WILCO TRAINING LLC

Privacy Policy

Effective Date: May 22, 2026 | Last Updated: June 1, 2026

Wilco Training LLC (“Wilco,” “we,” “us,” or “our”) is committed to protecting the privacy of all users of the Wilco Training platform (“Platform”), including athletes, coaches, and school administrators. This Privacy Policy explains what information we collect, how we use it, how we protect it, and what choices you have. By using the Platform, you agree to the practices described in this Privacy Policy.

This Privacy Policy applies to the Platform operated at TrainWilco.com and all associated web and mobile applications.

1. Information We Collect

1.1 Information You Provide Directly

When you create an account and use the Platform, we collect information you provide, including:

Account information: full name, email address, date of birth, and password;
Athletic profile: sport, position, height, weight, and training history (including estimated 1-rep maxes and prior performance data);
Session data: workout logs, sets, reps, weights, notes, and coach feedback submitted through the Platform;
Optional health information: prior injuries, physical limitations, or medical conditions you choose to disclose to personalize your training programs; and
Video and image submissions: footage or still frames you upload for form review analysis.

1.2 Information Collected Automatically

When you use the Platform, we automatically collect certain technical and usage data, including:

Device type, operating system, and browser information;
IP address and general geographic location;
Pages visited, features used, and time spent on the Platform; and
Session identifiers and authentication tokens.

This information is used to operate and improve the Platform and does not identify you personally on its own.

1.3 Payment Information

Payment transactions are processed by Stripe, Inc., our third-party payment processor. Wilco does not collect, store, or have access to your full credit card number, bank account number, or other sensitive financial data. Stripe’s handling of your financial information is governed by Stripe’s Privacy Policy, available at stripe.com/privacy.

1.4 Analytics and Tracking Technologies

We may use analytics tools and similar technologies to collect information about how users interact with the Platform. This may include cookies, pixel tags, and similar tracking technologies that collect aggregate information about device usage and Platform interaction. You may disable certain cookies through your browser settings, though doing so may affect some Platform features. We do not respond to “Do Not Track” browser signals at this time, as no uniform industry standard has been established.

2. How We Use Your Information

We use the information we collect to provide, maintain, and improve the Platform. Specifically, we use your information to:

Generate personalized, AI-powered strength and conditioning training programs based on your athletic profile and history;
Power the AI coaching assistant and provide exercise recommendations and form feedback;
Track your progress over time and display performance data within your account;
Enable your coach or institution’s coaching staff to access your session data, progress reports, and AI coaching interactions through the coach dashboard;
Process subscription payments and manage your account;
Send essential service communications, including account confirmations, subscription updates, and policy changes;
Respond to your support inquiries and resolve disputes;
Analyze aggregate, de-identified usage patterns to improve Platform features and AI model performance; and
Improve and train our AI systems using de-identified, aggregated data derived from Platform usage. This data cannot reasonably be used to identify you individually.

We do not use your personal data for targeted advertising and do not sell your personal data to third parties under any circumstances.

3. How We Share Your Information

3.1 With Coaching Staff and Institutions

If you are an athlete enrolled under a school or coach account, your session data, progress reports, AI coaching interactions, and form review feedback are visible to the coaching staff authorized under that account. This sharing is a core function of the Platform and is necessary to deliver the Services.

3.2 With Third-Party Service Providers

We share your data with a limited set of vetted third-party service providers who help us operate the Platform. These providers are contractually prohibited from using your data for any purpose other than providing services to Wilco. Our current service providers include:

Anthropic PBC — AI processing and language model infrastructure. Athlete data submitted to AI coaching features is processed through Anthropic’s systems, governed by Anthropic’s Privacy Policy at anthropic.com/privacy.
Supabase — Secure cloud database and authentication infrastructure.
Vercel, Inc. — Platform hosting and content delivery.
Stripe, Inc. — Payment processing, governed by Stripe’s Privacy Policy at stripe.com/privacy.

We do not share your personal data with any other third parties without your explicit consent, except as required by law.

3.3 Legal Disclosures

We may disclose your information if required to do so by law, regulation, legal process, or governmental request, or if we believe in good faith that disclosure is necessary to: (a) comply with a legal obligation; (b) protect the safety of any person; or (c) protect the rights, property, or safety of Wilco Training LLC.

3.4 Business Transfers

In the event that Wilco Training LLC is acquired, merged, or undergoes a substantial asset transfer, your information may be transferred as part of that transaction. We will provide notice of any such change and applicable choices you may have in accordance with applicable law.

4. Data Retention

We retain your personal data for as long as your account is active and for a period of 30 days following account cancellation or deletion. During this 30-day window, you may reactivate your account and recover your data. After 30 days, all personal data associated with your account is permanently and irreversibly deleted from our systems.

Aggregate, de-identified data that cannot reasonably be used to identify you may be retained indefinitely for the purpose of improving the Platform.

Wilco retains certain records as required by applicable law, including financial transaction records, which may be retained beyond the 30-day period in accordance with legal requirements.

5. Your Rights and Choices

You have the following rights with respect to your personal data:

Access: You may request a copy of the personal data we hold about you.
Correction: You may request that we correct inaccurate or incomplete personal data in your account.
Deletion: You may request deletion of your account and associated personal data by contacting us or using the account deletion option in your account settings. Deletion requests are processed within 30 days, subject to applicable legal retention obligations.
Opt-Out of Communications: You may opt out of non-essential marketing communications at any time via the unsubscribe link in any marketing email or by contacting us directly. Essential service communications — including billing notices, subscription changes, and Terms updates — cannot be opted out of while your account remains active.

To exercise any of these rights, contact us at support@trainwilco.com. We will respond within 30 days of receipt. We may request verification of your identity before fulfilling any request.

6. Children’s Privacy

The Platform is intended for users who are at least 13 years of age. Wilco does not knowingly collect personal data from children under 13. If you are a parent or guardian and believe your child under the age of 13 has created an account without your consent, contact us immediately at support@trainwilco.com and we will promptly delete the account and all associated data.

For users between the ages of 13 and 17, the Platform’s sign-up flow uses date of birth verification to identify minor users. When a user’s date of birth indicates an age between 13 and 17, the sign-up screen displays a separate, clearly labeled parental consent acknowledgment checkbox that must be affirmatively checked before account creation is permitted. By checking that box, the parent or legal guardian confirms that they have reviewed this Privacy Policy and the Terms of Service and consent to the data practices described herein on behalf of the minor user.

We encourage parents and guardians of minor users to review this Privacy Policy periodically and to monitor their child’s use of the Platform.

7. Video and Image Data

When you submit video footage or images for form review, the Platform extracts still frames from your submission for automated AI analysis. Wilco does not manually review your video footage; analysis is performed automatically. Still frames are used only during the processing period to generate your form feedback and are not retained or used for any other purpose.

Wilco does not collect, store, or derive biometric identifiers or biometric information — including facial geometry, voiceprints, or similar identifiers — from video or image submissions. Still frames are used solely for motion and athletic form analysis within the context of the Services.

Wilco does not share, sell, or publicly display any user video or image content. Video submissions of minor users are subject to the same protections as all other personal data described in this Policy.

8. Data Security

Wilco implements industry-standard technical and organizational security measures designed to protect your personal data against unauthorized access, loss, alteration, or destruction. These measures include encrypted data transmission, access controls, and secure cloud infrastructure maintained by our service providers.

No security system is impenetrable. In the event of a data breach involving your personal data, Wilco will notify affected users in accordance with applicable law, including within 30 days of determining that a breach has occurred as required under the Florida Information Protection Act (Fla. Stat. § 501.171).

You are responsible for maintaining the confidentiality of your account credentials. Use a strong, unique password and notify us immediately at support@trainwilco.com if you suspect unauthorized access to your account.

9. Third-Party Links

The Platform may contain links to third-party websites or services. This Privacy Policy does not apply to those third-party sites. Wilco is not responsible for the privacy practices or content of third-party websites. We encourage you to review the privacy policies of any third-party services you access through the Platform.

10. Changes to This Privacy Policy

Wilco reserves the right to update this Privacy Policy at any time. We will notify you of material changes by posting the updated Policy on the Platform and by sending a notice to your registered email address at least 14 days before the changes take effect. Your continued use of the Platform after the effective date of any updated Policy constitutes your acceptance of the changes.

The “Last Updated” date at the top of this Policy reflects when the most recent version was published. We encourage you to review this Policy periodically.

11. Contact Us

If you have questions, concerns, or requests related to this Privacy Policy or our data practices, please contact us:

Wilco Training LLC 801 International Pkwy, Suite #5034 Lake Mary, Florida 32746 TrainWilco.com | support@trainwilco.com

We will respond to all privacy-related inquiries within 30 days of receipt.

12. Additional Rights for Users in the European Economic Area and United Kingdom

If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”), the General Data Protection Regulation (“GDPR”) and, where applicable, the UK GDPR provide you with additional rights and impose additional obligations on Wilco regarding the processing of your personal data.

12.1 Legal Basis for Processing

We process your personal data on the following legal bases:

Contract Performance (Article 6(1)(b)): Processing necessary to deliver the Services you subscribed to, including generating training programs, processing payments, and maintaining your account.
Legitimate Interests (Article 6(1)(f)): Processing for our legitimate interests in operating and improving the Platform, preventing fraud, and ensuring security, where those interests are not overridden by your fundamental rights.
Legal Obligation (Article 6(1)(c)): Processing required to comply with applicable law, including financial record retention and responding to lawful governmental requests.
Consent (Article 6(1)(a)): Where we rely on consent — including for optional health information and for AI improvement uses — you may withdraw consent at any time without affecting the lawfulness of prior processing.

For special category data (health information you voluntarily provide), we rely on your explicit consent under Article 9(2)(a) GDPR.

12.2 Additional Data Subject Rights

In addition to the rights in Section 5, EEA and UK users have the right to:

Data Portability: Receive a copy of your personal data in a structured, machine-readable format for transfer to another controller, where processing is based on consent or contract performance.
Restrict Processing: Request that we restrict processing of your personal data in certain circumstances, such as while a correction request is pending.
Object: Object to processing based on our legitimate interests at any time. We will cease processing unless we demonstrate compelling legitimate grounds that override your interests.
Lodge a Complaint: Lodge a complaint with your local supervisory authority. In the EU, contact the supervisory authority in your country of residence. In the UK, contact the Information Commissioner’s Office (ICO) at ico.org.uk.

To exercise these rights, contact us at support@trainwilco.com. We will respond within one calendar month as required by GDPR.

12.3 International Data Transfers

The Platform is operated from the United States. If you are located in the EEA or UK, your personal data will be transferred to and processed in the United States. Where required by GDPR or UK GDPR, we rely on Standard Contractual Clauses approved by the European Commission (or the applicable UK equivalent) as the legal mechanism for such transfers. For more information, contact us at support@trainwilco.com.

12.4 Retention for EEA and UK Users

In addition to the retention periods in Section 4, EEA and UK users’ personal data is retained only as long as necessary for the purposes for which it was collected, consistent with the legal bases in Section 12.1. We review retention periods periodically.

13. Additional Rights for California Residents

If you are a California resident, the California Consumer Privacy Act (“CCPA”) as amended by the California Privacy Rights Act (“CPRA”) grants you the following additional rights.

13.1 Categories of Personal Information Collected

In the preceding 12 months, we have collected the following categories of personal information as defined under the CCPA:

Identifiers: name, email address, IP address, account credentials, and device identifiers;
Personal information under Cal. Civil Code § 1798.80: name and general location;
Internet or electronic network activity: pages visited, features used, session data, and interaction logs;
Geolocation data: general geographic location derived from IP address;
Inferences: training program recommendations derived from your athletic profile; and
Sensitive personal information: health information you voluntarily provide (injuries, medical conditions); and financial data processed by Stripe, Inc. on our behalf.

13.2 No Sale or Sharing

Wilco does not sell your personal information. Wilco does not share your personal information with third parties for cross-context behavioral advertising. You have the right to opt out of any such sale or sharing; to exercise this right, contact us at support@trainwilco.com (though no sale or sharing currently occurs).

13.3 Your CCPA/CPRA Rights

In addition to the rights in Section 5, California residents have the right to:

Know the categories and specific pieces of personal information collected, the sources, the business purpose, and the third parties with whom it is shared;
Delete personal information we hold about you, subject to certain legal exceptions;
Correct inaccurate personal information;
Opt out of sale or sharing (not currently applicable);
Limit use of sensitive personal information to what is necessary to provide the Services; and
Non-Discrimination: We will not deny Services, charge different prices, or provide a different quality of service because you exercised any CCPA/CPRA right.

Contact us at support@trainwilco.com to exercise your rights. We will verify your identity and respond within 45 days, extendable by 45 additional days with notice.

13.4 Authorized Agent

You may designate an authorized agent to submit requests on your behalf by providing written signed authorization. We may verify your identity directly before honoring such requests.

14. International Users and Export Controls

The Platform is operated from the United States and is subject to U.S. export control laws. By using the Platform, you represent that you are not located in, under the control of, or a national or resident of any country subject to U.S. trade sanctions or export restrictions, including Cuba, Iran, North Korea, Russia, Syria, or the Crimea region of Ukraine. Users in sanctioned territories are not authorized to use the Platform.

Wilco Training LLC | TrainWilco.com | support@trainwilco.com 801 International Pkwy, Suite #5034, Lake Mary, Florida 32746