YOUR FAMILY’S TRUST MATTERS

Privacy Policy

Last updated: November 3, 2026

This policy covers the Whilo website and parent early access list, operated by Nolan HK Limited, Hong Kong. It is intended for adult parents and guardians in the United States and other English-speaking countries. It does not cover a future Whilo device or companion app; those experiences will have separate privacy information before collecting data.

1. Who we are

Nolan HK Limited is responsible for the personal information described in this policy. Our business address is HOUSE 11, No.28 Tai Po Kau San Wai, Tai Po, N.T, HK. Whilo is our working brand name. For privacy questions, requests, or unsubscribe instructions, email privacy@whilo.ai.

2. Information we collect

When you join the early access list, we collect your email address, the time of signup, and a record of the consent wording you accepted. We do not require your name, your child’s name, or an account. The optional AI preview is described separately below.

Vercel hosts our website and Supabase stores signup records in a United States database region. These infrastructure providers may process IP addresses, browser information, request times, and diagnostic or security logs to deliver and protect their services.

If you contact us, we also receive the email address and information you include in your message. Please do not send children’s personal information.

AI question preview for parents

Adults can choose to submit a general curiosity question for an AI-generated preview. Do not include names, contact details, or other personal information about a child. With your confirmation, the website sends the question to OpenAI for content screening and response generation, and screens the generated answer before displaying it. This consent is separate from email updates or optional tracking.

Our application does not save questions or answers in its database, persistent browser storage, or application logs. To support follow-up replies, it keeps the original question and up to two recent question-and-reply pairs in temporary page memory and sends them to our server and OpenAI with the next reply. The server returns a signed context token to your browser; it contains conversation text, is not encrypted, and expires after 30 minutes without a new reply. We do not store the token on the server. Refreshing the page or choosing “New question” clears the active conversation from the page. We request that OpenAI not store response application state, but this does not eliminate provider retention: OpenAI may retain abuse-monitoring data for up to 30 days under its standard controls, with exceptions described in its policies. See OpenAI’s data controls.

For cost control, the application records a site-wide daily request count and a random per-request quota marker. These markers do not identify or group visitors, and our trial quota system does not store your network address. Older request quota markers and random feedback receipts are removed on subsequent trial requests after their short operational period (approximately two days); daily aggregate counts are retained for up to one year, with cleanup on subsequent requests. Infrastructure logs and backups may have separate retention. Ratings are stored as daily positive and negative counts with a temporary random receipt to prevent duplicate votes; they are not linked to an email address, question, or answer. If you choose to explain a negative rating, we collect your written note, encrypt it with our public key before database storage, and use it for team review and response improvements. Notes are not sent to OpenAI for automatic training and do not include the original question or answer. Please do not include personal information. Encrypted notes are retained for up to one year, with cleanup on subsequent note submissions. Email signup remains a separate, optional choice.

The preview is for parents to evaluate and may make mistakes. It does not establish what a future Whilo device will do. No voice recordings are requested or collected.

3. How we use information

We use your email address to manage the early access list and send the Whilo product, crowdfunding, and potential early-bird offer updates you choose to receive. We also use necessary information to respond to requests, honor unsubscribe choices, prevent abuse, maintain the website, and meet legal obligations.

Where applicable, we rely on your consent for marketing emails and optional tracking, our legitimate interests for proportionate website security and administration, and legal obligations where required. You can withdraw consent without affecting processing that was lawful before withdrawal.

4. Children’s privacy

This website and its signup form are for adults. We do not knowingly collect personal information from children under 13 through the landing page. The site does not request children’s questions or collect voice recordings. If you believe a child has submitted personal information, contact privacy@whilo.ai so we can investigate and remove it as appropriate.

A parent’s signup is not permission to collect a child’s information through a future product.

5. Who receives information

We use Vercel for website hosting and Supabase for database storage. Providers supporting email delivery, security, and administration may process information needed to provide those services on our behalf. We do not publish subscribers’ email addresses.

We do not sell our early access email list. Any future advertising-related disclosures are described separately below. We may disclose information when reasonably necessary to comply with law, protect rights and security, or carry out a business transfer subject to applicable privacy obligations.

6. Analytics, advertising, and cookies

Google Analytics and Google Ads tags are planned but are not currently included in the website application. Before enabling them, we will identify the features used, update this policy, and provide the choices and consent controls required for the places where we operate.

Depending on the features enabled, those tools can use cookies or similar identifiers to measure visits, understand site interactions and referral sources, measure advertising conversions, or support personalized advertising. Information can include browser and device details, page views, interactions, cookie identifiers, and IP addresses handled by the provider. Email signup consent is separate from consent for optional tracking.

Learn how Google uses information from partner sites, visit Google’s ad controls, or see the Google Analytics browser opt-out.

No CAPTCHA provider has been selected or integrated. We will disclose its data practices before introducing one. The current application does not implement browser Do Not Track or Global Privacy Control handling; applicable opt-out signal requirements must be addressed before advertising tracking is activated.

7. How long we keep information

Our retention policy is to keep unsent early access signup records for no longer than one year after signup. Sending an update does not restart that period. Records used for an email campaign are deleted from active online storage no later than one year after that campaign, and may be removed sooner.

Local exports, including decrypted email lists, are kept for no longer than one year after export and may be deleted sooner once no longer needed. You can request earlier deletion at privacy@whilo.ai.

We may retain limited records necessary to honor an unsubscribe request or meet a legal obligation. Infrastructure logs and backups follow the relevant provider’s retention and deletion processes; deleting an active record does not immediately remove every historical backup. You can contact us for information about applicable provider retention periods.

8. Security and email encryption

We use server-side credentials and database access controls. We encrypt email addresses with a public key before storing them in our signup database. The corresponding private key and decryption tools stay offline and are excluded from hosting and code-repository uploads.

An authorized operator can export encrypted records and decrypt them locally for email delivery. A keyed, one-way fingerprint supports duplicate detection without storing the address in plaintext in the active signup table. The website server still receives the address during submission; this is not end-to-end encryption. Email delivery providers also process recipient addresses. No system can guarantee absolute security.

9. Your choices and rights

To unsubscribe, request access, correct an address, or request deletion, email privacy@whilo.ai from the address you used to sign up. You do not need to create an account. We may reasonably verify requests to protect your information and will respond within applicable legal time limits.

Depending on your location and applicable law, you may also have rights to restrict or object to processing, receive a portable copy, withdraw consent, appeal a decision, or complain to your local privacy regulator. We do not discriminate against you for exercising applicable privacy rights.

10. International processing

Nolan HK Limited operates from Hong Kong, and our Supabase database region is in the United States. Hosting, email, and other service providers may process information in additional locations. Privacy laws may differ from those where you live. Where required, we will use applicable safeguards for international transfers rather than treating use of the site as consent to a transfer.

11. Changes and contact

We will update the date above when this policy changes and provide additional notice where required. Questions and requests can be sent to Nolan HK Limited at privacy@whilo.ai.