MyWayv Consumer Health Data Privacy Policy
Initial Effective Date: June 1, 2026 (ET)
Latest Revised Date: August 21, 2026 (ET)
Version: 1.0.1
This Consumer Health Data Privacy Policy (“Privacy Policy”) explains what MyWayv (“we”, “our”, “us” or “MyWayv”) does with your information when you use our website or web pages [mywayv.com], our web-based or mobile-based software (“MyWayv App” or “app”) and its services.
MyWayv is a wellness platform designed to support relaxation, reflection, perspective, everyday resilience and overall wellbeing. MyWayv is not a medical or mental health service. It does not diagnose, treat or prevent any condition and is not a substitute for care from a qualified health professional. MyWayv is not a trauma treatment or PTSD therapy service and is not a substitute for clinical mental health care or Veterans Affairs services.
You may have access to one or more of the following services:
A conversational experience powered by artificial intelligence that begins with a short guided conversation (“Connect”).
A personalized selection of music and sound matched to the direction of that conversation (“Immerse”).
A personalized narrative or story offered to support a shift in perspective (“Perspective”).
A closing reflection to help you carry the experience into your day (“Integrate”).
Voluntary questionnaires about your experience and self-reported everyday wellbeing (“Program Evaluation”).
Access provided through your employer, agency, institution or other organization, including structured pilot programs (“Organizational Services”).
You are interacting with AI software when using our AI-enabled services, and not a person. The Software cannot replace care from a qualified health professional. AI does not replace human judgment and is intended solely as a supportive wellness tool.
We work with employers, public agencies, healthcare organizations, educational institutions, veteran and military organizations, first responder agencies and community organizations to offer our services. These are called Organizational Services. Before you can use Organizational Services, you will need to agree to our notices and to the notices of your Organization.
By using our website, web pages, app and services, you acknowledge this Privacy Policy and any other related terms and policies [mywayv.com/terms] (“notices”).
Acknowledging this Privacy Policy is not consent to our collection or sharing of sensitive or health-related information. Where applicable law requires your consent for that, we ask you for it separately and affirmatively, and you may withdraw it at any time.
If you are a resident of Washington, Nevada or Connecticut, information you share about how you feel is “consumer health data” under the laws of your state. Please read our separate Consumer Health Data Privacy Policy [mywayv.com/health-privacy], which governs that information and sets out additional rights.
If you are a California resident, please also read Section 13, which contains the disclosures and rights required by the California Consumer Privacy Act, as amended by the California Privacy Rights Act.
1. About MyWayv and Our Contact Details
MyWayv Holding, Inc., a Delaware corporation (“MyWayv”) is the maker of the MyWayv App and its services. The app and services are available in English and Hebrew.
Where MyWayv decides the purpose and means of personal data processing, we act as the “business or controller”, “business” or equivalent. Where we process personal data at the instruction and direction of your Organization, we act as a “service provider” or “service provider”.
If you have any questions, comments, complaints or requests about our app and services, you can email us at info@mywayv.com. To contact our Privacy Officer directly, email privacy@mywayv.com. You can also write to us at:
MyWayv
21301 Powerline Rd, Suite 206
Boca Raton, FL 33433
United States
Telephone: +1 561-749-2090
2. What Information We Collect and Use
Depending on how you interact with us, we may collect a minimal amount of personal data, meaning information that identifies you or could reasonably be used to identify you. Personal data does not include publicly available information, or anonymized or aggregated information.
We design our app to collect as little personal data as possible in order to keep your data safe and protect your privacy. This means there is less risk of your information being misused. You control the information you share with us. When you share information with us, we are responsible for taking care of it.
When you use our app and services
Information provided by you
Information about you. This includes things such as your nickname or display name, age range, and any identifiers you may voluntarily reveal about yourself. Where required by your Organization, this may include contact information or an Organization-issued identifier.
Conversation data. This covers what you type or say during the Connect conversation, including your stated feelings, preferences, the emotional direction you indicate, and anything else you choose to share. It also includes your responses to any voluntary questionnaires from us or your Organization.
Experience data. This covers the experiences delivered to you, including the sound and music selections, narratives and reflections presented, how long you listened, whether you completed an experience, and any ratings or reactions you provide.
Correspondence data. If you email us, you might share personal data such as your name, email address, postal address, the organization you are part of, your job title, and the subject matter of your message.
Feedback data. When we ask for your thoughts on our app and services, we gather your contact information and some basic details about you.
Information collected by automated means or from third parties
Information shared by your Organization. Your Organization, or its appointed representative, may share, or ask you to share, limited personal data with the app, such as an eligibility identifier or contact details, so that we can offer you our services. Where required by your Organization, and without affecting your rights, we may share aggregated engagement information with them as described in Section 3.
App event data. We collect information about what you do in the app, such as where you tap, what actions you take, your settings, notifications you receive, referrer information, channel information, and the screens you visit.
Device data. When you install the app, we receive an app instance identifier for your device and, where provided by the app store, an age-range signal. We also collect information about your device, such as the device type, its time zone, its operating system, and its audio output configuration where relevant to delivering sound. A service provider that helps us deliver content may also receive your IP address in order to provide our services.
Audio playback data. We collect technical information necessary to deliver Experience Content, such as playback events, buffering, and volume-independent completion status. We do not record, store or transmit audio from your device microphone except where you expressly enable and use a voice input feature.
Cookie information. We and our third-party providers collect information about your app and website use via cookies or similar technologies. We use strictly necessary cookies to provide our services. See Section 3 for details.
When you use voice input (where available)
Where a voice input feature is made available and you choose to enable it, we process the audio of what you say in order to convert it to text so that the conversational experience can respond. You must grant microphone permission before any audio is captured, and you can withdraw that permission at any time in your device settings. Audio is processed for transcription and is not retained after transcription is complete, except where retention is necessary to investigate a technical fault or safety issue. We do not use your voice to identify you and we do not create voiceprints or biometric identifiers.
When you access MyWayv through your Organization
Where your Organization provides access, the following additional information may be used:
Information from your Organization. This may include an eligibility identifier, participant group or cohort designation, program or pilot identifier, and, where your Organization uses Single Sign-On (SSO), a unique encrypted code that allows us to create a random identifier for you. MyWayv does not collect or use your Organization login credentials.
Information about you. This may include, but is not limited to, your preferred language, country, participant group and program start date.
When you participate in Program Evaluation
If you choose to complete a voluntary questionnaire, we collect your responses. These may cover:
Participant experience. Your views on the relevance, personalization and perceived value of the MyWayv experience.
Engagement. How you interact with the platform over time.
Everyday wellbeing. Your self-reported perceptions of relaxation, rest, perspective, focus, energy and overall wellbeing.
Program satisfaction. Your overall satisfaction, continued interest, and likelihood of recommending the program.
These questionnaires are not clinical or diagnostic assessments and are not used to evaluate you individually.
When you participate in a MyWayv evaluation or research study
You can choose to sign up and join a study run by us or by one of our research partners. If you volunteer, we will collect some information from you. This may include:
Information about you. This may include, but is not limited to, your contact details, country, age range, and general demographic details relevant to the study.
Wellbeing data. This may include, but is not limited to, your responses to validated self-report measures of relaxation, rest, perspective, focus, energy and overall wellbeing, and your responses to study questionnaires.
You will always be told what a specific study collects before you consent to join, and you can withdraw at any time. Studies are voluntary, and declining does not affect your access to the Software.
When you visit our website or social media accounts or our web pages
Correspondence data. If you contact us, you might share personal data such as your name, email address, postal address, the organization you are part of, your job title, business contact details, and the subject matter of your message.
Cookie information. We and our third-party providers collect information about your website use via cookies or similar technologies. This information could include, but is not limited to, browser type, browser language, operating system, language settings, web page views and link clicks, campaign clicks, and IP address.
If you interact with us on our social media channels, we may see the personal information you choose to share there, such as your profile name and the content of your message. Your social media account will not be linked to your MyWayv app account.
When you participate in our campaigns, promotions or marketing events
Promotion event data. If you participate in our promotional activities, we may collect your name and contact details.
Any promotions, campaigns or surveys you participate in will not be connected to your app account. Instead, this information will be stored securely in our business productivity or marketing tool accounts.
We may place advertisements online to see how many people are interested in our service or to promote it. We use only trusted advertising managers. We do not collect any personal information about you when you see or click on our advertisements.
When you apply for a role at MyWayv
Recruitment data. This may include, but is not limited to, your name, contact details, resume, references, credentials, transcripts, government-issued identification, compensation information, and any information you voluntarily provide in your application.
Sources of personal data
We obtain your personal data either from you, from your Organization, or from service providers that your Organization asks us to work with.
Information we do not collect
To be clear about our boundaries:
We do not collect diagnoses, medical records, prescription information, or clinical assessment results.
We do not collect information about crimes or offenses. Please do not share any such information when using our Software.
We do not collect or store payment card information. See Section 4.
We do not create biometric identifiers from your voice.
We do not sell your personal data, and we do not share your conversations, messages or usage with advertisers or data brokers.
3. How We Use Your Information
Legal grounds
We follow data protection laws that require us to look after your personal data properly. Here is how and why we might use it:
Consent. Sometimes we ask whether it is acceptable to use your personal data. You can always change your mind later by writing to us.
Contract performance. When you use our app or services, we may need some of your personal data in order to provide our services and make sure everything works properly.
Legitimate interests. We, or someone we trust, may use your personal data to keep our services safe from fraud or security problems. We may also use it to make our services better.
Legal obligation. Sometimes we need to use your personal data to follow the law or to protect our company and the people who provide the services.
Sometimes we process information that you share about how you feel, your mood, or your emotional state. Depending on the jurisdiction, this may be treated as sensitive or special category data. We will only process it where we have a lawful basis and an appropriate additional condition, such as your explicit consent, or where the processing is necessary for the establishment, exercise or defense of legal claims.
Uses of your information
1. Information about you
a. To provide and manage the app and services:
i. To recognize which Organization you are part of, where applicable.
ii. To recognize whether you are a new or existing user of the app and service.
iii. Where needed, to request your permission to enable your device’s microphone.
iv. To collect, transfer, store and use your provided information so that our services work.
v. To set up and keep track of your sessions and your use of our services.
vi. To allow you to change your nickname or display name.
vii. Where needed, to connect with your Organization’s approved systems to handle your information.
viii. To keep a record of any permissions you give us.
ix. To let you know if we change our rules or this privacy notice in the app.
Legal grounds: for each purpose listed above, we will rely on one of the following: contract performance, legitimate interests, or consent.
2. Use of conversation data
a. To provide and manage the app and services:
i. To understand the emotional direction you indicate so that we can assemble an experience for you.
ii. To select and sequence music, sound, narrative and reflection content that matches that direction.
iii. To remember the messages you send and the choices you make while using the app, so that the conversation makes sense and so that your experience can carry forward across sessions.
iv. To translate between your preferred language and the language used by our systems, where a translation feature is provided.
v. To detect and remove personal identifiers that you may have shared accidentally, so that they cannot be traced back to you.
vi. To detect words or phrases that may indicate distress or an emergency, and to respond with pre-defined safe content and signposting to support resources. This is an automated safety feature, not a monitoring or intervention service.
vii. To provide personalized recommendations of supportive self-help resources and content.
viii. To design, test and improve the AI systems, content libraries, narratives and conversational flows used in the MyWayv experience, using anonymized data.
Legal basis: for each purpose listed above, we will rely on one of the following: contract performance, legitimate interests, or consent, together with appropriate additional conditions for any sensitive data.
3. Use of experience data
a. To deliver and improve the experience:
i. To deliver the correct sound, music and narrative content to your device.
ii. To understand which combinations of content are experienced as most relevant and valuable across the participant population, in aggregate.
iii. To improve the sequencing, pacing and composition of the four-stage experience.
iv. To develop new content, new experience formats and new services.
Legal basis: for each purpose listed above, we will rely on one of the following: contract performance or legitimate interests.
4. Use of Program Evaluation responses
a. To evaluate and report on the program:
i. To understand participant experience, engagement, self-reported everyday wellbeing, and program satisfaction.
ii. To produce aggregated, program-level reporting for your Organization.
iii. To improve the design of our services.
iv. To support our own internal evaluation and research.
We remove details that identify you before using questionnaire responses for evaluation and reporting.
Legal basis: for each purpose listed above, we will rely on one of the following: consent, legitimate interests, or as defined by your Organization.
5. Use of correspondence data
a. To communicate effectively with you:
i. To answer your questions, requests, complaints and other feedback.
ii. To fix any problems with our services.
iii. To send you important service updates.
iv. To keep a record of our conversations with you so that we can ensure quality, follow applicable rules, and train our team.
Legal basis: for each purpose listed above, we will rely on one of the following: contract performance or legitimate interests.
6. Use of feedback
a. To improve our app and services:
i. To invite you to take part in activities such as sharing your thoughts about our product or helping us test it.
ii. To understand your feedback so that we can make our product and services safer and better.
iii. To make sure that everyone has a fair opportunity to take part and that we test our product with the right groups of people.
Legal basis: for each purpose listed above, we will rely on one of the following: consent or legitimate interests.
7. Information sharing with your Organization
a. To provide and manage the app and services:
i. We may send you links, or allow you to use access codes, so that you can use the app.
ii. The app may verify that you are part of your Organization.
iii. We share aggregated, program-level reports and statistics with your Organization.
Your Organization does not receive your individual conversations, the content of your conversations, your questionnaire responses at an individual level, or the specific experiences delivered to you. Your Organization receives program-level information only, such as participation rates, engagement patterns, and summarized feedback.
Where a participant group is small enough that aggregated reporting could reasonably identify an individual, we apply a minimum reporting threshold of 20 participants and suppress or further aggregate the reporting.
Legal basis: contract performance, together with appropriate additional conditions for any sensitive data.
8. Use of app event and device data
a. To understand app and service usage:
i. We remove identifiers from your information before using it to check how well our app works and to make sure your information is safe.
ii. We monitor and record the safety and performance of the app so that we can meet our legal requirements and report to your Organization. Any reporting to your Organization is aggregated and program-level only, and never includes individual safety events, conversations or messages.
iii. We share usage data that cannot identify you with trusted analytics providers. This helps us make the app better.
iv. We use the information to create new services, technologies and products.
Legal basis: for each purpose listed above, we will rely on one of the following: contract performance, legitimate interests, or legal obligation.
b. For marketing purposes:
i. We create and run campaigns, send out surveys, and give updates about our programs.
ii. We use anonymized data to understand how well we are doing, to make marketing materials, and to benchmark ourselves against others.
Legal basis: for each purpose listed above, we will rely on one of the following: legitimate interests or consent.
c. To ensure availability and security:
i. To make sure the content in our app works well.
ii. To keep your information safe from unauthorized access and online threats.
Legal basis: for each purpose listed above, we will rely on one of the following: contract performance or legitimate interests.
d. For fraud prevention: to prevent fraud or misuse of our services and to secure our systems.
Legal basis: legitimate interests.
e. To provide in-app notifications and reminders: we send you alerts if you choose to set reminders or enable notifications, for example to return to an experience or to complete a voluntary questionnaire. You can turn notifications off at any time in the app settings or in your device settings.
Legal basis: consent.
9. Use of cookie information
We use some necessary cookies to make sure our website and app work properly. Here is a simple guide to the kinds of cookies we might use:
Essential cookies. These are necessary for the website and app to work. They help make sure everything runs smoothly, such as when you use the conversational experience. These cookies do not collect any information about you. We manage these cookies ourselves.
Analytical cookies. We use these cookies to see how well our website and app are performing. They help us understand what is working and what needs fixing.
“Do Not Track” (DNT) is a setting you can turn on in your web browser to keep your online activities more private. There is no common industry standard for DNT, and we do not currently respond to DNT signals. We do, however, recognize and honor the Global Privacy Control (GPC) and other browser or device opt-out preference signals. Where you enable GPC, we treat it as a valid request to opt out of any sale or sharing of personal information from that browser or device, as described in Section 13.
Legal basis: legitimate interests, or consent where required by applicable law.
Additional processing when you use LLM-enabled AI
By default, the MyWayv conversational experience uses proprietary logic together with third-party large language models (“LLM”) to provide the service. This allows the experience to respond in a way that is more suited to you and to the emotional direction you indicate. Your conversation data is processed to provide this service.
a. To provide the LLM-enabled AI:
i. We share your relevant conversation messages with the LLM (“Input”).
ii. We use the LLM to process and classify conversation data in order to select appropriate content and to support safer conversational flows.
iii. We design prompts to guide the LLM to respond appropriately to the Input. The prompts include your message, summaries of your sessions over a period, and our validated instructions.
iv. Our systems detect personal identifiers that you may have shared by mistake. Where any are found, we either prompt you to revise your message before it is sent to the LLM, or automatically remove the identifier from the text before transmission. Identifiers removed in this way are not recoverable.
v. We maintain safety guardrails to keep the experience safe. All Inputs pass through these guardrails. If your message does not clear the guardrails, we do not send it to the LLM. When the LLM responds (“Output”), the Output must also pass our safety rules. If it does not, we do not release the Output, and instead provide a pre-defined safe response.
Legal basis: for each purpose listed above, we will rely on one of the following: contract performance or legitimate interests.
Important note: We do not share your device identifiers with the LLM provider. Where we generate summaries or insights for you, we share only derived and anonymized data with the third-party service provider.
Additional processing when you access MyWayv through your Organization
a. To process Organization-provided data:
i. Where applicable, to redirect you to your Organization’s SSO page when you access the app.
ii. To collect, store and use the Organization-provided identifier in order to provide access to the app and service.
iii. To confirm your eligibility for the program.
Legal basis: contract performance and as defined by your Organization.
If you have any questions about your use of SSO, please contact your Organization directly.
b. To process your provided data:
i. To deliver the MyWayv experience to you.
ii. To share population-level and aggregated analytics on app and service engagement with your Organization, subject to the minimum reporting threshold described above.
You can delete your data at any time by selecting the data reset option available within the app.
Legal basis: contract performance and as defined by your Organization.
Additional processing during participation in evaluation or research studies
a. To process the information you share during participation:
i. To inform you about the study purposes.
ii. To understand your eligibility for the study.
iii. To manage your enrollment.
iv. To send study-related information and reminders.
v. To contact you during the study for research purposes and to respond to your requests.
vi. To seek your feedback and clarify any questions.
vii. To perform analysis using the information provided.
Legal basis: your consent and legitimate interests.
Note: You can stop participating in a study at any time after it starts. You can do this by changing the settings in the app or by sending an email to info@mywayv.com with the subject “opt out of MyWayv study”. Once you opt out, we will delete your enrollment data within one year. However, the data you provided while using the app will be kept in accordance with our data retention practices, which are described in Section 4.
Additional processing when you visit our website, social media accounts or web pages
a. To process your correspondence data:
i. We collect, store and use business data when you contact us.
ii. We respond to and provide support for your questions.
iii. We communicate with prospective and existing customers to develop our business, manage accounts, or for marketing purposes.
iv. We monitor, enforce and comply with unsolicited communication laws prior to any marketing or business development outreach.
Legal basis: your consent and legitimate interests.
b. To process cookie information during your visit. To find out how we manage cookie data, please see the section on the use of cookie information above.
Additional processing during campaigns, promotions or marketing events
a. To process promotion event data:
i. To sign you up and get you started on the promotion or campaign.
ii. To contact you about campaigns and promotions.
iii. To send you information about promotions, newsletters, webinar invitations and reminders.
iv. To make sure we follow the rules about unsolicited messages before we contact you for marketing or business reasons.
Legal basis: for each purpose listed above, we will rely on one of the following: your consent, legitimate interests, or as defined by your Organization.
Note: If you want to leave a promotion or campaign, you can email us at info@mywayv.com. We will reply within three business days. Your information will remain private.
Additional processing when you apply for a role at MyWayv
a. To process recruitment data:
i. To gather, save and organize recruitment data from external recruitment sources.
ii. To review your application.
iii. To make a job offer.
iv. To enter into an employment contract with you.
v. To run background and reference checks.
vi. To inform you of your application status.
vii. To consider you for other job opportunities.
viii. To improve our hiring process.
Legal basis: your consent and legitimate interests.
We do not share or sell your information, your conversations, or how you use our apps to advertisers or to companies that buy data.
Processing for legitimate interests
We may need to use your personal information for important reasons. Before doing so, we will always weigh and protect your rights and privacy. Here are the reasons we might use your data:
To perform our agreements with your Organization.
To comply with the law where it requires us to use or share it.
For court cases or legal orders.
For law enforcement or national security requirements.
To help investigate or prevent illegal activities.
To preserve data for legal reasons so that it cannot be changed or deleted.
To report public health information where required.
To prevent serious risks to health or safety.
To conduct evaluation and research and to understand how people use our services.
To communicate with you about your use of our app and services.
To maintain and protect the app’s security and operations.
To prevent fraud or misuse of our service.
To keep your data secure and private.
To make sure the app and services work well and are easy to use.
To protect your fundamental rights and safety.
To use anonymized data for benchmarking and marketing.
To create new services, technologies and products.
To answer your questions and requests.
4. How We Protect Your Information
Where your information is stored
The information we collect is saved and kept secure in cloud servers managed by AWS. Some of your information might be shared with and stored by our third-party service providers in order to provide our services. For a list of service providers, please see mywayv.com/service-providers.
How long we keep your information
When you use our app and services, including Organizational Services
When you send us messages, any personal identifier you share is removed and stored in a way that cannot be reversed. We keep information only for as long as we need it to provide the service, to comply with the law, or to meet our contractual commitments with your Organization. If there is no specific time limit that applies, we keep your information for up to 3 years from the last time you updated it. You can also choose to delete all of your conversation and experience data permanently by using the data reset/delete account option in the app settings.
Your correspondence data
When you email us, we use the information you provide to help you. We keep your emails secure in our business productivity account, and only authorized staff can access them. We will keep your email for up to 3 years from the last time you contacted us.
Information received from your Organization
We keep your information for the period your Organization has determined. After that period, we delete your information permanently. If you need to correct something or have any questions about information your Organization provided, please contact your Organization.
When you use LLM-enabled AI
We keep your personal and derived information in our systems and those of our third-party service providers only for as long as needed to meet the purposes stated in this Privacy Policy or as required by law. We have enabled zero data retention with our LLM provider, which means your conversation data is not stored by them and is not used by them to train their models.
Personalized recommendations
We irreversibly remove any accidental personal identifiers from your conversation data before processing. All insights and recommendations are pseudonymized and encrypted in our systems.
When you join our evaluation or research initiatives
You can stop participating in a study at any time after it starts. You can do this using any of the available opt-out features or by sending an email to info@mywayv.com with the subject “opt out of MyWayv study”. Once you opt out, we will delete your study enrollment data within one year. The data you provided during the study will be kept in accordance with our data retention practices. Where required, we may retain one copy of your anonymized data for a longer duration for future audit or verification purposes.
Payment data
We do not collect, keep or store your credit card information. Third-party payment companies handle card processing. We do not receive personal data from app stores after a purchase or from our third-party payment providers. However, we may record the name of a business customer for our internal purposes. Please read the payment provider’s terms and privacy policy before you make a payment. We do receive and handle payment confirmations and subscription details in order to support your subscription requests.
Third-party sites
The app may contain links to other websites or resources. When you click on these links, remember that those other sites have their own privacy practices. We do not control those sites and we are not responsible for their privacy practices. We recommend that you read their privacy notices before you share any personal data with them.
Children’s privacy
The app is intended for adults aged 18 and over. You cannot use the app and services if you are under 18. MyWayv does not take responsibility if someone misrepresents their age in order to use the app and services.
Protecting children’s privacy is important to us. We do not knowingly collect personal data from anyone below the approved age. If you believe we hold personal data relating to a child, please write to us at info@mywayv.com. We will respond within one month after verifying the information. If we cannot identify the user correctly, we may not be able to address your request. If we find that we have collected personal data from a child, we will deactivate the account and take steps to remove the relevant data.
Best practices
We want to help you stay safe online. Here are some tips:
Always lock your mobile screen with a passcode. Make sure it is strong and do not share it with anyone. Never leave your device unattended.
Always update your device’s operating system to the latest version.
Turn on remote access on your device so that you can find and control it if it is lost or stolen.
Install anti-virus software to protect your device.
Be careful with emails. Do not open files, click on links, or download anything from sources you do not know.
Be careful when using public Wi-Fi. Before sending personal or important data over a public network in a place such as a coffee shop or airport, check that the network is safe.
Use headphones in shared spaces if you would prefer that others not hear your experience.
5. Data Security Overview
We use commercially reasonable efforts to implement administrative, organizational and technical safeguards to keep your information secure. We adhere to information security policies and procedures and have implemented controls to protect sensitive data. We have appointed a Privacy Officer and a Chief Information Security Officer (CISO) to oversee information governance and product safety.
Protecting your privacy
We ask for the minimum information necessary to provide the service.
A nickname is enough for the conversational experience to address you.
We use masked identifiers to keep your data and identity separate.
No MyWayv staff member listens to your conversations for routine purposes.
If you accidentally share personal data, we take steps to remove it.
You can choose the data reset option to delete your information.
Before we use any personal data about you, we assess whether the use respects your rights.
Your Organization never receives your individual conversations.
Protecting your security
We use strong encryption to protect your data in transit and at rest.
Only authorized people can access your data. They must use strong passwords and multi-factor authentication.
All staff computers have endpoint security controls.
We maintain contracts with the companies we work with to keep your data safe.
We carry out background checks on new staff before hiring them.
We train our staff on how to handle your information securely.
We engage independent external auditors to assess our compliance annually.
We regularly test our app and systems for vulnerabilities.
We remediate identified issues in our code to keep it secure.
We regularly review our compliance with our own security policies.
Additional safeguards when you use LLM-enabled AI
Every message sent to and from the LLM is encrypted so that no one else can read it.
Any personal identifiers voluntarily shared in conversation data are removed. This helps keep your private details from being shared with the LLM service provider.
We use safety guardrails to check everything sent to and received from the LLM to make sure it is safe and appropriate.
We do not share your device data with the LLM.
Your conversation messages are not retained by the LLM provider.
Your conversation messages are not used as training data by the LLM provider.
We do our best to keep your personal data secure, but no method is perfect. We cannot promise complete security. You can help keep your data safe too. Please do not share personal identifiers where they are not requested, and please do not copy and share your sessions with people you do not know.
6. Responsible Use of Artificial Intelligence
At MyWayv, we use artificial intelligence to understand what you tell us during the Connect conversation, and to assemble a personalized experience of music, sound, narrative and reflection in response.
Our AI is purpose-built and does not operate as a general-purpose generative AI assistant. It does not change in real time, meaning it does not continually modify itself or learn from each conversation on its own. Each conversation works at a step level within a structured experience framework. At each step, we may use the prediction from our own programs, the inference from an LLM, or both. We may also use our proprietary programs to qualify a conversation for an LLM inference.
All content presented in a MyWayv experience is drawn from our own curated library. Every piece of AI-generated language passes through our safety and quality checks, and all LLM-based conversational prompts are designed and tested by our team to be safe and appropriate for a non-clinical wellness context.
Our AI is not designed to, and does not, make decisions that produce legal or similarly significant effects concerning you. It does not evaluate, score, rank, screen or triage you, and its outputs are not provided to your Organization.
We maintain governance practices to monitor and review the use of AI at MyWayv, making sure your rights are protected. Please contact us at info@mywayv.com if you have any questions about our use of AI.
Read our product’s intended purposes and terms of use mywayv.com/terms-of-use.
Read our Responsible AI approach mywayv.com/responsible-ai.
While MyWayv has put in place reasonable safety and data protection controls, you understand and acknowledge that AI is a developing technology. The potential risks inherent to this technology may not be fully understood and safeguards may not be fully developed. Due to the nature of the technology, you may sometimes receive responses that do not accurately reflect the action required.
7. Who We Share Information With
Service providers
We work with third-party companies that help us run our app, resolve problems, and provide other important services. These companies may process your personal data in order to provide services for us, under contract and only on our instructions. For a list of service providers, please see mywayv.com/service-providers.
Where your Organization authorizes it, we may also connect with your Organization’s authorized service providers so that you can access the resources your Organization offers.
Your Organization
We share aggregated, program-level information with your Organization as described in Section 3. We do not share your individual conversations, the content of your conversations, or your individual questionnaire responses with your Organization.
Legal
We sometimes need to use your personal data to comply with the law. This might mean sharing your information with courts, law enforcement, regulators or other appropriate bodies. We might also use your information to prevent serious health or safety risks, for required public health reporting, and to preserve information during legal proceedings so that it is not altered. We might also share your information to help detect or prevent fraud or crime. We will take steps to ensure that your rights and interests are protected.
Reorganization
In situations such as a sale of our business, a merger with another company, a reorganization, or insolvency, we may need to share some of your personal data with others. These third parties would use your information to evaluate the transaction. Following such a change, we might also share your information with the new company for the same purposes described in this privacy notice. We will try to let you know by posting a notice on our website, informing your Organization, sending you a notification in the app, or updating this privacy notice.
8. Sharing Information Outside Your Country
MyWayv processes and stores all consumer health data in the United States. Our service providers who handle consumer health data are located in the United States unless we notify you otherwise. Every service provider that handles personal information for us is bound by a written contract that limits what it may do with the information, requires it to protect the information, and prohibits it from selling the information or using it for its own purposes.
We only share the data that is necessary between MyWayv offices in order to provide the service. We use appropriate technical measures to keep your data safe.
If you have any questions about how we transfer your data to other countries, you can email us at info@mywayv.com.
9. Your Data Protection Rights
When you use the data reset option in the app settings
The data reset feature is found in the app settings. If you use this feature, your conversation information, including your identifier, past sessions, experience history, reminders, questionnaire responses and settings, will be deleted from our systems. Once you reset, you cannot recover any of your previous sessions and you will be treated as a new user. Please consider carefully before using this feature.
Aggregated and anonymized information that can no longer be associated with you, including information already incorporated into program-level reporting provided to your Organization, cannot be retrieved or removed.
Your privacy rights
What you can do about your data:
Ask questions. You can ask us how we are using your personal data.
Get a copy. You can ask for a copy of the personal data we hold about you.
Correct it. If any personal data about you is wrong or incomplete, you can ask us to fix it.
Delete it. If we no longer need your personal data, you can ask us to delete it.
Pause it. While we look into any questions you raise, you can ask us to restrict our use of your data.
Change your mind. If you previously consented to something, you can withdraw that consent later.
Send it elsewhere. You can ask us to transmit your personal data to someone else electronically.
Object. You can object to our use of your personal data for purposes based on legitimate interests.
No marketing. If you do not want to receive marketing emails, click “unsubscribe” in the email.
Be treated fairly. We will not treat you unfairly, or deny you access to the service, for exercising your rights.
No sale. We do not sell your personal data. You can also direct us not to share your personal data with others who might sell it.
Automated decisions. Our service uses AI to assemble your experience. We do not use AI to identify you, and we do not use AI to make decisions that produce legal or similarly significant effects concerning you. You can tell us at any time that the experience is not working for you, and we will adjust it. We and our service providers may use automated processing where necessary to provide our services or to prevent fraud, abuse or misuse. By using our services, you agree to our use of AI to provide the service. We may change the automated approach we use in the future, and we will update this notice if we do.
Depending on where you live, you may have additional or different rights. Please see Section 13.
Consent management
Obtaining consent. Where we request your consent before collecting any personal data, we will provide clear and easily understandable explanations of the purpose and scope of the data processing activities. You have the right to grant or deny consent.
Modification of consent. If you wish to modify your consent for data processing, you can do so by contacting our Privacy Officer or our customer support. Modification will not affect the lawfulness of any processing carried out based on your prior consent.
Withdrawal of consent. If you wish to withdraw your consent for data processing, you can do so by contacting our Privacy Officer or our customer support. Withdrawal will not affect the lawfulness of any processing carried out based on your prior consent.
By providing this consent management facility, we aim to give you control over your personal data, ensuring transparency and compliance with privacy regulations.
How to exercise your rights
You do not usually have to pay anything to exercise your rights. Sometimes we might need to verify your identity. Contact us using the details in Section 1, or use the request methods in Section 13. If you are a United States resident, we will reply within 45 days of receiving your request, and where reasonably necessary we may extend that period by a further 45 days, telling you before the first 45 days expire. Elsewhere we will reply within one month, or within any shorter period required by applicable law.
When we might say no
We might not be able to agree to your request if:
Retaining the information is necessary to complete a transaction you requested, to provide a service you are still using, or for another purpose expressly permitted as an exception under applicable law.
The law requires us to retain the information.
Granting the request would affect someone else’s privacy.
Granting the request could harm you, us, or someone else’s rights or safety.
The information has already been anonymized or aggregated and can no longer be linked to you.
The request is excessive or manifestly unfounded.
Your right to appeal
If we decline your request, we will tell you why and how to appeal. To appeal, reply to our decision or email privacy@mywayv.com with the subject line “Privacy Request Appeal”. We will respond to your appeal in writing within 45 days, explaining the reasons for our decision.
If we deny your appeal, you may submit a complaint to the Attorney General of your state. Contact details are available at mywayv.com/regulatory-contacts.
10. How to Complain
If you have any concerns about our use of your personal data, you can make a complaint to us at info@mywayv.com. We will acknowledge your complaint within three working days. Some complaints may take longer to resolve. We will keep you updated until the matter is resolved.
You also have the right to lodge a complaint with your local data protection or supervisory authority. Details of the relevant authority can be found mywayv.com/regulatory-contacts.
11. Privacy Officer
If you are still not satisfied with how a matter has been resolved, you can send an email to our grievance officer / Privacy Officer at privacy@mywayv.com.
Privacy Officer roles and responsibilities:
Oversee the implementation of data protection policies and procedures.
Ensure the organization’s compliance with data protection regulations.
Conduct risk assessments related to data processing activities.
Serve as a point of contact for data subjects, data principals and supervisory authorities.
Monitor data security measures, investigate breaches, and enforce staff training to uphold data security.
12. Personal Data Breach Management
In the event of a personal data breach, we follow a defined procedure to mitigate and address the incident promptly. Our response includes identifying the breach, containing its impact, assessing affected data, notifying relevant authorities, and communicating transparently with affected individuals. We conduct thorough investigations to understand the extent of the breach and implement corrective measures to prevent recurrence.
Where a breach requires notification, we will notify affected individuals and the relevant authorities without unreasonable delay and within the time period required by applicable law, including applicable state breach notification statutes and, where it applies, the Federal Trade Commission’s Health Breach Notification Rule. We will not delay notification except as necessary to determine the scope of the breach, to restore the integrity of our systems, or at the request of law enforcement.
13. United States State Privacy Rights and Supplementary Notices
13.1 Consumer health data (Washington, Nevada and Connecticut)
Information you share about how you feel is “consumer health data” under the Washington My Health My Data Act and the Nevada Consumer Health Data Privacy Law. If you are a Connecticut resident, the Connecticut Data Privacy Act (CTDPA) requires your affirmative consent before we collect or process sensitive data about your health or emotional state. Those laws give you additional rights, including the right to a list of everyone we have shared that data with, the right to withdraw your consent, and the right to have the data deleted from our backups and archives.
Those disclosures and rights are set out in our separate Consumer Health Data Privacy Policy mywayv.com/health-privacy, which is linked prominently and separately from our homepage as those laws require.
13.2 California privacy notice (CCPA, as amended by the CPRA)
This section applies to California residents and supplements the rest of this Privacy Policy. Terms such as “personal information”, “sensitive personal information”, “sell”, “share”, “service provider” and “contractor” have the meanings given in the California Consumer Privacy Act.
Categories of personal information we collect
In the preceding 12 months we have collected the following categories of personal information. For each we set out the business purposes for which we use it and the categories of recipients to whom we disclose it for a business purpose.
Categories of sources. We collect this information directly from you; automatically from your device or browser when you use the service; from your Organization where it provides your access; from app stores and payment processors for direct subscribers; and from our own systems, where we derive an inference from what you have told us.
Identifiers
Examples we collect: Nickname or display name; app instance identifier; Organization-issued eligibility identifier; IP address; email address if you contact us.
Business purposes: Providing and securing the service; recognizing returning users; responding to you.
Disclosed for a business purpose to: Cloud hosting and technology service providers.
Internet or other electronic network activity
Examples we collect: App event data; screens visited; playback and completion events; cookie data.
Business purposes: Operating, debugging and improving the service; analytics; security.
Disclosed for a business purpose to: Hosting, analytics and security providers.
Audio, electronic or similar information
Examples we collect: Voice input you choose to provide, processed to text and not retained afterwards.
Business purposes: Converting speech to text so the conversation can respond.
Disclosed for a business purpose to: Speech-to-text service provider.
Commercial information
Examples we collect: Subscription status and payment confirmations for direct subscribers. We do not collect or store payment card numbers.
Business purposes: Managing your subscription.
Disclosed for a business purpose to: App stores; payment processors.
Professional or employment-related information
Examples we collect: Job title and employer where you provide them; recruitment data if you apply for a role.
Business purposes: Business correspondence; recruitment.
Disclosed for a business purpose to: Recruitment and productivity service providers.
Inferences
Examples we collect: Emotional direction inferred from your conversation in order to assemble your experience.
Business purposes: Personalizing the experience.
Disclosed for a business purpose to: Large language model provider; hosting provider.
Sensitive personal information
Examples we collect: Conversation data and Program Evaluation responses concerning your mental or emotional state and wellbeing.
Business purposes: See “Sensitive personal information” below.
Disclosed for a business purpose to: Large language model provider; hosting provider.
We do not collect government identifiers, precise geolocation, biometric identifiers, racial or ethnic origin, religious beliefs, union membership, genetic data, or information about sexual orientation or reproductive health.
Sensitive personal information
Information you give us about your mental or emotional state is sensitive personal information under the CCPA. We use and disclose it only for the purposes permitted by CCPA §1798.121 and its regulations, namely to perform the service you asked for, to ensure security and integrity, to detect and respond to safety signals, for short-term transient use, and to maintain the quality of the service. We do not use it to infer characteristics about you, and we do not use or disclose it for any other purpose.
Because our use is limited to those permitted purposes, the right to limit the use and disclosure of sensitive personal information does not require us to change how we handle it.
You may still submit a limitation request using the methods below, and we will honor it.
Sale and sharing of personal information
We do not sell personal information, and we have not sold personal information in the preceding 12 months. We have never sold or shared the personal information of consumers we know to be under 16.
We do not share personal information for cross-context behavioral advertising, and we do not share consumer health data with any advertising or analytics provider.
Whether or not any sharing occurs, we honor the Global Privacy Control and other opt-out preference signals as described in Section 3, and you may exercise the opt-out right using the methods below.
Retention
We retain each category of personal information for the periods described in Section 4, and no longer than is reasonably necessary for the purpose for which it was collected. Where a fixed period is not stated, we retain the information for up to 3 years from your last interaction, and we retain sensitive personal information for no longer than we retain conversation data generally.
Your California rights
Right to know. To request the specific pieces of personal information we have collected about you, and the categories collected, the sources, the business or commercial purposes, and the categories of third parties to whom we disclosed it.
Right to delete. To request deletion of personal information we collected from you, subject to the exceptions in the CCPA.
Right to correct. To request correction of inaccurate personal information.
Right to opt out of sale or sharing. To direct us not to sell or share your personal information, including by enabling the Global Privacy Control.
Right to limit use of sensitive personal information. To direct us to limit use and disclosure of sensitive personal information to permitted purposes.
Right to non-discrimination. We will not deny you service, charge you a different price, or give you a lower quality experience because you exercised any of these rights. We offer no financial incentive in exchange for personal information.
How to submit a request
You may submit a request in either of these ways:
Email privacy@mywayv.com with the subject line “California Privacy Request”; or
Use the privacy request form in the app settings, or you may also call us at +1 561-749-2090.
Authorized agents. An authorized agent may submit a request on your behalf if they provide your signed written permission. We may contact you directly to confirm the authorization and to verify your identity.
Verification. We will verify that a request comes from you before acting on it. Because the service is designed to collect as little identifying information as possible, we may need to ask for information that lets us match your request to your data, such as the account identifier used in the app. We will use that information only to process your request. If we cannot verify you, we will explain why.
Timing. We will confirm receipt within 10 business days and respond within 45 days. Where reasonably necessary we may extend that by a further 45 days and will tell you before the first period expires. Requests are free unless they are manifestly unfounded or excessive.
If we decline your request, you may appeal as described in Section 9, and you may complain to the California Privacy Protection Agency or the California Attorney General.
California “Shine the Light”
California Civil Code §1798.83 permits California residents to request information about disclosure of personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes.
13.3 Other United States state privacy rights
If you are a resident of Colorado, Connecticut, Virginia, Texas, Oregon, Montana, or another state with a comprehensive consumer privacy law, you have rights to confirm and access your personal data, to correct it, to delete it, to obtain a portable copy, and to opt out of targeted advertising, the sale of personal data, and profiling in furtherance of decisions producing legal or similarly significant effects. MyWayv does not engage in targeted advertising, the sale of personal data, or that kind of profiling.
Processing of sensitive data, including data about mental or emotional health, requires your opt-in consent in these states. We obtain that consent separately, as described above, and you may withdraw it at any time.
Use the request methods in Section 13.2 to exercise these rights. If we decline, you may appeal as described in Section 9, and then complain to your state Attorney General.
13.4 Other supplementary notices
Depending on where you live, additional disclosures and rights may apply to you. Please read the applicable supplementary notice:
Supplementary privacy notice for individual US states mywayv.com/us-state-privacy.
14. Changes to This Policy
If we change our Privacy Policy, we will let you know in the app. If we make material changes to how we handle sensitive personal information, we will seek your affirmative consent before applying those changes to your data. For other changes, if you keep using the app after we notify you of the changes, it means you agree with them. For a list of past changes, please see mywayv.com/changelog.