1. Introduction Welcome to Wave, the messaging service provided by Fairbrook, Inc. (“Fairbrook,” “we,” “us,” or “our”). This Privacy Policy explains how we collect, use, and share your personal data when you use Wave. We comply with applicable data protection laws (such as the GDPR, CCPA/CPRA, LGPD, and PIPEDA). By using Wave, you agree to the practices described in this Policy. If you do not agree, please do not use our Service. Last Updated: April 7, 2025 2. Scope & Definitions • Service (“Wave”): Our messaging application, website, or any platform or feature we operate. • User (“You”): The individual or entity using our Service. • Personal Data: Information that identifies or can be linked to you (e.g., name, email, phone number, voice recordings, etc.). • Usage Data: Information automatically collected from your interactions (e.g., device details, IP addresses, analytics). • User-Generated Content: Content you upload or share (e.g., messages, photos, voice recordings). • Third-Party AI Partners: External services used solely to process data for AI features. 3. Data We Collect We collect data in the following categories, based on your use of Wave: • Account & Contact Information: Your name, email address, phone number, and any profile identifiers. • User-Generated Content: Messages, photos, videos, and voice recordings you share through our Service. • Usage Data: Device details, IP address, app version, and other technical data collected automatically. • Location Data (Optional): Precise or approximate location if you grant permission. • Inquiries & Support: Information provided when you contact our support team. 4. How We Use Your Data We use your data for the following purposes: • Service Delivery & Improvement: To enable messaging, maintain your account, support system features, analyze usage, and enhance your overall experience. • Security & Fraud Prevention: To detect, investigate, and prevent unauthorized or suspicious activity. • Communications: To send Service-related notices and, where you’ve opted in, marketing or promotional communications. • Legal Compliance: To comply with legal obligations and respond to lawful requests. 5. Data Sharing for AI Processing To deliver and continually improve our AI-powered features, we share certain user data—such as voice recordings and associated content—with trusted third-party service providers that specialize in voice transcription, text-to-speech conversion, and AI assistance. For competitive reasons, we do not publicly disclose the names of these partners. However, we assure you that all such data sharing occurs under strict confidentiality and security measures and solely for the purposes described above. If you would like further details regarding the specific providers and the methods they use, please contact us at [email protected], and we will be happy to provide additional information upon request. 6. Data Retention & International Transfers We retain your data only for as long as necessary to deliver our Service, support its improvement, and satisfy legal obligations. Our retention practices are flexible and determined by the purposes for which data is collected. Because Wave is available worldwide, your data may be transferred to and stored in countries outside your jurisdiction. We use appropriate safeguards to ensure your data remains protected regardless of where it is processed. 7. Your Rights & Choices Depending on your location and applicable law, you may have certain rights regarding your data, including: • Access, Correction & Deletion: Request details about the data we hold, correct inaccuracies, or request deletion. • Data Portability: Obtain your data in a structured and machine-readable format. • Opt-Out: Withdraw consent for certain data processing practices (e.g., marketing communications). If you wish to exercise these rights or have any concerns, please contact us using the details provided below. 8. Security & Children's Privacy • Security: We implement commercially reasonable measures to safeguard your data. While we strive to maintain data security, no method is entirely impervious to risks. • Children’s Privacy: Our Service is not intended for children under 13. If we learn that data from a child under 13 was collected without parental consent, we will promptly delete it. 9. Contact & Updates If you have any questions about this Privacy Policy or wish to exercise your rights, please contact us: Fairbrook, Inc. 1050 Haight Street, San Francisco, CA 94117, USA Email: [email protected] We may update this Privacy Policy periodically. Any changes will be posted on our Service with an updated “Last Updated” date. Continued use of Wave indicates your acceptance of the revised terms.