Privacy Policy

Effective Date: 5/1/2018

This Privacy Policy ("policy") applies to the websites: www.awio.com, www.improvely.com, www.w3counter.com, and www.websitegoodies.com (the "Websites", "Sites") owned and operated by Awio Web Services LLC (collectively "Awio", "we", "us", "our"). This Privacy Policy describes how Awio collects, uses, shares and secures the personal information you provide, as well as any personal information transferred to us for processing on behalf of our clients ("Client Data"). It also describes your choices regarding use, access and correction of your personal information.

By visiting one of our websites, visiting an Awio client's website that provides notice of its use of one of our products and/or this policy, or registering for our service, you acknowledge that you accept and consent to the practices outlined in this Privacy Policy.

EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield

Awio Web Services LLC complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Awio has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit the U.S. Department of Commerce's Privacy Shield List at https://www.privacyshield.gov/list.

Awio is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Awio complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Awio is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Awio may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the Privacy Shield Principles, Awio commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Awio at: Daniel Grossman, Owner, dan@awio.com.

Awio has further committed to refer unresolved Privacy Shield complaints to an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, you may visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint, free of charge. To facilitate fast and convenient resolution of complaints, you agree to participate in on-line dispute resolution through JAMS Online Mediation (Endispute).

Under certain conditions, Privacy Shield provides the right to invoke binding arbitration when other dispute resolution procedures have not provided resolution. This is described in Annex I to the Privacy Shield.

Information We Collect

Visitors to Awio's Websites

If you are a visitor to one of our Websites or an Awio client ("Client") who registers or signs in to one of our websites, we may collect the following information about you which may include information that can itself be used to identify and/or contact you ("Personally Identifiable Information"):

We also automatically collect certain information via technology:

We may create anonymous data records from personal information by excluding information (such as your name) that makes the data personally identifiable to you. We reserve the right to use anonymous data for any purpose and disclose anonymous data to third parties in our sole discretion.

Visitors to Awio's Clients' Websites

Our Clients may use customized and proprietary code, software and/or services ("Service(s)") to obtain information regarding the activities that users engage in while visiting their web pages ("Client Data"). When a user visits a website that uses Awio's Services, code contained on the website contacts Awio's servers and enables Awio to collect Client Data. Some Clients may also use their own code to obtain Client Data and then send such information to Awio's servers. Client Data may include Personally Identifiable Information, including, but not limited to, the types of information listed above.

Client Data is stored on Awio's web servers and databases (including those hosted on third party servers on behalf of Awio) for use in performing analysis, producing reports, and providing notifications or other services for the applicable Awio Client. In addition, Awio itself uses Awio's services in order to obtain insights into visitors’ activities on its own Websites.

Awio's collection and analysis of Client Data helps our Clients to understand and improve their websites, to understand and improve their marketing campaigns, and to identify, investigate and deter fraudulent, illegal or unauthorized activity. Awio's Clients determine the types of Client Data that are sent to Awio's servers for analysis. This data may include or be linked to Personally Identifiable Information depending on how the Client uses Awio's Services on its website(s).

Awio's Clients are contractually prohibited from sending personally sensitive Client Data (e.g. personal health information, political opinions, religious or philosophical beliefs) to Awio and Awio does not knowingly receive such data.

In addition, Awio may collect certain information about a Client's visitor automatically, including: the Operating System (OS) running on their device, Internet Protocol (IP) address, geo location based on their IP address, Internet service provider (ISP), access times, browser type and version, screen size, language, and the website they visited before Client's website. We also collect information about what files viewed on Client's website (HTML pages, graphics, etc), what links they've clicked on and what page elements they've interacted with. Such information may be collected and shared with the Awio Client even though not specifically requested by the Client.

How We Use the Information We Collect

Visitors to Awio's Websites

We use the information collected through our site to:

Visitors to Awio's Client's Websites

Except as described in the "Who We Share Information With" section below, Awio never sells or shares any Client Data with individuals or companies other than the specific Client whose website transmitted the Client Data to Awio.

Awio does not link any Personally Identifiable Data across multiple, different websites that are operated by different Clients, nor does it use any Client Data for purposes of behavioral advertising. However, Awio may analyze Client Data in the aggregate for purposes of internal research and/or to determine overall trends or metrics concerning how users are engaging with websites, and may report such general trends publicly, without disclosing any Client Data.

Awio contractually requires its Clients to abide by all applicable laws, rules and regulations, including the Safe Harbor and Privacy Shield where it applies, as well as other applicable laws relating to privacy and data collection ("Applicable Laws"). Awio also contractually requires its Clients to obtain any necessary consents from visitors to its website(s) for the Client's use of Awio's services, comply with all Applicable Laws (including, as an example, the Safe Harbor and Privacy Shield where it applies) with respect to the transfer of Personally Identifiable Information of EU or Swiss subjects through the Service, and to post an online privacy policy that provides each visitor with clear notice of its practices regarding data collection, use, and disclosure (including the Client’s use of Awio's Services), along with a link to the Awio Privacy Policy and to the Awio Service Opt-Out (discussed below).

Awio cannot be held responsible for any Client's failure to make these disclosures on its website or for any Client's use or collection of Client Data that is not permitted under this Privacy Policy or otherwise.

Who We Share Information With

1. With Third Parties:

We may share your information with third-party business partners for the purpose of enhancing our products and services. We may share the names and logos of current clients with prospective clients, or on our website. If you do not want us to share your personal information with these companies, contact us at the contact information below.

2. With Service Providers:

We may share your information with third parties who provide services on our behalf to help with our business activities. These companies are authorized to use your personal information only as necessary to provide these services to us. These services may include:

3. With Public Authorities or Law Enforcement:

In certain situations, Awio may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose your personal information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, when we believe there is a violation to our Terms of Service, to protect your safety or the safety of others, to investigate fraud, or respond to a government request.

Opt-in/Opt-out of Tracking

You may use the buttons below to opt-in or opt-out of being tracked by Awio's analytics services.

Opt Out of W3Counter Tracking   Opt Out of Improvely Tracking

Security

We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. We restrict access to personal information to Awio employees, contractors and agents who need to know that information in order to operate, develop or improve our service. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

If you have any questions about the security of your personal information, you can contact us at the contact information below. We may retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements.

Access

Upon request Awio will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by logging into your account or by contacting us at the contact information below. We will respond to your request within a reasonable timeframe. In certain circumstances we may be required by law to retain your personal information, or may need to retain your personal information in order to continue providing a service.

With respect to our analytics platform and other services Awio provides to clients, Awio acknowledges that you have the right to access your personal information. Awio has no direct relationship with the individuals whose personal information it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his or her query to the Awio's client (the data controller). If requested to remove data we will respond within a reasonable timeframe. In certain circumstances we may be required by law to retain your personal information, or may need to retain your personal information in order to continue providing a service.

Choice

We partner with third parties to manage our advertising on other sites. Our third party partners may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests. If you wish to opt out of interest-based advertising click here (or if located in the European Union click here). Please note you will continue to receive generic ads.

We may contact you by e-mail or other equivalent electronic communications if you access Awio products or services. By registering or using Awio Services, you specifically consent to the receipt of these communications. You may unsubscribe to any of our e-mail or direct message communications regarding updates or products by following the unsubscribe instructions in the body of any message.

Our Policy Toward Children

Our Sites and Services are not directed to children under 13. We do not knowingly collect personally identifiable information from children under 13 or from websites that are targeted to children under 13. If you are under 13, please do not attempt to register or send any information about yourself to us, including your name, address, telephone number, or email address. If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information without their consent, he or she should contact us as provided below. If we become aware that a child under 13 has provided us with personally identifiable information, we will delete such information from our servers.

Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account), through an in-app message, or by means of a prominent notice on this website. We encourage you to periodically review this page for the latest information on our privacy practices.

Privacy Questions/Feedback

In compliance with the Principles, Awio commits to resolve any complaints about your privacy and our collection, use, or disclosure of your personal information. If you have any inquiries or complaints regarding this Policy or our compliance with Privacy Shield, you should first contact Awio at:

Email: dan@awio.com
Postal mail: Awio Web Services LLC, 219 Chatham Pl., Lansdale, PA 19446