Walaw - Privacy Policy
Last Updated: September 15, 2025
9539-4268 Québec inc., doing business as Walaw, a Québec corporation (“Walaw”, “we”, “us”, and “our”) provides AI agent infrastructures designed, among other things, to manage and facilitate communications between you and Users (as defined below) and other related products or services (collectively, the “Service”). We take your privacy and the protection of your Personal Information (as defined below) seriously. This Privacy Policy (the “Policy”) describes our privacy practices, the types of Personal Information we may receive or collect from you and how we use, disclose, store and secure it, so that you can make informed choices with respect to the Personal Information you provide us with.
This Policy applies to the Service, our online platform accessible for our customers (the “Customers”, and each a “Customer”) to review, customize and manage the performance of the Service and the use of any other service or product available on the platform (the “Platform”) as well as to our processing of your Personal Information whether such processing is taking place on our website (the “Site”), when you communicate with us on the phone, or when you otherwise interact with us. We invite you to read this Policy carefully to understand our policies and practices regarding the collection, processing and storage of your Personal Information, or any other information in order to give us your informed consent where appropriate. If you do not consent to this Policy, then you may not use our Service or our Platform.
Remember that when you visit our Site or use the Platform or the Service, such visits and uses are at all times subject to our Terms of Use, which incorporates this Policy.
We wish to draw your attention to the fact that the rights and obligations described in this Policy do not apply to third-party websites or third-party technologies that may be linked to, integrated or mentioned in our Service or on our Platform. These third-party websites or third-party technologies have their own privacy policies and we encourage you to read them carefully.
1. WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL INFORMATION?
We provide the Service and operate our Platform and are the controller of Personal Information that you provide or that we collect from you when you visit our Platform or our Site. This means that we determine and are responsible for how this Personal Information is processed.
When we provide the Service to our Customer, the relevant Customer will be the controller of the Personal Information that we collect, including Personal Information that we collect through the Service relating to individuals that contact such Customer by phone, chat, through widgets or other forms of communications connected to our Service (the “Users”, each a “User”). This means that the relevant Customer determines and is responsible for how that Personal Information is processed. We will process that Personal Information primarily as a processor or service provider on behalf of the relevant Customer, meaning that we have contractually committed to processing that Personal Information only on the instructions of the relevant Customer.
In addition, in order to improve and customize the knowledge base powering the Service, a Customer may provide us with, or upload information to the Platform. Such information may include the Personal Information of such Customer’s officers, directors, employees, contractors or clients, such as first name, last name, job title or professional designation, role or function within the organization of such Customer, email address, telephone number, educational background or credentials, areas of expertise or fields of practice, work schedule or availability, work address or languages spoken. In such case, the relevant Customer will be the controller of such Personal Information. This means that the relevant Customer determines and is responsible for how that Personal Information is processed. We will process that Personal Information primarily as a processor or service provider on behalf of the relevant Customer, meaning that we have contractually committed to processing that Personal Information only on the instructions of the relevant Customer.
2. WHAT PERSONAL INFORMATION DO WE COLLECT?
“Personal Information” means any information that identifies, relates to, describes, is about, is capable of being associated with, or could reasonably be linked, directly or indirectly, with an identified or identifiable individual. Information that is aggregated or anonymized and cannot be associated with an identifiable individual is not considered Personal Information.
Walaw collects and processes your Personal Information in order to provide you with the Service, the Platform and the Site. The Personal Information we collect about you will depend on the nature of your interactions with the Service, the Platform and our Site.
We only collect the information necessary to fulfill the purposes described in this Policy. We process Personal Information in accordance with applicable privacy laws.
We may collect, use and disclose the following categories of Personal Information:
Login credentials, such as your email address, username and password;
Contact details, such as your first and last name, email address, postal address and telephone number;
Technical information and metadata about your use of the Platform or our Site, such as your login information, dates of your visits, internet protocol (IP) address, information about your internet connection, web browser type, version, time zone setting, browser plug-in types, operating system, and settings, information about the equipment used to browse the Platform or our Site;
Information about your interactions with the Platform or our Site, such as pages visited, clickstreams, content searched for, page response times, duration of visits to certain pages and methods used to leave the page;
Geolocation information, such as may be collected when you use our Platform or our Site; or
Any other Personal Information you have provided to us.
When you use our payment processing system:
Your payment information is sent directly to our payment processor and we only receive and retain a confirmation token of the transaction.
3. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
We collect information about you, which may may include Personal Information, in a variety of different ways:
Information you provide to us, such as when you contact us.
Information we collect while you interact with our Site and our Platform, or through our electronic communication with you, including via your laptop or mobile device, social media sites and email communications. For additional details please see below the subsection “Personal information we collect through cookies and other automatic data collection technologies”.
From other sources, such as data analytics firms.
Information we create ourselves after we analyze the information we collected about you, such as how you interact with our Site or our Platform.
Personal information we collect through cookies and other automatic data collection technologies
As you navigate through and interact with our Site and our Platform, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
details of your visits to our Site and our Platform, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Site and the Platform; and
information about your computer and internet connection, including your IP address, operating system, and browser type.
The information we collect automatically may include Personal Information. It helps us to improve our Site, the Platform and the Service, and to deliver a better and more personalized service, including by enabling us to estimate our audience size and usage patterns and to ensure the security and improve the operation of the Site and the Platform. The technologies we use for this automatic data collection may include:
Cookies. Our Site and our Platform uses cookies and other tracking technologies. A cookie is a small text file containing tiny amounts of information which are downloaded to your device when you visit a website. Cookies are thereafter accessed by the same website each time you visit, and by other websites that recognize that cookie. We only place non-essential cookies on your device and use other interaction and/or performance monitoring tools with your affirmative consent. You may withdraw or change your consent at any time by accessing our cookie consent manager through the “Cookies” link on our Site. You may also refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access or use certain parts of our Site.
Web Beacons. Pages of our Site, our Platform and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count the number of users who have visited those pages or opened an email and for other related Site or Platform statistics (for example, recording the popularity of certain Site or Platform content, feature, service, product and verifying system and server integrity).
With your consent
We collect your Personal Information with your consent, unless applicable law provides an exception to this principle (for example, to comply with our legal obligations, when necessary to establish, exercise or defend a legal claim or proceeding).
4. WHY DO WE COLLECT YOUR PERSONAL INFORMATION?
For specific and limited purposes
Walaw generally collects your Personal Information for the purposes listed below (collectively, the “Purposes”).
a) To provide the Platform and the Service;
This includes, but is not limited to:
Create and administer your account once you have registered on the Platform;
Process and classify information about you; and
Personalize your use and experience of the Platform.
b) To communicate with you, provide you with updates and other information related to the Platform or the Service, provide information that you request, respond to comments and questions, and otherwise provide the support you need;
This includes, but is not limited to:
Facilitate our communication with you;
Communicate with you regarding your registration to the Platform and your account and to respond to your requests and/or inquiries about the Platform or the Service in general or for any assistance and support;
Send you administrative information, for example, information about the Platform, the Service and changes to our terms, conditions and policies or inform you of changes to the Platform or the Service; and
Help you use the Platform or the Service.
c) For AI and business administration purposes, to understand and analyze how you use the Platform and the Service, to maintain, improve, and enhance the Platform or the Service, and to develop new products, services and features;
This includes, but is not limited to:
Meet our legitimate business objectives, such as developing new products and services, improving or modifying the Platform or the Service;
Train and improve our existing artificial intelligence (AI) models or to create new ones;
Create statistics to demonstrate the usefulness of the Platform or the Service; and
Conduct research to determine how to improve the Platform, the Service or develop new products.
d) For marketing purposes;
This includes to:
Keep you informed of our new offers;
Send you marketing communications that we think may be of interest to you, such as newsletters, promotional emails, direct mailings or business contacts;
Inform you of new product or service releases, new partnerships and other key information about the Platform or the Service;
Provide you with useful information about the Platform or the Service; and
Measure data for analysis purposes, including the identification of usage trends, and to determine the effectiveness of our promotional campaigns and commercial activities.
e) To protect the safety and integrity of our Customers, the Users, employees and other parties, members of the public, the Platform and the Service;
This includes to:
Verify your identity and grant you access to the Platform; and
Ensure the security of the Platform.
f) To comply with our legal obligations and protect our interests; and
This includes:
Carry out our obligations and enforce our rights under any contract we may have with you, including our Terms of Use;
Audit, surveillance and fraud prevention purposes;
Respond to requests from public and governmental authorities, including public and governmental authorities outside your jurisdiction of residence;
Protect our operations and legitimate interests or those of our subsidiaries or partners; and
Enable us to pursue available remedies or limit the damages we may suffer.
g) For any other purpose compatible with the purpose of the Platform, the Service, the Site or to which you have consented.
With your express consent, we may use your Personal Information for any other purpose consistent with the purpose of the Platform, the Service or the Site.
If we wish to use your Personal Information for a purpose not mentioned above and for which you have not consented, we will ensure that we seek appropriate consent from you or inform you of the change, where permitted by law.
5. HOW DO WE SHARE OR DISCLOSE YOUR PERSONAL INFORMATION?
Internally with our employees
In the course of their work, our employees or contractors may need to access your Personal Information, for example, when you contact us or request assistance. Their access is limited to what is necessary for the performance of their duties.
With third parties
Your Personal Information will not be sold to third parties.
We share your Personal Information with third parties to (i) fulfill the Purposes, (ii) respond to requirements or requests made under applicable laws, and (iii) perform tasks contracted to us by our Customers. More specifically, we will share your Personal Information with the following categories of third parties.
With service providers
Walaw may share your Personal Information with its service providers and partners to enable the provision of the Platform and the Service, payment and hosting service providers, automated text analysis service providers, Large language models (LLMs), voice-to-text and text-to-voice translation providers or cybersecurity service providers.
Our service providers may have access to your Personal Information in connection with these activities.
Please note that these third parties may be located outside of your jurisdiction of residence. In such cases, Walaw takes commercially reasonable steps, as described below in the section “Cross-Jurisdictional Transfers of your Personal Information".
During a commercial transaction
We may share your Personal Information in the event of a merger, acquisition, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of all or part of equity or our assets, for example, as part of a due diligence review. In such a case, we limit sharing to what is necessary to assess the feasibility or advisability of the transaction.
Where required by applicable law
We may also share your Personal Information if required to do so by law or in the good faith belief that such action is necessary to: (i) comply with the law; (ii) comply with an order of a competent judicial authority in any jurisdiction; (iii) comply with legal process served on Walaw; (iv) protect and defend the rights or property of Walaw; (v) enforce or verify your compliance with any agreement you have entered into with Walaw, including our Terms of Use; (vi) prevent fraud or other illegal activity perpetrated through the Platform or the Service; or (vii) act in urgent circumstances to protect the personal safety of Clients or Users of the Platform or our Service or the general public.
For any other purposes, with your consent
Where you have expressly consented, your Personal Information may be shared with other third parties. For example, there may be specific cases where additional conditions apply and through these we make it clear that specific third parties are processing your Personal Information.
6. CROSS-JURISDICTIONAL TRANSFERS OF YOUR PERSONAL INFORMATION
Your Personal Information may be disclosed and stored outside your jurisdiction of residence where data protection laws may differ from those of the jurisdiction in which you are located or reside, and your Personal Information may be accessible to law enforcement and national security authorities in such jurisdictions.
Our business partners and service providers may be located outside the Province of Québec and in other jurisdictions. We ensure that appropriate safeguards are in place to protect your Personal Information when it is transferred to these business partners and service providers, in compliance with applicable privacy laws and this Policy.
We seek to limit access to Personal Information by such third parties to that which is necessary to perform the tasks entrusted to them. We also strive to establish, as soon as possible, contractual agreements with such third parties to ensure the confidentiality and security of your Personal Information.
7. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?
We retain your Personal Information only for as long as necessary to fulfill the Purposes, to comply with applicable legal, tax or regulatory requirements. At the end of this period, we will destroy, delete or anonymize such Personal Information securely in accordance with relevant legal, regulatory and contractual requirements.
In determining the appropriate retention period for your Personal Information, we take into account the amount, nature and sensitivity of the Personal Information, the potential risk of harm arising from unauthorized use or disclosure of your Personal Information, the Purposes for which we process your Personal Information and the possibility of achieving those Purposes by other means, as well as applicable legal, regulatory, tax, accounting or other requirements.
If you wish to obtain more information on this subject or otherwise request the deletion of your Personal Information under this Policy, we invite you to contact us.
8. HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
With necessary and appropriate measures
Walaw has implemented physical, technological and administrative security measures to protect your Personal Information. The standard security measures we use depend on the type of information collected. We encourage you to use caution when using the Internet, including not sharing your login or password.
Our employees are informed of the confidential nature of the Personal Information we collect and are made aware of the appropriate security measures to prevent unauthorized access to, use or disclosure of your Personal Information.
If you have any questions about the security of your interaction with us (if, for example, you believe that the security of any account you may have with us has been compromised), or if you believe that an unauthorized account has been created using your name, please contact us as described in the “How to contact us” section.
Children’s privacy
The Service, the Platform and the Site are not designed for nor meant to be used by children under the age of 14. Walaw does not knowingly collect or solicit Personal Information from anyone under the age of 14. If we learn that we have collected such information we will delete it as quickly as possible. If you believe that a child under the age of 14 has provided us with Personal Information, please contact us using the information under the section “How to contact us”.
9. WHAT ARE YOUR RIGHTS?
Depending on your jurisdiction of residence, you may have certain rights regarding your Personal Information, including:
Access and Correction: You can request access to your Personal Information and ask us to correct or update any inaccuracies.
Withdrawal of Consent: If you have given consent for us to use your information, you may withdraw that consent at any time. Please note that withdrawing your consent will not affect the legality of our processing of your Personal Information prior to such withdrawal.
Anonymization or Deletion: You can request that we delete your Personal Information, subject to our legal obligations.
Portability: You may have the right, in certain circumstances, to obtain Personal Information you have provided us with in a structured, commonly used, and machine-readable format and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.
Restriction: You can limit the way we use your Personal Information if you are concerned about the accuracy of such information or how it is being used. If necessary, you can also ask us to refrain from deleting your Personal Information.
Automated decision: You may obtain additional information regarding, and request a review of, decisions that are made on solely automated processing carried out by us, where applicable.
Your rights are subject to applicable legal restrictions. We will respond to your requests to exercise your rights within a reasonable timeframe, in compliance with applicable laws. We may take reasonable steps to verify your identity before fulfilling your requests. If we cannot fulfil your request, we will explain why, and try to find a solution with you. We may refuse to rectify Personal Information if we believe that the correction would violate a law or legal requirement or would render the information incorrect.
File a complaint
You may file a complaint with our Privacy Officer (as defined below) if you are dissatisfied with our handling of your Personal Information or compliance with this Policy.
Depending on your jurisdiction of residence, you may also be entitled to lodge a complaint with a privacy commissioner or any other competent supervisory authority for the protection of Personal Information.
How to exercise your rights
To exercise any of your rights (to the extent that they are available), please contact us as indicated in the “How to contact us” section.
10. HOW TO CONTACT US
Walaw has appointed a privacy officer (the “Privacy Officer”) whose duties consist of managing and monitoring Walaw’s internal Personal Information management program. It is the Privacy Officer who approves and implements privacy policies and procedures, including this Policy, ensures their proper functioning and reports to Walaw senior management on the effectiveness of the program.
It is also the responsibility of the Privacy Officer to provide you with the necessary support in the event of a question, complaint or request relating to the protection of Personal Information.
If you have any questions about any aspect of this Policy, wish to send a comment, lodge a complaint or exercise any of the rights available to you under applicable law, please contact our Privacy Officer as follows:
Privacy Officer Email: privacy@walaw.ca cc. legal@walaw.ca |
If you have any questions regarding a technical problem with the Platform or the Service, or your access to or use of their functions, please contact us at the following address: support@walaw.ca
11. PRIVACY RIGHTS OF UNITED STATES RESIDENTS
U.S. state legislation, for example, California Civil Code Section 1798.83, may permit customers to ask us for certain information regarding Walaw disclosures in the prior calendar year, if any, of personally identifiable information to third parties or our affiliates for their own direct marketing purposes. If you are a California resident, or resident of a state permitting such a request, and would like to make such a request, please contact our Privacy Officer in writing using the information available under the “How to contact us” section.
Please include your name and the address to which you would like us to respond, and allow us thirty (30) days to respond to your request.
12. MODIFICATIONS AND UPDATES TO THE POLICY
It is our policy to post any changes we make to this Policy on this page. If we make changes to this Policy, we will provide more prominent notice to you as and where required by applicable law. By continuing to interact with us or using this Site or the Platform after the modified version of this Policy has been posted or you have been informed of such update, you agree to be bound by all such changes. If you do not agree to the changes in this Policy, it is your responsibility to stop interacting with us.
We include the date this Policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our Site and our Platform and this Policy to check for any changes.