Privacy Policy

Welya places data security and privacy at the heart of its priorities.

For its own activities, Welya applies all applicable requirements regarding the protection of personal data and makes available to its Clients tools designed to help them comply with their regulatory obligations, in particular under the General Data Protection Regulation (GDPR).

This Privacy Policy sets out the terms under which Welya, Inc. collects, processes, uses, stores and protects the personal data obtained through the use of the Welya platform.

Welya, Inc. is a company registered in the State of Delaware, United States, whose principal address is:

Welya, Inc.

131 Continental Dr, Suite 305

Newark, DE 19713

United States

In accordance with Article 27 of the GDPR, Welya has designated a representative in the European Union:

Marvin Hannachi

To be confirmed: Q-LEG-01: business postal address of the representative in the European Union

To be confirmed: Q-LEG-02: email address at which the representative can be reached

Welya operates the Welya platform and acts as a SaaS service provider.

As such, Welya exclusively provides a SaaS technical infrastructure enabling the hosting, distribution and automated processing of the data and content supplied by Clients, without any editorial intervention, without prior review and without any involvement in determining the purposes or the content of the processing carried out by Clients through the platform.

This Policy applies to all users, whether they reside in the United States, the European Union, the United Kingdom, Canada, Switzerland or any other jurisdiction.

Use of the platform constitutes full and unreserved acceptance of this Policy.

Definitions

Client / Client-Organizer: Means any natural or legal person acting in a professional capacity who holds an account on the Welya platform, uses the Service to organize, broadcast or administer webinars and, in that capacity, determines the purposes and means of the processing of data relating to Participants.

Participant: Means any natural person who registers for, accesses or takes part in a webinar organized through the Welya platform, and whose Personal Data is processed on behalf of the Client-Organizer.

User: Means any natural person accessing the Welya website or platform, whether a Client, a Prospect, an Authorized User or a Participant.

Authorized User: Means any person expressly authorized by the Client to access the Welya platform under the Client’s responsibility, in particular for the purposes of managing, configuring or administering webinars.

Prospect: Means any person who is not yet a Client but has provided certain Personal Data to Welya, in particular when signing up for a free trial period.

Service / Platform: Means all of the services, features, software tools, interfaces and infrastructure made available by Welya, accessible in particular through the website and associated applications, enabling the organization and broadcasting of webinars.

Personal Data: Means any information relating to an identified or identifiable natural person, within the meaning of the applicable data protection regulations, and in particular the General Data Protection Regulation (GDPR).

Client Data: Means all data, including Personal Data, provided, imported, generated or processed by the Client in the course of using the Welya platform, in particular data relating to Participants.

Controller: Means the natural or legal person that determines the purposes and means of the processing of Personal Data, within the meaning of the GDPR and equivalent legislation.

In the context of the Welya platform, the Client-Organizer acts as Controller for Participants’ data, and Welya acts as Controller for data relating to Client and Prospect accounts.

Processor: Means the natural or legal person that processes Personal Data on behalf of the Controller, on the Controller’s documented instructions. In the context of webinars, Welya acts as Processor for Participants’ data.

Sub-processor: Means any third-party provider that Welya may engage to carry out, on its behalf, certain Personal Data processing operations (hosting, security, technical broadcasting, payment, etc.), in compliance with the applicable contractual safeguards.

Cookies and Trackers: Means the files or technologies that may be placed or read on a user’s device when browsing the website or using the platform, enabling in particular the operation of the Service, audience measurement or the improvement of the user experience.

Standard Contractual Clauses (SCCs): Means the standard clauses adopted by the European Commission pursuant to Article 46 of the GDPR, governing transfers of Personal Data to third countries that do not benefit from an adequacy decision.

Policy: Means this Privacy and Personal Data Protection Policy, including its appendices.

1. Applicable legal framework

Given the geographical diversity of its users, Welya applies a combined legal framework in order to ensure consistent protection of personal data.

• United States: data is processed in compliance with rules governing user information, fair practices, data security and the protection of minors (Federal Trade Commission Act, Section 5; Children’s Online Privacy Protection Act, COPPA; Delaware General Corporation Law; California Consumer Privacy Act; California Privacy Rights Act, CCPA/CPRA).
• European Union: data is processed in accordance with the principles of transparency, purpose limitation, security and respect for the rights of Data Subjects (General Data Protection Regulation, GDPR).
• United Kingdom: data is processed in accordance with principles equivalent to those applicable within the European Union (United Kingdom General Data Protection Regulation, UK GDPR).
• Canada: data is processed on the basis of valid consent, with clear information provided to users and appropriate safeguards (Personal Information Protection and Electronic Documents Act, PIPEDA).
• Switzerland: data is processed in compliance with obligations of transparency, proportionality and enhanced security (Federal Act on Data Protection, revFADP).
• To be confirmed: Q-LEG-11: Brazil: data is processed in accordance with the Lei Geral de Proteção de Dados (LGPD, Law No. 13,709/2018)

It is the responsibility of the Client-Organizer to ensure that its own business, as well as its use of data, complies with the laws and regulations applicable in the country in which it operates.

This Policy does not relieve the Client-Organizer of its own legal and regulatory obligations.

2. Roles and responsibilities in data processing

When a Client uses the Welya platform to organize a webinar, import or collect data relating to Participants, or analyze their behavior, it acts as Controller within the meaning of the General Data Protection Regulation (GDPR), the UK GDPR, PIPEDA and equivalent legislation.

As such, the Client alone determines the purposes and means of the processing of Participants’ data and remains responsible for compliance with the applicable legal obligations, in particular regarding the information of Data Subjects and the legal basis for processing.

For data relating to webinar Participants (in particular names, email addresses, attendance and interaction data), Welya acts exclusively as Processor. Welya processes this data solely on the Client’s documented instructions and for the sole purpose of performing the webinar service.

Welya exercises no control over the content, messages, materials or interactions broadcast during webinars, which remain the sole responsibility of the Client-Organizer.

For data relating to the Client account (in particular name, email address, login credentials, subscription and billing), Welya acts as Controller, for its own purposes relating to the management of the platform and of the contractual relationship.

Welya may engage Sub-processors, such as providers of cloud hosting, video streaming, transactional email delivery, payment or technical security services.

In this context, Welya remains responsible for ensuring that these providers maintain an equivalent level of data protection and implements the appropriate contractual safeguards, including where data is hosted or processed in other jurisdictions.

3. Personal Data collected

In connection with the use of the Welya platform, Personal Data is collected and processed according to the capacity in which Welya acts:

• as Controller for data relating to Clients using the platform;
• as Processor for data relating to webinar Participants, processed on behalf of Client-Organizers.

3.1 Data collected by Welya as Controller

In connection with the creation, management and use of a Client account, Welya may collect the following data:

• first and last name;
• email address;
• telephone number, where applicable;
• payment information (bank details, card numbers, transaction date, transaction amount, transaction number). The banking and transaction information transmitted by the Client is encrypted by state-of-the-art software and cannot be read by Welya or by any third party.
• technical data relating to the use of the platform (IP address, connection logs, type of device and browser used).

The Personal Data collected by Welya from Clients using the platform is processed, in its capacity as Controller, solely for the purposes necessary for the performance of the contract, the management of the contractual relationship and the operation of the platform, namely:

• creating, managing and administering Client accounts;
• enabling access to, authentication on and secure use of the platform and its features;
• managing subscriptions, billing and payments;
• enabling the configuration, use and operation of the features offered by the platform;
• providing Client support and handling assistance requests;
• ensuring the security, integrity, availability and stability of the platform;
• preventing, detecting and addressing fraudulent or abusive use, or use that does not comply with the terms of use;
• improving and developing the features and performance of the Service.

This processing is strictly limited to what is necessary to provide the Service and to perform contractual obligations.

In addition, when a Prospect signs up for the free trial period, Welya collects and processes identification data (first and last name) and contact data (email address).

This data is processed by Welya as Controller, exclusively in order to deliver the requested content, manage the relationship with the Prospect and send informational communications relating to Welya’s business.

The Prospect may unsubscribe from the communications sent to them at any time, as described in each message.

The following details concern the welya.io website.

When a User visits the welya.io website and agrees to it, Welya, as Data Controller, processes browsing data: pages viewed, where the visit came from, country, device and browser type. This data is used to measure traffic to the site, to improve it and to know which channels lead to account creation. It is not used for targeted advertising. The legal basis for this processing is the User’s consent, which they may withdraw at any time; withdrawal does not affect processing carried out before it.

When a User arrives on the site through a link from a partner in Welya’s affiliate program and agrees to it, that partner’s code is kept by the FirstPromoter cookie and passed to the platform in the sign-up link. Welya then sends FirstPromoter, its affiliate program provider, the email address of the new account, its internal identifier and the partner’s code; a promo code specific to a partner produces the same attribution. This data is used to attribute the referral to the partner and calculate their commission. To be confirmed: Q-LEG-06: retention period for this attribution data at FirstPromoter and at Welya

When a Prospect requests a demo, the information they enter in the booking form is processed by Welya to organize the demo and respond to their request. This form is provided by Kombineo, acting on Welya’s behalf: each answer is saved as soon as it is confirmed, even before the booking, so that the request is not lost. To be confirmed: Q-LEG-12: legal basis for this processing (pre-contractual measures taken at the person’s request, or legitimate interest) and any later prospecting

3.2 Data processed by Welya as Processor

In connection with the organization and broadcasting of webinars, Welya processes the following Personal Data of Participants, exclusively on behalf of the Client-Organizer:

• first and last name;
• email address;
• telephone number, where requested by the Client;
• country and IP address;
• attendance duration and connection times;
• interactions during the webinar (messages, questions, poll responses, clicks on links or offers presented);
• technical data relating to the device and browser used.

This data is processed solely to ensure the proper running of webinars and the provision of the associated features, in accordance with the Client-Organizer’s instructions.

3.3 Data from integrations and third-party services

When using the Welya platform, the Client-Organizer may choose to connect third-party services, software or tools to the platform, such as customer relationship management (CRM) tools, email marketing solutions, automation tools, payment solutions or any other external API.

Where such integrations are set up, the Personal Data transmitted, synchronized or used through these third-party services is transmitted, synchronized or used at the initiative and under the sole responsibility of the Client-Organizer.

In this context, Welya acts solely as a technical provider enabling the interconnection of tools, without determining the purposes or means of the processing carried out through these third-party services.

It is the responsibility of the Client-Organizer to ensure that the third-party services it uses comply with the applicable data protection regulations and that Data Subjects have been duly informed, where applicable.

Welya shall not be held liable for processing carried out by these third-party services or for the conditions under which data is processed by them.

4. Disclosure of Personal Data

Personal Data collected and processed through the Welya platform is intended exclusively for Welya, acting, as the case may be, as Controller or Processor, in accordance with the provisions of this document.

Welya undertakes never to transfer, rent or sell Personal Data to third parties for commercial purposes.

No Personal Data is disclosed to third parties without the prior consent of the Data Subject, except in the cases set out below.

Welya may disclose certain Personal Data to Processors acting on its behalf (in particular providers of hosting, security, technical broadcasting or associated services), strictly to the extent necessary for the performance of the services entrusted to them.

These Processors only have access to the data strictly necessary for the performance of their contract with Welya and are bound by contractual confidentiality, security and data protection obligations equivalent to those set out in this document.

To operate the welya.io website, the recipients of the data include in particular: Google (Google Analytics, for traffic measurement; Google Tag Manager, for tag management; Firebase Hosting, for hosting the site); Igil Webs SRL, Talmaciu (Sibiu), Romania, publisher of FirstPromoter (management of the affiliate program); KOMBINEO SERVICES - FZCO, Dubai, United Arab Emirates, publisher of Kombineo (demo booking form). To be confirmed: Q-LEG-09: any other recipients of data coming from the site, for example the email sending tool

In addition, Welya may be required to disclose certain Personal Data in response to an express, legitimate and reasoned request from a competent administrative or judicial authority, or in order to comply with an applicable legal or regulatory obligation.

In such cases, only the strictly necessary data is disclosed.

5. Transfer of Personal Data outside the European Union

In connection with the use of the Welya platform, certain Personal Data may be hosted, accessed or processed outside the European Union, in particular in the United States, due to the location of certain technical providers or of the infrastructure used.

Where such transfers take place and concern data relating to residents of the European Union, Welya undertakes to ensure that these transfers are carried out in compliance with the applicable data protection requirements, and in particular the General Data Protection Regulation (GDPR).

Accordingly, transfers of data outside the European Union are governed by the Standard Contractual Clauses adopted by the European Commission, in accordance with Article 46 of the GDPR.

These Standard Contractual Clauses are available upon request.

For data coming from the welya.io website: Google LLC is certified under the EU-U.S. Data Privacy Framework; FirstPromoter is published by a company established in the European Union; Kombineo hosts its data in France and covers processing outside the European Union with the Standard Contractual Clauses (European Commission Decision 2021/914). To be confirmed: Q-LEG-10: mechanism covering the relationship between Welya and KOMBINEO SERVICES - FZCO (United Arab Emirates), to be confirmed with the signed data processing agreement

6. Retention period of Personal Data

Any personal information collected by Welya is retained only for the period strictly necessary to process the requests made by Data Subjects and/or to perform the requested services, in accordance with the applicable personal data protection regulations.

Welya undertakes to retain Personal Data only for as long as is necessary to achieve the purposes for which it was collected, as defined in this document, and, where applicable, for the period required to comply with its legal or regulatory obligations.

Data erasure and deletion procedures are implemented to ensure the effective deletion of Personal Data once the applicable retention or archiving period has expired, or when its continued processing is no longer necessary in light of the purposes pursued. Such deletion may take the form of permanent erasure or irreversible anonymization.

In addition, Clients and Users of the website may unsubscribe at any time from the informational or promotional communications sent to them. Each communication of this kind includes a simple and accessible unsubscribe mechanism.

Once the unsubscribe request has been processed, Welya stops sending such communications and, where applicable, deletes or updates the relevant data, in accordance with the applicable legal obligations.

Retention periods vary depending on the status of the Data Subject and the nature of the data processed.

• Personal Data relating to Clients, including in particular identification and account data and the associated professional information, is retained for as long as the Client account remains active.

From the closure of the account, this data is deleted or irreversibly anonymized within a maximum period of twenty-four (24) months, unless a legal obligation or evidentiary need justifies a longer retention period.

• Billing, accounting and contractual data necessary for Welya to comply with its legal and tax obligations is retained for a period of ten (10) years, in accordance with the applicable legal provisions.
• Technical data enabling the direct or indirect identification of Clients (in particular IP address and connection logs) is retained for a maximum period of twenty-four (24) months and then anonymized, in order to be used exclusively for statistical, technical, security and Service improvement purposes.
• Personal Data relating to Prospects and to Participants in online events, including in particular registration, identification and attendance data, is retained for the period strictly necessary for the organization, management and follow-up of the event concerned.

At the end of this period, this data is deleted or anonymized within a maximum period of twenty-four (24) months from the date of the event, unless otherwise instructed by the Client-Organizer or required by a specific legal obligation.

• Data resulting from interactions during online events (messages, poll responses, attendance rates, clicks on content), insofar as it constitutes Personal Data, is anonymized as soon as possible.

Once anonymized, this data may be retained without time limit in order to produce aggregated statistics and performance reports and to improve the features of the Service, without enabling the identification of Data Subjects.

• Identifying technical data relating to participation in online events (in particular IP addresses and connection timestamps) is retained for a maximum period of twelve (12) months and then anonymized, unless required for the security of the Service, the prevention of fraud or compliance with legal obligations.

• To be confirmed: Q-LEG-13: traffic measurement data from the welya.io website subject to the Google Analytics data retention setting is kept for fourteen (14) months. Setting to be confirmed once the Google Analytics property is created (Mama SEO)
• To be confirmed: Q-LEG-07: the origin of the visit linked to a Client account when it is created is kept for as long as the account is active. Sentence to be removed until the app records this origin (task G-06), then to be confirmed: duration, starting point, what happens when the account is closed
• Information entered when requesting a demo is kept by Kombineo for as long as Welya subscribes to this service, then deleted within one hundred and eighty (180) days after it ends; Welya can delete it at any time, and does so at the request of the person concerned. To be confirmed: Q-LEG-08: retention period chosen by Welya for the prospect records resulting from these requests

The Client-Organizer remains solely responsible for the Personal Data that it collects, imports, processes or uses through the Welya platform, in particular in connection with the webinars it organizes.

As such, the Client-Organizer determines the purposes and retention periods applicable to Participants’ data and ensures that they comply with the legal and regulatory requirements in force, in particular with regard to the protection of Personal Data.

Welya acts exclusively as Processor for Participants’ data and plays no role in defining the applicable purposes or retention periods, other than providing technical tools that enable the Client-Organizer to manage them.

Welya shall not be held liable for any failure by the Client-Organizer to comply with its obligations as Controller.

7. Rights of the person whose Personal Data is collected

In accordance with the applicable personal data protection regulations, and in particular the General Data Protection Regulation (GDPR), any person whose Personal Data is collected and processed has the following rights:

• Right of access: Every Data Subject has the right to obtain confirmation as to whether or not Personal Data concerning them is being processed and, where that is the case, to access that data and the information provided for by the applicable regulations.
• Right to rectification: Every Data Subject may request the rectification of Personal Data concerning them where it is inaccurate, incomplete or out of date.
• Right to erasure: Every Data Subject may request the erasure of their Personal Data under the conditions provided for by the applicable regulations, in particular where the data is no longer necessary in relation to the purposes for which it was collected or processed.
• Right to restriction of processing: Every Data Subject may request the restriction of the processing of their Personal Data in the cases provided for by the regulations, in particular where the accuracy of the data is contested or where the processing is unlawful.
• Right to data portability: Where the processing is based on consent or on the performance of a contract and is carried out by automated means, every Data Subject has the right to receive the Personal Data concerning them in a structured, commonly used and machine-readable format, or to request that it be transmitted to another Controller.
• Right to object: Every Data Subject may object at any time, on grounds relating to their particular situation, to the processing of their Personal Data where such processing is based on legitimate interest, under the conditions provided for by the applicable regulations.
• Right to withdraw consent: Where the processing is based on consent, the Data Subject may withdraw their consent at any time, without affecting the lawfulness of the processing carried out before such withdrawal.

Where Welya acts as Processor on behalf of a Client-Organizer, requests from Participants are forwarded to the relevant Client-Organizer, which remains solely competent to respond to them in its capacity as Controller.

Welya undertakes to cooperate with the Client-Organizer to enable it to respond to Data Subjects’ requests within the statutory time limits.

If the person from whom the data is collected wishes to obtain information about the processing of their Personal Data, exercise their rights (in particular the rights of access, rectification, objection or erasure) or object to any processing, they may send their request to the following contact details:

Welya, Inc.

131 Continental Dr, Suite 305

Newark, DE 19713

United States

contact@welya.io

Persons located in the European Union may also send their request to Welya’s representative in the European Union, whose contact details appear at the beginning of this Policy.

To enable the request to be processed, the Data Subject is invited to specify the subject of their request and to indicate the Personal Data they wish to have rectified, updated or deleted.

For identity verification purposes, Welya may request a copy of a valid identity document (national identity card or passport), which will be used solely for the purpose of processing the request and will not be retained beyond that purpose.

Requests for the erasure of Personal Data may be limited where the retention of certain data is required under legal or regulatory obligations, in particular with regard to the retention or archiving of documents.

Finally, every Data Subject has the right to lodge a complaint with the competent supervisory authority or with any other supervisory authority that is competent according to their jurisdiction of residence.

In France, the competent supervisory authority is the Commission nationale de l’informatique et des libertés (CNIL), 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07 (www.cnil.fr). To be confirmed: Q-LEG-14: in Brazil, the Agência Nacional de Proteção de Dados (ANPD), under Law No. 15,352 of February 25, 2026, if Brazil is added to the legal framework (Q-LEG-11)

8. Protection of the Personal Data collected

Welya implements appropriate technical and organizational measures to ensure a level of security appropriate to the risks presented by the processing of Personal Data, in accordance with the applicable legal and regulatory requirements.

These measures aim in particular to ensure the confidentiality, integrity, availability and resilience of the systems and services processing Personal Data, and to prevent any destruction, loss, alteration, unauthorized disclosure of or unauthorized access to such data.

Accordingly, Welya implements in particular, where relevant:

• an infrastructure hosted within isolated private networks, with no external exposure beyond the flows strictly necessary for the operation of the Service (VPC, subnets, firewalls, NAT);
• encryption of data flows using secure protocols that comply with current standards (TLS / HTTPS);
• an application firewall (Web Application Firewall, WAF) incorporating protection mechanisms against DDoS attacks and common application vulnerabilities (OWASP);
• strong authentication mechanisms for access to internal tools, technical infrastructure and user accounts;
• strict and limited control of access to Personal Data;
• logging, monitoring and security incident management procedures.

Access to Personal Data is strictly limited to authorized persons, to the extent necessary for the performance of their duties.

Where Welya acts as Processor on behalf of a Client-Organizer, it undertakes to apply security measures that comply with industry standards and to cooperate with the Client-Organizer to enable it to comply with its own data protection obligations.

In the event of a Personal Data breach, Welya undertakes to notify the Client-Organizer without undue delay after becoming aware of it, and to cooperate in order to enable, where applicable, the required notifications to be made to the competent authorities and to the Data Subjects.

9. Data of minors

The Welya platform is intended exclusively for adults and for professionals acting in the course of their business.

Welya does not knowingly collect or process Personal Data concerning minors under the age of 18. Use of the platform by a minor is not permitted.

Should Personal Data concerning a minor be collected unintentionally, in particular in the context of a webinar organized by a Client-Organizer, the latter remains solely responsible for the lawfulness of such collection and for compliance with the applicable legal obligations, in particular with regard to obtaining parental consent where required.

As soon as Welya becomes aware of the collection or processing of Personal Data concerning a minor in breach of the applicable provisions, Welya undertakes to take appropriate measures to delete such data as soon as possible.

The Client-Organizer shall indemnify Welya against any claim, penalty or damage resulting from the collection or processing of Personal Data of minors carried out through the platform in breach of the applicable laws and regulations.

10. Hyperlinks

The Welya website and platform may contain hyperlinks to third-party websites or services, provided in particular for informational or functional purposes.

Welya exercises no control over the content of these third-party websites and shall not be held liable for their content, their practices, their privacy policies or the Personal Data processing they carry out.

Access to these third-party websites is at the sole responsibility of the User, Prospect or Client, who are invited to read the terms of use and privacy policies applicable to those websites.

The presence of hyperlinks to third-party websites does not imply any validation, endorsement or partnership on the part of Welya with respect to such websites or the information published on them.

11. Cookies and tracking technologies

When browsing the website or using the Welya platform, cookies and other trackers may be placed on the device of the User, Prospect, Client or Participant, subject to the choices expressed in accordance with the applicable regulations.

11.1 Definition of cookies

A cookie is a text file that may be stored on the user’s device when visiting a website or using an online service. It makes it possible in particular to recognize a device, remember preferences or collect information about browsing.

11.2 Cookies used by Welya

Welya uses different types of cookies:

• Strictly necessary cookies: these are essential for the operation of the website and the platform, the security of access, user authentication and the use of essential features. They cannot be disabled.
• Audience measurement and performance cookies: these make it possible to analyze the use of the website and the platform, measure traffic and improve performance and the user experience.
• Functional cookies: these make it possible to remember certain choices or preferences of the user in order to make browsing easier.
• Cookies relating to webinars and interactions: in the context of webinars, cookies or trackers may be used to enable participation in sessions, the tracking of interactions and the technical analysis of the proper running of webinars.

The cookies and trackers set by the welya.io website are the following:

• wl_consent (Welya): remembers the choices made in the cookie manager, whether acceptance or refusal, so they are not asked again on every page. Strictly necessary. Duration: 182 days, or about six months.
• _ga and To be confirmed: Q-LEG-04: full name of the _ga_… cookie observed in production (Mama SEO) (Google Analytics): measurement of traffic to the site (pages viewed, where visits come from, country, device type). Set only if the User accepts the “Analytics” category. Duration: To be confirmed: Q-LEG-05: thirteen (13) months at most, duration set in the Google tag, to be confirmed once the tag is live (Mama SEO).
• wl_attr (Welya): remembers where the visit came from (search engine, AI assistant, social network, campaign, referring site or partner link) and the landing page, in order to know which channel leads to the creation of an account. It keeps limited information, after excluding values likely to contain personal data. Set only if the User accepts the “Analytics” category. Duration: ninety (90) days.
• FirstPromoter cookies (_fprom_…, To be confirmed: Q-LEG-15: exact names observed in production (Mama SEO); Igil Webs SRL, Romania): identify the partner in Welya’s affiliate program who recommended the site. Set only if the User accepts the “Partner program” category. Duration: To be confirmed: Q-LEG-16: tracking duration set in FirstPromoter.
• wl_demo_source and wl_demo_comptee (Welya, browser session storage): keep the page from which the demo form was opened and avoid counting the arrival on the confirmation page more than once in the same tab. Only if the User accepts the “Analytics” category. Duration: that of the tab session.

When the User refuses a category or withdraws their consent, the corresponding measurement or attribution operations stop and the corresponding cookies and session storage accessible to the site are deleted. Withdrawal does not affect processing carried out before it.

11.3 Consent

In accordance with the applicable regulations, cookies that are not strictly necessary are placed only after the user’s prior consent has been obtained through a consent management tool.

The user may modify or withdraw their consent at any time, in the manner provided by the cookie manager made available on the website or platform.

On the welya.io website, this mechanism takes the form of a banner shown on the first visit. It offers two optional purposes, turned off by default: measurement of traffic and of where visits come from (“Analytics”) and attribution of referrals to partners in the affiliate program (“Partner program”). The User can accept all, reject all or choose purpose by purpose, rejecting being as easy as accepting. Their choices are kept for 182 days, then asked again, and can be changed at any time from the “Manage cookies” link in the footer. The welya.io website uses no targeted advertising trackers.

11.4 Responsibility of the Client-Organizer

Where cookies or trackers are used in connection with webinars organized by a Client-Organizer, in particular for tracking or analysis purposes, it is the responsibility of the Client-Organizer, in its capacity as Controller, to inform Participants and, where applicable, to obtain their consent in accordance with the applicable regulations.

In this context, Welya acts solely as a technical provider and makes available the tools needed to manage cookies, without determining the purposes of the processing decided by the Client-Organizer.

11.5 Cookie settings

The user may also configure their browser to refuse all or some cookies.

However, disabling certain cookies may impair access to, or the operation of, certain features of the website or platform.

12. Web beacons (“tags”)

Welya may use web beacons (also known as “tags”, “pixels” or “invisible beacons”) on its website or on the platform.

Web beacons are pieces of code embedded in web pages or emails that make it possible to collect technical or statistical information about the use of the website or platform, such as, in particular, viewing a page, opening an email or interacting with certain content.

The main purposes of the web beacons used by Welya are:

• audience measurement and analysis;
• improving the performance and operation of the website and the platform;
• security and the prevention of fraudulent use;
• technical monitoring of the features offered, in particular in connection with webinars.

Where the use of web beacons is equivalent to cookies or trackers subject to prior consent, they are deployed in accordance with the choices expressed by the user, the applicable regulations and the settings defined through the consent management tool.

Where web beacons are used in connection with webinars organized by a Client-Organizer, in particular for tracking or analysis purposes, it is the responsibility of the Client-Organizer, in its capacity as Controller, to inform Participants and, where applicable, to obtain their consent in accordance with the regulations in force.

In that case, Welya acts solely as a technical provider, without determining the purposes of the processing decided by the Client-Organizer.

On the welya.io website, Google Tag Manager is used to manage when tags fire. Measurement and attribution tags only fire according to the choices made in the cookie manager.

13. Amendments to the Policy

This Privacy and Personal Data Protection Policy may be amended or updated at any time by Welya, in particular to take into account legal, regulatory, case-law, technical or operational developments, or any change in the services offered.

Any material change will be notified in advance by any appropriate means, in particular by publication on the Welya website or platform, or by electronic communication where required.

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