Willo App Product Privacy Policy

Effective as of 11/24/25

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 under the originating account 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 for specific products or services at the time we collect personal information.

Index

Personal information we collect

Information you provide to us. The information we may collect from you varies depending on how you interact with the Service.

Personal information you may provide as a Guardian or Authorized Adult includes:

  • Contact data, such as your first and last name, phone number, billing and mailing address, 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 responses to surveys we may ask you to complete for research purposes.
  • Marketing data, such as your preferences for receiving marketing communications and details about your engagement with them.
  • Account data, such as your username and password, photo, interests, preferences, and information about your participation in contests, promotions, or surveys, as well as any information added to your profile.
  • Relationship data, such as your familial or other relationship to third parties whose information you provide.
  • Promotion data, including information shared when entering a competition, promotion, sweepstakes, or survey. This may include Contact Data to notify you if you win, verify identity, determine eligibility, or send prizes. Some promotions may require additional information. Participation is voluntary.
  • User-generated content data, such as comments, questions, messages, and other content you generate or submit, plus metadata (e.g., timestamps, format, keywords, and location information).
  • 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 collected from or about your Child may include:

  • Contact data, such as first and last name.
  • Research data, such as survey responses.
  • Account data, such as username, password, mouthpiece size, photo or avatar, age, interests, preferences, and any contest or promotion participation information.
  • Brushing data, such as brushing history, toothbrush type (model number, serial number, firmware, manufacturer), brushing duration, frequency, start time, and intensity.
  • Willo Toothbrush data, such as usage logs, button presses, error logs, and reboot information.
  • User-generated content data, such as photos, images, comments, messages, and related metadata.
  • Other data not specifically listed here.

Third-party sources. We may combine information received from Guardians, Authorized Adults, and Children with information from:

  • Public sources, such as government agencies, public records, social media, and other publicly available sources.
  • Data providers, such as demographic and information services.
  • Marketing partners, such as joint marketing partners and co-sponsors.

Automatic data collection. We, our service providers, and business partners may automatically log information about your device and interactions with the Service, including:

  • Device data, such as operating system, browser type, model, unique identifiers, IP address, language settings, carrier, and general location.
  • Online activity data, such as pages viewed, time spent, referring pages, navigation paths, access times, and email interaction data.
  • Location data, when you allow the app to access your device’s location.
  • Communication interaction data, such as email opens or forwards, collected via pixel tags.

Cookies and similar technologies

  • Local storage technologies, like HTML5, which provide cookie-like functionality but can store larger amounts of data.

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 devices you have previously used and remembering your selections and preferences;
  • identify usage trends to better understand how you use the Service and how we can improve it;
  • establish and maintain your user profile on the Service;
  • enable security features, such as sending security codes via email or SMS and remembering trusted devices;
  • communicate with you about the Service, including announcements, updates, alerts, and support messages;
  • communicate with you about events in which you participate;
  • understand your needs and interests to personalize your experience and communications;
  • provide support and respond to 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 anonymous data by removing information that identifies you. We may use or share this data for lawful purposes, including analysis and improving the Service.

Marketing. We, our service providers, and third-party partners may collect and use personal information for marketing purposes:

  • Direct marketing (GUARDIANS AND AUTHORIZED ADULTS ONLY). If you are a Guardian or Authorized Adult, we may send you direct marketing communications. You may opt-out as described in the Your choices section.

Events, promotions and contests. We may use your personal information to:

  • administer promotions and contests;
  • communicate with you about promotions or contests in which you participate;
  • contact or market to you after collecting your personal information at an event.

Compliance and protection. We may use your personal information to:

  • comply with applicable laws, lawful requests, and legal processes (e.g., responding to subpoenas);
  • protect our, your, or others’ rights, privacy, safety, or property (including making and defending legal claims);
  • audit internal processes for compliance with legal or internal requirements;
  • enforce the Service’s terms and conditions;
  • 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 ask for your consent to collect, use, or share your personal information when required by law.

Cookies and similar technologies. In addition to the above uses, we may use the technologies described in Cookies and similar technologies for:

  • Technical operation. To enable the technical operation of the Service.
  • Functionality. To enhance performance and functionality.
  • Analytics. To understand user activity, including feature usage, navigation, and email interactions.

Retention

We generally retain personal information to fulfill the purposes for which we collected it, including satisfying legal, accounting, or reporting requirements, establishing or defending legal claims, or for fraud prevention.

To determine appropriate retention periods, we may consider factors such as the amount and sensitivity of the personal information, potential risks of unauthorized use, the purposes for processing, whether the purposes can be met by other means, and applicable legal requirements.

When we no longer require personal information, we may 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 operate the Service or our business (e.g., hosting, IT, AI and language modeling, customer support, email delivery, research, marketing, analytics).

Third parties designated by you. We may share personal data with third parties when you instr

Your choices

In this section, we describe the choices available to you.

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

Opt-out of marketing communications. You may opt-out of marketing-related emails by following the unsubscribe instructions included in those emails or by contacting us. Please note that you may continue to receive service-related and other non-marketing emails.

Blocking images / clear GIFs. Most browsers and devices allow you to disable images from loading. To do so, follow the instructions in your browser or device settings.

Mobile location data. You may disable our access to your device’s precise geolocation through your mobile device settings.

You must apply opt-out settings on each device and browser you use. We cannot guarantee whether the companies we work with participate in the opt-out programs described above.

Declining to provide information. Certain services require personal information in order to function. If you do not provide required information, we may be unable to provide those services.

Delete your content or close your account. You may delete certain content through your account. If you wish to request account closure, please contact us.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. Our content may also be integrated into third-party web pages or online services. These links and integrations do not constitute endorsements, nor do they indicate affiliation. We do not control third-party services and are not responsible for their actions. We encourage you to read their privacy policies.

Security

We employ technical, organizational, and physical safeguards designed to protect the personal information we collect. However, no security measures are perfect, 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 operating in other countries. Your personal information may be transferred to the United States or other jurisdictions 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 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 required consent or if you wish to withdraw consent. If we learn that we have collected information about a Child User without required consent, we will use commercially reasonable efforts to delete that information.

How does a Child User access the Service?

After the app is installed, a Guardian with a verified email address must create an account and provide 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 until the Child User logs out. To log in again, the Guardian must sign in using their verified email and credentials.

Accessing a Child User’s personal information.

Guardians may review, access, or delete their Child User’s personal information by contacting us via email or by 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, we will notify you by updating the effective date at the top of this Privacy Policy and posting it on the Service or through other appropriate means. Any modifications will be effective upon posting (or as otherwise indicated at the time of posting). Your continued use of the Service after the effective date of any modified Privacy Policy indicates your acceptance of the modified version.

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