Privacy Policy

Latest Update: November, 2023


Welcome to Waverly

We’re happy to meet you!

At Waverly AI inc. (referred to as “Waverly”, “Waverly AI”, “we”, or “us”), we understand that you want transparency about how we process your personal data. This Privacy Policy contains information about your privacy and your rights.

This Privacy Policy applies to your use of the Waverly application (“App”), the Waverly AI website at https://waverly.social/ (“Website”), our use of social media, and the communications you may have with us from time to time (together, the “Services”).

Waverly AI’s App is a cross between a personal journal and a search engine which is powered by artificial intelligence. The App collects information which you provide in order to come up with recommendations that align with your values. In order to be able to offer you this service, we collect personal information about you, so that we may provide you with personalized recommendations.

If you have any concerns or inquiries regarding the processing of your personal data, do not hesitate to reach out to us! You can e-mail us at support@mywaverly.com.

1. What do we mean by personal data?

This Privacy Policy applies to personal data. We consider that “personal data” means any information which allows us to identify you directly or indirectly, including “cookies” and other electronic data. Some information may not be personal on its own, but may become personal data if associated with or if the sum of the information allows us to identify you.

A “cookie” is information that a website puts on your computer’s hard drive so that the website can remember something about you at a later time. In this Privacy Policy, when we refer to “cookies” we include other technologies with similar purposes, such as pixels, tags and beacons. If you are looking for more information on cookies, you can refer to websites such as http://www.cookiecentral.com/ and https://www.allaboutcookies.org/.

This Privacy Policy is for transparency purposes and some of the data that we identify in this Privacy Policy as personal data may not be protected as personal data under applicable laws.

2. When does this Privacy Policy not apply?

If you click through to links to third parties’ websites, applications, or services from our Services, this Privacy Policy does not apply to the processing of personal data by such external services. It is always a good idea to read their privacy policies to understand what they do with your personal data!

For example, if you see content on Waverly which links to an external website and if you click through, that website may also collect personal data about you. We do not control the data collection of these third parties, and if you have any questions about how they process your personal data, you should contact them directly.

3. What type of personal data do we collect and why?

We collect personal data to offer our Services, and to perform analytics. Below is a table containing the categories of personal data that we collect, along with the purpose for such collection.

Category
Description
Purpose and Use
Electronic Data
When you use our Services, we may collect electronic data:
  • IP address
  • device type
  • Location/Time zone information
  • Geolocation
This information is collected automatically through cookies on our Services to function effectively, to fix bugs, or ensure the security of our Services. For instance, we may collect data in order to distinguish between humans and bots.
Usage and Performance Data
We collect:
  • Time spent on the Services
  • Pages visited
  • Links clicked
  • Language preferences
  • Pages that led or referred you to the Services
  • Device model
  • Operating system

We collect this information to understand the usage of our Services, whether there are bugs, and generally, to improve our Services.

Usage data does not allow us to determine your identity, and is generally provided as aggregated data or by reference to an anonymous identifier.

Account Data
When you open an account with us, we may collect:
  • Name
  • Email address
  • Password
We collect your email address to allow you to send yourself or someone else the offer, but we do not use this information for other purposes.
Queries and Search Terms

When you use Waverly, you are encouraged to share your ideas and thoughts. We use this information to scan the internet and provide you with recommendations.

The type of personal data that we collect depends on what you search for on the App.

We only collect the information that you provide us with in order to give you recommendations, and we do not use other data signals.

In order to present you with appropriate content, we collect information about the queries and search terms that you insert into Waverly.

Our algorithms learn from the information that you provide to give you personalised recommendations. The more you interact with the App, the better our algorithms become at providing you with the right content.

You can delete your content on the App at any time.

Communication Data
We collect:
  • Email address
  • Content of your message
If you communicate with us by email, on social media, by using the form on our Website, or by any other means, we collect the personal data that you share with us, such as your email address and the content of your communication. If you communicate with us using social media, we will have access to your publicly available information.
Marketing Data
We collect:
  • Email address
  • Consent to receive emails

We collect your email address in order to we can send you communications about Waverly.

You can unsubscribe at any time directly in the emails or by contacting us.

Social Media Data
Publicly available information
If you follow us or interact with us on social media, we may process your personal data for marketing or advertising purposes, subject to applicable laws, including those on consent.

4. Do you use tracking technologies and why?

We do not use cookies or other data tracking technologies on our Website. We use tracking technologies such as pixels and cookies to collect statistics on the use of the App. We use Mixpanel to collect analytics data based on usage of the App.

5. Who do you share my personal data with?

Yes, we do share your personal data with third parties for a number of reasons including providing you with the Services and as required by the law. We may also share your personal data in the context of a merger and acquisition, as part of bankruptcy procedures or for other corporate requirements.

Just to be clear, we are not data brokers, and we do not sell your personal data to third parties.

In the table below, we provide more information on the third parties we share your personal data with, and provide hyperlinks to their privacy policies.

Category
Explanation
IT Service Providers
We use IT service providers to offer you the Services. For example, we use:
  • AWS to host the Services. You can find their privacy policy here.
  • We use textrazor.com for natural language analysis to improve our services. You can consult their privacy policy here.
  • We use Mixpanel for analytics purposes. You can find their privacy policy here.
  • We use MailerLite for email marketing purposes. You can find their privacy policy here.
Others App users
You may choose to make your content available to other App users, in which case, the selected content can be viewed by fellow App users of your choice.
Law Enforcement and other authorities
We may receive requests by authorities to access your personal data. We will validate that the request is licit before responding. When possible, we will advise you. We will only share what is strictly required.
Business Partners
We may disclose your personal information in connection with, or during negotiations of, any merger, sale of assets, financing, or acquisition of all or a portion of our business by another entity or investors. We will only share what we are required to share for these specific purposes.

6. Where do you store my personal data ?

We use AWS to store your personal data. Our service providers may process your personal data internationally, including in the United States, depending on where they are located.

7. How long do you retain my personal data ?

We retain personal data for as long as necessary to provide you with the Services, to perform our marketing campaigns effectively or as required by applicable laws, whichever is longer.

8. How do you keep my personal data secure ?

We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Our hosting provider AWS is certified ISO/IEC 27001:2013 and ISO 27701. We use identity and access management to limit access to your personal data to the developers who need to access it.

9. What are my rights regarding my personal data ?

The law provides you with rights over your personal data. Your rights vary depending on the laws that apply to your situation, and the specific circumstances of the request. Waverly acknowledges the right of individuals to access their personal data. Upon request to support@mywaverly.com, we will provide you with confirmation as to whether we are processing your personal data, and have the data communicated to you within a reasonable time. Your rights differ depending on where you are located in the world.

In most locations, you have the right to correct, amend or delete your personal data where it is inaccurate or has been processed in violation of this Privacy Policy.

If you want to exercise one of these rights and the situation allows for such exercise, you can contact us at support@mywaverly.com. We will try to help you with your request free of charge. However, we may request that you pay a reasonable fee if you request a transcript, or a reproduction or for us to send a copy of your personal data, if the law allows us to do so. If we need to charge a fee to process your application, we will contact you before addressing your request.

For security reasons and to avoid fraudulent requests, we may be required to ask that you provide proof of identity with your request. We will not use such personal data for any other purposes.

We will respond to your request within thirty (30) days, unless agreed otherwise. If your request is denied, we will notify you in writing, and provide you with detailed motives and information on how to contest our decision.

You can also contact the Office of the Privacy Commissioner of Canada’s Information Center:

Telephone
9:00 am to 4:00 pm EST
Toll-free: 1-800-282-1376

Mailing address
Office of the Privacy Commissioner
30 Victoria Street
Gatineau, Québec
K1A 1H3

If you have any issue with how we process your personal data, or how we responded to your request, please let us know. We will do our best to improve our processes to make certain that it does not happen again. We will also provide you with additional information about our practices if you would like us to do so.

If you are still not satisfied, you can lodge a complaint to the Office of the Privacy Commissioner of Canada using this online form, or to your local privacy regulators, or if you are in Quebec, you can lodge a complaint with the Commission d’accès à l’information.

10. Children’s privacy

We restrict the use of our Services to individuals age 16 and above. We do not knowingly collect or retain Information from our Services from children under the age of 16. If we learn that we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at support@mywaverly.com.

11. Changes to this Privacy Policy

We may change this Privacy Policy from time to time. When material changes are made to this Privacy Policy, you will be notified through the contact email given to us at least two weeks prior to such modification taking effect. Questions about the new Privacy Policy should be addressed to support@mywaverly.com.