Privacy Policy

Effective Date: January 14, 2025

Winnow One, Inc. ("Winnow," "we," "us," or "our") operates the Winnow mobile application (the "App"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our App. Please read this Privacy Policy carefully. By accessing or using the App, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access the App.

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the "Effective Date" of this Privacy Policy. You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the App after the date such revised Privacy Policy is posted.

1. Information We Collect

1.1 Personal Information You Provide

When you register for an account, we collect: your phone number; date of birth; gender; approximate location (zip code); a profile photo; a short biographical description; and your matching preferences. You must be at least 18 years old to use the App.

1.2 Voice Recordings and Biometric Data

IMPORTANT NOTICE REGARDING BIOMETRIC DATA: The App collects voice recordings when you participate in AI-facilitated conversations. These voice recordings may be used to derive biometric identifiers or biometric information, including voiceprints and voice characteristics (collectively, "Biometric Data"). We process voice recordings on our servers to analyze conversational patterns, communication style, and compatibility indicators.

By using the voice conversation features of the App, you expressly consent to the collection, use, and storage of your voice recordings and any Biometric Data derived therefrom.

In accordance with the Illinois Biometric Information Privacy Act (740 ILCS 14) and similar laws, we inform you that: (a) we collect and store your Biometric Data; (b) the purpose of collecting your Biometric Data is to analyze conversational compatibility and provide you with insights and matches; (c) we will retain your Biometric Data for as long as your account remains active, or for three (3) years following your last interaction with the App, whichever is shorter, after which it will be permanently destroyed; and (d) we will not sell, lease, trade, or otherwise profit from your Biometric Data except as necessary to provide the App's services or as required by law.

1.3 Conversation Insights

We generate insights and analytics based on your voice conversations, including assessments of communication style, conversational patterns, and compatibility indicators ("Conversation Insights"). These Conversation Insights are derived from your voice recordings and other interactions with the App.

1.4 User Communications

When you communicate with other users through the App's messaging features, we collect the content of those communications to provide the messaging service and to enforce our Terms of Service.

1.5 Automatically Collected Information

When you access the App, we may automatically collect certain information, including: device type, operating system, and unique device identifiers; usage data such as access times, pages viewed, and features used; and IP address and general location information derived therefrom.

2. How We Use Your Information

We use the information we collect to: create and manage your account; analyze your voice conversations and generate Conversation Insights; facilitate matches with other users based on compatibility analysis; enable communication between matched users; improve, personalize, and optimize the App; respond to your comments, questions, and requests; send you technical notices, updates, security alerts, and support messages; monitor and analyze trends, usage, and activities in connection with the App; detect, investigate, and prevent fraudulent transactions and other illegal activities; protect the rights and safety of Winnow and others; and comply with legal obligations.

3. Disclosure of Your Information

We may share your information in the following situations:

Service Providers. We share your information with third-party service providers that perform services on our behalf, including artificial intelligence and machine learning providers that process your voice recordings to generate Conversation Insights. These service providers are contractually obligated to use your information only for the purposes of providing services to us and are required to maintain the confidentiality of your information. We currently use OpenAI to process voice data, but we may change providers at any time without notice.

Other Users. Certain information in your profile, including your photo, bio, age, and general location, will be visible to other users. Your Conversation Insights may be shared with users you match with, to the extent you choose to share them.

Legal Requirements. We may disclose your information where required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.

With Your Consent. We may disclose your information for any other purpose with your consent.

We do not sell your personal information or use it for advertising purposes.

4. Data Retention

We retain your personal information, including voice recordings and Biometric Data, for as long as your account is active. If you delete your account, we will delete or anonymize your personal information within thirty (30) days, except as necessary to comply with our legal obligations, resolve disputes, or enforce our agreements. Notwithstanding the foregoing, we may retain certain information for legitimate business purposes or as required by law.

5. Your Rights and Choices

Account Information. You may update, correct, or delete your account information at any time by accessing your account settings within the App. If you wish to delete your account entirely, you may do so through the App settings or by contacting us.

Data Export. You may request a copy of your Conversation Insights by using the export feature within the App.

Biometric Data. You may withdraw your consent to the collection and use of your Biometric Data at any time by deleting your account. Upon deletion of your account, we will permanently destroy your Biometric Data within thirty (30) days.

Communications. You may opt out of receiving promotional communications from us by following the unsubscribe instructions in those communications or by adjusting your notification settings in the App.

6. Security

We implement appropriate technical and organizational measures designed to protect your personal information against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the Internet or electronic storage is completely secure, and we cannot guarantee absolute security.

7. Children's Privacy

The App is not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we learn that we have collected personal information from a child under 18, we will take steps to delete that information as quickly as possible. If you believe that a child under 18 may have provided us personal information, please contact us.

8. California Privacy Rights

If you are a California resident, you have certain rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information we collect, the right to delete your personal information, and the right to opt out of the sale of your personal information. As stated above, we do not sell your personal information. To exercise your rights, please contact us using the information below.

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by posting a notice in the App or by sending you an email. Your continued use of the App after any modification constitutes your acceptance of the modified Privacy Policy.

10. Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please contact us at:

Winnow One, Inc.

Email: privacy@winnow.one