Privacy Policy

‍Privacy Policy

Updated as of July 1st, 2025.

For previous versions of the privacy policy, see here.

Kouto Inc. d/b/a Way ("Way," "we", “us” or "our") is an all-in-one experiences platform aimed at helping partners create elevated experiential programs to drive ancillary revenue and deepen brand loyalty. This Privacy Policy describes how Way processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable, our website, web application, member platform,  and social media pages) as well as our marketing activities, live events and other activities described in this Privacy Policy (collectively, the “Service”). 

This Privacy Policy does not apply to information that we process on behalf of our business customers (such as hotel properties and experience hosts) while providing services to them. Our use of information that we process on behalf of our business customers may be governed by our agreements with such customers. If you have concerns regarding your personal information that we process on behalf of a business customer, please direct your concerns to that customer.

Personal information we collect

Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:

  • Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, name, and phone number.
  • Demographic data, such as your city, state, country of residence, postal code, and age.
  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.Profile data, such as the username and password that you may set to establish an online account on the Service, biographical details, job title, photograph or picture, date of birth, preferences, and any other information that you add to your account profile.  
  • Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history. 
  • Payment data needed to complete transactions, such as payment card or bank account information, is collected and processed directly by our third-party payment provider. We do not store your full payment card information on our servers—instead, we use secure tokens provided by the payment processor to facilitate transactions.
  • Communications data, including our exchanges with you when you contact us through the Service. This may include messages via chat features, social media, or other channels. We currently use Intercom to facilitate customer support and live chat interactions. In the future, we may introduce commenting functionality within our products to allow users to interact with each other while building experiences.
  • Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
  • User-generated content data, such as any communications you send to other users through the Service as well as your comments, questions, messages, works of authorship, activations, and other content or information that you generate, transmit, or otherwise make available on the Service, including associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data.
  • Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Data about others. We may offer features that help users invite their contacts to use the Service, and we may collect contact details about these invitees so we can deliver their invitations. Please do not refer someone to us or share their contact details with us unless you have their permission to do so.

Third-party sources. We may combine personal information we receive from you with personal information falling within one of the categories identified above that we obtain from other sources, such as:
  • Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
  • Data providers, such as information services and data licensors. 
  • Service providers that provide services on our behalf or help us operate the Service or our business.
  • Partners, such as joint marketing partners and event co-sponsors.
Automatic data collection. We, our service providers, and our marketing partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:
  • Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
  • Location data when you authorize the Service to access your device’s location.
  • Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails. 
Cookies and similar technologies. Some of the automatic collection described above is facilitated by the following technologies:
  • Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place. 
  • Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications. 
  • Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked. 
  • Session-replay technologies, such as those provided by Posthog that employ software code to record users’ interactions with the Services in a manner that allows us to watch video replays of those user sessions. The replays include users’ clicks, mobile app touches, mouse movements, and scrolls during those sessions. These replays help us diagnose usability problems and identify areas for improvement. We configure these tools to mask sensitive user inputs to protect personal information. You can learn more about Posthog at https://posthog.com/privacy.
How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to:
  • provide, operate and improve the Service and our business;
  • enable security features of the Service;
  • personalize the service, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Service;
  • establish and maintain your user profile on the Service;
  • communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, user-to-user communications, and support and administrative messages;
  • communicate with you about events for which you register;
  • understand your needs and interests, and personalize your experience with the Service and our communications; and
  • provide support for the Service, and respond to your requests, questions and feedback;
  • to collect and share user testimonials 

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We make personal information into anonymous or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business. 

Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services. For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.  

We may use artificial intelligence (“AI”) technologies, including those that employ cookies and software code, to power features within the Service. These technologies may process information such as webpages visited on our website, your IP address, general geographic information (e.g., city, state), and other personal information you choose to share. Such features may include experience suggestions, intelligent pricing, data analytics, and personalized recommendations for users and brands. If and when we engage third-party AI providers, we will update this policy to include the relevant vendor information and a link to their privacy practices.

Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:
  • Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.  
  • Interest-based advertising. We and our third-party advertising partners may use cookies and other technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Service, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the Your choices section of our Cookie Notice. 
Compliance and protection. We may use your personal information to:
  • comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
  • protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); 
  • audit our internal processes for compliance with legal and contractual requirements or our internal policies; 
  • enforce the terms and conditions that govern the Service; and 
  • prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.  
With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.  

Cookies and similar technologies. In addition to the other uses included in this section, we may use the Cookies and similar technologies described above for the following purposes:

  • Technical operation. To allow the technical operation of the Service.
  • Functionality. To enhance the performance and functionality of our services.
  • Advertising. To help our third-party advertising partners collect information about how users use the Service over time, which they use to show ads on other online services and measure how the ads perform.
  • Analytics. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails. For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.
Data sharing in the context of corporate events, we may share certain personal information in the context of actual or prospective corporate events – for more information, see How we share your personal information, below.

Further uses, in some cases, we may use your personal information for further uses, in which case we will ask for your consent to use your personal information for those further purposes if they are not compatible with the initial purpose for which information was collected.

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How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.  

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, online chat functionality providers, email delivery, marketing, consumer research and website analytics). 

Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Stripe. Stripe may use your payment data in accordance with its privacy policy, available at https://stripe.com/privacy.

Artificial intelligence platforms. We may use third-party artificial intelligence (AI) providers to power certain aspects of the Services, such as suggesting experience ideas to users and brands, as well as offering intelligent pricing of experiences, data analytics, and recommendations. If and when we engage an AI provider, we will update this policy to include the relevant vendor information and a link to their privacy policy.

Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above. 

Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so.

Sponsor Partners. Third parties with whom we partner, including parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above. 

Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Way, financing of Way, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares). For example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Way as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

Other users and the public. Certain of your Profile data, data may be visible to other users of the Service and the public. For example, other users of the Service may have access to your information if you chose to make your profile or other personal information available to them through the Service, including in relation to experiences made available through the Service, when you communicate through the Service, provide comments, reviews, or share other content.  This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information.

Your choices 
In this section, we describe the choices available to you.

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account and navigating to Your Profile. Please refer to Way’s self-service help documentation for help updating your account or contact support@way.co with questions not addressed in the help center.

Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.  

Mobile location data. You can disable our access to your device’s precise geolocation in your mobile device settings.

Blocking images/clear gifs: Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Advertising choices. You may be able to limit use of your information for interest-based advertising through the following settings/options/tools:

  • Browser settings. Changing your internet web browser settings to block third-party cookies.
  • Privacy browsers/plug-ins. Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies. 
  • Platform settings. Google and Facebook offer opt-out features that let you opt-out of use of your information for interest-based advertising. You may be able to exercise that option at the following websites:
  • Ad industry tools. Opting out of interest-based ads from companies that participate in the following industry opt-out programs: 
  • Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

You will need to apply these advertising-related opt-out settings on each device and browser from which you wish to limit the use of your information for interest-based advertising purposes. We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above. 

Training data. While we do not currently use customer personal information to train our AI models, we may do so in the future, provided that such information is aggregated, de-identified, and/or anonymized, as described in the How We Use Personal Information section. This would help improve the Service. If we begin this practice, we will update this policy accordingly and provide you with the ability to opt out.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security 

We employ technical, organizational and physical safeguards that are designed to protect the personal information we collect. However, security risk is inherent in all Internet and information technologies, and we cannot guarantee the security of your personal information.

International data transfer

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.  

Children  

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy 

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.

How to contact us
  • Email: info@way.co
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