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.
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:
a. When you fill out forms or fields through our Services, including a request for more information on our Website;
b. When you order products or services from, or through our Service;
c. When you register for an account with our Service;
d. When transmit any spoken words, phases, audio, messages or other verbal content during the use of our translation applications including, without limitation the Pilot Speech Translator and the Ambassador Interpreter;
e. When you provide responses to a survey or questionnaire;
f. When you join or enroll in an event through our Services;
g. When you sign up for any newsletters or other materials through our Services;
h. When you provide information to us through a third-party application, service or website;
i. When you communicate with us or request information about us, or our products or Services, whether via email or other means;
j. When you participate in any of our marketing initiatives, including, contests, events, or promotions; and
k. When you participate in forums, reviews or transmit, provide or post user generated content or other submissions.
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.
a. When you visit our Services, we may send one or more Cookies – small data files – to your computer to uniquely identify your browser and let us help you log in faster and enhance your navigation through the Sites. “Cookies” are text-only pieces of information that a website transfers to an individual’s hard drive or other website browsing equipment for record keeping purposes. A Cookie may convey anonymous information about how you browse the Services to us so we can provide you with a more personalized experience, but does not collect Personal Data about you. Cookies allow the Sites to remember important information that will make your use of the site more convenient. A Cookie will typically contain the name of the domain from which the Cookie has come, the “lifetime” of the Cookie, and a randomly generated unique number or other value. Certain Cookies may be used on the Sites regardless of whether you are logged in to your account or not.
b. Session Cookies are temporary Cookies that remain in the Cookie file of your browser until you leave the Site or App.
c. Persistent Cookies remain in the Cookie file of your browser for much longer (though how long will depend on the lifetime of the specific Cookie).
d. When we use session Cookies to track the total number of visitors to our Website or App, this is done on an anonymous aggregate basis (as Cookies do not in themselves carry any personal data).
e. We may also employ Cookies so that we remember your computer or device when it is used to return to the Site or App to help customize your Waverly Labs experience. We may associate Personal Data with a Cookie file in those instances.
i. Waverly Labs may use third-party services such as Google Analytics to help understand use of the Services. These services typically collect the information sent by your browser as part of a web page request, including Cookies and your IP address. They receive this information and their use of it is governed by their respective privacy policies. You may opt-out of Google Analytics for Display Advertisers including AdWords and opt-out of customized Google Display Network ads by visiting the Google Ads Preferences Manager here https://adssettings.google.com/authenticated?hl=en. To provide website visitors more choice on how their data is collected by Google Analytics, Google has developed an Opt-out Browser add-on, which is available by visiting Google Analytics Opt-out Browser Add-on here https://tools.google.com/dlpage/gaoptout. For additional information on how Google uses data when you use Google partners’ sites or apps, go here: https://policies.google.com/technologies/partner-sites.
m. When you use our Services, we may employ Web Beacons (also known as clear GIFs or tracking pixels) to anonymously track online usage patterns. No Personally Identifiable Information from your account is collected using these Web Beacons.
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.
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:
b. It is necessary for entering into, or performing, the obligations of a contract between you and Waverly Labs, including, without limitation, our Terms of Service agreement which may be accessed by you here https://www.waverlylabs.com/terms-service;
c. It is necessary registering you as a user, managing your account and profile, and authenticating you when you log in;
d. It is necessary for our legitimate interests in the proper administration of our Website and business; analyzing the use of the Website and our Services; assuring the security of our Website and Services; maintaining back-ups of our databases; and communicating with you;
e. To resolve technical issues you encounter, to respond to your requests for assistance, comments and questions, to analyze crash information, to repair and improve the Services and provide other customer support;
f. To send communications via email and within the Services, including, for example, responding to your comments, questions and requests, providing customer support, and sending you technical notices, product updates, security alerts, and account management related messages;
g. To send promotional communications that you have consented to receive or have expressed a legitimate interest in receiving;
h. It is necessary for our legitimate interests in the protection and assertion of our legal rights, and the legal rights of others, including you; and
i. It is necessary for our compliance with certain legal provisions which may require us to process your personal data. By way of example, and without limitation, we may be required by law to disclose your personal data to law enforcement or a regulatory agency.
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. Operate and provide our Services;
b. Improve our technology, voice recognition software, internal operations, systems, products, and Services;
c. Create and develop new Services and add customized features to existing Services;
d. Provide users with customer support including, sending you application updates, related support information, confirmations, technical notices, security alerts, and administrative messages;
e. Understand you and your preferences to enhance your experience and enjoyment using our Services;
f. Resolve problems and disputes, and engage in other legal and security matters;
g. Protect, investigate, and deter against fraudulent, unauthorized use or illegal activity;
h. Enforce our Terms of Service and any terms and conditions of any agreements for our Services;
i. Send you communications we think will be of interest to you, including information about our products, services, promotions, news, and events of Waverly Labs; and
j. Verify your identity and prevent impersonation, spam or other unauthorized or illegal activity including, without limitation, infringement of intellectual property rights of third parties.
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;
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 email@example.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.
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.
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: firstname.lastname@example.org
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 email@example.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.
Last updated: June 22, 2020