Introduction and scope
This Privacy Policy applies to the BWAYS website and to the enquiry, discovery, demonstration and communication features offered through it (the “Website”). It describes how we handle personal information relating to visitors and to people who contact us.
It does not replace the agreement we sign with a client for a specific project or service. When we deliver services under a separate agreement, that agreement (and any data-processing terms in it) governs the personal information handled for that work, and may add to this policy.
Please read this policy together with our Terms of Use. You can change your cookie choices at any time through .
Who is responsible for your information
The data controller for the Website is HALOMOT MITGASHMIM SOCIEDAD DE RESPONSABILIDAD LIMITADA (S.R.L.), which operates under the brand BWAYS (“BWAYS”, “we”, “us”). Our business location is Tinamaste de Barú, Pérez Zeledón, San José, Costa Rica.
You can contact us about privacy at office@bways.co.il.
Personal information we collect
What we collect depends on how you use the Website. We ask only for information that is relevant to the feature you choose, and we ask you not to send us sensitive information (such as health, financial-account or government-identification details) through the Website.
Contact and discovery forms
- your name and email address, and, where requested, your telephone number and company;
- your answers to our discovery questions, your project requirements and the content of your messages;
- a record of the consent or confirmation you gave when submitting the form;
- the page and call-to-action from which you reached the form, so we can understand your enquiry.
Correspondence and CRM records
If we correspond with you, we keep that correspondence. We record enquiries and the history of our relationship with you (for example notes, proposals and follow-ups) in our customer relationship management system, described below.
AI voice demonstrations and other AI interactions
If you request a voice demonstration, we process your name, the telephone number you enter, your language, your confirmation of consent, call details (such as date, duration and status), the audio of the call and a transcript of it. If you use another AI-enabled feature, we process what you type or say to it and the responses it generates. See “AI interactions, recordings and transcripts” below.
Technical, security and cookie-related data
Like most websites, our servers and providers process technical data such as IP address, browser and device type, pages requested, date and time, and error and security logs. We also store a small cookie that remembers your cookie choices. See “Cookies and your choices”.
How and why we use personal information
- to respond to your enquiries, understand your needs and prepare proposals or next steps;
- to manage our business relationship with you and keep a record of it;
- to run the voice demonstrations and AI features you request, and to review how they performed;
- to operate, secure and maintain the Website, and to detect and prevent abuse, fraud and misuse (for example, we may apply limits to repeated demonstration requests, which may involve keeping a one-way, non-readable representation of a telephone number);
- to understand how the Website is used and improve it, using optional analytics only if you allow them;
- to meet our legal, accounting and regulatory obligations, and to establish, exercise or defend legal claims.
Marketing. Submitting a contact or discovery form does not automatically subscribe you to marketing communications. We send promotional messages only where the law allows and, where consent is required, with your consent. You can ask us to stop at any time.
Legal grounds and consent
We handle personal information in accordance with the data-protection law that applies to us, including the laws of Costa Rica. Depending on the situation, we rely on one or more of the following grounds:
- your consent, for example when you confirm consent on a form, agree to a voice demonstration or allow optional cookies. You may withdraw consent at any time, without affecting what happened before you withdrew;
- steps you ask us to take, such as answering your enquiry or preparing a proposal;
- our legitimate business interests, such as keeping the Website secure, preventing abuse and administering our business, balanced against your rights;
- legal obligations and legal claims, where we must keep or disclose information.
If you are in a country whose law gives you additional rights or requires additional grounds, we will take that into account when we handle your request.
CRM storage and internal access
We use EspoCRM, a customer relationship management system that BWAYS hosts and controls itself, to record enquiries and our relationship history. Access is limited to authorised people who need it for their role, and it is protected by access controls.
Service providers and who receives information
We use trusted providers to run the Website and our business. They process personal information on our behalf and for the purposes described in this policy. The providers we use include:
- Contabo — infrastructure hosting for our servers and systems;
- SendGrid — delivery of email we send, which may involve email addresses, message content and delivery information;
- OpenRouter — routing of requests to AI models;
- Google (Gemini API), OpenAI (API) and Anthropic (API) — AI model processing;
- EspoCRM — our self-hosted CRM, controlled by BWAYS rather than by an outside company.
Not every provider receives personal information from every Website feature. Which provider is involved, and what it receives, depends on the feature you use and how it is configured. Voice features may also involve telephony or voice-platform providers that place, connect or record calls.
We may also disclose personal information to professional advisers, to authorities where the law requires or permits it, and to a successor if our business is reorganised or transferred. We keep control over our own CRM and do not give clients or other third parties general access to it.
Whether an AI provider may use submitted content to improve its own models depends on that provider’s terms and on the configuration of our account. This policy does not promise any specific position. If you want to know what applies to a particular feature, ask us at the contact address below.
AI interactions, recordings and transcripts
AI voice demonstrations are offered so that you can experience how a voice agent works. When you request a demonstration, you are told that the call is automated and that it may be recorded and transcribed, and we ask for your confirmation before the call is placed.
- What may be kept: the audio recording, the transcript, call details and your consent record.
- Why: to deliver the demonstration, to evaluate and improve its quality, to follow up on your interest if you asked us to, and to keep evidence of what you agreed to.
- How long: not indefinitely. See “Retention” below.
- Your telephone number: please enter only your own number, or one you are authorised to use. The call is placed only to the number you provide.
- Other people and sensitive information: please do not share other people’s personal information or sensitive information during a demonstration.
Demonstrations are different from services we provide to clients. Voice or AI systems we build or operate for a client are governed by that client’s agreement, and the recording, notice and consent arrangements for those systems are set for each deployment. Your confirmation on our Website applies to the demonstration you request; it is not permission to record other calls or other people, and we do not treat acceptance of our website terms as consent to recording.
Recording and call-monitoring rules differ between countries. If you prefer not to be recorded, do not start a demonstration, or tell us and we will handle your request as described under “Your rights”. AI-generated responses may be inaccurate or incomplete.
International processing and transfers
Our providers operate in several countries. As a result, personal information may be processed outside Costa Rica and outside your own country, including in countries whose data-protection rules differ from yours.
Where the law requires safeguards or your consent for such processing, we will put the required safeguards in place or ask for your consent before the transfer. We do not claim that any particular transfer mechanism applies unless it has been put in place.
Retention
We keep personal information only for as long as we need it for the purposes described in this policy, or longer where the law requires or where we need it to establish, exercise or defend legal claims. We do not keep personal information indefinitely without a reason. We treat different kinds of information differently:
- Enquiries and leads: kept while we are responding to you and while there is a reasonable prospect of a business relationship, then reviewed and deleted or anonymised when no longer needed.
- Business and client records: kept for the periods required by commercial, tax, accounting and other applicable law, and as needed to manage the contractual relationship.
- Voice recordings and transcripts: kept only as long as needed for the demonstration purposes described above, then deleted or anonymised. We do not keep them indefinitely.
- Security and technical logs: kept for a limited period needed to secure the Website and investigate abuse.
- Consent records: kept as long as needed to show what you agreed to. Your saved cookie preference lasts up to 120 days.
Security
We use technical and organisational measures that are appropriate to the nature of the information, such as encrypted connections, access controls limited to people who need access, separation of our CRM from other systems and careful selection of providers. No website or system is completely secure, and we cannot guarantee absolute security. We do not claim any security certification. If a security incident affects your personal information, we will act as the law requires.
Your privacy rights
Subject to the law that applies to you, you may ask us to:
- tell you whether we hold personal information about you and give you access to it;
- correct information that is inaccurate or incomplete;
- delete personal information, or restrict or stop certain uses of it;
- withdraw a consent you gave, including for recordings and optional cookies;
- provide your information in a portable format, where that right applies;
- stop sending you marketing communications.
These rights are not absolute. We may need to keep some information where the law requires it, where we need it for legal claims, or where deletion would affect the rights of others, and we will explain this if it applies. We may need to verify your identity before acting on a request. You may also complain to the data-protection authority that has jurisdiction, such as the Costa Rican data-protection agency, without prejudice to your other remedies.
How to make a privacy request
Write to office@bways.co.il with the subject “Privacy request”. Please tell us your name, the email address you used with us and what you would like us to do. If your request concerns a voice demonstration, include the telephone number and the approximate date and time of the call. We will respond within the time required by applicable law.
Third-party services and links
The Website may link to websites and services operated by others. We do not control them and are not responsible for their content or privacy practices. Please read their policies before giving them personal information.
Children’s privacy
The Website is intended for businesses and adults and is not directed to children under 18. We do not knowingly collect personal information from children. If you believe a child has given us personal information, contact us at office@bways.co.il and we will take appropriate steps.
Changes to this policy
We may update this policy as our Website, providers or legal obligations change. The “Last updated” date and version at the top show the current text. If we make a material change, we will make it visible on the Website and, where the law requires it, ask for your consent again.
Contact
HALOMOT MITGASHMIM SOCIEDAD DE RESPONSABILIDAD LIMITADA (S.R.L.), trading as BWAYS. Tinamaste de Barú, Pérez Zeledón, San José, Costa Rica. Email: office@bways.co.il.