Effective Date: 01 January 2021
Last edited: 01/01/2021
- takes reasonable and appropriate technical and operational measures to protect your personal,
- data collect and hold your personal data from loss, misuse and unauthorized access, disclosure, alteration, and destruction,
- takes into due account the risk involved in the processing and the nature of the personal data.
Capitalized terms shall have the same meaning as in Terms of Service.
HOW DO WE COLLECT PERSONAL INFORMATION?
We collect information about Users’ personal data when:
- you register on our website/to our Services or
- fill out a form or
- in connection with the correspondence between the user and us (used strictly to answer your correspondence)
- in connection with the correspondence between Members and Heroes.
Some of the provided User’s information such as your IP address, domain, browser type, operating system type etc. may be automatically acquired when a user visits our websites.
ARE MY MESSAGES PRIVATE?
When Members send or reply to messages via 2WAY, 2WAY collects messages, along with message-related information (i.e. the phone number from which the message was sent, when and where the message was sent). Please note that 2WAY takes all reasonable steps to use technical and organizational measures and the highest security to protect the provided data.
Be aware that anyone who receives messages using 2WAY can save copies and share received messages. This includes any personal information included in send messages (for example, your address). We advise to be careful with disclosing personal information.
WHAT CATEGORIES OF DATA DO WE COLLECT?
When ordering our Services or contacting 2WAY you may be asked to enter your:
- For Members: name, surname, phone number, age, gender, email,
- For Heroes: name, surname, company business name, email address, company size, phone number.
The aforementioned data is necessary to complete user registration and, at the same time to ensure access to 2WAY Services. Those data are collected by 2WAY. Users are responsible for maintaining accurate data within the Services.
Please note that you, as a user, are fully responsible for lawfully obtaining data in accordance with the applicable law, as well as a lawful entrusting of such data to us as we collect and process data entered by you to 2WAY. Details of your liability for the aforementioned data you can find in Terms of Service part “Limitation of liability”. To make it clear, you are the owner of such data, and you are responsible for collecting personal data in compliance with all applicable law provisions.
Taking the above into account, we may collect information regarding data subjects as follows: users of 2WAY and data collected by them in 2WAY, visitors of 2WAY websites, and individuals who may contact us via our websites.
WHAT DO WE USE YOUR INFORMATION FOR?
2WAY’s main purpose of collecting users’ information (including personal data) and using it is to make communication between Members and Heroes possible and to communicate with Users if applicable.
We can also collect and use Users’ information to upgrade and improve the functionality of our Services. Your information helps us to better respond to your individual needs and understand them. We use the information you provide us in order to:
- personalize user’s experience
- improve our Services
- process transactions
- provide you with customer Service
- prepare advanced statistics and analysis
- to send periodic emails.
We collect and process such data collectively and anonymously. We may also cooperate with selected third-party vendors such as Google Analytics, Google Tag Manager, LiveChat, Amplitude, Hubspot, Albacross and others to allow tracking technologies and remarketing services on the website and 2WAY applications through the use of first-party cookies and third-party cookies to analyze and track user’s use of the website. By accessing our website or using 2WAY, you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their privacy policies. We do not transfer personal information to these third-party vendors.
AND WHAT ABOUT PROFILING PERSONAL DATA?
By using our Services, you give us consent to the profiling of personal data for the purpose of maintenance and providing Services to you. Thanks to this, we may provide you accurate content. We inform you that if You are a resident of European Economic Area, the UK, or Switzerland, you have a right not to be profiled. If so, please inform us about your request via e-mail – such request is tantamount to the termination of the agreement for using our services.
AND WHAT ABOUT GEOLOCATION?
2WAY may have access to your geolocation data (as we collect and process IP address) regarding the device you use while using our services.
AND WHAT ABOUT SOCIAL MEDIA WIDGETS?
As you can see, our website contains social media widgets/features (Facebook, LinkedIn, Twitter).
Please be aware that those widgets/features:
- may collect your IP address
- may set a cookie to enable the features to function in the proper way
SOMETHING ABOUT DATA INTEGRITY AND PURPOSE LIMITATION
Personal data collected by the 2WAY is relevant to the purposes for which data is collected. We ensure that they will not be used by us for other purposes unless you authorize us to do so. We will make an effort to ensure data is reliable for its intended use, accurate, complete, and current. Taking it into account, we may contact you occasionally to check that your data is still accurate and current.
HOW DO WE PROCESS THIRD PARTY INFORMATION?
HOW DO WE PROTECT YOUR DATA?
The security of your personal data is our main concern. We follow high industry standards to protect the personal data processed via our services and products, both during transmission, and once we receive it.
We remind you, however, that no method of Internet transmission or electronic storage is 100% secure. 2WAY takes every reasonable step to keep the data protection system up to date and modern.
2WAY uses technical and organizational measures and the highest security to protect the provided data against loss, destruction, misuse, unauthorized access, or disclosure. The used measures and technology ensure the complete safety of the data provided by the User. We use a secure socket layer (SSL) during the registration process.
DO WE COLLECT CHILDREN PERSONAL DATA?
2WAY does not knowingly collect any information from children, as defined by applicable law, without parental consent or as otherwise permitted by applicable law.
As a responsible company, we encourage parents/legal guardians to monitor their children’s behavior on the Internet.
DO WE SELL OR DISCLOSE YOUR PERSONAL DATA TO THIRD PARTIES?
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. In particular, we shall transfer no information or personal data to third parties for marketing purposes without your prior consent.
This does not include trusted third parties who assist us in operating our Services, so long as those parties agree to keep this information confidential and use proper security measures.
Please be aware that we may also release your information when we believe in good faith that disclosure is appropriate to comply with the law, such as to comply with a subpoena or similar legal process. It is necessary to protect our rights, your safety or the safety of third parties, investigate fraud, respond to a government request, or if it is necessary for 2WAY’s security and the protection of its rights.
2WAY reserves the right to disclose personal data and other information relating to the User to third parties affiliated with 2WAY, connected with providing services, such as payment processing, providing customer support or delivering emails on our behalf.
Users’ credit/payment card data shall be disclosed solely to service providers that conduct non-cash transactions strictly for purposes related to the payments process.
We may share your personal data with:
- parent, subsidiary, affiliated or successor companies
- third party service providers, e.g. hosting, email, support services providers – if requested, we can provide you the list of those providers. Be sure that those entities have minimum access to your personal data, only to those necessary to services to be provided
We will provide an individual opt-out choice before we share data with third parties other than mentioned above or before we use it for a purpose other than which it was originally collected or subsequently authorized. To limit the use and disclosure of your personal data, please submit a request via email at
Please be aware of an exception to opt-out choice – it would be where we are required to disclose your personal data pursuant to a governmental or judicial order, law or regulation to meet national security or law enforcement requirements.
SOME INFORMATION ABOUT ACCOUNTABILITY FOR ONWARD TRANSFER
WHAT IF I AM BASED IN CALIFORNIA?
If you are a California resident, here is a brief summary of your rights under the California Consumer Privacy Act (“CCPA”):
You have the right to know that 2WAY does not sell, trade, or otherwise transfer to outside parties your personally identifiable information. In particular, we shall transfer no information or personal data to third parties for marketing purposes without your prior consent.
You have the right to receive an overview of the personal information we collect, how we use it, and who we share it with.
You can request access to your personal information, get a copy, and ask us to delete your personal information.
You have the right not to be discriminated against for exercising your privacy rights.
We collect personal information for the business purposes described in WHAT DO WE USE YOUR INFORMATION FOR? section.
The so-called ‘cookies’ may be used while using services or products rendered by 2WAY. These are pieces of information sent by the server, stored on a User’s computer for the purpose of automatic identification of a particular user when using our services.
‘Cookies’ enable us to quickly confirm your identity and owing to them, the use of our services becomes much easier and more widely available. ‘Cookies’ are used by 2WAY solely with the purpose of personalizing a particular user. ‘Cookies’ can be used on condition that they are accepted by a browser and that they shall not be removed from the storage media.
Users who removed ‘cookies’ from their storage media or have not accepted them on their browser may not have access to products or services rendered by 2WAY. We do not link the information we store in cookies to any personal data you submit while on our site.
WHO IS THE DATA GATHERING ENTITY?
Conducting its activity, under the business name of 2WAY, INC. with its registered seat at 651 N Broad St, Suite 206, Middletown, ZIP code 19709, Delaware shall be the entity gathering personal data and other information.
HOW TO CHANGE OR DELETE MY DATA?
If your personal data changes, or if you no longer desire our Service, you may correct, update, delete inaccuracies or request deactivation of your account by emailing us at
At any time, you have the right to access your personal data – look into the part “How to contact us”.
Our websites or messages sent by Heroes may contain links to other sites that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other sites.
Using offered products and services rendered by 2WAY, the user is obliged to comply with rules contained in the terms and conditions available on our website: Terms of Service.
We will respond to your request within 30 days.
RECOURSE, ENFORCEMENT, AND LIABILITY
Please be informed that in case:
- we are not in compliance with our Policy
- if you have any questions
- if you wish to take any other action concerning this Policy or your personal data
feel free to contact us and let us know about your concerns.
As the safety of your personal data means a lot for us, be sure that we will investigate your complaint, take appropriate action, and report back to you within 30 days.
HOW TO CONTACT US?