Privacy Policy

TheWheel, Inc. (“TheWheel,” “we,” “us” or “our”) provides a private knowledge-management platform that lets you store, organize, search, and interact with your own content using artificial intelligence, protected by client-side encryption. This Privacy Policy describes how TheWheel processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy (including as applicable, our website, mobile application, and social media pages) as well as our marketing activities, live events and other activities described in this Privacy Policy (collectively, the “Service”).

Personal information we collect

Information you provide to us

Personal information you may provide to us through the Service or otherwise includes:

• Profile data, such as the information you provide to establish an online account on the Service (we use passwordless passkey authentication and do not collect or store passwords), invite or redemption code, biographical details, photograph or picture, interests, preferences, and any other information that you add to your account profile.
• Communications data based on our exchanges with you, including when you contact us through the Service, communicate with us via chat features, social media, or otherwise.
• Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history.
• Marketing data, such as your preferences for receiving our marketing communications.
• Feedback data, such as ratings you give AI responses (for example, thumbs up or down), optional comments, corrections you make to AI-generated tags, and related context. Comments and any response text you attach are processed through automated pseudonymization that replaces personal details with surrogates before storage. If we offer optional surveys in the future, participation will be voluntary and we will describe any additional collection at that time.
• User-generated content and input data, such as photos, images, music, videos, comments, questions, messages, works of authorship, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data. Your content on the Service is encrypted in your browser before it is transmitted to us, and we can process it only during bounded sessions that you initiate, as described in the Security section below.
• Identity verification data (account recovery only), consisting of an image of a government-issued identification card and facial biometric data used to verify your identity if you choose to use our account-recovery process. This data is collected with your consent and is processed on our behalf by our identity-verification provider, Didit; we do not store it ourselves.
• Payment data needed to complete transactions. Payment card details are collected directly by our payment processor, Stripe; we receive only limited information such as card brand, last four digits, expiration date, and billing address, and we do not receive or store full card numbers.
• Other information you choose to provide, such as information you include in a support request, bug report, or other communication with us. We will use it as described in this Privacy Policy or as we describe at the time you provide it.

Third-party sources

We may combine personal information we receive from you with personal information falling within one of the categories identified above that we obtain from other sources, such as:

• Service providers that provide services on our behalf or help us operate the Service or our business.
• Business transaction partners. We may receive personal information in connection with an actual or prospective business transaction. For example, we may receive your personal information from an entity we acquire or are acquired by, a successor, or assignee or any party involved in a business transaction such as a merger, acquisition, sale of assets, or similar transaction, and/or in the context of an insolvency, bankruptcy, or receivership.
• Connected accounts, such as Gmail, Google Drive, Google Calendar, Slack, GitHub, and Notion, that you choose to link to the Service through a user-initiated OAuth connection. We collect content and account information from a connected account only at your direction and subject to your settings on that service. When you connect an account, you authorize the provider directly through its own consent screen and select the specific resources to sync (for example, particular folders, channels, or repositories). Connection tokens are encrypted in your browser with your own keys before they are stored, and synced content is encrypted at rest in the same manner as content you upload. Disconnecting a connected account also revokes your standing consent for that connector’s data. Our use and transfer of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

Automatic data collection

We and our service providers automatically collect a limited set of data when you use the Service:

• Analytics data. We use Plausible, a cookieless analytics service, to collect anonymous, aggregate feature-usage events (such as “signup,” “document uploaded,” or “chat started”). These events contain no user identifiers, no content, and no browsing history. Plausible does not use cookies, persistent identifiers, or cross-site tracking.
• Operational telemetry. We collect content-free operational data about AI request routing and backend performance (such as which provider handled a request, response latency, token counts, and system traces). Automated denylists and scrubbing processors exclude user content and identity from this data before it is recorded or exported.
• Error tracking. We use Sentry to collect error reports for debugging. Error reports are processed with a deny-by-default filter that removes request bodies, cookies, query strings, and personal information before transmission, and user identity is reduced to an opaque identifier.
• Security data. We log IP address (hashed), user agent, and coarse location (city/country) for security monitoring and fraud prevention. Raw IP addresses are not retained in logs.

You can individually turn off analytics, usage-data sharing, and error reporting in your privacy settings.

For more information concerning our automatic collection of data, please see the Tracking technologies section below.

Data about others. During beta, registration requires an invite code; when general registration opens, you will be able to register directly. You can invite team members, clients, and collaborators to your workspace by sharing a link or code. We do not access your address book or import contact lists from your device or connected accounts.

Tracking & Other Technologies

Artificial intelligence (“AI”) features. AI is core to the Service: you can chat with AI over your own content, and we use AI models for search, indexing, and safety features. AI queries are processed by our inference provider, Fireworks, under terms providing for zero data retention; prompts and outputs are not logged or stored by the provider, and we do not permit any AI provider to use your content to train AI models. When you ask a question that needs the open web, the search query (not your content) is sent to our web search provider, Valyu, and the results are returned to the Service. Before any data is sent for AI processing: (1) you must have granted AI-processing consent, a standing consent that is recorded when you grant it and that you can revoke at any time in your privacy settings, with revocation taking effect immediately; (2) automated safeguards replace names, contact details, and other identifying information with opaque surrogates; and (3) a sanitizer blocks user-identifying fields from leaving our systems. We will update this Privacy Policy before enabling any additional AI inference provider.

For information concerning your choices with respect to the use of tracking technologies, see the Your choices section below.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations

We may use your personal information to:

• provide the Service;
• enable security features of the Service;
• establish and maintain your user profile on the Service;
• facilitate your invitations to friends who you want to invite to join the Service;
• facilitate collaboration features of the Service, such as shared spaces and team workspaces;
• communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages; and
• provide support for the Service, and respond to your requests, questions and feedback.

Service personalization, which may include using your personal information to:

• understand your needs and interests;
• personalize your experience with the Service and our Service-related communications; and
• remember your selections and preferences as you navigate webpages.

Service improvement and analytics

We may use anonymous, aggregate feature-usage data and content-free operational telemetry to analyze how the Service is used and to improve the Service. Our telemetry systems are structurally designed to exclude user content and identity from operational data. We do not use your content to improve the Service unless you explicitly choose to contribute through our system-learning feature, described below.

Training contribution (optional)

We do not use your content to train AI models. If you choose to participate in our optional system-learning program, the Service may generate a synthetic, generalized version of a pattern observed during your use — stripped of identifying details and validated against prohibited content patterns. You can preview each synthetic contribution individually and approve, decline, or edit it before it is saved; you can also grant standing approval once you are comfortable with the process. Your original content is never included in a contribution or retained for training; only the approved synthetic version is retained, together with an encrypted record linking the contribution to your account that we cannot read. System-improvement contributions and model training are separate choices: we do not currently train AI models, and we will not use your synthetic contributions for model training without your separate opt-in consent. You can withdraw consent and opt out at any time, per conversation or globally. If you withdraw consent, we will stop generating new contributions and delete any synthetic contributions that have not yet been used for the purposes you approved. Where a contribution has already been used, we cannot fully remove its effects, so we instead delete the encrypted record linking you to it; once that link is deleted, the contribution cannot be traced back to you, and improvements already incorporated into the system cannot be reversed. Opting out does not affect your use of the Service.

Marketing

We may use your personal information for limited marketing purposes:

Direct marketing. We may send you transactional emails related to your account (such as security alerts, billing receipts, and service announcements). With your opt-in, we may also send you product updates and feature announcements. You can unsubscribe from non-transactional emails at any time using the link in any such email. We do not use your content or in-product activity to personalize marketing communications.

Compliance and protection

We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements or our internal policies;
• enforce the terms and conditions that govern the Service; and
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

Data sharing in the context of corporate events. We may share certain personal information in the context of actual or prospective corporate events; for more information, see How we share your personal information, below.

De-identified and anonymized data. When you delete your account, we anonymize (rather than delete) certain financial and audit records as required by law. We hash IP addresses in server logs so that the raw address is not retained. We may derive anonymous, aggregate usage statistics that do not identify you (such as feature-usage counts) and use them to analyze and improve the Service and to describe our business. We do not create de-identified or anonymized datasets derived from your content for business purposes, and we do not share de-identified data with third parties. We will not attempt to re-identify any anonymized data, except to test whether our anonymization processes comply with applicable law.

Further uses. In some cases, we may use your personal information for further uses, in which case we will ask for your consent to use your personal information for those further purposes if they are not compatible with the initial purpose for which information was collected.

Retention

We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, establishing or defending legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing. For example, we retain financial and transaction records for seven years to satisfy legal, tax, and accounting requirements; when an account is deleted, these records are anonymized rather than deleted.

Our current retention periods for the main categories of personal information are:

• Account data: for the life of your account and a 30-day grace period after you request deletion, during which you can recover your account.
• Encrypted content: deleted on account deletion; encrypted data is removed from active systems, and residual copies are purged from backups within 30 days.
• Financial and transaction records: seven years; anonymized, rather than deleted, on account deletion.
• Audit logs: seven years; anonymized on account deletion.
• Usage metrics: two years; anonymized.
• Security and access logs: 90 days.
• Analytics data (Plausible): aggregate only; no user-level data is retained.
• Operational telemetry: 90 days.
• Synthetic training contributions: deleted when you withdraw consent if not yet used for the purposes you approved; where a contribution has already been used, the anonymous synthetic record is retained and the encrypted record linking you to it is deleted, after which it cannot be traced back to you.

We may retain personal information for longer where required by law or in connection with legal claims, legal holds, or disputes.

When account deletion completes, you can download a cryptographically signed deletion certificate from the confirmation page.

How we share your personal information

We may share your personal information with the following parties (or as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection).

• Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, passkey authentication (Hanko), encrypted key-share custody (Web3Auth), identity verification (Didit), AI inference (Fireworks), web search (Valyu), transactional email (Resend), error monitoring (Sentry), and cookieless analytics (Plausible)).
• Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so.
• Linked third-party services. If you log into the Service with, or otherwise link your Service account to, a third-party service (such as Google, Slack, GitHub, or Notion), we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service.
• Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, in the course of the professional services that they render to us.
• Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
• Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in TheWheel, Inc., financing of TheWheel, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares). For example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of TheWheel as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets. Your content that is encrypted client-side will be transferred in encrypted form in any such transaction. We do not maintain the ability to decrypt your content without your participation, and we will require any acquirer, successor, or assignee to honor the commitments in this Privacy Policy.
• Other users and the public. Your content is private by default and is not visible to the public. Content you add to a shared space or team workspace is visible to the other members of that space, and profile information you share within a team is visible to that team. We do not make your content available to the public.

Your choices

In this section, we describe the rights and choices available to all users. Users who are located in certain U.S. states can find additional information about their rights below.

Access or update your information

If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account.

Opt-out of communications

You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

Cookies and other technologies. For information about the limited cookies and other technologies employed by the Service, see the Tracking & Other Technologies section above.

Privacy settings

We make available certain privacy settings on the Service, including options to control connected accounts, your standing consent to AI processing, your participation in the system-learning program, analytics, usage-data sharing, error reporting, data export, and account deletion.

Do Not Track

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit https://www.allaboutdnt.com.

Declining to provide information

We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Linked third-party platforms

If you choose to connect to the Service through your social media account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.

Delete your content or close your account. You can delete content, export your data, or delete your entire account at any time through the Service; account deletion includes a deletion certificate. You can also contact us for help with any of these.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We employ technical, organizational and physical safeguards designed to protect the personal information we collect. For example, your content is encrypted in your browser using AES-256-GCM before it is transmitted to us, your encryption keys are derived from a PIN that never leaves your device and are protected by a threshold key-custody scheme, and we can process your content only during bounded sessions that you initiate. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International data transfer

We are headquartered in the United States, where all of our infrastructure is located, and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country. The Service is currently offered only to users in the United States, and we will update this Privacy Policy before making the Service available in the European Union or the United Kingdom.

Children

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates that you acknowledge that the modified Privacy Policy applies to your interactions with the Service and our business.

How to contact us

If you have questions about our practices or if you would like to exercise any privacy-related right that may be available to you, please contact us via one of the methods listed below.

Email: privacy@jointhewheel.com

Mail: TheWheel, Inc., 1252 Forrest Avenue, Dover, DE 19904

Notice to users in the European Economic Area and the United Kingdom

Controller. TheWheel, Inc. is the controller of the personal information described in this Privacy Policy.

Legal bases. We process your personal information only where we have a legal basis to do so: performance of our contract with you (providing the Service, including AI features you request); our legitimate interests (securing and improving the Service, communicating with you, and protecting our rights), where those interests are not overridden by your rights; compliance with legal obligations; and your consent, where we ask for it, including your explicit consent before we process identity-verification data (government ID images and biometric data) through Didit for account recovery, and before any of your content is processed by an external AI provider. You may withdraw consent at any time without affecting prior processing.

Your rights. Subject to the conditions in applicable law, you may ask us to provide access to, correct, delete, restrict, or export your personal information; you may object to processing based on legitimate interests; and you may lodge a complaint with your local supervisory authority (in the UK, the Information Commissioner’s Office). Most of these rights can be exercised directly through the Service’s export and deletion tools, or by contacting us as described above. We do not make decisions based solely on automated processing that produce legal or similarly significant effects concerning you.

International transfers. We are located in, and process personal information in, the United States. Where required, transfers from the EEA or the UK are made under the European Commission’s Standard Contractual Clauses (and the UK Addendum or International Data Transfer Agreement), supplemented by the client-side encryption measures described in the Security section.

State privacy rights notice

Except as otherwise provided, this section applies to residents of U.S. states to the extent they have privacy laws applicable to us that grant their residents the rights described below (collectively the “State Privacy Laws”).

This section describes how we collect, use, and share Personal Information of residents of these states and the rights these users may have with respect to their Personal Information. Please note that not all rights listed below may be afforded to all users and that if you are not a resident of one of these states listed above, you may not be able to exercise these rights. In addition, we may not be able to process your request if you do not provide us with sufficient detail to allow us to confirm your identity or understand and respond to it. We verify requests by confirming your control of the email address associated with your account, and may request additional information where reasonably necessary or permitted by law.

For purposes of this section, the term “Personal Information” has the meaning given to “personal data,” “personal information” or other similar terms and “Sensitive Personal Information” has the meaning given to “sensitive personal information,” “sensitive data,” or other similar terms in the State Privacy Laws, except that in neither case does such term include information exempted from the scope of the State Privacy Laws. In some cases, we may provide a different privacy notice to certain categories of residents of these states, such as job applicants, in which case that notice will apply instead of this section.

Your privacy rights

The State Privacy Laws may provide residents with some or all of the rights listed below. However, these rights are not absolute and some State Privacy Laws do not provide these rights to their residents. Therefore, we may decline your request in certain cases as permitted by law.

Information. You can request the following information about how we have collected and used your Personal Information:

• The categories of Personal Information that we have collected.
• The categories of sources from which we collected Personal Information.
• The business or commercial purpose for collecting and/or selling Personal Information.
• The categories of third parties with which we share Personal Information.
• The categories of Personal Information that we sold or disclosed for a business purpose.
• The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose.

Access. You can request a copy of the Personal Information that we have collected about you.

Appeal. You can appeal our denial of any request validly submitted.

Correction. You can ask us to correct inaccurate Personal Information that we have collected about you.

Deletion. You can ask us to delete the Personal Information that we have collected from you.

Opt-out.

• Opt-out of certain processing for targeted advertising purposes. We do not process your Personal Information for targeted advertising purposes.
• Opt-out of or appeal profiling/automated decision making. We do not use your Personal Information to engage in profiling or to perform automated decision-making that results in significant financial impacts, significant impacts on housing, education, employment, health care, or criminal justice, or similarly significant impacts.
• Opt-out of other sales of personal data. We do not sell your Personal Information within the meaning of the State Privacy Laws.

Consumers under 16. We do not have actual knowledge that we collect, sell or share the personal information of consumers under 16 years of age.

Sensitive Personal Information. While we process certain categories of Sensitive Personal Information as described in this Privacy Policy (such as identity-verification data processed through Didit, and any sensitive information contained in content you store), we do not process Sensitive Personal Information for the purpose of inferring characteristics about consumers.

Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the State Privacy Laws.

Exercising your right to opt-out of the “sale” or “sharing” of your Personal Information. We do not sell or share your Personal Information within the meaning of the State Privacy Laws, and we do not use interest-based advertising services. If our practices change, we will update this Privacy Policy and provide any required opt-out mechanisms, including honoring Global Privacy Control (“GPC”) signals as required by applicable law.

Exercising other state privacy rights. You may submit requests to exercise any of the other state privacy rights listed above through the export and deletion tools in the Service, or via email to privacy@jointhewheel.com.

Verification of identity; authorized agents

We may need to verify your identity in order to process your information/know, access, appeal, correction, or deletion requests and reserve the right to confirm your residency. To verify your identity, we may require government identification, a declaration under penalty of perjury, or other information, where permitted by law.

Under some State Privacy Laws, you may enable an authorized agent to make a request on your behalf. However, we may need to verify your authorized agent’s identity and authority to act on your behalf. We may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your State Privacy Laws rights on your behalf, the information we request to verify your identity, and confirmation that you have given the authorized agent permission to submit the request.

Information practices

The following describes our practices currently and during the past 12 months:

• Sources and purposes. We collect all categories of personal information from the sources and use them for the business/commercial purposes described above in the Privacy Policy.
• Retention. The criteria for deciding how long to retain personal information is generally based on whether such period is sufficient to fulfill the purposes for which we collected it as described in this notice, including complying with our legal obligations.
• De-identification. We do not attempt to re-identify de-identified information derived from personal information, except for the purpose of testing whether our de-identification processes comply with applicable law.

Personal information that we collect, use and disclose. We have summarized the Personal Information we collect, the purposes for which we collect it and the third parties to whom we may disclose it by reference below to both the categories defined in the Personal information we collect section of this Privacy Policy above and the categories of Personal Information specified in the CCPA (Cal. Civ. Code §1798.140). This chart describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below.

Additional information for California residents

Shine the Light law. Under California’s Shine the Light law (California Civil Code Section 1798.83), California residents may ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes, and the categories of personal information disclosed. You may send us requests for this information to privacy@jointhewheel.com. In your request, you must include the statement “Shine the Light Request,” and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

Additional information for Nevada residents

Nevada residents have the right to opt-out of the sale of certain personal information for monetary consideration. While we do not engage in such sales, if you are a Nevada resident and would like to make a request to opt out of any potential future sales, please email privacy@jointhewheel.com.

Contact us. If you have questions or concerns about our privacy policies or information practices, please contact us using the contact details set forth in the How to contact us section above.