Wilgo — Privacy Policy (United States)

Applicable to users located in the United States — Version US-8
Effective September 25, 2026

Wilgo is a study app used by high-school and college students. Many of our users are minors, and we designed the service with that in mind. This policy is written to be read by a student as well as by a parent.

In one paragraph: we collect what we need to run your study account — who you are, what you are studying, what you get right and wrong, and what you send to the AI coach. We use it to teach you, to keep the service safe, and to understand how the app is used. We never sell your information, we never send what you study or how you do to advertisers, and we never let anyone use it to train an AI model. You can delete your account, and everything in it, from the app’s settings at any time.

The service is operated by Bongoway S.A.S., 68 rue Saint-Sabin, 75011 Paris, France (“Wilgo”, “we”). Questions: contact@wilgo.ai.

1. What this policy covers

This policy applies to the Wilgo mobile app, the web app and wilgo.ai, for users located in the United States. Because Wilgo is operated from France, your information is also protected under European data protection law, which applies to everything we do regardless of where you live. Where that law gives you more than US law does, you keep the benefit of it.

2. Information we collect

Notice at collection

Category What it includes Why we collect it Who we disclose it to
Identifiers First name, nickname, date of birth, email address, phone number, Wilgo user ID, Google or Apple account identifier if you sign in that way, device identifiers, IP address Create and run your account, sign you in, support Cloud hosting, analytics, email provider, authentication providers
Account and profile details Gender, country, school, grade and track, subjects, target exam and date, target grade, study difficulties you tell us about, how you heard about Wilgo Build your study path, adapt difficulty, understand where users come from Cloud hosting, analytics
Education information Answers, quiz and exercise results, progress by topic, error log, streaks, scores and leaderboard position, challenge results Teach, grade, track progress, run leaderboards and challenges; improve our exercises through aggregated analysis (Section 4) Cloud hosting, AI providers, analytics. Never advertising platforms
Content you submit Text you write, voice recordings, photographs of handwritten work, conversations with the AI coach Grade your work, answer your questions, generate study material AI providers, cloud hosting. Never advertising platforms
Commercial information Plan, order history, transaction dates and amounts, a pseudonymized payment reference Manage subscriptions, billing records, tax and accounting obligations; measure our advertising (Section 9) App stores, payment processor, advertising platforms in restricted mode
Internet and device activity App and site usage events, screens viewed, features used, device type, operating system, language, app version Improve the product, fix problems, measure usage Analytics, attribution and advertising partners
Approximate location Approximate location derived from your IP address; precise location only if you turn it on Localize content, audience measurement Cloud hosting, analytics
Inferences Estimated level per topic, recommended next activities, spaced-repetition scheduling Personalize your study path Cloud hosting. Never advertising platforms
Safety information When an automated safety check flags a conversation: the IP address at that moment and a reference to the conversation Show a help message and an appropriate helpline, protect users, respond to lawful requests A small number of authorized members of the Wilgo team; law enforcement only where legally required
Parent or guardian contact details First name, email and/or phone number, when you enter them Manage a subscription bought by a parent for a student, and send the corresponding receipts Cloud hosting, email provider, payment processor

Where this information comes from: almost all of it comes from you, or from your use of the app. Some comes from Google or Apple (if you sign in that way), from the App Store, Google Play or our payment processor (subscription and payment status), and from our analytics and attribution partners (device and campaign data).

What we do not collect: we do not ask for your Social Security number, we never receive or store your full payment card number, and we do not collect information from your device beyond what is described here.

3. Children and teens

Wilgo is a study service for high-school and college students. Many of our users are minors, and we take that into account in how the service is designed and how their information is handled.

What you confirm when you sign up

Creating an account is how you accept our Terms of Service and this policy, and the same statement carries a confirmation of your age. The wording shown to you is:

“By creating a Wilgo account, I accept the Terms of Service and the Privacy Policy. I confirm that I am at least 13 years old.”

This confirmation is declarative. We do not independently verify your age and we do not collect identity documents.

Children under 13

Wilgo is not directed to children under 13, an account cannot be created by a user who tells us they are under 13, and we do not knowingly collect personal information from a child under 13.

If we learn that an account belongs to a child under 13 — because a parent tells us, because support is contacted, or by any other means — we close the account and delete the associated data, and we send nothing about that account to any advertising platform.

We are building a way for a parent or legal guardian to open and supervise an account for a younger child. We will open it only once that is in place, and this policy will be updated before it is. When it opens, a child who tells us they are under 13 will not be able to use Wilgo straight away: we will ask for a parent’s or guardian’s contact details, send that parent a direct notice explaining what we would collect, what we would use it for and who would receive it, and we will collect nothing from the child until that parent has given verifiable consent — verified by a method recognised for that purpose, not by the child telling us the permission exists.

What a child’s account will include: the whole study product — quizzes and exercises, lessons, the AI coach, progress tracking, leaderboards and challenges.

What a child’s account will never include:

What a parent will be able to do, at any time. Review the personal information we hold about their child; ask us to correct or delete it; refuse any further collection or use; and withdraw their consent, which closes the account and deletes the data. Those requests go to contact@wilgo.ai and we answer within 45 days. We may ask for what is reasonably needed to confirm that the person asking is the child’s parent or guardian.

How long a child’s information will be kept. Only as long as it is needed for the purpose it was collected for, under a published schedule, and then deleted. A child’s information is never kept indefinitely.

Until all of that exists, the answer is simply no: under-13 accounts are not available, and a self-declaration by a child is not a substitute for a parent’s consent.

A parent or legal guardian who believes their child under 13 has created an account should write to contact@wilgo.ai. We act on it and confirm once it is done.

Users 13 to 17

Users between 13 and 17 need a parent’s or guardian’s permission to use Wilgo and to make any purchase. Users in this age group have the same rights over their information as adults, and their parent or guardian may exercise those rights for them, by writing to contact@wilgo.ai. We answer within 45 days, and we may ask for information reasonably needed to confirm the relationship before acting.

What we commit to for all minors

4. How we use information

We do not use your information for automated decisions that produce legal effects or similarly significant effects on you. Our level estimates and recommendations are educational only: they have no official academic value, they are not sent to your school or anyone else, and they do not determine any right or benefit.

5. AI features

Some Wilgo features run on AI models: the coach, grading of written answers and photographed work, generation of lessons, revision sheets, flashcards, quizzes and study plans, simplification of lessons, audio playback and voice dictation. The full list is in the app under Settings → AI & transparency.

Model providers: OpenAI (GPT family, including speech synthesis and transcription), Google (Gemini family) and Anthropic (Claude family). Which model is used depends on the feature and may change; the AI & transparency page shows the current state.

Training. What you send to these features is not used to train or improve our providers’ models. We use their business APIs, under which each of OpenAI, Google and Anthropic contractually commits that data sent is not used for training. We do not use it to train models of our own either.

Retention by the provider: up to 30 days, for security and abuse-monitoring purposes only.

Retention by Wilgo: your coach conversations are kept as long as your account exists, so you can find your history and so we can follow your progress. You can delete a conversation at any time. When you delete your account, your conversations stop being accessible immediately and are permanently erased within 48 hours.

Human review. Authorized members of the Wilgo team may read some conversations, solely to improve and secure the coach, without access to the information that identifies you.

6. Notifications

We collect the notification token your device is given by Apple or Google, whether you turned notifications on, and the reminder times you set.

If you turn notifications on, you will receive study notifications — revision reminders, deadlines you set, progress, streaks and service messages — and news about Wilgo — new features and, where applicable, our offers and subscriptions.

Notifications are turned on and off with a single setting that covers both. You can turn them off at any time in the app settings or your device settings. Doing so does not restrict your access to the service or to any feature.

7. Safety monitoring and distress detection

Conversations with the AI coach are subject to an automated safety analysis designed to detect situations of distress or serious danger — thoughts of suicide or self-harm, violence or abuse at home, sexual assault, or harassment.

What happens when something is detected. The app shows you a help message with a helpline appropriate to the situation and to your country, and may pause the conversation. In the United States that includes the 988 Suicide & Crisis Lifeline (call or text 988), the National Domestic Violence Hotline (1-800-799-7233) and the RAINN National Sexual Assault Hotline (1-800-656-4673).

What we record, in that case and only in that case: the IP address at the time of the exchange and a reference to the conversation. An internal alert — containing neither the content of the conversation nor the IP address — goes to a small number of authorized members of the Wilgo team.

Who is not contacted. No one outside Wilgo is contacted because of a distress signal. We do not notify your parents, your school, or anyone else. The only exception is a competent authority acting on a valid legal request.

No automated decision. The detection causes a help message to be displayed and, where appropriate, a temporary pause in the conversation. It produces no decision about you that has legal or similarly significant effects.

Retention: 12 months maximum, unless a legal proceeding is ongoing.

Consumer health data (Washington, Nevada, Connecticut). A signal detected by this analysis may qualify as consumer health data under the laws of some states. We use it only to show the help message described above and to keep the service safe. We do not sell it, we do not use it for advertising, and we do not use it to profile you. Washington and Nevada residents may exercise the rights described in Section 11 over this data, including deletion.

8. Voice and images

Voice. When you answer out loud, your recording is converted to text so your answer can be graded. We do not use your voice to identify you. We do not create, store or use a voiceprint or any other biometric identifier, and we do not disclose voice recordings to anyone except the AI provider that performs the transcription. Recordings are not kept beyond the processing.

Photographs of handwritten work. Used to grade the exercise, and kept for a maximum of 365 days. We may also count, across many students and without identifying anyone, which mistakes come up most often on a given question, so that we can improve our exercises and explanations (Section 4). That analysis produces aggregate results only, we do not attempt to trace them back to an individual, and the images are not used to train AI models.

9. Analytics and advertising

Analytics

Amplitude (Amplitude Inc., United States) measures how the app is used: your Wilgo user ID, technical data (device, OS, language, version) and usage events. Google Analytics measures traffic on the wilgo.ai website only, not in the app.

These statistics are used to understand and improve the product. They are not sold and they are not used for advertising.

Advertising measurement

Adjust (Adjust GmbH, Germany) tells us which campaign an install came from, using the device advertising identifier where available, technical data, and install and usage events. On iOS, we ask for permission through Apple’s App Tracking Transparency prompt; without your permission, no IDFA is collected. On Android, this depends on your acceptance of advertising cookies; without it, no advertising ID is collected.

Meta, TikTok and Google Ads. When you arrive from one of our ads, we tell the advertising platform which steps you completed — creating an account, reaching a first level of activity in the app, starting a trial, subscribing — together with the plan and the amount paid, and the identifier it needs to match this to the ad you saw, typically a hashed email address or a click identifier.

We send nothing about what you study or how you do: no results, no level, no subjects, no difficulties you told us about, and no coach conversations. The activity signal tells the platform only that you reached a level of use, never how well you are doing.

How these platforms may use it. We use Meta, TikTok and Google Ads in their restricted processing modes — Meta’s Limited Data Use, Google’s restricted data processing and TikTok’s Limited Data Use — under which they act on our instructions and may use what we send only to measure our own advertising. They do not use it to build audiences, to target you or anyone else with advertising, or for their own purposes.

We therefore do not sell your personal information, and we do not share it for cross-context behavioral advertising.

Wilgo is 13+ (Section 3). If an account is nonetheless found to belong to a child under 13, it is closed and deleted, and nothing about it is sent to an advertising platform.

10. Who we share information with

We use service providers who process information on our behalf and are contractually restricted to that purpose:

We also disclose information where we are legally required to, to respond to a valid legal request, to enforce our Terms, or to protect the rights and safety of our users, and to an acquirer in the event of a merger or sale of assets, in which case this policy continues to apply until it is replaced.

Other users see your nickname and ranking in leaderboards and challenges you take part in. That is a visibility you control and can turn off, not a disclosure to a third party.

A current list of our service providers, with their role, where they process data and the safeguards applied, is available on request at contact@wilgo.ai.

International transfers. Wilgo is operated from France and our servers are in the European Union, so information about US users is transferred to and stored in Europe. Some of our providers are in the United States. Transfers between the EU and the US are covered by the safeguards required under European law, including Standard Contractual Clauses.

11. Your rights and choices

What you can do yourself, at any time

We also honor the Global Privacy Control (GPC) signal on wilgo.ai: if your browser sends it, we do not load our advertising or analytics tags for that visit.

State privacy rights

Depending on where you live, you may have the right to:

California. We do not sell personal information and we do not share it for cross-context behavioral advertising, as explained in Section 9 — which is why you will not find a “Do Not Sell or Share My Personal Information” link on our site: we do neither. California law requires opt-in consent before selling or sharing the personal information of a consumer under 16, and many of our users are minors, which is one of the reasons we run advertising measurement in restricted mode rather than as ordinary ad targeting. California residents may also request the disclosure required by the “Shine the Light” law at contact@wilgo.ai.

Colorado, Connecticut, Virginia, Texas, Oregon, Montana, Delaware, New Jersey, New Hampshire, Minnesota, Maryland, Nebraska, Rhode Island, Indiana, Kentucky, Tennessee, Iowa, Utah and other states with comprehensive privacy laws — the rights listed above apply as their law provides, including the right to appeal.

Washington and Nevada — rights over consumer health data, as described in Section 7.

How to exercise a right

Write to contact@wilgo.ai. We respond within 45 days, and may extend once by another 45 days where the request is complex, telling you why. We do not charge for this, unless requests are excessive or repetitive.

Verification. We will ask you to confirm information that matches what we already hold, so that we do not give your data to someone else. We will not ask for more than we need.

Authorized agents. You may use an authorized agent. We will ask for proof of the agent’s authority and may ask you to confirm the request directly.

Parents and guardians may exercise these rights for their child, as described in Section 3.

Appeals. If we refuse a request, you may appeal by replying to our decision or writing to contact@wilgo.ai with “Appeal” in the subject line. We answer within 45 days and explain our reasoning. If we deny your appeal, you may complain to your state attorney general.

12. How long we keep information

We keep personal information only as long as we need it for the purpose it was collected for, or as long as the law requires.

Information How long we keep it
Account data 3 years after your last activity, unless you delete your account first
Data received from Google or Apple sign-in Deleted with your account
Progress and usage data Erased within 48 hours after account deletion
Nickname, scores and rankings Erased within 48 hours after account deletion. Past leaderboards are kept in aggregated, anonymous form
Referral data Erased within 48 hours after account deletion
Coach conversations As long as your account exists, unless you delete them sooner. Permanently erased within 48 hours after account deletion
Saved study material As long as you keep it in your library; same deletion rule
Voice recordings Converted to text, then deleted
Photographs of handwritten work 365 days maximum
Aggregated, anonymized statistics on common mistakes Kept without time limit. They identify no one and are not linked back to any account
Payment and billing records For the duration of the contract, then archived for up to 10 years to meet accounting and tax obligations. We never store card numbers
Record of your consent to automatic renewal For as long as your subscription lasts, then at least one year
Parent or guardian contact details As long as the subscription they relate to is active
IP address recorded on a distress alert 12 months maximum
Notification token and preferences Until you turn notifications off, uninstall the app, or delete your account
Advertising measurement events sent to a platform Held by that platform under its own retention rules, up to 13 months
Technical and advertising data held by us As long as the purpose requires, then anonymized
Cookie choice 12 months (Section 13)

13. Cookies and similar technologies

We use cookies and similar technologies in the app and on wilgo.ai. They fall into three families.

Strictly necessary. They keep you signed in during your visit, remember your cookie choice so we do not ask again, keep your display preferences, and protect registration against automated sign-ups. Durations: from the length of your visit (session cookie, deleted when you close) to 12 months, and 30 minutes for anti-bot protection.

Audience measurement. They produce usage statistics that tell us how the app and the site are used, so we can improve them. These statistics are not used for advertising and are not sold. Durations: 12 months for app usage measurement; up to 2 years for wilgo.ai traffic measurement, which uses Google Analytics and follows that tool’s default. The resulting data is not kept beyond 25 months, after which it is anonymized.

Advertising measurement and attribution. They connect an app install or a sign-up to the campaign it came from, so we can tell which of our ads work. They involve TikTok, Google Ads, Meta and Adjust, and are limited to the measurement described in Section 9. Duration: up to 13 months. Attribution identifiers used in the app, which are not cookies but similar technologies, last for as long as the app is installed.

Your choice is kept for 12 months, after which we ask again. You can change it at any time in the app or device settings, and refusing does not restrict your access to the service or any feature.

14. Security

We use technical and organizational measures that meet industry standards. No transmission over the internet is completely secure, and we cannot guarantee absolute security. If a data breach occurs, we notify the authorities and the affected users as required by law.

15. Changes to this policy

We may update this policy. If we make a material change, we will tell you in the app, by email, or by another appropriate means before it takes effect. Previous versions are kept and can be sent to you on request.

16. Contact

contact@wilgo.ai — Bongoway S.A.S., 68 rue Saint-Sabin, 75011 Paris, France


Bongoway S.A.S. — RCS Paris 942 678 723 — 68 rue Saint-Sabin, 75011 Paris, France