Privacy Policy

This Privacy Policy explains how Who's In Labs, LLC, an Illinois limited liability company ("Who's In Labs," "we," "us," or "our"), collects, uses, shares, and protects information when you use the Whosly™ app and whosly.app (collectively, the "Service"). By using the Service, you agree to this Policy. If you do not agree, do not use the Service.

1. Information We Collect

We collect the following categories of information, directly from you, automatically through your use of the Service, and from third parties such as our service providers and partners:

• Account & profile information — your name, an identifier from Sign in with Apple, an optional phone number, and an optional profile photo, so friends' invitations can find you and so people on a plan can recognize you. Your phone number is kept privately with your account so you don't have to enter it again when you log in on another device — only you can access that copy (see "Phone Numbers" below).
• Plans & activity — the plans you create or join, invitations, RSVPs, comments, votes, saved places, notes, lists, ticket notes, groups and shared circles (including circle chat messages and any "who's around" status you post), photos you send in a chat (deleted from our servers 7 days after they're sent), templates, cost splits (what each person owes, and a payment username a host adds, such as a Venmo handle), settings, and — only if you opt in — your arrival at an event.
• Reports — when you report a place, a person, or a message, what you reported, the details you gave, and when. We use reports to review and act on them.
• Web RSVPs — if you respond to a plan from a web invite link without the app, the first name, last name, and phone number you enter, plus any comment you leave (which posts to the plan's chat). We use them to record and display your response, to let you update it later from any device, and to let the plan's host and co-planners see who is coming and reach you about the plan. Other guests never see your number.
• Website waitlist — if you join our launch waitlist on whosly.app, the email address you submit. We use it only to notify you when the app launches; it is not linked to any app account, and deleting an app account does not remove it. To have it removed, email admin@whos-in-labs.com.
• Contacts — if you invite people from your address book, we access contacts on your device so you can pick them; the contacts you add are stored privately with your account so they follow you to your other devices — only you can access them, and they are never shared with other users. When you invite a contact to a plan, their number is kept with the plan so you can text them about it — only you can see it, not the plan's other guests or co-planners. We do not bulk-upload your address book. For contact matching, our directory stores your name, identifier, optional photo, and a one-way hash of your phone number — never your raw number.
• Location information — if you allow it, we use your device location (which may include precise location, treated as "sensitive") to suggest nearby places, recommend a local City Pack, support maps and directions, and tailor suggestions to your area — generally only while the app is open — and, only if you turn on arrival sharing for a specific plan, to detect when you reach that plan's venue and let your group know. Arrival detection may use your location in the background until the plan ends or you turn sharing off; it watches only that plan's venue, and your exact location is never stored. When location is granted, we also derive and store your general location — your city, state, and country only, never your coordinates — to tailor recommendations to your area, decide which city packs to build, and (with the notifications below on) work out which City Packs are near you — our own first-party use; we do not use it to track you or share it with advertisers or data brokers. If you haven't shared your location and keep "Personalized recommendations" on, we may instead store the approximate city, state, and country your IP address points to, and use it the same way. Separately, if you keep the "New packs in your cities" notifications on in the app's Settings, we work out which cities are relevant to you and let you know when we add a City Pack there, or add new places to a pack you already have. A city is relevant to you if you've saved places in it or in a town near it, made plans there, or, when location is granted, your general location is near it. We work that out from the cities you have saved places in — city names only, derived on your device from your saved places, never coordinates, and stored only while these notifications are on — from the general location of your plan activity, such as the cities of plans you create, host, join, RSVP to, or are invited to, and from the general location described above. That information is already part of the records we hold: we read it for this purpose rather than collecting anything new, we use it only to decide which cities' packs are worth telling you about, and we do not sell it or share it with advertisers or data brokers. Turning these notifications off in Settings stops all of this and deletes the stored city list. If you turn off "Personalized recommendations" in the app's Settings, we stop collecting your general location — including the approximate one from your IP address — and delete the general location we've stored. You can revoke location access at any time in iOS Settings. We may also infer approximate location from your IP address.
• Purchase information — records of in-app purchases and subscriptions (processed by Apple; we do not receive your full payment card details).
• AI feature inputs — text and context you submit to AI-assisted lookup or place import are sent to our proxy and AI provider to generate a response.
• Device, usage & identifiers — IP address, device and app information (including your device's time zone and language setting), identifiers (including the notification token that lets us deliver pushes to your device), diagnostics (including crash and performance reports from your device, which do not identify you), log data, approximate location, cookies and similar local-storage technologies (on the website), and information about how you interact with the Service — for example, when you created your account and last opened the app, which first-time setup steps you completed or skipped, which features you use, and which notifications we sent you and whether you opened them. We use your time zone and language to send notifications at a sensible local hour and in your language; your time zone can also indicate the general region you are in.
• Inferences — characteristics, interests, and preferences we derive from the above to personalize content and recommendations (such as which places and city packs to suggest).

2. How We Use Information

We use information for the following purposes:

• Provide, operate, maintain, secure, and support the Service — create and show plans, deliver invitations and RSVPs, match invitations to the right people, power places and AI features, and send notifications you've enabled.
• Personalize your experience and improve, develop, and analyze the Service and build new features and products.
• Recommend content, places, venues, events, and businesses to you — and decide which city packs and features to build.
• First-party analytics — to understand how the Service is used and improve it, using aggregated data where we can and, where that is not enough, our team's review of individual accounts' records (see section 3). We do not use your information for third-party or cross-app targeted advertising.
• Conduct research and analytics, including aggregated and de-identified analysis.
• Protect the Service and our users, detect and prevent fraud and abuse, enforce our Terms, and comply with law.
• Communicate with you about the Service, and with your consent where required.

3. Recommendations & Analytics — We Don't Track You

We use your information only for our own first-party purposes — such as tailoring recommendations, deciding which city packs and features to build, and understanding how Whosly is used so we can improve it. We do not track you: we do not link your information with data from other companies' apps or websites for advertising, we do not share your information with data brokers, and we do not sell it or share it for "targeted advertising" or "cross-context behavioral advertising." Our analytics are first-party. Much of it is aggregated — daily counts, such as how many people finished setup or opened a notification — but our team may also review the information we hold about individual accounts to understand how people find and use Whosly, see where the app falls short, improve it, decide what to build, check that our notifications are useful rather than a nuisance, and support you. That can mean looking at records we already hold together — for example, when an account was created, which setup steps it completed, whether it has added friends, places, or plans, the general area it is in, whether it answered a plan's web invite before joining, and whether it opened the notifications we sent. This review stays within Who's In Labs and the service providers that host or process our data on our behalf — including AI tools we use to help analyze it; we do not sell it, share it with advertisers or data brokers, or combine it with information from other companies. If we ever introduce third-party advertising or tracking, we will update this Policy first and provide the choices the law requires (including, on iOS, an App Tracking Transparency prompt). The only third-party components in the app, Meta's and TikTok's install-measurement SDKs, are not tracking and involve no such prompt — section 3a explains exactly what they do and do not do.

3a. Advertising the App — Install Measurement

We advertise Whosly on Meta's platforms (Facebook and Instagram). So that we can tell which ads actually lead to installs, the app includes Meta's software development kit (SDK), configured for measurement only. Concretely:

• What Meta receives — that an install or app session happened, with basic device and app information. It does not receive your plans, places, messages, contacts, location, purchases, or anything you type. We have turned off the SDK's automatic event logging, so it cannot report anything beyond installs and sessions even if Meta's own settings would otherwise allow it.
• No advertising identifier. The app never reads your device's advertising ID (IDFA). Because we do not show an App Tracking Transparency prompt, iOS withholds that identifier from the SDK entirely — the app is built without the permission string needed to ask for it.
• Measurement runs through Apple. Install attribution uses Apple's SKAdNetwork, which reports results to Meta in aggregate and on a delay, with no identifier for you attached. Apple, not us and not Meta, decides whether and when any report is delivered; the one thing we contribute to it is the setup milestone described next.
• A single setup milestone rides that report. The app gives Apple one number from 1 to 5 summarizing how far first-time setup got — opened the app, created an account, created a first plan, sent a first invite, or received a first RSVP. Apple may include that number in its aggregate, delayed report. It carries no identity, no content, and no detail beyond the single number, it only ever moves forward (we never lower it or encode anything else in it), and it tells us "ads are producing accounts and plans," never who did what.
• Meta may only use it for us. We enable a Meta setting called Limited Data Use, which instructs Meta to process this information solely on our behalf — not for its own advertising models, not to build audiences, not for any other Meta purpose — for everyone protected by a state privacy law that requires it. We ask Meta to determine that from location rather than naming states ourselves, so the protection follows the law as it changes.

This is measurement, not targeting: it tells us "this ad produced installs," never "this person installed." We do not use it to build a profile of you, to retarget you, or to personalize ads to you, and it does not link your activity in Whosly to your activity in other companies' apps or websites. If we ever change that — by adding a tracking prompt, reading the advertising identifier, or sending Meta your in-app activity — we will update this Policy first and ask for the permissions the law and Apple require.

We also advertise Whosly on TikTok, and the app includes TikTok's SDK on the same terms:

• What TikTok receives — that the app was installed and opened, with basic device and app information: the device's model, operating system, language, and IP address, an identifier Apple gives each developer's apps on your device (it is not the advertising identifier and cannot link you across other companies' apps), and a random identifier the SDK creates. It does not receive your plans, places, messages, contacts, location, purchases, or anything you type. We have turned off the SDK's automatic event tracking and the app sends only those two events itself, so the SDK cannot report purchases, screen views, taps, or images of your screen even if TikTok's own settings would otherwise allow it.
• Same limits as Meta. The app never reads your advertising identifier; install attribution runs through Apple's SKAdNetwork, carrying only the single setup number described above; and we mark these events with TikTok's Limited Data Use setting so that, where a state privacy law requires it, TikTok processes them solely on our behalf.
• Crashes in TikTok's code. TikTok's SDK may report a crash that happens inside TikTok's own code, so TikTok can fix its software.

The same promise applies: if we ever change any of this, we will update this Policy first.

4. How We Share Information

• With your friends on Whosly — while "Share my places with friends" is on in the app's Settings (it is on by default), a copy of your saved places — place names, addresses, categories and map details only; never your notes, visit history or stars, and City Pack places only to friends who also subscribe to Planner Pro — is visible to your friends: people you have added who added you back, or who share a circle with you. Places you mark "Keep private", and places whose names read like a home or workplace, are never included, and a shared list you own can be hidden from friends the same way. Turning the switch off deletes that copy immediately. A username you choose is a public label: anyone who types it exactly can see your name and photo and send you a friend request; you can remove it at any time. Your friends can also see who your friends are: opening your profile shows them the people you are friends with — name, username and photo — and lets them send those people a friend request. Someone whose friend request you have not accepted sees only the people you and they already both know, never the rest of your list. Removing or blocking someone takes the two of you off each other’s lists.
• With people on your plans — your name, photo, RSVP status, comments, votes, and (if enabled) arrival are visible to others on the same plan, including people who RSVP through a web link. If you join a shared circle, its name and member list, the messages you post in its chat, and any "who's around" status you set are visible to that circle's members.
• Service providers — Apple (sign-in, notifications, payments), Cloudflare (hosting and database), Anthropic (AI features, and AI tools we use to analyze our own records), and Apple Maps (places and directions) — which process information on our behalf.
• Meta, for install measurement only — that an install or app session happened, plus basic device and app information, so we can tell which of our ads worked. No advertising identifier, no plans, places, messages, contacts, location, or purchases. Where a state privacy law requires it, we instruct Meta through its Limited Data Use setting to act only as our service provider and not to use any of it for Meta's own purposes. See "Advertising the App" above.
• TikTok, for install measurement only — on the same terms: that the app was installed or opened, plus basic device and app information. No advertising identifier, no plans, places, messages, contacts, location, or purchases. Where a state privacy law requires it, we instruct TikTok through its Limited Data Use setting to act only as our service provider. See "Advertising the App" above.
• Legal, safety & rights — when we believe it is required by law, legal process, or to protect the rights, safety, or property of users, the public, or Who's In Labs, LLC.
• Business transfers — in connection with a merger, acquisition, financing, reorganization, or sale of assets, information may be transferred to the successor.
• With your direction or consent — when you ask us to share, or otherwise with your consent.

We do not sell your personal information, and we do not share it with advertisers or data brokers or for targeted/cross-context behavioral advertising. Our product analytics are first-party; the only third-party measurement is the install measurement described in section 3a.

5. Phone Numbers

Your phone number is used to match invitations to your account. We keep it privately with your account, so you don't have to enter it again when you log in on another device — only you can access that copy. In our directory, numbers are matched using a one-way hash rather than stored in the clear. We never give your number to other users: not to the other people on a plan, and not to its host or co-planners. A host can text only people in their own contacts. The one exception is a number you type into a plan's web invite page when you answer without the app: it is shared with that plan's host and co-planners so they can reach you about the plan, and with no one else.

6. AI Features

When you use AI-assisted lookup or place import, the text and context you enter are sent to our AI provider (Anthropic) to generate results. Please do not enter sensitive information you do not want processed by those services.

7. Cookies & Tracking Choices

On the website we use only essential cookies (for example, to remember team access to a pre-launch preview of the site) — no third-party advertising cookies. Our analytics are cookieless and first-party. You can control cookies through your browser and manage tracking permissions in your device settings. Because we do not sell or share personal information or use it for cross-context behavioral advertising, a Global Privacy Control (GPC) signal has no sale or share to act on.

8. Data Retention & Deletion

We keep information while your account is active or as needed to provide the Service, comply with law, resolve disputes, and enforce our agreements. You can delete plans you host, and you can delete your account in Settings → Account → Delete account, which removes your profile, directory listing, and associated data from our active systems. Photos sent in a plan's or a circle's chat are deleted from our servers 7 days after they're sent — sooner if the message, the plan or circle, or your account is deleted — so save any you want to keep. Some information may remain on other participants' devices or in records they created (such as their RSVPs or comments), and we may retain de-identified or aggregated data. Reports you filed about places or other users are kept without your identity, so they can still be acted on. We may also create aggregated or de-identified information that does not reasonably identify you and use it for our own purposes; we do not attempt to re-identify it. To keep one-time promotional credits one-time, we also retain a minimal, anonymized fraud-prevention record of any free AI credits you have already used — a one-way hash derived from your Sign in with Apple identifier (never the identifier itself) plus the usage counts, nothing else — so deleting and recreating an account does not reset them. We also keep a record of each time you accept our Terms of Service and Privacy Policy in the App — which versions you accepted, a fingerprint of the exact text you were shown, and when — including after you delete your account, as the record of what you agreed to. It holds your Sign in with Apple identifier and those details, nothing else. To request deletion or a copy of your data, email admin@whos-in-labs.com.

9. Security

We use reasonable technical and organizational measures to protect information, including encryption in transit and storing your account identifier in your device's Keychain. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

10. Children

The Service is not directed to children under 16, and we do not knowingly collect personal information from anyone under 16. If you are a parent or guardian and believe someone under 16 has provided us personal information, contact us at admin@whos-in-labs.com and we will delete it.

11. Your Choices & Rights

You can control contacts, location, photos, calendar, and notification permissions in your device settings, manage notification preferences in the app, turn off arrival sharing per plan, turn off "Personalized recommendations" in the app's Settings → Privacy (which stops general-location collection and deletes what we've stored), and remove your profile photo. Depending on where you live, you may also have the rights described below.

12. Your U.S. State Privacy Rights

Residents of California, Virginia, Colorado, Connecticut, Utah, Texas, and other states with comprehensive privacy laws may have some or all of the following rights, subject to that law's limits and exceptions:

• Know/Access — the categories and specific pieces of personal information we collect, use, and disclose.
• Delete — request deletion of your personal information.
• Correct — request correction of inaccurate personal information.
• Portability — obtain a copy in a portable format.
• Opt out — of the "sale" or "sharing" of personal information, of targeted/cross-context behavioral advertising, and of certain profiling. We do not do these, so there is currently nothing to opt out of.
• Limit sensitive information — limit our use of sensitive personal information (such as precise geolocation) where applicable.
• Non-discrimination — we will not discriminate against you for exercising these rights.

To exercise any of these rights, email admin@whos-in-labs.com (because we do not sell or share personal information or use it for targeted advertising, a GPC signal has nothing to opt out of). We will verify your request as required by law, and you may use an authorized agent. If we deny your request, you may appeal by replying to our response; where applicable you may also contact your state attorney general. California's "Shine the Light" law: you may request information about disclosures to third parties for their direct marketing.

13. Illinois & Biometric Information

We are based in Illinois, United States, and your information is processed in the United States. The Service is not offered to, or directed at, people located in the European Economic Area, the United Kingdom, or Switzerland. We do not collect, capture, use, store, or sell biometric identifiers or biometric information as defined by the Illinois Biometric Information Privacy Act (BIPA). Profile photos are used only to display your avatar and are not used for facial recognition or biometric identification.

14. Changes

We may update this Policy from time to time. We will revise the "Last updated" date above and, for material changes, tell you in the app and may ask you to review and accept the updated Policy. Changes apply going forward.

15. Contact

Questions about your privacy, or to exercise your rights? Contact Who's In Labs, LLC at admin@whos-in-labs.com.