PRIVACY POLICY

Last updated July 4, 2026

This Privacy Notice for WaveBooks (“we ,” “us ,” or “our “), describes how and why we might access, collect, store, use, and/or share (“process “) your personal information when you use our services (“Services “), including when you:

• Download and use our mobile application (WaveBooks), or any other application of ours that links to this Privacy Notice

• Use WaveBooks, an offline-first audiobook player for people who already own DRM-free audiobooks.

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at wavebooks+privacy@proton.me.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? Some of the information may be considered “special” or “sensitive” in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We do not process sensitive personal information.

Do we collect any information from third parties? We do not collect any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by emailing us at wavebooks+privacy@proton.me, or by using the in-app bug report, feature request, or contact forms. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

5. HOW LONG DO WE KEEP YOUR INFORMATION?

6. DO WE COLLECT INFORMATION FROM MINORS?

7. WHAT ARE YOUR PRIVACY RIGHTS?

8. CONTROLS FOR DO-NOT-TRACK FEATURES

9. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

10. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

11. DO WE MAKE UPDATES TO THIS NOTICE?

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you contact us or when you send us a bug report, feature request, or other message through the Services.

Sensitive Information. We do not process sensitive information.

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s storage, iCloud, and files, so the app can read the audiobooks you already own. If you wish to change our access or permissions, you may do so in your device’s settings.

• Diagnostics and usage data. To keep the app reliable, we automatically collect diagnostic and usage information, including crash reports, error logs, app-launch and performance metrics, the screens you view, and app lifecycle events, together with technical details about your device (such as device model, operating-system version, and a randomly generated installation identifier). This data is collected using self-hosted observability software (Measure) that runs on servers we operate; it is not sent to any third party and is not used to advertise to you.

• Bug reports (“Rage Shake”). Rage Shake is an optional way to report a problem from inside the app, named after the gesture that opens it. When you physically shake your device (or tap “Report a Bug” in Settings), WaveBooks opens a report form and captures a screenshot of the screen you were on. You choose what to send: you write the description of the problem, and you can review, annotate/redact (draw over), or remove the captured screenshot and any additional photos before submitting. Nothing is sent until you tap “Send”. We collect only the description and the images you choose to include. Screenshots may show whatever was on your screen, such as the titles in your library, so please review them before submitting.

This information is primarily needed to maintain the security and operation of our application(s) and for troubleshooting.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process the personal information for the following purposes listed below. We may also process your information for other purposes only with your prior explicit consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To provide and operate the app. We process device-access permissions so the app can play the audiobooks you already own on your device.

• To diagnose problems and keep the app reliable. We process crash reports, error logs, and usage and performance metrics to detect, troubleshoot, and fix problems.

• To respond to bug reports. We process the descriptions and screenshots you submit through the in-app bug report (“Rage Shake”) feature to understand and resolve the issue you reported.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.

• Legitimate Interests. We process diagnostic and usage data (crash reports, error logs, and performance metrics) under our legitimate interest in keeping the app secure, stable, and free of defects. We rely on the same basis to act on the bug reports you choose to send us.

• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We do not share your diagnostic data, usage data, or bug reports with any third party. This information is collected using self-hosted software on servers we operate and stays under our control. Our servers are located in the United States, so if you access the Services from outside the United States (for example, from the EEA, the United Kingdom, or Mexico), your diagnostic and bug-report data is transferred to and stored in the United States. We may need to share your personal information only in the following situation:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

5. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). Diagnostic and usage data and bug reports (including any attached screenshots) are retained on our own servers for no longer than 90 days, after which they are deleted.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

6. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction.

We do not knowingly collect, solicit data from, or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or the equivalent age as specified by law in your jurisdiction or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age or the equivalent age as specified by law in your jurisdiction has been collected, we will take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18 or the equivalent age as specified by law in your jurisdiction, please contact us at wavebooks+privacy@proton.me.

7. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information.__ You may request access to, correction of, or deletion of your personal information at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you have questions or comments about your privacy rights, you may email us at wavebooks+privacy@proton.me.

8. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

9. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect

The table below shows the categories of personal information we have collected in the past twelve (12) months. The table includes illustrative examples of each category and does not reflect the personal information we collect from you. For a comprehensive inventory of all personal information we process, please refer to the section “WHAT INFORMATION DO WE COLLECT?”

Category| Examples| Collected —|—|— A. Identifiers| Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name| YES — a randomly generated installation identifier and related technical identifiers used for diagnostics

B. Personal information as defined in the California Customer Records statute| Name, contact information, education, employment, employment history, and financial information| NO

—|—|—

C. Protected classification characteristics under state or federal law| Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data| NO

—|—|— D. Commercial information| Transaction information, purchase history, financial details, and payment information| NO

E. Biometric information| Fingerprints and voiceprints| NO

F. Internet or other similar network activity| Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements| YES — your interactions with our app (screens viewed, app lifecycle, and performance metrics) for diagnostics

G. Geolocation data| Device location| NO

H. Audio, electronic, sensory, or similar information| Images and audio, video or call recordings created in connection with our business activities| YES — screenshots you choose to attach to an in-app bug report

I. Professional or employment-related information| Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us| NO

J. Education Information| Student records and directory information| NO

K. Inferences drawn from collected personal information| Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics| NO

L. Sensitive personal Information| | NO

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;

• Participation in customer surveys or contests; and

• Facilitation in the delivery of our Services and to respond to your inquiries.

Sources of Personal Information

Learn more about the sources of personal information we collect in “WHAT INFORMATION DO WE COLLECT?”

How We Use and Share Personal Information

Learn more about how we use your personal information in the section, “HOW DO WE PROCESS YOUR INFORMATION?”

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?”

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data

• Right to access your personal data

• Right to correct inaccuracies in your personal data

• Right to request the deletion of your personal data

• Right to obtain a copy of the personal data you previously shared with us

• Right to non-discrimination for exercising your rights

• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)

Depending upon the state where you live, you may also have the following rights:

• Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)

• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)

• Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)

• Right to obtain a list of third parties to which we have sold personal data (as permitted by applicable law, including the privacy law in Connecticut)

• Right to review, understand, question, and depending on where you live, correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Connecticut and Minnesota)

• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)

• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida)

How to Exercise Your Rights

To exercise these rights, you can contact us by emailing us at wavebooks+privacy@proton.me, by using the in-app bug report, feature request, or contact forms, or by referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at wavebooks+privacy@proton.me. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California “Shine The Light” Law

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?”

10. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: You may have additional rights based on the country you reside in.

Mexico

We process your personal information in accordance with Mexico’s Federal Law on the Protection of Personal Data Held by Private Parties (Ley Federal de Protección de Datos Personales en Posesión de los Particulares, or “LFPDPPP”). WaveBooks is the responsable for your personal information. Under the LFPDPPP you have the right to Access, Rectify, Cancel (delete), or Oppose the processing of your personal information (your “ARCO” rights), and to limit its use or disclosure. To exercise your ARCO rights, or to withdraw your consent at any time, contact us at wavebooks+privacy@proton.me. A Spanish-language version of this notice (aviso de privacidad) is available on request.

11. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated “Revised” date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at wavebooks+privacy@proton.me.

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please email us at wavebooks+privacy@proton.me.