Wollo - AI Companions

This Privacy Policy (the "Privacy Policy" or "Policy") describes the types of information Alperen LTD and its affiliates ("Wollo," "we," "our," or "us") collect and process from and about you.

The Policy applies to all websites, mobile applications, and any other electronic/digital products or other services that are made available by Wollo and that link to this Policy, and our offline services (collectively, the "Services").

Undefined capitalized terms used in this Policy have the meaning set forth in the Wollo Terms of Service.

For residents of the European Economic Area and the United Kingdom: please refer to our Regional Privacy Disclosures for additional details that may be relevant to you.

1. Information We Collect

When you access or otherwise use our Services, we collect information from you. The types of information we collect depend on how you use our Services. Please note that we need certain types of information to provide the Services to you. If you do not provide us with such information, or if you ask us to delete that information, you may no longer be able to access or use certain Services. The information we collect includes data you directly provide to us, data we obtain automatically from your interactions with our Services, and data we obtain from other sources.

Information You Provide Directly to Us

We collect information directly from you. For example, you provide us with information when you use the Services, communicate with us, register for an account, subscribe to our newsletters, participate in our community, engage with social features such as following other creators, liking content, leaving comments or reviews, posting in the feed, creating or responding to polls, sending direct messages to other users, or participating in promotions. Information you provide directly to us may include:

Identifiers, such as your name, email address, phone number, display name, or username;
Demographic information, such as your date of birth and general geolocation information;
Interests, such as categories like "Fantasy," "Gaming," or "Art;"
Inferences, such as preferences based on account settings or feedback on the Services;
Financial information, such as payment information and other information collected through our payment processing vendors (including Stripe Connect for Creator payouts);
Commercial information, such as purchases, Creator tier subscriptions, and transaction history;
Your content, such as AI characters you create, character descriptions and personalities, chat communications with characters, generated images, posted images or videos, biography description, comments on other users’ content, reviews and ratings on characters, feed posts, poll responses, reposts, direct messages to other users, and social interactions including likes and follows;
Creator monetization data, such as tier pricing, payout preferences, Stripe Connect account information, and earnings history;
Voice data, including recordings of your voice, if you choose to use certain voice features; and
Contents of communications with us, such as customer support messages.

Information you provide directly to us might also include information that may be treated as sensitive under applicable laws, such as login credentials, personal communications received or sent using our Services (including direct messages), or other information about yourself that you choose to provide. Sensitive personal information is not required or necessary to use the Services – please do not include any sensitive personal information in your interactions with us or the Services.

Creator Identity Verification: When you apply to become a Creator, you are required to complete identity verification through our payment processing partner, Stripe Connect. This may include submitting government-issued identification, tax identification numbers, and banking details. This information is collected and processed directly by Stripe under Stripe’s own privacy policy (available at https://stripe.com/privacy). Wollo does not store your full identity verification documents or banking details; we receive only a confirmation of your verification status and limited account identifiers from Stripe necessary to administer your Creator account and process payouts.

Information We Collect About Your Use of the Services

We and our third-party providers use cookies, web beacons, and other tracking technologies to collect information about your use of the Services. Please refer to our Cookie Policy for more information.

We use these technologies to collect and analyze device, Internet, and other electronic network activity information including: information about your computer or device (e.g., device type, browser type, ISP or operating system, IP address, device identifiers); information about how you use and interact with the Services (e.g., domain name, access time, referring or exit pages, page views, Service-related identifiers such as User ID, Character ID, Chat ID, Session ID, actions taken within the Services including characters you interact with, content you like, comments and reviews you leave, posts you create or engage with, polls you respond to, creators you follow, and direct messages you send); and geolocation data.

Information We Collect from Other Sources

We may also collect information from other sources, such as when you are referred to us by another user, when you interact with our ads on other platforms, or when you interact with our social media profiles. When you connect to your account using a Third-Party Account (such as Facebook or Google), we receive information from that third party identifying your account in accordance with your permissions.

We also collect information that is available on the Internet or from other publicly available sources to evaluate and improve our Services, including for model training and development.

2. How We Use the Information We Collect

We use information for the following purposes:

Provide, administer, and operate the Services and our business;
Enable social features, including allowing you to follow other creators, like content, leave comments and reviews, post in the feed, create and respond to polls, repost content, send direct messages, discover new characters and creators, and participate in the Wollo community;
Facilitate Creator monetization, including processing tier subscriptions, managing Creator payouts through Stripe Connect, and enabling Creators to manage their paid content;
Generate and analyze inferences about use of the Services, such as your preferences and interests and trends about our Services;
Tailor the Services to your preferences and interests, including recommending characters, creators, and content you may enjoy;
Evaluate the success of advertising campaigns;
Communicate with you, including to inform you about features or aspects of the Services we believe might be of interest to you;
Communicate with you about changes to our terms, conditions, or policies; or to respond to your inquiries;
Analyze, maintain, improve, modify, customize, and measure the Services, including to train our artificial intelligence/machine learning models;
Develop new features, algorithms and machine learning models, programs, and services;
Provide advertising and recruit new users;
Authenticate your account credentials;
Process payments and Creator payouts;
Detect and prevent fraud, criminal activity, or misuse of our Service; and
Comply with legal obligations and protect our rights, privacy, safety, or property.

We combine information that we collect through the Services with information that we obtain from other sources. We may also aggregate or anonymize information collected through the Services and use and disclose aggregated or anonymized data for a number of purposes, including research and marketing. To the extent we anonymize any data so that it is no longer reasonably linkable to an individual, we maintain and use such data in de-identified form and will not attempt to re-identify the data.

AI Model Training

We may use content submitted to the Services, including character interactions, Generated Content, and other user-generated data, to train, improve, and develop our artificial intelligence and machine learning models. This helps us improve character quality, content recommendations, image generation, and overall platform experience.

If you wish to opt out of having your content used for AI model training, you may do so by adjusting your settings in the Privacy section of your account or by contacting us at [email protected]. Please note that opting out may not retroactively remove data already incorporated into trained models, but we will exclude your future content from training datasets.

Direct Message Data

Direct messages (DMs) you send and receive are stored on our servers to deliver the messaging service. We may access, review, or process DM content for the following purposes: (i) to enforce our Terms of Service and Community Guidelines; (ii) to respond to legal requests or court orders; (iii) to detect and prevent abuse, spam, fraud, or illegal activity; and (iv) to maintain platform safety. We do not use the content of your direct messages to train AI models or for advertising purposes.

3. When We Disclose the Information We Collect

We disclose information in any of the following circumstances:

Affiliates. We disclose information to our affiliates and subsidiaries, who may use the information in a manner consistent with this Policy.
Vendors and Service Providers. We disclose information to service providers who need access to carry out work on our behalf, such as those who provide data storage, payment processing (including Stripe for Creator payouts), technology support, customer service, analytics, fraud prevention, content moderation, legal services, and marketing and advertising services.
Payment Processors. When you become a Creator or purchase Creator content, we share necessary information with Stripe Connect to facilitate onboarding, identity verification, payment processing, and payouts. Stripe processes this information as an independent data controller under its own privacy policy.
Safety and Protection. We may disclose information if we believe in good faith that doing so is necessary to protect or defend Wollo or other parties, including to enforce this Policy, our Terms of Service, or our Community Guidelines, and to protect the rights, property, or personal safety of Wollo, our agents, our employees, users, and the public.
Advertising and Analytics. We may disclose personal information to advertising and analytics providers in connection with tailored advertising and analytics services.
Your Content. Certain actions you take might result in your content being made available to others, including the public. For example: if you create public characters, they may be visible to others; when you post in the feed, your posts may be visible to other users; when you follow other creators, like content, leave comments or reviews, or create polls, this activity may be visible; when you send direct messages, those messages are visible to the recipient(s); your profile information and public activity may be visible to other users; and Creator content, tier descriptions, and pricing are visible to potential subscribers.
Legal Requirements. We may disclose information to comply with any law enforcement, legal, or regulatory process.
Business Transfers. We may disclose 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.
Other Disclosures with Consent or at Your Direction. We might make additional disclosures of your information when you direct us to do so.

4. Your Choices

Profile information. You may delete your account by contacting us at [email protected]. You may also verify, correct, update, or delete certain of your information through your account profile page.
Marketing communications. You can unsubscribe from marketing emails by following the directions in those emails.
Cookies. You may manage cookies as described in our Cookie Policy.
Social Features. You may control the visibility of your profile, characters, and activity through your account settings. You may also unfollow creators, manage DM settings, or manage your social interactions through the Services.
Creator Settings. If you are a Creator, you can manage your tier pricing, content visibility, and payout preferences through your Creator dashboard.
AI Training Opt-Out. You may opt out of having your content used for AI model training by adjusting your settings in the Privacy section of your account or by contacting us at [email protected].

For more information about region-specific rights, please refer to our Regional Privacy Disclosures.

5. Regional Privacy Disclosures

Depending on where you live, you may have specific rights or there may be certain information we need to make available to you. If you live in the European Economic Area or the United Kingdom, please refer to our Regional Privacy Disclosures for additional information.

California “Shine the Light”

Under California Civil Code Section 1798.83, California residents who have an established business relationship with us may request information about whether we have disclosed personal information to any third parties for the third parties’ direct marketing purposes during the preceding calendar year. To make such a request, please contact us at [email protected].

Nevada Privacy Rights

Nevada residents may opt out of the “sale” of certain personal information (as defined under Nevada law). Wollo does not sell your personal information as defined under Nevada law. If you have questions, please contact us at [email protected].

6. Children’s Privacy

The Services are not designed for minors under 13, and our Terms of Service prohibit use by anyone under 13 or under 16 if you are a resident of the European Economic Area or the United Kingdom. We do not knowingly collect personal information from children under 13 (or under 16 in the EEA/UK). If we become aware that we have collected personal information from a child below the applicable age, we will take steps to delete that information promptly. If you believe we have collected information from a child, please contact us at [email protected].

7. Data Retention

In General. We keep your information for the time necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and your choices, after which time we may delete and/or aggregate it. The following provides more specific guidance on our retention practices:

Data Category	Retention Period
Account information (name, email, profile)	Retained while your account is active. Deleted within 90 days of account deletion, except where retention is required by law.
Chat logs with AI Characters	Retained while your account is active. Deleted within 90 days of account deletion. May be retained in anonymized/aggregated form for model improvement if you have not opted out.
Direct messages	Retained while both parties’ accounts are active. If one party deletes their account, messages may be retained in redacted form for the other party or deleted in accordance with our practices. Deleted within 90 days of both parties’ account deletion.
Feed posts, comments, reviews, polls	Retained while your account is active. Public content may be preserved after account deletion to maintain platform continuity (see below).
Creator financial data (transactions, payouts, earnings)	Retained for a minimum of 7 years after the last transaction to comply with tax, accounting, and regulatory obligations.
Payment information (non-Creator)	Processed and stored by our payment processor (Stripe). Wollo retains transaction records for up to 7 years for tax and accounting purposes.
Device and usage analytics	Retained in identifiable form for up to 24 months. Retained indefinitely in aggregated/anonymized form.
Customer support communications	Retained for up to 3 years after resolution to handle follow-up inquiries and improve support quality.
Popular Characters. If a character you create has been made available to other users and has been interacted with by the community, we reserve the right to preserve that character’s characteristics and to keep that character active on the Services, even if you otherwise delete your data and your account. We do this to avoid impacting the experience of other users and to maintain the integrity of the social platform.	Public Content and Social Interactions. Similarly, if you have created public content, made comments, left reviews, posted in the feed, or engaged in social interactions visible to other users, we may retain certain elements of this activity to maintain the continuity and functionality of the platform, even after you delete your account. Where possible, we will disassociate this content from your personal identity.
8. Automated Decision-Making	We use automated systems to help with certain aspects of the Services, including:
• Content recommendations and feed personalization based on your activity, preferences, and interactions;	• Automated content moderation to detect and flag content that may violate our Terms of Service or Community Guidelines;
• Fraud detection and security monitoring to identify suspicious account activity; and	• Spam detection in direct messages, comments, reviews, and posts.
These automated processes may influence what content you see, whether your content is flagged for review, or whether your account is flagged for suspicious activity. However, significant decisions that affect your account status (such as account suspension or termination) are reviewed by human moderators before being finalized.	If you are located in the EEA or UK and believe an automated decision has significantly affected you, you have the right to request human review of that decision by contacting us at [email protected].
9. International Data Transfers	Wollo is based in Cyprus, and we process and store information in Cyprus and other locations. If you are accessing the Services from outside Cyprus, please be aware that your information may be transferred to, stored, and processed in Cyprus and other countries where our servers are located and our service providers operate.
For users in the European Economic Area and United Kingdom, we ensure that appropriate safeguards are in place for the transfer of personal data in accordance with applicable data protection laws, including through the use of standard contractual clauses approved by the European Commission where required.	10. Links to Third-Party Websites
The Services may contain links to third-party websites or services. We are not responsible for the content or practices of those websites or services.	11. Data Security
We implement appropriate technical and organizational measures to protect your personal information against unauthorized or unlawful processing, accidental loss, destruction, or damage. These measures include encryption of data in transit and at rest, access controls, regular security audits, and employee training. However, no internet or electronic storage system is completely secure. We cannot guarantee the absolute security of your information.	Data Breach Notification
In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the relevant supervisory authority without undue delay and, where feasible, within 72 hours of becoming aware of the breach, in accordance with the GDPR. Where the breach is likely to result in a high risk to your rights and freedoms, we will also notify you directly without undue delay.	12. Do Not Track Signals
Some web browsers transmit “Do Not Track” (DNT) signals to websites. Because there is no universally accepted standard for how to respond to DNT signals, we do not currently respond to DNT signals. Instead, we offer the privacy controls described in this Policy and our Cookie Policy to manage your preferences regarding tracking and personalization.	13. Changes to this Policy
We may update this Policy from time to time. If we make a material change to the Policy, you will be provided with appropriate notice in accordance with legal requirements, such as by email or prominent posting on our website or mobile application. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Policy.	14. Data Protection Officer
If you have questions or concerns about our data protection practices, you may contact our Data Protection Officer at:	Email: [email protected]
Alperen Ltd. (Wollo)	Agias Fylaxeos 123, Limassol, Cyprus
15. Contact Us	If you have any questions about our Privacy Policy or information practices, please email us at [email protected]. You can also write to us at:
Alperen LTD	Agias Fylaxeos 123, Limassol, Cyprus