Privacy
Privacy Policy
Effective as of 12/09/2024
Willo 32, Inc. (“Willo”, “we”, “us” or “our”) provides a mobile application that allows parents and legal guardians (“Guardians”) to monitor their child’s (“Child” or “Children”) brushing activities to improve their child's brushing habits and provides them with personalized brushing information based on their children's brushing data. Guardians can also allow other family members or adults (“Authorized Adults”) to create profiles to monitor their Child’s brushing data. This Privacy Policy describes how Willo handles personal information that we collect through our Willo Toothbrush, mobile application and other digital properties that link to this Privacy Policy (collectively, the “Service”). We may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information.
Index
Personal information we collect
How we use your personal information
How we share your personal information
Retention
Your choices
Other sites and services
Security
International data transfer
Children’s privacy
Changes to this Privacy Policy
How to contact us
Personal information we collect
Information you provide to us. Please note that the information we may collect from you may vary depending on how you interact with the Service. We have outlined these differences below.
Personal information you may provide to us as a Guardian or an Authorized Adult through the Service or otherwise includes:
- Contact data, such as your first and last name and email address.
- Demographic data, such as your city, state, country of residence, postal code, and age.
- Communications data based on our exchanges with you, including when you contact us through the Service or otherwise.
- Research data, such as your responses to surveys that we might ask you to complete for research purposes related to our business.
- Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
- Profile data, such as the username and password that you may set to establish an online account on the Service, photograph or picture, interests, preferences, information about your participation in our contests, promotions, or surveys, and any other information that you add to your account profile.
- Relationship data, such as familial or other relationship to third parties whose personal information you may provide to us.
- Promotion data, including information you share when you enter a competition, promotion or complete a survey. Please note that if you participate in a sweepstakes, contest or giveaway through the Service, we may ask you for your Contact Data to notify you if you win or not, to verify your identity, determine your eligibility, and/or to send you prizes. In some situations, we may need additional information as a part of the entry process, such as a prize selection choice. These sweepstakes and contests are voluntary. We recommend that you read the rules and other relevant information for each sweepstakes and contest that you enter.
- User-generated content data, such as comments, questions, messages, 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.
- Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
Personal information you may provide to us as a Child through the Service or otherwise includes:
- Contact data, such as your first and last name.
- Communications data based on our exchanges with you on the Service, including when you contact us through the Service, social media, or otherwise.
- Research data, such as your responses to surveys that we might ask you to complete for research purposes related to our business.
- Profile data, such as the username and password that you may set to establish an online account on the Service, mouthpiece size, photograph, picture or avatar, age, interests, preferences, information about your participation in our contests, promotions, or surveys, and any other information that you add to your account profile.
- Brushing data, such as brushing history, toothbrush type (model number, serial number, firmware version, manufacturer), brushing duration, brushing frequency, brushing start time and intensity.
- User-generated content data, such as photos, images, comments, questions, messages, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata.
- Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
Automatic data collection. We, our service providers, and our business partners may automatically log information about Guardians, Authorized Adults, and Children, your mobile device, and your interaction over time with the Service and our communications such as:
- Device data, such as your mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or general geographic area.
- Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
- Location data when you authorize (our mobile application) to access your device’s location.
- Communication interaction data such as your interactions with our email or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.
Cookies and similar technologies. Some of the automatic collection described above is facilitated by the following technologies:
- Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of the application in connection with specific applications.
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 and operate the Service and our business;
- personalize the service, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Service;
- identify usage trends to better understand how you use the Services and how we can improve them.
- establish and maintain your user profile on the Service;
- enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
- communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages;
- communicate with you about , in which you participate;
- understand your needs and interests, and personalize your experience with the Service and our communications; and
- provide support for the Service, and respond to your requests, questions and feedback.
Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We make personal information into anonymous or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
Marketing. We, our service providers and our third-party partners may collect and use your personal information for marketing purposes:
- Direct marketing (GUARDIANS AND AUTHORIZED ADULTS ONLY). If you are a Guardian or an Authorized Adult we may send you direct marketing communications. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.
Events, promotions and contests. We may use your personal information to:
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 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.
With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
Cookies and similar technologies. In addition to the other uses included in this section, we may use the Cookies and similar technologies described above for the following purposes:
- Technical operation. To allow the technical operation of the Service.
- Functionality. To enhance the performance and functionality of our services.
- Analytics. To help us understand user activity on the Service, including which features are most and least used and how visitors move around the Service, as well as user interactions with our emails.
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, to establish or defend 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.
How we share your personal information
We may share your personal information with the following parties and as otherwise described in this Privacy Policy 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, artificial intelligence and large language modeling, customer support, email delivery, consumer research, marketing, and website analytics).
Third parties designated by you. We may share your personal data with third parties where you have instructed us or provided your consent to do so. We will share personal information that is needed for these other companies to provide the services that you have requested.
Business and marketing partners. Third parties with whom we co-sponsor events, with whom we jointly offer products or services, or whose products or services may be of interest to you.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary 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. Acquirers and other relevant participants in business transactions (or negotiations of or due diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Willo (including, in connection with a bankruptcy or similar proceedings).
We make commercially reasonable efforts to verify that the parties with whom our mobile application shares personal information provide a level of protection of personal information consistent with the practices described in this Privacy Policy, except that all such parties described above other than service providers may, to the extent permitted by law, use personal information as described in their own privacy policies.
Your choices
In this section, we describe the choices available to you.
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 marketing 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.
Blocking images/clear gifs: Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.
Mobile location data. You can disable our access to your device’s precise geolocation in your mobile device settings.
You will need to apply these opt-out settings on each device and browser from which you wish to limit the use of your information for interest-based advertising purposes. We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above.
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.
Delete your content or close your account. You can choose to delete certain content through your account. If you wish to request to close your account, please contact us.
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 that are designed to protect the personal information we collect. 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 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.
Children’s privacy
The Service is intended to be used by Guardians, Authorized Adults, and Children. A user of the Service who is under the age of 13 (“Child User”) may use the Service only with the express prior consent of a parent or legal guardian. Please contact us at privacy@willo.com if you believe we have collected information from a Child User without consent from a Guardian or if you wish to withdraw consent for further collection or use of a Child User’s information. If we learn that we have collected information about a Child User without the consent of a Guardian as required by law, we will use commercially reasonable efforts to delete such information as soon as possible and take any other measures required by applicable law.
How does a Child User access the Service?
After our app is installed, a Guardian with a verified email address must create an account, and provide their consent in accordance with applicable law before a Child User may access the Service. The application will remain logged in as that Child User until uninstalled, or the Child User logs out. To log in again, parental permission will be requested.
Accessing a Child User’s Personal Information
Guardians can review, access, or delete their Child User’s personal information by contacting us via email or logging into their account.
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 your acceptance of the modified Privacy Policy.
How to contact us
To exercise your choices or if you have questions about this Privacy Policy or our privacy practices, please contact us at:
- Email: privacy@willo.com
- Mail: Willo 32, Inc.
115 Broadway Street, 5th Floor
Willo c/o WeWork
New York, NY 10006
United States