Privacy Policy

This Privacy Policy explains how Waylo Pty Ltd (ABN 57 703 695 265), an Australian company registered in New South Wales (we, us, our), collects, uses, discloses, stores and protects personal information when you use the Waylo app, website and related services.

Waylo is operated by Waylo Pty Ltd. The Waylo brand, technology and associated intellectual property are owned by Waylo Holdings Pty Ltd (ABN 13 703 695 078) and licensed exclusively to Waylo Pty Ltd.

Waylo is designed for learner-driver households and newly licensed drivers. Because the service may process information about young people, we aim to use privacy-protective defaults and collect only information reasonably necessary to provide the service.

1. Information we collect

Depending on how you use Waylo, we may collect the following information.

Account information

• Name.

• Email address.

• Mobile number.

• Account settings and preferences.

• Country, state, province or region.

• Subscription and entitlement information.

• Support communications.

Learner information

• Learner name or profile name.

• Age or age-related information where required.

• Learner-driver jurisdiction.

• Licence or permit information you choose to provide.

• Supervising-driver relationships and permissions.

• Driving-experience profile and history.

Drive and location information

When a Waylo drive is active, we may collect:

• Precise device location.

• Route and journey information.

• Distance, duration and time of drive.

• Road types and route classifications.

• Traffic, weather, light and driving conditions.

• Driving situations and experience categories encountered.

• Technical information needed to calculate, analyse or display a drive.

Where background location permission is enabled, Waylo may continue collecting location information during an active drive while the app is in the background or the phone is locked.

Waylo is designed to record journeys during active drives, not to continuously track users between drives.

Conversation Feedback

Conversation Feedback is an optional coaching feature available during supervised learning.

When enabled, Waylo may use speech recognition to convert relevant parts of in-car conversation into text for coaching analysis.

Waylo is designed not to record or permanently store raw in-car audio for this feature.

Recognised text may be transmitted securely to Waylo's backend and AI-processing providers to generate coaching observations.

Raw recognised text is intended to be temporary and not retained as a permanent transcript after processing.

Derived observations, coaching themes and summaries may be retained as part of a drive record.

Conversation Feedback is not available in Waylo Solo.

Website and technical information

We may collect:

• Device and browser information.

• IP address.

• App version and operating-system details.

• Crash reports and diagnostics.

• Security and performance information.

• Cookie or similar technology information.

• Website analytics where permitted by applicable law.

Subscription information

Where subscriptions are purchased through Apple, Google or another authorised platform, we may receive information needed to verify subscription status and entitlements.

We do not receive full payment-card details where payment is processed by the relevant app store.

2. How we collect information

We may collect information:

• Directly from users.

• From an authorised parent, guardian or supervising driver.

• Automatically from a device during use of Waylo.

• From app stores and authentication providers.

• From mapping, routing, weather and traffic providers.

• From analytics and diagnostic services where enabled.

• From service providers acting on our behalf.

Where information about a learner is provided by another person, that person must have appropriate authority to provide it.

Professional driving instructors do not have independent Waylo accounts.

Where Waylo is used during a professional lesson, the learner uses their own account.

3. Why we use personal information

We use personal information to:

• Create and manage user accounts.

• Connect learners with authorised supervisors.

• Record and analyse driving experiences.

• Display driving history and experience information.

• Identify gaps in driving experience.

• Generate suggested routes and practice opportunities.

• Apply jurisdiction-specific driving-experience safeguards.

• Provide optional Conversation Feedback.

• Generate post-drive summaries and observations.

• Support Waylo Solo.

• Manage subscriptions and entitlements.

• Provide customer support.

• Prevent misuse, fraud and security incidents.

• Diagnose faults and improve reliability.

• Understand service usage and improve the product.

• Comply with legal obligations.

• 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 an appropriate lawful basis.

Depending on the processing activity, those bases may include:

• Contract: Where processing is necessary to provide Waylo to the account holder.

• Legitimate interests: For proportionate service improvement, security, fraud prevention, reliability and support, where those interests are not overridden by individual rights.

• Consent: Where consent is required for optional features, analytics or processing involving young people.

• Legal obligation: Where processing is necessary to comply with applicable law.

• Vital interests: In exceptional circumstances where processing is necessary to protect someone's life or physical safety.

Where we rely on consent, it may be withdrawn, subject to applicable law.

Withdrawal of consent does not make earlier lawful processing unlawful.

5. Precise location and driving information

Precise location is central to Waylo's ability to record driving experiences and understand the roads, conditions, traffic environments and situations encountered.

Waylo aims to collect precise location information only while needed for an active drive and related processing.

Location tracking should be indicated through the app or operating-system permissions and indicators when active.

Users can manage device location permissions through their phone settings. Disabling necessary permissions may prevent some Waylo features from functioning.

Waylo does not make a learner's real-time precise location publicly available to other users.

Location data may be used to generate driving-experience summaries, classifications and suggested future driving opportunities.

Waylo does not use location information to determine or certify driving competence.

6. Young people, learners and supervisors

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

Where a learner cannot legally enter a binding contract or provide the necessary consent independently, an appropriate parent, guardian or legally responsible adult must authorise or manage their use of Waylo as required by applicable law.

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

Where information about a child under 13 is processed, appropriate parental or guardian authority is required unless another lawful basis applies.

For teenagers able to exercise certain privacy choices under applicable law, we aim to provide understandable information and appropriate controls.

Learner and supervisor connections

Learners may be connected with authorised supervising drivers through Waylo.

While a learner is using the supervised-learning experience, authorised supervisors may be able to access relevant information, including:

• Driving-experience history.

• Recorded driving environments and situations.

• Experience summaries and observations.

• Suggested areas for additional practice.

Access is limited to information made available through the relevant authorised connection and applicable product permissions.

Professional driving instructors

Professional driving instructors do not have independent Waylo accounts.

They do not receive separate access to learner profiles, driving history or account information.

During a professional driving lesson, the learner uses their own Waylo account.

An instructor may see information voluntarily displayed by the learner, but does not receive independent access to Waylo data.

Transition to Waylo Solo

When a learner passes their driving test, they may choose to continue using Waylo through Waylo Solo.

On transition to Solo:

• The driver may retain their existing driving-experience history.

• Future Solo drives are not automatically shared with former supervisors.

• Former supervisors do not receive notifications or updates about new Solo drives.

• Previous supervised-driving information may remain available where permitted by the existing account relationship and product settings.

• Conversation Feedback is not available in Solo.

• Solo driving information is used to support the driver's own experience record, observations and suggested driving opportunities.

Waylo Solo is designed to respect a newly licensed driver's increasing independence and privacy.

7. Conversation Feedback privacy

Conversation Feedback is optional and intended to support reflection and learning during supervised driving.

It should only be enabled with the knowledge of the people whose conversations may be processed, and with any consent required by applicable law.

When enabled:

• The app should indicate that Conversation Feedback is active.

• Speech recognition may derive text from relevant in-car conversation.

• Waylo is designed not to retain raw audio recordings.

• Recognised text may be transmitted to Waylo's backend and an AI-processing provider.

• Raw recognised text is intended to be deleted after relevant processing rather than retained as a permanent transcript.

• Derived coaching observations and themes may be retained with the relevant drive.

Conversation Feedback can be disabled, and relevant device permissions may also be managed through operating-system settings.

Conversation Feedback does not provide professional driving instruction, assess driving competence or make safety-critical decisions.

Conversation Feedback is not available during Waylo Solo drives.

8. AI and automated processing

Waylo uses automated systems and artificial intelligence to support its experience-led learning approach.

These systems may:

• Classify driving experiences.

• Identify gaps in exposure to different driving environments.

• Suggest routes and practice opportunities.

• Generate post-drive observations and summaries.

• Provide optional coaching insights during supervised learning.

AI-generated information may be incomplete, inaccurate or incorrect.

Waylo does not use automated processing to certify driver competence or determine whether someone is safe or legally qualified to drive.

We do not intend to use automated processing to make decisions producing legal or similarly significant effects concerning licensing, insurance eligibility, employment or access to public services.

Where applicable law provides rights concerning automated decision-making, users may contact us using the details below.

9. Analytics, cookies and similar technologies

The Waylo website may use necessary cookies or similar technologies to support core website functions.

Analytics technologies are used only where permitted by applicable law and, where required, following user consent.

Where optional analytics are declined, the core website should remain available.

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

10. Who we disclose information to

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

• Cloud hosting and databases.

• Authentication services.

• Mapping and routing systems.

• Weather and traffic information.

• Artificial intelligence processing.

• Subscription and entitlement validation.

• Communications services.

• Analytics and diagnostics.

• Security, fraud prevention and technical support.

• Professional legal, accounting and insurance services where reasonably necessary.

We may also disclose information where required by law, where permitted to address a serious threat, to investigate fraud or security incidents, or as part of a lawful corporate transaction subject to appropriate safeguards.

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

Professional driving instructors do not receive independent access to learner information through Waylo accounts.

Former supervisors do not automatically receive new Solo drive information.

11. International processing and transfers

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

Personal information may therefore be processed outside the country in which a user is located.

Where applicable law requires safeguards for international transfers, we will use appropriate contractual, legal or other recognised protections.

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

Where UK or EEA data-protection laws apply, we will use appropriate transfer mechanisms where legally required.

12. Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy.

These purposes may include:

• Providing Waylo.

• Maintaining user-requested driving history.

• Managing subscriptions and accounts.

• Meeting legal and accounting obligations.

• Resolving disputes.

• Preventing fraud or security incidents.

• Enforcing agreements and protecting legal rights.

Retention periods may vary depending on the type of information.

When an account is deleted, we will delete or de-identify personal information within a reasonable period unless continued retention is required or permitted for legitimate legal, security or other lawful purposes.

Raw recognised conversation text is intended to be transient and not permanently retained after the relevant processing.

Derived coaching observations may be retained as part of driving history.

Secure backups may require additional time to expire or be removed.

13. Account deletion

Users may initiate account deletion through the Waylo app where that feature is available.

Deleting an account does not automatically cancel a subscription purchased through an app store.

Subscriptions must be cancelled through the relevant store account.

If you cannot access the account-deletion function, contact:

Australia: hello@waylo.com.au
New Zealand: hello@waylo.co.nz

14. Security

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

No internet-connected service can guarantee absolute security.

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

15. Your privacy rights

Your rights depend on your location and the laws that apply.

They may include rights to:

• Access personal information held about you.

• Correct inaccurate personal information.

• Request deletion.

• Restrict or object to certain processing.

• Withdraw consent.

• Receive information in a portable format where applicable.

• Lodge a complaint with a privacy regulator.

• Receive information about certain automated processing.

To exercise your privacy rights, contact:

Australia: hello@waylo.com.au
New Zealand: hello@waylo.co.nz

We may need to verify your identity before completing a request.

We will not discriminate against users for exercising privacy rights where prohibited by law.

16. Privacy complaints

If you have a privacy concern, please contact us first so we can investigate and respond.

Australia: hello@waylo.com.au
New Zealand: hello@waylo.co.nz

You may also have the right to complain to the relevant privacy regulator.

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

For New Zealand matters, this may include the Office of the Privacy Commissioner.

17. UK and EEA representatives

Waylo is operated from Australia.

Where applicable UK or European data-protection laws require Waylo Pty Ltd to appoint a local representative, we will arrange the required appointment and publish the representative's contact details before providing the relevant service where legally required.

18. Changes to this Privacy Policy

We may update this Privacy Policy as Waylo, our service providers, business operations or applicable laws change.

Where a change materially affects how personal information is handled, we will take reasonable steps to notify users or obtain consent where required.

The current Privacy Policy will be published on the Waylo website with its effective date.

19. Contact

Waylo Pty Ltd
ABN 57 703 695 265
ACN 703 695 265

Unit 68, 42–46 Wattle Road
Brookvale NSW 2100
Australia

Australia: hello@waylo.com.au
New Zealand: hello@waylo.co.nz

Waylo is operated by Waylo Pty Ltd under an exclusive intellectual property licence from Waylo Holdings Pty Ltd (ABN 13 703 695 078).