Privacy Policy

Last updated: 27 June 2026

1. Who We Are

Wava is a SaaS platform operated by Filova LTD, a company registered in England and Wales (Companies House No: 17263134), with registered office at 71-75 Shelton Street, Covent Garden, London WC2H 9JQ, United Kingdom. For privacy enquiries: privacy@filova.io.

Controller / Processor distinction: Wava acts as a data controller in respect of Tenants (businesses using the platform), and as a data processor on behalf of Tenants in respect of their end-users' personal data. Tenants are the data controllers for their end-users' data.

2. EU Representative

We are evaluating the appointment of an EU representative under GDPR Article 27. In the interim, EU data subjects may contact us directly at privacy@filova.io.

3. Data We Collect

CategoryExamples
Account dataName, email address, company name
Communication dataWhatsApp phone number, message content
Technical dataHashed IP address, session token
Billing dataCompany name, tax ID, billing address

4. Legal Basis for Processing

PurposeLegal basis (GDPR Art. 6)
Providing the WhatsApp AI serviceArt. 6(1)(b) — contract performance
Security, fraud prevention, abuse detectionArt. 6(1)(f) — legitimate interest
Marketing communicationsArt. 6(1)(a) — consent (freely given)
Billing and tax record-keepingArt. 6(1)(c) — legal obligation

5. Automated Decision-Making (GDPR Art. 22)

Wava uses AI (Anthropic Claude) to generate WhatsApp responses and to qualify leads on behalf of Tenants. These outputs may constitute automated decisions affecting end-users. You have the right to request human review of any AI-generated decision that significantly affects you. To exercise this right, contact privacy@filova.io.

6. Sub-processors

We share personal data with a limited set of sub-processors to operate the Service. The full list, including data categories processed and locations, is available on our Sub-processors page. We do not sell or share personal data for advertising purposes.

7. International Data Transfers

Some of our sub-processors are located outside the EEA/UK. We use the following mechanisms to safeguard transfers:

  • EU to US (Meta, Anthropic): Standard Contractual Clauses (SCCs, 2021 EU SCC Decision) and/or EU-US Data Privacy Framework (DPF) certification where applicable.
  • UK to US (Meta, Anthropic): UK Addendum to the EU SCCs (approved by ICO, March 2022) and/or the UK-US Data Bridge (effective 12 October 2023).
  • Database (Supabase): Hosted in the EU (eu-central-1, Frankfurt, Germany) — no transfer outside the EEA for core data storage.

8. Retention Periods

Data categoryRetentionBasis
Message content90 daysData minimisation
Account / profileActive + 90 daysContract performance
Billing records7 yearsUK tax law (HMRC)
IP address / access logs2 yearsLegitimate interest
Phone / emailWhile account activeContract performance

9. Your Rights

EU / EEA — GDPR

Under GDPR Articles 15–21 you have the right to: access, rectification, erasure ("right to be forgotten"), restriction of processing, data portability, and to object to processing. You may also withdraw consent at any time without affecting prior lawful processing. To submit a request, contact privacy@filova.io. You may also lodge a complaint with the supervisory authority in your EU member state.

UK — UK GDPR

You have the same rights as under EU GDPR. Filova LTD is subject to UK GDPR and the Data Protection Act 2018. You may lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk.

US — CCPA / CPRA

California residents and residents of states with equivalent privacy laws have the right to access, delete, and correct their personal information, and to opt out of sale or sharing. We do not sell or share personal data. We honour the Global Privacy Control (GPC) signal. CCPA requests are responded to within 45 days (extendable by a further 45 days where reasonably necessary, with notice).

10. Cookies

We use only a single strictly-necessary cookie: the Supabase authentication session cookie (HttpOnly, Secure, SameSite=Strict). We do not use analytics, advertising, or tracking cookies or local storage. No cookie consent banner is required under GDPR / ePrivacy Directive because strictly-necessary cookies are exempt.

11. Contact

Filova LTD
Companies House No: 17263134
71-75 Shelton Street, Covent Garden
London WC2H 9JQ, United Kingdom
(Registered in England and Wales)

Privacy requests: privacy@filova.io

We aim to respond to all requests within 30 days (or 45 days for CCPA requests). Requests must include sufficient identity verification — a government-issued ID number (passport or equivalent) may be required.

12. Changes to This Policy

We will post any changes to this page and update the "last updated" date. For material changes (e.g. new data categories, new sub-processors), we will notify Tenant account holders by email.