Last Revised: February 28, 2018
This Section specifies the privacy and data retention practices related to use of the WalkMe System™, 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 WalkMe Mobile™, Visions™ 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 THE WALKME SYSTEM™?
- Categories of information and data we may collect from our Users.
- Passive Collection. Passively Collected Information means any information which is available to WalkMe while Users are using the Service. Passively Collected Information consists of technical information and behavioral information (i.e. the interaction of the User with the Service), including, but not limited to, the User’s operating system, type of browser, screen resolution, font type, time zone, Flash version, the User’s ‘click-stream’ on the Service, the period of time the User utilized the Services, etc.
- The WalkMe System™ utilizes certain identifiers retained in a cookie file as detailed below. Such identifiers are not linked to any Personal Information about a User and may also be stored (without any link to Personal Information) on WalkMe’s servers.
- WalkMe may also collect the email addresses of people who communicate with WalkMe via email or create accounts and login credentials.
- Special Features. Although the WalkMe System™ does not collect Personal Information by default, Customer may use certain features which may cause the system to collect and store Personal Information (“Special Features”). These Special Features may include:
- User Behavior Tracking: a feature which allows Customers to track End User’s interaction with HTML elements on an application or webpage for which the End User clicked on, including the following information: (i) End User IP address; (ii) URL; (ii) page title; (iii) text, value and description of each element the End User clicked on (excluding any inputted information that is in a credit card number format); and (iv) snapshot of Canvas elements (drawable regions defined in HTML code) which may be available on an application or webpage.
- Screenshot Settings: a feature which allows Customers to capture screenshots of the application or webpage including the WalkMe content. For instance, a Customer may capture a WalkThru™ as it appears on the user interface of the Customer’s application.
- Custom Variables: a feature which allows Customers to track End Users by an available HTML variable and which may be used to distinguish between segments of End Users. For instance, a Customer may use a custom variable to provide certain WalkMe content to only a particular set of End Users.
To use the Special Features, Customers need to actively turn on the applicable Special Feature, each of which is turned off by default, provided that User Behavior Tracking is automatically turned on for WalkMe Startup Edition (“SE”) Customers. WalkMe SE Customers may opt-out of the enablement of the User Behavior Tracking feature by contacting WalkMe at firstname.lastname@example.org the feature will thereafter be disabled. When a Customer turns on one of the Special Features, the Customer agrees to the collection of Personal Information. Certain other features (like surveys and free text fields) may collect Personal Information only if an End User voluntarily provides it. Customers are responsible for the lawful and fair collection of Personal Information through the WalkMe System™ and to hold any consent, permit or license required by applicable law to facilitate such collection, retention, use, processing and storage of any data.
WalkMe is not aware of the nature of the information collected through the Special Features. Such information may include Personal Information about an individual’s racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership (or non-membership), 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 SYSTEM™?
- Automatic Collection of Information. When You use the Service we gather, collect and record the information relating to such usage, either independently or through the help of third-party services as detailed below.
- Information You Provide to Us. You provide us information, including Personal Information, when you communicate with us, including for instance providing Your email when you contact support.
Feature-Specific Information. For more information see the Section about Special Features above.
C. WHAT ARE THE PURPOSES OF THE COLLECTION OF INFORMATION IN THE WALKME SYSTEM™?
- Passively Collected Information is collected in order to:
- Provide Customers with the Service;
- For customization and improvement of the Service.
- 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.
D. SHARING INFORMATION GATHERED THROUGH THE WALKME SYSTEM™ WITH THIRD PARTIES
E. MODIFICATION OR DELETION OF PERSONAL INFORMATION GATHERED THROUGH THE WALKME SYSTEM™
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 aggregated manner without being linked to any identifiers or Personal Information, depending on technical commercial capability, including without limitation by setting the last octet of IPv4 user IP addresses such that it cannot be linked to any identifiers of the User. Such information may continue to be used by WalkMe for the purpose of operating the Service.
For any request or question regarding deletion or amendment of User data, you can contact us at the contact details listed in the General Section and we shall make efforts to respond and support your request.
F. DATA RETENTION – THE WALKME SYSTEM™
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 a 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.
Type Timeline for Deletion (after deletion process begins) for Cancellation, Termination or Migration
Backups 30 days
Logs 365 days
Data in Analytics Platform 90 days
G. COOKIES & PASSIVE COLLECTION WITH THE WALKME SYSTEM™
H. THIRD-PARTY SOFTWARE/SERVICE
I. QUESTIONS, CONTACT INFORMATION AND COMPLAINTS
Please do not hesitate to contact us:
email@example.com or 1-855-4WALKME.
525 Market Street
San Francisco, California, 94105
Or contact WalkMe’s Data Protection Officer at:
525 Market Street
San Francisco, California, 94105