Privacy Policy

1. Introduction

Welcome to Willo – Fitness on Autopilot (“Willo,” “we,” “us,” or “our”).

Willo is an AI-powered fitness and wellness application designed to help users plan workouts, track physical activity, monitor nutrition, establish fitness routines, and receive personalized guidance.

We recognize that privacy is particularly important when an application processes information relating to health, fitness, nutrition, and personal well-being.

This Privacy Policy explains how we collect, use, store, disclose, protect, and otherwise process personal information when you access or use:

• The Willo mobile application (the “App”);
• Our website and associated webpages (the “Website”);
• Our AI-powered coaching, workout, and nutrition features;
• Our customer support and communications; and
• Any related services we provide (collectively, the “Services”).

This Privacy Policy also explains your rights and choices regarding your personal information.

By using Willo, you acknowledge that you have been provided with this Privacy Policy. Where applicable law requires consent for particular processing activities, we will seek that consent separately.

Our Services are intended exclusively for individuals aged 18 or older.

If you do not agree with our Terms of Use, you should not use the Services.

2. Who We Are

Willo is operated by:

Legal Entity: Willo

Country of Establishment: Israel

Privacy Contact: hello@willo.fitness

Website: willo.fitness

For applicable privacy laws, the operating entity identified above is generally responsible for determining the purposes and means of processing personal information collected through Willo.

Certain third-party providers may independently determine how they process information for their own legally permitted purposes.

You may contact us using the information above with questions about this Privacy Policy or our privacy practices.

3. Information We Collect

We collect information that you provide directly, information generated through your use of the Services, information obtained through integrations you authorize, and certain information collected automatically.

The categories described below may vary depending on the features you use.

3.1 Account and Authentication Information

When you create or access a Willo account, we may process:

• Email address;
• Name or display name;
• Authentication identifiers;
• Firebase user identifier;
• Authentication provider information;
• Sign-in method; and
• Information necessary to maintain and secure your account.

Willo supports email-based authentication and Sign in with Apple.

Authentication information may be processed by Firebase Authentication and, where applicable, Apple.

We do not require access to your Apple ID password.

3.2 Personal Profile and Fitness Information

When you complete onboarding, configure your profile, or use personalization features, we may collect:

• Age;
• Sex or gender selection;
• Height;
• Weight;
• Goal weight;
• Body measurements;
• Body-fat information or estimates;
• Fitness goals;
• Desired weight-change rate;
• Training experience;
• Preferred workout frequency;
• Preferred workout duration;
• Workout location;
• Available exercise equipment;
• Preferred exercises and activities;
• Muscle-group preferences;
• Dietary preferences;
• Food dislikes;
• Food allergies; and
• Measurement-unit preferences.

Certain information is optional and may be updated through available profile settings.

We use this information primarily to provide personalized fitness, activity, and nutrition functionality.

3.3 Health-Related Information

Depending on the information you choose to provide, Willo may process health-related information, including:

• Injuries or physical limitations;
• Injury descriptions and severity;
• Allergy information;
• Health-related profile preferences;
• Information about medical clearance, where provided;
• Pregnancy-related information, where applicable;
• Weight history;
• Exercise performance;
• Physical activity records; and
• Other health-related details voluntarily included in messages or interactions with Willo.

Some of this information may qualify as sensitive personal information or special-category personal data under applicable law.

We process such information to provide requested features, personalize recommendations, account for relevant limitations, and support your fitness and wellness activities.

Where required by applicable law, we will obtain explicit consent or establish another appropriate legal basis before processing sensitive personal information.

You should avoid providing medical information that is unnecessary for your use of the Services.

3.4 Workout and Activity Information

When you use Willo’s fitness features, we may collect or generate:

• Workout plans and schedules;
• Completed and skipped workouts;
• Exercise selections;
• Sets and repetitions;
• Exercise weights;
• Workout duration;
• Personal records;
• Fitness goals and progress;
• Activity types;
• Activity duration;
• Estimated calories burned;
• Running and other activity metrics;
• Workout notes;
• Routine adherence; and
• Related performance information.

We use this information to track progress, generate recommendations, maintain workout history, and personalize future workouts.

3.5 Nutrition and Meal Information

When you use Willo’s nutrition features, we may process:

• Meal descriptions;
• Food names and quantities;
• Calorie estimates;
• Protein and other nutritional information;
• Nutrition targets;
• Dietary preferences;
• Meal history;
• Custom food entries;
• Barcode-related food information;
• Meal photographs submitted for analysis; and
• Corrections or modifications to AI-generated nutrition estimates.

Nutrition information may be entered manually or generated through AI-assisted features.

AI-generated nutritional values are estimates and may be inaccurate.

Meal photographs submitted for AI analysis are processed to identify foods and estimate nutritional information.

According to the implementation reviewed, Willo does not intentionally retain the original meal photograph in its application database after processing. However, the photograph is transmitted to the AI service used to analyze it, and that provider may retain information according to its applicable data-handling practices.

3.6 AI Coaching and Conversation Information

When you interact with Willo’s AI-powered features, we may process:

• Messages you submit;
• Relevant recent conversation history;
• AI-generated responses;
• Requests to modify workouts;
• Exercise-related questions;
• Nutrition-related questions;
• Relevant fitness goals;
• Relevant workout information;
• Relevant daily nutrition summaries;
• Daily check-in information; and
• Other contextual information needed to respond to your request.

For example, when you ask Willo for coaching assistance, the application may include relevant workout, nutrition, goal, or mood information in the request sent to its AI provider.

We use this information to generate personalized responses and perform requested actions.

AI conversations may be stored in your Willo account to maintain conversational continuity and support the Services.

Willo may limit the amount of conversation history retained or included in individual AI requests.

3.7 Mood and Daily Check-In Information

If you use daily check-in features, we may collect your selected mood or similar self-reported information.

This information may be used to personalize coaching responses, understand your current experience, and provide relevant motivational or fitness guidance.

3.8 Apple Health Information

With your permission, Willo may access certain information through Apple HealthKit.

The current integration requests read access to:

• Daily step counts; and
• Active energy burned.

Willo may retrieve recent historical data, including approximately the previous 30 days, when synchronizing Apple Health information.

This information may be transmitted to and stored on Willo’s servers to provide activity history, progress tracking, and related fitness functionality.

Willo does not currently write information to Apple Health through this integration.

Apple Health access is optional.

You can manage or revoke Willo’s HealthKit permissions through your device’s Apple Health or system privacy settings.

Disabling Apple Health integration within Willo stops future synchronization through that integration but does not necessarily delete information previously synchronized to Willo’s servers.

Previously synchronized server-side information is deleted through the account deletion process, subject to the retention exceptions described in this Policy.

We do not use information obtained from Apple HealthKit for targeted advertising, advertising measurement, or sale to data brokers.

We do not intentionally disclose HealthKit-derived information to advertising platforms.

3.9 Device and Technical Information

When you use Willo, we may collect or process technical information, including:

• Device and installation identifiers;
• Operating system and version;
• Application version and build number;
• Device language and locale;
• Time zone;
• Notification permission status;
• Push notification tokens;
• Application activity;
• Technical events;
• Authentication-related information; and
• Diagnostic or operational information.

Certain information may be collected automatically by the operating system, Firebase, or other infrastructure providers.

We use technical information to operate, secure, maintain, troubleshoot, and improve the Services.

3.10 Analytics and Usage Information

Willo uses Firebase Analytics to understand how users interact with the App.

Information processed through analytics may include:

• Account creation and sign-in events;
• Onboarding progress;
• Feature usage;
• Workout logging events;
• Meal logging events;
• Activity categories;
• Selected mood categories;
• AI feature usage;
• Subscription screen interactions;
• App engagement information;
• Device and application information; and
• Other technical information automatically collected by the analytics SDK.

Willo may associate analytics events with a Firebase user identifier.

According to the application implementation reviewed, Willo does not intentionally include raw meal photographs, conversation text, weight measurements, step counts, or calorie values in its custom Firebase Analytics event parameters.

However, Firebase may automatically collect additional technical and usage information according to its SDK functionality and configuration.

We do not intentionally use HealthKit-derived data for advertising or analytics purposes prohibited by Apple’s applicable requirements.

3.11 Subscription Information

If you purchase a Premium subscription through the App, your purchase is processed through Apple’s in-app purchase system.

Willo may access information necessary to determine your subscription entitlement, such as:

• Purchased subscription product;
• Subscription status;
• Subscription duration; and
• Subscription expiration information.

Apple processes payment information according to its own terms and privacy practices.

Willo does not directly collect or store your complete payment card details through Apple’s in-app purchase process.

3.12 Website and Waitlist Information

When you visit our Website or join our waitlist, we may collect:

• Email address;
• Information submitted through website forms; and
• Information identifying the form or page through which you subscribed.

Our website uses Loops to process waitlist registrations.

Loops may process submitted information and associated technical information according to its applicable terms and privacy practices.

Additional technical information, such as IP addresses and server request information, may be processed by website hosting or infrastructure providers.

If we introduce additional website analytics, advertising technologies, or cookies, we will update our disclosures and provide any notices or choices required by applicable law.

4. How We Use Personal Information

We process personal information for the following purposes.

4.1 Providing the Services

To:

• Create and maintain accounts;
• Authenticate users;
• Generate workout plans;
• Track fitness activities;
• Maintain nutrition logs;
• Display progress;
• Calculate fitness and nutrition targets;
• Provide AI coaching;
• Process meal photographs;
• Synchronize authorized Apple Health information;
• Manage subscriptions; and
• Deliver requested features.

4.2 Personalization

To tailor workout plans, nutrition targets, coaching responses, activity recommendations, and other features based on your preferences, goals, and relevant information.

Personalization may involve automated analysis of your activity history, profile, and interactions.

4.3 Communications

To send:

• Workout reminders;
• Activity notifications;
• Progress-related notifications;
• Service announcements;
• Account-related communications;
• Security notifications; and
• Support responses.

Where permitted and appropriately authorized, we may also send marketing communications.

You can manage push notification permissions through your device settings and available Willo preferences.

Marketing emails, where provided, will include an applicable unsubscribe mechanism.

4.4 Improving the Services

To understand feature usage, identify technical issues, improve application performance, and develop better user experiences.

We seek to limit the information used for these purposes to what is reasonably necessary.

4.5 Security and Abuse Prevention

To:

• Protect accounts;
• Detect unauthorized access;
• Prevent misuse;
• Investigate technical incidents;
• Maintain system integrity; and
• Enforce applicable agreements.

4.6 Legal Compliance

To comply with applicable laws, respond to lawful requests, protect legal rights, and fulfill legitimate legal obligations.

5. Legal Bases for Processing

Where applicable data protection laws require a legal basis for processing, we rely on one or more of the following grounds, as appropriate:

Performance of a contract: Processing necessary to provide the Services you request, including account management, workout tracking, and personalized functionality.

Consent: Processing that requires your permission, including certain sensitive-data processing, optional integrations, or marketing activities.

Legitimate interests: Processing reasonably necessary for security, fraud prevention, troubleshooting, and service improvement, where those interests are not overridden by your rights.

Legal obligations: Processing necessary to comply with applicable laws and lawful requirements.

Where we rely on consent, you may withdraw that consent through available controls or by contacting us, subject to applicable law.

Withdrawal of consent does not affect the lawfulness of processing performed before withdrawal.

Different processing activities may rely on different legal bases.

6. Artificial Intelligence and Automated Processing

Willo uses artificial intelligence to provide features such as:

• Personalized fitness guidance;
• Workout-related assistance;
• Exercise recommendations;
• Nutrition interpretation;
• Meal photograph analysis;
• Natural-language interactions; and
• Other requested coaching functionality.

6.1 AI Service Provider

Willo currently uses OpenAI to process requests for AI-powered features.

Depending on the feature, information transmitted to OpenAI may include:

• User-submitted text;
• Meal descriptions;
• Meal photographs;
• Relevant conversation history;
• Workout information;
• Fitness goals;
• Nutrition summaries;
• Mood information; and
• Other context necessary to fulfill the request.

Not every AI request contains every category of information.

We seek to transmit information relevant to the requested feature rather than unnecessarily transmitting complete user profiles.

6.2 AI Provider Data Practices

Willo uses OpenAI’s API services.

Under OpenAI’s published API data controls, API customer content is not used to train OpenAI’s models by default unless the customer affirmatively opts into applicable data-sharing arrangements.

OpenAI may nevertheless process and temporarily retain API content for purposes such as abuse monitoring, security, and service operation, subject to its applicable policies, agreements, configurations, and legal obligations.

Certain API features may involve additional application-state retention.

Willo does not control every aspect of OpenAI’s infrastructure or independently determine OpenAI’s retention practices.

We encourage users to avoid submitting unnecessary sensitive information through AI conversations.

6.3 AI Accuracy and Limitations

AI-generated content may contain errors, omissions, or inaccurate estimates.

Willo’s AI functionality is intended to support general fitness and wellness activities.

It is not intended to replace professional medical advice, diagnosis, or treatment.

Users should exercise independent judgment and seek qualified professional guidance when appropriate.

Further limitations are described in our Terms of Use.

6.4 Automated Personalization

Willo uses automated processing to generate and adapt fitness-related recommendations.

These processes may consider your profile, goals, preferences, activity history, and other relevant information.

Such processing is intended to provide personalized wellness functionality, not to make decisions concerning employment, credit eligibility, insurance eligibility, or similarly significant matters.

7. How We Share Personal Information

We do not sell personal information to data brokers.

We may disclose personal information to the following categories of recipients when necessary for the purposes described in this Policy.

7.1 Cloud Infrastructure Providers

We use cloud infrastructure and database services to operate Willo.

These may include:

• Amazon Web Services;
• MongoDB-related database infrastructure; and
• Supporting hosting, caching, storage, and networking services.

These services may process account identifiers, application records, technical information, and other information necessary to provide their functions.

7.2 Authentication, Analytics, and Notification Providers

We use Firebase and related Google services for functions including:

• Authentication;
• Application analytics; and
• Push notification delivery.

Firebase may process account identifiers, device information, analytics events, push notification tokens, and related technical information.

Push notifications may also be processed through Apple’s notification infrastructure.

7.3 Artificial Intelligence Providers

We disclose information to OpenAI as described in Section 6.

7.4 Apple Services

Apple may process information associated with:

• Sign in with Apple;
• Apple Health permissions;
• Speech recognition;
• Push notifications; and
• In-app purchases.

These activities are subject to Apple’s applicable privacy practices.

7.5 Email and Website Service Providers

We use Loops to process website waitlist submissions and related communications.

7.6 Legal and Safety Disclosures

We may disclose information where reasonably necessary to:

• Comply with applicable law;
• Respond to valid legal process;
• Protect the rights and safety of users or others;
• Investigate suspected fraud or misuse; or
• Establish, exercise, or defend legal claims.

We assess such requests according to applicable legal requirements.

7.7 Business Transfers

If Willo undergoes a merger, acquisition, financing transaction, reorganization, or sale of assets, personal information may be disclosed or transferred as part of that transaction, subject to applicable law and appropriate safeguards.

We will provide notice where legally required.

8. Health Data and Special Protections

We recognize the sensitivity of health-related information.

We use health-related information to provide requested fitness, nutrition, and wellness functionality.

We do not intentionally use information obtained through Apple HealthKit for:

• Targeted advertising;
• Advertising profiling;
• Sale to data brokers; or
• Unrelated commercial exploitation.

Access to Apple Health information requires authorization through Apple’s permission system.

You may revoke permissions through Apple Health or your device settings.

Information you voluntarily provide directly to Willo, including injury details, weight information, or dietary restrictions, may be processed separately from HealthKit information.

We seek to apply appropriate protections to sensitive information and limit access to individuals and service providers with a legitimate operational need.

9. Data Storage and Security

Willo uses technical and organizational measures intended to protect personal information against unauthorized access, loss, alteration, misuse, and disclosure.

These measures may include:

• Authentication controls;
• Access restrictions;
• Secure communication protocols;
• Protected application credentials;
• Server-side authorization;
• Restricted access to operational systems; and
• Security monitoring and maintenance.

Authentication is managed through Firebase Authentication.

Certain information may also be stored locally on your device to support application functionality.

For example, Willo may store application preferences, cached profile information, and widget-related information on the device.

Some locally stored information may remain until it is cleared through the application’s normal operation, account-related actions, or device controls.

No method of electronic storage or transmission is completely secure.

Although we take reasonable steps to protect information, we cannot guarantee absolute security.

If we become aware of a security incident involving personal information, we will assess and respond to it in accordance with applicable law.

10. International Data Processing and Transfers

Willo may use service providers that operate in countries different from your country of residence.

Depending on our infrastructure configuration and the services used, personal information may be processed or stored in countries where our cloud, authentication, analytics, AI, and communication providers operate.

These countries may have data protection laws different from those in your jurisdiction.

Where applicable law requires safeguards for international transfers, we will use appropriate transfer mechanisms or other lawful arrangements.

Such mechanisms may include contractual protections, adequacy decisions, or other measures recognized under applicable law.

We do not represent that all personal information is stored exclusively in your country of residence.

11. Data Retention

We retain personal information for as long as reasonably necessary to provide the Services, fulfill the purposes described in this Policy, comply with applicable legal obligations, resolve disputes, and protect legitimate interests.

Retention depends on the category of information and the purpose for which it is processed.

11.1 Account and Profile Information

Account and profile information is generally retained while your account remains active, unless you delete particular information or request account deletion.

11.2 Fitness and Nutrition History

Workout records, activity history, body measurements, nutrition logs, and related information may be retained while your account remains active to provide progress tracking and historical functionality.

11.3 AI Conversations

Conversation history may be retained to support continuity and personalization.

Willo may limit stored conversation history by message count or other technical controls.

11.4 Temporary Processing Data

Certain temporary records, including AI-assisted meal drafts and action proposals, may have application-level expiration periods.

Expiration settings do not necessarily mean that every associated record is physically deleted at the exact expiration time.

11.5 Analytics and Technical Information

Analytics, security, and technical records may be retained according to operational requirements and applicable third-party service settings.

11.6 Backups and Logs

Some information may remain temporarily in backups, security logs, or provider-managed systems after deletion from active application databases.

Such information may be retained where necessary for security, recovery, legal compliance, or other lawful purposes.

We do not guarantee immediate deletion from every backup or independently operated third-party system.

When information is no longer required, we take appropriate steps to delete it, anonymize it, or otherwise handle it according to applicable law.

12. Account Deletion

Willo provides an in-app account deletion feature.

You may initiate account deletion through the account management controls available in the App.

When you request account deletion, Willo initiates deletion of the personal information associated with your account from its active application systems, including applicable:

• Account and profile records;
• Workout and activity history;
• Nutrition and meal records;
• Fitness goals and progress;
• Stored coaching information;
• Related application records; and
• Apple Health information previously synchronized to Willo’s servers.

Account deletion also includes removal of the associated authentication account as part of the implemented deletion process.

Certain information may remain temporarily in backups, operational logs, or third-party systems, or may be retained where permitted or required by applicable law.

Information maintained independently by Apple, including Apple Health records on your device and purchase records associated with your Apple account, is not deleted merely because you delete your Willo account.

Deletion of your Willo account does not automatically cancel an active App Store subscription.

You should separately manage or cancel subscriptions through Apple’s subscription management settings.

If you experience difficulties deleting your account, you may contact us using the privacy contact information in Section 2.

13. Your Privacy Rights and Choices

Depending on your location and applicable law, you may have rights concerning your personal information.

These may include:

13.1 Access

You may request information about personal data we hold concerning you.

13.2 Correction

You may request correction of inaccurate personal information.

Many profile details can be updated directly within the App.

13.3 Deletion

You may request deletion of personal information, subject to applicable legal exceptions.

You may also delete your Willo account through the App.

13.4 Data Portability

Where applicable law provides a right to data portability, you may request a copy of eligible personal information in an appropriate format.

Willo may handle such requests through its privacy contact rather than through a dedicated in-app export feature.

13.5 Withdrawal of Consent

Where processing is based on consent, you may withdraw that consent.

Withdrawal may affect the availability of features that require the relevant information.

13.6 Objection or Restriction

Where applicable law provides these rights, you may object to or request restriction of certain processing activities.

13.7 Device Permissions

You can manage relevant permissions through your device settings, including:

• Apple Health;
• Camera;
• Photo library;
• Microphone;
• Speech recognition; and
• Notifications.

13.8 Marketing Communications

You may unsubscribe from marketing emails using available unsubscribe mechanisms or by contacting us.

13.9 Exercising Your Rights

To exercise applicable privacy rights, contact:

[PRIVACY EMAIL ADDRESS]

We may request information reasonably necessary to verify your identity before fulfilling a request.

We will respond within the time required by applicable law.

We will not unlawfully discriminate against users for exercising applicable privacy rights.

Where applicable, you may also have the right to complain to a relevant data protection authority.

14. Analytics, Advertising, and Tracking

Willo uses Firebase Analytics to understand application usage and improve the Services.

Analytics may include user-linked identifiers and automatically collected technical information.

We do not currently integrate a dedicated third-party advertising SDK into the App.

We do not intentionally use HealthKit-derived information for targeted advertising.

We do not intentionally engage in cross-app tracking for advertising purposes through the App.

If our advertising, analytics, or tracking practices materially change, we will update this Policy and obtain any permissions required by applicable law or platform rules.

15. Camera, Microphone, and Speech Recognition

Certain Willo features require access to device capabilities.

Camera and Photographs

Willo may request camera or photo library access to analyze meals or scan food barcodes.

Photographs selected for AI meal analysis may be transmitted to OpenAI.

Willo does not intentionally store the original meal photograph in its application database as part of the current meal-analysis workflow.

Microphone and Speech Recognition

Willo may request microphone and speech recognition permissions to allow voice-based meal entry.

Speech recognition uses Apple’s speech recognition technology.

Depending on Apple’s supported processing methods, device configuration, and service availability, speech recognition may involve processing by Apple-operated services rather than exclusively on-device processing.

Willo receives the resulting transcription for use in its meal-entry functionality.

We do not represent that all speech recognition is performed exclusively on your device.

You can deny or revoke these permissions through your device settings.

16. Push Notifications

Willo may send notifications concerning:

• Scheduled workouts;
• Missed activities;
• Progress;
• Fitness reminders;
• Re-engagement; and
• Other service-related events.

Push notifications may be delivered using Firebase Cloud Messaging and Apple’s Push Notification service.

Notification delivery may involve processing device tokens and notification content by these providers.

You can disable notifications through device settings and manage available notification preferences within Willo.

17. Children’s Privacy and Minimum Age

Willo is intended only for individuals aged 18 years or older.

Individuals under 18 are not permitted to create accounts or use the Services.

Willo requests age information during onboarding and uses age-based eligibility controls to restrict access.

These controls rely on information provided by the user and do not necessarily involve independent identity or age verification.

We do not knowingly provide the Services to individuals under 18.

If we become aware that an individual under 18 has created an account, we may suspend or terminate access and take appropriate steps to delete associated personal information, subject to applicable legal obligations.

If you believe a minor has provided personal information to Willo, please contact us at:

[PRIVACY EMAIL ADDRESS]

18. Third-Party Services and Links

Our Services may contain links to third-party websites, platforms, or services.

These third parties may have privacy practices different from ours.

Their collection and processing of information are governed by their own applicable privacy policies and legal obligations.

We encourage you to review those policies before providing information directly to third parties.

Nothing in this section limits responsibilities that Willo has under applicable law for its own processing activities or service-provider arrangements.

19. Business Changes

If Willo undergoes a merger, acquisition, restructuring, sale, or similar transaction, personal information may be transferred as part of that transaction where legally permitted.

We will take appropriate steps to protect personal information and provide notices required by applicable law.

20. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect:

• Changes to our Services;
• New features;
• Changes in data-processing practices;
• Changes in service providers;
• Security improvements; or
• Legal or regulatory developments.

When we make changes, we will update the “Last Updated” date.

Where required by applicable law, we will provide additional notice or obtain consent before implementing material changes.

The current version of this Privacy Policy will be available through our Website and the App.

21. Relationship to Our Terms of Use

This Privacy Policy explains how Willo processes personal information.

Our Terms of Use govern the contractual relationship between Willo and its users.

The two documents address different matters and should be read together.

Nothing in the Terms of Use or this Privacy Policy is intended to limit rights or remedies that cannot lawfully be excluded under applicable law.

22. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our processing of personal information, please contact:

Willo – Fitness on Autopilot

Operated by: [LEGAL BUSINESS NAME]

Country: [COUNTRY]

Email: [PRIVACY EMAIL ADDRESS]

Website: willo.fitness

We will review and respond to privacy-related inquiries in accordance with applicable law.

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End of Privacy Policy