WAVYN - PRIVACY POLICY

Wavyn LLC respects your privacy. Wavyn LLC and its affiliates (“Wavyn” or the “Company”) offer safety driving alert services to users of www.Wavyn.com (the “Website”) and/or users of Wavyn’s mobile applications (the “Application”) (collectively referred to as the “Services”). When you use our services, you’re trusting us with your information. We understand this is a big responsibility and work hard to protect your information and put you in control.

This Privacy Policy is meant to help you understand what information we collect, why we collect it, and how you can update, manage, and delete your information.

This Privacy Policy is incorporated as part of the Wavyn Terms of Use (the “Terms of Use” or the “Terms”). Your use of the Services is subject to the Terms of Use, Copyright Policy and this Privacy Policy and indicates your consent to them.

To use our Services you must be 16 years of age or older. If you are under 16, you may not download or use the Services.

In this Privacy Policy, the term “personal information” means information which you provide to us which personally identifies you, such as your name, email address or billing information, and, in certain circumstances, your location and route information or other data which can be reasonably linked to such information by Wavyn.

Contact Wavyn - Privacy concerns reports

If you have any questions about this Privacy Policy, or if you believe that your privacy has been compromised in the course of using the Services, please contact Wavyn at: privacy@Wavyn.com. You may send Wavyn other requests, responses, questions and complaints by email at: support@Wavyn.com.

User Accounts & Accessing the Services

Please note that when you install the Application on your mobile device, Wavyn will set up an account associated with that mobile device (the “Account” or “Wavyn Account”). After installation, Wavyn will collect and use your information, including meta-data (as described below), in accordance with this Privacy Policy. This use may include linking your information with your Account. This is the case irrespective of whether or not you choose to create a Wavyn username and password in the Wavyn Application (as explained below).

Wavyn may allow you to use the Wavyn Application whether or not you choose to set up a username for yourself. If you choose to use the Wavyn Services without setting up a username you may do so by skipping the username setup stage of the application installation process. If you do so:

If you do set up a Wavyn username and password in the Application:

Information that is being collected

We want you to understand the types of information we collect as you use our services

Wavyn collects information to provide better services to all its users - from figuring out stuff like what’s the best route, to more complex things like monitoring traffic so you know when to leave, and showing you relevant ads while using Wavyn. The information Wavyn collects, and how that information is used, depends on how you choose to use our services and how you manage your privacy controls.

Information you create or provide to us:

You may also provide additional information that will be used to personalize the Services and enhance your experience with the Services. For example, if you provide us with your “home” and “work” information, we may provide you with what we think is the preferred route between those locations.

Information we collect as you use our services

We collect information about your activity in the Services, which we use to provide you with the Services of Wavyn, including features which are meant to personalize your experience. This includes things like finding you the preferred route and propose favorites or destinations commonly traveled by you to streamline your search and travel. The activity information we collect may include:

Meta-data (information about your device, browser and app use):

Once you install the Application, Wavyn collects information about the use of the Services and information from the device you have Wavyn installed on. For example:

Information we collect about you from our partners

We work with ad partners, including entities that belong to the Google group of companies, in order to show you more relevant and useful ads based on your Wavyn activity and information associated with your device’s identifier (i.e, Advertising identifiers or similar technologies) shared with us by our ad partners. Your device’s identifier can be managed in your device’s settings (for more information: see here and here).

You can decide whether we’ll show you personalized ads or not through your in-app Privacy Settings–>Ads personalization. Note: turning Ads personalization off does not turn off ads - only their personalization. For more information see section titled ‘Advertising campaigns’ under this Privacy Policy.

We may also receive aggregated, non-personally identifiable information and analysis from third parties measurement services which help us understand how our users interact with our ads. We may also receive information from third party services about how Wavyn’s own marketing efforts performed on third party sites or platforms.

We use various technologies to collect and store information, including, cookies, Advertising ID available on Android mobile devices or similar technologies, local storage, browser web storage, application data caches, databases, and server logs.

Why Wavyn collects data

Wavyn may use information collected from or provided by you for the following purposes:

Provide our services

We use your information to deliver our services. For example:

Maintain & improve our services

Provide personalized services, including content and ads

Measure performance

Communicate with you

To protect Wavyn, our users, the public and for Legal reasons

We may also use and process your information and content, using different technologies to the following purposes:

We’ll ask for your consent before using your information for a purpose that isn’t covered in this Privacy Policy.

Sharing your information

Personal information that you share

The Services are based on a community of users publicly sharing information with Wavyn and with other members of that community.

In particular, users may choose to share personal information such as name, age, gender, picture, their location information, reports and other files. This information may be shared either directly to the Services and to all users, such as in the case of traffic reports or just to your friends on Wavyn. This information may also be shared via third party services (such as social networks) which interact with the Services upon such users’ choice.

You can decide whether or not to upload content to the Services. However any content that you choose to share and submit for posting is neither private nor confidential and you should expect that it may be made public and known to others. Information you choose to upload will be posted along with your user name and other information including personal information you attached to your publicly available user profile . You should note that certain road incidents you report may include your driving path within the vicinity of those incidents. Therefore, you must exercise caution and common sense when submitting information. At the very least you should demonstrate the same degree of caution as when publishing personal information by means other than the Internet and cellular services.

In any event (but except as detailed below with respect to information shared from your social network accounts according to your privacy settings for such social network accounts), your email address will not be visible to others through any reports or user posts that you share or upload.

if you choose to either record your own voice onto the Service, or to use the voice command features, Wavyn will collect the voice information related to such use, including voice files. If, after recording your own voice, you chose to share your voice recordings, other Wavyn users and other people will be able to download and use your voice recordings. Once downloaded, Wavyn may not have any control over the voice files, so you should only share content that you are comfortable being made public.

We, at Wavyn, take great measures to provide you with the best experience you can have while using the Services. However, Wavyn has no control over the conduct of any user and disclaims all liability in this regard. Users are advised to carefully and thoroughly consider whether or not to make public or available any information and carefully examine all necessary details related to any communication with other users prior to any engagement or communication being made.

Participating in any user’s activities as a result, directly or indirectly, from using Wavyn, is entirely at your own risk. Wavyn is not a party to any agreement entered into between the users in any circumstances. The user has the sole and ultimate responsibility regarding compliance with all laws, regulations or any other duty. We do not accept any liability for any loss, damage, cost or expense that you may suffer or incur as a result of or in connection with your participation in any activity or event initiated, held or conducted by a user or a third party nor in connection to any agreement between the users or third parties, including any activity or event related in any way, directly or indirectly, the Services or the use thereof.

When Wavyn shares your information

Wavyn does not sell, rent or lease your personal information to third parties.

Wavyn will not share your personal information with others, without your permission, except for the following purposes and to the extent necessary in Wavyn’s good-faith discretion:

Visibility

Please note that your username and some other information will be visible to others. Note that your username will be included along with any information you submit for posting (such as traffic reports or chat messages). It will therefore be visible to others. Also - your friends on Wavyn will see your name & profile photo and any other information you chose to share with them.

If you prefer to remain invisible on the Wavyn map, you can set the Wavyn Application not to show your location on the map. To do so you should go to the Privacy Settings and adjust accordingly by switching on to Invisible Mode. If on, some features may not be available. If you make this choice, while you will be ‘invisible’ on the map to other users, your location and route information will continue to be collected by Wavyn for the purposes listed in this Privacy Policy and your Carpool profile (if you choose to set one) may be visible to other Wavyn’s users.

Integration with social networks

You may choose to share information between your Wavyn account and your social network account (such as Facebook). Through this option, you may choose to have personal information and other content about you available from social networks, transmitted and shared through the Services. Similarly, you may choose to have personal information and other content about you available from Wavyn, including your location and route information, transmitted to and shared through your social network account.

By setting your Wavyn Account to integrate with social networks, including by signing onto Wavyn by using your social network account (such as your Facebook account and your Google account), you agree to share information (including personal information) between Wavyn and such social networks, for the purposes provided under this Privacy Policy.

The social network’s use of information made available by Wavyn is governed by that social network’s privacy policy and controlled by the social network, not by this Privacy Policy or Wavyn.

When you connect to the social network account through the Services for the first time or otherwise make the Services interact with your social network account, you will be asked by the social network to permit the social network to share your personal information stored on such social network with Wavyn. We collect your information from your social network account only in accordance with the permissions granted by you (such as your name, email address, list of friends, profile picture and other information available via the applicable social network).

You understand and agree that the Services may access, make available and store such information so that it is available on and through your Wavyn Account, until your Wavyn Account is deleted.

Please note that certain information which you have defined as private on your third party social network accounts may become public to other Wavyn Users through the Services once you have allowed the social network to share such information with Wavyn (for example through your Carpool Profile).

Integration with other third party services

Wavyn may offer you the option to link Wavyn to third party services that may be useful to you (like, Spotify). Where Wavyn detects an integration may be available (either because a third party service attempts to link to Wavyn, or Wavyn detects an installed service on the device which has an integration option, or you request a particular integration), Wavyn will ask for confirmation to connect the accounts. If you choose to connect the accounts, Wavyn will ask for your permission to share data with the third party service. You should only agree to connect accounts if you are comfortable with the third party service receiving the data set out at the time of connecting the accounts and Wavyn is not responsible for the third party service’s use of data. You can disconnect Wavyn and the third party service at any time and Wavyn will cease sharing data with that service from the point of disconnection onwards.

Controlling your personal information

You can always review and update certain information by visiting your Account & Login settings (such as your phone, email and more) or the in-app left menu (to update your home, work and favorites).

You can log on to the Wavyn website to view your route history by going to “Edit the Map”/ “Drives” function on the Wavyn website. Note that in order to access certain information you will need to set up a username. Your location and route history is associated with your Account and (if you have chosen to set one up) your username or (if you have chosen not to set up a username) the unique identifier generated by Wavyn.

If you find that the information associated with your Account is not accurate, complete or updated, then you should make all necessary changes to correct it. Please keep in mind that false, incorrect, or outdated information may prevent you from setting up a username and impair the ability to provide you with Services.

Privacy controls

Your in-app Privacy Settings provide you with quick access to settings and tools that let you safeguard your data and decide how your information can make Wavyn services work better for you. For example, you can control your visibility on the map and manage your preferences about the ads shown to you on Wavyn.

There are other ways to control the information Wavyn collects whether or not you’re signed in to a Wavyn Account, including device-level settings: your device may have controls that determine what information we collect. For example, you can modify location settings on your device.

Deleting your information

If you would like us to delete your Account, please send an email to support@wavyn.com with the subject “Delete Account”. On receiving such a request, Wavyn will use reasonable efforts to delete such information, however please note that information may not be deleted immediately from our back-up systems. We aim to initiate the deletion process immediately after your request. Once we receive your request, your data will no longer be used to personalize your Wavyn experience. We then begin a process designed to safely and completely delete the data from our storage systems. This process generally takes around 2 months from the time of deletion. As with any deletion process, things like routine maintenance, unexpected outages, bugs, or failures in our protocols may cause delays in the processes and time frames defined in this policy. We maintain systems designed to detect and remediate such issues.

How Wavyn retains data we collect

Some data you can delete whenever you like, some data is deleted automatically, and some data we retain for longer periods of time when necessary. This section describes why we hold onto different types of data for different periods of time.

How does Wavyn use aggregated information?

Wavyn may use anonymous, statistical or aggregated information (including anonymous location information), in a form that does not enable the identification of a specific user, to properly operate the Services, to improve the quality of the Services, to enhance your experience, to create new services and features, including customized services, to change or cancel existing content or service, and for further internal, commercial and statistical purposes (including advertising).

Wavyn may also use anonymous, statistical or aggregated information collected on the Services, in a form that does not enable the identification of a specific user, by posting, disseminating, transmitting or otherwise communicating or making available such information to users of the Services, to the Services’ providers, partners and any other third party. For example, GPS information that we receive from your mobile device may be provided to map editors in an aggregated and/or anonymous form to help improve the map and solve map problems, traffic data may be provided to cities, and aggregated ads analysis may be provided to advertisers.

Cookies

Wavyn may use cookies and similar technologies on the Services. Cookies are packets of information sent by the Website’s servers to your web browser and then sent back by the browser each time it accesses the Website’s servers.

Wavyn may use cookies for various purposes, such as to save you the need to re-enter your username and password each time you log in, to facilitate the use of the Website, to collect statistical information, to verify information, and to customize the Website to your personal preferences and for information security purposes.

Some of the cookies may expire when the session ends and you exit your browser. Other cookies are saved on your computer’s hard drive. If you wish to block the Website’s cookies, then please use the help button in your browser and follow the necessary instructions. However, bear in mind that disabling cookies may complicate or even prevent your use of the Website, or certain features thereof.

Advertising campaigns

Wavyn allows advertisers to run ad campaigns on the Services.

The information and advertisements that you see when accessing the Services may be targeted on the basis of your current Wavyn activity, such as your current location, your destination or contextual information based on your current drive session. For example: if you search for “gas station” you may see an ad for a local gas station.

Depending on your settings, you may also see ads personalized to you based on:

Please note:

The Services includes an internal messaging system which provides you the ability to send and receive messages to and from other users, and to receive marketing messages from us. You hereby agree that we may use the internal messaging system for the purpose of informing you regarding products or services, which may interest you.

Please note however that other Wavyn users are not allowed to use your contact details or our internal messaging account for commercial advertising purposes. If you have encountered any user generated advertising material, please inform us through the channels listed on the “About” menu in the Software or through the “Contact Us” page on the Site link here.

It is clarified that we are not responsible for the content of said advertisements and the products delivered or services rendered thereby by third parties and you irrevocably and unconditionally agree that we shall not be held responsible or liable for any loss, damage, cost or expense that you may suffer or incur as a result or in connection thereof.

Information security

Wavyn considers information security to be a top priority. Wavyn services are built with strong security features that continuously protect your information. Wavyn implements systems, applications and procedures to secure your personal information, to minimize the risk of theft, damage, loss of information, or unauthorized access or use of information. For example, we review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems. In addition, we restrict access to personal information to Wavyn employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

The insights we gain from maintaining our services help us detect and automatically block security threats from ever reaching you.

However, these measures are unable to provide absolute assurance. Therefore, although Wavyn takes great efforts to protect your personal information, Wavyn cannot guarantee and you cannot reasonably expect that Wavyn’s databases will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

Compliance & cooperation with regulators

We regularly review this Privacy Policy and make sure that we process your information in ways that comply with it.

Data transfers

We store data on servers located around the world and your information may be processed on servers located outside of the country where you live. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections described in this policy.

When we receive formal written complaints, we respond by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of your data that we cannot resolve with you directly.

European requirements

If the European Union (EU) data protection law applies to the processing of your information, we provide the controls described in this policy so you can exercise your right to request access to, update, remove, delete, and restrict the processing of your information.

You can also export a copy of data in your Wavyn account if you want to back it up or export your information to another service. You can log in to the dashboard by going to the Wavyn website, then Settings, then choose Download your data archive. Note that in order to access the dashboard you will need a Wavyn account with a valid email address to receive your data archive.

You also have the right to object to the processing of your information.

We process your information for the purposes described in this policy, based on the following legal grounds:

With your consent

We ask for your agreement to process your information for specific purposes and you have the right to withdraw your consent at any time. You can manage your settings at any time, including your in-app Privacy Settings.

When we’re pursuing legitimate interests

We process your information for our legitimate interests and those of third parties (such as partners including advertisers, in order to report use statistics) while applying appropriate safeguards that protect your privacy. This means that we process your information for things like:

When we’re providing a service

We process your data to provide a service you’ve asked for under a contract (including our terms of use).

When we’re complying with legal obligations

We’ll process your data when we have a legal obligation to do so, for example, if we’re responding to legal process.

If you have questions, you can contact Wavyn and our data protection office, led by our Data Protection Officer, at: privacy@Wavyn.com. And you can contact your local data protection authority if you have concerns regarding your rights under local law.

Changes to this Privacy Policy

Wavyn may from time to time change the terms of this Privacy Policy. Substantial changes will take effect 30 days after Wavyn has posted a:

Other changes will take effect 7 days after their initial posting on the Website. However, if Wavyn amends this Privacy Policy to comply with legal requirements, the amendments will become effective immediately upon their initial posting, or as required.

You agree to be bound by any of the changes made in the terms of this Privacy Policy. Continuing to use the Services will indicate your acceptance of the amended terms. If you do not agree with any of the amended terms, you must avoid any further use of the Services.

Last modified: 15 Jan 2019