Privacy Policy

Last Updated: August 28, 2026

PawLogic Inc., a Delaware corporation with a business address at 1200 Brickell Avenue, Suite 510, Miami, FL 33131, United States (“PawLogic,” “Actionway,” “we,” “us,” or “our”), respects your privacy.

This Privacy Policy describes how we collect, use, disclose, retain, and otherwise process Personal Data when you use Actionway.ai, including our websites, APIs, developer tools, dashboards, software, capabilities, and related services (collectively, the “Service”).

“Personal Data” means information that identifies, relates to, describes, or can reasonably be linked to an identified or identifiable individual.

Scope

This Privacy Policy applies to Personal Data processed by Actionway in connection with the Service.

It does not govern the independent privacy practices of third-party Tool Providers.

When you or your Agent invokes a third-party Tool through Actionway, information necessary to execute that Tool Call may be transmitted to the applicable Tool Provider. The Tool Provider's own privacy policy, terms, retention practices, training policies, and other rules may apply to its processing.

If you use Actionway through an organization, enterprise account, or other business customer, additional contractual terms, including a Data Processing Addendum, may apply.

Personal Data We Collect

2.1 Account Information

We may collect:

• name;
• email address;
• account identifiers;
• company or organization information;
• authentication information;
• account preferences;
• team membership; and
• account configuration.

2.2 Billing and Transaction Information

When you purchase Balance, enable Auto Pay, or otherwise make payments, we may collect:

• billing information;
• transaction identifiers;
• purchase amounts;
• refund information;
• Purchased Balance;
• Promotional Credits;
• Auto Pay settings;
• Recharge Threshold;
• Recharge Amount;
• payment status;
• invoice information; and
• limited payment method information.

Payments may be processed by third-party payment processors.

Actionway generally does not receive or store complete payment card numbers.

2.3 Tool Call Information

When you or your Agent initiates a Tool Call, Actionway may temporarily process information necessary to execute the request, which may include:

• prompts;
• queries;
• instructions;
• API parameters;
• URLs;
• files;
• images;
• structured data;
• documents;
• identifiers;
• other Tool Input; and
• Tool Output returned by the applicable Tool.

The specific content depends on the Tool being used.

Tool Call content may contain Personal Data about you or other individuals.

You are responsible for ensuring that you have the rights, permissions, notices, consents, or other lawful basis necessary to submit Personal Data through the Service.

2.4 Tool Call Metadata

We may collect and retain metadata relating to Tool Calls, such as:

• account identifier;
• Agent or API key identifier;
• Tool or Capability identifier;
• Tool Provider identifier;
• timestamp;
• execution status;
• usage quantity;
• billing unit;
• charge amount;
• latency;
• request or transaction identifier;
• technical error codes;
• fraud and abuse signals; and
• operational and security information.

2.5 Device and Usage Information

We may automatically collect:

• IP address;
• browser type;
• operating system;
• device information;
• approximate location derived from IP address;
• access dates and times;
• pages or Service features used;
• API activity;
• referral information;
• advertising campaign and click identifiers;
• a randomly generated browser installation identifier;
• diagnostic information;
• performance information; and
• security signals.

2.6 Communications

When you contact us, request support, communicate with sales, submit a refund request, or otherwise communicate with Actionway, we may collect:

• your contact information;
• account information;
• the contents of your communication; and
• related support or transaction information.

How We Use Personal Data

We may use Personal Data to:

• provide and operate Actionway;
• authenticate users;
• maintain accounts;
• execute and route Tool Calls;
• transmit Tool Inputs to applicable Tool Providers;
• return Tool Outputs;
• meter Tool usage;
• calculate charges;
• maintain Purchased Balance;
• operate Auto Pay;
• process payments and refunds;
• provide invoices and transaction records;
• provide technical and customer support;
• troubleshoot Service issues;
• maintain security;
• detect fraud and abuse;
• identify potentially abnormal or runaway automated usage;
• enforce our Terms of Service;
• comply with applicable law;
• respond to lawful legal requests;
• analyze Service performance;
• improve Actionway infrastructure and functionality; and
• communicate material Service, policy, security, or billing updates.

Tool Input and Tool Output Retention

4.1 Default Retention Practice

Actionway does not persistently store the substantive contents of Tool Inputs or Tool Outputs by default after the applicable Tool Call has been completed.

Tool Input or Tool Output content may be processed temporarily in memory, transit, caches, queues, logs, or other technical systems as reasonably necessary to execute and deliver the Tool Call.

We may retain Tool Call metadata as described in this Privacy Policy even after substantive Tool Input or Tool Output content is no longer retained.

4.2 Your Responsibility for Agent Memory and Storage

Actionway should not be treated as the permanent memory, conversation archive, file storage system, backup service, or historical data repository for your Agent.

If you or your Agent requires continued access to:

• Tool Inputs;
• Tool Outputs;
• conversation history;
• previous actions;
• context;
• Agent memory;
• execution history;
• files; or
• other historical information,

you are responsible for ensuring that your Agent, application, database, or other system has appropriate data storage, backup, retention, and retrieval capabilities.

You should not assume that Actionway will be able to retrieve, reconstruct, or restore the substantive contents of a completed Tool Call.

4.3 Limited Temporary Retention

In limited circumstances, Actionway may temporarily retain relevant Tool Input or Tool Output content where reasonably necessary to:

• investigate a customer-reported technical issue;
• debug a Tool Call;
• investigate fraud or abuse;
• investigate a security incident;
• prevent harm to Actionway or third parties; or
• comply with applicable law.

Unless a longer period is required by law or reasonably necessary to resolve an ongoing legal, security, fraud, abuse, or compliance investigation, such content will generally be retained for no more than thirty (30) days.

Access to temporarily retained Tool Input or Tool Output content may be restricted to personnel or service providers with a legitimate need to access it for the relevant purpose.

Tool Providers

5.1 Information Shared with Tool Providers

When you or your Agent requests a Tool Call, Actionway may transmit information reasonably necessary to perform that Tool Call to the applicable Tool Provider.

For example, depending on the Tool, this may include:

• a query;
• prompt;
• URL;
• document;
• image;
• identifier;
• search term;
• structured parameter; or
• other requested input.

This transmission is necessary to provide the Tool you requested.

5.2 Tool Provider Categories and Providers

Actionway may disclose Tool Input data to third-party Tool Providers used to provide the requested Capability.

Current or supported Tool Providers are identified in Appendix A of the Actionway Terms of Service and may include providers of:

• artificial intelligence and model APIs;
• model hosting;
• voice synthesis;
• image or media generation;
• AI infrastructure;
• cloud compute;
• API gateway services;
• search, data, or retrieval services; and
• other Tool functionality requested through Actionway.

The specific provider used for a particular Tool Call may depend on the Capability, technical configuration, routing, availability, geography, user settings, or other operational considerations.

Where reasonably available, Actionway may provide information regarding the Tool Provider and applicable data practices on the relevant Capability page.

5.3 Independent Tool Provider Practices

Tool Providers may maintain their own:

• privacy policies;
• terms of service;
• data retention periods;
• logging practices;
• security practices;
• model-training practices;
• subprocessors;
• processing locations; and
• legal obligations.

Actionway's own data retention or training practices do not necessarily apply to information after it has been transmitted to an independent Tool Provider.

We encourage users to evaluate whether a particular Tool Provider's practices are appropriate for the data they intend to submit.

AI and Machine-Learning Training

Actionway does not use the substantive contents of your Tool Inputs or Tool Outputs to train generalized artificial intelligence or machine-learning models unless you expressly opt in to such use.

We may use aggregated, statistical, or de-identified information that does not reasonably identify you and does not reveal substantive Tool Input or Tool Output content to:

• analyze Service performance;
• improve routing;
• improve reliability;
• understand aggregate usage patterns;
• prevent fraud;
• identify abnormal automated usage; and
• improve Actionway infrastructure.

Third-party Tool Providers may have different policies regarding training, model improvement, logging, or retention.

Their independent use of Tool Inputs or Tool Outputs is governed by their applicable terms and privacy practices.

Cookies and Similar Technologies

Actionway and our service providers may use cookies, local storage, software development kits, pixels, and similar technologies where reasonably necessary to:

• maintain user sessions;
• authenticate accounts;
• remember settings;
• maintain security;
• prevent fraud;
• measure Service performance;
• understand product usage; and
• improve the Service.

Your browser may allow you to block or delete cookies and similar technologies, although doing so can affect measurement or some Service features.

Actionway uses Google Analytics 4 to measure public page views, account registrations, and successful Balance purchases and to understand the campaign, referral, or direct source associated with those events. Depending on the event, the information sent may include the page URL and referrer, bounded campaign attributes, a random browser installation identifier, an internal Actionway user identifier after registration, registration surface, transaction identifier, currency, and purchase value. We do not send complete payment card numbers or Tool Input or Tool Output content to Google Analytics.

Our Google tag disables advertising personalization signals. We may link Google Analytics with our Google Ads account to measure campaign performance and import registration and purchase conversions. This measurement is part of the Service's standard analytics operation and is not controlled by an in-product analytics consent setting.

How We Disclose Personal Data

We may disclose Personal Data to the following categories of recipients.

8.1 Tool Providers

We disclose information necessary to execute Tool Calls requested by you or your Agent.

Tool Providers may process that information under their own terms and privacy practices.

8.2 Service Providers

We may use third-party companies to provide:

• cloud infrastructure;
• hosting;
• authentication;
• payment processing;
• email delivery;
• security;
• fraud prevention;
• monitoring;
• analytics;
• customer support; and
• other operational services.

These service providers may process Personal Data in connection with services they provide to Actionway.

Google LLC provides Google Analytics and Google Ads measurement services. Google's own privacy terms and international processing practices may apply.

8.3 Affiliates

We may disclose Personal Data to our corporate affiliates where reasonably necessary to operate our business, administer accounts, maintain infrastructure, provide support, or provide the Service.

8.4 Legal and Safety Disclosures

We may disclose Personal Data where we reasonably believe disclosure is necessary to:

• comply with applicable law;
• respond to legal process;
• comply with a lawful governmental request;
• enforce our agreements;
• investigate fraud or security incidents;
• protect Actionway, our users, Tool Providers, or third parties;
• prevent illegal activity; or
• establish, exercise, or defend legal claims.

8.5 Business Transactions

Personal Data may be disclosed or transferred in connection with:

• a merger;
• acquisition;
• financing;
• corporate reorganization;
• sale of assets;
• bankruptcy; or
• similar transaction.

8.6 At Your Direction

We may disclose information where you instruct or authorize us to do so.

Sale, Sharing, and Advertising

Actionway does not sell the substantive contents of your Tool Inputs or Tool Outputs.

Actionway does not use the substantive contents of Tool Calls for cross-context behavioral advertising.

We do not sell Personal Data for monetary consideration.

If our practices materially change in the future, we will update this Privacy Policy and provide legally required notices, choices, consent mechanisms, or opt-out mechanisms where applicable.

Payments and Auto Pay

Payment transactions may be processed by third-party payment processors.

When you enable Auto Pay, Actionway maintains information regarding:

• whether Auto Pay is enabled;
• your selected Recharge Threshold;
• your selected Recharge Amount;
• payment status; and
• limited information associated with the payment method.

Your Recharge Threshold and Recharge Amount are selected by you and may be modified or disabled by you through the applicable account settings.

Your payment processor may independently process additional Personal Data to:

• complete payments;
• authenticate payment methods;
• prevent fraud;
• manage disputes; and
• comply with legal obligations.

The payment processor's own privacy policy applies to its independent processing.

Actionway may use account, usage, transaction, and security information to detect potentially abnormal payment or usage activity and to apply available safeguards such as alerts, throttling, spending controls, temporary payment restrictions, or account review.

Data Retention

Different categories of Personal Data may be retained for different periods.

Account Information

We generally retain account information while your account remains active and for a reasonable period afterward as necessary for legitimate business, legal, security, fraud-prevention, and compliance purposes.

Billing and Transaction Records

We may retain billing, payment, refund, tax, accounting, and transaction records for periods required by applicable law or reasonably necessary for financial recordkeeping, fraud prevention, chargeback management, audits, and dispute resolution.

Tool Input and Output Content

As described above, Actionway does not persistently store substantive Tool Input and Tool Output content by default following completion of a Tool Call.

Limited temporary retention may occur for the purposes and periods described in Section 4.3.

Tool Call Metadata

We may retain Tool Call metadata for legitimate purposes including:

• billing;
• accounting;
• fraud prevention;
• security;
• operational analytics;
• troubleshooting;
• service reliability;
• compliance; and
• dispute resolution.

Legal and Security Information

We may retain information longer where reasonably necessary to:

• comply with law;
• preserve evidence;
• enforce agreements;
• investigate fraud;
• respond to security incidents;
• address abuse; or
• resolve disputes.

When Personal Data is no longer reasonably required, we may delete, aggregate, or de-identify it, subject to backup, legal, and technical retention requirements.

Enterprise and Team Accounts

If you access Actionway through a company, team, or other organization, that organization may control your Actionway account or certain information associated with it.

Organization administrators may have access to information such as:

• account membership;
• usage information;
• API or Agent activity;
• billing information;
• Tool Call metadata; and
• administrative settings.

Where Actionway processes Personal Data on behalf of an enterprise customer as a processor or service provider, a separate Data Processing Addendum or other enterprise agreement may govern that processing.

International Processing

Actionway is operated by PawLogic Inc. in the United States.

Personal Data may be processed in the United States and in other jurisdictions where:

• our service providers operate;
• Tool Providers operate; or
• their subprocessors operate.

Those jurisdictions may provide data protection rules different from those in your jurisdiction.

Where required by applicable law, Actionway will use appropriate mechanisms or safeguards for international transfers of Personal Data.

Your Privacy Rights

Depending on your location and applicable law, you may have rights relating to Personal Data, including the right to:

• request access;
• request correction;
• request deletion;
• obtain a portable copy of certain information;
• object to or restrict certain processing;
• withdraw consent where processing is based on consent;
• opt out of certain sales, sharing, targeted advertising, or profiling where applicable; and
• appeal certain privacy decisions where applicable.

These rights may be subject to legal exceptions.

To submit a privacy request, email:

**assist@actionway.ai**

and describe your request.

We may request information reasonably necessary to verify your identity and protect your account.

Where permitted by law, an authorized agent may submit a request on your behalf, subject to appropriate verification.

California Privacy Information

If applicable California privacy law applies to our processing of your Personal Data, California residents may have rights that include rights to:

• know or access certain Personal Data;
• request deletion;
• request correction;
• receive information regarding categories of Personal Data collected or disclosed;
• opt out of sale or sharing where applicable;
• limit certain uses of sensitive Personal Data where applicable; and
• receive equal service and pricing notwithstanding the exercise of applicable privacy rights.

Actionway does not sell the substantive contents of Tool Inputs or Tool Outputs.

Actionway does not use substantive Tool Call content for cross-context behavioral advertising.

Requests may be submitted to:

**assist@actionway.ai**

Nothing in this Section is intended to provide fewer rights than applicable California law requires.

Where applicable law requires recognition of an authorized opt-out preference signal, Actionway will process such a signal as required by law.

European Economic Area, United Kingdom, and Similar Jurisdictions

Where applicable law requires a lawful basis for processing, Actionway may process Personal Data based on:

Performance of a Contract

Where processing is necessary to provide Actionway or execute Tool Calls requested by you.

Legitimate Interests

Where processing is reasonably necessary to:

• operate the Service;
• secure the Service;
• prevent fraud;
• detect abnormal usage;
• troubleshoot;
• improve reliability;
• enforce our agreements; or
• protect our users and business,

and those interests are not overridden by applicable rights and interests.

Legal Obligations

Where processing is necessary to comply with applicable law.

Consent

Where we specifically request and receive consent.

Where Actionway processes Personal Data solely on behalf of an enterprise customer, that customer may be responsible for identifying the relevant lawful basis.

Depending on applicable law, you may also have the right to lodge a complaint with a competent data protection authority.

Security

Actionway maintains administrative, technical, and organizational safeguards designed to protect Personal Data against unauthorized access, loss, alteration, destruction, or disclosure.

However, no internet transmission, software system, network, or storage mechanism can be guaranteed to be completely secure.

You are responsible for maintaining appropriate security for:

• your Actionway account;
• API keys;
• Agents;
• applications;
• databases;
• devices;
• credentials; and
• systems connected to Actionway.

You should limit access to API keys and credentials to persons and systems that reasonably require that access.

Children

Actionway is intended for users aged 18 or older.

We do not knowingly permit individuals under 18 to create individual paid Actionway accounts.

If you believe that a minor has provided Personal Data to us contrary to this Privacy Policy, contact:

**assist@actionway.ai**

Do Not Track and Privacy Signals

Browser and device privacy signals may operate differently depending on the technology involved.

Where applicable law requires Actionway to recognize a legally valid privacy preference signal, we will process such signals as required by applicable law.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect:

• changes to the Service;
• changes to our data practices;
• changes in Tool infrastructure;
• changes in Tool Providers;
• legal requirements; or
• operational developments.

When we update this Privacy Policy, we will revise the “Last Updated” date.

Where required by applicable law, we will provide additional notice regarding material changes.

If a material change requires affirmative consent under applicable law, we will obtain such consent before applying that change where required.

Contact Us

For questions, privacy requests, or concerns regarding this Privacy Policy, contact:

PawLogic Inc. 1200 Brickell Avenue, Suite 510 Miami, FL 33131 United States

Email: assist@actionway.ai