Privacy Policy

Welcome to Wayfinder. Wayfinder is an AI-powered career advisor platform operated by Virtuous Capital Foundation, a 501(c)(3) nonprofit organization. We are committed to protecting your privacy and ensuring you have a positive experience on our platform.

This Privacy Policy explains what information we collect, how we use it, how we protect it, and your rights regarding your data. By accessing and using Wayfinder, you agree to the terms of this Privacy Policy. If you do not agree with our practices, please do not use our platform.

1. Information We Collect

Account Information

When you create a Wayfinder account, we collect:

• Your full name
• Email address
• Password (stored as a secure hash, never in plain text)
• Account creation date

Profile Information

To provide you with personalized career advice, we collect:

• Age or date of birth
• Current grade level or educational status
• Academic interests and strengths
• Extracurricular activities and hobbies
• Career goals and aspirations
• Geographic location (optional)

Admissions Profile Data

To help you with college admissions planning, we collect:

• Graduation year and target schools
• Intended majors and academic interests
• State/location for regional opportunities
• ED/EA/RD strategy preferences
• Reminder preferences for deadlines

Conversation Data

We collect and store:

• All messages you send to Wayfinder's AI advisor
• All responses from our AI advisor
• Timestamps of your conversations
• Topics and subjects discussed

Essay Content

For our essay review service, we collect:

• Essays submitted for AI review
• Essay type, target school, and prompt provided
• AI-generated review scores and feedback
• Essay review history and timestamps
• Note: Essay content is processed by Wayfinder's proprietary AI engine

Usage Data

We automatically collect information about how you use Wayfinder:

• Queries and questions you submit
• Features you use and their frequency
• Time spent on the platform
• Content you save or bookmark
• Pages you visit within Wayfinder

Technical Data

We collect technical information to improve our service:

• Browser type and version
• Device type and operating system
• Internet Protocol (IP) address
• Referring website URL
• Pages visited and time spent
• Cookies and similar tracking technologies

Payment Information (if applicable)

If you subscribe to a premium plan, we collect:

• Billing name and address
• Payment method information (processed securely by Stripe)
• Transaction history

Note: Credit card numbers are never stored on our servers. Payment processing is handled securely by Stripe, our payment processor.

Cookies and Tracking

Wayfinder uses the following technologies to enhance your experience:

• Wayfinder uses essential cookies for authentication and session management
• We use localStorage to persist your login session and UI preferences
• We do not use third-party advertising cookies
• We do not engage in cross-site tracking

2. How We Use Your Information

Providing Career Guidance

We use your profile information, interests, and goals to:

• Provide personalized career advice tailored to your situation
• Suggest relevant majors, careers, and educational paths
• Answer questions about specific careers and industries
• Help you plan your academic and professional journey

Improving Our Services

We use conversation data and usage analytics to:

• Understand how students interact with career planning
• Improve the quality and relevance of AI responses
• Identify gaps in our knowledge base
• Develop new features that better serve your needs
• Enhance the overall user experience

Account Management

We use your account information to:

• Create and maintain your account
• Authenticate your login
• Send you service-related notifications
• Process subscription payments (if applicable)
• Respond to your support requests

Research and Nonprofit Mission

As a 501(c)(3) nonprofit, we use anonymized and aggregated data to:

• Conduct research on career interests and trends among students
• Better understand barriers to career planning
• Identify underserved student populations
• Publish insights to benefit the broader education community

Essay Review Processing

We use essay content to provide AI-powered review services:

• We use essay content to generate AI-powered reviews and scores
• Essay content is processed by Wayfinder's AI engine for analysis
• Reviews are stored in your account for future reference
• Aggregated, anonymized essay data may be used to improve our review quality
• We do not share your essay content with any third party beyond what is necessary for AI processing

Deadline Reminders and Notifications

We use your admissions profile to keep you on track:

• We use your admissions profile to generate personalized deadline reminders
• We send email notifications for upcoming decision dates, application deadlines, and scholarship deadlines
• You can manage reminder preferences in your account settings

Communications

With your permission, we may send you:

• Updates about new features and improvements
• Educational content related to career planning
• Important service announcements

Legal Compliance

We may use your information when required by law or to protect our rights and the rights of other users.

3. Data Storage and Security

Where Your Data is Stored

Your data is securely stored on servers provided by Render, our hosting provider. These servers are located in secure data centers with industry-standard physical security measures. This includes:

• Essay reviews stored as JSON files on our servers
• Reminder deduplication data to prevent duplicate notifications
• Admissions profile data used for timeline generation

Password Security

We take password security very seriously:

• Passwords are never stored in plain text
• We use industry-standard hashing algorithms to encrypt passwords
• Even our administrators cannot access your password
• If you forget your password, we provide a secure reset process

Data Encryption

We protect your data in multiple layers:

• In Transit: All traffic between your device and wayfinderai.org is encrypted with TLS (HTTPS), using a certificate auto-managed by Render and renewed continuously.
• At Rest — Disk Layer: Our hosting provider, Render, encrypts the underlying persistent disk with industry-standard block-level encryption.
• At Rest — Application Layer: Sensitive personal fields on user accounts (your name, school, interests, profile, freeform notes) are additionally encrypted at the application layer with AES-256-GCM (authenticated encryption with random per-record IVs) using a key held only by the running service. Even if the underlying file contents were exposed, those fields would remain opaque ciphertext.
• Passwords: Hashed with bcrypt at 12 rounds. Never stored, logged, or transmitted in any recoverable form. Even our administrators cannot recover your password — we can only reset it.
• Backups: Daily encrypted snapshots are retained for 7 days and then automatically deleted.

Privacy by Design — Conversation Capture

Your conversations with David, our AI advisor, are persisted to support continuity and to make the system smarter for everyone over time. To protect your privacy at the source:

• PII redaction at write time: Before any conversation is written to disk, it passes through a deterministic redactor that scrubs personally identifying information — emails, phone numbers, K-12 school names, addresses, SSN-like patterns, and contextual mentions of family members' names.
• Salutation scrub: Any mention of your profile name in the AI's responses (e.g. greetings) is also scrubbed before persistence.
• Weekly automated audit: A scheduled audit re-reviews recent captures using a separate review pass, catching anything the deterministic redactor missed and patching it in place.
• What is not redacted: Public entities like college names (Stanford, MIT), companies, courses (AP Calculus, SAT), and broad geographic regions stay intact — they are the topics of conversation, not personal identifiers.

Conversation Data

Your conversation history with Wayfinder's AI advisor is stored securely on our servers. This data may be used to:

• Maintain continuity in your conversations across sessions
• Improve the AI model's ability to provide better advice
• Allow you to review past conversations and advice

Security Measures

We implement multiple security measures to protect your information:

• Daily automated security audits — rotating focus areas (auth, data integrity, code quality, performance, UX, API surface). Findings logged to AUDIT_LOG.md, fixes auto-committed.
• Daily holistic system audit — independent review of the entire codebase looking for vulnerabilities, regressions, or weaknesses.
• Input injection filter (SS-01) — every user message passes through a regex + keyword filter before reaching any model. Known prompt injection patterns are blocked with a hardcoded refusal — the model never sees them.
• Scope classifier (SS-04) — out-of-scope queries (medical, legal, financial product advice) get a hardcoded refusal with zero AI generation, eliminating both cost and the risk of off-topic responses.
• Rate limiting — per-user and per-IP caps to prevent abuse, with a hard daily ceiling on anonymous traffic.
• Admin access — restricted to a small allowlist, gated by token authentication and a separate internal-task token for scheduled automation.
• Atomic file writes — all data writes use temp-file-then-rename to prevent corruption from concurrent or interrupted writes.

3.1. Data Breach Notification Procedures

Breach Notification Commitment

In the event of a confirmed data breach involving personal information, Wayfinder is committed to notifying affected users promptly. We will notify you as soon as reasonably practical, but in no case later than 72 hours after confirming a breach.

Notification Methods

We will use multiple methods to ensure you receive breach notifications:

• Email: A detailed breach notification will be sent to the primary email address associated with your account
• In-App Notice: If you are logged into Wayfinder, you will see an urgent notification on your dashboard
• Website Notice: Information will be posted on our website and social media channels

Content of Breach Notification

Breach notifications will include:

• A description of the nature and scope of the confirmed breach
• Identification of the types of personal information affected (e.g., names, email addresses, passwords, financial information)
• Remediation steps we have taken or are taking to address the breach
• Recommended steps you should take to protect yourself
• Contact information for further assistance and questions

Investigation and Transparency

Upon discovering a suspected breach, we will:

• Conduct a prompt investigation to confirm the breach and identify affected data
• Take immediate steps to contain the breach and prevent further unauthorized access
• Preserve evidence for law enforcement cooperation if needed
• Document and communicate our findings to affected users

Law Enforcement Cooperation

If law enforcement or other government agencies request that we delay notification of a breach as part of a criminal investigation, we will comply with such requests. Once the legal hold is lifted, we will immediately notify affected users.

4. Third-Party Services

Wayfinder AI Engine

Important: Wayfinder uses a proprietary RAG-architected AI engine to power our career advisor and essay review services. When you send messages or essays to Wayfinder, your content is processed by our AI engine for analysis and personalized guidance. By using Wayfinder, you understand and consent to this data processing.

• Data Processing: Your conversation messages and essay content are processed by Wayfinder's AI engine for analysis and personalized guidance
• Data Agreement: Wayfinder has data processing agreements that govern how your data is handled and protected during AI processing
• Data Usage: Your conversation and essay data may be used in anonymized and aggregated form to improve our AI engine's performance and service quality
• Conversation Data Improvement: By default, Wayfinder conversation data may be used for model improvement purposes. However, you can opt-out of this data usage in your Settings
• Opting Out: If you opt-out of conversation data being used for Wayfinder model improvement, your data will not be used for this purpose. Opting out does not affect your access to the core Wayfinder service
• Data Retention: Wayfinder retains conversation and essay data for a limited period for safety and abuse prevention purposes. We do not use your data to train public models without your explicit consent

Stripe (Payment Processing)

If you subscribe to a premium plan or purchase essay credits, payment processing is handled by Stripe, Inc.

• Stripe is PCI-DSS Level 1 certified
• Stripe processes both recurring subscription payments and one-time essay credit purchases
• Credit card information is never stored on Wayfinder's servers
• Stripe's Privacy Policy: stripe.com/privacy

Resend (Email Service)

Wayfinder uses Resend for transactional and reminder emails.

• This includes invitation emails, deadline reminders, decision date alerts, and essay review notifications
• Resend processes your email address and name for delivery
• Resend's Privacy Policy: https://resend.com/legal/privacy-policy

Render (Hosting Provider)

Wayfinder's infrastructure is hosted by Render, which provides secure cloud hosting services.

• Render maintains industry-standard security and compliance standards
• Render's Privacy Policy: render.com/privacy

Google Fonts

We use Google Fonts to improve the visual presentation of Wayfinder. Google may collect limited technical data when you access our site. For more information: Google Privacy Policy

Third-Party Links

Wayfinder may contain links to external websites and resources. We are not responsible for the privacy practices of external websites. We encourage you to review their privacy policies before sharing your information.

5. Your Rights

Right to Access

You have the right to access the personal information we hold about you. You can:

• View your profile information by logging into your account
• Request a complete copy of your data by contacting us

Right to Correction

You can update or correct your profile information at any time by logging into your account or contacting us.

Right to Delete

You have the right to delete your account and all associated data. To delete your account:

• Log into your account and navigate to Settings
• Select "Delete Account"
• Confirm your decision
• Your data will be permanently deleted within 30 days

Right to Opt-Out

You can control how your data is used:

• Opt out of having your conversation data used to improve Wayfinder
• Opt out of promotional emails and communications
• Manage these preferences in your account settings

Right to Data Portability

You have the right to request your data in a portable format:

• Request an export of your profile information
• Request an export of your conversation history
• Data will be provided in a standard, machine-readable format

How to Exercise Your Rights

To exercise any of these rights, contact us at privacy@wayfinderai.org with your request and account details. We will respond within 30 days.

6. Children's Privacy (COPPA Compliance)

Age Requirements

Wayfinder is intended for users ages 13 and older. To use Wayfinder, you must be at least 13 years old.

Special Protections for Users Under 18

We provide special privacy protections for users under 18:

• We collect only the minimum information necessary to provide our service
• We do not sell or share your information with third parties (except as described in this policy)
• We do not use your information for targeted advertising
• Parents and guardians have the right to access, correct, and delete their child's information
• We use appropriate security measures to protect young users' data

Parental Access

If you are a parent or guardian of a Wayfinder user under 18, you have the right to:

• Access your child's account information
• Request deletion of your child's data
• Opt your child out of data usage for improvement
• Contact us with questions about your child's privacy

Parental Consent

For users under 13, we require verifiable parental consent. Parents should contact us at privacy@wayfinderai.org if:

• They wish to withdraw consent
• They want to access their child's information
• They want to delete their child's account

7. California Privacy Rights (CCPA)

Your CCPA Rights

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

Right to Know

You have the right to know what personal information is collected and how it is used.

Right to Delete

You have the right to request deletion of personal information we hold about you.

Right to Opt-Out

You have the right to opt-out of the sale of personal information. Note: Wayfinder does not sell personal information.

Right to Non-Discrimination

You have the right to non-discrimination for exercising your privacy rights. We will not discriminate against you for exercising your CCPA rights.

How to Exercise Your CCPA Rights

To exercise your CCPA rights, contact us at privacy@wayfinderai.org with the subject line "CCPA Request". We will respond within 45 days as required by California law.

8. International Data Transfers

Data Processing Location

Wayfinder is operated from the United States. Your data is processed in the United States, including:

• Account information and profile data
• Conversation history and career guidance interactions
• Essay content and review data
• Usage analytics and technical data

International Users and Data Transfer

If you access Wayfinder from outside the United States:

• Your personal data will be transferred to, stored in, and processed in the United States
• By using Wayfinder, you explicitly consent to this transfer and processing of your data in the United States
• Data protection laws in the United States may differ from those in your country or jurisdiction

EU and EEA Users

For users in the European Union and European Economic Area:

• We acknowledge that US data protection standards may differ from GDPR and other European data protection requirements
• Where applicable, we apply Standard Contractual Clauses (SCCs) to govern international data transfers
• By using Wayfinder, you acknowledge the differences in data protection frameworks and consent to your data being processed in the United States
• You retain all rights under applicable data protection laws in your jurisdiction

Your Consent

By creating an account and using Wayfinder as an international user, you explicitly consent to:

• The transfer of your personal data to the United States
• Processing of your data according to this Privacy Policy and applicable US law
• The potential differences in data protection standards between your country and the United States

9. GDPR Rights (European Users)

Applicability

If you are located in the European Union (EU), European Economic Area (EEA), or the United Kingdom (UK), you have additional rights under the General Data Protection Regulation (GDPR) and equivalent UK data protection laws. This section supplements the rights described elsewhere in this Privacy Policy.

Legal Basis for Processing

We process your personal data on the following legal bases:

• Consent: Where you have given us explicit consent to process your data for specific purposes (e.g., using your conversation data to improve Wayfinder). You may withdraw consent at any time without affecting the lawfulness of processing performed before withdrawal.
• Contract Performance: Where processing is necessary to provide you the Wayfinder service you have signed up for, including account management, career guidance delivery, and subscription management.
• Legitimate Interest: Where processing is necessary for our legitimate interests (e.g., service improvement, fraud prevention, platform security) and these interests are not overridden by your data protection rights.
• Legal Obligation: Where we are required to process data to comply with applicable laws or regulations.

Your GDPR Rights

In addition to the rights described in Section 5, EU/EEA/UK users have the following specific rights:

• Right to Restrict Processing: You have the right to request that we restrict the processing of your personal data in certain circumstances, such as when you contest the accuracy of data or object to processing.
• Right to Object: You have the right to object to processing of your personal data based on legitimate interests. Upon receiving an objection, we will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right Not to Be Subject to Automated Decision-Making: You have the right not to be subject to decisions based solely on automated processing that produce legal or similarly significant effects. See the Automated Decision-Making section below for more detail.
• Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority in your country of residence if you believe our processing of your personal data violates applicable data protection law.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw consent at any time via your account settings or by contacting us. Withdrawal does not affect the lawfulness of processing conducted prior to withdrawal.

Data Protection Contact

For GDPR-related inquiries, requests, or complaints, please contact our data protection team at privacy@wayfinderai.org with the subject line "GDPR Request". We will respond to all GDPR requests within 30 days. If we need additional time (up to 60 additional days for complex requests), we will inform you within the initial 30-day period.

International Transfers and Safeguards

Your data is transferred to and processed in the United States. To provide appropriate safeguards for these transfers, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission. You may request a copy of the applicable SCCs by contacting us at privacy@wayfinderai.org.

10. Automated Decision-Making

How We Use Automated Processing

Wayfinder uses AI-powered automated processing in the following ways:

• Career Guidance: Wayfinder's AI engine generates personalized career advice based on your profile and conversation history. This is informational only and does not produce legally binding or similarly significant effects.
• Essay Review Scoring: Essays are scored by AI using automated criteria. Scores are advisory and informational; they are not used for any admissions decisions and have no binding effect.
• Usage Limits: Your subscription plan determines automated rate limits and feature access. This is based on your selected plan tier, not profiling.
• Account Lockout: Repeated failed login attempts trigger automated temporary lockouts for security purposes.

No Solely Automated Decisions with Legal Effect

Wayfinder does not make decisions based solely on automated processing that produce legal effects or similarly significant effects concerning you. All AI-generated outputs (career advice, essay scores, admissions strategy suggestions) are informational and advisory only. No automated decision by Wayfinder will affect your legal rights, financial standing, or access to services beyond the scope of the Wayfinder platform itself.

Your Right to Human Review

You have the right to request human review of any automated output. If you believe an automated decision has adversely affected you, contact us at support@wayfinderai.org and we will arrange for a human review of the matter.

11. Data Retention

Data Anonymization Definition

Throughout this Privacy Policy, we reference anonymized or aggregated data. We define anonymization as:

• Irreversible Removal: The permanent and irreversible removal of all personally identifiable information that could directly identify an individual
• No Re-Identification: After anonymization, data cannot be linked back to or associated with any individual person
• Process Includes:
  • Removal of names, email addresses, and usernames
  • Removal of specific school names and identifiable institution information
  • Removal of specific geographic identifiers (exact addresses, unique location data)
  • Removal of dates of birth and other identifiers that could pinpoint individuals
  • Removal of conversation content that contains personal identifiers
• Aggregated Use: Anonymized data may be used for statistical analysis, research, and service improvement without risk of individual re-identification

Active Accounts

As long as your account is active, we retain all your information:

• Account information (name, email, profile)
• Conversation history and career planning data
• Usage analytics and preferences

Deleted Accounts

When you delete your account:

• Your data is marked for deletion immediately
• Complete deletion occurs within 30 days
• Backups containing your data are deleted within 90 days
• Anonymized, aggregated data may be retained for research purposes

Conversation History

Your conversation history is retained to:

• Allow you to review past advice and recommendations
• Improve the AI's ability to provide better guidance
• Provide continuity across sessions

You can delete individual conversations or your entire conversation history at any time through your account settings.

Legal Retention

We may retain data longer than specified above if required by law or legal processes.

12. Changes to This Policy

Updates and Notifications

Wayfinder may update this Privacy Policy from time to time to reflect:

• Changes in our data practices
• New features or services
• Legal or regulatory requirements
• Industry best practices

How We Notify You

When we make material changes to this policy, we will:

• Update the "Last Updated" date at the bottom of this page
• Notify you via email to your registered email address
• Display a prominent notice on the Wayfinder platform
• Require your acceptance of the updated policy

Your Continued Use

Your continued use of Wayfinder after changes become effective constitutes your acceptance of the updated Privacy Policy. If you disagree with any changes, you may delete your account.

13. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

Privacy Requests

When submitting a privacy request, please include:

• Your name and registered email address
• Your Wayfinder user ID (if applicable)
• A clear description of your request
• Any relevant account information

About Virtuous Capital Foundation

Virtuous Capital Foundation is a 501(c)(3) nonprofit organization dedicated to supporting career planning and educational advancement for pre-college and college students. We are committed to protecting your privacy while advancing our mission to provide equitable access to career guidance.