Privacy Policy 

Last Updated on October 23, 2018

This is the privacy policy (the “Policy”) of Bayware, Inc., a Delaware corporation (the “Company”, “we”, or “us”).  This Policy describes the treatment of information provided or collected on (the “Website”), the Sandbox application (the “Sandbox Application”) or other products or services (each a “Product” and collectively, the “Products”). The purpose of this Policy is to describe how we collect, share and secure information provided by you. Therefore, before you provide us with any personal information via the Products, you should read through this Policy in its entirety and understand its terms. We may update the Policy from time to time, so please check in occasionally.  Ultimately, our goal is to provide a Policy that is transparent in how we handle your information.  




When using the Products, you may choose to provide us with personally identifiable information about yourself (“Personal Information”). The term “Personal Information” means information that is collected in connection with your name such as your address, e-mail, phone number and credit card information. Your use of the Products may also entail you providing information that is not Personal Information, meaning that such information is not connected to your name and is, therefore, anonymous information and which does not identify and cannot reasonably be used to identify an individual user of the Products.  

We collect information that you provide to us, which may include:

  • your name, email address, phone number, physical address, and other information you may disclose when you create an account, complete your profile or submit a request for support;
  • cloud services, applications, and vendors that you use.

We may also automatically collect other data, including:

  • Cookies. We use cookies on our website to collect data about your visit (like usage data, and other information automatically collected from your browser or mobile device; this information may include your IP address; browser type and version; preferred language; geographic location using IP address or the GPS, wireless, or Bluetooth technology on your device; operating system and computer platform) and to allow you to navigate from page to page without having to re-login each time, count visits, and see which areas and features of our website are popular. We do not link the information we store in cookies to any information you submit while on our website. We may also use the data collected via cookies to tailor advertisements to you and to track the popularity of our website. Our use of cookies and other technologies may allow us and third parties to collect information about your browsing activities over time and across different websites following your use of our services. Click here to revoke your consent to cookie tracking on
  • Analytics. When you visit our website, we use third party analysis tools to collect data about your computer and Internet connection. That information includes the IP address of your computer and/or Internet service provider, when you access our website, the Internet address of websites from which you link to our website and from which you came before landing on our website, the browser that you are using, and your movements and preferences on our website. All of this information is used internally for the purpose of understanding how our website is being used and improving our website. We also use third party analysis tools to collect data about your use of our mobile apps. The information collected identifies the types and timing of actions you take within our mobile, including installation, registration, uploading, and certain types of navigating. All of this information is used internally for the purpose of understanding how our mobile apps are being used and improving them.
  • Do Not Track. We do not track the Products’ users and visitors over time and across third party websites to provide targeted advertising. Consequently, the Owner does not respond to Do Not Track (DNT) signals. Other third-party websites may keep track of your browsing activities when they provide you with content, which enables them to customize what they present to you on their websites.

We do not collect any personally identifiable information from children under the age of 16. If you believe that a child under the age 16 has provided us with personally identifiable information, please contact our customer support.


We collect and process the data you provide to us based on the following reasons:

  • For the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract;
  • For our legitimate interests, namely the proper administration of our business, the monitoring and improving of our website and services, and the protection and assertion of our legal rights, your legal rights and the legal rights of others;
  • In limited circumstances, further to your consent.

Some of the reasons that we collect Personal Information include:

  • Provide our products and services, including our Website and Sandbox Application, and improve them over time;
  • Personalize and manage our relationship with you, including introducing you to products or services that may be of interest to you or to provide customer support;
  • Investigate, respond to, and manage inquiries or events;
  • Work with and respond to law enforcement and regulators; and
  • Research matters relating to our business such as security threats and vulnerabilities.

We may share your information as follows:

  • If we have aggregated or de-identified the information, so that it cannot reasonably be used to identify you;
  • With third party service providers who we use in delivering our Products, including certain advertising, referral, operations, financial services and technology services (such as hosting providers, identity verification, support, payment, and email service providers);
  • If required by applicable law or legal process, or if we believe it is in accordance with applicable law or legal process;
  • To protect the rights, property and safety of the Company, our users and the public, including, for example, in connection with court proceedings, or to detect or prevent criminal activity, fraud, material misrepresentation, or to establish our rights or defend against legal claims; or
  • In connection with selling, merging, transferring, or reorganizing all or parts of our business.

We are headquartered in California, United States, and we have operations, entities, and service providers in multiple countries, including in the United States and Ukraine. As such, we and our service providers may transfer your Personal Information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.


As an identified or identifiable natural person (“Data Subject”), you have the following rights which can be exercised by contacting us at  

  • The right to confirmation and access

You have the right to ask us to confirm to you whether or not we collect, process or store your Personal Information. Where we collect process or store your Personal Information, you are entitled to access to your Personal Information.

  • The right to rectification

You have the right to have any inaccurate Personal Information about you rectified and to have any incomplete Personal Information about you completed.

  • The right to erasure

You have the general right to request the erasure of your Personal Information. This right can be exercised if one of the following applies:

  • the Personal Information is no longer necessary for the purpose the we collected it for;
  • you withdraw your consent to consent based processing and no other legal justification for processing applies;
  • you object to processing for direct marketing purposes;
  • we unlawfully processed your Personal Information; or
  • erasure is required to comply with a legal obligation that applies to us.
  • The right to restrict processing

You have the right to restrict the processing of your Personal Information under certain circumstances. You may restrict the processing of your Personal Information in the following circumstances:

  • if you contest the accuracy of the Personal Information;
  • where processing is unlawful you may request, instead of requesting erasure, that we restrict the use of the unlawfully processed Personal Information;
  • if we longer need to process your Personal Information but you need the Personal Information for the establishment, exercise, or defense of legal claims; or
  • if you object to processing that relies on the public interest or on our legitimate interests as the lawful processing grounds, we must restrict the challenged processing activity pending verification of whether our legitimate interests override your interests.
  • The right to object to processing

You have the right to object to processing of your Personal Information under certain circumstances. These include:

  • where our processing of your Personal Information is for direct marketing purposes (including profiling for direct marketing purposes) you may object free of charge by contacting us in writing; or
  • where our processing of your Personal Information is for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation.
  • The right to data portability

Where the legal basis for our processing your Personal Information is:

  • your consent; or
  • that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

and where this processing is carried out by automated means, you have the right to receive your Personal Information from us in a structured, commonly used and machine-readable format, and also the right to transmit your Personal Information from us to another data controller without any hindrance from us where this is technically feasible. However, this right does not apply where it adversely affects the rights and freedoms of others.

  • The right to complain to a supervisory authority

If you consider that our processing of your Personal Information infringes data protection laws applicable to you, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

  • The right to withdraw consent

Where the legal basis for processing your Personal Information is your consent, you have the right to withdraw that consent at any time, including in respect of direct marketing and automated decision making.

  • If you are a California resident, California Civil Code Section 1798.83 permits you to request a notice regarding the disclosure of your Personal Information by us to partners for the partners’ direct marketing purpose. If you are a California resident and would like a copy of this notice, please contact us at     

The security, integrity and confidentiality of your Personal Information is extremely important. We use reasonable physical, electronic, organizational and procedural safeguards to protect the personal information that we obtain from you from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable and, therefore, we cannot guarantee that Personal Information will remain secure in all circumstances.


Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. You may request the deletion of your account through our Website. We will retain and delete your personal data as follows:

  • For all users who have deleted their account:
  • Personally-identifiable analytics data is removed 14 days after account deletion.
  • Notification data is not generally stored by our processors but they may retain activity logs for a short period of time (this time varies depending on the processor in question but is not greater than 13 months).

If you opted-in to receive information about our products, updates and offers, we will use your name and email address to send this information to you. If you no longer wish to receive these communications, you can unsubscribe by following the instructions contained in the emails you receive or on our website. Please note that we may send you transactional and relationship messages, even if you have unsubscribed from our marketing communications. For instance, if our service is going to be temporarily suspended for maintenance, we might send you an email to update you.


We may update this Policy from time to time and will notify you of changes to this Policy affecting your rights by email and/or by posting on our Website. If we make material changes, we will do so in accordance with applicable legal requirements, and we will notify you prior to such changes becoming effective.

To keep your Personal Information accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Information in our possession that you have previously submitted using our services. Please also feel free to contact us if you have any questions about this Policy or our information practices.


The data controller responsible for your Personal Data for is Bayware, Inc., a Delaware corporation, with the principal address located 100 Pine St, Suite 300, San Francisco, CA 94111. If you have any questions about this Policy, your rights and/or our data collection practices, please contact us at