users when they engage with Services. This includes:
|Automatically through use of the Services.||Enable the operation and provision of the Services.
Analyse, develop and improve the Services.
Keeping the Services secure and ensuring effective user authentication
|Legitimate interests (to run a successful business).|
We collect personal information from Authorized Representatives of our Customers upon creation of a WalkMe account. This includes:
|Collected from Authorized Representatives during the onboarding process when opening a WalkMe account on behalf of a Customer.||Enable the operation and provision of the Services.
Communicate with Customers via their Authorized Representatives in a range of circumstances, for example, in order to administer the account, where we update legal/privacy notices or if there has been a security incident.
Detect and protect against error, fraud or other criminal activity.
For risk control, to comply with laws and regulations, other legal processes and law enforcement requirements.
|Legitimate interests (to run a successful business).
Where Customers have subscribed to receiving support Services, the following personal information will be collected about Authorized Representatives:
|Authorized Representatives provide this information to WalkMe when requesting support.||Enable the operation and provision of the Services.
Perform troubleshooting, analyse, develop and improve our products and Services.
|Legitimate interests (to provide customer support and to run a successful business).|
In order to invoice and process payments, this may involve the processing of personal information relating to Authorized Representatives, including:
|Authorized Representatives provide this information during the onboarding process when opening a WalkMe account.||Facilitate payment for the provision of the Services.||Legitimate interests (to run a successful business).|
We collect personal information from Authorized Representatives for marketing purposes such as:
|Authorized Representatives provide this information during the onboarding process when opening a WalkMe account.||Maintain a community platform to share Customer success stories.
Organise corporate events and webinars.
|Legitimate interests (to run a successful business)|
B. SHARING INFORMATION GATHERED THROUGH THE WALKME SYSTEM™ WITH THIRD PARTIES
Where we process personal information on behalf of our Customers, we use various sub-processors. A list of our current sub-processors are available here.
- service providers and vendors for business purposes. Such third parties include: (i) security vendors; (ii) hosting and storage vendors, such as Amazon Web Services and Google Cloud Provider in the United States; (iii) third party technology partners; and (iv) third parties that assist us in communicating with you. These service providers assist us with many different functions and tasks relating to the Services, such as providing data storage and disaster recovery services and enabling us to communicate with you.
- professional advisors, as necessary, such as auditors, law firms, or accounting firms.
- For legal and security reasons and to protect our Services and business. We will share your personal information with regulators, law enforcement agencies, public authorities, or any other relevant organisations: (i) in response to a legal obligation; (ii) if we have determined that it is necessary to share your personal data to comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries; (iii) to protect the interests of, and ensure the safety and security, of us, our users, a third party or the public; (iv) to exercise or defend legal claims; and (v) to enforce our terms and conditions, other applicable terms of service, or other agreements.
- our affiliates and companies within our corporate family in order to provide the Services.
- In connection with an asset sale or purchase, a share sale, purchase or merger, bankruptcy, or other business transaction or re-organisation, in our legitimate interests. We will share your personal data with a prospective buyer, seller, new owner, or other relevant third party as necessary while negotiating or in relation to a change of corporate control such as a restructuring, merger, or sale of our assets.
C. COOKIES & OTHER TRACKING TECHNOLOGIES
WalkMe uses strictly necessary cookies which are essential to the functioning of our Services, to provide a service requested by our Customer, their Authorized Representative or End Users, and to make their user experience better and more personalized; or to comply with the law (e.g. the security requirements of data protection law).
You can find more information about cookies at www.allaboutcookies.org.
If you want to delete or block any cookies, please contact WalkMe support so that we can assist you or refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies. Please note that deleting our cookies or disabling future cookies may prevent you from accessing our Services or may otherwise adversely affect your user experience.
“Do Not Track” Signals: Some browsers may transmit Do Not Track signals to websites with which the browser communicates, telling the site not to follow its online movements. Because of differences in how web browsers interpret this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they are even aware of them. Therefore, we currently do not respond to such Do Not Track signals.