Privacy Policy

WAULD PRIVACY POLICY

Wauld LLC (“Wauld” or “We” or “Us”) is committed to data security and the fair and transparent processing of personal data. We provide a content management and content generation platform. Wauld’s platform assists people in making documents and credentials for events, courses and activities. This Privacy Policy also describes your choices regarding use, access and correction of your personal information. “You” or “Your” refers to the person or organization using the Service. The “Service” is the digital credentialing and certification functionality, associated insights and connection to relevant education and training opportunities provided through the platform offered by Wauld. This Privacy Policy is subject to the Data Processing Agreement [please incorporate link here] and Terms [please incorporate link here] (“Terms” or “ToS”). Any term not defined herein shall be interpreted as per the definition provided in the Terms of Use  and Data Processing Agreement (“DPA”)

1. SCOPE

Unless specified otherwise, this Privacy Policy applies to your personal information processed by Wauld as a data controller on or via the Website or App. When the platform is provided by us and links to this Privacy Policy, this Privacy Policy applies. When these offerings are provided by third parties, the Privacy Policy of the third party applies, and this Privacy Policy is not applicable in such cases unless otherwise expressly stated.

If you use the Services for your business that has a separate Service Agreement or other governing agreement with Wauld, the terms of that agreement will supersede the Privacy Policy herein. All capitalized terms not explained herein shall be interpreted as per the ToS.  

“Affiliates”, Wauld’s attorneys, auditors, consultants, and service providers who are under confidentiality obligations at least as restrictive as those contained herein. This Policy, together with Wauld’s Terms of Use and any other documents referred to in them, sets out the basis on which processes Personal Data. 

“Personal Data” includes the data we collect directly from Issuers and Recipients in some cases. This Privacy Policy sets out how we will treat the Personal Data which you provide to us in compliance with Applicable Data Protection Laws. We will not share your Personal Data except on a need-to-know basis with third party under common ownership or control with Wauld 

“Website Analytics” includes but is not limited to user analytics, website usage times, sessions and bounce rates. 

Any definitions not mentioned herein shall be interpreted according to the Terms of Use. 

PLEASE READ THIS POLICY CAREFULLY AS IT CONTAINS IMPORTANT INFORMATION ON WHO WAULD ID, HOW AND WHY WAULD COLLECTS, STORES, USES AND SHARES PERSONAL DATA, YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA AND HOW TO CONTACT US IN THE EVENT THAT YOU WOULD LIKE TO REPORT A CONCERN ABOUT THE WAY IN WHICH WAULD PROCESSES YOUR DATA.

This Privacy Policy describes Wauld’s broadest potential use of your Personal Data, although Wauld may actually make less use. The basis for Wauld’s processing of your Personal Data is your informed consent. No law requires you to provide us with your Personal Data. You may withdraw your consent for us to process your Personal Data at any time, but that may preclude you thereafter from using the Website and the Service. Wauld will delete your Personal Data following the withdrawal of your consent, however, such withdrawal will not affect the lawfulness of processing prior to withdrawal. Wauld collects Personal Data when you choose to submit it through e-mail, an online form or any other mode. Wauld also maintains a log of certain information concerning visitors to Wauld’s websites, including but not limited to, internet protocol (“IP”) address (a computer's numerical Internet address), third party websites from which visitors access Wauld’s website, type of web browsers used, and pages viewed. Such information may include Personal Data and website analytics. By using this website, you give Wauld consent to collect and process your Personal Data and website usage data which includes Website Analytics,.

By your use of the Service, you consent to Wauld’s use and disclosure of your Personal Data in accordance with this Privacy Policy.

2. ABOUT US

Wauld is a digital credentialing platform that enables organizations (“Issuers”) to create, issue, and manage digital certificates, badges, and other forms of documentation for individuals or organizations (“Recipients”). Recipients can access, store, and share these credentials, including with third parties (“Verifiers”) who do not have Wauld accounts. Issuers are Wauld’s direct customers, while Recipients are the users who receive credentials created by the Issuers. The Issuer is solely responsible for the verification and accuracy of any content they create. The Recipient acknowledges that Wauld acts merely as a platform and intermediary. In the event of any complaints or issues regarding the content, the Recipient may reach out to Wauld using the contact information provided in Section 5.

Wauld may share your information with trusted affiliates (both within and outside the United States), which includes sharing Recipient Analytics Information with the Issuer. By using Wauld’s website and Services, you consent to such data transfers and sharing with Wauld’s affiliates for the purpose of enhancing Wauld’s Services. For the purposes of the GDPR and other applicable data privacy laws, Wauld is considered the ‘processor’ of the personal data provided by Issuers, who are the “controllers.”

3. WHAT PERSONAL DATA DO WAULD COLLECT?

Wauld may collect and process the following personal data:

3.1 INFORMATION YOU PROVIDE TO US- 

To register for or use the Service, you will be prompted to give us certain required information about yourself, such as your name and email address. When you configure your account settings, you may enter additional, optional information about yourself. You may, at times, also send us an e-mail which may contain not only your e-mail address, but other information about you, including home or business addresses, telephone numbers, or account details. The information you give us may also include statements you make on the Service such as testimonials, services reviews, or other statements that may identify you personally. 

An Issuer may directly create an account on the Service by providing the requested information    mjwhich may include your name, email address, phone number, company, among other information. Please note, Wauld will never ask for your (whether you are an Issuer or Recipient) Social Security Number, bank account passwords, credit card numbers or any other financial information. If you have been requested to provide such information, please refer to the How to Contact Our Data Protection Officer section below to get in touch with us.. 

Wauld may use your Personal Data to contact you regarding your use of the Service, for customer support purposes, and to inform you of updates, modifications and other matters relating to the Service, and information about other services that Wauld offers in accordance with your subscription preferences. You may decline to receive mail or e-mail from us that does not relate directly to your access to or use of the Service by selecting the opt-out link contained in any such e-mail or by contacting us through the information provided in the How to Contact Our Data Protection Officer section.

3.2 INFORMATION WAULD COLLECTS ABOUT YOU

Wauld also will maintain a history of your access to the Service, and certain actions taken by you while accessing the Service, a log of users' IP addresses, the third-party Website from which users access the Service, the type of web browsers used to access the Service and the browser's settings that may affect Service performance (collectively, “Usage Log Information”) explicitly when recipients share credential links. 

3.3 INFORMATION WAULD RECEIVES FROM ISSUERS AND RECIPIENTS 

Issuers, when creating their account and using the Services, provides Personal Information to us, including name, email, organization name, logo, billing details, verification documents (domain verification or similar), and authorized users' contact information. The use of information collected from Issuers shall be limited to the purpose of providing the service for which these Organizations have engaged Wauld. Wauld collects information about Recipients directly from the Issuer regarding their name and email. A Recipient who creates an account on Wauld provides his name and email to Wauld directly.  

An individual who seeks access, or who seeks to correct or amend inaccurate Credentials should direct their query to the Issuer. Wauld retains Personal Information that Wauld processes on behalf of the Issuers for as long as needed to provide services to the Issuers and the Users and in compliance with all applicable personal information retention laws. Individual Credentials and a User’s entire account may be deleted by the User at any time by contacting us using the information provided under the How to Contact Our Data Protection Officer section. There is no default automatic purge policy. Wauld verifies deletion requests, and if deletion may affect system consistency, the data is pseudonymized. 

3.4 NON-PERSONAL INFORMATION

Wauld may statistically aggregate in non-person-specific form information collected to improve Wauld’s websites, their quality controls, operations management, security processes, future marketing and promotional efforts, and the overall Service in an attempt to better understand their user’s interests and preferences. In some cases, Wauld may transfer this information to their third-party service providers who will have access to only the required data for delivery of their service. By using this Services, you consent to this non-personally identifiable data aggregation and the use and transmission of this aggregated statistical data as outlined above.

4. HOW DOES WAULD USE YOUR DATA (PERSONAL & OTHERWISE)?

In addition to the uses described above of the information received in connection with your use of the Service, Wauld uses and, where specified, shares your information:

• To display Credentials to users. 

• To provide support or other services that you have requested, and to respond to your inquiries.

• To engage in transactions with you, including contacting you about your account or transactions.

• To notify you of relevant opportunities such as new product releases and service developments, related facts or programming that may be relevant to you.

• To improve quality and facilitate use of the Service.

• To operate the Service through the assistance of third parties. Wauld may use services from third-party service providers, such as hosting services, software developers, etc. in support of its operation of the Service. When doing so, Wauld will take steps to ensure that such service providers implement appropriate privacy and security measures consistent with this Privacy Policy to safeguard against the unauthorized use or disclosure of your information. These companies are authorized to use your personal information only as necessary to provide these services to us.

• To comply with legal requirements. In addition, Wauld may also disclose information about you as required by law, such as to comply with a subpoena or other legal process, when Wauld believes in good faith that disclosure is reasonably necessary to enforce their rights or protect their operations or users or others investigate fraud, or in response to legal processes or governmental investigations in accordance with their internal policy on access by governmental authorities, or under exigent circumstances in response to a perceived significant threat to a person's health or property.

• To assist in verification or other processes ancillary to the Services. 

• We engage third-party service providers or Subprocessors (as defined in the DPA) to help us operate and support our services. These Subprocessors may process personal data on our behalf, consistent with the purposes described in this Privacy Policy. A current list of subprocessors is available in our [Data Processing Addendum].

• We are committed to transparency regarding how and why we process your Personal Data.   The table below outlines the lawful bases for processing, in accordance with the General Data Protection Regulation (GDPR) and other applicable data protection laws.
  
  While the specific purposes for processing are explained throughout this Privacy Policy, the table below provides a consolidated view of the primary categories of data we collect and the lawful bases we rely upon.

This table is provided for transparency and ease of reference only. It does not restrict Wauld’s ability to rely on other lawful bases where permitted under applicable law.

• Data Sharing for Analytics and Advertising (Post Sign-Up)

  • Wauld uses self-hosted, first-party analytics via PostHog to understand platform usage and improve user experience. These analytics are anonymized and do not involve third-party tracking by default.

  • When you create an account or while using the Service, you may provide consent for us to use your data for additional purposes, including:

    • Enhanced product analytics

    • Engagement tracking across sessions and devices

    • Custom audience creation for advertising

    • Delivery of targeted advertising via third-party platforms (e.g., Google Ads, Meta Ads)

You can manage your data-sharing preferences at any time via your account settings or by contacting our Data Protection Officer. 

• Credential Engagement Analytics

  • We may collect and use analytics data such as views, downloads, shares, and engagement metrics associated with credentials issued through Wauld. This information helps credential issuers understand how their credentials are being accessed, used, and distributed.

  • These engagement metrics are visible only to the issuing organization and are not shared with unrelated third parties.

5. HOW WAULD OBTAINS CONSENT

1. Wauld is dedicated to safeguarding your privacy and ensuring that your personal information is collected, used, and disclosed in accordance with applicable laws and regulations. If you are the parent or guardian of a child under the age of 13, Wauld requires verifiable parental consent before collecting any personal information from your child, in compliance with the Children’s Online Privacy Protection Act (COPPA) and other relevant legislation.

2. Direct Notice: Before collecting personal information from your child, Wauld will provide you with a direct notice that explains:

   1. The types of personal information Wauld intends to collect

   2. How Wauld will use this information.

   3. Wauld’s rights regarding your child's personal information

3. Consent Methods: Wauld may obtain your consent through one of the following methods:

1. Website Check-Box: Upon checking the consent box on Wauld’s website located at [PLEASE ATTACH LINK], you are agreeing to this Privacy Policy, the Terms of Use and Data Processing Agreement. 

2. Email Confirmation: Wauld may send you an email requesting your consent. You must reply to this email to confirm your consent.

3. Print-and-Send: You may receive a consent form that you can print, sign, and return to us via mail or fax.

4. Phone Verification: You may call from Wauld’s designated toll-free number to provide consent verbally.

5. Online Payment: If applicable, Wauld may obtain consent during a monetary transaction, ensuring that the transaction is linked to the parent or guardian.

4. Revoking Consent: You have the right to revoke your consent at any time. To do so, please contact us using the information provided below. Upon receiving your request, Wauld will take appropriate steps to delete your child's personal information from Wauld’s records.

5. Contact Information

If you have any questions about Wauld’s consent mechanism or wish to revoke your consent, please contact us using the information under the How To Contact Our Data Protection Officer (DPO) section.

6. PRIVACY OF YOUR DATA

Wauld only collects name, email, organization name, logo, billing details, verification documents (domain verification or similar), and authorized users' contact information from Issuers. In the instance of Recipients, name and email are supplied by the Issuer. Issuers can create custom fields (e.g., certificate ID, grades). This data is provided to Wauld via CSV uploads, API, or manual entry. The verification and validity of any data provided by the Recipient or Issuer is the responsibility of the Issuer.

Wauld uses select third-party services under appropriate contractual terms to support platform functionality which includes Hosting & infrastructure, Email delivery, Monitoring, analytics, and customer experience tools. These providers are used solely for their intended technical purpose and do not access data beyond what is required for delivery of their service. A current list of our subprocessors, including their functions and locations, is available at <link>. We will notify Issuers of any intended changes to this list in accordance with our Data Processing Agreement.

6. SECURITY OF YOUR DATA 

Wauld takes appropriate and reasonable precautions to implement appropriate administrative and technical procedures to protect the security of Personal Information provided or generated through the Service. Wauld permits persons working for and with us to access and use your information only in a manner consistent with this Privacy Policy and they do not access data beyond what is required for delivery and improvement of the service. Third parties are used solely for their intended technical purpose.

Wauld protects the security of your information by using Zero Trust security principles, including role-based access control and regular access audits. Wauld also uses encryption technology, which encrypts information you input. Wherever appropriate, Wauld pseudonymizes and/or encrypt information in Wauld’s systems and/or during information transfer or at rest. Wauld regularly reviews the cryptographic protocols it uses to protect the privacy and security of your Personal Information.

The Administrative actions (e.g., voiding credentials, editing fields) are logged and visible to both internal staff (when needed) and Issuers for auditability. Moreover, a formal incident response plan exists and is followed in the event of a data breach.

While Wauld strives to protect your Personal Information, please be aware that online security can be compromised. To safeguard your data, Wauld recommends the following precautions:

• Change your passwords regularly.

• Use a mix of letters, numbers, and symbols in your passwords.

• Utilize a secure browser.

• Always log off when using a shared computer.

Wauld employs industry-standard security measures to protect Your personal data upon receipt, though it cannot fully guarantee its security. Please be aware that any data transmitted is done with an understanding of potential risks. Once Wauld receives your Data, it will apply industry-standard procedures and security measures to help safeguard it from unauthorized access. To the fullest extent permitted by law, Wauld disclaims liability for unauthorized access resulting from circumstances beyond our reasonable control.

In the event of a personal data breach, Wauld will notify affected Issuers without undue delay and, where feasible, within 72 hours of becoming aware of the breach, providing information available at that time regarding the nature of the breach, categories of data affected, and measures taken to mitigate its effects. Where Wauld acts as a Processor, Issuers are responsible for communicating with affected data subjects and regulators, and Wauld will provide reasonable assistance to Issuers to enable them to meet their legal obligations.

7. ACCESS, RETENTION AND DELETION 

Wauld undertakes to store the Data on Google Cloud Platform within the United States for the off-the-shelf solution. Storage includes both structured databases and object storage (e.g., PDFs).  If an Issuer's account is terminated, the credentials they’ve issued remain on the platform (unless revoked) as they are considered independent, persistent digital records. Wauld may retain your Personal Information for as long as your account is active and so long as retention is required or permitted in accordance with this Privacy Policy, or otherwise by law.  You may access, correct, or request deletion of your personal information by logging into your account or please refer to the How to Contact Our Data Protection Officer section.

1. The Data available with Wauld is retained until explicitly deleted by Issuers or Recipients. There is no default automatic purge policy. For the deletion of your data, you need to request deletion of your personal information by logging into your account or please refer to the How to Contact Our Data Protection Officer section. Upon request Wauld verifies deletion requests and post successful verification, deletes the data, and if deletion may affect system consistency, the data is pseudonymized. Deleted data may remain in backups for a defined retention period i.e. X days as per Wauld’s internal data retention policy.
   
   
   

2.  Change Requests and Account Creation:

   1. For Recipients with an existing account, they may submit change requests through their account. A verification code will be sent to the Recipient by Wauld when a change request is submitted. Upon correctly entering the verification code, the Recipient may submit the change request, which will subsequently update their account.

   2. For Recipients without an existing account, they may submit change requests. An account will be created for the Recipient by Wauld and, subsequently a verification code will be sent to the Recipient. Upon correctly entering the verification code, the Recipient may submit the change request, which will subsequently update their account.

8. COOKIES AND TRACKING TECHNOLOGIES

We utilize a limited number of cookies and similar technologies to enhance your experience on the Site. These are strictly first-party cookies and we may seek your consent to utilize additional cookies or pixels for the purpose of personalized advertising. Any such tracking will only commence following your explicit opt-in.

Our cookies serve the following purposes:

1. To understand user interactions with our platform

2. To enhance product functionality and performance

3. To monitor progress during onboarding and feature utilization

We do not utilize third-party cookies, nor do we permit external advertisers to track our users unless we .

You retain the ability to manage or delete cookies at any time through your browser settings. Please be aware that disabling cookies may impact the performance and usability of certain features.

Should you have any inquiries regarding our cookie practices, please do not hesitate to contact us via the 'How to Contact Our Data Protection Officer' section provided below.

9. THIRD-PARTY SITES

Wauld works with authorized resellers and other Affiliates who assist in sales, data processing, internal management, human resources, onboarding, and customer relationships. Depending on the agreement in place with the end customer, a reseller may or may not host the platform independently or access end-user data. Wauld always enters into a formal reseller agreement in such cases, which clearly defines roles, data responsibilities, and access permissions.

10. CONFIDENTIALITY OF DATA

Wauld will use industry standard physical, technical, and administrative security measures to keep your Personal Data confidential and secure, and will not share it with third parties, except as otherwise provided in this Privacy Notice, or unless such disclosure is necessary in special cases, such as a physical threat to you or others, as permitted by applicable law. 

11. YOUR RIGHTS

You have certain rights in relation to your Personal Data. You can access your Personal Data and confirm that it remains correct and up-to-date, choose whether or not you wish to receive material from Wauld or some of Wauld’s partners, and request that Wauld delete or provide you with a copy of your Personal Data by logging into the Site.

Where Wauld acts as a Controller (for example, when you create an account directly with Wauld), you may exercise your data subject rights directly with us.

Where Wauld acts as a Processor (for example, when your credential is issued by an organization using Wauld), your data subject rights should be directed to the issuing organization, and Wauld will assist them in fulfilling such requests.

Wauld also believes that all data subjects have the following rights:

• provide access to any Personal Data Wauld holds about you; 

• update any Personal Data which is out of date or incorrect;

• delete any Personal Data which Wauld is holding about you;

• restrict the way that Wauld processes your Personal Data; or

• provide you with a copy of any Personal Data which Wauld holds about you.

• Right to Object (GDPR Article 21): You may object at any time to Wauld’s processing of your personal data where such processing is based on our legitimate interests, or where your data is processed for direct marketing purposes.

• Right not to be subject to Automated Decision-Making (GDPR Article 22): Wauld does not engage in automated decision-making or profiling that produces legal or similarly significant effects on you. If this changes in the future, we will notify you and provide you with the rights available under applicable law.

Wauld will try to answer every request promptly where possible, and provide a response within a reasonable time period, however, when deleting your Personal Data there may be residual information that will remain within Wauld’s databases, access logs, and other records, which may or may not contain your Personal Data. Please also note that certain Personal Data may be exempt from such requests in certain circumstances, which may include if Wauld needs to retain your Personal Data to comply with a legal obligation. 

Wauld does not permit its Users to share their sensitive data. If any sensitive data (including financial data, healthcare data, social security numbers, etc.) is sent to Wauld by you, you shall ensure that Wauld is properly notified as per the terms of this Privacy Policy and you consent to the return and destruction of such Sensitive Data. If you plan to use the Services for managing, producing, or utilizing content that involves Sensitive Data (“Sensitive Data Services”), you must submit a prior written request to the Company. Upon receiving your email request, the Company may request additional information to verify your identity. You may only proceed with the Sensitive Data Services after receiving approval from the Company. Issuers are solely responsible for ensuring they have lawful authority to upload or disclose any sensitive personal information (including but not limited to health data, government IDs, or financial account data). If sensitive personal information is uploaded without Wauld’s prior written approval, Wauld may delete or anonymize such data without notice and shall not be liable for any resulting loss, regulatory consequence, or claim. Wauld will notify the Issuer promptly upon discovery of such unauthorized data but accepts no responsibility for the legality, accuracy, or handling of such data.

To exercise these rights, or if you have an unresolved privacy or data use concern that Wauld has not addressed satisfactorily, please refer to the How to Contact Our Data Protection Officer section below.please contact the following information:

11.1  Rights of California Residents (CCPA/CPRA)

If you are a resident of California, you have specific rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA). These rights include the following:

1. Right to Know
   You have the right to request that we disclose the following information about your personal information collected over the past 12 months:

• The categories of personal information we have collected

• The sources from which the personal information was collected

• The purposes for which the personal information was collected

• The categories of third parties with whom we share personal information

• The specific pieces of personal information we have collected about you

2. Right to Delete
   You may request that we delete the personal information we have collected from you, subject to certain legal or operational exceptions (such as complying with our legal obligations or completing a transaction you requested).
   
   
   

3. Right to Correct
   You may request that we correct inaccurate personal information we maintain about you.
   
   
   

4. Right to Opt Out of Sale or Sharing
   Wauld may share limited personal information, such as email addresses or behavioral data, with advertising platforms to help us reach new users through targeted ads. This type of sharing qualifies as “cross-context behavioral advertising” under the California Privacy Rights Act (CPRA). You have the right to opt out of this sharing at any time. To exercise this right, please visit our [Do Not Share My Info] page or contact our Data Protection Officer. We never sell data for monetary compensation.
   
   
   

5. Right to Limit Use of Sensitive Personal Information
   Wauld may collect or process limited categories of sensitive personal information (such as government ID numbers, precise geolocation, health data, or financial account credentials) where necessary to operate our platform and fulfill requested services. In certain cases, we may also process such information for additional purposes, for example, to enhance security, prevent fraud, improve our services, or deliver advertising and marketing that may be relevant to you.

6. Under applicable privacy laws (including the California Privacy Rights Act), you have the right to direct Wauld to limit its use and disclosure of sensitive personal information to only those purposes that are strictly necessary to provide the Services.

7. You may exercise this right at any time by contacting our Data Protection Officer or, where available, by adjusting your privacy preferences in your account settings. Once you exercise this right, Wauld will restrict its use of your sensitive personal information accordingly.

8. Right to Use an Authorized Agent
   You may designate an authorized agent to submit requests on your behalf. We may require verification of both your identity and the agent’s authority before fulfilling the request.
   
   
   

9. Non-Discrimination
   We will not discriminate against you for exercising any of your rights under the CCPA/CPRA. This includes denying services, charging different prices, or altering service levels.
   
   
   

How to Exercise These Rights

To exercise any of the rights described above, please contact us using the information provided under How To Contact Our Data Protection Officer section.

11.2  Rights of Utah Residents (UCPA)

If you are a resident of Utah, you have rights under the Utah Consumer Privacy Act (UCPA). These rights apply to personal data that we collect through your interaction with Wauld.

As a Utah resident, you may:

1. Right to Access
   Request confirmation of whether we are processing your personal data and obtain access to the categories and specific pieces of personal data collected.
   
   
   

2. Right to Delete
   Request the deletion of personal data you have provided to us, subject to legal and operational exceptions.

3. Right to Obtain a Copy
   Request a copy of your personal data that you have previously provided to us, in a portable and readily usable format.
   
   
   

4. Right to Opt Out

   1. Wauld may use personal information to deliver targeted advertising, including sharing data with platforms such as Google or Meta to help us reach similar audiences. This may include identifiers like email addresses or device data.

   2. You may opt out of targeted advertising at any time by adjusting your privacy settings or contacting us.
      
      
      

   3. You have the right to opt out of the processing of your personal data for:

• Targeted advertising

• The sale of personal data

• Certain automated decision-making (where applicable)

How to Exercise These Rights

To exercise any of the rights described above, please contact us using the information provided under How To Contact Our Data Protection Officer section.

Other U.S. States: Residents of Virginia, Colorado, Connecticut, and other states with comprehensive privacy laws may have rights similar to those described above, including rights to access, delete, correct, and opt-out of certain processing. To exercise such rights, please contact us as described in the How to Contact Our Data Protection Officer section.

11.3  Rights Related to Education Records (FERPA)

Wauld may be used by educational institutions to issue credentials or process student-related information. In such cases, Wauld acts solely as a service provider or “school official” under the Family Educational Rights and Privacy Act (FERPA), and we process education records only on behalf of and under the direction of the educational institution.

We do not independently access, use, disclose, or sell student data. All student information remains under the control of the institution that uploads or issues credentials through Wauld. Our role is limited to providing the infrastructure to store, manage, and deliver credentials in accordance with applicable educational policies and agreements.

Requests to access, correct, or delete education records should be directed to the issuing institution. We will assist the institution in responding to such requests as required by FERPA.

11.4  Children’s Data Privacy (COPPA)

Wauld is not intended for use by children under the age of 13, and we do not knowingly collect personal information directly from children under 13 years of age. 

We do not allow account creation by minors and do not target our services toward them.  However, our platform may be used by authorized institutions or organizations (such as schools, nonprofits, or training programs) to issue credentials that may include information about minors under 13, including but not limited to names, email addresses, or photos. 

In such cases, Wauld acts as a data processor or service provider, and the responsibility to obtain any required parental or guardian consent under the Children’s Online Privacy Protection Act (COPPA) lies with the issuing organization.  

If you believe that Wauld has collected personal information about a child under 13 without appropriate authorization, please contact us using the information under the How To Contact Our Data Protection Officer (DPO) section. Upon confirmation, we will promptly delete the information in question.

110.5 Utah Online Privacy Protection Act (UOPPA)

In accordance with the Utah Online Privacy Protection Act (UOPPA), Wauld provides clear and transparent information regarding the personal data we collect, how we use it, and your rights related to that data.

Utah residents may contact us using the information under the How To Contact Our Data Protection Officer (DPO) section to:

- Request access to the personal data we hold about you

- Request corrections or updates to your information

- Request deletion of your account and associated data

We do not share your personal information with third parties except as described in this Privacy Policy, and we update this policy periodically to reflect any material changes.

12.  International Data Transfers

Wauld’s parent organization and a significant portion of our development and support team are based in India. As a result, personal data may be accessed, processed, or stored by team members located outside your country of residence, including in India.

If you are located in the European Economic Area (EEA), United Kingdom, or other jurisdictions with data transfer restrictions, we ensure that such transfers are governed by appropriate safeguards, including the Standard Contractual Clauses (SCCs) approved by the European Commission or equivalent contractual protections under applicable law.

For more information, or to request a copy of these safeguards, please contact us using the information under the How To Contact Our Data Protection Officer (DPO) section.

13. POLICY UPDATES

Wauls may update this Privacy Policy from time to time, and the updated version will be effective upon posting as to Wauld’s treatment of subsequently acquired Personal Information. If Wauld makes any material changes, Wauld will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective. Please check the revision date at the beginning of this Privacy Policy periodically to check for revisions. By continuing to use the Service, including the Website, after a revised version has been posted, you agree to be bound by the revised Privacy Policy as to subsequently acquired Personal Data.

14. MISCELLANEOUS 

1.  Third Party Websites/ Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to the Services (“Third-Party Websites”). The Third-Party Websites are not controlled by us. Providing personal information to third-party websites or applications is at your own risk. Wauld encourages their users to read the privacy policies of each website and application with which they interact. Wauld does not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. 

2. Governing Law. By using the Service or by otherwise providing information to us, you agree that any dispute over the privacy or the terms contained in this Privacy Policy will be governed in accordance with the Terms of Use located at [link for Terms of Use]

3. Supervisory Authority. If you are located in Switzerland, European Economic Area, Brazil, you have the right to lodge a complaint with a supervisory authority if you believe the processing of your personal information violates applicable law.

15. HOW TO CONTACT OUR DATA PROTECTION OFFICER (DPO)

If you have any questions, concerns, or requests regarding your personal data or this Privacy Policy, you may contact our Data Protection Officer using the details below:

Data Protection Officer
Gaurav Charokar
Email: dpo@wauld.com
Mailing Address:
Wauld LLC
1021 E Lincolnway Suite #8406, Cheyenne, Wyoming 82001, United States

You may also use this contact to exercise your data protection rights under applicable laws, including GDPR, CCPA/CPRA, UCPA, UOPPA, COPPA, and FERPA.