Last Update: October 17, 2018
ø. It's All about Transparency
ø.1 First time access and registration
1 - You download the Wafer app and You launch it for the first time; You are asked to select Your phone Country Code and insert Your phone number, before tapping on "Next";
3 - The third registration page is necessary for You to provide Your Wafer Name (it does not need to be unique, it does not need to be Your real name, and can certainly be a nickname or a pseudonym) while Your profile photo is optional. Additionally You shall be asked to grant Wafer access to Your phone address book; Wafer is a messaging application and cannot function without having access to Your phone number and Your contacts' phone numbers. After having provided Your Wafer Name, You shall be able to tap on "Start" and access Wafer. You will not be prompted to go through the registration for any other subsequent access to the Wafer app.
Data policy: Wafer permanently archives Your phone number, the phone numbers contained into Your address book, Your Wafer Name and, if provided, Your profile picture on our encrypted servers in Europe. All the above information shall be promptly deleted, should You choose to delete Your Wafer Account directly from the Wafer app settings.
ø.2 Sending a message to any other Wafer user
1 - In Wafer You have the possibility to send free messages containing multimedia files to other Wafer users at any time.
Data policy: When You send a message to any Wafer user, the message is uploaded from Your device to our encrypted server and it is then transferred to the device of Your contact on Wafer. As soon as the message is received by Your contact, the message path is instantly deleted. Should Your message contain any multimedia file, that file will be archived on encrypted servers for a period of 30 days, in order to allow You to retrieve it and re-download it within that timeframe should You accidentally lose access to it. After 30 days, the file shall be permanently deleted from the servers and will only exist on Your personal device and on Your contact's device. The same applies for a group where all participants are Wafer users.
ø.3 Sending a message to any contact who is not on Wafer
1 - In Wafer You have the possibility to send free messages containing multimedia files to Your contacts who are not on Wafer at any time.
Data policy: When You send a message to any contact who is not on Wafer, the message is uploaded from Your device to our encrypted server and it is ready to be accessed by Your contact who is not on Wafer from any web browser. In order to allow Your contact who is not on Wafer to access the history of the conversation with You, Wafer archives on encrypted servers up to 10 messages; as soon as the 11th message is sent, the first one is marked for deletion, so that only the last 10 messages will be readable at any time by Your contact who is not on Wafer. Should You message contain any multimedia file, that file would be archived on encrypted servers for a period of 30 days, in order to allow You to retrieve it and re-download it within that timeframe should You accidentally lose access to it. After 30 days, the file shall be permanently deleted from the servers and will only exist on Your personal device and Your contact who is not on Wafer shall no longer be able to access it. The same applies for a group where not all participants are Wafer users.
ø.4 Deleting a message
1 - When using Wafer You have the possibility to delete messages at any time, by simply tapping and holding on a message and selecting the option "Delete this Message".
Data policy: When the command "Delete this Message" is given by You, You being the sender of said message, Wafer immediately deletes the message and all associated multimedia files from Your device, as well as from the recipient's device, as well as from all encrypted servers. Following this command, nobody will ever be able to retrieve the message. Alternatively, when the command "Delete this Message" is given by You, You being the recipient of said message, Wafer immediately deletes the message and all associated multimedia files from Your device, thus preserving it on the sender's device as well as on all the encrypted servers.
ø.5 Initiating a free call with any other Wafer user as well as non-Wafer user
1 - In Wafer You have the possibility to initiate free calls with other Wafer users as well as with non-Wafer users at any time.
Data policy: All voice data transferred during a free call on Wafer are end-to-end encrypted.
ø.6 Sharing a message on Facebook and/or Twitter
1 - In Wafer You have the possibility to share messages on Facebook and/or Twitter at any time.
Data policy: When sharing a message on Facebook and/or Twitter, either through direct sharing or through a sharable link, Wafer permanently archives on encrypted servers the shared content, so that said content can be always available on Facebook and/or Twitter.
ø.7 Deleting Your Wafer Account
1 - In Wafer You have the possibility to delete Your Wafer Account at any time, by accessing the settings and selecting the option "Delete Your Wafer Account".
Data policy: When the command "Delete Your Wafer Account" is given by You, Wafer immediately deletes all data associated to You, including phone numbers, address book data, recent files, profile photo, and any other information related to You. Once deleted, said data is not retrievable by anybody.
ø.8 Usage analytics
1 - In Wafer we monitor aggregated user statistics, such as number of registered users, retention rates, total number of exchanged messages, total number of links created, in order to improve the user experience on both the client side and the server side.
Data policy: Aggregated user statistics are collected by Wafer as well by third party tools, in order to gather and validate the most useful parameters for service optimization.
ø.9 Commercial data mining
1 - In Wafer You can rest assured that no commercial data mining is performed on any of Your data or content.
Data policy: N/A
1. Your Acceptance
“Personal Information” shall mean information or combination of information that relates to You, and which can be used to identify You. Personal Information shall include the following:
1 - the information that You make available to the Company when You open Your user account such as Your Wafer Name, Your profile photo, and Your telephone number,
2 - the information which is submitted or made available by You as You use the Service; this includes Your Submissions, Your Log Data, Your Shared Information, as well the information You make available about others with which You communicate through the Service,
3 - as well as other non-public information that is associated with your Personal Information.
“Shared Information” shall mean information about You or relating to You that is voluntarily shared through using the Service, including Submissions that You submit through the Service, any Submissions from others that You re-submit, including Log Data associated with these Submissions and the information about You (including Log Data) that others who are using the Services share about You.
“Submissions” shall mean Your nickname that You use to access the Service (the “Wafer Name”), profile photos and multiple other communications in the form of sketches, photos, stickers, texts, audio messages, videos, and/or any combinations of the above, in addition to like instances, as well as the automatic submission of user’s “last seen” status and “current activity” status. These Submissions may be hosted, and/or published as part of the Service, and may be visible to other users of the Service; in addition, the Submissions may be seen by non-users of the Service, should the Submissions be shared.
“Log Data” shall mean any technical information which is collected by the Company automatically as You use the Service; such Log Data can be collected through log files, cookies or any other means as further explained in the “Automatically Collected Data” section below.
2. How Does the Company Collects, Uses and Shares Information about You
You hereby understand, acknowledge and agree that You will be solely responsible for the Personal Information and any other content You share through the Service and should be aware that when You voluntarily disclose Personal Information using the Service such information may be generally accessible, and may be seen, collected and used by anyone who uses the Service. This may result in unsolicited messages from third parties, and such messages are beyond Company’s control.
The Company shall collect and use information about You exclusively for improving Your experience when using the Service, however the Company does not perform any form of commercial data mining on the content of your Submissions and shall not disclose Your Personal Information or any other content which You disclose through the Service. You are however encouraged to exercise discretion when disclosing Personal Information about Yourself through the Service.
In addition, it is important to note that the ubiquitous nature of the communications made by You using the Service may put a portion of Your Personal Information in the hands of third parties that the Company cannot control. Once Your Personal Information entered into a public domain, such information is no longer considered as private. This means that even after You instruct the Company to terminate Your user account, or Your choose to do so directly through the app Wafer, Your Personal Information and other content You shared through the Service might still be publicly available.
The Company archives permanently only the Personal information and those Submissions that the users deliberately choose to share on Facebook or Twitter. Other Submissions are never archived permanently and are solely archived in their encrypted form for a period of 30 days; this is done in order to allow You to retrieve them should You wish to do so within a reasonable timeframe. In addition, Submissions only exist on the devices of the users. In any case, no archived information is ever subject to any commercial analysis. Fact, the Company has no means to extract any commercial information from archived data.
For the purpose of providing the Service, the Company may collect and use within its architecture the following information about You for the purposes described herein:
2.1 Information about Your Contacts
Wafer is a messaging platform. The most powerful and versatile one, but a messaging platform nonetheless. This entails that it cannot function without accessing Your contacts on Your address book on Your device. Consequently to You granting Wafer access to Your address book, a copy of the phone numbers saved therein (but not names, emails, notes or any other Personal Information in Your address book) will be stored on Company’s servers and will only be used to:
1 - notify You when Your contacts become active on Wafer,
2 - indicate which of Your contacts is already a Wafer user,
3 - correctly display the name of each contact as it appears in Your address book when a call is received (Wafer Free Call),
4 - sync Your contacts with Wafer running on any device,
5 - perform basic numeric analytics to count the Wafer users and their potential reach.
You hereby acknowledge and agree that Your Wafer Number, Wafer Name and Wafer Profile Photo shall be considered as public information, since Wafer and non-Wafer users may add Your Wafer Number, Wafer Name and Wafer Profile Photo to their address book and see that You registered to Wafer.
2.2 Log File Information
You should be advised that while You use the Service, the Company’s servers shall automatically record certain information that Your web browser sends whenever You access the Service. Such server logs may include information such as Your platform type, browser type, browser language, referring page, exit page, URL, pages viewed, how much time You have spent on any of the pages, which pages have followed one another, Your cookies, Your phone number, as well as Your Submissions (the “Log File Information”). During Your use of the Service, the Company’s servers log certain general information that our application sends whenever a message is sent or received, or if You update or request any status information, including time and date stamps and the mobile phone numbers the messages were sent from and to. Log File Information can not be disabled since they are needed for the backend infrastructure of the Service to properly function and connect You with Your friends and contacts.
2.3 Online Status and Seen Status
Every time You access Wafer, other users may see Your connection status (whether You are online or not – and if not, when was the last time You were connected to Wafer, as well as whether You saw messages they sent to You and / or whether You are in the process of creating any content). Should You not want to be seen by any of Your contacts, Wafer allows You to block any contact or to make Yourself invisible to that contact, directly through toggle controls available from the profile page of that specific contact.
2.4 Out of Wafer Communications
Wafer allows You to reach Your friends even if they do not have their Wafer User Account. This means that the information and content that You share through the Service can be broadly and instantly shared publicly with all Wafer users, as well as with any third parties which do not have their Wafer User Account (the “Out of Wafer Communications”). The information and content that You deliberately share through Wafer may thus become public immediately when You share it with a contact who does not have a Wafer User Account, and could be seen by a wider public. In addition, any information and/or content can be shared on external social platforms and/or external online tools and thus may be publicly visible to any third party according to Your settings on those social platforms and/or external online tools.
Out of Wafer Communications cannot be disabled, therefore the Company advises You to consider carefully what You submit and communicate through Wafer, when establishing a conversation with a non-Wafer user.
2.5 Automatically Collected Data
3. Transfer of Your Personal Information to Other Jurisdictions
4. Updates to Your Personal Information
Subject to applicable laws and regulations, You may have the right to request to receive a copy of and make any corrections to Your Personal Information which are held by the Company. You may also choose at any time to deactivate Your User account, directly from the Wafer app settings.
Should Your User Account be terminated by You or by the Company for any reason, the Company will take steps to ensure, to the extent possible, that Your Personal Information is no longer available through the Service within a reasonable period of time (currently estimated to be 12 hours, subject to technical limitations) after such account termination.
5. Third-Party Sites and Platforms
6. Sharing and Disclosure of Personal Information with Third-Parties
The Company does not rent, sell, or share your Personal Information with any third-parties, except as specifically described herein. The Company may disclose Your Personal Information to third-parties if the Company believes such action is necessary:
1 - to comply with national security or other issues of public importance,
2 - to comply with the governmental subpoenas, warrants, orders, or Company’s bankruptcy procedures,
3 - to protect and defend Company’s rights or property (including the enforcement of Company’s agreements),
4 - to protect the Company against potential liability,
6 - to act in urgent circumstances to protect the rights and/or personal safety of users of the Service or members of the public,
7 - to properly provide, maintain or improve the Service.
The Company may from time to time ask You to provide information about your experiences, which will be used to measure and improve quality. You are at no time under any obligation to provide any of such data. Any and all information which is voluntarily submitted in feedback forms or any survey that You accept to take part in is exclusively used for the purposes of reviewing this feedback and improving the Service.
The Company may contact You to send You messages about faults and service issues. The Company reserves the right to use email, Company Website and/or Service Website, Wafer or SMS to notify You of any eventual claims related to the use of our software, websites and/or products, including without limitation claims of violation of third party rights.
The Company may send You alerts/notifications via Wafer to notify You when someone has tried to contact You, or when there is any relevant piece of information that requires your attention.
7. Children’s Privacy
The Service is not designated and does not attend to attract anyone under the age of 16 and the Company does not intentionally or knowingly collect Personal Information through the Service from anyone under the age of 16 (or older in some jurisdictions). If your age is less than 16, You should not use Wafer. The Company encourages parents to be involved in the online activities of their children to ensure that no Personal Information is collected from a child without parental permission.
8. Security of Your Personal Information
The Company takes reasonable precaution to protect Personal Information from misuse, loss and unauthorized access. For the purpose of providing the Service, the Company uses encryption technology to protect Your Personal Information. Please be aware that despite Company’s efforts, no data security measures can guarantee 100% security at all times. Company’s systems and communications networks through which You access the Services may be subject to security breaches and failures which are due to circumstances beyond Company’s reasonable control. If You have any questions regarding the security of your Personal Information, please contact via e-mail the Company, by using the contact form on wafermessenger.com.
10. Contact Information