Privacy Policy

Effective as of September 16, 2024.

Please also see our Protected Health Information Notice of Privacy Practices to learn how your medical information may be used and disclosed and how you can get access to this information. PLEASE REVIEW IT CAREFULLY.

This Privacy Policy describes how Wave Life, Inc (“Wave Life,” “we”, “us” or “our”) handles personal information that we collect through our digital properties that link to this Privacy Policy, including our website and mobile application (collectively, the “Service”), as well as through social media, our marketing activities, and other activities described in this Privacy Policy.  

We may provide additional or supplemental privacy policies to individuals for specific services that we offer at the time we collect personal information.

Personal information we collect

Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:

  • Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, professional title and company name, and phone number.

  • Demographic data, such as your city, state, country of residence, postal code, gender identity, sexual identity, ethnicity, date of birth, and age.

  • Profile data, such as the username that you may set to establish an online account on the Service, biographical details, photograph, links to your profiles on social networks, interests, user preferences, and any other information that you add to your account profile.  

  • Communications that we exchange with you, including when you contact us through the Service, social media, or otherwise.  

  • Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.

  • Wellness information and related data that you may provide when you respond to surveys as part of our programs, Services, or otherwise, such as information about your physical, mental, emotional and financial well-being.

  • Job application data, such as professional credentials and skills, educational and work history, LinkedIn profile page, personal website, authorization to work in the U.S., immigration status, criminal history, and other information that may be included on a resume or curriculum vitae as well as in a cover letter. This may also include diversity information that you voluntarily provide.

  • Payment and transactional data needed to complete your orders and/or payments on or through the Service (including name, payment card information, bank account number, payment processor information), and your payment history.

  • Promotional data, including information you share when you enter a competition, promotion or complete a survey. Please note that if you participate in a sweepstakes, contest or giveaway through the Service, we may ask you for your Contact Data to notify you if you win or not, to verify your identity and/or to send you prizes. In some situations, we may need additional information as a part of the entry process, such as a prize selection choice. These sweepstakes and contests are voluntary. We recommend that you read the rules and other relevant information for each sweepstakes and contest that you enter.

  • Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

  • Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.

  • Data providers, such as information services and data licensors that provide demographic and other information. 

  • Our affiliate partners, such as our affiliate network provider and publishers, influencers, and promoters who participate in our paid affiliate programs.

  • Marketing partners, such as joint marketing partners and event co-sponsors.

  • Third-party services, such as social media services, that you may choose to link to your Service account. This data may include your username, profile picture and other information associated with your account on that third-party service that is made available to us based on your account settings on that service.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

  • Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.

  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.

Cookies and similar technologies. Some of the automatic collection described above is facilitated by the following technologies:

  • Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers place. 

  • Local storage technologies, like HTML5 that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications. 

  • Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked. 

These technologies are used for the following purposes:

  • Essential. To allow the technical operation of the Service, such as by remembering your selections and preferences as you navigate the site, and whether you are logged in when you visit password protected areas of the Service.

  • Analytics. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails. For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en. 

 Data about others. We may offer features that help users invite their friends or contacts to use the Service, and we may collect contact details about these invitees so we can deliver their invitations. Please do not refer someone to us or share their contact details with us unless you have their permission to do so.

Consent to record

By using the Wave Life platform, you are giving consent to Wave Life, Inc. (“Wave”) to record your therapy or coaching sessions on audio or video and create transcriptions from these recordings.

  • Purpose of Use: The recordings and transcriptions may be used for Wave’s business purposes, including, but not limited to, quality control, training, treatment recommendations, and research and development of Wave services. Artificial intelligence technology may assist in some of these processes.

  • De-Identification: Wave may de-identify the recordings and transcriptions, using the resulting data for the purposes outlined above.

  • Access to Recordings: Your coach or therapist, along with their supervisors and peers, may have access to the recordings and transcripts. They may also be used and shared as described in this Privacy Policy.

  • Revoking Consent: You have the right to revoke this consent at any time. To do so, you must send a written request to privacy@wavelife.io. Once revoked, no further recordings or transcriptions will be made, but any existing recordings or transcriptions may still be used as outlined prior to the revocation.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery. We may use your personal information to:

  • provide, operate and improve the Service and our business;

  • establish and maintain your user profile on the Service;

  • facilitate your invitations to friends who you want to invite to join the Service;

  • enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;

  • communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages;

  • understand your needs and interests, and personalize your experience with the Service and our communications; and

  • provide support for the Service, and respond to your requests, questions and feedback.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business. 

Marketing. We, our service providers and our third-party partners may collect and use your personal information for marketing purposes, including sending you direct marketing communications. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.  

To manage our recruiting and process employment applications. We may use personal information, such as information submitted to us in a job application, to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, and monitoring recruitment statistics.

Compliance and protection. We may use your personal information to:

  • comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;

  • protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); 

  • audit our internal processes for compliance with legal and contractual requirements or our internal policies; 

  • enforce the terms and conditions that govern the Service; and 

  • prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.  

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.  

To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.  

Retention. We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection.  

Coaches. Selected coaches in connection with providing the Services, such as to schedule virtual coaching sessions or to assess progress. 

Affiliates. Our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, video conferencing, scheduling, consumer research and website analytics). 

Third parties to assist with health and safety concerns. We may communicate and share personal information with third parties as we believe in good faith is necessary or appropriate to address health and safety concerns or other similar issues, including to comply with any mandatory reporting obligations.

Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Square. Square may use your payment data in accordance with its privacy policy. You may also sign up to be billed by your mobile communications provider, who may use your payment data in accordance with their privacy policies.

Linked third-party services. If you link your Service account to a social media or other third-party service, we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service.

Third parties designated by you. We may share your personal data with third parties where you have instructed us or provided your consent to do so. 

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above. 

Business transferees. Acquirers and other relevant participants in business transactions (or negotiations of or due diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Wave Life, Inc or our affiliates (including, in connection with a bankruptcy or similar proceedings).  

We make commercially reasonable efforts to verify that the parties with whom our mobile application shares personal information provide a level of protection of personal information consistent with the practices described in this Privacy Policy, except that all such parties described above other than service providers and affiliates may, to the extent permitted by law, use personal information as described in their own privacy policies.    

Your choices

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account. 

Opt-out of marketing communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at privacy@wavelife.io. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.  

If you receive marketing text messages from us, you may opt out of receiving further marketing text messages from us by replying STOP to our marketing message.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Linked third-party platforms. If you choose to connect to the Service through your social media account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.

Remove or anonymize your content. You may request that the content that you posted to the Service be removed or anonymized such that your personal information will not be publicly identifiable on the Service by contacting us at privacy@wavelife.io. We may decline to process your request as consistent with law. Please note that even if we process your request, it does not ensure complete or comprehensive removal of the content or information posted on the Service.  

Delete your content or close your account. You can choose to delete certain content through your account. If you wish to request to close your account, please contact us at privacy@wavelife.io.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information. 

International data transfer

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.  

Children

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us at privacy@wavelife.io. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

How to contact us