Please read this document carefully before using our services.

Privacy Policy

PROVISIONAL PRIVACY POLICY

This Privacy Policy is provisional and subject to change. A final version will be published in the future. By using our Services, you agree to be bound by these provisional terms until the final version is published.

Last Updated: May 2, 2025

1. Introduction

Welcome to Winglet.ai ("Winglet," "we," "our," or "us"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website, services, and products (collectively, the "Services"). Winglet.ai is a product of First12, LLC, a Delaware limited liability company.

We are committed to protecting your privacy and handling your data with transparency and care. This policy is particularly mindful of our educational context and the sensitive nature of student data.

2. Information We Collect

2.1 Information You Provide to Us

  • Account information (name, email address, password)
  • Profile information (educational institution, grade level, role)
  • Content you submit through our Services
  • Communications with us
  • Payment information (processed securely through our payment providers)

2.2 Information We Collect Automatically

  • Usage data (how you interact with our Services)
  • Device information (browser type, operating system)
  • IP address and location data
  • Cookies and similar technologies

2.3 Information from Third Parties

  • Information from educational institutions
  • Information from authentication providers
  • Information from payment processors

3. How We Use Your Information

We use your information to:

  • Provide, maintain, and improve our Services
  • Process your transactions
  • Send you technical notices and support messages
  • Communicate with you about products, services, and events
  • Monitor and analyze trends and usage
  • Detect, prevent, and address technical issues
  • Protect the security and integrity of our Services
  • Comply with legal obligations

4. Student Data Protection

4.1 Educational Context

We recognize the sensitive nature of student data and are committed to protecting it. We:

  • Limit collection of student data to what is necessary for educational purposes
  • Do not sell student data
  • Do not use student data for targeted advertising
  • Maintain appropriate security measures for student data

4.2 Parental Rights

For students under 18:

  • Parents/guardians may request access to their child's data
  • Parents/guardians may request deletion of their child's data
  • Parents/guardians may opt out of data collection

5. Data Sharing and Disclosure

We may share your information with:

  • Service providers who assist in operating our Services
  • Educational institutions (with appropriate consent)
  • Legal authorities when required by law
  • In connection with a business transaction (e.g., merger or acquisition)

We do not sell your personal information to third parties.

6. Data Security

We implement appropriate technical and organizational measures to protect your information, including:

  • Regular security assessments
  • Access controls and authentication
  • Secure data storage and processing

7. Your Rights and Choices

You have the right to:

  • Access your personal information
  • Correct inaccurate information
  • Request deletion of your information
  • Object to processing of your information
  • Export your data
  • Opt out of marketing communications

8. International Data Transfers

We may transfer your information to countries other than your country of residence. When we do, we ensure appropriate safeguards are in place to protect your information.

9. Children's Privacy

Our Services are strictly limited to users 13 years of age and older. We do not knowingly collect, maintain, or use personal information from children under 13 years of age. If you are under 13, please do not use our Services or provide any personal information to us.

If we learn we have collected or received personal information from a child under 13, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us immediately.

By using our Services, you represent and warrant that you are at least 13 years old. If you are between 13 and 18 years old, you represent and warrant that you have your parent's or guardian's permission to use our Services.

We expressly disclaim any liability for any unauthorized use of our Services by individuals under 13 years of age. Parents and guardians are responsible for monitoring their children's use of our Services and ensuring compliance with this age restriction.

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date.

11. Contact Us

If you have questions about this Privacy Policy, please contact us at:

First12, LLC
720 Seneca St Ste 107 #1020
Seattle, WA 98101
United States
Phone: (425) 671-5739
Email: contact@first12.org

12. Additional Information for Specific Regions

12.1 California Residents

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA). Please contact us for more information about these rights.

Important Notice for California Residents:

  • By using our Services as a California resident, you acknowledge and agree that:
    • We make no representations or warranties about compliance with CCPA or other California-specific laws
    • You are responsible for ensuring your use of our Services complies with applicable California laws
    • Our liability to California residents is limited to the maximum extent permitted by applicable law
    • We reserve the right to restrict or terminate access to our Services for California users at any time
    • Any claims arising from or related to the use of our Services by California residents shall be governed by Delaware law
    • You waive any rights under the California Consumer Privacy Act to the maximum extent permitted by law
    • You understand that we may not be able to provide the same level of service or support as we do for users in other jurisdictions

If you are a California resident and have concerns about these limitations, please do not use our Services.

12.2 European Union Residents

If you are in the European Union, you have additional rights under the General Data Protection Regulation (GDPR). Please contact us for more information about these rights.

Important Notice for EU Residents:

  • Our Services are primarily designed for and targeted at users in the United States
  • By using our Services from the EU, you acknowledge and agree that:
    • You are using our Services at your own risk
    • We make no representations or warranties about compliance with EU-specific laws
    • You are responsible for ensuring your use of our Services complies with applicable local laws
    • We may not be able to provide the same level of service or support as we do for US users
    • Data transfers outside the EU may occur, and you consent to such transfers
    • We reserve the right to restrict or terminate access to our Services for EU users at any time
    • Our liability to EU users is limited to the maximum extent permitted by applicable law

If you are an EU resident and have concerns about these limitations, please do not use our Services.

13. Limitation of Liability

To the maximum extent permitted by applicable law, First12, LLC shall not be liable for any indirect, incidental, special, consequential, or punitive damages, or any loss of profits or revenues, whether incurred directly or indirectly, or any loss of data, use, goodwill, or other intangible losses, resulting from:

  • Your use or inability to use our Services
  • Any unauthorized access to or use of our servers and/or any personal information stored therein
  • Any interruption or cessation of transmission to or from our Services
  • Any bugs, viruses, or other harmful code that may be transmitted through our Services
  • Any errors or omissions in any content or for any loss or damage incurred as a result of the use of any content posted, transmitted, or otherwise made available via our Services

This limitation of liability applies regardless of whether the damages arise from breach of contract, tort, or any other legal theory, and whether or not we have been informed of the possibility of such damages.