Waverly Labs Inc., the owner and operator of waverlylabs.com (the "Website" or "Site), and our mobile applications the Pilot™ Speech Translator and the Ambassador™ Interpreter (the "App" or "Apps"), hereafter collectively referred to in this Privacy Policy as "Waverly Labs", "us", "our" or "we", respects the privacy of your personal information and, as such, we make every effort to ensure your personal information is protected and remains private.
For purposes of this Privacy Policy, personal information ("Your Information" or "Personal Data") means information about you, which may be of a confidential or sensitive nature and may include personally identifiable information ("PII") and/or financial information. PII means individually identifiable information that would allow us to determine the actual identity of a specific living person, while sensitive data may include other information, comments, content and other information that you voluntarily provide.
We have provided this Privacy Policy to explain how we collect, use, share and protect information about the purchaser of our Products and the users of our Website, App and Services (hereafter referred to as “user”, “you” or "your"). We will not use or share your Personal Data with anyone except as described in this Privacy Policy. This Privacy Policy will inform you about the types of personal data we collect, the purposes for which we use the data, the ways in which the data is handled and your rights with regard to your personal data. Furthermore, this Privacy Policy is intended to satisfy the obligation of transparency under the European Union ("EU") General Data Protection Regulation ("GDPR") and the laws implementing the GDPR.
Waverly Labs collects Personal Data about you when you purchase our products, use our Website or App to access our services, and other online products and services (collectively, the “Services”), and through other interactions and communications you have with us. The term Services includes the content, services, technology, software and Products available through the Waverly Labs Website or App.
A "Data Controller" is the natural or legal person who (either alone or jointly with other persons) determines the purposes for which and the manner in which any Personal Data is, or will be, processed. The Data Controller for Waverly Labs is Waverly Labs Inc. and our contact details are set out in the Contact section at the end of this Privacy Policy.
We may change this Privacy Policy from time to time. If we decide to change this Privacy Policy, we will inform you by posting the revised Privacy Policy on the Website and in our App. If the changes to the Privacy Policy are significant, we will send an email notice to you, and may request that you accept the revised Privacy Policy terms. Changes will go into effect on the "Last updated" date shown at the end of this Privacy Policy. By continuing to use the Website, App or our Services, you consent to the revised Privacy Policy. We encourage you to periodically review the Privacy Policy for the latest information on our privacy practices.
By accessing or using our services, you consent to the collection, transfer, manipulation, storage, disclosure and other uses of your information (collectively, "use of your information") as described in this privacy policy and our Terms of Service which may be accessed here https://www.waverlylabs.com/terms-service. If you do not, or no longer, agree with or consent to this privacy policy and our terms of service you may not access or use our services. Furthermore, for users of our services, we rely upon the legal grounds found in the section entitled "the legal basis and reasons for collection and processing your Personal Data" found hereinafter in this privacy policy.
We collect information you provide directly to us, such as when you request information, make a purchase, create or modify a personal account, request Services, complete a Waverly Labs form, survey, questionnaire or application, contact customer support, join or enroll for an event or otherwise communicate with us in any manner. This information may include, without limitation: your name, date of birth, e-mail address, physical address, business address, phone number or any other personal information you choose to provide.
We collect information about your activity on our services, for instance how you use them (e.g., features you’ve been using, searches, clicks and pages that have been shown to you, referring webpage address, advertising that you click on) and how you interact with other users and us. The following are situations in which you may provide Your Information to us:
We may automatically collect information via the Website or our App through the use of various technologies, including, but not limited to Cookies, Pixel Tags and Web Beacons (explained below). We may collect your IP address, browsing behavior and device IDs. This information is used by us in order to enable us to better understand how our Services are being used by visitors and allows us to administer and customize the Services to improve your overall experience.
We may also receive information from other sources and combine that with information we collect through our Services. For example if you choose to link, create, or log in to your Waverly Labs account with a social media service, e.g. LinkedIn, Facebook or Twitter, or if you engage with a separate application or website that uses our API, or whose API we use, we may receive information about you or your connections from that website or application. This includes, without limitation, profile information, profile picture, gender, user name, user ID associated with your social media account, age range, language, country, friends list, your contact names, e-mail addresses, phone numbers, and other identifiers and any other information you permit the social network to share with third parties. The data we receive is solely dependent upon your privacy settings with the social network.
The following is a list of the possible Cookies we may use in our Services. Please note that the names of Cookies and other technologies may change over time.
We may collect information about you from sources other than you, such as from social media websites (i.e., Facebook, LinkedIn, Twitter or others), blogs, analytics providers, business affiliates and partners and other users. This includes, without limitation, identity data, contact data, marketing and communications data, behavioral data, technical data and content data.
When you use our Services through your computer, mobile phone or other device, we may collect information regarding and related to your device, such as hardware models and IDs, device type, operating system version, the request type, the content of your request and basic usage information about your use of our Services, such as date and time. In addition, we may collect information regarding application-level events and associate that with your account to provide customer service. We may also collect and store information locally on your device using mechanisms such as browser web storage and application data caches.
When you use the Services we may collect your precise location data. We may also derive your approximate location from your IP address.
In connection with providing some Service, we may receive call data, including the date and time of the call or SMS message, the parties phone numbers, and the content of the SMS message. You consent to the receipt, collection and storage of this information.
We may collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data is de-identified or anonymized and does not constitute Personal Data as this data does not directly or indirectly reveal your identity. If we ever combine Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as PII which will only be used in accordance with this Privacy Policy.
The Children's Online Privacy Protection Rule ("COPPA") and the rules promulgated by the GDPR impose certain requirements on operators of online services directed to children under 13 years of age or 16 years of age respectively. Our Services are intended for users who have attained the age of majority where they reside (18 years of age or older in most jurisdictions) unless they have received parental or legal guardian consent to use our Services. Furthermore, we do not knowingly collect personally identifiable information (PII) from persons under the age of 13 in the United States, or under the age of 16 in the European Union, the "Protected Age". If you are under the Protected Age, please do not provide us with information of any kind whatsoever. If you have reason to believe that we may have accidentally received information from a child under the Protected Age, please contact us immediately. If we become aware that we have inadvertently received Personal Information from a person under the Protected Age, we will delete such information from our records.
The legal basis upon which we rely for the collection and processing of your Personal Information under the GDPR are the following:
We protect your information using commercially reasonable technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. Although we take measures to secure your information, we do not promise, and you should not expect, that your Personal Data, or searches, or other information will always remain secure. We cannot guarantee the security of our information storage, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet including, without limitation, email and text transmissions. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
Our primary purpose in collecting, holding, using and disclosing your Information is for our legitimate business purposes and to provide you with a safe, smooth, efficient, and customized experience. We will not rent, sell, lease or barter your information to anyone unless you grant us explicit permission for this information to be shared in that manner. We will use this information in order to:
a. We share the information we collect about you as described in this Privacy Policy, or as described at the time of collection or sharing, as follows:
With third party Service Providers to enable them to provide the Services you request;
With third parties with whom you choose to let us share information, for example other websites or apps that integrate with our API or Services, or those with an API or Service with which we integrate;
With Waverly Labs subsidiaries and affiliated entities that provide services or conduct data processing on our behalf, or for data verification, data centralization and/or logistics purposes;
With vendors, consultants, marketing partners, and other service providers who need access to such information to carry out work on our behalf;
In response to a request for information by a competent authority if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, court or legal process;
With law enforcement officials, government authorities, or other third parties if we believe your actions are inconsistent with our user agreements, Terms of Service, or policies, or to protect the rights, property, or safety of Waverly Labs, our users or others;
In connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company;
If we otherwise notify you and you consent to the sharing; and
In an aggregated and/or de-identified form which cannot reasonably be used to identify you. We only use such data in the aggregate form and our analytical services do not record any Personal Data.
b. We may disclose Your Information as follows:
To any person who, in our reasonable judgment, is authorized to receive Your Information as your agent, including as a result of your business dealings with that person (for example, your attorney);
As required by law or ordered by a court, regulatory, or administrative agency;
As we deem necessary, in our sole discretion, if we believe that you are violating any applicable law, rule or regulation, or are otherwise interfering with another's rights or property, including, without limitation, our rights or property;
To enforce our Terms of Service, this Privacy Policy, and any other applicable agreements and policies.
a. If you share User Content, as defined in our Terms of Service Agreement, or post a comment or message that contains personally identifiable information to a page on our Services that is accessible to the public, third parties may use that information, or share it with other parties. As a result, you may receive unsolicited messages from other parties. Such User Content, comments or messages is not subject to this Privacy Policy and you share this information at your own risk.
b. You will need to contact Waverly Labs in the event that you wish to have this personally identifiable information removed from our Service. Please note that responding to your request may not ensure complete or comprehensive removal from the internet if the content or information has been reposted by another party. To request removal of content or information from our Services, please contact us at support@waverlylabs.com.
a. Our Services may now or in the future integrate with social sharing features and other related tools which let you share actions you take on our Services with other apps, sites, or media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the social sharing service. Please refer to the privacy policies of those social sharing services for more information about how they handle the data you provide to or share through them.
b. Any information or content that you voluntarily disclose for posting publicly to a social sharing service becomes available to the public, as controlled by any applicable privacy settings that you set with the social sharing service. Once you have shared User Content or made it public, that User Content may be re-shared by others. If you remove information that you posted to the social sharing service, copies may still remain viewable in cached and archived pages, or if other users or third parties, using the social sharing service, have re-shared, copied or saved that User Content.
We may allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use Cookies, Web Beacons, software development kits (SDKs), and other technologies to identify your device when you visit our Site and use our Services, as well as when you visit other online sites and services.
a. Our Services, as well as the email messages sent with respect to our Services, may contain links or access to websites operated by third parties, including advertisers, that are beyond our control. Links or access to third parties from our Services are not an endorsement by us of such third parties, or their websites, applications, products, services, or practices. We are not responsible for the privacy policy, terms and conditions, practices or the content of such third parties. These third-parties may send their own Cookies to you and independently collect data.
b. If you visit or access a third-party website, application or other property that is linked or accessed from our Services, we encourage you to read any privacy policies and terms and conditions of that third party before providing any personally identifiable information. If you have a question about the terms and conditions, privacy policy, practices or contents of a third party, please contact the third party directly.
You may opt out of receiving promotional messages from us at any time by following the instructions in those messages sent to you including emails, or by contacting us at any time using the Contact Us information at the end of this Privacy Policy. In doing so, you elect not to receive correspondence from us or have Your Information shared with other entities for their marketing purposes. If you opt out, we may still send you non-promotional communications, such as those about your account, about Services you have requested, or our ongoing business relations.
In order to provide our products and services to you, we may send and store your Personal Data outside of the country where you reside or are located, including to the United States. Accordingly, if you reside or are located outside of the United States, your Personal Data may be transferred outside of the country where you reside or are located, including countries that may not, or do not, provide the same level of protection for your Personal Data. We are committed to protecting the privacy and confidentiality of Personal Data when it is transferred. If you reside or are located within the European Union ("EU") or European Economic Area ("EEA") and such transfers occur, we take appropriate steps to provide the same level of protection for the processing carried out in any such countries as you would have within the EU and EEA to the extent feasible under applicable law. By accessing and using the Waverly Labs Website, our Apps or our Services, users who reside, or are located, in countries outside of the United States, agree and consent to the transfer to, and processing of, Personal Data on servers located outside of the country where they reside, and assume the risk that the protection of such information may be different, and may be less protective, than those required under the laws of their residence or location.
Some web browsers may give you the ability to enable a "do not track" feature that sends signals to the websites you visit, indicating that you do not want your online activities tracked. This is different than blocking or deleting Cookies, as browsers with a "do not track" feature enabled may still accept Cookies. There currently is no accepted standard for how to respond to this signal, and we do not take any action in response to this signal.
Under the GDPR, you have certain rights in relation to Personal Information we hold about you. You can exercise any of the following rights by contacting us using any of the methods in the Contact section below. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
a. Right to Access Your Personal Data. You have the right to access information held about you for the purpose of viewing and in certain cases updating or deleting such information. Furthermore, if you prefer that Waverly Labs does not share certain information as described in this Privacy Policy, you can direct Waverly Labs not to share that information. We will comply with an individual’s requests regarding access, correction, sharing and/or deletion of the personal data we store in accordance with applicable law. To make changes to your account affecting your Personal Data contact us at the email address in our Contact section below. For any deletion, non-sharing or update request, we will make the changes as soon as practicable, however this information may stay in our backup files. If we cannot make the changes you want, we will let you know and explain why.
b. Right of Correction or Completion of Your Personal Data. If Personal Data we hold about you is not accurate, out of date or incomplete, you have a right to have the data corrected or completed. To make corrections to your account please contact us at the email address in our Contact section below.
c. Right of Erasure or Deletion of Your Personal Data. In certain circumstances, you have the right to request that Personal Data we hold about you is deleted. If we cannot delete the information you want, we will let you know and explain why. To request information deletion please contact us at the email address in our Contact section below.
d. Right to Object to or Restrict Processing of Your Personal Data. In certain circumstances, you have the right to object to our processing of your Personal Data. For example, you have the right to object to use of your Personal Data for direct marketing purposes. Similarly, you have the right to object to use of your Personal Data if we are processing your information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which supersede your rights and interests. You may also have the right to restrict our use of your Personal Data, such as in circumstances where you have challenged the accuracy of the information and during the period where we are verifying its accuracy. To object to or restrict processing please contact us at the email address in our Contact section below.
e. Right to Data Portability or Transfer of Your Personal Data. You have the right to be provided with a copy of the information we maintain about you in a structured, machine-readable and commonly used format. To receive a copy of the information we maintain about you please contact us at the email address in our Contact section below.
f. Right to Withdrawal of Consent. If you have given your consent to us to process and share your Personal Information after we have requested it, you have the right to withdraw your consent at any time. To withdraw your consent please contact us at the email address in our Contact section below.
g. Right to Complain. You have the right to file a complaint regarding our data protection practices with a supervisory authority in your country. Please see this directory for contact details: https://edpb.europa.eu/about-edpb/board/members_en.
a. California Civil Code Section 1798.83 entitles California residents to request information concerning whether a business has disclosed Personal Information to any third parties for their direct marketing purposes. California residents may request and obtain from us once a year, free of charge, information about the Personal Data, if any, we disclosed to third parties for direct marketing purposes within the immediately preceding calendar year. If applicable, this information would include a list of the categories of Personal Data that was shared and the names and addresses of all third parties with which we shared information within the immediately preceding calendar year.
b. If you are a California resident and would like to make such a request, please submit your request in writing to: support@waverlylabs.com
a. Waverly Labs is committed to cooperating with law enforcement while respecting each individual’s right to privacy. If Waverly Labs receives a request for user account information from a government agency investigating criminal activity, we will review the request to be certain that it satisfies all legal requirements before releasing information to the requesting agency.
b. Furthermore, under 18 U.S.C. §§ 2702(b)(8) and 2702(c)(4) (Voluntary Disclosure Of Customer Communications or Records), Waverly Labs may disclose user account information to law enforcement, without a subpoena, court order, or search warrant, in response to a valid emergency when we believe that doing so is necessary to prevent death or serious physical harm to someone. Waverly Labs will not release more information than it prudently believes is necessary to prevent harm in an emergency situation.
You may correct your account information at any time by logging into your online account. If you wish to cancel your account, please email us at support@waverlylabs.com Please note that in some cases we may retain certain information about you as required by law, or for legitimate business purposes to the extent permitted by law.
Unless you request that we delete certain information, we retain the information we collect for as long as your account is active or as needed to provide you services. Following termination or deactivation of your account, we will retain information for at least 1 year and may retain the information for as long as needed for our business and legal purposes. We will only retain your Personal Data for so long as we reasonably need to unless a longer retention period is required by law (for example for regulatory purposes).
If you have any questions or if you would like to contact us about our processing of your Personal Data, including exercising your rights as outlined above, please contact us by any of the methods below. When you contact us, we will ask you to verify your identity.
Waverly Labs Inc.
Contact name: Data Protection Officer
Email: support@waverlylabs.com
Our office address:
19 Morris Avenue
Brooklyn, NY 11205
Last updated: June 22, 2020
