Privacy Policy

Waylo Ahead is a registered business name of Naked Rivals Pty Ltd (ABN 72 665 070 477), Australia. Naked Rivals Pty Ltd is the legal entity that operates the Waylo Ahead app, website and related services. In this Policy, the service may also be referred to as Waylo (we, us, our).

This Privacy Policy explains how we collect, use, disclose, store and protect personal information when you use the Waylo app, website and related services.

Waylo is designed for learner-driver households and may process information about young people. We therefore aim to use privacy-protective defaults and collect only information reasonably needed to provide the service.

1. Information we collect

Depending on how you use Waylo, we may collect:

Account information

• name;

• email address;

• mobile number;

• account settings;

• country, state, province or region;

• subscription and entitlement information; and

• support communications.

Learner information

• learner name or profile name;

• age or age-related information where needed for the service;

• learner-driver jurisdiction;

• licence or permit-related settings you choose to provide;

• supervising-driver relationship or role; and

• driving-experience profile information.

Drive and location information

When a drive is active, Waylo may collect:

• precise device location;

• route and journey information;

• distance, duration and time of drive;

• road types and route classifications;

• traffic, weather, light and condition information;

• driving situations or experience categories encountered; and

• technical information needed to calculate or display the drive.

If you permit background location, Waylo may continue collecting location during an active drive when the app is in the background or the phone is locked. We do not intend to use background location to track a learner when a Waylo drive is not active.

Conversation Feedback

Conversation Feedback is optional.

When enabled, Waylo may use on-device speech recognition to convert parts of in-car conversation into text for processing. Waylo is designed not to record or store raw in-car audio for this feature.

Recognised text may be sent securely to Waylo's backend and an AI-processing provider to generate coaching feedback. Raw recognised text is intended to be transient and not retained as a permanent transcript after processing.

Derived feedback, themes, summaries or scores may be stored with the drive so that users can review them later.

Website and technical information

We may collect:

• device and browser information;

• IP address;

• app version and operating-system information;

• crash, diagnostics and security information;

• cookie or similar technology information; and

• website analytics where you have consented or where otherwise permitted by law.

Subscription information

Where you subscribe through Apple or another app store, we may receive information needed to validate your entitlement, such as product, transaction or subscription status.

We do not receive your full payment-card details from Apple when Apple processes the payment.

2. How we collect information

We collect information:

• directly from you;

• from a parent, guardian, supervising driver or other authorised account user;

• automatically from your device when you use Waylo;

• from app stores and authentication providers;

• from mapping, routing, weather, traffic or similar service providers;

• from analytics and diagnostics providers where enabled; and

• from service providers acting on our behalf.

Where we receive information about a learner from another person, that person must have appropriate authority to provide it.

3. Why we use personal information

We use personal information to:

• create and manage accounts;

• operate active drives;

• record and display driving experience;

• identify gaps in experience;

• generate route suggestions and experience recommendations;

• apply jurisdiction-specific product rules and safeguards;

• provide optional Conversation Feedback;

• manage subscriptions and entitlements;

• provide customer support;

• prevent fraud, misuse and security incidents;

• diagnose faults and improve reliability;

• understand how the service is used;

• comply with legal obligations; and

• establish, exercise or defend legal claims.

We do not sell personal information.

We do not use a learner's precise drive location for third-party behavioural advertising.

4. Legal bases for UK and EEA users

Where UK GDPR or EU GDPR applies, we process personal data only where we have a lawful basis.

Depending on the processing, our lawful bases may include:

• contract: where processing is necessary to provide Waylo to the account holder;

• legitimate interests: for service security, fraud prevention, product reliability, support and proportionate product improvement, where those interests are not overridden by the individual's rights;

• consent: where the law requires consent, including for optional features or certain analytics, device permissions or processing involving young people;

• legal obligation: where processing is needed to comply with applicable law; and

• vital interests: only in exceptional circumstances where processing is necessary to protect someone's life or physical safety.

Where we rely on consent, it can be withdrawn, although withdrawal does not make earlier lawful processing unlawful.

5. Precise location

Precise location is central to recording a Waylo drive and understanding which roads and driving environments were experienced.

We aim to collect precise location only while it is needed for an active drive and related drive processing.

Location tracking should be visible through the app or operating-system indicators when active. Device permissions can be changed in your phone settings, although disabling necessary location access may prevent drive-recording features from working.

We do not intend to make a learner's real-time precise location publicly visible to other users.

6. Young people and families

Waylo is likely to be used by families with teenage learner drivers.

An adult parent, guardian or other legally responsible person should create or manage the account where the learner is not legally able to enter the relevant contract or provide valid consent independently.

We do not knowingly invite children under 13 to create independent Waylo accounts.

Where a learner is under 13 and their information is processed, we require the account and required permissions to be managed by an appropriate parent or guardian unless applicable law provides another lawful basis.

For teenagers who can provide some privacy choices themselves under local law, we aim to present those choices in language appropriate to their age while also involving parents or guardians where legally required.

We aim to use privacy-protective defaults for young people and avoid collecting information that is not reasonably necessary for the service.

7. Conversation Feedback privacy

Conversation Feedback is optional and should be enabled only with the knowledge of the people whose conversation may be processed.

When active:

• the app should provide a visible indication that Conversation Feedback is on;

• speech recognition is used to derive text for coaching analysis;

• Waylo is designed not to store raw audio recordings for this feature;

• recognised text may be transmitted to Waylo's backend and an AI-processing service;

• raw recognised text is intended to be deleted after the relevant processing rather than retained as a permanent transcript; and

• derived coaching feedback and themes may be retained with the drive.

Conversation Feedback can be left off, and microphone or speech-recognition permissions can also be controlled through device settings.

8. AI and automated processing

Waylo may use automated systems and AI to generate coaching feedback, classify experience or support route and experience suggestions.

These systems can make mistakes.

Waylo does not intend to use automated processing to make decisions that produce legal effects or similarly significant effects about a learner, such as licensing, insurance eligibility, employment or access to public services.

Where applicable law gives you rights relating to automated decision-making, you may contact us using the details below.

9. Analytics, cookies and similar technologies

The Waylo website may use necessary cookies or similar technologies for core operation.

Analytics technologies are used only where permitted by applicable law and, where required, after you choose to allow them.

If you choose not to allow optional analytics, the core website should remain available.

We may use aggregated or de-identified information to understand service performance and improve Waylo where lawful.

10. Who we disclose information to

We may disclose personal information to service providers that help us operate Waylo, including providers of:

• cloud hosting and databases;

• authentication;

• mapping and routing;

• weather and traffic information;

• AI processing;

• app-store subscriptions and entitlement validation;

• communications;

• analytics and diagnostics;

• security, fraud prevention and technical support; and

• professional advice, insurance and legal services where reasonably necessary.

We may also disclose information where required by law, to protect a person from a serious threat where law permits, to investigate misuse or security incidents, or as part of a corporate transaction subject to appropriate safeguards.

Service providers are expected to process information only for authorised purposes and subject to appropriate contractual or legal protections.

11. International processing and transfers

Waylo is operated from Australia and may use service providers located in, or processing data from, other countries.

This means personal information may be processed outside the country where the user is located, including in Australia and countries in which our service providers operate.

Where applicable law requires safeguards for international transfers, we will use an appropriate mechanism, which may include contractual protections, adequacy arrangements or another legally recognised safeguard.

For New Zealand users, we will take steps required by the Privacy Act 2020 in relation to overseas disclosures.

For UK and EEA users, where restricted-transfer rules apply, we will use an appropriate transfer mechanism required by applicable data-protection law.

12. Retention

We keep personal information only for as long as reasonably necessary for the purposes described in this Policy, including to provide Waylo, maintain user-requested drive history, meet legal and accounting obligations, resolve disputes, prevent fraud and enforce agreements.

Retention periods can vary by data type.

When an account is deleted, we will delete or de-identify personal information within a reasonable period unless we need to retain particular information for legal, security, fraud-prevention, dispute or other lawful purposes.

Transient Conversation Feedback text is intended not to be retained as a permanent raw transcript after processing.

Backups may take additional time to cycle out securely.

13. Account deletion

Where available, you can initiate account deletion from the Waylo app.

Deleting the Waylo account does not automatically cancel a subscription purchased through an app store. App-store subscriptions must be managed through the relevant store account.

If you cannot access the deletion function, contact us at hello@wayloahead.com.

14. Security

We use reasonable technical and organisational safeguards designed to protect personal information against unauthorised access, loss, misuse, alteration and disclosure.

No internet service can guarantee absolute security.

If we become aware of a data breach, we will assess and notify affected individuals and regulators where required by applicable law.

15. Your privacy rights

Your rights depend on where you live and the law that applies. They may include rights to:

• access personal information we hold about you;

• correct inaccurate information;

• request deletion;

• restrict or object to certain processing;

• withdraw consent;

• receive certain information in a portable form;

• complain to a privacy or data-protection regulator; and

• receive information about certain automated processing.

To exercise a privacy right, contact hello@wayloahead.com. We may need to verify your identity before completing a request.

We will not discriminate against you for exercising a privacy right where applicable law prohibits that conduct.

16. Privacy complaints

If you have a privacy concern, please contact us first at hello@wayloahead.com so we can investigate it.

You may also have the right to complain to the privacy or data-protection regulator in your country, state, province or territory.

For Australian matters, this may include the Office of the Australian Information Commissioner where its jurisdiction applies.

17. UK and EEA representatives

Waylo is operated from Australia.

Where applicable data-protection law requires Naked Rivals Pty Ltd to appoint a representative in the United Kingdom or European Economic Area, we will appoint that representative and publish the representative's contact details before providing the relevant service where that appointment is legally required.

18. Changes to this Policy

We may update this Privacy Policy as Waylo, our service providers or applicable law changes.

Where a change materially affects how we handle personal information, we will take reasonable steps to provide additional notice or obtain consent where required.

The current version will always be published on the Waylo Ahead website with its effective date.

19. Contact

Waylo Ahead is a registered business name of:
Naked Rivals Pty Ltd
ABN 72 665 070 477
Australia
Email: hello@wayloahead.com