Wavie Privacy Statement

This Privacy Statement describes the personal data we collect and/or process (which may include collecting, organizing, structuring, storing, using, or disclosing) to provide products and services offered directly by Wavie Technologies LLC. (“Wavie”), including Wavie’s websites, its webinars, and messaging platform, related collaborative features (“Wavie products and services” or “products and services”). Wavie products and services covered in this Privacy Statement do not include products or services developed by Wavie that are covered under a separate privacy policy (including those listed here).

What Personal Data Do We Receive?

• Account Information: Information associated with an account that licenses Wavie products and services, which may include administrator name, contact information, account ID, billing and transaction information, and account plan information.
• Profile and Participant Information: Information associated with the Wavie profile of a user who uses Wavie products and services under a licensed account or that is provided by an unlicensed participant joining a space, which may include name, display name, picture, email address, phone number, job information, stated locale, user ID, or other information provided by the user and/or their account owner.
• Contact Information: Contact information added by accounts and/or their users to create contact lists on Wavie products and services, which may include contact information a user integrates from a third-party app or provided by users to process referral invitations.
• Settings: Information associated with the preferences and settings on a Wavie account or user profile, which may include audio and video settings, recording file location, screen sharing settings, and other settings and configuration information.
• Registration Information: Information provided when registering for a Wavie Space, webinar, Wavie Room, or recording, which may include name and contact information, responses to registration questions, and other registration information requested by the host.
• Device Information: Information about the computers, phones, and other devices used when interacting with Wavie products and services, which may include information about the speakers, microphone, camera, OS version, hard disk ID, PC name, MAC address, IP address (which may be used to infer general location at a city or country level), device attributes (like operating system version and battery level), WiFi information, and other device information (like Bluetooth signals).
• Content and Context from Webinars, Messaging, and Other Collaborative Features: Content generated in webinars, or messages that are hosted on Wavie products and services, which may include audio, video, chat messaging content, transcriptions, transcript edits and recommendations, written feedback, responses to polls and Q&A, and files, as well as related context, such as invitation details, chat name. Content may contain your voice and image, depending on the account owner’s settings, what you choose to share, your settings, and what you do on Wavie products and services.
• Usage Information Regarding Webinars, Messaging, Collaborative Features and the Website: Information about how people and their devices interact with Wavie products and services, such as: when participants join and leave a space; whether participants sent messages and who they message with; performance data; mouse movements, clicks, keystrokes or actions (such as mute/unmute or video on/off), edits to transcript text, where authorized by the account owner and other inputs that help Wavie to understand feature usage, improve product design, and suggest features; which third-party apps are added to a product or service and what information and actions the app is authorized to access and perform; use of third-party apps and the Wavie App Marketplace; features used (such as screen sharing, emojis, or filters); and other usage information and metrics. This also includes information about when and how people visit and interact with Wavie’s websites, including what pages are accessed, interaction with website features, and whether or not the person signed up for a Wavie product or service.
• Limited Information from Wavie Email and Calendar Services: “Wavie Email” refers to Wavie’s native email service and emails sent from Wavie’s native email service. Wavie Email is designed to be end-to-end encrypted by Wavie by default for emails sent and received directly between active Wavie Email users. Support for end-to-end encryption requires Wavie Email users to have added a device to their Wavie Email account with the associated email address and to use a supported Wavie client. When an email is end-to-end encrypted, only the users, and, depending on their settings, account owners, or designated account administrators control the encryption key and therefore access to the email content, including body text, subject line, attachments, and custom labels applied to messages by users in their inboxes. Emails sent to or received from non-Wavie Email users are encrypted after the email is sent or received from Wavie’s servers if the Wavie Email user chooses to send them with encryption. In all cases, Wavie does have access to email metadata used for basic email delivery—specifically, email addresses in the from, to, cc, and bcc fields, time, mimeID, and the number and size of attachments. From use of Wavie’s native calendar service, Wavie receives information regarding messaging invitations, body text, sender and recipients, and other calendar information.
• Content from Third-Party Integrations: Users can access email and calendars from third-party services through their Wavie client if they choose to integrate them. This information is not end-to-end encrypted by Wavie, but Wavie employees do not access this content unless directed to or required for legal, safety, or security reasons. If account owners and/or their users integrate their third-party emails with products and services offered or powered by Wavie, Wavie may collect or process email information, including email content, headers and metadata, from such third-party services in order to provide services requested by the account and to improve the product.
• Communications with Wavie: Information about your communications with Wavie, including relating to support questions, your account, and other inquiries.
• Information from Partners: Wavie obtains information about account owners and their users from third-party companies, such as market data enrichment services, including information about an account owner’s company size or industry, contact information, or activity of certain enterprise domains. Wavie may also obtain information from third-party advertising partners who deliver ads displayed on Wavie products and services, such as whether you clicked on an ad they showed you.

In certain jurisdictions, some of the personal data Wavie receives may be considered sensitive. Please see “California & Other Other U.S. State Privacy Rights” for more information.

How Do We Use Personal Data?

• Provide Wavie Products and Services: To provide and develop products and services to account owners, their users, and those they invite to join spaces and webinars hosted on their accounts, including customization, recommendations, routing invitations and messages, and customer support.
• Advanced Voice and Video Features: Processing certain video features, such as filters and effects, on the user's device without leaving the device, and using audio analysis to generate accurate transcripts.
• Intelligent Features: Using artificial intelligence, machine learning, or other technology to analyze and process content and personal data for intelligent features and product improvement.
• Product Research and Development: Developing, testing, and improving Wavie products and services, troubleshooting, and enhancing content-related features.
• Marketing, Promotions, and Third-Party Advertising: Marketing, advertising, and promoting Wavie products and services based on product usage, information from third-party partners, and user interactions. Webinar, and messaging content are not used for marketing or promotions.
• Authentication, Integrity, Security, and Safety: Authenticating accounts and activity, detecting and preventing fraudulent and malicious conduct, addressing security threats, and ensuring public safety.
• Communicate with You: Using personal data to communicate about Wavie products and services, including updates, account-related matters, and policy or term changes.
• Legal Reasons: Complying with applicable law, responding to legal process, investigating potential violations, protecting against fraud and unlawful activities, and enforcing terms of service or policies.
• Automated Content Scanning: Automatically scanning content, such as virtual backgrounds, profile images, emails, and files, for product and service improvement, detecting violations, and preventing illegal or harmful activity. Access to such content by Wavie employees is subject to legal, safety, or security requirements or account authorization.

How Do We Share Personal Data?

• Vendors: Working with third-party service providers for product support, improvement, technical infrastructure, payment processing, advertisements, and business analytics. Personal data is subject to contractual and technical requirements.
• For Legal Reasons: Sharing personal data to comply with applicable law, respond to legal processes, enforce terms, detect and prevent fraud, and protect public safety and rights.
• Marketing, Advertising, and Analytics Partners: Using third-party providers for statistics, analysis, advertising, and marketing, based on user activities on Wavie's website.
• Corporate Affiliates: Sharing personal information with corporate affiliates for consistent experiences and to detect and prevent fraud and threats to public safety.
• Change of Control: Sharing personal data in the context of a sale, merger, acquisition, restructuring, or change in control of Wavie's business or assets.

Retention

We retain personal data for as long as required to engage in the uses described in this Privacy Statement, unless a longer retention period is required by applicable law.

The criteria used to determine our retention periods include the following:

• The length of time we have an ongoing relationship with you and provide Wavie products and services to you (for example, for as long as you have an account with us or keep using our products)
• Whether account owners modify or their users delete information through their accounts
• Whether we have a legal obligation to keep the data (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them)
• Whether retention is advisable in light of our legal position (such as in regard to the enforcement of our agreements, the resolution of disputes, and applicable statutes of limitations, litigation, or regulatory investigation)

European Data Protection Specific Information

Data Subjects Rights

If you are in the EEA, Switzerland, or the UK, your rights in relation to your personal data processed by us as a controller specifically include:

• Right of access and/or portability: You have the right to access any personal data that we hold about you and, in some circumstances, have that data provided to you so that you can provide or “port” that data to another provider
• Right of erasure: In certain circumstances, you have the right to the erasure of personal data that we hold about you (for example, if it is no longer necessary for the purposes for which it was originally collected)
• Right to object to processing: In certain circumstances, you have the right to request that we stop processing your personal data and/or stop sending you marketing communications
• Right to rectification: You have the right to require us to correct any inaccurate or incomplete personal data
• Right to restrict processing: You have the right to request that we restrict processing of your personal data in certain circumstances (for example, where you believe that the personal data we hold about you is not accurate or lawfully held)

If you have any other questions about our use of your personal data, please send a request at the contact details specified in the How to Contact Us section of this Privacy Statement. Please note that we may request you to provide us with additional information in order to confirm your identity and ensure that you are entitled to access the relevant personal data.

You also have the right to lodge a complaint to a data protection authority. For more information, please contact your local data protection authority.

Legal Basis for Processing Personal Data

We only use your information in a lawful, transparent, and fair manner. Depending on the specific personal data concerned and the factual context, when Wavie processes personal data as a controller for individuals in regions such as the EEA, Switzerland, and the UK, we rely on the following legal bases as applicable in your jurisdiction:

• As necessary for our contract: When we enter into a contract directly with you, we process your personal data on the basis of our contract in order to prepare and enter into the contract, as well as to perform and manage our contract (i.e., providing Wavie products and services, features and services to account owners, their users, and those they invite to.