Privacy Policy

Last updated: 27 May 2025

Welcome to Wavey. This Privacy Policy informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data. It is compliant with the General Data Protection Regulation (GDPR) and the Spanish Organic Law 3/2018 on Data Protection and Guarantee of Digital Rights (LOPDGDD).

We use your data to provide and improve the Service. By using the Service and explicitly consenting at sign-up, you agree to the collection and use of information in accordance with this policy.

1. Data Controller

  • The data controller(s) for your personal data are Anna Routledge and Santiago Cuenca, contactable at info@joinwavey.com.

  • This section will be formally updated upon business registration.

2. Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected:

  • Personal Identifiable Information (PII):

  • Email address

  • First name and last name

  • Date of birth (for age verification, minimum 18 years to use the service)

  • Location (general area, e.g., city/region for event planning, as provided by you)

  • Instagram handle (optional, for verification if provided by you)

  • Profile picture (optional, if uploaded by you)

  • Description/Bio (if provided by you)

Usage Data:

  • Chat messages and content shared within the app (stored on Google Firestore).

  • App interaction data (features used, time spent, crash logs).

Device Information:

  • We may collect information about the device you use to access our Service, such as IP address, operating system version, device identifiers (for security and analytics).

3. Purpose of Data Processing and Legal Basis (GDPR & LOPDGDD)

We use the collected data for the following purposes, with their corresponding legal bases:

  • To provide and maintain our Service (e.g., account creation, chat functionality): Art. 6(1)(b) GDPR (performance of a contract).

  • To verify user eligibility (age verification for 18+ community): Art. 6(1)(b) GDPR (performance of a contract).

  • To facilitate event planning and communication: Art. 6(1)(b) GDPR (performance of a contract).

  • To personalize your experience (e.g., showing relevant content): Art. 6(1)(a) GDPR (consent, if specific consent is sought for certain personalization).

  • To notify you about changes to our Service or important updates: Art. 6(1)(b) GDPR (performance of a contract).

  • To provide customer support: Art. 6(1)(b) GDPR (performance of a contract) or Art. 6(1)(f) GDPR (legitimate interest to assist users).

  • To gather analysis or valuable information to improve our Service: Art. 6(1)(f) GDPR (legitimate interest to enhance the app).

  • To monitor the usage of our Service and ensure security: Art. 6(1)(f) GDPR (legitimate interest to protect our service and users).

  • To detect, prevent and address technical issues or policy violations: Art. 6(1)(f) GDPR (legitimate interest).

  • To comply with legal obligations (e.g., requests from authorities): Art. 6(1)(c) GDPR.

4. Data Storage, Security, and Retention

  • Your data is stored on Google Firestore, a service provided by Google. Google LLC is certified under the EU-U.S. Data Privacy Framework, which provides an adequate level of data protection for transfers of personal data from the EU to the U.S. We rely on Google's Standard Contractual Clauses (SCCs) or other appropriate transfer mechanisms for data transfers outside the EEA where necessary.

  • We implement appropriate technical and organizational measures to protect the security of your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.

  • We will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy, to provide the service (i.e., while your account is active), or as required to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies. After this period, your personal data will be securely deleted or anonymized.

5. Data Sharing and Disclosure

We do not sell your personal data, however, we may share your data with:

  • Service Providers: Third-party companies that provide services on our behalf, such as cloud hosting (Google Firestore). These providers are contractually bound to protect your data and use it only for the purposes we specify.

  • Legal Requirements: If required by Spanish law or in response to valid requests by public authorities (e.g., a court or government agency).

  • Change of Ownership: If the App or its assets are acquired by another individual or entity, your data may be transferred. You will be notified of such a change.

6. Your Data Protection Rights (GDPR & LOPDGDD)

You have the following rights regarding your personal data under GDPR and LOPDGDD:

  • The right to access: You can request copies of your personal data.

  • The right to rectification: You can request that we correct any information you believe is inaccurate, or complete information you believe is incomplete.

  • The right to erasure (right to be forgotten): You can request that we erase your personal data, under certain conditions.

  • The right to restrict processing: You can request that we restrict the processing of your personal data, under certain conditions.

  • The right to object to processing: You can object to our processing of your personal data, under certain conditions, especially where processing is based on legitimate interests.

  • The right to data portability: You can request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

  • The right to withdraw consent: If we are processing your personal data based on your consent, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.

  • The right not to be subject to automated individual decision-making: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

To exercise these rights, please contact us at info@joinwavey.com. We will respond to your request within one month.

You also have the right to lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos - AEPD) if you believe that your data protection rights have been infringed: AEPD, C/ Jorge Juan, 6, 28001-Madrid, or via their website www.aepd.es.

7. International Data Transfers

  • As mentioned, your information, including Personal Data, is stored via Google Firestore. Google adheres to recognized data transfer mechanisms like Standard Contractual Clauses and/or the EU-U.S. Data Privacy Framework to ensure that data transferred outside the EEA is adequately protected.

  • Your explicit consent to this Privacy Policy, followed by your submission of such information, represents your agreement to these transfers.

8. Children's Privacy

Our Service is not intended for and does not knowingly collect data from anyone under the age of 18. We verify age during the sign-up process. If we become aware that we have collected Personal Data from children, we take steps to remove that information from our servers.

9. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and within the App, and by updating the "Last Updated" date. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

10. Contact Us

If you have any questions about this Privacy Policy or our data protection practices, please contact us:

info@joinwavey.com